ML060130281

Inservice Test (IST) Program Update and Associated Relief Requests for Third Ten-Year Interval

ML060130281
Person / Time
Site:	Sequoyah
Issue date:	01/10/2006
From:	Pace P Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML060130281 (178)

Text

Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 10 CFR 50.55a January 10, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - INSERVICE TEST (IST) PROGRAM UPDATE AND ASSOCIATED RELIEF REQUESTS FOR THIRD TEN-YEAR INTERVAL

References:

1. NRC letter to TVA dated October 5, 2000, "Relief from ASME Code Requirements for Pump and Valve Inservice Testing Requirements at Sequoyah Nuclear Plant, Units 1 and 2 (TAC Nos. MA7966 and MA7967)"

2. NRC letter to TVA dated August 7, 1998, "Safety Evaluation of Relief requests for the Pump and Valve Inservice Testing Program - Sequoyah Nuclear Plant Units 1 and 2 (TAC Numbers MA0417, MA0418, MA1595, and MA 1596)"

3. NRC letter to TVA dated March 20, 1996, "Inservice Testing Program Relief Requests, Second Ten-Year Interval Sequoyah Nuclear Plant Units 1 and 2 (TAC Nos. M94117 and M94118)"

The purpose of this letter is to provide for your review SQN's updated IST programs and the associated requests for relief for SQN's third 10-year IST interval. Requests for relief, included with these programs, are being submitted for staff review and approval in accordance with 10 CFR 50.55a.

AoWJ Pfnted on nIcyed paper

U.S. Nuclear Regulatory Commission Page 2 January 10, 2006 The IST programs are provided in two enclosures (pump test program - Enclosure 1 and the valve test program - ). The pump test program contains a total of six requests for relief (RP-1 through RP-6) and the valve test program contains three relief requests (RV-1 through RV-3). The updated IST programs have been developed to the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants.

By References 1, 2, and 3, NRC issued Safety Evaluation Reports for SQN's second 10-year interval IST programs. A portion of the relief requests provided for SQN's third 10-year interval programs are a continuation of those previously approved for SQN's second interval.

SQN's third 10-year IST interval begins June 1, 2006. TVA requests NRC review and approval of the enclosed relief requests to support the June 1, 2006 start date.

In conjunction with the enclosed relief requests, TVA submitted a related TS Change 05-11 by letter dated December 19, 2005.

Please direct questions concerning this issue to me at (423) 843-7170 or J. D. Smith at (423) 843-6672.

Sincerel P. L. Pace Manager, Site Licensing and Industry Affairs Enclosures cc (Enclosures):

Mr. Douglas V. Pickett, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 Pump Test Program With Relief Requests (RP-1 thru RP-6)

Third 10-Year Interval

Sequoyah Nuclear Plant UnitO, 1,&2 Technical Instruction O-TI-SXI-000-200.P ASME IST PUMP TESTING Revision 0000 Quality Related Level of Use: Reference Use Effective Date:

Responsible Organization: SCE, System Eng - Component Prepared By: LARRY ALEXANDER Approved By: Gay Haliburton Current Revision Description NEW PROCEDURE.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 2 of 40 Table of Contents

1.0 INTRODUCTION

............................ 3 1.1 Purpose ............................ 3 1.2 Scope ............................ 3

2.0 REFERENCES

............................ 4 3.0 PERFORMANCE ............................ 6 3.1 Definitions ............................ 6 3.2 General Program Requirements ............................ 8 3.3 Pump Testing Frequency ............................ 9 3.4 Reference Values ........................... 10 3.5 Test Parameters ........................... 11 3.6 Allowable Ranges for Test Parameters ........................... 12 3.7 Pump Testing .................... . 14 3.8 Relief Requests .................... 15 3.9 Data Analysis and Evaluation .................... 15 3.10 Augmented Pump Testing .16 4.0 RECORDS ................... 16 4.1 Pump Records ................... 16 4.2 Inservice Test Plans ................... 17 4.3 Record of Tests .................... 17 4.4 Record of Corrective Action ................... 18 Appendix A: REQUEST FOR RELIEF............................................................... 19 Appendix B: ASME IST PUMP TEST PROGRAM .. ........................ 36

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 3 of 40

1.0 INTRODUCTION

1.1 Purpose The purpose of this document is to provide technical requirements to assure compliance with the requirements of IOCFR50.55a and Sequoyah Nuclear Plants (SQN) Technical Specifications (TS) which require that ASME inservice testing of pumps be met throughout the service life of the nuclear power plant and be updated at each 10 year interval. Interval extensions of as much as one year are allowed as long as successive intervals are not altered by more than one year from the original pattern of interval. The purpose of the inservice test program (IST)is to ensure operational readiness of ASME Code Class 1,2 and 3 plant components which are required for a specific function in (1) shutting down the reactor to a safe shutdown condition (hot shutdown for SQN), (2) maintaining the safe shutdown condition, or (3) mitigating the consequences of an accident. Inservice tests are designed to detect component degradation by assessing component performance in relation to operating characteristics when the component was known to be operating acceptably. At no time will ASME requirements supersede SQN Technical Specification requirements. The rules for the in-service pump testing for Nuclear Power Plant Components for the Third Ten Year Interval, are contained in the ASME OM Code 2001 Edition, through the 2003 Addenda, approved Code cases, and approved relief requests. The milestone dates for SQN are:

Commercial Operation Unitl: 7/1981 Commercial Operation Unit2: 6/1982 Second 10 year interval start: 12/15/1995 Third 10 year interval start: 6/1/2006 1.2 Scope The scope of this instruction applies to pumps determined to be ASME Code Class 1,2, and 3 plant components which are required for a specific function in (1)shutting down the reactor to a safe shutdown condition (hot stand by for SQN.), (2) maintaining the safe shutdown condition, or (3)mitigating the consequences of an accident and receive power from an emergency power service. The scope of this instruction applies to the applicable pumps within the ASME Section XI boundaries as defined by the SQN ASME Section Xl Color Coded Boundary Drawings. All pumps which have been determined to meet ASME & Technical Specification requirements for inclusion in the test program are identified in Appendix A. General program requirements are included within this instruction with specific requirements listed in the individual implementing instructions.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 4 of 40 1.2 Scope (continued)

The following are excluded from the requirements of this procedure

1. Fans and compressors are exempt from the ASME Code testing requirements.

2. Drivers are exempt from Code testing requirements except where the pump and driver form an integral unit and the pump bearings are located in the driver (RHR pumps at Sequoyah) and vertical line shaft pumps. The ASME OM Code does not define "integral unit". Vibration measurements on pump drivers, if not integral to the pump, are not currently considered to be within the scope of the ASME OM Code.

3. Pumps which do not perform a function within the scope of the ASME Code but are supplied with emergency power solely for operating convenience are exempt from ASME Code testing requirements.

4. Skid-mounted pumps that are tested as part of the major component and are determined by the Owner to be adequately tested are exempt from the requirements of ISTB.

Components outside the scope of the 10CFR50.55a program will be tested at a level commensurate with their intended function to demonstrate that they will perform satisfactorily when in service as required by 10CFR50 Appendix A, Appendix B, GDC-1, and NUREG 1482 R1. These components will be tested as specified in the SQN Augmented Test Program.

2.0 REFERENCES

A. 10CFR50.55a.

B. NRC Documents:

1. Inspection Manual, Temporary Instruction 2515/114, Inspection Requirements for Generic Letter 89-04, Acceptable Inservice Testing Programs.

2. NRC Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs. April 3, 1989.

3. NRC letter on the "Minutes of the Public Meetings on Generic Letter 89-04 Oct 25, 1989.

4. NRC NUREG 1482 Rev 1, Guidelines for Inservice Testing at Nuclear Power Plants, January, 2005.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 5 of 40

2.0 REFERENCES

(continued)

5. Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756 "Inservice Testing of Pumps and Valves" and Answers to Panel Questions on IST Issues, July 18,1997.

6. NRC Information Notice 97-16: Preconditioning of Plant Structures, Systems, and Components Before ASME Code Inservice Testing OR Technical Specification Surveillance Testing.

7. Generic Letter 91-18 Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and nonconforming Conditions and on Operability.

8. Regulatory Guide 1.192 Operation and Maintenance Code Cases Acceptability, ASME OM Code.

9. Regulatory Guide 1.193 ASME Code Cases not Acceptable for Use.

10. Regulatory Guide 1.147 Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1.

11. NEI White Paper, Entitled Standard Format for Relief Requests from Commercial Reactor Licensees Pursuant to 10CFR50.55a".

C. CODES and STANDARDS:

1. ASME OM Code, Inservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants, OM-2001 Edition to the OMb-2003 Addenda.

2. ANSI/ASME N45.2.6-1978, Qualification of Inspection Examination and Testing Personnel for Nuclear Power Plants.

D. SPP-9.1, ASME Section XI.

E. TVA Calculation SQN-SQTP-002, ASME Section Xl Pump and Augmented Pump Identification for Inservice Testing.

F. TVA Calculation SQN-SQTP-001, ASME Section XI Inservice Code Class Boundaries for Inservice Testing.

G. 0-SI-SXV-000-266.0, Summary of Pump And Valve Tests For ASME OM Code.

H. 0-TI-SXX-000-005.0, Augmented Pump and Valve Test Program.

I. Sequoyah Nuclear Plant Technical Specifications.

J. Sequoyah Nuclear Plant Design Criteria and Design Guides:

1. SQ-DC-V-3.0 Classification of Piping, Pumps, Valves and Vessels.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0,1, & 2 Rev. 0000

, Page 6 of 40

2.0 REFERENCES

(continued)

2. SQ-DC-V-2.16 Single Failure Criteria.

3. SQ-DC-V-3.2 Classification of HVAC Systems.

K. TVA submittals to the NRC:

1. Second Ten Year Program Update submitted 11/21/95 RIMS S64951121800.

2. RAI response submitted 5/9/96 RIMS S64960509800.

3. RAI response submitted 3/4/97 RIMS S64970305800.

4. RAI response submitted 8/28/97 RIMS S64970829801.

L. SQN UFSAR Section 3.2 and 6.8.

M. NEI White Paper, Entitled "Standard Format for Relief Requests from Commercial Reactor Licensees Pursuant to 10CFR50.55a".

N. SQN ASME Section XI Color Coded Boundary Drawings.

0. ASME Section XI Programs for the Second Inspection Interval, Unitsl & 2, RIMS S64 951121 800.

P. Revised Inservice Test (IST) Program, Second Ten-Year Interval, RIMS S649712228000.

Q. NRC documents to TVA:

Safety Evaluation Report on Sequoyah Inservice Test Programs for Pumps and Valves (IST) dated March 20, 1996 (TAC NOS. M94117 and M94118).

3.0 PERFORMANCE 3.1 Definitions OPERABLE - OPERABILITY: - A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and all necessary attendant instrumentation, controls, a normal and emergency electrical power source, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 7 of 40 3.1 Definitions (continued)

ASME PUMP TEST PROGRAM: - The pump test program required by I OCFR50.55a(f) provides the testing requirements of ASME Code Class 1,2, and 3 pumps by using the ASME OM Code. Those pumps with an emergency power supply that are required in shutting down the reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident are to be tested per ISTB of the OM Code.

AUGMENTED PUMP TEST PROGRAM: - The pumps that are outside the scope of ASME OM Code (and therefore outside the scope of IOCFR50.55a) will be tested at a level commensurate with their intended function. The intent of 10CFR50 Appendix A, GDC-1, and Appendix B, Criterion Xl is that all components, such as pumps, necessary for safe operation are to be tested to demonstrate that they will perform satisfactorily in service. Therefore, while 10CFR50.55a provides the testing requirements for ASME Code Class 1,2, and 3 pymps, the testing of pumps is not to be limited to only those covered by 10CFR50.55a (refer to item II of Generic Letter 89-04).

Comprehensive Pump Test: - An Inservice Test performed on both Group A and Group B pumps at least once every 2 years at +/- 20% of design flow conditions.

This test measures hydraulic and vibration parameters with hydraulic parameter acceptance criteria more stringent than that imposed by the Group A and Group B Tests. In addition, accuracy of pressure instrument used for measuring pump differential pressure is more stringent.

Group A Pumps: - Pumps that are operated continuously or routinely during normal operation, cold shutdowns, or refueling operations.

Group A Pump Test: - A quarterly Inservice Test performed on pumps that are operated continuously or routinely during normal operation, cold shutdowns, or refueling operations. This test measures hydraulic and vibration parameters with hydraulic parameter acceptance criteria less stringent than that imposed by the Comprehensive Test.

Group B Pumps: - Pumps in standby systems that are not operated routinely except for testing.

Group B Pump Test: - A quarterly Inservice Test performed on pumps in standby systems that are not operated routinely except for testing. This test measures hydraulic parameters only with acceptance criteria less stringent than that imposed by the Comprehensive Test.

- SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000

' Page 8 of 40 3.1 Definitions (continued)

Skid-Mounted Pumps and Valves: - Pumps and valves which are integral to or that support operation of major components, even though these pumps and valves may not be located on the skid. Ingeneral, these pumps and valves are supplied by the manufacturer of the major component. Examples include: diesel generator lube oil pumps and valves, steam admission and trip throttle valves for turbines, and solenoid operated pilot valves used to control air operated valves.

Vertical line shaft pumps: - A vertically suspended pump where the pump driver and pump element are connected by a line shaft with an enclosed column.

3.2 General Program Requirements A. All components tested under the IST Pump Program and the test parameters to be measured are identified in Appendix B. Appendix A to this document contains requests for relief from code requirements.

B. The ASME Inservice Pump Tests shall be reviewed and approved by the Program Test Engineer.

C. The ASME Inservice Pump Test records shall be maintained in accordance with ISTB-9000 of the OM Code.

D, Pump Groups:

1. Group A Pumps: - The OM Code defines Group A pumps as those pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations. Sequoyah considers the following pumps to be Group A pumps. Basis for grouping are:

a. Charging Pumps - The charging pumps are utilized during plant operation for normal charging and letdown activities.

b. Motor Driven Auxiliary Feedwater Pumps - These pumps are utilized during startup from refueling outages to fill the steam generators and to maintain steam generator level prior to initiation of normal feedwater.

c. Boric Acid Transfer Pumps - These pumps are in service for recirculation of the boric acid tanks during normal operation.

d. Component Cooling Water Pumps - The CCW pumps operate continuously during normal plant operation to supply cooling water to non-essential heat loads as well as cooling water to the RCP motor bearings and thermal barriers.

e. Chilled Water Pumps - These pumps are in service during normal operation to supply cooling to various loads.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000

. Page 9 of 40 3.2 General Program Requirements (continued)

f. Residual Heat Removal Pumps - The RHR pumps are required to operate when maintaining the plant in a cold shutdown condition.

g. ERCW Pumps - The cooling water vertical line shaft pumps operate continuously during normal plant operation to supply cooling water to non-essential heat loads.

h. ERCW Screen Wash Pumps - The vertical line shaft pumps operate intermittently during normal plant operation to maintain the screens clean.

2. Group B Pumps - The OM Code defines Group B pumps as those pumps in standby systems that are not operated routinely except for testing.

SQN considers the following pumps Group B pumps:

a. Turbine Driven Auxiliary Feedwater Pump - This pump is not utilized during any plant operating evolution. The pump remains in standby during all operating Modes and is required to operate only during accident or transient conditions in which it is credited for accident mitigation.

b. Containment Spray Pumps - The spray pumps are not utilized during any plant operating evolution. The pumps remain in standby during all operating Modes. The pumps are required to operate only during a loss-of-coolant accident (LOCA) or main steam line break (MSLB) inside containment for containment heat removal and pressure suppression.

c. Safety Injection Pumps - The pumps remain in standby during all operating Modes, except during testing.

3.3 Pump Testing Frequency A. Tech Spec frequency shall not be superseded by ASME frequency. The provisions of Tech Spec 4.0.2 allowing the use of a +1-25% tolerance to specified test frequencies listed in the Tech Spec may be applied.

B. When plant conditions restrict the availability of some'e components for testing, testing may be delayed until appropriate plant conditiops are available.

C. Components tested during power ascension due 6to nmaintenance performed during the outage shall be considered inoperable until the post maintenance tests are completed.

D. ASME Inservice pump testing (in the as found condition where practical) shall be conducted quarterly (at least once every 92 days).

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1,& 2 Rev. 0000

'Page 10 of 40 3.3 Pump Testing Frequency (continued)

E. A comprehensive pump test is performed every 2 years.

F. ASME pumps lacking required fluid inventory shall be tested at least once every two years (at least once every 24 months).

G. Pump testing shall continue through shutdown periods on operable equipment.

H. Pump performance may require increasing the test frequency to twice per quarter.

I. Pumps in systems out of service for an extended period of time are not required to be tested but will be tested within the last 92 days of the outage or prior to being returned to service or entry into an operational mode which requires the pump to be OPERABLE unless technical specifications allows otherwise.

J. Pump testing is required prior to returning to service following maintenance activities which could affect pump performance.

K. Pumps that are discovered to be out of frequency shall be subject to the requirements of TS 4.0.3 and Generic letter 91-18.

3.4 Reference Values A. Pump parameter reference values shall be established when the pump is known to be operating acceptably and at points of operation that are relatively stable and readily duplicated during subsequent tests. Reference values are found in implementing instructions.

B. Reference values for Group A and B pumps shall be established within +/- 20%

of pump design flow, if practicable. If not practicable, then the reference point shall be established at the highest practicable flow.

C. Reference values shall be established within +1-20% of design flow for the comprehensive pump test.

D. Following repair and/or replacement activities which may have affected established reference valves, the reference values shall be reconfirmed as acceptable or a new set of reference values shall be established.

E. A new set of reference values may be established for pumps in the Alert or Required Action Range when supported by an analysis which includes both the pump performance and the system requirements in accordance with ASME OM Code ISTB 6200(c).

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 11 of 40 3.4 Reference Values (continued)

F. When it is otherwise desirable to establish a new set of reference values, a Group A or comprehensive test shall be performed at the current reference values and determined to be acceptable prior to performing the test at the new reference values. A test shall be run to verify the new reference values before their implementation and the reasons for the change documented in the record of test.

G. Reference values shall be established using the most conservative values from Tech Specs, Code, or design limits.

3.5 Test Parameters A. Speed - Pump speed is only measured for variable speed pumps.

B. Differential Pressure - Differential pressure is calculated from suction and discharge pressure or obtained by direct differential pressure measurement.

Lake level and pump elevation are used to obtain suction pressure when necessary and the calculational method is included in the pump test procedure.

C. Discharge Pressure - The pump discharge pressure. Discharge pressure is to be measured for positive displacement pumps.

D. Flow Rate - Flow rate is measured using a rate or quantity meter installed in the pump test circuit. If a meter does not indicate the flow rate directly, the record shall include the method used to reduce the data. Internal recirculation flow is not required to be measured. External recirculation flow is not required to be measured when it has been evaluated and determined to not have a substantial effect on test results, has a fixed resistance, or is not practical to isolate.

E. Vibration - All centrifugal pumps will have vibration measurements taken in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each accessible pump bearing housing. Measurement will also be taken in the axial direction when accessible at the thrust bearing housing.

Vertical line shaft pumps will have vibration measurements taken on the upper motor bearing housing in three orthogonal directions, one of which is the axial direction. Reciprocating pumps will have vibration measurements taken approximately perpendicular to the crankshaft and the line of plunger travel, including the axial direction when accessible on each bearing housing (vibration measurement is not required for Group B quarterly tests).

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 12 of 40 3.6 Allowable Ranges for Test Parameters Tables ISTB-5100-1 and ISTB-5200-1 of OM Code provide the allowable ranges for pump testing parameters. Expanded ranges are not allowed without relief from the NRC. New reference values may be established as allowed by ISTB-3320 and ISTB-6200(c) of the ASME OM Code.

Requirements are developed from OM Code ISTB and approved Relief Requests.

A. Reference Values: The following table provides acceptable ranges of acceptance criteria. Values shall not exceed the more conservative of Design, Tech Spec, or Code limits.

PUMP VIBRATION TEST PARAMETERS (Quarterly and Comprehensive)

PumpType Pump Test Acceptable Alert Range Required Action Speed Parameter Range Range Centrifugal and <600 rpm VV <2.5Vr >2.5Vrto 6Vr >6Vr veritcal line shaft Centrifugal and Ž600 rpm VV <2.5Vr >2.5Vr to 6Vr or >6Vror vertical line shaft >0.325 in./sec >0.70 in./sec Reciprocating Vv *2.5Vr >2.5Vr to 6Vr >6Vr NOTE: Vr is vibration reference value in the selected units.

QUARTERLY PUMP TEST PERFORMANCE RANGES Alert Range J Required Action Range Test Acceptable .

Parameter l Range Low l F High Low l High Vertical Line Shaft GroupA (No GroupB at Sequoyah)

AP 0.95 to 0.93 ... <0.93APr >1.10APr 1.10APr tO<0.95APr Q 0.95 to 0.93 . <0.93Qr >1.lOQr 1.10Qr tO<.95Qr _

Centrifugal Group A and B Pumps AP 0.90 to ... ... <0.90APr >1.10APr 1.10APr Q 0.90 to ... ... <0.90Qr >I.1OQr 1.1OQr Positive Displacement Pumps (none at Sequoyah)

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 13 of 40 3.6 Allowable Ranges for Test Parameters (continued)

_ _ COMPREHENSIVE PUMP TEST PERFORMANCE RANGES Required Pump Test Acceptable Alert Action Range Type Parameter Range Range Low High Vertical Q 0.95 to 1.03 0.93 to < 0.93 Qr > 1.03 Qr Line Shaft Qr < 0.95 Qr AP 0.95 to 1.03 0.93 to < < 0.93 APr > 1.03 APr APr_0.95APr

___ __ _ _\'

Centrifugal Q 0.94 to 1.03 0.90 to < 0.90 Qr > 1.03 Qr Qr < 0.94 Qr AP 0.93 to 1.03 0.90 to < 0.90 APr > 1.03 APr

APr < 0.93APr A _ _ _ _ _ _ _ _ _ \ _ _

NOTE: The subscript r denotes reference value.

B. Instrumentation:

1. Instrumentation shall meet the requirements of the following table:

ACCEPTABLE INSTRUMENT ACCURACY Group A and Comprehensive and Quantity Group B Tests, % Preservice Tests, %

Pressure i2 +/-1/2 FlowRate 2 +/-2 Speed +/-2 +/-2 Vibration +/-5 i5 Differential Pressure +/-2 +/- 1/2 NOTE:

(1) Percent of full scale for individual analog instruments, percent of total loop accuracy for a combination of instruments, or over the calibrated range for digital instruments.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 14 of 40 3.6 Allowable Ranges for Test Parameters (continued)

2. The full range of analog instruments shall not exceed three times the reference value.

3. Digital instruments shall not exceed 70% of the calibrated range of the instrument except where relief has been granted.

4. Vibration instruments are exempted from range requirements.

5. Measurement locations shall be repeated for subsequent testing. Vibration measurement locations are marked on the equipment and identified in plant procedures.

6. Throttling small instrumentation valves or the use of snubbers/damping devices is permissible.

7. Vibration ranges shall be from one third rotating speed to at least 1000Hz.

3.7 Pump Testing A. Pumps shall be operated at nominal motor speed for constant speed drivers and at a speed adjusted to the reference value (+/-1%) for variable speed drivers.

B. Vibration measurements shall be taken and compared to their reference values.

NOTES

1) Option C, D, or E is acceptable.

2) When flowrate or pressure is a fixed value, it shall not vary by more than +1-2%

inclusive of total instrument accuracy unless a similar reduction in acceptance criteria is made.

C. System resistance shall be varied until the flow rate equals the reference value.

The differential pressure shall be measured or determined and compared to its reference value.

D. System flow rate shall be varied until the differential pressure equals the reference value. The flow shall then be measured and compared to its reference value.

E. If system resistance cannot be varied, then flow rate and differential pressure shall be measured or determined and compared to their respective reference values.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 15 of 40 3.7 Pump Testing (continued)

F. For Group A and the comprehensive tests, testing shall not begin until at least two minutes following system stabilization.

INSERVICE TEST PARAMETERS l Quantity Remarks Speed: N If variable speed Differential Pressure: AP Centrifugal Pumps, including vertical line shaft pumps Discharge Pressure: P Positive Displacement Pumps Flow Rate: Q All Vibration: Velocity, Vv Peak 3.8 Relief Requests In the event that compliance with a specific requirement of 10CFR50.55a or the ASME OM Code is determined; 1) to be impractical and cannot be met; 2) to result in undue difficulty without a compensating increase in quality or safety; or 3) to be less preferred than a specific proposed alternative, then relief may be granted by the NRC. A general request for a group of components may be submitted, or a specific request may be submitted for specific issues. Each relief request should follow the guidance of NEI White Paper, entitled "Standard Format for Relief Requests from Commercial Reactor Licensees Pursuant to 10CFR50.55a", identify as to whether the request was approved in the second interval, or whether it is a new relief request. Relief requests are to be submitted prior to the start of the third interval where possible, and not later 12 months following end of the current inspection interval in accordance with 10CFR50.55a(f)(5).

3.9 Data Analysis and Evaluation If deviations fall within the alert range the frequency of testing is doubled until the cause of the deviation is determined and the condition corrected. If deviations fall within the required action range the pump is declared inoperable as soon as the data is recognized to be unacceptable until the cause of the deviation has been determined and the condition corrected or an appropriate analysis is completed and new reference values are established. The analysis shall include an evaluation of both the system and pump operational readiness, the cause of the change in pump performance, and an evaluation of all trends of available data. The results of this analysis shall be documented in the record of tests. If testing indicates that instruments are erratic, the test may be discontinued and the instruments recalibrated, or replaced, without declaring the pump inoperable.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 16 of 40 3.9 Data Analysis and Evaluation (continued)

Upon finding a pump inoperable and entry into appropriate action statements of technical specifications, the test results may be reviewed and compared to previous test data to decide if a condition has or has not developed that will further degrade the pump and exceed the safety analysis limit. If the pump is found not in danger of further degradation over an acceptable period of time, an analysis and new reference values may be an acceptable alternative to pump repair or replacement until such time as repairs can be affected, as allowed by the code. If the analysis determines that the pump will soon degrade further, immediate action is required.

The analysis must establish a basis for meeting the safety analysis limits/licensing basis and must assess the condition of the redundant train.

With the exception of the fixed parameter, test results shall be trended.

3.10 Augmented Pump Testing The inservice operability testing of safety-related pumps associated with non-Code pumping systems are not tested per the ASME inservice test program. For example, the inservice operability testing of pumps associated with the emergency diesels do not meet the criteria for inclusion in the ASME pump test program. The fuel oil transfer pumps, and lube oil pumps are tested per the augmented test program.

Other components are an integral part of the Emergency Diesel System and are functionally tested by the diesel engine tests. Thus, the functional operability testing of these pumps is performed at a frequency equal to that required by OM Code for pumps or at a frequency commensurate with their safety function. Additionally, the failure of a pump to perform its intended function will be identified by the failure of the associated Emergency Diesel to meet its functional requirements.

4.0 RECORDS 4.1 Pump Records Records will be maintained for each pump included in the IST Program. This will include the following items and must be retained for the lifetime of the component:

A. Manufacturer's information, including:

1. Manufacturer.

2. Manufacturer's model and serial or other identification number.

B. A copy of summary of the manufacturer's acceptance test report, if available.

C. A copy of the pump manufacturer's operating limits.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 17 of 40 4.2 Inservice Test Plans A record of test plans and procedures shall be maintained which shall include the following:

A. The hydraulic circuit to be used.

B. The location and type of measurement for the required test parameters.

C. The reference values.

D. The method of determining reference values which are not directly measured by instrumentation.

E. The category of each pump.

4.3 Record of Tests A record of each test shall be maintained which shall include the following:

A. Pump identification.

B. Date oftest.

C. Reason for test (e.g., post-maintenance, routine inservice test, establishing reference values).

D. Values of measured parameters.

E. identification of instruments used.

F. Calibration Records.

G. Comparisons with allowable ranges of test values and analysis of deviations.

H. Requirement for corrective action, if any.

I. Evaluation and justification for changes to reference values.

J. Signature of the person or persons responsible for conducting and analyzing the test.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 18 of 40 4.4 Record of Corrective Action Records of corrective action shall be maintained which shall include the following:

A. A summary of the corrections made.

B. The subsequent Inservice Test and confirmation of operational adequacy.

C. The signature of the individuals responsible for corrective actions and verification of results.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 19 of 40 Appendix A (Page 1 of 17)

REQUEST FOR RELIEF Pump Relief Request - RP-01 ERCW SCREEN WASH PUMP FLOW MEASUREMENT Affected Components ERCW Screen Wash Pumps Test Requirement ISTB-5121(b) requires that the system resistance be varied until the flow rate equals the reference point, then differential pressure is measured and compared to the reference value.

Basis for Relief No in-line instrumentation exists to measure flow and the physical configuration of the pump and piping does not allow the use of portable flow measuring equipment such as ultrasonics. Piping from the discharge of the screen wash pumps is open-ended to the spray nozzles at the traveling screen and is relatively short with multiple elbows, reducers, and valves in different planes. The physical configuration of this piping system is such that no portion of the piping meets the requirements for adequate installation of a permanent flow measuring device. Therefore, measured flow readings from an installed device may not be repeatable nor representative of actual pump flow. Significant system modifications, such as piping rerouting and support redesign, would be required to obtain a configuration that would provide reliable flow readings.

Alternative Test SQN plans to perform the test by setting the system resistance to the same point for each test. The throttle valves will be full open, flow iill not be measured. By performing the test at the same resistance condition,l the flow rate should be constant and therefore, only the differential pressure is needed to be measured.

Differential pressure is calculated using inlet (based 1upon the lake level) and discharge pressure. The pump can be trended for degradation based on differential pressure at this point. Vibrations readings will also be taken at this reference system resistance (flow) as well. The pumps will be tested in this manner for both the quarterly Group A test and the biennial Comprehensive test.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000

. Page 20 of 40 Appendix A (Page 2 of 17)

Pump Relief Request - RP-01 ERCW SCREEN WASH PUMP FLOW MEASUREMENT Conclusion Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with 10CFR50.55a(3)(i).

This is a new relief request. This relief request is similar to one approved for Watts Bar Nuclear Plant for their current interval TAC NOS. M89217, M89218, and M74801.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 21 of 40 Appendix A (Page 3 of 17)

Pump Relief Request - RP-02 RESIDUAL HEAT REMOVAL PUMP FLOW MEASUREMENT Affected Components Residual Heat Removal Pumps Test Requirement ISTB-5120 requires the flow rate to meet the ranges specified in Table ISTB-51 00-1.

Basis for Relief Residual Heat Removal Pumps are tested using the minimum flow recirculation line provided for pump protection. No other flow path is available to meet the Group A quarterly testing of ISTB. The miniflow path is of fixed resistance, instrumented, and limits flow to the minimum required flow for pump protection. The nominal miniflow rate is 500 gpm for pump protection.

Test results during -thefirst ten-year inspection interval have shown variations of recorded flow readings which exceed ISTB allowable range requirements. Residual Heat Removal pump miniflow rate is determined using an installed flow measuring device in the 14 inch pump discharge header while flowing through the 3 inch miniflow line which includes a 2 inch miniflow return valve. The flow measuring device meets ISTB range and accuracy requirements, however, small changes in the differential pressure across the flow element equate to relatively large changes in the flow. A differential pressure change of 2 inches of water at the flow element would equal a 44 gpm change in flow.

While testing using the miniflow recirculation line, the pump is operating in the flat portion of the pump curve near shutoff head conditions. Changes in the flow rate of the magnitude which would equal or exceed the ISTB required range for flow would result in negligible changes in pump differential pressure. Pump differential pressure would only change a maximum of 0.15 psig from the 520 gpm reference value to the ISTB upper and lower limits for flow of 572 and 468 gpm, respectively. A change in flow in excess of 3000 gpm would be required for the differential pressure to exceed the ISTB acceptable range of 0.9 times the reference value..

With the configuration of the installed flow instrumentation and the negligible effect of the changes in the flow have on differential pressure while operating on miniflow, maintaining compliance to ISTB specified flow ranges is NOT practical. Ensuring miniflow rate is in compliance with ISTB required ranges is of little value in determining pump condition or the pumps ability to meet its design function.

SQN . ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 22 of 40 Appendix A (Page 4 of 17)

Pump Relief Request - RP-02 RESIDUAL HEAT REMOVAL PUMP FLOW MEASUREMENT This relief request meets the intent of Position 9 in Generic Letter 89-04.

No other flow measurement means are available that will provide the repeatability necessary to meet ISTB ranges.

Alternative Test The Residual Heat Removal Pumps will be Group A tested quarterly using the minimum flow recirculation line where differential pressure and vibration will be measured and trended. The Residual Heat Removal Pumps will be subject to a Comprehensive Pump test in accordance with ISTB requirements each refueling outage.

Conclusion Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with IOCFR50.55a(3)(i).

This relief request was approved for the Second Ten Year Interval by TAC NOS.

M94117, M94118, MA0417, MA0418, MA1595, and MA1596. No changes in Code requirements have occurred affecting this relief request.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 23 of 40 Appendix A (Page 5 of 17)

Pump Relief Request - RP-03 Boric Acid Transfer Pumps Affected Components Boric Acid Transfer Pumps Test Requirement ISTB-351 0 (b)(1) requires that the full-scale range of each analog instrument shall be not greater than three times the reference value.

Basis for Relief These pumps have low suction pressure requirements where the pressure is as low as 1.5 psig. To meet the requirements of ISTB, special low-range pressure gauges would have to be purchased. Three times this pressure is 4.5 psig and the maximum allowable error of 2% would be 0.09 psig. Using a 15 psig gage during testing would provide a maximum allowable error of 0.30 psig. The 0.21 psig difference in accuracy of the two gauges is negligible. This variance is not sufficient for the degradation of the pump to be overlooked. Instrument replacement does not provide an increase in the level of safety. The Boric Acid Transfer Pumps have a differential pressure of 80 to 90 psid and typical discharge pressure readings are in the range of 90 to 105 psig. The discharge pressure is measured with 150 to 300 psig gages with a minimum accuracy of +/- 1% which exceed Code accuracy requirements. The discharge pressure is the controlling value in the differential pressure measurement. The gage used to measure the discharge pressure would still provide accurate and repeatable readings necessary to determine acceptable pump performance. Considering the inaccuracies in readability of 0.025 psig of 15 psig suction gauge, the effect on the determination of an accurate differential pressure reading is negligible.

This relief request is based on guidance provided in the SER dated October 23, 1987 and was approved in the previous 10 year interval.

Alternative Test Pump testing will be performed using 15 psig suction gauges in lieu of gauges required by ISTB-3510 (b)(1).

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 24 of 40 Appendix A (Page 6 of 17)

Pump Relief Request - RP-03 Boric Acid Transfer Pumps Conclusion Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with 10CFR50.55a(3)(i).

This relief request was approved for the Second Ten Year Interval by TAC NOS.

TAC NOS. M94117, M94118, MA0417, MA0418, MA1595, and MA1596. No changes in Code requirements have occurred affecting this relief request.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 25 of 40 Appendix A (Page 7 of 17)

Pump Relief Request - RP-04 Smooth Running Pump Vibration Acceptance Criteria Affected Components This is a general relief request that applies to all pumps in the IST program, Test Requirement ISTB-3300, requires that reference values be determined from the results of preservice testing or from the results of the first inservice test. This request for relief applies only to vibration testing.

Basis for Relief Many pumps have at least one vibration reference value (Vr) that is currently less than 0.05 inches per second (ips). Small values for Vr produce small acceptable ranges for pump operation. The acceptable ranges are defined in Tables ISTB-5100-1 and ISTB-5200-1, as less than or equal to 2.5 Vr. Based on a small acceptable range, a smooth running pump could be subject to unnecessary corrective action.

For very small reference values, hydraulic noise and instrument error can be a significant portion of the reading and affect the repeatability of subsequent measurements. Also, experience gathered from the preventive maintenance program has shown that changes in vibration levels in the range of 0.05 ips do not normally indicate significant degradation in pump performance.

To avoid unnecessary corrective action, a minimum value for Vr of 0.05 ips has been established for velocity measurements. This minimum value will be applied to individual vibration locations where the measured reference value is less than 0.05 ips.

When new reference values are established per ISTB-3310, ISTB-3320 or ISTB-6200(c), the measured parameters will be evaluated for each location to determine if the provisions of this relief request still apply. If the measured Vr is greater than 0.05 ips, the requirements of ISTB-3300 will be applied. Conversely, if the measured Vr is less than 0.05 ips, a minimum value of 0.05 ips will be used for Vr-In addition to the requirements of ISTB, the pumps in the ASME Inservice Testing Program are included in the Predictive Maintenance Program. The Predictive Maintenance Program currently employs predictive monitoring techniques such as:

vibration monitoring and analysis beyond that required by ISTB,

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1,& 2 Rev. 0000 Page 26 of 40 Appendix A (Page 8 of 17)

Pump Relief Request - RP-04 Smooth Running Pump VIBS Acceptance bearing temperature trending, oil sampling and analysis, and thermography analysis.

If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may include:

increased monitoring to establish rate of change, review of component specific information to identify cause, and removal of the pump from service to perform maintenance.

It should be noted that all of the pumps in the IST Program will remain in the Predictive Maintenance Program even if certain pumps have very low vibration readings and are considered to be smooth running pumps. This alternative to the requirements of ISTB-3300 provides an acceptable level of quality and safety.

Alternative Actions Pumps with a measured reference value below 0.05 ips for a particular vibration measurement location shall have subsequent test results for that location compared to an acceptable range based on 0.05 ips. Inaddition to the Code requirements, all pumps in the IST Program are included in and will remain in the Predictive Maintenance Program regardless of their smooth running status.

Conclusion Using the provisions of this relief request as an alternative to the specific requirements of ISTB-3300 identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(i) we request relief from the specific ISTB Code requirements identified in this relief request.

This is a new relief request. This relief request is similar to one approved for North Anna Power Station TAC NOS MB2221 and MB2222 and approved for Watts Bar Nuclear Plant for their current interval TAC NO. M74801.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 I..

X Page 27 of 40 Appendix A (Page 9 of 17)

Pump Relief Request - RP-05 Use of OMN-06 Affected Components This is a general relief request that applies to all pumps in the IST program.

Test Requirement ISTB-3510 (b)(2) requires digital instruments to be calibrated such that the reference value does not exceed 70% of the calibrated range of the instrument.

Basis for Relief OMN-6 addresses alternate rules for digital instruments. The ASME Code committee states that digital instruments may be selected such that the reference value does not exceed 90% of the calibrated range of the instrument.

The applicability listed in the ASME Code Case is the 1990 Edition through the 1997 Addenda. In addition, the Code committee has reaffirmed OMN-6 for the 2004 Edition.

SQN's Third 10 Year Interval will conform to the requirements of the 2001 Edition with the 2003 Addenda. Since neither the applicability listed, nor the reaffirmation dates match this Code edition, relief is requested for its use. This follows the guidelines discussed in NUREG 1482R1 Section 2.1.1.

Alternative Test SQN proposes to calibrate digital instrumentation such that the reference value for the parameter does not exceed 90% of the calibrated range. This alternative will apply to both the Group A or B quarterly test and the Comprehensive test.

Conclusion Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with 10CFR50.55a(3)(i). I This is a new relief request. The containment spray 'pumps we granted similar relief by TAC NOS. TAC NOS. M94117, M94118, MA0417, MA0418, MA1595, and MA1596 in the Second Ten Year Interval. No changes in Code requirements have occurred affecting this relief request.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 28 of 40 Appendix A (Page 10 of 17)

Pump Relief Request - RP-06 RHR Pump Vibration Measurements Executive Summary: TVA performs testing of safety-related pumps in accordance with American Society of Mechanical Engineers (ASME) Code, which endorses Operations and Maintenance Standard, ISTB. The provisions of ISTB require the vibration measurements to be broad band and unfiltered with instrumentation calibrated in a range from one-third minimum pump shaft rotational speed to at least 1000 hertz.

TVA's proposed request for relief provides alternative testing to measure RHR pump vibration in the range from one-half pump shaft rotational speed to at least I 000 hertz (Hz). The request is based on high natural vibration levels in the low frequency band (between one-third to one-half rotational speed) that is inherent to the pump/motor framework design. The inherent vibration levels at this frequency range are not representative of pump vibration trends and do not provide useful information for the assessment of pump performance and trending during quarterly pump tests.

TVA's request for relief includes consideration of four key components recommended by NRC NUREG/CP-0152. These key components include:

1) Pump vibration history

2) Information from pump manufacturer

3) Discussion of TVA attempts to lower vibration

4) Spectral analysis of the pump-driver system.

TVA's request for relief was approved for SQN's second 10-year inservice test (IST) interval. This relief request is provided for NRC review and approval in accordance with IOCFR50.55a(a)(3)(i).

Unit Affected: Units 1 and 2 System: Residual Heat Removal (RHR) System Components: RHR Pumps 1A, 1B, 2A, and 2B.

Code Class: ASME Code Class 2

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 29 of 40 Appendix A (Page 11 of 17)

Pump Relief Reauest - RP-06 RHR Pump Vibration Measurements Component Function: Provides low-head safety injection during emergency core cooling and provides RHR for core cooling during unit shutdown.

Code Requirement: ISTB-5121 (d)states 'Vibration measurements are to be broad band (unfiltered)."

ISTB-351 0 (e) states: "the frequency response range of the vibration measuring transducers and their readout system shall be from one-third minimum pump shaft rotational speed to at least 1000 Hz."

Code Requirement From Which Relief is Requested: Relief is requested to exclude the measurement of broad band (unfiltered) vibration in the response range from one-third rotational speed up to one-half rotational speed.

Basis for Relief: The following background information is provided in accordance with the guidance of NUREG/CP-0152.

Historical Data: Pump performance historical documents indicate that a high vibration condition has existed on SQN's RHR pumps since original installation of these pumps. This condition also existed prior to the ASME conversion to the ISTB pump criteria that incorporated an expanded frequency range for measurement of pump vibration (one-third to one-half rotational speed). TVA has monitored this condition for SQN's RHR pumps and concludes there is no degradation of the pump/motor/foundation assembly from the inherent high vibration in this range.

Manufacturer Data: Westinghouse Electric Company, provider of SQN's RHR pumps, issued a Technical Bulletin (NSID-TB-86-02) that advised utilities of the potential for a high vibration condition in vertical pump/motor/foundation support assemblies. The bulletin references the condition that SQN is experiencing. Consultation with Westinghouse and the results of TVA's evaluation of this issue are provided below.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000

-IPage 30 of 40 Appendix A (Page 12 of 17)

Pump Relief Request - RP-06 RHR Pump Vibration Measurements Attempts to Correct Problem: In accordance with the vendor recommendations from NSID-TB-86-02, TVA inspected SQN's RHR pumps and pump supports to verify there were no loose supporting connections contributing to the vibration condition. Plant modifications to lower vibration by installing additional supports was not a preferred option based on a concern for relocation of the vibration to other points in the pump/motor/foundation. Attempts to relocate the vibration were found to have limited success at other utilities and in some instances vibration levels were increased.

Spectral Analysis: Analysis of the condition indicates that the vibration occurs in a low frequency range less than one-half rotational speed.

Analysis indicates there are no problems with the bearings or rotating elements (i.e., imbalance or misalignment). TVA's request is restricted to those frequencies that exhibit the natural resonance vibration levels. The results and evaluation of TVA's spectral analysis were provided in the original relief request during the second ten year interval.

Pump/Svstem Design: The RHR system pumps for SQN are the typical design for more recent Westinghouse four loop plants, which are centrifugal pumps with the motor in the vertical position.

There is no typical bearing housing(s) associated with these pumps as there are with centrifugal pumps where the pump and the driver are in the horizontal position. The pump and motor utilize one continuous shaft. There is no coupling located along the shaft and all of the bearings for the pump/motor assembly are located in the motor.

Although mounted vertically, these pumps are not vertical line shaft pumps. Two motor designs exists for this application with different bearing arrangements. In one design the bearing located in the upper motor housing acts as a thrust and upper radial bearing while the lower bearing is a radial bearing. In the other pump/motor design, the lower motor housing bearing acts as the thrust and lower radial bearing while the upper bearing is a radial bearing.

The pump support is designed to support the pump and the motor which rests on top of the pump. The motor is unrestrained and is in effect a large moment arm. The bearings for this pump are within the motor.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 31 of 40 Appendix A (Page 13 of 17)

Pump Relief Request - RP-06 RHR Pump Vibration Measurements Comoliance with ASME ISTB: The natural system frequency of 10 to 11 Hz exhibits sufficient force such that when measurements are taken during quarterly pump testing at the upper motor bearing, the vibration readings are outside of the OM Code acceptable range limits.

When applying the OM Code criteria, the vibration limits will place the pump consistently in the uAlert Range" or the 'Required Action Range.'

SQN originally took a literal reading of OM Part 6 wording to determine if vibration testing is required for the RHR pumps. Since the bearings are part of the motor (i.e., pump driver), these vibration points were not included in SQN's IST program. Following a self-assessment of SQN's IST program, TVA determined that this is not the most conservative position. SQN now evaluates these measurements in accordance with ISTB acceptance criteria for pump vibration.

Plant Operation and Pump Vibration History: Prior to initial operation of either unit, a nonconformance report was written which identified a natural frequency of the RHR pumps of 10 to 11 Hz .At the time, the seismic qualification of the pump had been performed based upon no natural frequencies below 33 Hz. The safety implication was that the RHR pumps did not meet their design basis for seismic qualification.

This was reported to the NRC .TVA performed design changes and reanalysis of the pump support structure and piping system to qualify the 10 to 11 Hz natural frequency condition. Westinghouse Electric Company reviewed and approved the changes.

Both units were shut down for approximately three years beginning in 1985. Both units remained on RHR at shut down cooling flow conditions (greater than 2,000 gallons per minute [gpmj) in order to maintain the RCS in accordance with the Technical Specifications.

During this time, there were no problems with the RHR pumps. The pumps operated continuously with no adverse conditions identified.

Both units at SQN were again shut down in 1993 for approximately one year. During this time, both units remained on RHR with the pumps operating at full flow conditions. The pumps operated continuously with no adverse conditions identified.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 32 of 40 Appendix A (Page 14 of 17)

Pump Relief Request - RP-06 RHR Pump Vibration Measurements Advanced Vibration Diagnostics: SQN has performed advanced vibration diagnostics to assess the condition on all four RHR pumps.

The same 10 to 11 Hz natural frequency identified in the late 1970's was identified again.

Impact testing was performed on all four RHR pump/motor assemblies. The testing revealed the following data:

Pump ID Natural Frequency of Natural Frequency of Motor Alone Motor and Frame '

1A 14 to 16 Hz 120 to 350 Hz 1B 11 Hz 175to331 Hz 2A 10 Hz 287 to 356 Hz 2B 11to13Hz - 100 to 350 Hz

'Based on location on the frame.

For the 1B and 2A RHR pump motors, this data confirms the previous evaluation that a resonant condition exists at 10 and 11 Hz, respectively. The testing revealed that the motor upper bearing exhibited natural frequencies at approximately 10 and 11 Hz, respectively, which is coincident with the maximum amplitude vibration measurement for the same point found during OM Code quarterly pump testing.

The testing performed on the 1A RHR pump motor revealed a 14 to 16 Hz response frequency range on the motor and the motor/support frame frequency response is between 120 and 350 Hz .The overall vibration levels on 1A RHR pump are stable and below the alert range.

However, the vibration occurring at the 14 Hz frequency is contributing to the overall levels.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 33 of 40 Appendix A (Page 15 of 17)

Pump Relief Request - RP-06 RHR Pump Vibration Measurements The testing performed on the 2B RHR pump motor revealed a 11 to 13 Hz response frequency range on the motor and the motor support/frame frequency response is between 100 and 350 Hz . The overall vibration levels on 2B RHR pump are stable and below alert range. However, the vibration occurring at the 11 Hz frequency is contributing to the overall levels.

Quarterly ISTB Group A pump testing is performed with the pump operating on miniflow, approximately 500 gpm. The pump operation flow characteristics create low frequency flow pulsations which tend to excite the structural resonant frequencies of the machine assembly.

Spectra analysis of vibration data collected during pump testing activities indicates a dominant peak between 10 to 14 Hz for all RHR pump motors. To improve the vibration would require separating the low natural frequencies away from the operating frequency of 29.8 Hz.

Physical modifications to drive the natural frequency up beyond 30 Hz (greater than 15 percent of operating frequency as a rule of thumb) can be unpredictable and difficult even when performed with detailed analysis. Efforts at other plants have been unsuccessful due to shifting the vibration to adjacent components such as the pump or piping.

Full Flow Testing: Near full flow vibration data obtained during refueling outages shows that the vibration is greatly reduced at near full flow conditions. This indicates that the higher test measurements occur only during the quarterly tests, which are conducted with ithe RHR pumps on miniflow. The pumps are designed to run at full-flow conditions for normal plant operations and for accident conditions.

Thus, the minimum flow test configuration causes the motor structure to be excited and a higher vibration to be present during the quarterly pump tests.

This testing supports the expected results identified by Westinghouse in Technical Bulletin NSID-TB-86-02.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 34 of 40 Appendix A (Page 16 of 17)

Civil/Structural Evaluations: TVA originally modeled the pump and its support as a rigid anchor. During the reanalysis discussed above, the pump and its support were modeled as a flexible member. The results of this analysis confirmed that the measured natural frequency of approximately 10 to 11 Hz was a system frequency, i.e., pump, pump support, and piping. The reanalysis changed the nozzle loads on the pump and on local pipe supports to meet the new support loads. The pump support was also stiffened, incidental to the vibration problem.

A Civil Engineering review has been performed on the results of the advanced vibration diagnostics with respect to the problem described above. The review determined that the new measurements reflect the problem identified during initial system operation and is not a new vibration problem. Based upon this analysis, the pump and its structure continue to meet the design requirements for acceptable operation.

ISI Examinations of the Piping and Supports: A review of ISI examinations of pipe welds and pipe supports in the area surrounding the pumps was performed. Of the examinations in this area which did not meet the acceptance criteria, all of them were minor indications and are characterized as typical indications found during inservice examinations following the completion of construction activities. No failures were associated with any of these indications. None of the indications could be characterized as defects due to pump vibration.

No further indications have been identified. The issues found by in-service examination are indicative that the vibration problems are a natural frequency of the system and not a destructive vibration force.

Alternative Vibration measurements of the upper motor bearing of the RHR Testing: pumps will be taken during the quarterly ISTB Group A pump tests in a range from one-half minimum pump shaft rotational speed to at least 1000 Hz.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 35 of 40 Appendix A (Page 17 of 17)

Pump Relief Request - RP-06 RHR Pump Vibration Measurements

==

Conclusion:==

SQN proposes to exclude from the ISTB Group A pump test the vibration measurement in the range from one-third up to one-half pump shaft rotational speed. The exclusion of vibration measurements from one-third to one-half minimum pump shaft rotational speed will exclude the readings associated with the natural frequencies as described above. It has been shown that these frequencies do not affect pump performance. Excluding this range of vibration for test measurements would prevent placing the pumps in an "Increased Frequency" test status. Placing SQN's RHR pumps on an increase frequency test status provides no added value for monitoring pump performance. The dominant peak at one-third running speed masks data trending at the frequencies that represent actual pump/motor health. This places an unnecessary burden on SQN resources and of having to place the pumps on an increased frequency for testing resulting in additional wear on the equipment and potential challenges to the plant. Pump degradation due to real physical problems, will be evident with the pump test monitoring the representative pump/motor condition frequencies without being masked by the unrelated structural resonant peak. This will ensure appropriate corrective actions are taken to address those levels of vibration that could result in pump degradation.

Based upon the above, SQN concludes that the pumps operate acceptably and will perform their safety function as required during normal and accident conditions.

This relief request was approved during SQN'p second 10-year IST Program interval by TAC NOS. MA7966 and MA79671 No changes in Code requirements have occurred affecting this relief request.

SQNASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 36 of 40 Appendix B (Page 1 of 5)

ASME IST PUMP TEST PROGRAM Summary of Information Provided:

The pump test table provides the following information on testing requirements:

1. Pump ID.

2. Pump Group.

3. Drawing, on which the pump is depicted.

4. ASME Class.

5. Pump Type.

6. Differential Pressure.

7. Flow Rate.

8. Vibration Velocity.

General Notes:

1. Quarterly testing in accordance with the requirements of the OM Code is indicated by "Q", otherwise it is addressed in specific notes as indicated.

2. TVA Calculation SQN-SQTP-002 provides the basis for selection of pumps to be tested, their unique identification numbers, TVA Class, and basis for testing.

3. RP refers to the associated relief request.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 37 of 40 Appendix B (Page 2 of 5)

Specific Notes:

1. Synchronous or induction motor driven pumps do not require speed check per Table ISTB-3000-1.

2. RHR Suction and Discharge pressure gauge range requirements are selected based on the RHR suction and discharge pressures present at the time of testing (i.e. 3 times the referenced value). This is due to the significant variation in RHR suction pressures in the various plant modes.

3. ERCW pump and ERCW screen wash pump suction pressure is derived in the pump test record from the elevation of Chickamauga Lake as allowed by Section 5.5.3 of NUREG-1482, Revision I and the OM Code.

4. The Si and RHR recirculation miniflow test paths are fixed resistance flow paths.

. SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 38 of 40 Appendix B (Page 3 of 5)

Relief ASME Diff Flow el Pup Requests Pump ID Pump P&ID Code Pump Press Dp Rate Q VibCPTl Supee Tehia Group 47W Class Type CPT Q CPTCPSpe Tchia Positions Auxiliary Feed A 803-2 3 Centrifugal Q 2Y Q 2Y Q 2Y NR 4, 5 Water (Motor) 1A-A, 1B-B 2A-A, 2B-B1.

Auxiliary Feed B 803-2 3 Centrifugal Q 2Y 0 2Y NR 2Y Q 4, 5 Water (Steam)

IA-S, 2A-S Centrifugal A 811-1 2 Centrifugal Q 2Y Q 2Y Q 2Y NR 4, 5 Charging 1A-A, 1B-B 2A-A, 2B-B Boric Acid A 809-5 3 Centrifugal Q 2Y Q 2Y Q 2Y NR 3, 4, 5 Transfer lA-A, 1B-B 2A-A, 2B-B

Appendix B (Page 4 of 5)

Relief Pump P&ID ASME P p Dff Flow Vib el) Q Pump Requests Pump ID Group 47W Code Pumpe Press Dp Rate Q CPT Speed Tehia Class Tye CPT Q CPT Tehia Positions Safety B 811-1 2 Centrifugal Q 2Y Q 2Y NR 2Y NR 4, 5 Injection IA-A, 1B-B 2A-A, 2B3-B Component A 859-1 3 Centrifugal Q 2Y Q 2Y Q 2Y NR 4, 5 Cooling 1A-A, 1B-B 2A-A, 2B-B..

C-S Containment B 812-1 2 Centrifugal Q 2Y Q 2Y NR 2Y NR 4, 5 Spray IA-A, 1B-B 2A-A, 2B-B_.

SQN ASME IST PUMP TESTING 0-TI-SXI-000-200.P Unit 0, 1, & 2 Rev. 0000 Page 40 of 40 Appendix B (Page 5 of 5)

Relief Pump P&ID ASME Pup Diff Flow Vib (Vel) 0 Pump Requests Pump ID Group 47W Code Pmpe Press Dp Rate V CPT Speed Technical Class Tye CPT Q CPTTehia Positions Residual Heat A 810-1 2 Centrifugal Q 2Y Q 2Y Q 2Y NR 2, 4, 5, 6 Removal 1A-A, 1B-B 2A-A, 2B-B1_

Essential Raw A 845-5 3 Vertical Q 2Y Q 2Y Q 2Y NR 4, 5 Cooling Water Line Shaft J-A, K-A, L-B, M-B, N-B, P-B, Q-A, R-A ERCW Screen A 845-5 3 Vertical Q 2Y Q 2Y Q 2Y NR 1, 4, 5 Wash A-A, Line Shaft B-B D-A, C-B_

Chilled Water A 865-8 3 Centrifugal Q 2Y Q 2Y Q 2Y NR 4, 5 A-A, B-B

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 Valve Test Program With Relief Requests (RV-1 thru RV-3)

Third 10-Year Interval

Sequoyah Nuclear Plant Unit 0, 1, & 2 Technical Instruction 0-TI-SXI-000-200.V ASME OM CODE VALVE TESTING Revision 0000 Quality Related Level of Use: Reference Use Effective Date:

Responsible Organization: SCE, System Eng - Component Prepared By: LD ALEXANDER Approved By: GAY HALIBURTON Current Revision Description New Procedure.

This procedure has been converted using Word 2002 (XP). Technical changes were not made.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 2 of 134 Table of Contents

1.0 INTRODUCTION

................................ 4 1.1 Purpose ................................ 4 1.2 Scope ................................ 5

2.0 REFERENCES

................................ 6 3.0 DEFINITIONS ................................ 8 4.0 Implementation Plan ................................ 9 5.0 PERFORMANCE ................................ 10 5.1 Valve Exercising and Testing ............................... 10 5.1.1 Power Operated Valves ............................... 10 5.1.2 Check Valves............................... 10 5.1.3 Relief Valves ............................... 11 5.2 Valve Seat Leakage Testing ............................... . 11 5.3 Fail - Safe Testing ................................ 11 5.4 Valve T esting Frequency ............................... . 12 5.4.1 Category A and B Power Operated Valves .............................. 13 5.4.2 Category C Valves (Check valves) .............................. 15 5.4.3 Manual Valves .............................. 16 5.4.4 Pressure Relief Valves .............................. 16 5.4.5 Pressure Isolation Valves Leakage Testing .............................. 17 5.5 Deferred Testing Justifications ............................... 18 5.6 Relief Requests ................................ 18 5.7 Test Instrumentation ................................ 18 5.8 Power Operated Valves Acceptance Criteria ............................... 19 5.9 Power Operated Valve Test Performance .. ............................. 21 5.10 Manual Valve Exercise .22 5.11 Relief Valve Testing .. 23 5.12 Check Valve Testing .. 24 5.12.1 Check Valve Sample Disassembly Program .2 5.12.2 Nonintrusive Check Valve Testing Program .26 5.12.3 Check Valve Condition Monitoring Program .27 5.13 Pressure Isolation Check Valves Testing .. 28

Table of Contents (continued) 6.0 RECORDS .................................................... 29 6.1 Inservice Test Plans .................................................... 29 6.2 Record of Tests .................................................... 29 6.3 Record of Corrective Action .................................................... 30 6.4 Record of Relief Requests, Deferred Test Justifications, and Technical Positions .................................................... 30 Appendix A: ASME VALVES .. 31 Appendix B: SYMBOLS USED IN THE VALVE TEST PROGRAM .98 Appendix C: DEFERRED TEST JUSTIFICATIONS .101 Appendix D: RELIEF REQUEST ............. 130

1.0 INTRODUCTION

1.1 Purpose The purpose of this document is to provide technical requirements to assure compliance with the requirements of 10CFR50.55a and Sequoyah Nuclear Plant's (SQN) Technical Specifications (TS) which require that ASME inservice testing of valves be met throughout the service life of the nuclear power plant and be updated at each 10 year interval. Interval extensions of as much as one year are allowed as long as successive intervals are not altered by more than one year from the original interval pattern. The purpose of the inservice test program (IST) is to ensure operational readiness of ASME Code Class 1, 2, and 3 plant components which are required for a specific function in (1) shutting down the reactor to a safe shutdown condition (hot shutdown for SQN), (2) maintaining the safe shut down condition, or (3) mitigating the consequences of an accident. Inservice tests are designed to detect component degradation by assessing component performance in relation to operating characteristics when the component was known to be operating acceptably. At no time will ASME requirements take precedence over SQN Technical Specification requirements. The rules for the in-service valve testing for Nuclear Power Plant Components for the Third Ten Year Interval, are contained in the ASME OM Code 2001 Edition, through the 2003 Addenda, NRC approved code cases, and relief requests. The milestone dates for SQN are:

Commercial Operation Unit 1 7/1981 Commercial Operation Unit 2 6/1982 Second 10 year interval start 12/15/1995 Third 10 year interval start 6/1/2006

SQN ASME OM CODE VALVE TESTING O-TI-SXI-000-200.V Unit 0, 1, &2 Rev. 0000 Page 5 of 134 1.2 Scope The scope of this instruction applies to valves determined to be ASME Code Class 1,2, and 3 plant components which are required for a specific function in (1) shutting down the reactor to a safe shutdown condition (hot stand by for SQN), (2) maintaining the safe shut down condition, or (3) mitigating the consequences of an accident. The scope includes pressure relief devices provided for over pressure protection as required by Section III of the ASME Boiler and Pressure Vessel Code.

Thermal relief devices whose only function is to protect isolated components, systems, or portions of systems from thermal expansion caused by changes in fluid temperature are also included. The scope of this instruction applies to the applicable valves within the ASME Section Xl boundaries as defined by the SQN ASME Section Xl Color Coded Boundary Drawings.

Components which have been determined to meet ASME 0 & M Code & plant Technical Specification requirements for inclusion in the test program are identified in Appendix A. General program requirements are included within this instruction with specific requirements listed in the individual implementing instructions.

The following are excluded from the requirements of this procedure provided that the valves are not required to perform a specific function as stated above:

A. Valves used only for operating convenience such as vent, drain, instrument and test valves.

B. Valves used only for system control, such as pressure regulating valves.

C. Valves used only for system or component maintenance.

D. Skid-mounted valves are excluded provided they are tested as part of the major component and are determined by SQN to be adequately tested.

E. External control and protection systems responsible for sensing plant conditions and providing signals for valve operation.

Components outside the scope of the 10CFR50.55a program will be tested at a level commensurate with their intended function to demonstrate that they will perform satisfactorily when in service as required by 10CFR50 Appendix A, GDC-1, Appendix B, Criterion Xl, and NUREG 1482 R1. These components will be tested as specified in the SQN Augmented Test Program.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 6 of 134

2.0 REFERENCES

A. IOCFR50.55a, Code of Federal Regulation.

B. NRC Documents:

1. Inspection Manual, Temporary Instruction 2515/114, Inspection Requirements for Generic Letter 89-04, Acceptable Inservice Testing Programs.

2. NRC Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, April 3, 1989.

3. NRC letter on the "Minutes of the Public Meetings on Generic Letter 89-04", Oct 25, 1989.

4. NRC NUREG 1482 Revision 1, Guidelines for Inservice Testing at Nuclear Power Plants, January, 2005.

5. Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756 "Inservice Testing of Pumps and Valves" and Answers to Panel Questions on IST Issues, July 18,1997.

6. NRC Information Notice 97-16: Preconditioning of Plant Structures, Systems, and Components Before ASME Code Inservice Testing OR Technical Specification Surveillance Testing.

7. 10CFR50 Appendix J Option B, Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors.

B. Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and nonconforming Conditions and on Operability.

9. Regulatory Guide 1.192, Operation and Maintenance Code Cases Acceptability, ASME OM Code.

10. Regulatory Guide 1.193, ASME Code Cases Not Acceptable for Use.

11. Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section Xl, Division 1.

2.0 REFERENCES

(continued)

C. CODES and STANDARDS:

ASME OM Code, Inservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants, 2001 Edition of the OM Code through the 2003 Addenda to the Code and applicable Code Cases.

D. SPP-9.1, ASME Section Xi.

E. TVA Calculation SQN-SQTP-003, ASME Section Xi Valve and Augmented Valve Identification for Inservice Testing.

F. TVA Calculation SQN-SQTP-001, ASME Section Xl Inservice Code Class Boundaries for Inservice Testing.

G. Sequoyah Nuclear.Plant Technical Specifications.

H. Sequoyah Nuclear Plant Design Criteria and Design Guides:

1. SQ-DC-V-3.0, Classification of Piping, Valves, Valves and Vessels.

2. SQ-DC-V-2.16, Single Failure Criteria.

3. SQ-DC-V-3.2, Classification of HVAC Systems.

I. TVA submittals to the NRC:

1. ASME Section Xi Programs for the Second Inspection Interval, Units 1 and 2, RIMS S64951121800.

2. Revised Inservice Test (IST) Program, Second Ten-Year Interval, RIMS S64971222800.

J. SQN UFSAR Section 3.2, 6.2, and 6.8.

K. NRC documents to TVA:

Second interval Safety Evaluation Report on Sequoyah Inservice Test Programs for Valves and Valves (IST) dated March 20, 1996 (TAC NOS.

M94117 and M94118).

L. NEI White Paper, Entitled 'Standard Format for Relief Requests from Commercial Reactor Licensees Pursuant to 10CFR5O.55a".

M. SQN ASME Section Xl Color Coded Boundary Drawings.

3.0 DEFINITIONS Operable - Operability - A system, subsystem, train, component, or device shall be OPERABLE, or have OPERABILITY, when it is capable of performing its specified function(s), and all necessary attendant instrumentation, controls, a normal and emergency electrical power source, cooling or seal water, lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

ASME Valve Test Program - The valve test program required by 10CFR50.55a(f) delineates the testing requirements of ASME Code Class 1, 2, and 3 valves by using the ASME OM Code. Those valves that are required in shutting down the reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident are to be tested in accordance the ASME OM Code.

Augmented Valve Test Program - Valves outside the scope of 10CFR50.55a will be tested at a level commensurate with their intended function. The intent of IOCFR50 Appendix A, GDC-1, and Appendix B, Criterion Xl is that all components, such as valves, necessary for safe operation are to be tested to demonstrate that they will perform satisfactorily in service. While 10CFR50.55a delineates the testing requirements for ASME Code Class 1, 2, and 3 valves, the testing of valves is not to be limited to only those covered by 10CFR50.55a. (refer to item 11 of Generic Letter 89-04).

Active Valves - Valves which are required to change normal obturator position to accomplish the required functions.

Category of Valves - Valves within the scope of this procedure shall be placed in one or more of the following categories. When more than one distinguishing category characteristic is applicable, all requirements of each of the individual categories are applicable, although duplication or repetition of common testing requirements is not required.

A. Category A - Valves for which seat leakage is limited to a specific maximum amount in the closed position for the fulfillment of their required functions.

B. Category B - Valves for which no maximum seat leakage limit in the closed position is specified for fulfillment of the required functions.

C. Category C - Valves that are self-actuating in response to some system characteristic, such as pressure (relief valves) or reverse direction flow (check valves) for fulfillment of the required functions.

Code - As used in this procedure, shall refer to ASME OM Code 2001 Edition with Addenda through 2003.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000

, Page 9 of 134 3.0 DEFINITIONS (continued)

Passive Valves - Valves which maintain obturator position and are not required to change obturator position to accomplish the required functions as specified in Section 1.2.

Preconditioning -The act of exercising or performing maintenance for the purpose of enhancing the results of an inservice test. The act of preconditioning could mask a degrading condition that may otherwise be detected when testing a component in the "as found" condition. NRC Information Notice 97-16 provides guidelines for determining actions which would be considered preconditioning.

Reference Values - One or more values of test parameters measured when the equipment is known to be operating acceptably.

Skid-Mounted Valves - Valves integral to or that support the operation of major components and are generally supplied with the major component. These valves may not necessarily be located directly on the skid.

Thermal Relief Application - A safety relief valve whose only overpressure protection function is to protect isolated components, systems, or portions of systems from fluid expansion caused by changes in fluid temperature.

4.0 Implementation Plan A. The ASME valves subject to testing shall be identified, documented, and the selection controlled by the TVA Calculation SQN-SQTP-003.

B. The ASME Inservice valve testing shall be performed in accordance with ISTC bf the OM Code and approved alternatives such as request for relief and code cases. Pressure Relief Devices including capacity certified check valves shall be tested in accordance with OM Code Appendix I and approved altematives.

C. The ASME Inservice Valve and Pressure Relief Device Tests shall be reviewed and approved by the IST Program Test Engineer.

D. The ASME Inservice Valve and Pressure Relief Device Test records shall be maintained in accordance with ISTC-9000.

5.0 PERFORMANCE 5.1 Valve Exercising and Testing The "Testing Required" column of the Valve Test Table in Appendix A identifies the safety position(s) and the testing required (e.g. CVC, STO, etc.) for valves. This nomenclature is defined in Appendix B.

5.1.1 Power Operated Valves Power operated valves included in the scope of the IST Program are required to be tested to the position(s) required to perform their safety function(s) as listed in TVA Calculation SQN-SQTP-003. For Category A and B power operated valves full stroke exercising shall consist of movement of the valve obturator to both the open and closed positions while timing the indicated duration of valve movement to the safety position(s). Any exercising less than full stroke exercising is considered part stroke exercising.

5.1.2 Check Valves Check valves included in the scope of the IST Program are required to be exercised such that valve obturator movement is demonstrated in both the open and closed direction. Observation may be made by observing a direct indicator, a position indicating device, or by other positive means such as changes in system pressure, flow rate, level, temperature, seat leakage testing, nonintrusive testing results, or by disassembly and inspection.

A. For active check valves having a safety function in the open or open and closed position as defined in TVA Calculation SQN-SQTP-003, testing will demonstrate that upon initiating fluid flow the obturator travels to the full open position, or that the valve is capable of passing the flowrate necessary to fulfill its intended function, and verify that on cessation of flow, or flow reversal, that the obturator travels to the seat.

B. For active check valves having only a safety function in the open position as defined in TVA Calculation SQN-SQTP-003, testing will be by initiating flow and verifying the obturator travels to the full open position, or to the position required to fulfill its intended function, and verify closure.

C. For active check valves having only a safety function in the closed position as defined in TVA Calculation SQN-SQTP-003, testing will be by initiating flow and verifying the obturator travels to the partial open position and verify that on cessation of flow or flow reversal that the obturator travels to the seat.

D. For passive check valves, only LLRT will be performed. Passive check valves are those for which flow is blocked by an upstream valve.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 11 of 134 5.1.3 Relief Valves Relief valves for overpressure protection included in the scope of the IST Program require the following parameters to be tested in the following sequence:

A. Visual inspection.

B. Owner defined seat tightness determination, if practicable.

C. Set pressure determination.

D. Verification of the integrity of the balancing device for balanced valves.

E. Owner defined seat tightness determination.

Thermal relief valves included in the IST Program will be tested as stated above or replaced.

5.2 Valve Seat Leakage Testing Category A valves, or valve combinations, shall have a permissible leakage rate specified by the owner. Valve leakage rates shall be subject to the analysis and corrective action of OM Code (ISTC-3600) and by IOCFR50.55a(b)(2)(vii) for Containment Isolation Valves and TS for Pressure Isolation valves (PIV's). SQN will utilize ISTC 3620 which allows credit to be taken for the Appendix J program for meeting Category A valve leakage requirements for containment isolation valves.

5.3 Fail - Safe Testing For valves designed with a fail-safe function, testing of the valves may be performed by placing the control switch in the open position for fail-open valves, and the closed position for fail-closed valve, when control switch operation results in the loss of actuator power. The fail-safe testing requirements of OM Code ISTC-3560 will be satisfied by the exercising required by paragraph ISTC-3520. Fail-Safe testing will be performed in conjunction with valve stroke time testing.

5.4 Valve Testing Frequency A. When valve testing is required by both plant TS and the ASME OM Code, testing must meet the minimum testing frequency of both requirements. The provisions of Tech Spec 4.0.2 allowing the extension to the specified test frequencies listed in the TS are allowed.

B. When plant conditions restrict the availability of components for testing, testing may be delayed until plant conditions such as start up or shutdown allow for testing. These components will be classified as cold shutdown, or refueling outage frequency, will be listed in Appendix C, Deferred Test Justifications, and will be performed when component(s) are available.

C. Valves tested during power ascension due to maintenance performed during the outage are required to be considered inoperable until required PMT(s) are performed to comply with TS operability requirements.

D. Valves categorized as Category A valves shall be leak tested, except that valves which function in the course of plant operation in a manner that demonstrates functionally adequate seat leak tightness, need not be additionally tested. Leakage testing of Containment Isolation Valves will be performed in accordance with SQN's 10CFR50, Appendix J program. Other Category A valves will be tested in accordance with ISTC 3630.

E. Valves necessary for Reactor Coolant Pump (RCP) operation will be tested during Cold Shutdowns if the RCPs are stopped. The RCPs will not be stopped and then restarted solely to test valves that supply support services to the RCPs. The stopping and starting of RCPs solely to allow valve testing produces unnecessary challenges, wear, stress, and increases the number of cycles on plant equipment. The length of cold shutdown outages may also be extended resulting in undue burden. These valves are coded for a frequency of "RCP" in the Valve Test Table in Appendix A. All the rules for Cold Shutdown testing apply to the RCP frequency. When the plant is ready for RCP startup to support the plant's return to service, the remaining RCP associated tests need not be completed but will be completed in subsequent RCP out of service periods.

F. Valves that are discovered to be out of frequency shall be subject to the requirements of TS 4.0.3 and GL 91-18.

- 5.4.1 Category A and B Power Operated Valves Category A and B Power Operated Valves include air operated valves, solenoid operated valves, and motor operated valves.

A. For Category A and B power operated valves full stroke exercising shall consist of movement of the valve obturator to both the open and closed positions while timing the indicated duration of valve movement to the safety position(s).

B. Full stroke exercising, in the as found condition where practical, during operation to the position(s) require to fulfill its function(s) as noted in Appendix A shall be conducted quarterly (at least once every 92 days) when practicable.

C. When full stroke exercising during operation is not practicable, then part stroke exercising quarterly during operation and full stroke exercising during cold shutdown, when practicable, is required. Timing of valve movement is not required for partial stroke exercising.

D. When exercising during operation is not practicable, then full stroke exercising may be limited to full stroke exercising during cold shutdowns.

E. When exercising during operation and during cold shutdown is not practicable, exercising may be limited to part stroke exercising during cold shut down and full stroke exercising during refueling outages.

F.. When full and partial stroke exercising during operation and during cold shutdown is not practicable, then full stroke exercising shall be performed during each refueling outage. All valves in this category are required to be exercised prior to restart from a refueling outage.

G. Valve exercising is not required more frequently than each 92 days.

H. When valve exercising is not begun within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving the cold shutdown condition, all valves out of frequency must be exercised prior to reactor restart.

I. When valve exercising is started within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving a cold shutdown, exercising may be discontinued when the unit is ready to restart. Once valve exercising has begun, it must continue as plant 6ondibons allow and as valves and personnel are available. Valves selected for exercising should be those outside the 92 day frequency which are available and should start with the available valves having the oldest previous exercising date.

J. During extended shutdowns, all valves required to be operable at startup are required to have been exercised within 92 days.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, &2 Rev. 0000 Page 14 of 134 5.4.1 Category A and B Power Operated Valves (continued)

K. Exercising is required prior to returning to service following maintenance activities which could affect valve performance. Performance of valve exercising following minor packing adjustment within manufacturers torque limits or manual back seating of valves is not required when an engineering evaluation is performed demonstrating that the valve's performance parameters have not been adversely affected. The following are examples of maintenance which could affect valve performance:

1. Adjustment of valve stem packing.

2. Adjustment or replacement of valve operator limit switches.

3. Adjustment or replacement of valve control system.

4. Disassemble of valve, including removal of bonnet, stem assembly, actuator, or control system components.

5. Manually back seating valves.

L. Valve position verification is required to be performed each two years for valves with remote position indicators by comparing local position with the remote indication to verify that the valve operation is accurately indicated and valve operates acceptable. Where visual verification cannot be performed, position verification shall be by other positive means such as flow, pressure, or instrumentation. Where practicable, visual observation should be supplemented by other indications such as pressure, flow, temperature, etc.

The remote position indicator in the main control room and the remote position indicator used for valve exercising and stroke timing will be verified for accuracy. For valves having remote position indicator at multiple locations that include the main control ro) m and the main control room indication is used for exercise testing and strobe timing, then only the main control room remote position indicator is required to be verified for accuracy.

M. Testing of Category A and B motor operated valves will be supplemented by SQN's MOV program.

5.4.2 Category C Valves (Check valves)

A. Open and close exercising during operation, in the as found condition where practical, shall be conducted quarterly, at least once every 92 days, when practicable. The exercising interval is defined as the time that it is practicable to perform both open and close exercising. Open and close exercising is not required to be performed at the same time but must occur within the same interval.

B. When exercising during operation is not practicable, then exercising during cold shutdowns is required.

C. When exercising during operation is not practicable and exercising during cold shutdown is not practicable, exercising shall be performed during refueling outages. All valves in this category are required to be exercised prior to restart from a refueling outage. The NRC has determined that the need to set up test equipment constitutes adequate basis to defer reverse flow testing of a check valve to a refueling outage.

D. Exercising is not required more frequent than each 92 days.

E. When exercising is not begun within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving a cold shutdown, all valves out of frequency are required to be exercised prior to restart.

F. When exercising is started within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving a cold shutdown, exercising may be discontinued when the unit is ready to restart. Once valve exercising has begun, it must continue as plant conditions allow and as valves and personnel are available. Valves selected for exercising should be those outside the 92 day frequency which are available and should start with the available valves having the oldest previous exercise date.

G. When a sample disassemble and inspect program is used to meet testing requirements, one valve from the group must be disassembled and inspected each refueling outage with all valves being inspected within eight years. If failure(s) occur which are applicable to other valves within the group, all valves within the group shall be inspected. Additionally, generic problems applicable to other similar valves shall be evaluated for impact., Following reassembly, a partial opening or a full opening exercise shall be performed as a post maintenance test (PMT) when practicable in addition to any other PMT requirements such as leakage and closure testing.

H. As an alternative to exercising frequency of ISTC, frequency may be established in accordance with a Check Valve Condition Monitoring program in accordance with ISTC 5222 and Mandatory Appendix 11, Check Valve Condition Monitoring Program.

1. Exercising is required following maintenance activities which may affect valve performance.

5.4.3 Manual Valves A. Full stroke exercising to assure valve obturator exhibits required position change is required each two years.

B. Exercising is required following maintenance activities which may affect valve performance.

5.4.4 Pressure Relief Valves The testing frequency of relief valves is defined in IST Mandatory Appendix I.

Valves are grouped by manufacturer, type, system application, and service media.

A. ASME Class 1 valves and Main Steam Safety valves require testing of 20% of each group every 24 months with all valves required to be tested each five years. Fraction of valves shall be counted as whole valves in determining number of valves to be tested. Untested valves for that interval shall be selected prior to previously tested valves when they exist. Failure of selected valves to meet their acceptance criteria requires the selection of two additional valves from that group. If failures occur in the additional sample group, all valves in that group are required to be tested. When a full complement of pretested replacement valves are installed, valves removed from service must be tested within twelve months of removal. When a partial complement of pretested replacement valves are installed, valves removed from service must be tested prior to resumption of electric power generation.

B. ASME Class 2 and 3 valves require testing of 20% of each group every 48 months with all valves required to be tested each ten years. Fraction of valves shall be counted as whole valves in determining number of valves to be tested. Untested valves for that interval shall be selected prior to previously tested valves when they exist. Failure of selected valves to meet their acceptance criteria requires the selection of two additional valves from that group. If failure occurs in the additional sample group, all valves in that group are required to be tested. When a full complement of pretested replacement valves are installed, valves removed from service must be tested within twelve months of removal. When a partial complement of pretested replacement valves are installed, valves removed from service must be tested prior to resumption of electric power generation, or within three months, whichever is later.

C. Class 2 Primary Containment Vacuum breakers require testing each two years, unless performance data suggest the need for more frequent testing. Leakage testing shall be in accordance with SQN's 10CFR 50 Appendix J Program.

5.4.4 Pressure Relief Valves (continued)

D. ASME Class 2 and 3 thermal relief valves determined to be within the scope of the IST program shall be tested each ten years, unless performance data indicate more frequent testing is necessary. In lieu of set point testing, the relief devices may be replaced at a frequency of every ten years, unless performance data indicate more frequent replacements are necessary.

E. Check valves which are used to limit pressure and are capacity certified shall be classified as a relief valve and tested as such.

5.4.5 Pressure Isolation Valves Leakage Testing Leakage testing of Pressure Isolation Valves shall be in accordance with TS 3.4.6.3 and ASME OM Code requirements.

A. Valves must be tested at least once per 18 months.

B. Testing must be performed prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for seven days or more and if leakage testing has not been performed in the previous nine months.

C. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action which puts flow through the valve. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> clock will start after the flow through the valve(s) has been stopped.

Surveillance Requirement 4.4.6.3 and the associated bases allow testing to be delay when plant conditions needed for testing are not available in Modes 3 or 4.

D. Testing should be performed during startup after coming off RHR to eliminate multiple performances due to RHR flow through Cold Leg Primary and Secondary check valves.

E. Testing at low RCS pressure will minimize the personnel safety hazard and will provide a conservative leakage rate resulting in early indication of potential problems.

F. Testing must be performed prior to returning to Mode 2 following maintenance, repair, or replacement work that could affect valve disk seating.

5.5 Deferred Testing Justifications A. When performing quarterly testing on components is not practicable, testing on a cold shutdown or refueling frequency is allowable. Additionally, the Code allows the disassembly of check valves during refueling outages if flow testing cannot be performed. When valves are not exercised on a quarterly frequency, or when check valve disassembly is performed in lieu of flow testing, justification shall be provided by a Deferred Test Justification. Appendix C contains all associated Deferred Test Justifications (DJT). The Valve Test Table contains "DTJ", numbers for Cold Shutdown Justifications, and Refueling Outage Justifications that are contained within Appendix C. In addition, various tests require the Reactor Coolant Pumps to be removed from service. These tests will be performed similar to the cold shutdown tests and are coded "RCPJ" in Appendix C.

B. Typically, Category AC containment isolation check valves cannot be verified closed quarterly or during cold shutdown due to lack of remote position indication, inaccessible locations, no practical means of verifying check valve closure, possible extension of cold shutdown outages, and/or inability to remove the system from service for testing. These valves will be verified closed during refueling outages via the seat leakage test. These valves have a DTJ in Appendix C.

C. If a check valve is included in the Condition Monitoring Program, it will be identified in the test table in Appendix A. The Condition Monitoring Program will control the frequency of testing for those valves.

5.6 Relief Requests In the event that compliance with a specific requirement of IOCFR50.55a or the ASME OM Code is determined; 1) to be impractical and cannot be met; 2) to result in undue difficulty without a compensating increase in quality or safety; or 3) to be less preferred than a specific proposed altemative, then relief may be granted by the NRC. A general request for a group of components may be submitted, or a specific request may be submitted for specific issues. Each relief request should follow the guidance of NEI White Paper, entitled "Standard Format for Relief Requests from Commercial Reactor Licensees Pursuant to 10CFR50.55a", and be identified as to whether the request was approved in the second interval, or whether it is a new relief request. Relief requests are to be submitted prior to the start of the third interval where possible, and not later twelve months following end of the current inspection interval in accordance with 10CFR50.55a(f)(5).

5.7 Test Instrumentation Instrumentation used during testing shall comply with requirements of SQN Measurement and Test Equipment.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 19 of 134 5.8 Power Operated Valves Acceptance Criteria A. Establishing Reference Stroke Time Values Reference valves shall be established when the component is known to be operating acceptably. For the third 10 year inspection interval, power operated valves will utilize the reference stroke time established during the second 10 year interval when available. When reference values do not exist, values will be determined by averaging three stroke times from previous tests or new tests, when available, to establish a baseline stroke time for comparison to subsequent testing as required by ISTC-5122, -5132, -5142, and -5152.

Reference values may be revised with appropriate justification and documentation. Following repair and/or replacement activities which may have affected reference valves, the reference values shall be reconfirmed or a new set of reference values shall be established. Deviations between the previous reference value and the new reference value shall be documented in the record of test.

B. Acceptance Criteria for Power Operated valves

1. Test results shall be compared to the reference values established in accordance with Step 5.8.A above. Table 1 identifies the basis for establishing acceptance criteria for stroke timing.

2. When establishing the acceptance criteria limits, rounding to a tenth of a second shall be done conservatively. Lower limits will be rounded up and upper limits will be rounded down to the tenth of a second. For example, an AOV with reference stroke time of 7.1 seconds; +/- 50 % results in 3.55 to 10.65 seconds. With conservative rounding, the acceptance criteria becomes 3.6 to 10.6 seconds.

5.8 Power Operated Valves Acceptance Criteria (continued)

Table I Allowable Ranges for Valve Stroke Timing Valve Reference Acceptable Alert Required Type Value Range Ranges Action Value Motor Operated t,>10sec 0.85tr to 1.15 t. <0.85 t, >1.30 tr and Note'

>1.15 t to 1.3 tr Motor Operated 0.75tr to 1.25 tr <0.75 tr >1.50 t, tr <1 Osec (or +/-1 sec and Note 1 whichever is >1.25 t to 1.5 tr greater)

Other Power <0.75 tr >1.50 t, Operated Valves tr >1 Osec 0.75tr to 1.25 tr and Note 1

>1.25 trto 1.5 tr Other Power <0.5tr >2 ti Operated Valves tr <10sec 0.50tr to 1.50 tr and Note '

>1.5 tr to 2 tr All Power2 N/A >2.0 sec Operated Valves tr <1.5sec < 2.0 sec Note 1 tr Reference stroke time to tenth of a second 1

The multiplier for the Required Action stroke time value is defined by the Owner. When the design stroke time, as referenced in Tech. Specs., the accident analysis, or other design documents, is more restrictive than the multiplier, then the design stroke time shall be used as the maximum allowed value.

2 The criteria applicable to other power operated valves with a stroke time reference value of

< 10 sec may also be applied to valves with stroke time values < 2 sec.

5.9 Power Operated Valve Test Performance A. Remote Stroke Time

1. The "remote stroke time" is the time required to open/close the valve observed at the valve hand switch.

2. The remote stroke time is measured from the time the valve hand switch is actuated until the initial position light goes out and the final position indicating light is on. Initial and final positions are identified on Valve Data Sheets.

3. The "remote stroke time" shall be recorded to the nearest tenth of a second.

4. The initial stroke time is the official time and is to be recorded as the "remote stroke time."

B. Local Stroke Time

1. The "Local stroke time" is the time required to open/close the valve as observed locally, at the valve, and is applicable to valves without remote indicating systems.

2. The "local stroke time" is measured from the time the hand switch is actuated until the valve travels final position, as specified on Valve Data Sheets, and movement has stopped.

3. The local stroke time shall be recorded to the nearest tenth of a second.

4. The initial stroke time is the official time and is to be recorded as the "local stroke time".

C. If the initial measured valve stroke time falls within the Aert Range, two additional stroke tests are required unless significant euiprnent damage may occur. Failure to perform the additional stroke tests req ires the valve be immediately declared inoperable. If the stroke test time fal s within the Alert Range on the second or third test without falng in the uationge on any test,thenSy Engineering stem must complete caluation within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or the valve is Inoperable. If the seco n dathid test results fall within the acceptance criteria, then the initial devial 9 hall be analyzed and the results documented in the test document.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 22 of 134 5.9 Power Operated Valve Test Performance (continued)

D. If the initial stroke test time falls within the Required Action Range, or fails to demonstrate acceptable performance during testing, then

1. Notify SRO that valve is inoperable for system evaluation.

. R aNOTE Additional stroke testing may be waived when significant equipment damage may occur and the valve is declared inoperable.

2. Repeat stroke test two additional times.

3. Initiate Chronological Test Log (CTL) entry.

4. Initiate corrective action (repair, replacement, or data analysis to determine cause).

5. Retest valve following repairs/replacements.

E. Power Operated valves which fail their acceptance criteria may be placed in their fail safe position and be controlled in that position by an administrative control process. This would allow the component to be classified as an inactive component until removed from the administrative control.

5.10 Manual Valve Exercise A. Manual Valve Stroking is verification that valve will change position when manually manipulated without abnormal/erratic performance. The following actions are required for valves which fail to demonstrate the required change in position.

1. Notify SRO that valve is inoperable for system evaluation.

2. Initiate Chronological Test Log (CTL) entry.

3. Initiate corrective action (repair, replacement, or data analysis to determine cause).

4. Retest valve following repairs/replacements.

B. Manual valves which fail their acceptance criteria may be placed in their safety position and be controlled in that position by an administrative control process.

This would allow the component to be classified as an inactive component until removed from the administrative control.

5.11 Relief Valve Testing Requirements are developed from OMb-2003 Appendix I and approved relief requests.

A. Testing is required in the following sequence:

1. Visual Examination.

2. Seat tightness, if practicable.

3. Set Point determination.

4. Balancing device integrity for valves with bellows.

5. Determination of compliance with SQN established seat tightness criteria.

B. Set point Verification is determined from test actuation using as the test median the fluid to which the valve is subject under operating conditions. Relief valves are required to be tested in the as-found condition with the initial actuation used for determining as-found set point. Acceptance criteria is determined from either +/- 3% of the valve nameplate set pressure or SQN established tolerance limit.

C. Seat Leakage Verification is determined by measuring actual leakage through the valve seat during testing. Specific acceptance values are determined by SQN.

D. Instrument accuracy shall have an overall combined accuracy not to exceed

+/- 1% of the indicated (measured) set point.

E. Personnel performing relief valve testing shall be trained in accordance with SQN requirements.

F. Relief valves that fail to meet their set point or leakage criteria shall be repaired, replaced, and have the results analyzed for cause and effect. Additional valves may be required to be tested as described in Section 5.4.4, Test Frequency.

5.12 Check Valve Testing Category C check valve exercise testing shall be performed in accordance with the following.

A. Bi-directional testing of each check valve is required. The preferred open test is with fluid flow.

B. Open and closed tests are not required to be performed at the same time if they are performed in the same interval. Open and closed tests need only be performed at an interval when it is practicable to perform both tests.

C. Test order shall be determined by SQN. Testing more frequently than required by the Code is acceptable. For example, pump discharge checks may be tested open quarterly in conjunction with the pump test, while the closure test may be performed during refueling.

D. If two check valves are in a series configuration without provisions to verify individual reverse flow closure and the plant safety analysis assumes closure of either valve, but not both, the valve pair may be tested as a unit. If the plant safety analysis assumes that a specific valve or both valves of the pair close to perform the safety function(s), the valve(s) shall be tested to demonstrate individual valve closure. I E. The following action is required for valves which fail to demonstrate the required change of position or fail their leakage acceptance criteria:

1. Notify SRO that valve is inoperable for system evaluation.

2. Initiate Chronological Test Log (CTL) entry.

3. Initiate corrective action (repair, replacement, or data analysis to determine cause).

4. Retest valve following repairs/replacements.

F. Check Valve testing using check valve mechanical exerciser is allowed by ISTC 5220(b), but none are currently installed at SQN.

5.12.1 Check Valve Sample Disassembly Program This test methodology is developed from ISTC 5221 (c) and GL 89-04. Where it is determined to be burdensome to disassemble and inspect all applicable valves each refueling outage, a sample disassembly and inspection plan for groups of valves may be employed. The valves may be grouped and then sampled each refueling in accordance with the following:

A. Grouping of check valves shall be technically justified and shall consider as a minimum, valve manufacturer, design, service, size, materials of construction, and orientation. Each group shall be limited to a maximum of four valves.

Many of these check valves are included in the Condition Monitoring Program, but the grouping option is provided, in the event the valves are removed from CVCMP.

B. Disassembly and inspection to assess check valve operability is limited to valves that cannot practically be exercised by flow or by other positive, non-intrusive means allowed by the Code.

C. Check valves that may have their obturator disturbed before full stroke motion is verified shall be examined to determine if a condition exists that could prevent full opening or reclosure of the obturator. Examples applicable to this consideration are bonnet hung and piston type check valves.

D. One valve from each group shall be selected for testing on a rotating basis each refueling outage. During the disassembly process, the full stroke motion of the obturator shall be verified. Full stroke motion of the obturator shall be reverified immediately prior to completing reassembly.

E. The operability of a check valve may be determined by performing, at the minimum, the following inspections with the valve disassembled:

1. Verify the operability of the valve disk assembly by verifying the disk swings freely on its hinge pin.

2. Inspect all parts for damage or corrosion.

3. Inspect the valve seat and disk for degradation.

F. If the inspection identifies an unsatisfactory or abnormal condition, the valve shall be declared inoperable and either refurbished or replaced. When the condition is determined to be generic to other check valves, corrective action should include those affected components.

G. If practicable, partial or full exercising of the check valve using flow and any addition testing required to meet other requirements, such as leakage and closure testing, is required to be performed following valve reassembly but before returning the valve to service.

5.12.2 Nonintrusive Check Valve Testing Program Nonintrusive testing methods are acceptable other positive means to verify the capability of some valves to open, close, and full stroke provided the testing method used for the valve application has been certified in accordance with the plant quality assurance requirements. When nonintrusive testing is required to verify check valve obturator movement, the valves may be grouped and then sampled each refueling if the following conditions are met:

A. A Group may not consist of more than four valves.

B. Valves must be in similar service (i.e. valves in series with same flow and environment, or valves in parallel with similar flows and environment).

C. Valves must be of the similar in type, system application, and service media.

D. All valves must have had the test position verified nonintrusively under the test flow conditions before sampling can be accepted.

E. The sampling test, addressed in D above, must be performed under similar flow conditions.

F. Personnel performing check valve inspections shall meet SQN training requirements.

G. If the above conditions are met, the testing frequency can then be satisfied by establishing the applicable flow rate and sample testing, on a rotating sequence, one of the valves in each group each refueling outage using nonintrusive techniques. SQN has performed baseline testing of several groups of check valves in both Unit I and 2 in accordance with the NRC guidance in NUREG-1482. Starting with the U2C9 RFO, non-intrusive testing on a sampling basis has been performed on those groups which have had baseline testing performed in accordance with NRC guidance given in NUREG-1482. In the future, other groups can be tested in the same manner. If acceptance criteria for the sample valve is not met, then the other valves in the group will be tested using either non-intrusive techniques or they will be disassembled. Corrective actions will be taken as necessary to ensure that the valve(s) perform as required.

5.12.3 Check Valve Condition Monitoring Program As an alternative to the testing methods listed above, the owner may establish a Check Valve Condition Monitoring Program per ISTC-5222 of the OM Code and the following guidelines. The purpose of this program is to both improve check valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable performance of a select group of check valves. SQN may implement this program on a valve or a group of similar valves.

A. Examples of candidates for improved valve performance are check valves that:

1. Have an unusually high failure rate during inservice testing or operations.

2. Cannot be exercised under normal operating conditions or during shutdown.

3. Exhibit unusual, abnormal, or unexpected behavior during exercising or operation.

4. The Owner elects to monitor for improved valve performance.

B. Examples of candidates for optimization of testing, examination, and preventive maintenance activities are check valves with documented acceptable performance that:

1. Have had their performance improved under the Condition Monitoring Program.

2. Cannot be exercised or are not readily exercised during normal operating conditions or during shutdowns.

3. Can only be disassembled and examined.

4. The Owner elects to optimize all the associated activities of the valve or valve group in a consolidated program.

C. The program shall be implemented in accordance with Appendix II,Check Valve Condition Monitoring Program, of the OM Code. Additionally, the program must comply with the modifications to Appendix II as specified in 10 CFR 50.55a(b)(3)(iv).

5.12.3 Check Valve Condition Monitoring Program (continued)

D. The initial interval for tests and associated examinations may not exceed two fuel cycles or three years which ever is longer. Any extension to this interval may not exceed one fuel cycle per extension with the maximum interval not to exceed 16 years. Trending and evaluation of existing data must be used to reduce or extend the time interval between tests and associated examinations.

When a Condition Monitoring Program Plan consists of multiple activities performed at different frequencies the allowable extension of a single activity may deviate from the preceding extension allowable duration, but in no case exceed 16 years.

E. If the OM Code Appendix II condition monitoring program for a valve or valve group is discontinued then the requirements of ISTC must be implemented.

5.13 Pressure Isolation Check Valves Testing Components identified as Pressure Isolation Valves shall meet Technical Specification leakage requirements.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 29 of 134 6.0 RECORDS 6.1 Inservice Test Plans A record of test plans and procedures shall be maintained which shall include the following:

A. identification of valves subject to test.

B. Category of each valve.

C. Tests to be performed.

D. Justification for deferral of stroke testing in accordance with ISTC-3520.

6.2 Record of Tests A record of each test shall be maintained which shall include the following:

A. Valve identification.

B. Date of test.

C. Reason for test (e.g., post maintenance testing, routine inservice test, establishing reference values, etc.).

D. Values of measured parameters.

E. Identification of instruments used..

F. Comparisons with allowable ranges of test values and analysis of deviations.

G. Requirement for corrective action.

H. Signature of the person or persons responsible for conducting and analyzing the test.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, &2 Rev. 0000 Page 30 of 134 6.3 Record of Corrective Action Records of corrective actions shall be maintained which shall include the following:

NOTE These records are maintained with the scope of the SQN Corrective Action Program, Maintenance Program, and Test program.

A. A summary of corrective actions made for valves which fail to meet their acceptance criteria.

B. The subsequent Inservice Test and confirmation of operational adequacy.

C. The signature of the individual(s) responsible for corrective action and verification of results.

6.4 Record of Relief Requests, Deferred Test Justifications, and Technical Positions A. Relief Requests (RV), if any, shall be incorporated as part of this procedure in Appendix D.

B. Relief Requests will be prepared and approved in accordance with the guidance of NEI White Paper, Entitled "Standard Format for Relief Requests from Commercial Reactor Licensees Pursuant to IOCFR50.55a" and SPP 9.1.

C. Deferred Test Justifications (DTJ) shall be incorporated as part of this procedure in Appendix C.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 31 of 134 Appendix A (Page 1 of 67)

ASME VALVES System: 1 Main Steam Drawing No: 47W801-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Remarks Number Class Coord. Category Size Type_ Ty Position Testing Required Request Remarks RFV-1-512 2 F-3 C-ACT 6 RV SA C RVWRVF RFV 1-513 2 F-2 C-ACT 6 RV SA C RV/RVF RFV 1-514 2 F-2 C-ACT 6 RV SA C RV/RVF RFV 1-515 2 F-2 C-ACT 6 RV SA C RV/RVF RFV 1-516 2 F-2 C-ACT 6 RV SA C RV/RVF RFV 1-517 2 D-3 C-ACT 6 RV SA C RWRVF.

RFV 1-518 2 D-2 C-ACT 6 RV SA C RV/RVF RFV 1-519 2 D-2 C-ACT 6 RV SA C RV/RVF RFV 1-520 2 D-2 C-ACT 6 RV SA C RV/RVF _

RFV 1-521 2 D-2 C-ACT 6 RV SA C RV/RVF .

RFV 1-522 2 C-3 C-ACT 6 RV SA C RV/RVF RFV 1-523 2 C-3 C-ACT 6 RV SA C RV/RVF RFV 1-524 2 C-2 C-ACT 6 RV SA C RV/RVF _____

RFV 1-525 2 C-2 C-ACT 6 RV SA C RV/RVF RFV 1-526 2 C-2 C-ACT 6 RV SA C RV/RVF RFV 1-527 2 A-3 C-ACT 6 RV SA C RV/RVF RFV 1-528 2 A-3 C-ACT 6 - RV SA C RV/RVF RFV 1-529 2 A-2 C-ACT 6 RV SA C RV/RVF RFV 1-530 2 A-2 C-ACT 6 RV SA C RV/RVF RFV 1-531 2 A-2 C-ACT 6 RV SA C RVWRVF .

1-619 2 C-2 B-ACT 6 GT M 0 MS/2Y

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 32 of 134 Appendix A (Page 2 of 67)

ASME VALVES System: 1 Main Steam Drawing No: 47W801-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Request 1-620 2 E-2 B-ACT 6 GT M 0 MS/2Y 1-621 2 F-2 B-ACT 6 GT M 0 MS/2Y ____

1-622 2 A-2 B-ACT 6 GT M 0 MS/2Y FSC/CSD, */RO, FCV-1-1 1 2 E-3 B-ACT 32 GB CYL 0 STC/CSD DTJ-1, -INDIVIDUAL TRAIN SOLENOID TEST FCV-1-147 2 C-3 B-ACT 2 GB DIA C STCIQ, FSC/Q FCV-1-148 2 E-3 B-ACT 2 GB DIA C STC/Q, FSC/Q FCV-1-149 2 G-3 B-ACT 2 GB DIA C STC/Q, FSC/Q FCV-1-150 2 B-3 B-ACT 2 GB DIA C STC/Q, FSC/Q FSC/CSD, */RO, FCV-1-22 2 G-3 B-ACT 32 GB CYL 0 STC/CSD DTJ-1, -INDIVIDUAL TRAIN SOLENOID TEST FSC/CSD, */RO, FCV-1-29 2 A-3 B-ACT 32 GB CYL 0 STCJCSD DTJ-1, -INDIVIDUAL TRAIN SOLENOID TEST FSC/CSD, **/RO, FCV-1-4 2 C-3 B-ACT 32 GB CYL 0 STC/CSD DTJ-1, **INDIVIDUAL TRAIN SOLENOID TEST STC/CSD, PCV-1 -12 2 D-2 BC-ACT 8 GB DIA C FSC/CSD DTJ-4 STC/CSD, PCV-1-23 2 F BC-ACT 8 GB DIA C FSC/CSDI DTJ-4 STC/CSD, PCV-1-30 2 A-2 ---- -BC-ACT C : 8: GB DIA C FSC/CSD DTJ-4 STC/CSD, PCV-1-5 2 B-2 BC-ACT 8 GB DIA C FSC/CSD DTJ-4

Appendix A (Page 3 of 67)

ASME VALVES System: 1 Main Steam/Blowdown Drawing No: 47W801-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Testi Req*ied Relief Re k Number Class Coord. Category Size Type Type Position Teng Require Rues emarks FCV-1-14 2 E-3 B-ACT 2 GB DIA 0 STC/Q, FSC/Q FCV-1-181 2 C-2 B-ACT 2 GB DIA 0 STC/Q, FSC/Q FCV-1-182 2 E-2 B-ACT 2 GB DIA 0 STC/Q, FSC/Q FCV-1-183 2 F-2 B-ACT 2 GB DIA 0 STC/Q, FSC/Q FCV-1-184 2 B-2 B-ACT 2 GB DIA 0 STC/Q, FSC/Q FCV-1-25 2 F-3 B-ACT 2 GB DIA 0 STC/Q, FSC/Q FCV-1-32 2 B-3 B-ACT 2 GB DIA 0 ,TCIQ FSC/Q FCV-1-7 2 C-2 B-ACT 2 GB DIA 0 ,TCIQ FSC/Q

Appendix A (Page 4 of 67)

ASME VALVES System: 1 Main Steam/Blowdown Drawing No: 47W803-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 1-FCV-1-15 2 C-9 B-ACT 4 GT MO 0 STC/Q, STO/Q 1-FCV-1-16 2 A-9 B-ACT 4 GT MO C STC/Q, STO/Q 1-FCV-1-17 3 C-7 B-ACT 4 GT MO 0 STC/CSD DTJ-3 1-FCV-1-18 2 C-7 B-ACT 4 GT MO 0 STC/CSD DTJ-3 1-FCV-1-51 3 H-7 B-ACT 3 GB MO C STO/Q 2-FCV-1-15 2 C-3 B-ACT 4 GT MO 0 STC/Q, STO/Q 2-FCV-1-16 2 A-3 B-ACT 4 GT MO C STC/Q, STO/Q 2-FCV-1-17 3 B-4 B-ACT 4 GT MO 0 STC/CSD DTJ-3 2-FCV-1-18 2 B-4 B-ACT 4 GT MO 0 STC/CSD DTJ-3 2-FCV-1-51 3 B-6 B-ACT 3 GB MO C STO/Q  :.__

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 35 of 134 Appendix A (Page 5 of 67)

ASME VALVES System: 3 Feedwater Drawing No: 47W803-1 Valve ASME Drawing Valve Valve Valve Actuator Normal t- . Relief Remks Number Class Coord. Category Size Type Type Position Testing Required Request mar 3-508 2 F-2 C-ACT 16 CK SA - CVC/CSD, BDO/NO DTJ-5 3-509 2 E-2 C-ACT 16 CK SA CVC/CSD, BDO/NO

- DTJ-5 3-510 2 C-2 C-ACT 16 CK SA CVC/CSD, BDO/NO

- DTJ-5 3-511 2 B-2 C-ACT 16 CK SA CVC/CSD, BDO/NO

- DTJ-5 FCV-3-100 2 B-3 B-ACT 18 GT MO 0 STCICSD DTJ-5 FCV-3-33 2 D-3 B-ACT 18 GT MO 0 STC/CSD DTJ-5 FCV-3-47 2 E-3 B-ACT 18 GT MO 0 STC/CSD DTJ-5 FCV-3-87 2 F-3 B-ACT 18 GT MO 0 STC/CSD_ DTJ-5

- SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 36 of 134 Appendix A (Page 6 of 67)

ASME VALVES System: 3 Auxiliary Feedwater Drawing No: 47W803-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Test *ued Relief Re k Number Class Coord. Category Size Type Type Position esing Requir Request emars 1-3-805 3 F-5 C-ACT 8 CK SA C CVO/HSD, CVC/RO DTJ-6 1-3-806 3 F-6 C-ACT 8 CK SA C CVO/HSD, CVCIRO DTJ-6 1-3-810 3 H-4 C-ACT 10 CK SA C CVO/HSD, CVC/RO DTJ-6 1-3-814 3 G-5 C-ACT 1-112 CK SA - CVOIQ, BDCIRO DTJ-36 1-3-815 3 G-6 C-ACT 1-1/2 CK SA - CVO/Q, BDC/RO DTJ-36 1-3-818 3 G-7 C-ACT 1-1/2 CK SA - CVO/Q, BDC/RO DTJ-36 1-3-820 3 F-5 C-ACT 6 CK SA - CVO/HSD, BDC/RO DTJ-36 1-3-821 3 F-6 C-ACT 6 CK SA - CVO/HSD, BDC/RO DTJ-36 1-3-830 2 G-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-831 2 E-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-832 2 D-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-833 2 A-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-861 2 G-10 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-862 2 E-10 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-864 3 H-6 C-ACT 6 CK SA - CVO/HSB, BDC/RO DTJ-36 1-3-871 2 F-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-872 2 D-8 C-ACT 4 CK SA - ICVC/DIF, CV0IHSB CMP 1-3-873 2 C-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB_ CMP 1-3-874 2 A-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB I _CMP

Appendix A (Page 7 of 67)

ASME VALVES System: 3 Auxiliary Feedwater Drawing No: 47W803-2 Valve ASME Drawing Valve Valve Valve Actuator Normal . . Relief Number Class Coord. Category Size Type Type Position Testng Required Request Remarks 1-3-891 2 C-8 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 1-3-892 2 A-8 C-ACT 4 CK SA - CVCIDIF, CVO/HSB CMP 1-3-921 2 G-10 C-ACT 4 CK SA C CVC/DIF, CVO/HSB CMP 1-3-922 2 E-10 C-ACT 4 CK SA C CVC/DIF, CVO/HSB CMP 1-FCV-3-116A 3 G-6 B-ACT 8 GT MO C STO/Q 1-FCV-3-116B 3 F-6 B-ACT 8 GT MO C STO/Q 1-FCV-3-126A 3 G-7 B-ACT 8 GT MO C STO/Q 1-FCV-3-126B 3 F-7 B-ACT 8 GT MO C STOIQ 1-FCV-3-136A 3 H-4 B-ACT 10 GT MO C STOIQ, STC/Q 1-FCV-3-136B 3 H-4 B-ACT 10 GT MO C STOIQ, STC/Q 1-FCV-3-179A 3 H-5 B-ACT 10 GT MO C STOIQ 1-FCV-3-179B 3 H-5 B-ACT 10 GT MO C STO/Q 1-FCV-3-400 3 F-5 B-ACT 2 GB DIA C STC/Q 1-FCV-3-401 3===-=-F-6.--- .=B-ACT 2 GB DIA C STC/Q FSO/Q, STO/Q, 1-LCV-3-148 3 G-8 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 1-LCV-3-148A 3 G-8 B-ACT 2 GB DIA C STC/Q FSO/Q, STOIQ, 1-LCV-3-156 3- E - B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 1-LCV-3-156A 3 E-8 B-ACT 2 GB DIA C STC/Q

Appendix A (Page 8 of 67)

ASME VALVES System: 3 Auxiliary Feedwater Drawing No: 47W803-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Reque Remarks FSO/Q, STO/Q, 1-LCV-3-164 3 D-8 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 1-LCV-3-164A 3 D-8 B-ACT 2 GB DIA C STC/Q j_l-FSOIQ, STO/Q, I-LCV-3-171 3 B-8 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 1-LCV-3-171A 3 B-8 B-ACT 2 GB DIA C STC/Q -

FSO/Q, STO/Q, 1-LCV-3-172 3 F-8 B-ACT 3 GB DIA C STCIQ FSO/Q, STO/Q, 1-LCV-3-173 3 E-8 B-ACT 3 GB DIA C STC/Q FSO/Q, STO/Q, 1-LCV-3-174 3 C-8 B-ACT 3 GB DIA C STC/Q FSOIQ, STO/Q, 1--LCV-3-175 3 A-8 B-ACT 3 GB DIA C STC/Q 2-3-805 3 D-5 C-ACT 8 CK SA C CVO/HSD, CVC/RO DTJ-6 2-3-806 3 D-6 C-ACT 8 CK SA C CVO/HSD, CVC/RO DTJ-6 2-3-810 3 C-4 C-ACT 10 CK SA C CVO/HSD, CVC/RO DTJ-6 2-3-814 3 E-5 C-ACT 1-1/2 CK SA CVO/Q, BDC/RO DTJ-36 2-3-815 3 E-6 C-ACT 1-1/2 CK SA CVO/Q, BDC/RO DTJ-36 2-3-818 3 C-6 C-ACT 1-1/2 CK SA CVO/Q, BDC/RO DTJ-36 2-3-820 3 E-5 C-ACT 6 CK SA CVO/HSD, BDC/RO DTJ-36 2-3-821 3 E-6 C-ACT 6 CK SA CVO/HSD, BDC/RO DTJ-36 2-3-830 2 G-3 C-ACT 4 CK SA _CVC/DIF, CVO/HSB CMP

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 39 of 134 Appendix A (Page 9 of 67)

ASME VALVES System: 3 Auxiliary Feedwater Drawing No: 47W803-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Remarks Number Class Coord. Category Size Type Type Position Request 2-3-831 2 E-3 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP

_-3-832 2 D-3 C-ACT 4 _ K SA - CVC/DIF, CVOHSB CMP 2-3-833 2 D-3 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 2-3-861 2 G-1 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 2-3-862 2 E-1 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 864 3 C-.6 C-ACT 6 CK SA - CVO/HSB, BDC/RO DTJ-36 2-3-871 2 F-3 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 2-3-872 2 E-3 C-ACT 4 CK SA - CVCIDtF, CVO/HSB CMP 2-3-873 2 C-3 C-ACT 4 CK SA - CVCIDIF, CVO/HSB CMP 874 2 A-3 C-ACT 4 CK SA - CVC/DIF, CVO.HSB CMP 2-3-891 2 C-3 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 2-3-892 2 A-3 C-ACT 4 CK SA - CVC/DIF, CVO/HSB CMP 2-3-921 2 G-1 C-ACT 4 CK SA C CVC/DIF, CVO/HSB CMP 2-3-922 2 A-1 C-ACT 4 CK SA C CVC/DIF, CVO/HSB CMP 2-FCV-3-116A 3 E-6 B-ACT 8 GT MO C STO/Q 2-FCV-3-116 3 A-6 B-ACT 8 GT MO C STO/IQ 2-FCV-3-126A 3 E-7 B-ACT 8 GT MO C STOIQ 2-FCV-3-126B 3 E-7 B-ACT 8 GT MO C STO/Q 2-FCV-3-136A 3 C-4 B-ACT 10 GT MO C STO/Q, STC/Q 2-FCV-3-136B 3 CA B-ACT 10 GT MO C STO/Q, STCIQ 2-FCV-3-179A 3 C-5 B-ACT 10 GT MO C STO/Q .

Appendix A (Page 10 of 67)

ASME VALVES System: 3 Auxiliary Feedwater Drawing No: 47W803-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 2-FCV-3-179B 3 C-5 B-ACT 10 GT MO C STO/Q 2-FCV-3-400 3 E-5 B-ACT 2 GB DIA C STC/Q 2-FCV-3-401 3 D-6 B-ACT 2 GB DIA C STC/Q FSO/Q, STO/Q, 2-LCV-3-148 3 G-3 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 2-LCV-3-148A 3 G-3 B-ACT 2 GB DIA C STC/Q FSO/Q, STO/Q, 2-LCV-3-156 3 E-3 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 2-LCV-3-156A 3 E-3 B-ACT 2 GB DIA C STC/Q FSO/Q, STO/Q, 2-LCV-3-164 3 D-3 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 2-LCV-3-164A 3 D-3 B-ACT 2 GB DIA C STC/Q FSO/Q, STO/Q, 2-LCV-3-171 3 B-3 B-ACT 4 GB DIA C STC/Q FSC/Q, STO/Q, 2-LCV-3-171A 3 B-3 B-ACT 2 GB DIA C STC/Q FSO/Q, STOIQ, 2-LCV-3-172 3 F-3 B-ACT 3 GB DIA C STC/Q FSO/Q, STOIQ, 2-LCV-3-173 3 E-3 B-ACT 3 GB DIA C STC/Q FSO/Q, STO/Q, 2-LCV-3-174 3 C-3 B-ACT 3 GB DIA C STC/Q

. FSO/Q, STO/Q, 2-LCV-3-175 3 A-3 B-ACT 3 GB DiA C STC/Q____________________

Appendix A (Page 11 of 67)

ASME VALVES System: 26 Fire Protection Drawing No: 47W850-10 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 26-1260 2 A-10 AC-PAS 4 CK SA C SLTJ/J 26-1296 2 B-3 AC-PAS 4 CK SA C SLTJ/J FCV-26-240 2 A-9 ' A-ACT 4 GT MO 0 STC/Q, SLTJ/J FCV-26-243 2 B-3 A-ACT 4 GT MO 0 STC/Q, SLTJ/J I I

Appendix A (Page 12 of 67)

ASME VALVES System: 30 Heating and Ventilation (Air) Drawing No: 47W866-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Categor Size Type Type Position Testing Required Request Remarks 1-30-571 2 B-4 AC-ACT 24 CK SA C RWRVF, SLTJ/J 1-30-572 2 B-5 AC-ACT 24 CK SA C RV/RVF, SLTJ/J 1-30-573 2 B-7 AC-ACT 24 CK SA C RV/RVF, SLTJ/J FSC/Q STC/Q, FCV-30-10 2 C-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-14 2 E-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-15 2 E-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-16 2 F-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-17 2 F-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-19 2 G-2 A-ACT 12 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-20 2 G-2 A-ACT 12 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-37 2 D-10 A-ACT 8 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-40 2 D-9 A-ACT 8 BF CYL C SLTJ/J STO/Q, FSO/Q INDIVIDUAL TRAIN A AND B HANDSWITCH FCV-30-46 2 B-4 A-ACT 24 BF CYL C STC/Q, SLTJ/J TEST STOIQ, FSO/Q INDIVIDUAL TRAIN A AND B HANDSWITCH FCV-30-47 2 B-6 A-ACT 24 BF CYL C STC/Q, SLTJ/J TEST

Appendix A (Page 13 of 67)

ASME VALVES System: 30 Heating and Ventilation (Air) Drawing No: 47W866-1 Valve ASME Drawing Valve Valve Valve Actuator Normal . . Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks STO/Q, FSO/Q INDIVIDUAL TRAIN A AND B HANDSWITCH FCV-30-48 2 B-7 A-ACT 24 BF CYL C STC/Q, SLTJ/J TEST FSC/Q STC/Q, FCV-30-50 2 C-9 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-51 2 C-10 l A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-52 2 C-9 A-ACT 24 BF CYL C SLTJ/J FSCiQ STC/Q, FCV-30-53 2 C-10 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-56 2 E-9 A-ACT 24 BF CYL C SLTJ/N FSC/Q STC/Q, FCV-30-57 2 E-10 A-ACT 24 BF CYL C SLTJ/J FSCiQ STC/Q, FCV-30-58 2 G-9 A-ACT 12 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-59 2 G-10 A-ACT 12 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-7 2 C-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-8 2 C-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FCV-30-9 2 C-2 A-ACT 24 BF CYL C SLTJ/J FSC/Q STC/Q, FSV-30-134 2 F-9 A-ACT 3/8 GB SO 0 SLTJ/J FSC/Q STC/Q, FSV-30-135 2 F-10 A-ACT 3/8 GB SO 0 SLTJ/J _

Appendix A (Page 14 of 67)

ASME VALVES System: 31 Heating and Ventilation (Water) Drawing No: 47W865-5 Valve ASME Drawing Valve Valve Valve Actuator Normal Tet- Re*ied Relief Remarks Number Class Coord. Category Size Type Type Position esting equir Request CVC/RO, CVO/RO, 31 C-697 2 F-8 AC-ACT 1/2 SC SA C SLTJ/J CMP CVC/RO, CVO/RO, 31 C-715 2 E-8 AC-ACT 1/2 SC SA C SLTJ/J CIMP

. CVC/RO, CVO/RO, 31 C-734 2 C-8 AC-ACT 1/2 SC SA C SLTJUJ CMP CVC/RO, CVO/RO, 31 C-752 2 B-8 AC-ACT 1/2 SC SA C SLTJ/J CMP FCV-31C-222 2 A-7 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J FCV-31C-223 2 A-8 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J FCV-31 C-224 2 C-7 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J FCV-31 C-225 2 C-8 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J FCV-31C-229 2 D-7 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J FCV-31C-230 2 D-8 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J FCV-31C-231 2 F-7 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J UM__ _

FCV-31C-232 2 F-8 A-ACT 2 PLG DIA 0 STC/Q, SLTJ/J System: 31 Heating and Ventilation (Water) Drawing No: 47W865-8 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 0-31C-1 027 3 E-3 C-ACT 6 SC SA 0 CVO/Q, BDC/RO DTJ-34 0-31C-985 3 E-8 C-ACT 6 SC SA 0 CVO/Q, BDC/RO DTJ-34

Appendix A (Page 15 of 67)

ASME VALVES System: 32 Control Air Drawing No: 47W848-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size T Position Testing Required equestemarks CVC/RO, BDO/NO, 1-32-287 2 C-10 AC-ACT 2 CK SA C SLTJ/J CMP CVC/RO, BDO/NO, 1-32-297 2 D-10 AC-ACT 2 CK SA C SLTJ/J CMP CVC/RO, BDO/NO, 1-32-377 2 A-10 AC-ACT 2 CK SA C SLTJ/J CMP FSC/CSD, STO/CSD, 1-FCV-32-102 2 D-9 A-ACT 2 GB DIA 0 STC/CSD, SLTJ/J DTJ-10 FSC/CSD, STOICSD, 1-FCV-32-1 10 2 A-9 A-ACT 2 GB DIA 0 STC/CSD SLTJ/J . DTJ-10 FSC/CSD, STO/CSD, 1-FCV-32-80 2 C-9 A-ACT 2 GB DIA 0 STC/CSD, SLTJ/J DTJ-10 CVC/RO, BDO/NO 2-32-348 2 F-10 AC-ACT 2 CK SA C SLTJ/J CMP CVC/RO, BDO/NO 2-32-358 2 G-10 AC-ACT 2 CK SA C SLTJ/J CMP CVC/RO, BDO/NO 2-32-387 2 H-10 AC-ACT 2 CK SA C SLTJ/J CMP

Appendix A (Page 16 of 67)

ASME VALVES System: 32 Control Air Drawing No: 47W848-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request FSC/CSDSTO/CSD 2-FCV-32-103 2 F-9 A-ACT 2 GB DIA 0 STC/CSD,SLTJ/J DTJ-10 FSCICSD,STOICSD 2-FCV-32-111 2 H-9 A-ACT 2 GB DIA 0 STC/CSD,SLTJ/J DTJ-10 FSC/CSD,STO/CSD 2-FCV-32-81 2 G-9 A-ACT 2 GB DIA 0 STC/CSD,SLTJ/J DTJ-10

Appendix A (Page 17 of 67)

ASME VALVES System: 43 Sampling Drawing No: 47W881-5 Valve ASME Drawing Valve Valve Valve Actuator Normal . . Relief Number Class Coord. Category Size Type Type Position Testng Required Remarks FSV-43-2 2 E-4 A-ACT 3/8 GB SO 0 FSC/Q STC/Q SLTJ/J 1'-FSV-43-3 2 F-3 A-ACT 3/8 GB SO 0 FSC/Q STC/Q SLTJ/J _ _

2-FCV-43-3 2 F-3 A-ACT 3/8 GB DIA 0 FSC/Q STCIQ SLTJ/J FSV-43-11 2 E-4 A-ACT 3/8 GB SO C FSC/Q STC/Q SLTJ/J 1-FSV-43-12 2 F-2 A-ACT 3/8 GB SO C FSC/Q STC/Q SLTJ/J 2-FCV-43-12 2 F-2 A-ACT 3/8 GB DIA C FSC/Q STC/Q SLTJ/J FSV-43-22 2 C-1 A-ACT 3/8 GB SO 0 FSCIQ STC/Q SLTJ/J 1-FSV-43-23 2 E-I A-ACT 3/8 GB SO 0 FSC/Q STC/Q SLTJ/J .

2-FCV-43-23 2 E-1 A-ACT 3/8 GB DIA 0 FSC/Q STC/Q SLTJ/J 1-FCV-43-30 2 C-6 B-PAS 3/8 GB DIA C RPI - _

1-FCV-43-31 2 C-B B-PAS 3/8 GB DIA C RPI i-FCV-43-32 2 C-B B-PAS 3/8 GB DIA C RPI I-FCV-43-33 2 C-  :- B-PAS 3/8 GB DIA C RPI 1-FSV-43-34 2 D-B A-ACT 3/8 GB SO C FSC/Q STC/Q SLTJ/J 1-FSV-43-35 2 D-B A-ACT 3/8 GB SO C FSC/Q STC/Q SLTJ/J _

1-FSV-43-55 2 C-8 B-ACT 3/8 GB SO 0 FSC/Q STC/Q  :

i-FSV-43-58 2 C-8 B-ACT 3/8 GB SO 0 FSCIQ STCIQ 1-FSV-43-61 2 C-9 B-ACT 3/8 GB SO 0 FSC/Q STC/Q _

1-FSV-43-64 2 C-8 B-ACT 3/8 GB SO 0 FSC/Q STC/Q

Appendix A (Page 18 of 67)

ASME VALVES System: 43 Sampling Drawing No: 47W881-5-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Ty Type Position Testing Required Request Remarks 2-FCV-43-30 2 B-2 B-PAS 3/8 GB DIA C RPI 2-FCV43-31 2 B-2 B-PAS 3/8 GB DIA C RPI 2-FCV-43-32 2 B-2 B-PAS 3/8 GB DIA C RPI 2-FCV-43-33 2 B-3 B-PAS 3/8 GB DIA C RPI 2-FCV-43-35 2 C-2 A-ACT 3/8 GB DIA C FSC/Q STC/Q SLTJ/J 2-FSV-43-34 2 C-2 A-ACT 3/8 GB SO C FSC/Q STC/Q SLTJ/J

-FSV-43-55 2 B4 B-ACT 3/8 GB SO 0 FSC/Q STC/Q

-FSV-43-58 2 B-5 B-ACT 3/8 GB SO 0 FSC/Q STC/Q

-FSV43-61 2 B-5 B-ACT 3/8 GB SO 0 FSC/Q STC/Q

-FSV-43-64 2 B-6 B-ACT 3/8 GB SO 0 FSC/Q STC/Q

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 49 of 134 Appendix A (Page 19 of 67)

ASME VALVES System: 43 Sampling Drawing No: 47W881-6 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 1-43-460 2 K-2 A-PAS 1/2 CK SA C SLTJtJ 1-43-461 2 K-8 AC-PAS 1/2 CK SA C SLTJ/J STC/CSD, 1-FSV-43-250 2 C-2 A-ACT 3/8 GB SO C FSC/CSD, SLTJ/J DTJ-1 I STC/CSD, 1-FSV-43-251 2 B-2 A-ACT 3/8 GB SO C FSC/CSD, SLTJ/J DTJ-1 1 STC/CSD, 1-FSV-43-309 2 C-3 A-ACT 3/8 GB SO C FSC/CSD, SLTJ/J DTJ-11 STC/CSD, 1-FSV-43-310 2 B-3 A-ACT 3/8 GB SO C FSC/CSD, SLTJ/J DTJ-11 STC/CSD, 1-FSV-43-317 2 K-7 A-ACT 3/8 GB SO C FSC/CSD, SLTJ/J DTJ-1 1 STC/CSD, 1-FSV-43-341 2- -. 2 K-7 A-ACT 3/8 GB SO C FSC/CSD, SLTJ/J DTJ-1 1 2-43-460 2 K-2 A-PAS 1/2 CK SA C SLTJ/J 461 2- -8 AC-PAS 1/2 CK SA C SLTJ/J

Appendix A (Page 20 of 67)

ASME VALVES System: 43 Sampling Drawing No: 47W866-6 Valve ASME Drawing Valve Valve Valve Actuator Normal Required Relief Remarks Number Class Coord. Category Size Type Type Position TestingReques STC/CSD, FSC/CSD, 2-FSV-43-250 2 B-2 A-ACT 3/8 GB SO C SLTJ/J DTJ-11 STC/CSD, FSC/CSD 2-FSV-43-251 2 B-2 -ACT 3/8 GB SO C SLTJ/J DTJ-11 STC/CSD, FSC/CSD, 2-FSV-43-309 2 B-3 A-ACT 3/8 GB SO C SLTJ/J DTJ-11 STC/CSD, FSC/CSD, 2-FSV-43-310 B-3 A-ACT 3/8 GB SO C SLTJ/J DTJ-11 STC/CSD, FSC/CSD, 2-FSV-43-317 2 K-7 -ACT 3/8 GB SO C SLTJ/J DTJ-11 STC/CSD, FSC/CSD, 2-FSV-43-341 2 .K-7 A-ACT 3/8 GB SO C SLTJ/J DTJ-11

Appendix A (Page 21 of 67)

ASME VALVES System: 43 Sampling Drawing No: 47W881-8 Valve ASME Drawing Valve Valve Valve Actuator Normal T Relief Number Class Coord. Category Size Type Type Position Testng Required Request Remarks 1-FSV-43-201 2 D-2 A-PAS 3/8 GB SO C RPI SLTJ/J 1-FSV-43-202 2 A-1 A-PAS 3/8 GB SO C RPI SLTJ/J 1-FSV-43-450 2 C-1 A-PAS 3/8 GB SO C RPI SLTJ/J 1-FSV-43-451 2 C-I A-PAS 3/8 GB SO C RPI SLTJ/J 1-FSV-43-452 2 C-6 A-PAS 3/8 GB SO C RPI SLTJ/J 1-FSV43453 2 B-6 A-PAS 3/8 GB SO C RPI SLTJ/J FSV-43-200A 2 .- G-3 A-PAS 3/8 GB so C RPI SLTJ/J 2-FSV-43-201 2 H-2 A-PAS 3/8 GB SO C RPI SLTJ/J 2-FSV43-202 2 E-1 A-PAS 3/8 GB so C RPI SLTJ/J 2-FSV-43-210A 2 G-7 A-PAS 3/8 GB SO C RPI SLTJ/J FSV43-207 2 D-7 A-PAS 3/8 GB SO C RPI SLTJ/J FSV43-208 2 A- A-PAS 3/8 GB SO C RPI SLTJ/J U

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 52 of 134 Appendix A (Page 22 of 67)

ASME VALVES System: 61 Ice Condenser Drawing No: 47W809-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Tet- Re*rd Relief ks Number Class Coord. Category Size Type Type Position esting equire Request Remar CVC/RO BDO/RO 61-533 2 A-5 AC-ACT 1/2 SC SA C SLTJ/J CMP CVC/RO BDO/RO 61-680 2 B-5 AC-ACT 1/2 SC SA C SLTJ/iJ CMP CVC/RO BDO/RO 61-692 2 G-10 AC-ACT 3/8 SC SA C SLTJ/J CMP CVC/RO BDO/RO 61-745 2 H-10 AC-ACT 3/8 SC SA C SLTJ/J CMP FSC/Q STC/Q, FCV-61 -110 2 H-10 A-ACT 2 DIA DIA 0 SLTJ/J FSC/Q STC/Q, FCV-61-122 2 H-9 A-ACT 2 DIA DIA 0 SLTJ/J FSC/Q STC/Q, FCV-61-191 2 A-5 A-ACT 4 DIA DIA 0 SLTJ/J.

FSC/Q STC/Q, FCV-61-192 2 A-6 A-ACT 4 DIA DIA 0 SLTJ/J FSC/Q STC/Q, FCV-61-193 2 B-5 A-ACT 4 DIA DIA 0 SLTJ/J .

FSC/Q STC/Q, FCV-61-194 2 B-6 A-ACT 4 DIA DIA 0 SLTJ/J FSC/Q STC/Q, FCV-61-96 2 G-9 A-ACT 2 DIA DIA 0 SLTJ/J FSC/Q STC/Q, FCV-61-97 2 G-10 A-ACT 2 DIA DIA 0 SLTJ/J

Appendix A (Page 23 of 67)

ASME VALVES System: 62 Chemical Volume and Control Drawing No: 47W809-1 Valve ASME Drawing Valve Valve Valve Actuator Normal . R Relief Remarks Number Class Coord. Category Size Type Type Position Testng Required Request Remarks62-504 2 G-10 C-ACT 8 CK SA C CVOIRO CVC/RO DTJ-8 RFV-62-505 2 G-10 C-ACT 3/4 RV SA C RV/RVF 62-523 2 G-8 C-ACT 2 CK SA C CVO/Q, CVC/Q 62-525 2 G-8 C-ACT 4 CK SA C CVC/Q, CVO/RO DTJ-7 62-530 2 F-8 C-ACT 2 CK SA C CVO/Q, CVC/Q 62-532 2 F-8 C-ACT 4 CK SA C CVO/RO CVC/Q . DTJ-7 62-543 2 B-6 C-ACT 3 CK SA 0 CVO/RO, CVC/RO DTJ-13 62-546 2 G-6 B-ACT 3 GB M C MS/2Y 62-549 2 G-7 B-ACT 2 GB M C MS/2Y 62-550 2 H-7 B-ACT 2 GB M 0 MS/2Y 62-560 1 F-6 C-ACT 2 CK SA 0 CVC/RO, CVO/RO CMP 62-561 1 F-6 C-ACT 2 CK SA 0 CVC/RO, CVO/RO CMP 62-562 1 H-5 C-ACT 2 CK SA 0 CVC/RO, CVO/RO CMP 62-563 1 H-5 C-ACT 2 CK SA 0 CVC/RO, CVO/RO CMP 62-576 1 E-3 C-ACT 2 CK SA 0 CVO/RO, CVC/RO CMP 62-577 1 E-2 C-ACT 2 CK SA 0 CVO/RO, CVC/RO CMP 62-578 1 G-2 C-ACT 2 CK SA 0 CVO/RO, CVC/RO CMP 62-579 1 G-3 C-ACT 2 CK SA 0 CVO/RO, CVC/RO CMP RFV-62-636 2 C-5 C-ACT 2 RV SA C RV/RVF CVC/RO CVO/RO 62-639 2 C-6 AC-ACT 3/4 CK SA C SLTJNJ CMP RFV-62-649 2 C-8 C-ACT 2 RV SA C RV/RVF 62-659 1 B-2 C-ACT 3 CK SA 0 CVC/DIF BDO/NO CMP 62-660 1 B-2 C-ACT 3 CK SA C CVC/DIF BDO/NO CMP

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 54 of 134 Appendix A (Page 24 of 67)

ASME VALVES System: 62 Chemical Volume and Control Drawing No: 47W809-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks62-661 1 B-2 C-ACT 2 CK SA C CVC/DIF, BDO/RO CMP RFV-62-662 2 A-3 AC-ACT 2 RV SA C RV/RVF, SLTJ/J RFV-62-675 2 B-9 C-ACT 2 RV SA C RV/RVF RFV-62-688 2 B-10 C-ACT 3 RV SA C RV/RVF 62-697 2 E-10 C-ACT 4 CK SA - CVO/Q BDC/RO CMP 62-716 1 B-2 C-ACT 3 CK SA 0 CVC/DIF BDO/NO CMP 62-717 2 B-2 C-ACT 3 CK SA C CVC/DIF BDO/NO CMP FSV-62-125 B2-10 B-PAS 3/4 GB SOL C RPI FCV-62-22 2 D-2 B-ACT 2 GB DIA 0 FSO/RCP STC/RCP RCPJ-2 FCV-62-35 2 D-1 B-ACT 2 GB DIA 0 FSO/RCP STC/RCP RCPJ-2 FCV-62-48 2 F-5 B-ACT 2 GB DIA 0 FSO/RCP STC/RCP RCPJ-2 FCV-62-61 2 C-6 A-ACT 4 GT MO 0 STC/RCP SLTJ/J RCPJ-1 FCV-62-63 2 B-7 A-ACT 4 GT MO 0 STC/RCP SLTJ/J RCPJ-1 FCV-62-69 1 A-2 B-ACT 3 GB DIA 0 STC/CSD FSC/CSD DTJ-14 FCV-62-70 1 A-2 B-ACT 3 GB DIA 0 STC/CSD FSC/CSD DTJ-14 FSC/CSD STC/CSD FCV-62-72 2 A-4 A-ACT 2 GB DIA O/C SLTJ/J DTJ-14 FSC/CSD STC/CSD FCV-62-73 2 A-4 A-ACT 2 GB DIA O/C SLTJ/J DTJ-14 FSC/CSD STC/CSD FCV-62-74 2 A-4 A-ACT 2 GB DIA C SLTJ/J DTJ-14

Appendix A (Page 25 of 67)

ASME VALVES System: 62 Chemical Volume and Control Drawing No: 47W809-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Remarks Number Class Coord. Category Size Type Type Position Testing Required Request FSC/CSD STC/CSD FCV-62-77 2 A-6 A-ACT 2 GB DIA 0 SLTJ/J . DTJ-14 FSC/Q STCIQ FCV-62-83 2 A-6 B-ACT 2 GB DIA C STO/Q NO RPI FCV-62-84 2 B-2 B-ACT 2 GB DIA C FSC/CSD STC/CSD DTJ-13 FCV-62-9 2 D-3 B-ACT 2 GB DIA 0 FSO/RCP STC/RCP RCPJ-2 FCV-62-90 2 D-7 B-ACT 3 GT MO 0 STC/CSD DTJ-14 FCV-62-91 2 D-8 B-ACT 3 GT MO 0 STC/CSD DTJ-14 LCV-62-132 2 D-10 B-ACT 4 GT MO 0 STC/CSD DTJ-12 LCV-62-133 2 E-10 B-ACT 4 GT MO 0 STC/CSD DTJ-12 LCV-62-135 2 H-9 B-ACT 8 GT MO C STO/CSD STC/CSD DTJ-12 LCV-62-136 2 H-9 B-ACT 8 GT MO C STO/CSD STC/CSD DTJ-12

Appendix A (Page 26 of 67)

ASME VALVES System: 62 Chemical Volume and Control Drawing No: 47W809-2 I

I Valve ASM Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category. Size Type Type Position Testing Required Request Remarks62-928 3 A-3 C-ACT 2 CK SA C CVO/RO BDCtRO e DTJ-15 62-930 2 B-4 C-ACT 3 CK SA C CVOIRO BDC/RO DTJ-15 FCV-62-138 ,3 ,,,,,A-4,, B-ACT 3 GT MO C STtSTQ System: 62 Chemical Volume and Control Drawing No: 47W809-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required RequesRemarks 1-RFV-62-1081 3 C-12 C-ACT 4 RV SA C RV/RVF 2-RFV-62-1081 3 C-7 C-ACT 4 RV SA C RV/RVF 1-RFV-62-955 3 C-1I C-ACT 4 RV SA C RV/RVF 2-RFV-62-955 3 C-7 C-ACT 4 RV SA C RV/RVF System: 62 Chemical Volume and Control Drawing No: 47W809-5 Valve ASME Drawing Valve Valve 'Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Req uest Remarks 1-62-1052A 3 F-7 C-ACT 2 CK SA 0 CVO/Q BDC/RO I0I CMP 1-62-1052B 3 F-6 C-ACT 2 CK SA 0 CVO/Q BDCtRO I_ ICMP 1-FCV-62-237 3 D-7 B-ACT 2 GB DIA 0 FSCIQ STCIQ NO RPI 2-62-1052A 3 F4 C-ACT 2 CK SA 0 CVO/Q BDC/RO i_ iCMP 2-62-1052B 3 F-4 C-ACT 2 CK SA 0 CVO/Q BDCtRP CMP 2-FCV-62-237 3 D-4 B-ACT 2 GB DIA l FSCIQ STCIQ l_._INO RPI 0-FCV-62-241 3 D-4 B-ACT 2 GB DIA 0 FSCIQ STCtQ ____NO RPI

Appendix A (Page 27 of 67)

ASME VALVES System: 63 Safety Injection Drawing No: 47W600-154 Valve ASME Drawing Valve Valve valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request 63-344B 2 F-9 A-PAS 1/4 GT M C STCJ/J 63-344D 2 F-9 A-PAS 1/4 GT M C STCJ/J

Appendix A (Page 28 of 67)

ASME VALVES System: 63 Safety Injection Drawing No: 47W81 1-1 Valve ASME Drawing Valve Valve Valve Actuator Normal T Relief Number Class Coord. Category Size Type Type Position esting Required Request Remarks63-502 2 F-10 C-ACT 12 CK SA C CVC/RO CVO/RO DTJ-9 63-510 2 D-10 C-ACT 8 CK SA C CVC/CSD CVO/RO CMP-25 RFV-63-51-1 2 D-1 0 C-ACT 3/4 RV SA C RVIRVF 63-524 2 F-8 C-ACT 4 CK SA C CVC/Q CVOIRO DTJ-33 63-526 2 D-8 C-ACT 4 CK SA C CVC/Q CVO/RO DTJ-33 63-528 2 F-8 C-ACT 3/4 CK SA C CVC/Q CVO/Q 63-530 2 E-8 C-ACT 3/4 CK SA C CVC/Q CVO/Q RFV-63-534 2 E-7 C-ACT 3/4 RV SA C RV/RVF RFV-63-535 2 E-7 C-ACT 3/4 RV SA C RV/RVF RFV-63-536 2 D-7 C-ACT 3/4 RV SA C RV/RVF 63-543 1 F-3 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-545 1 E-3 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-547 1 D-3 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-549 1 E-3 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-551 1 H-1 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-553 1 H-3 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-555 1 G-3 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-557 1 G-2 AC-ACT 2 CK SA C CVO/RO SLTP/TS DTJ-31 63-558 1 E-2 AC-ACT 6 CK SA C CVO/RO SLTPITS DTJ-31 63-559 1 E-1 AC-ACT 6 CK SA C CVO/RO SLTPITS DTJ-31 63-560 1 E-1 AC-ACT 10 CK SA C CVO/DIF SLTP/TS CMP 63-561 1 D-1 AC-ACT 10 CK SA C CVO/DIF SLTP/TS CMP 63-562 1 E-2 AC-ACT 10 CK SA C CVO/DIF SLTP/TS . CMP 63-563 1 F-2 AC-ACT 10 CK SA C CVO/DIF SLTP/TS CMP

Appendix A (Page 29 of 67)

ASME VALVES System: 63 Safety Injection Drawing No: 47W811-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Reuest Remarks RFV-63-577 2 A-7 C-ACT 3/4 RV SA C RV/RVF 63-581 1 C-6 C-ACT 3 CK SA C CVC/RO, CVO/RO DTJ-32 63-586 1 E-1 C-ACT 1-1/2 CK SA C CVC/RO, CVO/RO DTJ-32 63-587 1 D-2 C-ACT 1-1/2 CK SA C CVC/RO, CVO/RO DTJ-32 63-588 1 E-2 C-ACT 1-1/2 CK SA C CVC/RO, CVO/RO DTJ-32 63-589 1 F-2 C-ACT 1-1/2 CK SA C CVC/RO, CVO/RO DTJ-32 RFV-63-602 3 A-1 C-ACT I RV SA C RV/RVF RFV-63-603. 3 A-3 C-ACT 1 RV SA C RV/RVF RFV-63-604 3 A-4 C-ACT 1 RV SA C RVWRVF RFV-63-605 3 A-6 C-ACT 1 RV SA C RVWRVF 63-622 1 D-1 AC-ACT 10 CK SA C CVO/DIF SLTP/TS CMP 63-623 1 D-2 AC-ACT 10 CK SA C CVO/DIF SLTP/TS CMP 63-624 1 D-3 AC-ACT 10 CK SA C CVO/DIF SLTP.TS CMP 63-625 1 D-3 AC-ACT 10 CK SA C CVO/DIF SLTPITS CMP RFV-63-626 2 G-7 C-ACT 2 RV SA C RWRVF _

RFV-63-627 2 F-7 C-ACT 2 RV SA C RWRVF 63-632 1 H-2 AC-ACT 6 CK SA C CVO/DIF SLTP/TS CMP 63-633 1 G-1 AC-ACT 6 CK SA C CVO/DIF SLTP/TS CMP 63-634 1 G-3 AC-ACT 6 CK SA C CVO/DIF SLTPITS CMP 63-635 1 G-1 AC-ACT 6 CK SA C CVO/DIF SLTPITS CMP RFV-63-637 2 F-6 C-ACT 3/4 RV SA C RV/RVF 63-640 1 G-3 AC-ACT 8 CK SA C CVO/DIF SLTP/TS CMP 63-641 1 F-1 AC-ACT 6 CK. SA C CVO/DI F SLTPITS CMP 63-643 1 G-3 AC-ACT 8 CK SA C CVO/DIF SLTPITS CMP

Appendix A (Page 30 of 67)

ASME VALVES System: 63 Safety Injection Drawing No: 47W81 1-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks63-644 1 D-2 AC-ACT 6 CK SA C CVOIDIF SLTP/TS CMP FCV-63-1 2 E-10 B-ACT 12 GT MO 0 STC/CSD STO/CSD DTJ-16 FCV-63-107 2 A-2 B-ACT 1 GB DIA C FSC/CSD STO/CSD DTJ-2 FCV-63-11 2 F-9 B-ACT 8 GT MO C STO/CSD STC/CSD DTJ-20 FCV-63-1l1 2 H-1~6 B-PAS 3/4 GB DIA C RPI _

FCV-63-112 2 H-6 B-PAS 3/4 GB DIA C RPI FCV-63-115 2 B-2 B-PAS 1 GB DIA C RPI FCV-63-116 2 C-I B-PAS 3/4 GB DIA C RPI FCV-63-117 2 H-1 B-PAS 3/4 GB DIA C RPI FCV-63-118 2 B-1 B-ACT 10 GT MO 0 STO/CSD STC/CSD DTJ-22 FCV-63-121 2 E-6 B-PAS 3/4 GB DIA C RPI _

FCV-63-127 2 A-1 B-ACT 1 GB DIA C FSC/CSD STO/CSD DTJ-2 FCV-63-152 2 F-7 B-ACT 4 GT MO 0 STC/Q STOIQ FCV-63-153 2 E-7 B-ACT 4 GT MO 0 STC/Q STO/Q FCV-63-156 2 F-6 B-ACT 4 GT MO C STC/Q STO/Q FCV-63-157 2 F-6 = B-ACT 4 GT MO C STC/Q STO/Q FCV-63-158 2 F-5 B-PAS 3/4 GB DIA C RPI STO/Q FCV63-163 2 G-5 B-PAS 3/4 GB DIA C RPI FCV-63-164 2 G-4 B-PAS 3/4 GB DIA C RPI FCV.63-165 2 C-3 B-PAS 3/4 GB DIA C RPI FCV-63-166 2 E-5 B-PAS 3/4 GB DIA C RPI FCV-63-167 2 D-6 B-PAS 3/4 GB DIA C RPI FCV-63-172 2 G-6 B-ACT 12 GT MO C STO/CSD STC/CSD DTJ-21 FCV-63-174 2 C-6 B-PAS 3/4 GB DIA C RPI

Appendix A (Page 31 of 67)

ASME VALVES System: 63 Safety Injection Drawing No: 47W81 1-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Testin Reuired Relief Remarks Number Class Coord. Category Size Type Type Position g eq Request FCV-63-175 2 E-8 B-ACT 2 GB MO 0 STC/Q FCV-63-21 2 F-6 B-PAS 1 GB DIA C RPI FCV-63-22 2 E-6 B-ACT 4 GT MO 0 STC/CSD STOICSD DTJ-19 FSC/Q STC/Q, FCV-63-23 2 E-7 A-ACT 3/4 GB DIA C SLTJ/J FCV-63-24 2 C-6 B-PAS 1 GB DIA C RPI FCV-63-25 2 B-7 B-ACT 4 GT MO C STO/Q STC/Q FCV-63-26 2 B-7 B-ACT 4 GT MO C STO/Q STC/Q FCV-63-3 2 E-8 B-ACT 2 GB MO 0 STC/CSD DTJ-17 FCV-63-39 2 C-9 B-ACT 4 GT MO C STO/Q STC/Q FCV-63-4 2 E-8 B-ACT 2 GB MO 0 STC/Q FCV-63-40 2 C-8 B-ACT 4 GT MO C STO/Q STC/Q FCV-63-47 2 F-10 B-ACT 6 GT MO 0 STO/CSD STC/CSD DTJ-26 FCV-63-48 2 E-10 B-ACT 6 GT MO 0 STO/Q STC/Q FCV-63-5 2 D-10 B-ACT 8 GT MO 0 STC/CSD STO/CSD DTJ-1 8 FCV-63-6 2 F-10 B-ACT 4 GT MO C STO/Q STC/Q FCV-63-63 2 A-5 B-ACT 1 GB DIA C FSC/CSD STO/CSD DTJ-2 FCV-63-67 2 B-5 B-ACT 10 GT MO 0 STO/CSD STC/CSD DTJ-22 FCV-63-68 2 C-5 B-PAS 3/4 GB DIA C RPI FCV-63-69 2 H-2 B-PAS 3/4 GB DIA C RPI FCV-63-7 2 F-10 B-ACT 4 GT MO C STO/Q STC/Q __._

FCV-63-70 2 B-6 B-PAS 1 GB DIA C RPI FSCIQ STCIQ, FCV-63-71 2 C-6 A-ACT 3/4 GB DIA C SLTJ/J FCV-63-72 2 H- B-ACT 18 GT MO C STO/CSD STC/CSC DTJ-20

Appendix A (Page 32 of 67)

ASME VALVES System: 63 Safety Injection Drawing No: 47W81 1-1 Valve ASME Drawing Valve Valve Valve Actuator Normal * *ued Relief Remarks Number Class Coord. Category Size Type Type Position Testng Requir Request FCV-63-73 2 H-7 B-ACT 18 GT MO C STO/CSD STC/CSD DTJ-20 FCV-63-77 2 BA B-PAS 1' GB DIA C RPI _ _

FCV-63-78 2 C-4 B-PAS 3/4 GB DIA C RPI FCV-63-79 2 G-5 B-PAS 3/4 GB DIA C RPI FCV-63-8 2 H-9 B-ACT 8 GT MO C STO/CSD STC/CSD _ DTJ-20 FCV-63-80 2 B-4 B-ACT 10 GT MO 0 STO/CSD STC/CSD DTJ-22 FSC/Q STC/Q, FCV-63-84 2 D-6 A-ACT 3/4 GS DIA C SLTJ/J FCV-63-87 2 A4 B-ACT 1 GB DIA C FSC/CSD STO/CSD DTJ-2 FCV-63-93 2 G-7 B-ACT 8 GT MO 0 STC/CSD STO/CSD DTJ-21 FCV-63-94 2 G-7 B-ACT 8 GT MO 0 STC/CSD STO/CSD DTJ-21 FCV-63-95 2 B-3 B-PAS 1 GB DIA C RPI _

FCV-63-96 2 C-2 B-PAS 3/4 GB DIA C RPI FCV-63-97 2 H-4 B-PAS 3/4 GB DIA C RPI FCV-63-98 2 B-2 B-ACT 10 GT MO 0 STOICSD STC/CSD DTJ-22 FSV-63-25 2 B-7 B-ACT 3/4 GB SO C STO/Q STC/Q _

FSV-63-26 2 C-7 B-ACT 3/4 GB SO C STO/Q STC/Q System: 63 Safety Injection Drawing No: 47W830-6 Valve ASME Drawing: Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testig Required Request

. IFSC/Q STC/Q, FCV-63-64 2 B-6 AC-ACT 1 GB DIA C SLTJ/J

Appendix A (Page 33 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required euesRemarks 1-67-508A 3 B-12 C-ACT 6 CK SA C CVO/RO, BDC/RO CMP 14-7-508B 3 B-8 C-ACT 6 CK SA C CVO/RO, BDC/RO_ CMP 1-FCV-67-66 3 B-12 B-ACT 6 BF MO C STO/Q 1-FCV-67-67 3 B-7 B-ACT 6 BF MO C STO/Q 1-RFV-67-509A 2 B-11 C-ACT 1/2 RV SA C TRVW10Y 1-RFV-67-509B 2 B-8 C-ACT 1/2 RV SA C TRV/10Y 1-RFV-67-514A 2 C-1I C-ACT 1/2 RV SA C TRVW10Y 1-RFV-67-514B 2 C-8 C-ACT 1/2 RV SA C TRVW10Y 2-67-508A 3 B-10 C-ACT 6 CK SA C CVOIRO, BDC/RO CMP 2-67-508B 3 B-6 C-ACT 6 CK SA C CVO/RO, BDC/RO CMP 2-FCV-67-66 3 B-10 B-ACT 6 BF MO C STO/Q 1 .- -.- -- .

Appendix A (Page 34 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 2-FCV-67-67 3 B-6 B-ACT 6 BF MO C STO/Q __I 2-RFV-87-509A 2 B-10 C-ACT 1/2 RV SA C TRV/10Y 2-RFV-67-509B 2 B-6 C-ACT 1/2 RV SA C TRV/10Y 2-RFV-67-514A 2 C-10 C-ACT 1/2 RV SA C TRW10Y 2-RFV-67-514B 2 C-6 C-ACT I1/2 RV SA C TRV/10Y

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3EL= =  : :V=: ::=D: T:

Appendix A (Page 35 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testng Required Request Remarks 0-FCV-67-152 3 C-7 B-ACT 24 BF MO TH STO/Q O-RFV-67-1513 3 B-6 C-ACT 3/4 RV SA C TRV/I0Y 1-67-543A 3 C-10 B-ACT 3 GT M C MS/2Y 1-67-543B 3 C-10 B-ACT 3 GT M C MS/2Y 1-67-544 3 C-10 B-ACT 3 GT M C MSI2Y 3 C-9

_-FCV-67-123 B-ACT 18 BF MO C STO/Q 1-FCV-67-124 3 E-8 B-ACT 18 BF MO C STO/Q 1-FCV-67-124 3 C-8 B-ACT 18 BF MO C STOIQ 1-FCV-67-126 3 D-7 B-ACT 18 BF MO C STO/Q

Appendix A (Page 36 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position T Request 1-RFV-67-1513 3 B-7 C-ACT 3/4 RV SA C TRV/10Y 1-RFV-67-1514 3 B-8 C-ACT 3/4 RV SA C TRV/10Y 1-RFV-67-1590A 3 D-7 C-ACT 1/2 RV SA C TRV/10Y 1-RFV-67-1590B 3 D-8 C-ACT 1/2 RV SA C TRV/10Y 2-67-543A 3 C-2 B-ACT 3 GT M C MS/2Y 2-67-543B 3 C-2 B-ACT 3 GT M C MS/2Y 2-67-544 3 C-1 B-ACT 3 GT M C MS/2Y 2-FCV-67-123 3 D-2 B-ACT 18 BF MO C STO/RO DTJ-35 2-FCV-67-124 3 E-4 B-ACT 18 BF MO C STO/RO DTJ-35 2-FCV-67-125 3 C-3 B-ACT 18 BF MO C STO/RO DTJ-35 2-FCV-67-126 3 D-5 B-ACT 18 BF MO C STO/RO DTJ-35

Appendix A (Page 37 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size . Type Type Position Request 2-RFV-67-1513 3 B4 C-ACT 3/4 RV SA C TRV/IOY .

2-RFV-67-1514 3 B-5 C-ACT 3/4 RV SA C TRW10Y 2-RFV-67-1590A 3 D-5 C-ACT 1/2 RV SA C TRV/1OY 2-RFV-67-1590B 3 D-4 C-ACT 1/2 RV SA C- TRV1OY STO/CSD FCV-67-146 3 C-7 B-ACT 24 BE MO TH STC/CSD ____DTJ-25

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 68 of 134 Appendix A (Page 38 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 1-RFV-67-566D 3 D-5 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-67-566D 3 E-5 C-ACT 3/4 RV SA C TRVW10Y CVC/RO, CVO/RO 67-1523A 2 H-5 AC-ACT 1/2 CK SA C SLTJ/J CMP CVC/RO, CVO/RO 67-1523B 2 F-5 AC-ACT 1/2 CK SA C SLTJ/J CMP CVC/RO, CVO/RO 67-1523C 2 G-5 AC-ACT 1/2 CK SA C SLTJ/J CMP CVC/RO, CVO/RO 67-1523D 2 E-5 AC-ACT 1/2 CK SA C SLTJ/J CMP

Appendix A (Page 39 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request CVC/RO, CVO/RO 67-575A 2 G-6 AC-ACT 1/2 CK SA C SLTJ/J CMP CVC/RO, CVO/RO 67-575B 2 E-6 AC-ACT 1/2 CK SA C SLTJ/J CMP CVC/RO, CVO/RO 67-575C 2 F-6 AC-ACT 1(2 CK SA C SLTJ/J CMP CVC/RO, CVO/RO 67-575D 2 D-6 AC-ACT 1/2 CK SA C SLTJ/J CMP STC/CSD, FCV-67-103 2 E-6 A-ACT 6 BF MO 0 STO/CSD SLTJ/J DTJ-24 STC/CSD, FCV-67-104 2 E-7 A-ACT 6 BF MO 0 STO/CSD SLTJ/J DTJ-24 STC/CSD, FCV-67-105 2 G-5 A-ACT 6 BF MO 0 STO/CSD SLTJ/J DTJ-24

Appendix A (Page 40 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Remarks Number Class Coord. Category Size Type Type Position Testing Required Request STC/CSD, STO/CSD FCV-67-106 2 H-5 A-ACT 6 BF MO 0 SLTJ/J -_- DTJ-24 STC/CSD, STO/CSD FCV-67-107 2 H-7 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-111 2 D-6 A-ACT 6 BF MO 0 SLTJ/J . DTJ-24 STC/CSD, STO/CSD FCV-67-112 2 D-7 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-83 2 D-7 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-87 2 G-6 A-ACT 6 BF MO 0 SLTJ/JCSDSTOCS DTJ-24 STC/CSD, STO/CSD FCV-67-88 2 G-7 A-ACT 6 BE MO 0 SLTJ/J____ DTJ-24

Appendix A (Page 41 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request STC/CSD, STO/CSD FCV-67-89 2 D-5 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-90 2 F-5 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-91 2 F-7 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-95 2 F-6 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-96 2 F-7 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 STC/CSD, STO/CSD FCV-67-99 2 G-7 A-ACT 6 BF MO 0 SLTJ/J DTJ-24 RFV-67-566A 3 H-5 C-ACT 3/4 RV SA C TRV/10Y RFV-67-566B 3 F-5 C-ACT 3/4 RV SA C TRV/10Y

Appendix A (Page 42 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-3 Valve ASME Drawing Valve. Valve Valve Actuator Normal Testing Required Relief Remarks___

Number Class Coord. Category Size Type Type Position Request RFV-67-566C 3 G-5 C-ACT 3/4 RV SA C TRW10Y TCV-67-100 3 E-4 B-ACT 4 GB DIA O/C FSO/Q, STO/Q TCV-67-108 3 D-4 B-ACT 4 GB DIA O/C FSO/Q, STO/Q TCV-67-84 3 H4 B-ACT 4 GB DIA O/C FSO/Q, STO/Q TCV-67-92 3 G- B-ACT 4 GB DIA O/C FSO/Q, STO/Q _

System: 67 Essential Raw Cooling Water Drawing No: 2-47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Testin Required Relief Number Class Coord. Category Size Type Type Position Reques Rqs CVC/RO, BDO/NO 2-67-580A 2 C-4 AC-ACT 2 CK SA O/C SLTJ/J DTJ-40 CVC/RO, BDO/NO 2-67-580B 2 B4 AC-ACT 2 CK SA O/C SLTJ/J DTJ40 CVC/RO, BDO/NO 2-67-580C 2 B-4 AC-ACT 2 CK SA O/C SLTJIN DTJ40 CVC/RO, BDO/NO 2-67-580D 2 A4 AC-ACT 2 CK SA O/C SLTJ/J DTJ40 2-67-585A 2 C-6 AC-ACT 1/2 CK SA C CVC/RO CVO/RO SLTJ/J CMP 2-67-585B 2 B-6 AC-ACT 1/2 CK SA C CVC/RO CVO/RO SLTJ/J CMP 2-67-585C 2 C-6 AC-ACT 1(2 CK SA C CVC/RO CVOIRO SLTJ/J CMP

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 73 of 134 Appendix A (Page 43 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 2-47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. C Size T Type Position Request Remarks CVC/RO, CVO/RO 2-67-585D 2 A-6 AC-ACT 1/2 CK SA C SLTJ/J CMP 2-FCV-67-130 2 C-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J _

2-FCV-67-131 2 C-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-133 2 B-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-134 2 B-4 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J ____ _

2-FCV-67-138 2 B-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-139 2 B-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-141 2 A-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-142 2 A-7 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J -

2-FCV-67-295 2 C-6 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-296 2 C-6 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J

Appendix A (Page 44 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 2-47W845-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required_ Request Remarks 2-FCV-67-297 2 B-6 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-FCV-67-298 2 A-6 A-ACT 2 PLG MO 0 STC/Q, SLTJ/J 2-RFV-67-582A 3 C-3 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-67-582B 3 A-3 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-67-582C 3 B-3 C-ACT 3/4 RV SAC TRV/10Y 2-RFV-67-582D 3 A-3 C-ACT 3/4 RV SAC TRV/1OY

I Appendix A (Page 45 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-4 IValve I ASME I Drawing Valve IValve IValve Actuator INormal TetigReuie Reliel Remarks I

I Number I Class I Coord. I Cateaorv I Sie I TvDe I Tvee I Position TetngRq Ird Reaurest I I IOFS-2-7 I B7 I -A T I G s8 C - !ET/Q FSOIQ I R7-2 I NO REMOTE INDICATOR 12-RFV-67-1 521 1 3 1 A-7 IC-ACT 1 3/4 1 RV I SA I C IRV-RVFII

.1. =-

Appendix A (Page 46 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 2-47W845-4 Valve ASME Drawing Valve Valve Valve Actuator Normal T Relief Number Class Coord. Category Sze Type_ Type Position Testing Required Request Remarks 2-FCV-67-176 3 D-5 B-ACT 1-1/2 GB DIA C STOIQ FSO/Q _ NO REMOTE INDICATOR 2-FCV-67-182 3 E-7 B-ACT 1-1/2 GB DIA C STOIQ FSO/Q NO REMOTE INDICATOR 2-FCV-67-184 3 E-5, B-ACT 1-112 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-186 3 D-6 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-217 3 B4 B-ACT 2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-219. 3 C-7 B-ACT 2 GB DIA 0 STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-336 3 A-5 B-ACT 1 GB DIA C STOiQ FSO/Q NO REMOTE INDICATOR 2-FCV-67-338 3 A-7 B-ACT 1 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-342 3 G-5 B-ACT 2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-344 3 G-7 B-ACT 2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-346 3 F-5 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-348 3 F-6 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-350 3 F-5 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-352 3 F-6 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-354 3 G4 B-ACT 1-1/2 GB PIA C STO/Q FSO/Q NO REMOTE INDICATOR 2-FCV-67-356 3 G-7 B-ACT 1-1/2 GB DIA C STOIQ FSO/Q NO REMOTE INDICATOR

Appendix A (Page 47 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-5 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Reluef Remarks Number Class Coord. Category Size Type Type Position Request 0-FCV-67-208 3 G-10 B-ACT 4 BF MO 0 STC/Q 1-67-1070 3 E-5 B-ACT 4 BA M C MS/2Y 1-67-1073 3 D-5 B-ACT 4 BA M C MS/2Y 2-67-1070 3 G-5 B-ACT 4 BA M C MS/2Y 2-67-1073 3 F-5 B-ACT 4 BA M C MS/2Y 67-719A -3 B-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q 67-719B 3 C-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q 67-720A 3 B-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q 67-720B 3 D-3 C-ACT 2 CK SA 0/C CVO/Q, CVC/Q 67-723A 3 B-4 C-ACT 24 CK SA 0/C CVO/Q, CVC/Q 67-723B 3 C-4 C-ACT 24 CK SA 0/C CVO/Q, CVC/Q

Appendix A (Page 48 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-5 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Number Class Coord. Category Size Type Type Position TestingR d Request Remarks 67-724A 3 B4 C-ACT 24 CK SA O/C CVO/Q, CVC/Q 67-724B 3 D-4 C-ACT 24 CK SA O/C CVO/Q, CVC/Q 67-739A 3 F-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q 67-739B 3 D-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q .

67-740A 3 G-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q 67-740B 3 E-3 C-ACT 2 CK SA O/C CVO/Q, CVC/Q 67-743A 3 F-4 C-ACT 24 CK SA O/C CVO/Q, CVC/Q 67-743B 3 E-4 C-ACT 24 CK SA O/C CVO/Q, CVC/Q 67-744A 3 G4 C-ACT 24 CK SA O/C CVO/Q, CVC/Q 67-744B 3 E-4 C-ACT 24 CK SA O/C CVO/Q, CVC/Q

I Appendix A (Page 49 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-6 Valve ASME Drawing Valve Valve Valve Actuator Normal Test Reired Relief Remk Number Class Coord. Category Size Type Type Position esing equ Request marks 0-FSV-32-61 3 A-4 B-ACT 1 GT SO C ET/Q FSOtQ RV-2 NO REMOTE INDICATOR 1-RFV-67-1521 3 A-4 C-ACT 3/4 RV SA C RVWRVF i-FCV-67-162 3 B4 B-ACT 2 GB DIA 0 STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-164 3 A-7 B-ACT 2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-176 3 D-4 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q . NO REMOTE INDICATOR 1-FCV-67-182 3 D-6 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-184 3 D-4 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR

0-TI-SXI-000-200.V Rev. 0000 Page 80 of 134 Appendix A (Page 50 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-6 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Number Class Coord. Category Size Type Type Position ________Required Request Remarks 1-FCV-67-186 3 D-6 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-213 3 A-4 B-ACT 1-1/2 GB DIA 0 STO/Q FSO/Q1 NO REMOTE INDICATOR 1-FCV-67-215 3 A-7 B-ACT 1-1/2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-342 3 F-4 B-ACT 2 GB DIA 0 STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-344 3 F-7 2B-ACT GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-346 3 E-4 B-ACT 1-1/2 GB DIA 0 STO/Q FSO/Q NO REMOTE INDICATOR

Appendix A (Page 51 of 67)

ASME VALVES System: 67 Essential Raw Cooling Water Drawing No: 47W845-6 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 1-FCV-67-348 3 E-6 B-ACT 1-112 GB DIA C STO/Q FSOtQ NO REMOTE INDICATOR 1-FCV-67-350 3 E-4 B-ACT 1-1Q2 GB DIA 0 STO/Q FSOIQ NO REMOTE INDICATOR 1-FCV-67-352 3 E-6 B-ACT 1-1Q2 GB DIA C STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-354 3 F-4 B-ACT 1-1Q2 GB DIA 0 STO/Q FSO/Q NO REMOTE INDICATOR 1-FCV-67-356 3 F-7 B-ACT 1-1Q2 GB DIA C STO/Q FSO/Q I_ I NO REMOTE INDICATOR

Appendix A (Page 52 of 67)

ASME VALVES System: 68 Reactor Coolant Drawing No: 47W813-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks68-559 1 B-9 C-ACT 4 CK SA C CVO/DIF CVC/DIF CMP RFV-68-563 1 A-3 C-ACT 6 RV SA C RV/RVF RFV-68-564 1 A-4 C-ACT 6 RV SA C V/RVF RFV-68-565 1 A-5 C-ACT 6 RV SA C RV/RVF FCV-68-307 2 A-10 A-ACT 3/8 GB DIA C FSC/Q STC/Q, SLTJ/J FCV-68-308 2 A-9 A-ACT 3/8 GB DIA C FSC/Q STC/Q, SLTJ/J FCV-68-332 1 B-3 B-ACT 3 GT MO 0 STC/Q STO/Q FCV-68-333 1 B-3 B-ACT 3 GT MO 0 STC/Q STO/Q FSC/CSD STO/CSD FSV-68-394 2 C-7 B-ACT 1 GB SO C STC/CSD DTJ-39 FSC/CSD STO/CSD FSV-68-395 2 C-7 B-ACT 1 GB SO C STC/CSD DTJ-39 FSV-68-396 2 C-7 B-ACT 1 GB SO C STC/RO STO/RO RV-1 FSV-68-397 2 C-7 B-ACT 1 GB SO C STC/RO STO/RO RV-1 FSC/CSD STO/CSD PCV-68-334 1 B-3 B-ACT 3 GB SO C STC/CSD FSC/CSD STO/CSD PCV-68-340A 1 S-3 B-ACT 3 GB SO C STC/CSD

Appendix A (Page 53 of 67)

ASME VALVES System: 68 Reactor Coolant Drawing No: 47W830-6 Drawing Valve Valve Valve Actuator Normal Relief l Relief Valve Valve Actuator Normal Valve ASME Drawing _Valve I Number Coord. Category Size Type Type Position Testing Required Request Remarks -I I-FCV-68-305 S2 G-7 A-ACT 3/4 DIA DIA C FSC/Q STC/Q. SLTJ/J I

SQN - ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0,1, & 2 Rev. 0000 Page 84 of 134 Appendix A (Page 54 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request 0-70-504 3 D-8 C-ACT 16 CK SA O/C CVOIQ, CVC/Q 0-FCV-70-1 3 H-6 B-ACT 12 BF MO O/C STO/Q 0-FCV-70-11 3 H-5 B-ACT 12 BF MO 0 STO/Q 0-FCV-70-193 3 B-3 B-ACT 20 BF MO O/C STC/Q STO/Q 0-FCV-70-194 3 B4 B-ACT 20 BF MO O/C STC/Q STO/Q 0-FCV-70-197 3 B-5 B-ACT 20 BF MO 0 STCIQ STOIQ 0-FCV-70-198 3 B-5 B-ACT 20 BF MO 0 STC/Q STO/Q 0-FCV-70-40 3 G4 B-PAS 12 BF MO O/C RPI 0-FCV-70-41 3 G-5 B-PAS 12 BF MO O/C RPI 0-RFV-70-782 3 0-4 C-ACT 3/4 RV SA C TRV/10Y 0-RFV-70-783 3 D-4 C-ACT 314 RV SA C TRVIW0Y 0-RFV-70-833 3 G-4 C-ACT 3/4 RV SA C TRV/10Y 0-RFV-70-834 3 G-6 C-ACT 3/4 RV SA C TRV/10Y .

1-70-504A 3 C-8 C-ACT 16 CK SA O/C CVO/Q, CVC/Q 1-70-504B 3 D-8 C-ACT 16 CK SA O/C CVO/Q, CVC/Q 1-70-531 3 D B-ACT 16 BF M 0 MS/2Y 1-70-535 3 H-7 C-ACT 1-1/4 CK SA CVC/Q BDO/NO _

1-RFV-70-538 3 F-3 C-ACT 3 RV SA C RVF 1-RFV-70-539 3 F-3 C-ACT 3 RV SA C RV/RVF

Appendix A (Page 55 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-1 Valve ASME Valve Valve Valve Actuator Normal Tetn eurd ReliefReak Number Class Drawing Coord. Category Size Type Type Position Ttg qu Request Remarks 1-70-540 3 F-2 B-ACT 3 GT M 0 MS/2Y 1-70-541 3 F-2 C-ACT 3 CK SA C CVC/DIF BDO/DIF CMP 1-70-542 3 G-2 B-ACT 3 GT M C MS/2Y 1-FCV-70-66 3 F-3 B-ACT 2 GB DIA 0 FSC/Q STC/Q 1-LCV-70-63 3 G-2 B-ACT 3 GB DIA C FSC/Q STO/Q 1-RFV-70-782 3 D-5 C-ACT 3/4 RV SA C TRW10Y 1-RFV-70-783 3 D-5 C-ACT 3/4 RV SA C RV/W10Y 70-504A 3 F-8 C-ACT 16 CK SA O/C CVO/Q, CVC/Q 504B 3 E-8 C-ACT 16 CK SA O/C CVO/Q, CVC/Q 531 3 E-9 B-ACT 16 BF M 0 MS/2Y 535 3 G-7 C-ACT 1-1/4 - CK SA C CVC/Q BDO/NO 2-RFV-70-538 3 F-1 C-ACT 3 RV SA C RV/RVF _

RFV-539 3 F-1 C-ACT 3 RV SA C RV/RVF 2-70-540 3 F-1 B-ACT 3 GT M 0 MS/2Y

Appendix A (Page 56 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-1 Valve ASME Drawing Valve Valve Valve Actuator Normal . Relief Number Class Coord. Category Size Type Type Position Testing Required Rquest Remarks 2-70-541 3 F-1 C-ACT 3 CK SA C CVC/DIF BDO/DIF CMP 2-70-542 3 G-1 B-ACT 3 GT M C MS/2Y

-FCV-70-66 3 F-1 B-ACT 2 GB DIA 0 FSC/Q STC/Q

-LCV-70-63 3 G-1 B-ACT 3 GB DIA C FSC/Q STO/Q

-RFV-70-782 3 D-3 C-ACT 3/4 RV SA C TRV/1OY .

-RFV-70-783 3 D-3 C-ACT 3/4 RV SA C TRW10Y

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 87 of 134 Appendix A (Page 57 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-2 Valve ASME Drawing Valve Valve Valve Actuator Normal Testin Reuired Relief Re ks Number Class Coord. Category Size Type Type Position e g q Request emar 1-RFV-70-683A 3 F-9 C-ACT 3/4 RV SA C TRVW10Y 1-RFV-70-683B 3 F-9 C-ACT 3/4 RV SA C TRV/10Y I 1-RFV-70-683C 3 E-9 C-ACT 3/4 RV SA C TRV/W10Y 1-RFV-70-683D 3 G-9 C-ACT 3/4 RV I SA I C TRV/10Y I I

Appendix A (Page 58 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-2 & -3 Valve ASME Drawing Valve Valve Valve Actuator Normal . . Relief Number Class Coord. Catory Size Type Type Position Testng Required Request Remarks 1-FCV-70-87 2 H-10 A-ACT 3 GT MO 0 STC/RCP, SLTJ/J RCPJ-3 1-FCV-70-89 2 E-9 A-ACT 6 BF MO 0 STC/RCP, SLTJ/J RCPJ-4 70-671 3 F-I C-ACT 4 CK SA 0 CVOIRO BDCIRO DTJ-38 70-676A 3 G-2 C-ACT 3 CK SA 0 CVO/RO BDC/RO DTJ-38 70-676B 3 G-1 C-ACT 3 CK SA 0 CVO/RO BDC/RO DTJ-38 CVO/RO CVC/RO,70-679 2 H-4 AC-ACT 3 CK SA 0 SLTJ/J DTJ-41 70-681A 3 G-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-681B 3 F-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-681C 3 E-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-681D 3 H-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-682A 3 G-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-682B 3 F-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-682C 3 E-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP 70-682D 3 H-8 C-ACT 1-1/2 CK SA 0 CVO/RO, CVC/DIF CMP CVC/RO CVO/RO 70-687 2 H-10 AC-ACT 1/2 CK SA C SLTJ/J CMP CVC/RO CVF/RO 70-698 2 E-9 AC-ACT 1/2 CK SA C SLTJ/J CMP RFV-70-703 3 D-6 AC-ACT 3 RV SA C RV/RVF, SLTJ/J CVC/RO CVO/RO 70-791 2 GA AC-ACT 1/2 CK SA C SLTJ/J CMP FCV-70-133 3 H-2 B-ACT 3 GT MO 0 STC/RCP RCPJ-3 FCV-70-134 2 H-3 A-ACT 3 GT MO 0 STC/RCP, SLTJ/J RCPJ-3

Appendix A (Page 59 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-2 & -3 Valve ASME Drawing Valve Valve Valve Actuator Normal R Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks FCV-70-139 3 G-2 B-PAS 6 BF MO 0 RPI FCV-70-140 2 G-3 A-ACT 6 BF MO 0 STC/RCP, SLTJ/J RCPJ-4 FCV-70-141 2 G-4 A-ACT 6 BF MO -O STC/RCP, SLTJ/J RCPJ-4 FCV-70-143 2 E-3 A-ACT 6 BF MO 0 STC/Q, SLTJ/J FCV-70-85 2 D-10 A-ACT 6 BF DIA 0 STC/Q, SLTJ/J FCV-70-90 2 E-10 A-ACT 3 GT MO 0 STC/RCP, SLTJ/J RCPJ-3 FCV-70-92 2 E-10 A-ACT 6 BF MO 0 STC/RCP, SLTJ/J RCPJ-4 RFV-70-694 3 F-5 C-ACT 3/4 RV SA C TRW10Y I System: 70 Component Cooling Drawing No: 47W859-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Remarks Number Class Coord. Category Size Type Type Position Testing Required Request 2-FCV-70-87 2 H-9 A-ACT 3 GT MO 0 STC/RCP, SLTJ/J RCPJ-3 2-FCV-70-89 2 E-9 A-ACT 6 BF MO 0 STC/RCP, SLTJ/J RCPJ-4 2-RFV-70-683A 3 G-8 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-70-683B 3 F-8 C-ACT 3/4 RV SA C TRV/IOY 2-RFV-70-683C 3 E-8 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-70-683D 3 G-8 C-ACT 3/4 RV SA C TRV/10Y

Appendix A (Page 60 of 67)

ASME VALVES System: 70 Component Cooling Drawing No: 47W859-4 Valve ASME Drawing Valve Valve Valve Actuator Normal Tti Rrei Relief Number . Class Coord. Category Size Type Type Position esng equred Request Remarks 1-FCV-70-153 3 F-3 B-ACT 18 BF MO C STO/Q STC/Q I-FCV-70-156 3 F-4 B-ACT 18 BF MO C STO/Q STC/Q _

1-RFV-70-551A 3 F-4 C-ACT 1 RV SA C TRV/I10Y 1-RFV-70-551B 3 F-3 C-ACT 1 RV SA C TRV/IOY I-RFV-70-556A 3 BA4 C-ACT 3/4 RV SA C TRW10Y 1-RFV-70-556B 3 B-3 C-ACT 3/4 RV SA C TRV/10Y I-RFV-70-561A 3 C4 C-ACT 3/4 RV SA C TRV/10Y 1-RFV-70-561B 3 C-3 C-ACT 3/4 RV SA C tRV/IOY .

1-RFV-70-565A 3 D-4 C-ACT 3/4 RV SA C TRV/10Y ._.__

1-RFV-70-565B 3 D-3 C-ACT 3/4 RV SA C TRV/I10Y .

I-RFV-70-570A 3 D-4 C-ACT 3/4 RV SA C RWIOY_

1-RFV-70-570B 3 D-3 C-ACT 3/4 RV SA C TRV/10Y .-

1-FCV-70-153 3 F-9 B-ACT 18 BF MO C STOIQ STCIQ 2-FCV-70-156 3 F-10 B-ACT 18 BF MO C STOIQ STC/Q 2-FCV-70-5156 3 F-10 B-ACT 18 RV MO C STO/QSTC/

2-RFV-70-551A 3 F-10 C-ACT 1 RV SA C TRV/10Y 2-RFV-70-551B 3 E-8 C-ACT 1 RV SA C TRV/IOY 2-RFV-70-556A 3 B-10 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-70-556B 3 B-9 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-70-561A 3 C-10 C-ACT 3/4 _RV SA C TRV/10Y_____________

2-RFV-70-561B 3 C-8 C-ACT 3/4 RV SA C TRV/10Y _____________

2-RFV-70-565A 3 D-10 C-ACT 3/4 RV SA C TRV/I0Y 2-RFV-70-565B 3 D-8 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-70-570A 3 D-10 C-ACT 3/4 RV SA C TRV/10Y 2-RFV-70-570B 3 D-8 C-ACT 3/4 RV SA C tRV/10Y

Appendix A (Page 61 of 67)

ASME VALVES System: 72 Containment Spray Drawing No: 47W812-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request 72-506 2 D-10 C-ACT 12 CK SA C CVO/Q, CVC/Q 72-507 2 B-10 C-ACT 12 CK SA C CVO/Q, CVC/Q RFV-72-512 2 D-9 C-ACT 3/4 RV SA C RV/RVF RFV-72-513 2 A-9 C-ACT 3/4 RV SA C RV/RVF 72-528 2 D-7 C-ACT 12 CK SA C CVO/Q BDC/Q 72-529 2 A-7 C-ACT 12 CK SA C CVO/Q BDC/Q .

72-547 2 D-3 C-ACT 12 CK SA C CVC/DIF CVO/DIF CMP 72-548 2 A-3 C-ACT 12 CK -SA C CVCIDIF CVO/DIF CMP 72-555 2 G-3 C-ACT 8 CK SA C CVC/DIF CVO/DIF CMP 72-556 2 F-3 C-ACT 8 CK SA C CVC/DIF CVO/DIF CMP FCV-72-13 2 B-7 B-ACT 2 GB MO C STO/Q FCV-72-2 2 A-4 A-ACT 12 GT MO C STO/Q STC/Q SLTJ/J FCV-72-20 2 B-10 B-ACT 12 GT MO C STO/Q STC/Q FCV-72-21 2 B-10 B-ACT 12 GT MO 0 STCQ FCV-72-22 2 D-10 B-ACT 12 GT MO 0 STC/Q FCV-72-23 2 E-10 B-ACT 12 GT MO C STO/Q STC/Q FCV-72-34 2 C-7 B-ACT 2 GB MO C STO/Q FCV-72-39 2 D-4 A-ACT 12 GT MO C STO/Q STC/Q SLTJ/J STO/CSD STC/CSD FCV-72-40 2 F-5 A-ACT 8 GT MO C SLTJ/J DTJ-27 STO/CSD STC/CSD FCV-72-41 2 G-5 A-ACT 8 GT MO C SLTJ/J DTJ-27 RFV-72-40 2 G-5 AC-ACT 1/2 RV SA C TRV/10Y _

RFV-72-41 2 J-5 AC-ACT 1/2 RV SA C TRV/10Y

Appendix A (Page 62 of 67)

ASME VALVES System: 74 Residual Heat Removal Drawing No: 47W810-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Re ks Number Class Coord. Category Size Type Type Position e___________Request emar RFV-74-505 2 G-4 C-ACT 3 RV SA C RWRVF 74-514 2 E-9 C-ACT 8 CK SA C CVO/CSD CVC/CSD DTJ-29 74-515 2 B-9 C-ACT 8 CK SA C CVO/CSD CVC/CSD DTJ-29 74-530 2 D-6 B-ACT 2 GB M C MS/2Y 74-531 2 B-6 B-ACT 2 GB M C MS/2Y 74-554 2 E-6 C-ACT 8 CK SA C CVO/CSD CVC/Q DTJ-29 74-555 2 B-6 C-ACT 8 CK SA C CVO/CSD CVC/Q DTJ-29 STO/CSD STC/CSD FCV-74-1 I F-3 A-ACT 14 GT MO C SLTP/TS RV-3 DTJ-28 FCV-74-12 2 F-7 B-ACT 2 GB MO C STO/Q STC/Q FCV-74-16 2 E-5 B-ACT 8 BF DIA 0 STC/Q STO/Q, FSO/Q STO/CSD STC/CSD FCV-74-2 I F-3 A-ACT 14 GT MO C SLTP/TS RV-3 DTJ-28 FCV-74-21 2 B:0- B-ACT 14 GT MO 0 STC/CSD . DTJ-23 FCV-74-24 2 - A-7 xB-ACI 2 GB MO C STO/Q STC/Q _ __

FCV-74-28 2 B.S ;B-ACT 8 BF DIA 0 STC/Q STO/Q, FSO/Q FCV-74-3 2 D-1  ;- B-ACT 14 GT MO 0 STC/CSD DTJ-23 FCV-74-32 2 - 0-5 B-ACT 8 BF DIA C STC/Q STO/Q, FSOIQ NO RPI FCV-74-33 2 0-5 B-ACT 8 GT MO 0 STC/CSD STO/CSD _ DTJ-21 FCV-74-35 2 B-5 B-ACT 8 GT MO 0 STC/CSD STO/CSD DTJ-21 HCV-74-36 2 ;B- &ACT - 8 GT M C MS/2Y HCV-74-37 2 C-7 = =B-ACT 8 GT M C MS/2Y .

Appendix A (Page 63 of 67)

ASME VALVES System: 77 Waste Disposal Drawing No: 47W830-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Teti Req d Relief Number Class Coord. Category Size Type Type Position esng_______Request mar FCV-77-10 2 E-1 A-ACT 3 DIA DIA 0 FSC/Q STCtQ, SLTJ/J FCV-77-18 2 B-5 A-ACT 1 DIA DIA 0 FSC/Q STC/Q, SLTJ/J FCV-77-19 2 B-6 A-ACT 1 DIA DIA 0 FSC/Q STC/Q, SLTJ/J FCV-77-20 2 C-6 A-ACT 1 DIA DIA C FSC/Q STC/Q, SLTJ/J FCV-77-9 2 D-1 A-ACT 3 DIA DIA 0 FSC/Q STC/Q, SLTJ/J System: 77 Waste Disposal Drawing No: 47W830-6 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Remarks Number Class Coord. Category Size Type Type Position Request 77-849 2 G-7 AC-PAS 3/4 CK SA C SLTJUJ 77-868 2 B-6 AC-PAS 1 CK SA C SLTJUJ System: 77 Waste Disposal Drawing No: 47W851-1

Appendix A (Page 64 of 67)

ASME VALVES System: 78 Spent Fuel Pit Cooling Drawing No: 47W855-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Number Class Coord. Category Size Type Type Position Testing Required Request Remarks 1-78-557 2 G-7 A-PAS 4 DIA M C SLTJ/J 1-78-558 2 G-8 A-PAS 4 DIA M C SLTJ/J 1-78-560 2 G-8 A-PAS 6 GT M C SLTJ/J 1-78-561 2 G-7 A-PAS 6 GT M C SLTJ/J 2-78-557 2 G4 A-PAS 4 DIA M C SLTJ/J 2-78-558 2 GA A-PAS 4 DIA M C SLTJ/J 2-78-560 2 GA A-PAS 6 GT M C SLTJU 2-78-561 2 G4 A-PAS 6 GT M C SLTJ/J

Appendix A (Page 65 of 67)

ASME VALVES System: 81 Primary Water Drawing No: 47W819-1 Valve ASME Drawing Valve Valve Valve Actuator Normal Relief Remarks Number Class Coord. Category Size Type Type Position Testing Required Request CVC/CSD, BDO/NO 1-81-502 2 PF AC-ACT 3 CK SA C SLTJ/J DTJ-30 1-FCV-81-12 2 F4 A-ACT 3 DIA DIA 0 FSC/Q STC/Q, SLTJ/J CVC/CSD, BDO/NO 502 2 C4 AC-ACT 3 CK SA C SLTJ/J DTJ-30 2-FCV-81-12 2 C4 A-ACT 3 DIA DIA 0 FSC/Q STC/Q, SLTJ/J I I

Appendix A (Page 66 of 67)

ASME VALVES System: 84 Flood Mode Boration Drawing No: 47W809-7 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief I Number Remarks Class Coord. _ Category Size Type I Type I Position ReTestst 1-84-51 1 = l 2 F-7 _ A-PAS 1 GB M. LC SLTJ/J

_ A-PAS T 1 I GB I M I 2-84-51 1_ 2 F-4 LC SLTJ/J I +

-- 1. I . . I....

Appendix A (Page 67 of 67)

ASME VALVES System: 90 Radiation Monitoring Drawing No: 47W610-90-3 Valve ASME Drawing Valve Valve Valve Actuator Normal Testing Required Relief Number Class Coord. Category Size Type Type Position Request Remarks FCV-90-107 2 B-9 A-ACT 1-1/2 GB DIA 0 FSC/Q STC/Q, SLTJ/J FCV-90-108 2 C-8 A-ACT 1-1/2 GB DIA 0 FSC/Q STCiQ, SLTJ/J FCV-90-109 2 C-8 A-ACT 1-1/2 GB DIA 0 FSC/Q STC/Q, SLTJ/J FCV-90-110 2 C-8 A-ACT .1-1/ GB DIA 0 FSC/Q STC/Q, SLTJ/J _

FCV-90-111 2 D-9 A-ACT 1-1/2 GB DIA 0 FSC/Q STC/Q, SLTJ/J FCV-90-113 2 B-5 A-ACT 1-112 GB DIA 0 FSC/Q STC/Q, SLTJ/J FCV-90-114 2 CA A-ACT 1-1/2 GB DIA 0 FSC/Q STC/Q, SLTJ/J 2 CA A-ACT 1-1/2 GB DIA 0

.CV-90-115FSCQ STC/Q, SLTJIJ FCV-90-116 2 CA A-ACT 1-1/2 GB DIA 0 FSC/Q STC/Q, SLTJ/J  :

FCV-90-117 2 D-5 A-ACT 1-1/2 GB DIA 0 FSCIQ STC/Q, SLTJLJJ____

Appendix B (Page 1 of 3)

SYMBOLS USED INTHE VALVE TEST PROGRAM Valve Types Symbol Meaning BF Butterfly BA Ball CK Check DIA Diaphragm GT Gate GL Globe PLG Plug RV Relief SC Stop Check Valve Actuator Types Symbol Valve Actuator Type DIA Diaphragm Air Operator M Manual MO Motor Operator SA Self Actuated SO Solenoid Operator CYL Cylinder Operator HYD Hydraulic Operator Valve Positions Symbol Valve Position 0 Open C Closed LO Locked Open LC Locked Closed TH Throttled Valve position determined by other system parameters as in the case of any check

._ valve.

Appendix B (Page 2of3)

SYMBOLS USED IN THE VALVE TEST PROGRAM Valve Positions Symbol Valve Position BDC Check Valve Bi-directional Closed (not a safety function)

BDO Check Valve Bi-directional Open (not a safety function)

CVC Check Valve Closure CVO Check Valve Full Open MS Manual Stroke FSC Fail Safe Closed FSO Fail Safe Open RPI Remote Position Indication SLTJ Seat Leakage Test in accordance with Appendix J SLTP Seat Leakage Test for pressure isolation ET Exercise Test (no timing)

STC Stroke Time Closed STO Stroke Time Open RV Relief Valve Test TRV Thermal Relief Valve Test CMP Check Valve Condition Monitoring

Appendix B (Page 3 of 3)

SYMBOLS USED IN THE VALVE TEST PROGRAM Frequency Codes Symbol Frequency CSD These valves have been specifically identified as valves which cannot be tested during power operation. These valves shall be full stroked tested during cold shutdowns according to the CSD rules (but not more often than once every three months). Note: 3 months equals 92 days.

CSD9 These valves have been specifically identified as valves which cannot be tested during power operation. These valves shall be full stroke tested during cold shutdowns (but not more often than once every nine months). Note: 9 months equals 276 days.

DIF At the disassembly and inspection program frequency J As required by 10 CFR 50 Appendix J NO Normal Operation Q Quarterly (at least once every 92 days)

RCP These valves have been specifically identified as valves which cannot be tested during operation of the Reactor Coolant Pumps (RCPs).

These valves shall be full stroke tested during cold shutdowns according to the CSD and RCP rules only if the RCPs are stopped, but not more often that once every three months. Note: 3 months equals 92 days.

RO Exercise full stroke at refueling only. These valves are identified as valves which cannot be full stroke tested during power operation or cold shutdown or relief is requested for an alternate frequency. These valves shall be full stroke tested during refueling.

RVF At the relief valve test plan frequency per OM Code Appendix I TS Technical Specification Frequency 2Y Two Years 10Y Ten Years HSD Testing is to be performed while the unit is at Hot Shutdown during RFO.

See Technical Specifications for definition HSB Testing is to be performed while the unit is at Hot Standby during RFO.

See Technical Specifications for definition

SQN _ ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V rUnit 0, 1, & 2 Rev. 0000 I Page 101 of 134 Appendix C (Page 1 of 29)

DEFERRED TEST JUSTIFICATIONS Valves listed below are herein specifically identified by the Licensee as valves which cannot be exercised during power operation, per OM Code ISTC-3521 and -3522. The table lists the System, Valve Number, Code Class, Basis for Deferred Testing for each valve which is being tested on an alternate testing/frequency.

DTJ-1 System: Main Steam System Valves: FCV-1-4, FCV-1-11, FCV-11-22, FCV-1-29 Class: 2 Category: B-ACT Function: Close to isolate the Main Steam Line.

Impractical Requirement: Full Stroke and Part Stroke exercise quarterly.

Basis for Deferred Test: Full stroke exercising of these valves during operation could cause SG level transients which could result in a plant trip.

Part stroke excercising of these valves also can cause Steam Generator (SG) transients. Additionally, the revised standard technical specifications state that "MSIVs should not be tested at power since even a part-stroke exercise increases the risk of a valve closure when the unit is generating power."

Alt Testing/Frequency: These valves will be full stroke exercised during cold shutdown.

[

i SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 102 of 134 Appendix C (Page 2 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-2 System: Safety Injection System Valves: FCV-63-63, FCV-63-87, FCV-63-107, FCV-63-127 Class: 2 Category: B-ACT Function: Normally closed valve that may be opened to vent nitrogen from the associated cold leg accumulator if unisolated following a LOCA or non-LOCA shutdown.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising this valve quarterly during operation connects an ASME Code Class 2 passive cold leg accumulator with non nuclear code class piping/components. This could cause a loss of the accumulator nitrogen pressure placing the unit in a condition outside the design and licensing basis since all four accumulators are assumed available for the large break LOCA.

The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

DTJ-3 System: Main Steam System Valves: FCV-1 -17, FCV-1 -18 Class: 2&3 Category: B-ACT Function: Isolate on terry turbine steam line break via high temperature signal from TD AFW Pump Room.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: - Closing either of these valves during power causes loss of steam to the steam driven auxiliary feedwater pump. Failure of either of these two normally open valves in the closed position will result in no heat sink for the loss of all AC power accident.

The valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 3 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-4 System: Main Steam System Valves: PCV-1-5, PCV-1-12, PCV-1-23, PCV-1-30 Class: 2 Category: BC-ACT Function: Must close for Steam Generator isolation and for containment isolation and must operate for RCS temperature control and cooldown to cold shutdown.

Impractical'Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Basis for Deferred Test: Opening valve during power operation (full or partial stroke) will cause steam blowdown to the atmosphere and a steam generator level transient which could result in an inadvertent safety injection signal and/or plant trip.

Closure of the manual isolation valve in series with the PCV is not practical during operation due to high temperatures inside the main steam valve room.

Alt Testing/Frequency: Full Stroke exercise during cold shutdown.

DTJ-5 System: Feedwater System Valves: FCV-3-33, FCV-3-47, FCV-3-87, FCV-3-100 VLV-3-508, VLV-3-509, VLV-3-510, VLV-3-511 Class: 2 Category: B-ACT and C-ACT Function: The FCVs must close for feedwater isolation, containment isolation and Steam Generator (SG) isolation. These check valves must close to prevent reverse AFW flow or SG blowdown.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising these valves during power operation, full or partial, causes a loss of feedwater to the loop they supply. When feedwater flow is restored, the resulting SG level shrink could cause a reactor trip. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke the FCVs during cold shutdown and verify the checks closed during cold shutdown.

Appendix C (Page 4 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-6 System: Auxiliary Feedwater System Valves: 3-805, 3-806, 3-810 Class: 3 Category: C-ACT Function: Check valves 3-805, 3-806, and 3-810 open to admit auxiliary feedwater flow from the condensate storage tank to the auxiliary feedwater pump's suction; and close when the ERCW is aligned to auxiliary feedwater pump suction.

Impractical Requirement: Full stroke exercise quarterly.

Basis for Deferred Test: Full stroke exercising these valves during power operation could result in severe thermal shock to the auxiliary feedwater nozzles and cause SG level transients and a unit trip.

Alt Testing/Frequency: These valves will be full stroked during hot shutdown or hot standby, but not more often than once per three months.

DTJ-7 System: Chemical and Volume Control System Valve: 62-525, 62-532 Class: 2 Category: C-ACT Function: These check valves open to supply charging pump flow from RWST for safety injection.

Impractical Requiremlent: Exercise valve quarterly at full flow Basis for Deferred Te,st: The Centrifugal Charging Pumps cannot be run at full flow during normal operation due to the resulting undesirable temperature transients and boron concentration changes.

Operation of the CCPs during cold shutdown is undesirable due to the inability to letdown that full flow and the potential for cold over pressurization.

Alt Testing/Frequenci y: These valves will be full stroked open during refueling.

Appendix C (Page 5 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-8 System: Chemical and Volume Control System Valve: 62-504 Class: 2 Category: C-ACT Function: This check valve opens to admit flow from refueling water storage tank to the centrifugal charging pumps and closes to prevent back flow to RWST during recirculation mode of ECCS.

Impractical Requirement: Exercise quarterly at full flow.

Basis for Deferred Test: Charging pumps cannot be run at full flow or reduced flow taking suction from the RWST without causing undesirable RCS temperature and/or boron concentration changes resulting in boration and power changes and could result in a plant trip.

Full flow cannot be obtained during CSD with Reactor vessel head in place due to the inability to letdown full flow and the potential for cold over pressurization of the RCS.

Alt Testing/Frequency: Exercise at full flow at refueling.

DTJ-9 System: Safety Injection System Valve: 63-502 Class: 2 Category: C-ACT Function: This check valve opens to admit flow from RWST to the RHR pumps during safety injection and closes to prevent flow to RWST during recirculation mode of ECCS.

Impractical Requirement: Exercise quarterly at full flow.

Basis for Deferred Test: The RHR pumps do not develop sufficient head to pump to the reactor at normal operating pressures. The refueling cavity dewatering line cannot be used because the valve alignment required results in degrading both trains of RHR. Capabilities of the CVCS letdown system preclude use during cold shutdowns. Exercising 63-502 closed during power operations would require closure of FCV-63-1 and inoperability of both trains of low head SIS.

Alt Testing/Frequency: Exercise valve during refueling outage, but not more often than once every three months.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 106 of 134 Appendix C (Page 6 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-10 System: Compressed Air System Valves: I-FCV-32-80, 2-FCV-32-81, 1-FCV-32-102,2-FCV-32-103, I -FCV-32-110, 2-FCV-32-111 Class: 2 Category: A-ACT Function: These valves close on a phase B containment isolation signal and open to supply control air to valves inside containment Impractical Requirement: Full or partial exercise quarterly.

Basis for Deferred Test: Exercising these valves during operations results in a loss of control air to control valves inside containment and could result in valves going to their failed position and resulting in a possible unit trip. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

DTJ-11 System: Post Accident Sampling System Valves: FSV-43-250, FSV-43-251, FSV-43-309, FSV-43-310, FSV-43-317, FSV-43-341 Class: 2 Category: B-ACT Function: These valves must close or remain closed for containment isolation.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: These FSVs are containment isolation valves that do not receive a containment isolation signal. Testing during operation would require a violation of Containment Integrity.

The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 7 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-12 System: Chemical and Volume Control System Valves: LCV-62-132, LCV-62-133, LCV-62-135, LCV-62-136 Class: 2 Category: B-ACT Function: These valves operate to switch the centrifugal charging pumps suction from the VCT to the RWST on a safety injection or low VCT level signal.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Stroking these valves during power operation would cause unacceptable boron transients leading to RCS temperature and power transients which could result in unit trip. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

DTJ-13 System: Chemical and Volume Control System Valves: 62-543, FCV-62-84 Class: I and 2 Category: C-ACT and B-ACT Function: Check valve 62-543 must open to allow charging flow and close for containment isolation. FCV-62-84 must close for RCPB isolation.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Full or partial stroking of these valves causes thermal cyclic fatigue to the letdown heat exchanger, charging connections to the RCS and, in the case of FCV-62-84, thermal cyclic fatigue to the Pressurizer spray nozzle. In addition, stroking of the check valve closed during power operation is not practical since performance of the closure test requires isolation of the normal charging path for a prolonged period of time. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Exercise 62-543 during refueling outages. Full stroke exercise FCV-62-84 during cold shutdown.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 108 of 134 Appendix C (Page 8 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-14 System: Chemical and Volume Control System Valves: FCV-62-69, FCV-62-70, FCV-62-72, FCV-62-73, FCV-62-74, FCV-62-77, FCV-62-90, FCV-62-91 Class: 1 and 2 Category: B-ACT Function: These valves allow for charging and letdown flow from the CVCS to/from the RCS. FCV-62-72, FCV-62-73, FCV-62-74, FCV-62-77 and FCV-62-90 must close or be capable of closing for containment isolation. FCV-62-69 and 70 must close for RCPB isolation.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Full or partial stroking of these valves causes thermal cyclic fatigue to the letdown heat exchanger, letdown and charging connections to the RCS. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke during cold shutdown.

DTJ-15 System: Chemical and Volume Control System Valves: 62-928, 62-930 Class: 3 Category: C-ACT Function: These check valves open to allow boric acid flow to the centrifugal charging pumps suction.

Impractical Requirement: Full exercise quarterly.

Basis for Deferred Test: Stroking these valves during power operation would cause unacceptable boron transients leading to RCS temperature and power transients which could result in unit trip.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

/

Appendix C (Page 9 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-16 System: Safety Injection System Valve: FCV-63-1 Class: 2 Category: B-ACT Function: Allows flow from the RWST to both trains of RHR Pumps and closes during recirculation mode of ECCS.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising valve during operation results in losing suction from RWST to both trains of residual heat removal and placing the unit in a condition outside the design and licensing basis. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

DTJ-17 System: Safety Injection System Valve: FCV-63-3 Class: 2 Category: B-ACT Function: This valve allows recirculation of both SiPs miniflow back to the RWST and closes during recirculation mode of ECCS.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising valve during operation results in losing the miniflow recirculation flow path for both trains of safety injection pumps and placing the unit in a condition outside the design and licensing basis. If the pumps started without recirculation, severe damage to both pumps could occur. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 10 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-1 8 System: Safety Injection System Valve: FCV-63-5 Class: 2 Category: B-ACT Function: This valve allows flow from the RWST to both trains of SIPs and closes during recirculation mode of ECCS.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising valve during operation results in losing suction from RWST to both trains of safety injection pumps and placing the unit in a condition outside the design and licensing basis. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

DTJ-19 System: Safety Injection System Valve: FCV-63-22 Class: 2 Category: B-ACT Function: This valve is normally open and its closure isolates both trains of safety injection from their normal flow path to the cold legs.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising valve quarterly isolates both trains of safety injection from their normal flow path to the cold legs and places the unit in a condition outside the design and licensing basis. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 11 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-20 System: Safety Injection System Valves: FCV-63-8, FCV-63-11, FCV-63-72, FCV-63-73 Class: 2 Category: B-ACT Function: FCV-63-8 and 11 connect the discharge of the low head RHRPs to the suction of the higher head CCPs and SIPs during the recirculation mode of ECCS. FCV-63-72 and 73 are the containment ECCS sump isolation valves that open to provide the supply to the RHRP's suction during the recirculation mode of ECCS.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: These valves are associated with the containment sump and their operation during power operation could cause loss of the RWST inventory and flooding of lower containment which would result in inoperability of both trains of safety injection; placing the unit in a condition outside the design and licensing basis. FCV-63-8 and -11 are interlocked with FCV-63-72 and

-73. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

DTJ-21 System: Safety Injection and Residual Heat Removal System Valves: FCV-63-93, FCV-63-94, FCV-63-172, FCV-74-33, FCV-74-35 Class: 2 Category: B-ACT Function: These valves are associated with the RHR flowpaths to the RCS hot and cold legs.

Impractical Requirement:. Full or partial stroke exercise quarterly.

Basis for Deferred Test: Closing the normally open valves or opening the normally closed hot leg injection valve FCV-63-172 during operation results in less than the required RHR cold leg injection flow capability placing the unit in a condition outside the design and licensing basis. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 112 of 134 Appendix C (Page 12 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-22 System: Safety Injection System Valves: FCV-63-67, FCV-63-80, FCV-63-98, FCV-63-1118 Class: 2 Category: B-ACT Function: These valves are on the outlet of the SIS cold leg accumulators and are maintained open with power removed while the RCS is above 1000 psig. Inaddition, they will auto open on increasing pressure and on an Si signal if closed. These valves are closed to isolate the accumulator after blowdown following a LOCA and on decreasing RCS pressure during shutdown following a non-LOCA event.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Power is removed during operation. Exercising (closing) this valve quarterly during operation isolates a passive cold leg accumulator placing the unit in a condition outside the design and licensing basis since all four accumulators are assumed available for the large break LOCA. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 13 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-23 System: Residual Heat Removal Valves: FCV-74-3, FCV-74-21 Class: 2 Category: B-ACT Function: These valves are on the RHR pump suction path from the RWST and the RCS Hot Leg Loop 4. They close during switchover from the RWST to the Containment Sump.

Impractical Requirement: Full or partial stroke exercise quarterly during RHR decay heat removal operation when the suction pressure to the RHR pumps exceeds 300 psig.

Basis for Deferred Test: Exercising these valves with greater than 300 psig line pressure may subject the valves to a differential pressure of greater than 300 psig during stroke testing. The valve operator is not capable of stroking this valve at this high differential pressure. Maximum differential pressure expected during accident conditions is less than 50 psig.

Alt Testing/Frequency: Full stoke exercise quarterly whenever RHR is not in decay heat removal operation with the suction pressure to the pump greater than 300 psig.

Appendix C (Page 14 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-24 System: Essential Raw Cooling Water System Valves: FCV-67-83, FCV-67-87, FCV-67-88, FCV-67-89, FCV-67-90, FCV-67-91, FCV-67-95, FCV-67-96, FCV-67-99, FCV-67-103, FCV-67-104, FCV-67-105, FCV-67-106, FCV-67-107, FCV-67-1 11, FCV-67-112 Class: 2 Category: A-ACT Function: Full or partial stroke quarterly.

Impractical Requirement: Full or partial stroke exercise quarterly during RHR decay heat removal operation when the suction pressure to the RHR pumps exceeds 300 psig.

Basis for Deferred Test: Exercising valve quarterly causes a loss of flow to lower compartment coolers, control rod system drive coolers and reactor coolant pump motor coolers leading to undesirable temperature transients inside the various compartments of the Sequoyah ice condenser containment. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke during cold shutdown.

0-TI-SXI-000-200.V Rev. 0000 Page 115 of 134 Appendix C (Page 15 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-25 System: Essential Raw Cooling Water System Valve: FCV-67-146 Class: 2 Category: B-ACT Function: This valve isolates and throttles the ERCW flow through the CCS plate heat exchangers for Train A and loads necessary for continued safe operation of the unit.

Impractical Requirement: Full or partial stroke quarterly.

Basis for Deferred Test: Exercising valve quarterly causes a loss of cooling water flow to the CCS plate heat exchangers for Train A and all the loads necessary to support operation of the unit (e.g. RCP oil coolers, RCP thermal barriers, letdown and seal return heat exchangers, and various pump seal coolers. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke during cold shutdown.

DTJ-26 System: Safety Injection System Valve: FCV-63-47 Class: 2 Category: B-ACT Function: This valve is required to close for isolation of passive failure and is required to open for shutdown LOCA and loss of RHR.

Impractical Requirement: Full or partial stroke exercise quarterly.

Basis for Deferred Test: Exercising valve during operation results in the loss of two independent trains of ECCS and placing the unit in a condition outside the design and licensing basis. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 16 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-27 System: Containment Spray System Valves: FCV-72-40, FCV-72-41 Class: 2 Category: B-ACT Function: These valves allow flow to the RHR spray headers inside upper containment.

Impractical Requirement: Full or partial stroke quarterly.

Basis for Deferred Test: These valves are interlocked with the containment sump valves. Exercising these valves during operation could result in flooding of lower containment or would result in inoperability of both trains of low head safety injection since operation results in less than the required RHR cold leg injection flow capability; placing the unit in a condition outside the design and licensing basis. The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: Full stroke exercise during cold shutdown.

Appendix C (Page 17 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-28 System: Residual Heat Removal System Valves: FCV-74-1, FCV-74-2 Class: 2 Category: A-ACT Function: These valves allow flow from the RCS to the RHR system for normal cooldown and during shutdown for removal of decay heat.

They are opened to provide suction from the RCS for the Residual Heat Removal pumps when RCS pressure is below set point. They are maintained closed during operation to isolate the high pressure RCS from the low pressure RHR system.

Impractical Requirement: Full or partial stroke quarterly.

Basis for Deferred Test: Valves have interlocks to prevent opening them when RCS is above the RHR design temperature and pressure. Exercising valve during operation results in over pressurizing RHR. Full stroking of RHR return valves during shutdown isolates decay heat removal capacity, mixing capacity needed to maintain uniform boron concentration within the RCS, and ability to produce gradual reactivity changes during boron concentration reductions in the RCS. It is generally not considered prudent to remove a valve from its safety related position to perform a periodic code test when that testing places the unit in an LCO and an overall degraded condition.

With respect to these specific valves, it is deemed additionally ill-advised in consideration of Unresolved Safety Issues (USI) A-31, "Residual Heat Removal Shutdown Requirements" and A-45, "Shutdown Decay Heat Removal Requirements" which addresses concerns regarding loss of residual heat removal capability leading to core damage. Reliability of performing heat removal functions is specifically identified as being dependent on the frequency of events that jeopardize decay heat removal operations. Alternative testing will provide an acceptable level of quality and safety and the increase in the level of safety by normal testing is not commensurate with the difficulties or risks involved. Extended outages of greater than threemonths are not normally anticipated.

The FCV valve control circuit is not designed for partial stroke capability.

Alt Testing/Frequency: These valves will be full stroke exercised while shutting down when going on RHR or starting up when going on RHR if not exercised in the last three months or the projected outage duration would cause valves to require testing prior to startup. Testing may also be performed during core off load when RHR is not required.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 118 of 134 Appendix C (Page 18 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-29 System: Residual Heat Removal System Valves: 74-514, 74-515,74-554, 74-555 Class: 2 Category: C-ACT Function: These check valves open to allow flow from the RHR Pumps and close to prevent reverse flow through an idle pump or miniflow competition (e.g. a stronger pump causing a parallel weaker pump to be deadheaded).

Impractical Requirement: Full stroke exercise quarterly.

Basis for Deferred Test: These valves cannot be exercised open quarterly since the RHR pumps do not develop enough pressure to overcome normal RCS pressure. The refueling dewatering line cannot be used because opening HCV-74-34 would cause degradation of both trains of RHR and placing the unit outside the design and licensing basis. Valves74-514 and -515 cannot be stoked closed since the opening of HCV 36 and -37 would also degrade both trains of RHR and would also allow water to bypass the RHR Heat Exchangers which removes the pump heat during miniflow operation.

Alt Testing/Frequency: Check valves74-514, -515, -554, and -555 will be exercised during cold shutdown.

DTJ-30 System: Primary Water System Valve: 81-502 Class: 2 Category: AC-ACT Function: This check valve closes for containment isolation.

Impractical Requirement: Full stroke quarterly.

Basis for Deferred Test: Exercising this valve results in loss of primary water to the RCP standpipes and PRT. Personnel radiation exposures and valve inaccessibility also prohibit exercising these valves quarterly.

Alt Testing/Frequency: This valve will be exercised closed during cold shutdown.

Appendix C (Page 19 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-31 System: Safety Injection System Valves: 63-543, 63-545,63-547, 63-549,63-551, 63-553,63-555, 63-557,63-558, 63-559 Class: 1 Category: AC-ACT Function: These check valves open to admit flow from SI pumps to RCS during LOCA and close to prevent intersystem LOCA.

Impractical Requirement: Exercise quarterly.

Basis for Deferred Test: SIS pumps do not develop sufficient head to overcome normal RCS pressure. Use of another pump would result in an undesirable temperature transient on RCS components.

Letdown capability will not allow full flow testing with reactor head on. Technical Specification 3.4.6.3 requires these valves to be leak tested following valve actuation and during cold shutdown if they have not been leak tested in the last nine months. The first four valves are aligned in parallel in groups of two. Individual branch lines flow is only measured during refueling outage testing since plant instrumentation is not available to measure individual branch flows. Therefore, justification is provided to allow full stroke exercising during refueling outages. Valve closure will be verified during cold shutdown, not to exceed once per nine months when the pressure isolation boundary leak test required by Technical Specification 3.4.6.3 is performed.

Alt Testing/Frequency: Exercise during refueling outages. Leak test as required by Technical Specification 3.4.6.3.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, &2 Rev. 0000 Page 120 of 134 Appendix C (Page 20 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-32 System: Safety Injection System Valves: 63-581, 63-586,63-587, 63-588,63-589 Class: 1 Category: C-ACT Function: These check valves open to admit flow from centrifugal charging pump(s) to the RCS cold legs during safety injection and closes for RCPB isolation.

Impractical Requirement: Exercise valve on a quarterly basis at full flow.

Basis for Deferred Test: RCS letdown capacity will not allow full flow injection with the reactor vessel head on. Valve cannot be part stroked without discharging cold, borated water into the reactor. This would cause an undesirable temperature and boron concentration transients which could result in a safety injection or unit trip.

Cold water causes thermal stratification stresses at injection nozzles. The last four valves are in parallel and individual branch line flows are only measured during refueling testing since instrumentation is not available to measure the individual branch flows.

Alt Testing/Frequency: Exercise valve each refueling outage.

SQN I ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 d Page 121 of 134 Appendix C (Page 21 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-33 System: Safety Injection System Valves: 63-524, 63-526 Class: 2 Category: C-ACT Function: These check valves open to admit flow from SIS pumps to RCS during LOC and close to prevent flow through idle pump.

Impractical Requirement: Exercise quarterly at full flow.

Basis for Deferred Test: SIS pumps do not develop sufficient head to pump to the RCS during normal operation.

Alt Testing/Frequency: Exercise valves during refueling outage.

DTJ-34 System: Chilled Water System Valves: 0-31C-985, 0-31C-1027 Class: 3 Category: C-ACT Function: These pump discharge check valves open to provide the flow path for the chilled water system.

Impractical Requirement: Bi-directional close test quarterly.

Basis for Deferred Test: Exercise testing these valves to the closed position during operation at power is not practical because there are no system provisions for verifying reverse flow closure. To perform closure testing online or during cold shutdowns would involve setting up test equipment including outside water source to perform testing or disassembling for inspection. The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing of a check valves until a refueling outage.

Alt Testing/Frequency: Exercise valves once per cycle.

Appendix C (Page 22 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-35 System: Essential Raw Cooling Water System (ERCW) Unit 2 only Valves: FCV-67-123, FCV-67-124, FCV-67-125, FCV-67-126 Class: 3 Category: B-ACT Function: These valves open to provide ERCW cooling water flow to the containment spray heat exchanger shell side.

Impractical Requirement: Exercise valve on a quarterly basis, full or partial stroke.

Basis for Deferred Test: The raw water of the ERCW system contains chlorides which can cause heat exchanger tube pitting, and organisms which can produce micro biologically induced corrosion in the heat exchanger piping and shell. To preserve their integrity, the Unit 2 heat exchangers are placed in wet lay-up with demineralized water and corrosion inhibitors, and their chemistry is monitored. Whenever the chemistry specifications are exceeded, the heat exchangers maybe drained, flushed, and again placed in lay-up. During modes 1, 2, 3, and 4, Technical Specification 3.6.2.1 requires that the plant maintain two independent Containment Spray Systems operable or enter an LCO. When a containment spray heat exchanger is drained during the cleanup/lay-up operation, that containment spray loop is declared inoperable placing the unit in an LCO.

Chemistry data demonstrates that the quarterly cycling of the inlet and outlet heat exchanger valves increases the intrusion of raw water, thus forcing the plant to enter the LCO more often to preserve the integrity of the heat exchangers.

Alt Testing/Frequency: Full stroke exercise these valves at least once each refueling outage.

Appendix C (Page 23 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-36 System: Auxiliary Feedwater System Valves: (1) 3-814, 3-815, 3-818 (2) 3-820, 3-821, 3-864 Class: 3 Category: C-ACT Function: (1) These check valves open to provide the minflow path to protect the pumps. (2) These pump discharge checks open to allow flow to the steam generators.

Impractical Requirement: Bi-directional close test quarterly.

Basis for Deferred Test: Exercise testing these valves to the closed position during operation at power is not practical because there are no system provisions for verifying reverse flow closure. The only method of verifying closure during power operation would be to perform a leakage test with an outside pressure source. To perform closure testing during cold shutdowns would involve setting up test equipment and providing an alternate pressure source.

The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing of a check valves until a refueling outage.

Alt Testing/Frequency: These valves will be exercised once each refueling outage.

Appendix C (Page 24 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-37 System: Containment Spray System Valves: 72-528, 72-529 Class: 2 Category: C-ACT Function: These check valves open to provide containment spray flow.

Impractical Requirement: Bi-directional close test quarterly.

Basis for Deferred Test: Exercise testing these valves to the closed position during operation at power is not practical because there are no system provisions for verifying reverse flow closure. To perform closure testing online or during cold shutdowns would involve setting up test equipment to provide an outside pressure source to create a DP across the valve.

Alt. Testing/Frequency: These valves will be exercised during refuel outages.

DTJ-38 System: Component Cooling Water System Valves: (1)70-671, (2) 70-676A, 70-676B Class: 3 Category: C-ACT Function: (1) This check valve is the supply to the thermal barrier booster pumps. (2) These check valves are the thermal barrier booster pumps discharge check valves. They must open to provide cooling.

Impractical Requirement: Bi-directional close test quarterly.

Basis for Deferred Test: Exercise testing these valves to the closed position during operation at power is not practical because there are no system provisions for verifying reverse flow closure. To perform closure testing online or during cold shutdowns would involve setting up test equipment to provide an outside pressure source to create a DP across the valve.

Alt. Testing/Frequency: These valves will be exercised during refuel outages.

Appendix C (Page 25 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-39 System: Reactor Coolant System Valves: FSV-68-394, FSV-68-395 Class: 2 Category: B-ACT Function: These valves open to allow for RCS venting and close for RCPB isolation.

Impractical Requirement: Full or partial stroke quarterly.

Basis for Deferred Test: NRC has requested that Reactor Vessel Head Vents be tested during cold shutdown rather than during power operation.

Stroking these valves at power could result in depressurization of the RCS and resulting unit trip and safety injection. Failure of these valves to close when stroked could result in a LOCA.

Alt. Testing/Frequency: Full stroke during cold shutdown.

Appendix C (Page 26 of 29)

DEFERRED TEST JUSTIFICATIONS DTJ-40 System: Essential Raw Cooling Water System Valves: 2-67-580A, 2-67-580B, 2-67-580C, 2-67-580D Class: 2 Category: AC-ACT Function: These normally open check valves must close for containment isolation.

Impractical Requirement: Closure test quarterly.

Basis for Deferred Test: The upper compartment ventilation cooler containment isolation check valves are tested closed by using static head pressure to close the check valves. These valves are located in upper containment, requiring containment access, and require hooking up hoses to drain. The NRC has determined that the need to setup test equipment is adequatejustification to defer backflow testing of a check valves until a refueling outage.

Alt. Testing/Frequency: Full stroke closed during refueling.

DTJ-41 System: Component Cooling System Valve: 70-679 Class: 2 Category: AC-ACT Function: This check valve allows flow to the RCP thermal barriers and closes for containment isolation.

Impractical Requirement: Full stroke closed quarterly during RCP operation.

Basis for Deferred Test: Exercising this valve during operation of the RCPs results in loss of cooling water flow to the reactor coolant pump thermal barriers introducing the possibility of loss of a RCP seal and a LOCA or a unit trip. Stopping the RCP's for testing would increase the wear and stress on the RCP's, increase the number of cycles on other plant equipment, and would extend the length of cold shutdown outages. The NRC has determined that the need to setup test equipment is adequate justification to defer backflow testing of a check valves until a refueling outage.

Alt. Testing/Frequency: Full stroke exercise during refueling outage when the RCPs are stopped.

Appendix C (Page 27 of 29)

DEFERRED TEST JUSTIFICATIONS Valves listed below are herein specifically identified by the Licensee as valves which cannot be exercised during power operation, per OM Code ISTC-3521 and -3522.

The table lists the System, Valve Number, Code Class, Basis for Cold Shutdown Testing when the RCPs are stopped for each valve which is being tested on a reactor coolant pump shutdown frequency, and alternate testing/frequency. The reactor coolant pump shutdown frequency is described in detail in the Description section of this document.

RCPJ-1 System: Chemical and Volume Control System Valves: FCV-62-61, FCV-62-63 Class: 2 Category: A-ACT Function: There valves are in the RCP seal water return path and isolate on a containment isolation signal.

Impractical Requirement: Full or partial stroke exercise quarterly during Reactor Coolant Pump operation.

Basis for Deferred Test: Exercising these valves during RCP operation challenges a seal water return relief valve and could cause loss of seal water return and probable damage to the reactor coolant pump seals.

The FCV valve control circuit is not designed for partial stroke capability. Stopping the RCP's for testing would increase the wear and stress on the RCP's, increase the number of cycles on other plant equipment, and would extend the length of cold shutdown outages.

Alt. Testing/Frequency: Full stroke exercise during cold shutdown when the RCPs are stopped.

SQN ASME OM CODE VALVE TESTING 0-TI-SXI-000-200.V Unit 0, 1, & 2 Rev. 0000 Page 128 of 134 Appendix C (Page 28 of 29)

DEFERRED TEST JUSTIFICATIONS RCPJ-2 System: Chemical and Volume Control System Valves: FCV-62-9, FCV-62-22, FCV-62-35, FCV-62-48 Class: 2 Category: B-ACT Function: There valves are in the RCP #1 seal water leakoff return path.

Impractical Requirement: Full or partial stroke exercise quarterly during Reactor Coolant Pump operation.

Basis for Deferred Test: Exercising these valves during RCP operation isolates the leakoff from the #1 seal and challenges the #2 seal which could cause damage to the reactor coolant pump seals and a LOCA.

The FCV valve control circuit is not designed for partial stroke capability. Stopping the RCP's for testing would increase the wear and stress on the RCP's, increase the number of cycles on other plant equipment, and would extend the length of cold shutdown outages.

Alt. Testing/Frequency: Full stroke exercise during cold shutdown when the RCPs are stopped.

RCPJ-3 System: Component Cooling System Valves: FCV-70-133, FCV-70-134, FCV-70-87, FCV-70-90 Class: 3 Category: B-ACT or A-ACT Function: These valves allow flow to the RCP thermal barriers and close for containment isolation and to isolate a thermal barrier flow mismatch, except FCV-70-133 which closes to isolate a thermal barrier flow mismatch only.

Impractical Requirement: Full or partial stroke quarterly during RCP operation.

Basis for Deferred Test: Exercising these valves during operation of the RCP results in loss of cooling water flow to all four reactor coolant pump thermal barrier coolers introducing the possibility of thermal barrier failure. The FCV valve control circuit is not designed for partial stroke capability. Stopping the RCP's for testing would increase the wear and stress on the RCP's, increase the number of cycles on other plant equipment, and would extend the length of cold shutdown outages.

Alt. Testing/Frequency: Full stroke exercise during cold shutdown when the RCPs are stopped.

Appendix C (Page 29 of 29)

DEFERRED TEST JUSTIFICATIONS RCPJ-4 System: Component Cooling System Valves: FCV-70-140, FCV-70-141, FCV-70-89, FCV-70-92 Class: 3 Category: A-ACT Function: These valves allow flow to the RCP oil coolers and close for containment isolation.

Impractical Requirement: Full or partial stroke quarterly during RCP operation.

Basis for Deferred Test: Exercising these valves during operation of the RCPs results in loss of cooling water flow to all eight reactor coolant pump oil coolers introducing the possibility of loss of a RCP and a LOCA or a unit trip. The FCV valve control circuit is not designed for partial stroke capability. Stopping the RCP's for testing would increase the wear and stress on the RCP's, increase the number of cycles on other plant equipment, and would extend the length of cold shutdown outages.

Alt. Testing/Frequency: Full stroke exercise during cold shutdown when the RCPs are stopped.

Appendix D (Page 1 of 5)

RELIEF REQUEST RV-1 Alternative for Reactor Head Vent Valve Stroke Timing Component: FSV-68-396, FSV-68-397 Class: 2 Category: B-ACT Function: Valves are opened manually to provide a reactor vessel head vent path; to vent non-condensibles from the head during an accident to promote natural circulation; and to prevent gases from impeding reactor coolant circulation flow through the core.

Impractical Requirement: Quarterly stroke time test.

Basis for Relief: These solenoid valves have no position indication and are totally enclosed which prevents visual confirmation of the valve position and therefore the inability to measure the time that it takes the valve to stroke. These valves are throttle valves with a operator which positions the valve at 0%, 25%, 50%, and 100% which is set through the use of a thumbwheel. However, these valves are fast acting valves with a stroke time of less than two seconds and a stroke of approximately a quarter of an inch.

Alternate Testing: Verify that the valve operates properly using acoustic instrumentation. The acoustic instrumentation takes a signal of the system noise prior to opening the valve. The valve is opened by operating the thumbwheel and another acoustic signal-is obtained at the full open position. The valve is then closed and another acoustic signal is obtained at full closed.

The initial acoustic signal at full closed is compared to the second acoustic signal taken at the full closed position.

Comparative values provides assurance that the valve is moving to the correct positions and that the valve is operating acceptably. However, the signals do not provide the means to measure the amount of time it takes to go from one position to the other. These valves are one inch diameter Target Rock valves with a seal welded bonnet. They are the second of two one inch diameter valves in parallel to each other and are normally closed. An enhanced maintenance program of disassembly and inspection was considered. This method was not considered appropriate for the following reasons. One, this process can lead to assembly and operational problems

Appendix D (Page 2 of 5)

RELIEF REQUEST RV-1 (Continued)

Alternate Testing (cont.): due to distortion of the valve parts caused by the repetitive welding process to reinstall the seal weld every refueling outage. This is not considered acceptable for the purposes of testing and could lead to premature replacement of the valves.

Two, the repetitive removal of the seal weld between the body and the bonnet can cause another problem. When the seal weld is removed, a small amount of the base metal also has to be removed in order to find a separation point past the heat affected zone where the weld metal has not penetrated into the base metal so that the bonnet can be removed from the body.

Every time this operation is performed, more and more of the base metal is removed until the required thickness no longer exist which makes the valve not functional. Third, once the valve is opened and the internals of valve are examined, the condition of the internal parts do not typically give one any more indication of acceptable valve operation than the acoustic monitoring. Considering that there is no known feasible method for measuring the stroke time and an enhanced maintenance program does not provide additional assurance of acceptable valve operation and can possibly be detrimental to acceptable valve operation, the method described above using acoustical instrumentation provides the only known method from which acceptable valve operation can be determined. A refueling outage is the only time the valves can be monitored and the only time maintenance can be performed since the valves are located inside containment.

Frequency: Every refueling outage using acoustic instrumentation.

==

Conclusion:==

Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with 10CFR50.55a(3)(i).

This relief request was approved for the Second Ten Year Interval by TAC NOS.

M94117 and M94118. No changes in Code requirements have occurred affecting this relief request.

Appendix D (Page 3 of 5)

RELIEF REQUEST RV-2 Alternate To Auxiliary Air Compressor ERCW Valve Stroke Timing System: ERCW to Compressed Air System Component: FSV-32-61, FSV-32-87 Class: 3 Category: B-ACT Function: Opens to provide ERCW to the auxiliary control air compressors.

Impractical Requirement: Stroke time test.

Basis for Relief: These solenoid valves are part of the auxiliary air compressor package, have no position indication and are totally enclosed, preventing visual confirmation of valve position. Satisfactory operation of the auxiliary air compressors verifies that FSV-32-61 and 87 operates. Alternative testing will provide an acceptable level of safety.

Alt. Testing: Exercise by observing the auxiliary air compressors to ensure the solenoid valve opens to supply ERCW cooling by ensuring auxiliary air compressor temperature is acceptable.

Frequency for Alt. Testing: Quarterly

==

Conclusion:==

Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with I OCFR50.55a(3)(i).

This relief request was approved for the Second Ten Year Interval by TAC NOS.

M94117 and M94118. No changes in Code requirements have occurred affecting this relief request.

Appendix D (Page 4 of 5)

RELIEF REQUEST RV-3 RHR Valve Exercising During Cold Shutdown System: Residual Heat Removal (RHR)

Valve: FCV-74-1, FCV-74-2 Class: I Category: A-Active Function: Open to provide suction from the RCS for the Residual Heat Removal pumps when RCS pressure is below set point. Close to act as pressure isolation valves to prevent over pressurization of the RHR system Impractical Requirement: Full stroke exercise every three months while in cold shutdown or refueling when RHR is required to be operable.

Basis for Relief: Full stroking of RHR return valves during shutdown isolates decay heat removal capacity, mixing capacity needed to maintain uniform boron concentration within the RCS, and ability to produce gradual reactivity changes during boron concentration reductions in the RCS. It is generally not considered prudent to remove a valve from its safety related position to perform a periodic code test when that testing places the unit in an overall degraded condition. With respect to these specific valves, it is deemed additionally ill-advised in consideration of Unresolved Safety Issues (USI) A-31, "Residual Heat Removal Shutdown Requirements" and A-45, "Shutdown Decay Heat Removal Requirements" which address concerns regarding loss of residual heat removal capability leading to core damage. Reliability of performing heat removal functions is specifically identified as being dependent on the frequency of events that jeopardize decay heat removal operations. Alternative testing will provide an acceptable level of quality and safety and the increase in the level of safety by normal testing is not commensurate with the difficulties or risks involved. Extended outages of greater than three months are not normally anticipated.

Alt. Testing: Full stroke exercise while shutting down when going on RHR as required. Full stroke exercise during startup when coming off RHR as required. Testing while core is off loaded is also acceptable.

Appendix D (Page 5of5)

RELIEF REQUEST RV-3 (Continued)

Frequency for Alt. Testing: Full stroke exercise while shutting down when going on RHR if not exercised in the last three months, or the projected outage duration would cause valves to require testing prior to startup.

If not stroked during shutdown the surveillance interval expires during outage, or if outage duration exceeds three months, valves need not be exercised until startup when coming off RHR.

==

Conclusion:==

Based upon the above discussion, the alternative test provides an acceptable level of quality and safety. Authorization to implement the proposed alternative is requested in accordance with 10CFR50.55a(3)(i).

This relief request was approved for the Second Ten Year Interval by TAC NOS.

M94117 and M94118. No changes in Code requirements have occurred affecting this relief request.