ML20062D796
| ML20062D796 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/30/1978 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20062D794 | List: |
| References | |
| PROC-781130, NUDOCS 7811300220 | |
| Download: ML20062D796 (65) | |
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I PBISI-2 PEACH BOTTOM ATCMIC POWER STATION - -
INSERVICE INSPECTION PROGRAM UNIT 2 AND COMMON PLANT COfffENTS 1.0 I!FfRODUCTION 1.1 General 1.2 Responsibility 1.3 Records 1.4 Methods of Examinatica
.1. b 1 volumetric Examination 1.4.2 Surface Exa:mination 1.A3 Visual Examination 1.5 Classification 'of Components 1.6 Repair Procedures
- 2. 0 CIASS 1 PROGRAM 2.1 Identification of Components 2.2 Examinations Planned 2.2.1 Reactor Pressure Vessel 2.2.2 Piping 2.2.3 Pumps 2.2.4 Valves 2.3 System Leakage and Hydrostatic Pressure Tests 2.4 Requests for Relief from ASME Section XI Requirement.s 3.0 CLASS 2 PROGRAM 3.1 Identification of components 3.1'.1 Standby Liquid control System 3.1.2 Reactor Core Isolation Cooling System 3.1. 3 Residual Heat Removal System 3.1.4 Core Spray cooling System 3.1.5 High Pressure Coolant In-Jection System 3.1.6 Fuel Pool Cooling and Cleanup System i November 1978 .
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t l PBISI-2 3.2 Framinations Planned - Non-Exempt Components 3.2.1 Pressure Vessels 3.2.2 Piping 3.2.3 Pumps (
3.2.4 Valves 3.3 System Pressure Tests 3.4 Request for Relief from ASME Section XI Raquirements 4.0 CIASS 3 PROGRAM !
4.1 Identification of Components 4.1.1 Emergency Service water System 4.1.2 High Pressure Service Water System !
4.1.3 Emergency cooling System 4.1. 4 Fuel Pooling Cooling 5 Cleanup System !
4.2 Inspections Planned l 4.3 Requests for Relief from ASME Section XI Requirements "[
5.0 INSERVICE TESTING OF PUMPS AND VAL 7ES 5.1 General i 5.2 Inservice Testing Program for Class 1, 2, and 3 Pumps !
5.3 Requests for Relief from ASME Section XI Requirements '
5.4 Inservice Testing Program for Class 1, 2, and 3 Valves 5.5 Requests for Relief from ASME Section XI Requirements >
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11 November 1978 ;
PBISI-2 PEACH BOTTOM ATCMIC POWER STATION INSERVICE INSPECTION PROGRAM UNIT 2 AND COMMON PLANT TABLES TABLE NO. TITLE
- 2. 2- 1 Inservice Inspection Program for Class 1 Components
/ 3. 2- 1 Inservice Inspection Program for class 2 Non-Exempt Components 3.3-1 System Pressure Tests for class 2 Components 4.2-1 Inservice Inspection Program for Class 3 Components ,
5.2-1 Inservice Testing Program for Equivalent ASME Class 1, 2, and 3 Pumps S.4-1 Inservice Testing Program for Equivalent ASME Class 1, 2, and 3 Valves lii November 1978
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PBISI-2 PEACH BOTTOM ATOMIC POWER STATION INSERVICE INSPECTION PROGRAM UNIT 2 AND COMMON PLAWf FIGURES FIGURE NO. n'Ug ISI-M-315 Inservice Inspection Boundaries, Emergency Service Water and High Pressure Service Water Pumps ISI-M-330 Inservice Inspection Boundaries, Emergency Cooling System .
ISI-M-3 51 Inservice Inspection Boundaries, Nuclear'Boi.ler ISI-M- 3 54 Inservice Inspection Boundaries, Reactor Water Clean-up System ISI-M-357 Inservice Inspection Boundaries, Control Rod Drive Hydraulic System ISI-M-358 Inservice Inspection Boundaries, Standby Liquid Control System ISI-M-3 59 Inservice Inspection Boundaries, Reactor Core i
Isolation Cooling System ISI-M-361 Inservice Inspection Boundaries, Residual Heat Removal System ISI-M-362 Inservice Inspection Boundaries, Core Spray Cooling System ISI-M-363 Inservice Inspection Boundaries, Fuel Pool Cooling & Cleanup ISI-M-365 Inservice Inspection Boundaries, High Pressure Coolant Injection System 4
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iv November 1978
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PBISI-2 i
SECTION
1.0 INTRODUCTION
1.1 GENERAL Ihis program was originally written by Philadelphia Electric company to describe the application.of Section XI of the American gociety of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, " Rules for Inservice Inspection of Nuclear Reactor Coolant Systems", January 1, 1970, to Peach Bottom Atomic Power Station, Unita 2 and 3. The program cov_ered Class 1 components only.
i Ihis revision is an upgrading of the program for Unit 2 and common giant to address the 1974 Edition of Section XI " Rules for Inservice Inspection of Nuclear Power Plant Components *, through the Summer 1975 A_ddenda and applies to equivalent Class 1, Class 2, and class 3 componsats for _ inservice evaminations and for inservice testing of pumps and valves. Ior Unit 2 and common plant, the next regular 40-month inspection geriod begins on .
November 5, 1977.
A_s stated in the original program (Appendix I of the Peach Bottom Final gafety Analysis Report), the subject units are boiling
- water .r_eactors typical of the General Electric company's product line of 196 7. Ihe basic design is not consistent with the examination r_equirements of later codes; therefore, 100%
compliance with the code is not feasible. Ihis program identifies the areas in which Code compliance cannot be a,chieved.
I_n upgrading from the initial class 1 components program, review at the _end of the first 5 year period has been eliminated. Ihe new program establishes, from the date of its inception, revised requirements _ based on a ten-year inspection interval. In accordance with the existing regulations of 10 CFR 50.55a, the
_ inservice examination program for class 1, 2, and 3 components will be reviewed and modified as required each 40 months. Ihe inservice testing program for pumps and valves will be similarly reviewed a_nd modified each 20 months.
1.2 RESPONSIBILITY P_biladelphia Electric Company bears the overall responsibility
.for the performance of the inservice inspections. Certain nondestructive (NDT) examinations will be performed by a qualified examination agency. Ihe results and evaluation of the examinations will be reported to P_hiladelphia Electric Company for final evaluation and disposition.
1-1 November 1978
PBISI-2
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13 RECORDS R,ecords and documentation of all information and inspection results, which provide the basis for evaluation and which facilitate cvrison with results from previous and subsequent inspections, will be maintained and available for the active life of the plant in accordance with S_ection XI, IWA-6000.
1.4 METHODS OF EIAMINATION The method of examination planned for each area is delineated in subsequent sections. P_ersonnel performing NDT evaminations will i
be trained in accordance with _the American Society for fondestructive Testing (ASNT) " Recommended _ Practice SNT-TC-1A, supplements and Appendices", as applicable f,or technique and method used.
14.1 A volumetric examination is used for the purpose of indicating the presence of subsurface discontinuities with a method or technique capable of examtning the entire volume of metal contained beneath the surface to be examined. pso such methods are radiographic (RT) and ultrasonic (UT) examinations.
[or volumetric examination the major emphasis in this program is placed _cn the use of UT methods for the following reasons: ,
- 11) Other work can be conducted in the area where u'.trasonie examinations are being performed, thus pctentially reducing outage time.
- 12) In general, less radiatica exposure is required than for RT examination.
- 13) In some locations, background radiation levels would preclude RT examination.
- 14) Preparation of surface for examination is ginimal, and vessels or piping may be flooded.
- 15) Methods have been developed to permit remote a
examination with minimum occupancy time in gertain areas.
- 16) Records have been obtained utilizing UT to indicate gre-operational conditions for comparison with subsequent examinations.
1-2 November 1978 j
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PSISI-2 1 4.2 A surface examination is used to delineate or verify the presence of surface or near-surface cracks or discontinuities a_nd may be conducted by applying either magnetic particle (MP) methods or liquid penetrant (PT) methods where the surface conditions, material, and accessibility p_ermits such an examination.
1 4.3 A visual (VT) examination is employed to provide a report of _the general condition of the part, ccsaponent or surface to be examined, including such conditions as scratches, wear, p_ racks, corrosion, or erosion on the surfaces, or _ misalignment or movement of the part or component, or e_vidence of leaking.
- 1. 5 CLASSI?ICATION OF COMPONENTS Components have been classified for purposes of inservice inspection in accordance with the requirements of 10 CFR 50.55a and section XI of the Code and in consideration of the guidaru e contained in Regulatory Guide 1.26.
I_t must be noted that the classification of components as equivalent to ASME Class 1, 2, or 3 implies equivalency for c_urposes of inservice inspection only and does not imply that the components were designed in accordance with ASME requirements.
Since most of the basic plant design was accomplished prior to Cecember 1969, codes and standards applicable at that time were used, as set forth in the ESAR.
The component classification is shown in the ISI-M , _ _ series of f,igures and is discussed in detail in subsequent sections.
Ihe ISI diagrams are Piping and Instrumentation diagrams marked up to define the _ inservice inspection beimdaries and certain notes and details not r_ elated to inservice inspection have been deleted.
- 1. 6 REPAIR PROCEDURES gepairs to the pressure retaining boundary of ASME class 1, 2, or 3 1 equivalent) components will be performed in accordance with IWA-4000 b_y utilizing Philadelphia Electric Company approved procedures which generally comply with the Code applicable to the construction of the c_omponent. gepair procedures for quality assured components will be reviewed by an authorized Code inspector prior to imp 1.9 mentation. Repair work in progress will also be subject to surveillance by an authorized inspector.
1-3 November 1978
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S ECTION 2. 0 ;
i CLASS 1 PROGRX4 !
2.1 IDENTIFICATION OF COMPONENTS ;
i Ihe ASME Class 1 (equivalent) components are outlined or. ;
ISI-M-351 and further details are shown on the individual system '
diagrams. Ihe reactor pressure vessel and selected components in :
the following systems are included- i J,1) Head spray
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- 12) ' Main steam
- 15) Feedwater ,l
- 16) Control rod drive hydraulic return !
J7) ' Core spray J8) Reactor recirculation !
- 19) Residual heat removal '{
110) Cleanup system '
In these systems, the class 1 boundary includes the piping within l the drywell and extends to the first valve outside containment.
l l This is an acceptable iso 1Lation valve per the code except in the I
case o_f the feedwater supply, cleanup return, and control rod ,
drive return, where the first valve outside containment is a L simple check valve. '
Ibis Class 1 boundary was defined in the initial Inservice l
! Inspection Program, was approved by the regulatory authority
_ I l based on design prior to code requirement, a_nd formed the basis i upon which the plant was licensed and baseline data was taken.
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C_onsequently, this boundary is unchanged in the revised program.
t It should be noted that, in accordance with IWB-1220 (b) ,
components and piping containing water, two inches in diameter and smaller, and components and piping containing steam, 3 inches r in diameter and smaller have been exempted on the premise that l the amount of fluid lost in the event of a rupture can be I replenished by the nor:nal makeup systems. _Some.of the piping i systems falling into this category are: _ instrumentation lines, Standby Liquid control System, and Control Rod Drive Rydraulic System. T_he exempt components and piping will be sub3ect to
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visual examination per IWB-1220(c) . !
2-1 dovember 1978
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PBISI-2
- 2. 2 EXAMINATIONS PLANNED The examinations planned for the first 10 year interval are discussed below for the reactor pressure vessel (RPV) and Class 1 piping, p_ umps, and valves. The examination areas have been separated into categories in accordance with the 1974 Edition of ASME Section XI through the emmar 1975 Addenda. The areas are discussed in the following text and snamarized in Iahle 2.2-1.
2.2.1 Reactor Pressure vessel C_ategory B-A - Longitudinal and Circumferential Shell Welds 1,n Core Region--Item 31.1 At present no mechmahad equipment exists permitting a comprehensive u_1trasonic (UT) examination of the RPV shell. Ihe space between the insulation and the RPV outside surface, nominally four _ inches, has been measured in somo areas to be significantly less. The beltline welds will be considered individually for physical accessibility and radiation levels (dependent upon core loading) . Manual UT examinations will be applied where necessary, subject to the a_bove conside' rations.
T_hese examinations may be performed at or near the end of the i_nspection interval .and procedure changes /develormants will determine the methods used.
Category B-B - Longitudinal and Circumferential Welds in Shell J,other than those of Categories B-A and B-C) and Meridional and Circumferential Seam Welds in B_ottom Head and closure Head (other than those of C,ategory B-C) -Item 31.2 as in Category B-A, these welds will be considered individually f,or physical accessibility and radiation levels. Ihe welds on the closure head are accessible tne head is removed for refueling. for volumetric examination $en These examinations may be performed at or near the end of the inspection interval. ,
C_ategory B-C - Vessel-to-Flange and Head-to-Flange Circumferential Welds--Item St.3 Ihe vessel-to-Flange Weld will be examined ultrasonically from the seal surface. The Head-to-Flange Weld is available for UT examination when the head is .r_emoved for refueling.
2- 2 November 1978
PBISI-2 .
Category B-D - Primary Nozzle-to-Vessel Welds and Nozzle Inside gadii -item 31.4 i
These RPV nozzle welds are accessible for ultrasonic e_xamination from the outside surface of the RPV when the surrounding sections of the sacrificial shield and insulation are removed. _Permanant tracks are mounted on the Recirculation Outlet (N1),
gecirculation Inlet (N2) , Main Steam (N3) , Feedwater (N4) , and Core Spray (NS) gozzles for mechanized ultrasonic avamination.of ,
these welds and inside radii. Jiowever, these welds will be ; ,
considered individually for limitations of accessibility to meet the full code examination requirement. glosure head nozzles are '
readily accessible for UT examination when the head is removed- '
for refueling.
gategory B-E - Vessel Penetrations, Including Control Rod . Drive a_nd Instrumentation Penetrations - Ltem B1.5. .
3 VT examination will be conducted for evidence of leakage of e_artial penetration welds in the RPV.
Category B-F - Nozzle-to-Safe End Welds--Item BT.6 There is a dissimilar metal weld between the carbon steel nozzle forgings and the piping system on some nozzles in the RPV.
Access to these dissimilar metal welds for volumetric examination will b_e providad for in the same manner as for the nozzle pr4 ==_ry welds.
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qategory B-G Closure Head Studs, In Place--Item B1.7 Not all of the closure studs are scheduled to be removed during each refue Ling. However, the studs remaining in the RP7 will be volumeerically examined in p_ lace, with scheduling in accordance with Code requirements.
qategory B-G Closure Head Studs and Nuts, When Removed-Item B1.8 The closure head nuts will be removed and available for a volumetric and surface examination. glosure head studs that are removed will be subjected to both a voltmetric and a surface examination, with scheduling in accordance with code f requirements.
Gategory B-G Ligaments Between Threaded Stud Holes--Item B_1.9 The ligaments in the RPV flange may be examined from the flange surface when the head is removed for refueling.
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PBISI-2 C_ategory B-G Closure Bead Washers and BushizrJs--
I_ tem B1.10 The closure head washers and bushings, when removed, will be subjected t_o the required VT examination.
C_ategory B-G Pressure Retaining Bolting--Item B1.11 This category applies to bolting smaller than two inches in diameter. There is no bolting ===11er than two inches in diameter in the R,PV.
C_ategory B-H - Integrally-Welded vessel Supports-Item B1.12 The RPV 13 supported on a skirt integrally welded, below the Shell-to-Lower Head circumferential weld. If accessible, a portion of this weld will be avamir-ed' through an opening in the sacrificial shield by removing a section of insulation. Due to ,
radiation levels, this area may be inaccessible f_or examination.
The reactor vessel stabilizer har support welds will be included l in the examination program.
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Category B-I Mosure Head Cladding--Item B1.13 There is no cladc~.ing in the closure head, but UT thickness measurements of the head will be taken d eiag selected refueling outages.
qategory B-I Vessel Cladding--Item B1.14 The required six cladding patches will be examined visually during the inspection interval.
C_ategory B-N Vessel Interior--Item B1.15
_vT examinations will be performed in accordance with the C_ade.
Category B-N Interior Attachments and Core Support structures--Item B1.16 The visually accessible surfaces of the core support structure will b_e examined in compliance with the Code.
i 2-4 November 1978 i
l PBISI-2 C_ategory B-O - Control Rod Drive Housing--Item B1.18 Ian percent of the peripheral Control Rod Drive housings will be e_xamined to the extent that physical accessibility and radiation / contamination levels permit. The exasination w y be-performed at or near the end of the inspection interval.
A_ccessibility will be determined at that time.
C_ategory B-P - Exempted Components--Item B1.19 Components exempted from volumetric and surface examination will be visually examined for evidence of leakage during the hydrostatic pressure tests.
2.2.2 Piping P,ressure piping will be examined in accordance with Items B4.1 .
through B14.10 and B4.12 of the Section XI 1974 Edition through the Summer 1975 Addenda unless exempted under IWB-1220 and thus <
subjected to a VT e_xamination under Category B-P (Item B4.11) ,
with the exception of:
- 11) Areas within the containment penetrations,
- 12) Cast fittings and structures which are not a_menable to UT examination and which are in a system which c,annot be drained without draining the RPV, and
- 13) Any weld which during the preservice examination (PSI) was found not suitable for UT ap=4 aation (and continuous evaluation indicates that the State-of-
_the-Art tecEniques do not allow UT examination) and
! which c_annot be radiographed due to (a) geometry and/or interference from s_urrounding structures, or (b) the system cannot be drained without d_ raining the RPV.
C_ategory B-F - Safe End-to-Piping Welds and Safe-Ends in
_ Branch Piping Welds--Item B4.1 Ihe dissimilar metal welds joining the piping safe-ends to the RPV are included in the examination of the RPV nozzle-to-safe end welds (Item B1.6) . There are other dissimilar metal welds in the system where lines change f_ rom carbon steel to stainless steel.
l T_hese welds will be subjected to volumetric and surface examination.
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PBISI-2 Category B-G Pressure-Retaining Bolting--Items 34.2, B.4.3, and B4.4 Ihere is no pressure retaining bolting two inches in diameter or larger in these piping systems.
Category B-J - Circumferential and Iongitmiinal Pipe Welds-Item B4.5 T_he Code requirements for circumferential and longitudinal b_utt 8 welds in pressure rehmining pipe and fittings will be ucrt.
Category B-J - Branch Pipe Connections Exceeding Six Inches
_in Diameter--Item B4.6 As far as practical, branch connections will be DT examined.
Ihose branch connections not suitable for DT examination 3ay be radiographed.-
Category B-J -
Branch Connection Welds Smalle: Tuan S_ix Inches in niameter--Item B4.7 Branch connection welds in this category will be s,ubjected to surface examination.
Category B-J - Socket Welds-Item B4.8 Ihere are no socket welds to be examined in this category.
Iategray B-K . Integrally Welded Supports--Item BE 3 Ihe integrally welded external support _a,ttachments will be GT examined to the extent practical.
qategory B-K Support components--Item B4.10 Ihe support settings of constant and variable spring type hangers for piping will be verified by visual examination.
qategory B-P - Exempted Components--Item B4.11 Components of the piping systems exempted from volumetric or s,urf ace examination under IWB-1220 will be visually examined for evidence of leakage during the hydrostatic pressure tests.
I 2- 6 November 1978, 1
PBISI-2 C,ategory B-G Pressitre-Retai ning Bolting-Item B4.12 golting in the piping systems less than two inches in diameter will b_e visually examined. B_olting may be examined either in place under tension, when the connection is _ disassembled, or when the bolting is removed.
2_. 2. 3 Pumos Category B-G Pressure-Retaining Bolts and Studs, in Place
_--Item B5 1 B,olting, two inches and larger in diameter, will be examined rolumetrically.
Category B-G Press'ure-Retaining Bolts and Studs, when Removed-Item B5.2 golting examined when removed is subject to both volumetric and .
surface examination.
C_ategory B-G-t - Pressure-Retaining Bolting--Item B5.3 In addition to-the above examinations, bolting will be visually examined.
Category B-K Integrally Welded Supports-Item B5.4 The support members and structures in this category that will be subjected to vr and volumetric examination include the integrally welded external support attachments, which include the velds attached to the pressure-retaining boundary and the b,ase metal beneath the weld zone.
Category S-K Support componer.ts-Item. 35.5 Ihe support members and structures in this category that will be subjected to vr exmf nation include. those supports for pumps whose structural integrity is relied upm to withstand the design loads and seismic-induced displacements.
Category B-L Pump Casing Welds--Item B5.6 There are no pumps in the system with pressure-retaining _ welds.
Category B-L Pump Casingu--Item B5.7 T_he only pumps in this category subject to examination aru those in the Reactor Recirculation System. The areas subject to VT examination on these casings include the internal pressure l
2- 7 November 1978 l
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. 1 PBISI-2 boundary surfaces. Eo examinations are scheduled to be performed unless the pumps are disassembled for maintenance reasons, gategory B-P - Exempted Components--Item B5.8 2d1 components exempted from volumetric or surface examination b_y IWB-1220 are subj ect to VT examination for evidene. of leakage during _the hydrostatic pressure tests.
Gategory B-G Bolting Smaller than 2 Inches in Diameter--
Item B5.9 Bolting smaller than two inches in diameter will be visually '
examined either in place under tensica, when the connection is d_isassembled, or when the bolting is removed.
2.2.4 valves '
Category B-G Pressure-Retaining Bolts and Studs, in Place
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Bolting, two inches and larger in diameter, will be examined 7alumetrically. -
gategory 3-G Pressure-Retaining Bolts and Studs, whtn Eemoved-Item B6.2 Bolting exanined when removed .will be subjected to both volumetric and surface examination gategory B-G-1 -
Pressure-Retaining Bolting-Item B5.3 In addition to the above examination requirements, _ bolting will be examined visuany.
qategory B-K Integrally Welded Supports--Item B6.4 Ihe support members and structures in this category that will be subjected to volumetric examination include the integrally welded external support attachments. .pe examinations will include the welds attached to the pressure-retaining _ boundary and the base metal beneath the weld zone.
qategory B-K Support components-Item B6.5 I
The support members and structures in this category that will be subjected .t_o VT examination include those supports whose structural _ integrity is relied upon to withstand the design loads and seismic-induced displacements.
2- 8 November 1973
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gategory B-M Valve Body Welds--Item B6.6
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T_here are no. valves in the system with pressure-retaining welds.
C_ategory B-M Valve Bodien - Item B6.7 T_he areas subject to VT examination include the internal p_ressure boundary surfaces on valves exceeding four inches nominal s_ize.
gode-required coverage would include one of each group of valves of the _s,ame structural design and manufacturing method, manufacturer, apd function in the system. valvas in this category will be avamined only if disassembled for maintenance purposes.
gategory B-P - Exempted components--Item B6.8 v_alve components exempted from volumetric or surface examination by IWB-1220 will be examined visually for evidence of leakage d_uring the hydrostatic pressure tests..
Category B-G Bolting Smaller than Two Inches in D_iameter--Item 26.9 aolting may be visually examined either in place under terision, '
when the connection is dissambeled, or when the bolting is removed.
- 2. 3 SYSTEM LEAKAGE AND HYDRCSTATIC PRESSURE TESTS glass I components will be subjected to a system leakage t_est prior to startuo following each reactor refualing outage at a test oressure not less than spm nominal operating pressure at 100 % rated reactor power.
c_ lass 1 components will be subjected to a system hydrostatic test at or near the end of the inspection interval at a test pressure a_pproximately 30 psi below the lowest relief valve setting but not less than 105 times the system nominal operating pressure at 1001 rated reactor power. At test temperatures above 3500F the test pressure may be adjusted in accordance with IWB-5 222.
2-9 November 1978
PBISI-2 ,
2_. 4 Requests for Relief f rom ASME Section II Requirements ,
2,.4.1 Request for _ Relief 2.4.1.I comoonents Hydraulic shock suppressors for class 1 piping, pumps, and v_alves . i
- 2. 4.1. 2 Recuirement from which Relief Requested Iable IWB-2500, Category B-K-2 requizes visual examination of all support components _and verification of support settings of snubbers and shock absorbers once per inspection interval.
2.4,1.3 Justification ,i Ihe hydraulic shock suppressors on class 1 systems are currently subjected to an ongoing inspection and testing program detailed 1 in the plant Technical Specifications which exceeds the ).
requirements of the Section XI. _This program is designed to
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demonstrate continued operational readiness and structural !
integrity of the shock suppressors. This approach provides for l*
unified testing and reporting requirements and eliminates l .j duplication of records. '
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t 2_. 4.1. 4 Testing h Lieu of Section f X_I Recuirements I Hydraulic shock suppressors will be inspected and tested in l accordance with Technical Specification requirements. ~
2.4.2 Request for Relief '
2_.4.2.1 common ents
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1 Reactor recirculation pumps, 2AP34 5 2BP34, ASME class 1 i 1 equivalent) .
2 4.2.2 Recuirement from which Relief Requested Table IWB-2500, Category B-L-2, and Table IWB-2600, Item 3 5-7, require visual examination of the internal pressure boundary surfaces of one pump in each group of pumps of similar function ,
to be cerformed once per inspection interval.
2.4.2.3 Justificatio_n .
Ihis requirement, in absence of other required maintenance, would !
necessitate dismantling a recirculation. pump solely to perform a visual inspection of internal _ surfaces, and as such, represents ,
1 2-10 November 1978-i
l PBISI-2 an unnecessary exposure to radiation and _ contamination and an excessive expense. A job of this scope also presents an unnecessary risk of an industrial a_ccident due to the cramped quarters and limited visibility r,esulting from the use of full anti-c protective equipment.
Ihe disassembly of this pump constitutes a maintenance job of major groportions that, due to plant design, involves removing the motor and transporting it outside the containment. govement of such large heavy conponents within the drywell with the attendant hazard of accidental damage to other safety related Ei ping and equipment ' constitutes a risk to reactor safety. We estimate that the dismantling and reassembly of one pump would consume more than 10,000 manhours and in excess of one month of round-the-clock e_ffort and would result in a cmanhtive dose of between 100 and 500 man-rem.
The net result of this major effort would be a visual inspection consuming about 8 manhours. _The questionable benefit to be obtained from such an inspection ghen measured against the cost -
in man-rem appears to be in conflict with the concept of "As Low as Reasonably Achievable". In view of the cost in dollars, potential hazards, and man-rem _and in view of .the minimal benefits to be obtained, we conclude that ,t_his code requirement is impractical for Peach Bottom.
2.4.2.4 Testinn in Lieu _of Section XI Recuirements The internal surfaces of the recirculation pump casings will be visually inspec-ted whenever these surfaces are accessible as a result of disassembly for other maintenance purposes. I_n the interim, annual performance tests will be conducted to verify pumping capability and to indicate the condition of internal clearances. Ihis data, coupled with the hydrostatic tests performed once per inspection interval and the external inspections performed during seal maintenance, will provide a_dequate assurance of structural integrity.
2_.4.3 Request for Relief e 2.4.3.1 ccmoonents A_SME class 1 (equivalent) valves exceeding 4-inches nomial pipe size.
, 2_. 4 . 3. 2 Requirement from which Relief Requested Table IWB-2500, category B-M-2, and Table IWB-2600, Item B 6.7 require gisual examination of the internal pressure boundary surfaces of one galve in each group of valves of the same design, 2-11 November 1978
I PBISI-2 5 !
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manufacturing method, manufacturer, and function to be performed 855 :
once per inspection interval. 855 !
t 2.4.3.3 Justification 857 i Disassembly of these valves solely for visual inspection, in 86 0 absence of other required maintenance, represents an unnecessary 860 ,
exposure to radiation and contamination and an excessive expense. 861 l
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Ihe recirculation pump suction valves would require off-loading l 863 l the f_uel elements and draining the reactor prior to disassembly. 864 l Hork om recirculation pump discharge valves, recirculation loop . 865 '
equalizing valves, _and RER injection manual block valves would l 866 ;
require installation of plugs in the jet pump risers. l 866 l
?, reparatory work of this scope is considered impractical for the 86 7 i sole p_urpose of conducting a visual examination. _ Contamination 86 9 l 1evels in the valves associated with the recirculation loops are 870 particularly high due to the physical location of these valves at l 871 <
the bottom of the system. l 871 j 2.4.3.4 Alternate to Section II Recuirement 873 j
! Ihe following specific valves: recirculation pump suction valves j 875 i (Mo-2-43A, B) , recirculation pump discharge valves 1Mo-2-53A S 876 i
- 3) , recirculation loop equalizing valves (Mo-2-65A & B) , RER 876 injection line manual block valves JW-10-81A S B), and any valve 877 j whose disassembly would require extreme measures to isolate, or 878 '
presents a substantial personnel safety hazard; will be subjected 878 !
to visual inspection of the internal surfaces of the valve body 879 i when disassembled f_or maintenance in accordance with the code and 880 l documented procedures. If one valve in each group of valves of 881 ;
the same design, manufacturing method, manufacturer, and 881 function, is not d_isassembled for maintenance which provides 882 access to the internal pressure boundary during an i_aspection 883 interval, a volumetric exa'i ution of the valve body will be 883 ;
considered as an alternate. _This inspection program coupled with l 884 '
periodic leak tasts -and hydrostatic tests will provide adequate l 884 assurance o_f the structural integrity. Other class 1 valves will l 886 F be inspected in accordance with Section XI requirements. l 886 r
1 4.4 Request for Relief 889 ,
2.4.4.1 Components 891 ,
ASME class 1 (equivalent) components. 893 -
2.4.4.2 Recuirement from which Relief Recuested 895 2-12 November 1978 l 307
l l
PBISI-2
[4B-5222 requires that class 1 systems and components be subjected to a system hydrostatic test at pressures ranging from 110% to 1025 of nominal operating pressure (Po) d_ependent upon test temperature in the range of 100*F to 5000F.
2 4.4.3 Justification ht present, Technical Specifications require a mini mm temperature of 1858F before pressurising to greater than 250 psig. Ibis temperature would require a hydrostatic test pressure of 108.3% Po (approximately 1088 psig). _The present setting of the four lowest set relief valves is 1105 psig t 11 psig. Lie propose to conduct the hydrotest with all relief valves in place and to raise the p_ressure to within 30 psig of the lowest nominal relief valve setting. Ihis provides a reasonable margin to for pressure control'while recognizing the _ setting tolerance, allow of the valves. Ender present conditions this would result in a hydrotest which is 13 psig less than the code gequirement at the minimum test temperature. At higher test temperatures (>250*F) ,
P_each Bottom would be in compliance with the code, h,owever the higher temperatures make inspection of-the drywe.11 upper .
elevations time.
very difficult from the standpoint of personnel stay Ihe only alternative that permits meeting the code at the lowest test temperature is removal of the relief valves. Ihis job is expensive both in dollars and man-rem and necessarily results in 1engthening the refueling outage because such work is always on the ,c_ritical path to returning the reactor to service. W
_e conclude that adequate confidence in the structural integrity of the glass 1 systems and components can be gained by the proposed hydrostatic test and that removal of the relief valves to permit testiag to a slightly higher pressure is not justified.
14.4.4 Alternate g section XI, Recuirement Ihe class 1 system hydrostatic test will be conducted with all relief valves in place a_t a test pressure approximately 30 psig below the lowest nominal relief valve setting. In the event relief valve settings are changed, test pressure will be changed accordingly, but will not be less than 105% Po at test temperature below 3500F.
2-13 November 1978
__-____-_-_____b
' PBISI-2 .'
TABLE 7.2-1 ,
INSERVICE INSPECTION PROGRAM CLASS 1 COHPONENTS Sheet I of 8
)
Item Conponents & Parts Examination Schedule Category To Be Exanined Method in lu-Yea r Period Re ma rk s No.
REACToit PRESSURE VESSEL B1.1 B-A Longitudinal and Volumetric 10% of the length of May be examined Circunferential each longitudinal and at or near the Welds in Core Region 5% of each circumferential end of each I weld. inspection i n t e r va l .-
"i Hay be exauined Bl.2 B-B Longitudinal and Volunetric 10% of each longitudinal Circuuferential or me ridional and 5% of at or near the Welds in Vessel, each circumferential end of each als o He ridi onal and weld. inspection Circunferential interval.
Welds in lle a d Bl.3 B-C Vessel-to-Flange Volumetric 100% of each circum-Ilead-to-Flange f erentia l weld.
Bl.4 B-D Prinary Hozzle-to- Volunetric 100% of nozzles. ,
Vessel Welds in .#.
- ozzle Inside Radii Bl.5 B-E Partial Penetra- Visual 25% of each group of The e xanina t i ons will' tion welds (Vessel (IWA-5000) conp a ra ble size and be perforned when Pene t ra t ions , in- function. the system is cluding Control Rod pressurized after Drive and Instru- refueling and mentation) prior to operation.
.. ... . . . . . . . . . . ._..._.m. _.
. g , .r .
3 9 .- .
_,..~ ,
4 r
. . /* " ' .
She et P itI S~2
- T
~~~~~
" a rks s ~ 2+2'I Schedule
~~~
TA Bl.E ation ____.____
Exa min ~ -
I" ,_.___.
r u eta 1 Paru :le t hod sinila leS*
no zF esits & ed _.- - All
""1d" dis
- e a nd n uts.
Compo ng$e Exa min~~ etric'ce m ds -
To Volu Su rfa 0 fY a nd 100% of stu uts.
m Cate8 a nd.n
'-zle.co-SafeVolumetric tte go, ~~___.._.
Noz d ogg of studs
~g. y End wel s and nt Studs # t# l i ga me 31 6 he Clo sure E 1"C 'Vol""*'# gggg of t #
BG1 1;uts . In a nd a nd she rsWhen area. i BI* sure Studs mo ved n'Re Volun etric applic able..
Clo Whe 100% og wa o nly
!!ot 1 *** "'" %s %
' ~
PBISI-2 TABLE 2.2-1 (Cont'd) Sheet 3 of 8 I t e rn Conponents & Parts Examination Schedule No. Category To Be Exanined tie t h od in 10-Year Period Remarks Bl.15 B-N-1 Vessel Interior Visual Exam at first refuel- Applies to accessible ing outage and areas above and below subsequent 3 year reactor core.
intervals.
Bl.16 B-N-2 Interior Attach- Visual 100% of the visually To be exanined at nents and Core- accessible attachment or near the end of Support Structures welds and visually the inspsetion accessible surfaces interval..
of the support structure.
Bl.17 B-N-3 Renovable Core- ---------- ----------------------
Not applicable.
Support Structures 81.13 B-0 Control Rod Drive Volume t ric 100% of the welds in . May be examined at ilousings 10% of the peripheral or near tr.e end of l CRD housings. the inspection l interval.
Bl.19 B-P Exempted Con- . Visual All exempted components Exaninations to be ponents Defined by (IWA-5000) performed in accordance IUB-1220 with IWA-5000 d u ring
. the systen hydrostatic pressure tests requirsd j by IWu-5000. '
PBISI-2 TABLE 2.2-1 (con t 'd ) Sheet 4 of 8 Iten Components & Parts Examination Schedule No. Category To Be Examined !!ethod in 10-Year Period Rema rk s
_P_I P illG B4.1 B-F Dissimilar Metal Volumetric 100% of the welds.
Welds and Surface B4.2 B-G-1 P res su re Retaining ---------- ----------------------
Not applicable.
Bolts and StuJs,
- 2 inches in diam.
and larger In Place B4.3 B-C-1 Pressure Retaining ---------- ----------------------
'Not app 1icab1e.
11o l t s and Studs, 2 inchen in dian. ~1 and larger l When Remo ve d !
B4.4 B-G-1 Pressure-Rutaining ---------- ----------------------
Not appiicab1e.
Bolting, 2 inches ;
in diameter or larger.
..w. >
11 4 . 5 Il-J Ci rcumf e ren t ia l Volumetric 25% of the circumfer-a nd Lon;;i t ud ina l ential joints including Pipe Uelds the adjoining ! ft. of longitudinal welds.
B4.6 .B-J Branch Pipe Volumetric 25% of the branch Connection Welds connection joints.
Exceeding 6 Inches Diameter.
1
-y:
.. s .
PBISI-2 .
TABLE 2.2-1 (Cont'd) Sheit 5 of 8 Item Components & Parts Examination Schedule Method in 10-Year Period Re ma rk's;;i 4 No. Category To Be Examined
' '. .21*.
^ ..
B4.7 B-J Bran..a Pipe Surface 25% of the Branch ,
Connection Welds ,
connection joints.
6 inches in Diameter and Smaller B-J Sock et Welds --------- ---------------------- Not applicable.
84.8 B4.9 B-K-1 Integrally Welded Volumetric 25% of the supports.
Supports B-K-2 Support C o rap on e n t s Visual All support The support settings of 84.10 components. spring-type hangers shall be verified.
B-P Exempted Visual All components Examination to be.
B4.!!
Components (IWA-5000) exempted from performed in accordance volumetric and surface with IWA-5000 during e xa mina t i on by IWB-1220. the hydrostatic pressure tests required by IWB-5000.
B-C-2 Pressure-Retaining Visual 100% of the bolting, May be examined either B4.12 in place under tension Bolting Less Than studs, and nuts.
or when the bolting 2 Inches in Diameter is removed.
PBISI-2 ..
TABLE 2.2-1 (Cont'd) Sheet b of 8 item Components & Parts Examination Schedule . n .,
No. Category To Be Examined Hethod in 10-Year Period R e ma rk.g;j.',.'
smk: .
4 - . . . .
. Y.
PUHPS B5.1 B-G-1 Pressure-Retaining Volumetric 100% of the bolts and Bolts and Studs, studs.
2 inches in diam.
and larger in place B5.2 B-G-1 Pressure-Retaining Volumetric 200% of the bolts and Bolts and Studs, and Surface studs.
2 inches in diam, and larger when removed. ,
B5.3 B-C-1 Pressure-Retalning Visual 100% of the >31 ting.
Bolting, 2 inches in diameter or larger.
85.4 B-K-1 Integrally Welded Volumetric 25% of the supports.
Supports 85.5 B-K-2 Support Conponents Visual All support The support settings of components spring-type hangers shall be verified.
B5.6 B-L-1 Pump Casing Welds ---------- -------------------- Hot applicabic.
B5.7 B-L-2 Internal Surfaces Visual One reactor To be performed only of Puup Casings recirculation pump if pump is di6assewbivo for ma i r.t e n a n c e purpuses.
PBISI-2 TABLE 2.2-1 (Cont'd) Sheet 7 of 4;
. . V:: b .
'. T.'Q*!'t. '
Ituu Components & Parts Examination Schedule .INf9 fl o . Category To Be Examined ,
Method in 10-Year Period Re ma rk' jf,)
-.--.~..
B5.8 B-P Exempted Components Visu51 All components exempted All' components shall be (IWA-5000) from volumetric examined in.accordance and surface examination with IWA-5000 during by IWB-1220. hydrostatic pressure test required by IWB-5000.
B5.9 B-G-2 Pressure-Retaining Visual 100% of bolts, stude, Bolting Less Than and nuts.
2 inches Diameter VALVES B6.1 B-G-1 Pressure-Retaining Volumetric 100% of the bolts and Bolts and Stude, studs.
2 inches in diam.
and larger in place B6.2 B-G-1 Pressure-Retaining Volunetric 100% of the bolts and Bolts and Studs, and Surface ' studs.
2 inches in diam, and larger when removed.
86.3 B-G-1 Pressure-Retaining Visual 100% of the bolting.
Bolting, 2 inches in dianeter or larger.
BC.4 B-K-1 Integrally Welded Volumetric 25% of the supports.
Supports.
L
.t PBISI-2 TABLE 2.2-1 (Cont'd) Sheet 8 of 8 -
Item Components & Parts Examination Schedule
,. 7,' '
Category To Be Examined Method in 10-Year Period Remar
. .{
No.
5 y,-
86.5 B-K-2 Support Conponents. Visual All support c o mp on e n t s .' The si . dht' settings of spring 4jppe hangers shall be verified.
86.6 B-H-1 Valve Body Welds ---------- ---------------------- Not applicable.
B6.7 B-H-2 Internal Surfaces Visual One valve in each To be examined only of Valve Bodies on group of valves that when disassembled Valves Exceeding is of the same for maintenance 4 Inches Nominal construction and purposes.
Pipe Size similar function.
B6.8 B-P Exempted Components Visual All components exempted Examinations to be (IWA-5000) from volumetric and performed in accordance surface examination with IWA-5000 du ring under IWB-1220. the hydrost'atic pressure tests required by IWB-5000.
86.9 B-C-2 Bolt ing Snaller Visual 100% of bolts, studs, Than 2 Inches in and nuts.
Diameter
PBISI-2 SECTION 3.0
- CLASS 2 PROJRAM 3.1 IDEMTI7ICATION OF COMPONENTS I Ihe following systems or portions of systems have been c_lassified. l as ASM3 Class 2 (equivalent)
- !
i a_. Standby liquid control system !
- b. Reactor core isolation cooling system ,
- g. Residual heat removal system
- d_. Core spray cooling system i r
! e. High pressure coolant injection system i f_. , Portion of fuel pool cooling .and cleanup system.
l 3.1.1 Standby Lisuid Control System (SLC) ISI-M-358 I,he SLC system, beyond the check valve just outside primary !
containment, is classified Ciras 2 (equivalent) in accordance '
with Regulatory Guide 7.26, Section C.1.b. - system is important to safety and designed for reactor shutdown. Exemption from the ASME Section XI examination requirements of I,WC-2520 is taken as 1 follows: . !
E_ntire Class 2 portion of the system is exempt per '
IWC-12 20 (d) _- 4-inch nominal pipe si=e and smaller.
3.1.2 Reactor Core Isolation Cooling System (RCIC) ISI-M-359 ,
l Ibe RCIC system, outside the outermost containment isolation valves _and excluding the turbine and condenser, is classified as ;
Class 2 1 equivalent) . While the RCIC system is not specifically '
covered by any of the definitions in Regulatory Guide 1.26, i Section c.1, the system is gonsidered important to safety in that its primary design f_ unction is to supplement the ncemal makeup systems during reactor shutdown, particularly during isolation from the :nain condenser. A secondary function of the RCIC system L
is to supplement the HPCI system in the event of loss of coolant, however, no credit has been taken for this function in the planc safety analysis. Exemption from the ASME Section XI examination l
requireaants of IWC-2520 is taken as follows: '
f 3-1 November 1978
PBISI-2 ,
gntire class 2 portion of the system is exempt per -
I*AC-1220 (b) - a_ non-ECCS system which does not function during normal reactor gperation. JRCIC may, but does not necessarily, function during hot standby operation, however, this mode of operation occurs so infrequently c_ompared to startup, power operation, shutdown, and cooldown as to be considered insignifiaant. )
3.1.3 Residual Heat Removal System (RHR) ISI-M-361 Ihe RHR system, outside the outarmost containment isolation valves, is classified as Class 2 (equivalent) in accordance with Regulatory Guide 1.26, Sections C.1.a and b. pcrtions of the system are desa.gned for emergency core cooling and portions _are designed for residual heat removal. Exemptions from the ASME Section XI examination requirements of IWC-2520 are taken as fallows:
- a. Portions.of the system which perform an emergency core gooling function and which do not function during shutdown cooling are exempt per IWC-1220 (c) with gentrol of f Luid chemistry. Monitoring of chemical parameters (ph, conductivity, dissolved oxygen, and chlorides) of the RHR, gore spray, and HPCI systems is performed quarterly.
- b. Component connections, piping, valves, and vessels
_that are 4-inch nominal pipe size and smaller a,re exempt per IWC-1220 (d) .
Ihe exempt portions of the RER system are all carbon Jteel with a,dequate corrosion allowance such that _ corrosion effects of the contained fluid are minimized over the life of the plant.
chemical parameters are monitored by a periodic sampling and test program.
3.1. 4 Core Soray coolinct System ISI-M-362 Ihe Core Spray System, outside the outermost containment isolation valves, is classified Class 2 (equivalent) in accordance .w,ith Regulatory Guide 1.26, Section C.1.a - system is designed for emergency cora cooling. Exemption from the ASME Section XI examination requirements of IWC-2520 is taken as follows:
gntire Class 2 portion of the Core Spray system is exempt f_or IWC-1220 (c) with control of fluid chemistry. Monitoring of chemical parameters (ph, conductivity, dissolved oxygen, and chlorides) of the 3- 2 November 1978
~
PBISI-2 RHR, core spray, and HPCI systems is performed l quarterly. l
'dith the exception of the piping between val / ras Mo-11 ASB rnd MO-12ASB, the entire class 2 (exempt) portion of the core Spray system is carbon steel with adequate corrosion _a.llowance such that corrosion minimized overoffacts the lifeofofthe thecontained plant. _ fluid (torus water) are Chemical parameters are monitored by a periodic sampling and test program. .
Ihe piping between valves MO-11AS3 and' MD-12ASB is TP 304 stainless steel. Ihis piping normally contains torus water and is kept full by a supply of demineralized condensate. Ihe chemistry of both torus water and condensate is monitored by a periodic sampling and test program 3.1.5 High Pressure Coolant Iniection System (HPCII ISI-M-365 Ihe HPCI system, outside the outermost containment isolaticn valves _and excluding the turbine and condenser, is classified Class 2 Jequivalent) in accordance with Regulatory Guide 1.26, Section C 1.a - system is designed for emergency core cooling.
Exemption fres the ASME Section XI examination requirements of IWC-2520 is taken as follows:
Entire Class 2 portion of the HPCI system is exempt per IWC-1220 (c) with c_ontrol of fluid chemistry.
jionitoring of chemical parameters (ph, conductivity, dissolved oxygen, and chlorides) of the RHR, core spray, and HPCI systems is performed quarterly.
Ihe exempt portion of the HPCI system is carbon steel with adequate corrosion allowance such that _ corrosion effects of the contained finid (condensate storage tank water) are minimized over the life.of. the plant. Chemical parameters are monitored by a periodic sampling and test program 3.1.6 Fuel Pool Cooling and Cleanuo System ISI-M-363 The portion of the Fuel Pool Cooling system that ties into the BBR system is basically a Class 3 system, however that portion which does not f_ unction in normal operation and cannot be tested adequately is classified as class 2 (equivalent) in accordance with Regulatory Guide 1.26, Section C.2.a - s_ystem is designed for residual heat removal from spent fuel, does not operate d_uring nor:tal operation and cannot be tested adequately.
Exemption from the ASME Section XI examination requirements of IWC-2S20 is taken as follows:
3-3 November 197S i
i
i PBISI-2 l
E_ntire class 2 portion of the Fuel Pool Cooling system is _ exempt per IWC-1220 (b) pstem is non-ECCS and does not function in normal operation.
t
- 3. 2 EXAMINATIONS PLANNED - NON-EXEMPT CCMPONENTS The examinations planned for the first 10-year interval are discussed below for class 2 pressure vessels, piping, pumps, and v_alves. In systems or portions of systems with a single stream, examinations _will be performed such that 100% of the required examinations will be covered over service lifetime. Where multiple streams occur, the examinations.will be performed such that the equivalent of 100% of a . single stream will have been examined over the service lifetime, as defined in Section XI.
S_pecific examination restrictions will be identified as the actual examinations proceed. _The areas for examination are discussed in the following text and summarized in Table 3.2-1. ,
3.2.1 Pr=ssure vessels
! T_he only Class 2 pressure vessels in the system that require NDT 4
examinations _are the residual heat removal (RER) beat exchangers.
Category C-A - Circumferential autt Welds-Item C1.1 Ihis category applies to head and shell welds which are gross structural discontinuities. Welds in this category and the adjoining base metal will be volumetrically examined in accordance with the requirements o_f Section XI. ,
i r
C,ategory C-B - Nozzle-to-Vessel Welds-Item C1.2 Nozzles in Class 2 pressure vessels are subject to volumetric e_xamina tion. These examinations will cover 100% of the vessel attachment weld. ,
Category C-C - Integrally Welded Supports--Item C1.3 Ehe RER heat exchangers are supported by rod hangers. Integrally {
welded supports on the pressure retaining boundary will be i examined in accordance with Section XI.
l Category C-D - Pres.ruce-Retaining Bolting-Item C1.4 The bolting in the RRR. heat exchangers is less than 1-inch in ,
diameter.
i 1 2.2 ? icing i Category C-F - Welds in Piping Which Circulates Reactor Coolant {
3-4 November 1978
. - - , , - - ,a-- - - - - a- .- , - , - - - - r,-.-
PBISI-2
-Items C2.1, C2.2, and C2.3 T_his category applies to Class 2 lines which circulate reactor coolant. The volumetric examinations will include circumferential butt welds a_t pipe-to-vessel gozzles, pipe-to-'falve bodies, pipe-to-pump cadngs, pipe-to-fittings, pipe-to-pipe of d_ifferent wall schedule thickness, and pipe-to-nipe within three pipe diameters of rigid anchors. T_he examination will further include longitudinal joints in fittings, a_nd branch connection weld joints.
Category C-G - Welds in Piping Wich Circulates Other Than Reactor Coolant-Items C2.1, C2.2, and C2.3 Ihis category applies to Class 2 lines which circulate other than reactor coolant. A representative sample comprising 50% of the welds will b_e examined. The applicable welds include circumferential butt welds at pipe-to-vessel nozzles, pipe-to-valve bodies, pipe-to gipe of different wall schedule thickness, and pipe-to gipe within three pipe diameters of rigid anchors.
applicable welds further include longitudinal joints in f_ittings and branch connection weld joints.
Category C-D - ?ressure-Retaining Bolting-Item C2.4 Ihere is no bolting exceeding 1-inch in diamet'e r.
Category C-E Integrally Welded Supports-Item C2.5 The welded support attachments will be subjected to surface examination insof ar as practical.
Category C-E Support Compenents--Item C2.6 Ihe visually accessible surfaces of support components will be examined i_.n accordance with Section II. The support settings of constant and variable spring-ty,m hangers will be verified.
3_.2.3 Pumes Category C-F - Pump Casing Welds in Systens Which Circulate Reactor Coolant-Item C3.1 4
There are no pump casing welds in these systems.
Category C-G - Pump Casing Welds in Systems Which Circulate other ,
Than Reactor Coolant--Item C3.1 There are no pump casing welds in these systems.
2-5 November 1978
h PBISI-2 Category C-D - Pressure-Retaining Bolting-Item C3.2 Ihere is no bolting exceeding 1-inch in diameter.
Category C-E Integrally Welded Supports-Item C3.3 N_one of the Class 2 pumps have integrally welded supports.
Category C-E Support Components--Item C3.4
_All visually accessible surf aces will be examined in accordanct with Section XI.
3.2.4 Valves Category C-F - Valve Body Welds in Systems Which Circulate' Reactor Coolant-Item C4.1 -
There are no valves in these systems which have body welds.
Category C-G - Valve Body Welds in Systems Which Circulate -
Other Than Reactor Coolant-Item C4.1 i Ihere are no valves in these systems whieb have body welds.
Category C-D - Pressure-Retaining Bolting--Item C4.2 There is no bolting exceeding 1-inch 1:2 d h m ter.
Category C-E Integrally Welded Supports-Item C4.3 S,urface examinations will be performed on the integrally welded I supports.
Category C-E Support components--Item C4.3 '
611 visually accessible support components associated with Class 2 valves will be eranined and settings of constant and variable spring-type hangers will be verified.
3.3 SYSTEM PFESSURE TESTS Class 2 components will be subjected to the system pressure test requirements of IWC-5000. Ihe tests scheduled to be per*^rmed during the next 10-year interval are ,s_hown in Table 3.3 L In accordance with IWC-5220 (d) , open-ended portions o_f nonclosed systems extending to the first shutoff valve are exempted from the test require:nents of IWC-5000 and IWA-5000. _ Examples of this ,
exemption include suction lines from the torus, test lines and !
3- 6 November 1978
P3ISI-2 minimum flow recirculation lines which discharge to the torus, containment saray lines, torus spray linas and turbine exhaust lines to the torus.
3.4 REOOEST FOR RELIEF FROM ASME SEC"fION XI REOUMEMENTS 3.4.1 Itequest for Relief 3.4.1.1 Comoonents
.wa in steam lines outside the outermost containment isolation valves. ,
3.4.1.2 Requirement from which Relief Requested IJA-1400 (a) requires the owner to determine the appropriate Code Class and references Regulatory Guide 1.26. Regulatory Guide
- 1. 26, Section C. f.c classifies EWR main steam lines which do not contain a shutoff valve in addition to the two containment
, isolation valves as Quality Group B ,f, rom the outermost containment isolation valve up to but not including the turbine-stop and by pass valves. ~
3.4.1.3 J_ustificatiott P_each Bottom was designed and built price to the requirementi for a_ third valve in the main steam line. There are no safety related structures, systems, or components which could be adversely affected by a pipe break in the main steam line downstream of the outermost containment isolation valve and such a pipe breaE does not result in significant offsite doses as set forth in the FSAR Chapter 14 _and Supplement 2. _ Consequently, there is no need to classify the Peach Botton main steam lines as ASME class 2 (equivalent) for purposes of inservice inspection.
3.4.1.4 Testing in Lieu of Section XI Requirements Ihe main steam lines up to the turbine stop and by pass valves will be subjected to a hydrostatic test at the same time and under the same test conditions as the Class 1 components.
i 3-7 November 1978
- ~
PBISI-2 TABLE 3.2-1 .
INSERVICE INSPECTION PROGRAM CLASS 2 (NON-EXEMPT) COMPONENTS Sheet 1 of 3 Iten Components & Parts Examination Schedule No. Category To Be Examined Method in 10-Year Period Renarks PRESSURE VESSELS C1.1 C-A Circumferential Volumetric 20% of each circumfer- Applies to welds that Butt Welds ential weld are gross structural discontinuities (Nb-3213.2).
C1.2 C-B Nozzle-to-Vessel Voluuetric 100% of the attachment Welds welds.
Cl.3 C-C Integrally Welded Surface 100% of the weld.
Supports Cl.4 C-D Bolting Exceeding ---------- ---------------- ------ Not applicable.
One Inch in Dianneter .
PIPING' C2.1 C-F, Circunferentied Volumetric 100% of the welds in includes:
C-G Butt Uelds reactor coolant systens; - Welds at s t r u c t u r.i l 50% of the welds in discontinuities.
C. other systems. - Helds within 3 pipe d i .r .. t e r s of the centerline o t' ri: :
anchors.
C2.2 C-F, L o ng i t u.li na l Volunctric 100% of the welds in Tees, cibows, r e ... s .
C-G Joints reactor coolant systens, 507. in other systens.
~
PBISI-2 -
TABLE 3.2-1 (Cont'd) Sheet 2 of 3 Item Components & Parts Examination Schedule ti o . Category To Be Exanined tie t h od in 10-Year Period Re ma rk e l'/,
C2.3 C-F, Branch Pipe-to- Volumetric 100% of the welds in C-C Pipe Joints reactor coolant systems; 50% in other systems.
--------------------- Not applicable.
C2.4 C-D Bolting Exceeding One Inch Diameter C-E-1 Integrally Welded Surf ace 100% of the support C2.5 Supports attachment welds in the pressure-retaining boundary.
Support Components Visual All support conponents. Support settings of C2.6 C-E-2 spring-type hangers shall be verified.
-P ullP S Punp Casing Welds ---------- --------------------- Not applicabic. l C3.1 C-F, C-G Pressure-Hetaining ---------- --------------------- Not epplicable. l C3.2 C-D l Bolting Exceeding One Inch Dianeter. .
I Integrally Welded ---------- --------------------- Not applicable.
C3.3 C-E-1 Supports C3.4 C-E-2 Support Congonents Visual All support components.
.-. .~.-. .. -- . . . . - . . - ~ - . . . -. .. . . - . - -. . . . . _ . . - _ . . - . .
-~ ..
P t.1 :s t - 2 T A h!.t; 3.2-1 (Cont'd) Sheet 1 of 3 .
I t . ,9 Co si:s o:ic n t s Pa rt s Exanination S c ue du le
'le t in o d in 10-Year Period Menarks No. C.. t e r,o r y To ele 1: x. .:i n e.!
" A L V t: S
-- ------- --------------------- .Not a p p li c.n o l e .
C4.1 C-t', Valve hoJy >J e l d s C - t; Pressure-Retaining ---------- --------------------- Not_ applicable.
C4.2 C-u Solting Exceeding One Inch Di.nneter I n t e;; r a ll y Welded Surface 100% of the support C4.3 C- t:- l Supports attachnent w e lit s in the p re s su re containing boundary.
Visual All support conponents. Support settinas os
. C4.4 C-E-2 Support C u n,s u ne n t s s p r i n t,- t y p e h.i n ne r s shall be vertiled.
s t
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. --. ,m . - , . . . . - - - . .- w,- - . , . - . , , , - , .m .,. . ,, .,
PBISI-2 TABLE 3.3-1 SYSTEM PRESSURE TESTS t
CLASS 2 COMPONENTS 4 0 _H_o n,t h P e, r i_o d _S,y s t e_m b le,st TEST PRESSURE _R, First -
Core Spray System Pressure test per IWC-5000 1001 Operating Pressure begins 11/05/77 With Inspection per IWA-5000 llPC I Second NCIC
~ ~ " ~ " " " "
" " " " " " " ~
Third fuel Pool Ccating g ig g Notes: (1) Tentative schedule subject to change in accord with system aaintenance req u i renne n t s.
If a p a r t i cu la r component shall require a pressure test after repairs by welding on the p re s s u re retaining boundary, this test may be extended to cover the entire system and c redit may be taken for one of Ohe inservice tests in this table.
(2) Test pressure determined in accordance with IWC-5220(c) for components not required to function during reactor operation.
. . .s -
PBISI-2 SECTION 4.0
, , CLASS 3 PROGRAM 4.1 IDENTIFICATION OF CCMPONErfS Ihe following systems or portions of systems have been classified as ASME C_ lass 3 (equivalent) -
- a. Emergency service water system b_. High pressure service water system
- c. Emergency cooling system d_ Portion of fuel pool cooling and cleanup system 4.1.1 Emercancy Service Water Svstem fESW) ISI-M-31_5 The ESW system is classified class 3 (equivalent) in accordance with Regulatory Guide 1.26, Section C.2.b. - system is designed -
for functioning of components important to safety including diesels and ECCS pump room unit coolers.
4.1.2 High Pressure Service Water System (HPSW) IST-M-315, 361 The HPSW system is classified Class 3 (equivalent) in accordance witu Regulatory Guide 1.26, Section C.2.a gystem is important to saf ety and designed to supply ::coling water f_or post-accident -
Teat removal and normal residual heat removal.
4.1.3 Emergency Cooling System IST-M-330 The Emergency cooling System is classified class 3 (equivalent) in accordance with Regulatory Guide 1.26, Section C.2.aob -
s_ystem is important to safety and designed to supply a source of cooling water for residual heat removal and for functioning of other components such as diesels. O, pen-ended portions of the system are exempt from the pressure test requirements of ASME Section XI, IWD-5200 in accordance with IWD-5200 (c) .
- 4.1.4 Fuel Pooline Cooling and Cleanup Svstem ISI-M-36 3 T_he portion of the Fuel Pool Cooling system that ties into the RSR system (excluding that part taken as Class 2) is classified Class 3 (equivalent) in accordance Uith R,egulatory Guide 1.26, Section C.2.a - s_ystem is designed for residual heat removal frca the spent f uel. T,his system also provides a source of aakeup water for the pool in the e_ vent normal cooling is lost and the pool is allowed to boil. The Class 3 portions of this system are 4-1 November 1978
PBISI-2 exempt from the pressure t_est requirements of ASME Section XI IWD-5200 in accordance with IWD-5200 (c) .
- 4. 2 INSPECTIONS PLANNED la general, class 3 system will be tested in accordance with IWD-2410 which requires a leak test every gne-third of each inspection interval and a system gressure test once during each inspection interval. Ihe inspection program for class 3 components is s,hown in Table 4.2-1.
4.3 REQUESTS FOR RELIEF FROM ASME SECTION XI REQUIREMENTS
% 3.1 Request for Relief
- 4. 3.1. I comoonents gigh Pressure Service Water (HPSW) System, Emergency Service j wate:: (ESW) System, Emergency cooling System.
4.3.1.2 Requirement from which Relief Requested IWD-5: 0 0 (a) - Sy d_esign pressure., stem test pressure at least 1.10 times the system
- 4. 3.1, 3 Justification Iesting these systems to 110% design pressure is beyond the ,
capability of the gystem pumps and therefore would require the '
use of a special hydrostatic test pump. The available test !
.:onnections on these systems are 3/4 and 1 inch lines a_nd would sharply limit the inflow capability from the hydrostatic pump, !
thereby n_ecessitating leak-tightness of system 14, 16, 20, and 24 inch galves to successfully perfora the tesus. S_uch leak-tightness is not otherwise a requirement for systems of this type .
3 a_nd considerable maintenance expense would be required to make .
the valves leak-tight f_ot test purposes only. In addition, '
testing to 110% design pressure would require taking the entire ESW or HPSW system out of service at the same time which would i require .t_he cessation of all shutdown cooling. ?,or the above reasons, we conclude that a hydrostatic test to 1104 design pressure is impractical for systems of this type.
Iesting to 110% of operating pressure is practical and could be accomplished using the system gumps and throttling at the cooling tower inlet valves - MO-48-0502 (A, B,C) for the HPSW system and Mo- 48-0 501 (A,B,C) for the ESW system. T_esting in this unner l will provide adequate assurance of the structural integrity of l these systems.
4-2 November 1978
, s t 1
PBISI-2 I
4.3.1.4 Testing in Lieu of Section II Requirements l I
Ihe HPSW system, the ESW system, and their respective portions of the Emergency cooling S_ystems will be pressure tested to 1.10 :
times the system operating pressure. l 1 3.2 Request for Relief l r
13.2.1 Comoonents l H_igh Pressure Service Water (HPSW) Systess, Emergency Service l
' dater (ESW) System, Emergency Cooling System.,
l 4.3.2.2 Requirement from t '11ch Relief Recuested l ,
t
];,WD-260 0 (b) In the case of buried components (e.g., underground }
piping), valves shall be grovided to permit isolation of the buried portions of piping for the purpose of conducting a gystem pressure test in lieu of the visual examination. A loss of l l system pressure during the test shall constitute evidence of component leakage.
13.2.2 Justification .
l Selected isolation valves and test connections were not '
l incorporated into the design of these cooling systems to permit a, pressure decay test of the buried piping. Isolation of the i entire cooling system is impractical for the same reasons 1
discussed in Section 4.3.1.3 above, _and would require taking the entire ESW or HPSW systems out of service, resulting in the l cessatica o_f all shutdown cooling. _More than 95% of the ESW and HPSW piping is accessible for visual inspection.
13.2.3 Testing h Lieu of_ Section E Requirements
_ l These systems will be visually inspected at accessible portions l of the piping and at pipe tunnel penetrations. l .
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PalSI-2 ,
T ABLE 4.2-1 INSERVICS INSPECT 10tl PROCPAN CLASS 3 CD:!PONENTS SYSTEll LEAK _ TEST P d,E S,S,U R E S S Y S T E,H, P R,E_S S U.R E T E S T, ,P R E S, S,U R E b Energency Service Water Normal Operating Pressure 110% Operating Pressure lii gh P r e t. s u r e Service dater !!orua l Opera t ing Pressure !!O% Operating P res su re Emergency Cooling Systen f;orma l Opera t ing Pressure !!O% Operating Pressure l' u e l Pool Cooling S y s t en.. Isormal Operating Pressure E xe rup t per IWD-520b(c)
Notes: (I) Systen Pressure hest will he conducted once per IO-year inspection interaal.
(2) Leak test will be c o n tlu c t e d in cach one-third inspection interva l where System Pressure Test is not perforned.
. - _ __# _-ma , -
. s PBISI-2 SECTION 5.0 INSERVICE TESTING OF PUMPS AND VALVES 5,.1 GENERAL The inservice testing programs for pumps and valves for Unit 2 and common plant _have been developed in accordance with
. requirements of Subsections IWP and IWV of ASME galler and Pressure vessel Code Section II, 1974 Editica with Addenda thru S_ummer, 1975, and are applicable for the 20-month interval beginning November 5, ,,1,,977. _Cetails of the inservice test program for. pumps and valves with requests for relief from Section II requirements are identified..in this 3,ection.
- 5. 2 INSERVICE TESTING PROGRAM FOR CLASS 1, 2, and 3 PUMPS .
T_he inservice testing program for class 1, 2 and 3 pumps is detailed in Table 5.2-1. Table 5.2-1 identifies pumps to be tested, pump equivalent ASME code classes, garameters' to be measured based on plant design and te.;t intervals.
Inservice tests on pumps will be performed at the test intervals specified in Table 5.2-1. Consistent with the treatment of surveillance tests in the Technical Specifications, t_hese test intervals may be adjusted plus or minus 254. I_n cases where the elapsed interval has exceeded 100% of the specified interval, the next test interval shall commence at the end of the original specified interval.
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i 5-1 November 1978
PEISI-2 5.3 REQUESTS FOR RELIEF IPROM ASME SECTICN XI REQUIREME'rPS (PUMPS) 5.3.1 Request for Relief
- 5. 3. 1.1 Components Standby Liquid Control Pumps (equivalent ASME Code Class 2) .
- 5. 3.1. 2 Requirement from which Relief Requested The inservice test quantitles shall be measured nominally each month d_uring normal plant operation in accordance with IWP-3400.
- 5. 3.1. 3 Justification T_hese pumps are operated only during surveillance testing for very s_hort periods on'a monthly basis while checking pump operability _i_n accordance with plant Technical Specifications.
Such li:tited operation will not cause a detectable change in the hydraulic or mechanical c_haracteristics of the pump from month to month.
5.3.1.4 Testine in Lieu of Section XI Requirements These pumps will be tested for operability once per month and inservice test quantities will be measured at least once each operating cycle in a,ccordance with plant Technical -
Specifications.
5.3. 2 Recuest for Relief
- 5. 3. 2.1 Comeonents Emergency cooling Water and Emergency Service Water B_ooster Pumps (equivalent ASME Code class 3) .
- 5. 3.A.2 Recuirement from which Relief Requested '
The inservice test quantities shall be measured nominally each month during normal plant operation in accordance with IWP-3400.
5.3.2.3 Justification T_he Emergency Cooling Water pump and the Emergency Service Water l Booster pumps are associated with operation of the Emergency l
. Cooling Tower which is a backup heat sink provided for use in the {
! event of loss of the normal heat sink JConowingo Pond) due to l catastrophic failure of the conowingo Dam. Duri.g normal j operation, cooling water for safety-related room coolers is [
provided by the Service Water System Ja non-saf ety-related j i
5- 2 November 1978
e , *., R PBISI-2 system). gnder accident conditions or during the operation of a diesel generator, the Emergency Service Water pumps are gearted and the cooling duty is.taken over by the Emergency Service Water System. Testing of the Emergency cooling Water pump and the Emergency service Water Booster pumps Jbackup to the Emergency Service Water pumps for use with the Emergency cooling Tower) involves manually isolating the Emergency service Water System f rom the service Water System and operating several valves to establish a flow path through the Emergency cooling Tower. These operations result in the temporary loss of cooling water flow to the room coolers and the possibility of failure of a system component in a non-conservative direction during. the test which could cause loss of cooling function. Additionally, these pumps,
'.ue to their back-up function for a very unlikely event, are l operated only during annual surveillance testing in accordance with plant technical specifications and therefore pump performance will not change significantly between tests.
5.3.2.4 Testing in Lieu of Section XI Requirements Ibese pumps will be inservice tested at least once each operating cycle in accordance with plant Technical Specifications.
5.3.3 Recuest For Relief S. 3. 3.1 comoonents Emergency Service Water Pumps (equivalent ASME code class 3) . l
' . 3. 3. 2 Requirement from which Relief Requested The inservice test quantities shall be measured nominally each month during n_ormal plant operation in accordance with IWP-3400.
S . 3. 3. 3 Justification These pumps are infrequently operated and it is not necessary to take the measurements monthly to verify proper operation.
- 5. 3. 3. 4 Testing in Lieu of Section XI 3equirements Ihese pumps will be tested f or operability and the inservice test i quantities will be measured quarterly. This frequency corresponds to the requirements of the current Technical Specif ications.
5.3.4 Request For Relief 1
- 5. 3. 4.1 comoonents l 5-3 November 1979 l
PBISI-2 L
RHR, RCIC, Core Spray, Standby Liquid Control, (equivalent ASME Code class 2) ; a_nd Emergency Service Water, High Pressure Service :
Water, E:nergency Cooling Water, Emergency Service Water Scoster Pumps (equivalent ASME Code Class 3).
4 5.3.4.2 Requirement from which Relief Requested Bearing temperatures on these pumps shall be measured in i a_ccordance with IWP-4300.
5_. J. 4. 3 Justifiestion '
l Of the pumps in question, several have no bearings outside the main flow path and are therefore exempted ];ty IWP-4310. O,thers '
have bearing configurations which could make temperature measurements either impractical or of little value. All the pumps in question have either flow lubricated bearings (exempt per IWP-4310) or a_nti-friction bearings lubricated by static oil baths. l easurement of the bulk temperature of an oil bath is not indicative of bearing condition. Temperature measurements of the bearings themselves are not meaningful. _ cur discussions with bearing manufacturers, pump builders, and maintenance people ,
confirmed our c_onviction that the temperature rise of an anti- .]
friction bearing prior to failure occurs ove.r a_ periods of l seconds or minutes. .I_t is our position that attempts to measure j temperature of anti-friction bearings cannot _be justified since temperature is not an early warning device.
5.3.4.4 Testing in Lieu of the section XI 9ecuirements P, roper operation is verified by the other inservice test quantities wtilch are measured. C_ondition of the pump bearings will be determined by visual inspection when disassembled for maintenance purposes.
5.3.5 Request for Relief 5,. J . 5.1 Components All pumps and valves.
- 5. 3. 5. 2 Requirement from which Relief is Requested R_equirements of IWP-2111, IWP-6000 and IWV-6000 to provide special tests and records management for Inservice Testing of.
pumps and v_alves.
5-4 November 1978 i
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4 PBISI-2 '
5_. 3. 5. 3 Justification l
Existing plant surveillance test procedures document most of the gpecial test conditions and parameters identified in the pump and v_alve portions of Section II 1974 Edition, including Addenda thru Summer J,975.
- 5. 3. 5. 4 Alternate to Section XI Requirements Surveillance Tests will be revimsed and revised as required to incorporate .t,,be necessary docu.nentation to meet Section XI requirements for Eump and valve testing. gurveillance Tests are retained at the plant site and are available for a,udit by the enforcement authority.
5.3.6 Request for Relief
- 5. 3. 6.1 Comeonents '
RHR, RCIC, HPCI, Core Spray Pumps (equivalent ASME Code Class 2) . l -
- 5. 3. 6. 2 Recuirement from which Relief Requested
' vibration amplitude on these pumps to be measured during each inservice test in accordance with _IWP-4500.
53.6.3 Justifleation Instrumentation is not installed to measure vibration of these pumps. Ihese pumps are infrequently operated and as such the mechanical characteristics should not change during the limited amount of operation per year. High radiation levels during operation prevent operatur o_bservation while inservice test.ing ;
the RCIC and HPCI system. RCIC and HPCI turbine steam lines have ;
been measured at approximately t.OR during operation. Radiation [
levels can be higher- than this value, depending on the number of l i
leaking fuel elements.
l ;
- 5. 3. 6. 4 Testing in Lieu of section XI Pequirements RHR and Core Spray will be inservice tested for vibration l monthly; caless radiological conditions gender it impractical to ; !
limit personnel exposure to less than 20 man-rem per pump test, in which case the vibration measurement will be performed each l operating cycle. The RCIC alid HPCI pump will be inservice tested ,l for vibration once each operating cycle. ganual techniques will l ;
be utilized in monitcring vibration parameters. l 5.3.7 Request for Relief 5- 5 November 1978
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PBISI-2
- 5. 3. 7,1 commonent gtandby Liquid control pump (equivalent ASME code class 2) .
5.3.7.2 Recuirement from which Relief Requested Pressure measurement to be in accordance with g,equirements of ,
rdP-4200.
5,.3.7.3 Justification Plant design does not incorporate direct pump inlet gressure '
indication.
- 5. 3. 7. 4 Alternate in Lieu of Section XI Requirements Liquid level in the'S_tandby Liquid control Tank will be monitored during inservice testing once per operating cycle. Zump suction pressure will be assumed to be the difference in e_levation i between tbe pump suction line connection and the tank liquid elevation 5.3.8 Request for Relief .
i 5,. 3. 8.1 common ents High Pressure Service Water, Emergency Service water and Laergency cooling Water pumps (equivalent ASME code class 3) .
- 5. 3. 8. 2 Requirement from which Relief Requested Eressure measurements to be in accordance with requirements of IWP-4200.
53.8.3 Justification Plant _ design does not incorporate direct pump inlet gressure indication. Ihese pumps are of a vertical design with each pump i suction c_asing submerged in a wet pit.
5.3.8.4 Alternate in Lieu of Section XI Recuirements The water level in each wet pit will be monitored during inservice testing of the respective pump. _ Pump inlet pressure will be calculated by utilizing available station instrumentation to determine the appropriate wet git level and calculating the available suction head at the pump.
5.3.9 Request for Relief l l l 5-6 November 1978
i i
{,. 3. 9.1 Components >
j >
Emergency service Water, Emergency Service Water Booster and Emergency C,ooling Water Pumps.
5.3.9.2 Requirement from Which Relief Requested l [
Inservice test quantities shall include flow rate measurement in accordance with IWP-1600 and IWP-3000.
1 3.9.3 Justification l l, i
P,,,lant design does not include flow rate measurement i'
instrumentatica f,or these pumps.
5.3.9.4 Testine in Lieu of section XI owairements l Pumps will be inservice tested at pump shut off head conditions !
in accordance with plant Technical specifications. l 1 3.10 Request for Relief l
1, 3. 10. 1 Components j RER and HPSW Pumps l 1 3. 10. 2 Requirement from which Relief Requested l gump parameters to be compared with reference valves in l l accordance y,ith IWP-3200. l t 1 3. 10. 3 Justification l f ge ferenc.: valves are defined in the code as one or more fixed i sets of valves as measured or observed when the equipment is known to be operating acceptably. The flow resistar:ce of the RER and HPSW systems changes due to fouling of the system, and variations in the _ mode of operation to satisfy plant conditions. !
It is, therefore, technically ig ossible to assign a fixed 'j reference value to the parameters of pump flow _and differential i pressure, since these valves are inversely proportional to each j other. j 1 3. 10, 4 T weina .in, Lieu 'of,section XI Recuirements l gump flow and differential pressures may be compared with a j reference head capacity curve as an alternative method o_f perforsing the evaluation.
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5-7 November 1978 l
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. . .s PSIsl-2 l
- 5. 4 Inservice Tastino Program for class 1, 2 and 3 Valves i The inservice testing program for Class 1, 2 and 3 valves is detailed in Table 5.4-1. Iable 5.4-1 identifies the valves to be tested, ASME Section II category, ,t_est frequency, and type of '
test. >
gategories of valves subject to the rules of this subsection are :
defined as:
l qategory A - valves for which seat leakage is limited in ;
the closed position for fulfillment of their function. '
gategory B - valves for which seat leakage in the closed position is inconsequential for fulfillment of their function. ^
gategory C - valves which are self-actuating in response to some system characteristic, such as. pressure (relief valves) or f_ low direction (check valves) .
gategory D - valves which are actuated by an energy source '
capable of only o_ne operation, such as rupture discs or explosive actuated valves. '
gategory E - valves which are normally locked open or i
locked _ closed to fulfill their function.
Inservice tests on valves will be perfor: sed with the test frequencies specified _in Table 5. 4-1. gansistent with the treatment of surveillance tests in the Technical specificatidns, these test frequencies may be adjusted plus or mimm 25%. In cases where the elapsed interval has exceeded 100% of the pecified interval, the next test interval shall commence at the and of the original specified interval.
valve exercising tests may be cancelled at the discretion of the Shift Superintendent or his alternate when in his judgement the test could B l ace the plant in an unsafe condition. Examples of this situation include certain valves inside containment where a _
test f ailure could negate the safety function of a system, a_nd situations where a component is inoperable and testing of the :
redundant component u y cause undesirable transients.
Iable 5.4-1 specifies the type of local leak rate test required l for category A valves. _Another check or remotely operated valve l
in series with the pressure isolation valve designated in Table l 5.4-1 may b_e substituted and leak tested in accordance with l Section XI to satisfy the pressure isolation criteria.
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l 5-8 November 1978 l
PBI3I-2 __
- 5. 5 REQUESTS FOR RELIEF FROM ASME SECTION II' RECUIREME!7FS (VALVES) 5.5.1 Request for Relief '
55.1.1 components gategory A valves identified in Table 5.4-1
- 5. 5.1. 2 Requirement From Which Relief Recuested Valve leali rate testing shall be performed in a,ccordance with IWV-3420 of Section II.
5,. 5.1. 3 Justifleation Leak rate testing _is already being conducted in category A valves l that perform a containment isolation function in accordance with ,
the plant Technical Specifications which conform as far as practicable to the Criteria of Appendix J to 10 CFR 50.
l The NRC >
has reviewed and approved the existing Peach Bottom A_tc.mic Power i Station leak rate testing grogram. gategory A valves performing a pressure isolation function will meet section XI requirements.
4
- 5. 5. t. 4 Testing in Lieu of Section II Requirements
- Leak rata testing shall be performed and documented in accordance with the giant Technical Specification on category A valves that '
performs a containment isolation function. gategory A valves performing a pressure isolation function
- sill be leak tested in accordance with Section II of the applicable edition of the ASME Code, as noted in Table 5.4-1 j 5.5.2 Request for Relief
- 5. 5. 2.1 comoon ents gertain valves identified by notes indicated in Table 5.3-1 of the _ Inservice Testing Program for class 1, 2, and 3 valves.
- 5. 5. 2. 2 Recuirement from Which Relief Requested i
glass 1, 2 and 3 valves shall be tested in a_ccordance with IWV-3000. '
- 5. 5. 2. 3 Justification
- gartain valves cannot be practically tested in the manner or at ,
the f_requency required in IWV-3000 based on plant design.
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Existing plant surveillance tests and Tecinical Specifications l
5- 9 November 1978
. . ., . l 1
PBISI-2 -
already establish practical testing requirements which fulfill the intent of IWV-3000 within the constraints of plant design.
5.5.2.4 ,y3 ting in Lieu of Section XI Requirement.G Individual exceptions with alternatives identified as noted in Table 5.4-1.
5.5.3 neo pc.e for Relief 5.5.3.1 comoonents 611 valves identified in Table 5.4-1 of the Inservice Testing Progran f_or class 1, 2 and 3 Valves.
5.5.3.2 Requipement- from which Relief Requested g,orrective action for inoperable valves require condition be corrected before unit startup from a cold shutdown condition in accordance with IWV-3410 (g) and IWV-3520(c) .
- 5. 5. 3. 3 Justificaeion constraints on unit startup with an inoperable valve depend on many f actors s_pecific to individual plant desigo _ Limiting conditions for operation have been analy=ed and ale identified within the ol.mt Technical specifications.
5.5.3.4 Alternate to Section XI Requirements p aperable valves will be evaluated within the constraints of the plant Technical specifications ta determine when an inopu able valve will prevent pl. ant startup from a cold shutdown condition.
5.5.4 Request for Felief
)
- 5. 5. a. I commonents i
Spali control, solenoid, and check valves within class 1 exempt portice of Control Rod Drive Hydraulic System as identified on drawing ISI-M-357.
5.5.4.2 Requirement from which Relief Requested class 1 valves shall be categorized in accordance with rdv-2000 and tested in accordance with Idy-3000.
5-10 November 1978 i
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PBISI-2
- 5. 5. 4. 3 Justification Ihese small valves cannot ce practically tested to Section _XI '
criteria. They have not been categorized nor included in Table i
- 5. 4 - 1. ,
5.5.4.4 Testing in Lieu o f Section II Requirement.s Scram testing of control rods is the only practical method of ;
testing these small valves. _ scram testing is performed on all ;
control rods, consequently all _the affected small valves are functionally tested as part of the ,s_afety portion of the CRD system, near the end of each refueling outage. This frequency of
,- testing is acceptable ~ in accordance y_ith plant Technical l Specifications. l 5.5.5 Request for Rel.t.ef l
5_. 5. 5. I comoonent.c l l Category A and a valves j l 5.5.5.2 R_equirement from which Relief Requested l I valve stroke time shall be compared with the previous test j gesults in accordance with IWV-3410 (c) (3) . l ,
5_. 5. 5. 3 Justification l glectrically driven motor operator stroke times do not vary' l significantly. Excessive valve resistance results in motor overcurrent, and an electrical tripping of the motor operator.
P_erforming the evaluation to previous test data would therefore '
be meaningless. l 15.5.4 Testing h Lieu o_f Section y Requirements l An evaluation shall be performed by comparing the stroke time on l alectrically driven valves with _the more conservative of the -l l following two limits: (1) the limiting value of full stroke l l determined b_y the technical specification; or by some other j technical evaluation that establishes the criteria for l i determina.ng the operability status of the valve, and (2) increase in stroke time of 25% or more from the nor:nal or expected stroke ,
time, with stroke times greater than ten seconds; or 50% or more '
for valves with stroke times less _than or equal to ten seconds.
1 5.6 Request for Relief j 15.6.1 ,
comoonents l l l
5-11 November 1978 I l
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i PSISI-2
_All valves with remote position indicators. l 15.6.2 Requirement from which Relief Requested l
_All valves with remote position indicators, which during plant j operation are inaccessible for direct observation, shall be visiut 1 y observed in accordance with IWV-3300.
- 5. 5. 6. 3 Justificaeion l Our present program for the adjustment and verification of the l limit switches on motor operated valves ensures that the remote valvo indicators accurately reflect valve operations. A_fter maintenance on the valve or its operator, the limit switches are adjusted in accordance with a maintenance procedure, and the activity documented in the procedure. Ihe valve is stroked to [
verify proper operation after the adjustments and _this fact is l documented in our maintenance records. Ihis program satisfles [
the intent to IWV-3300. l 1
S. 5. 6. 4 Testing h Lieu o_f_ Section H Requirements j -
Ihe maintenance program' described in 5.5.6.3 above may be l performed to satisfy the intent of IWV-3300 on m_ctor operated j valves. l 5.5.7 Recuest for Relief l 1 5_. 5. 7.1 components j ,
i category A valves l .
- 5. 5. 7. 2 Requirement from which Relief Requested l .
Method for determining valve seat leakage in accordance with IWV- l 3420 (d) .
- 5. 5. 7. 3 Justification l Ihe two method described do not permit leak rate testing during l power operation, or presents a_ possible personnel safety hazard in the event a tell tale is opened. ;
- 5. 5. 7. 4 .T_estinc Jg}, Lieu pf Section y Requirements j 1
In addition to the two methods described the following method may l
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be used to verify leak tightness. One er more normally closed l valves on the line shall be closed and the leakage rate determined by m_easuring and evaluating the rate of pressure l o
i 5-12 November 1978 -(
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2 i PSISI-2
! l increase in an isolated section of the line adjacent to 'the !
pressure isolation valves.
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' 5-13 November 1978 i.
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1 PBISI-2 Tatle 5.2-1 INSLRVICE TESTLUG V:40GhM1 EOH E C UI V A L E h'I ASME CLASS gI _2 Ar4D _3 FUMPS kHECUENCY CF MEASUHEMENT FREQUENCY FQUIVALENT C E T EST PAR AMET EkG OF ASME OPERABILITY FUMP CLASS E Pi P Qi TL V L/P CilECK I.D. 11 0 .
litiR 2 Kb M M M NA M M M 2 ( A, B, C, D) P3 5 l IIPCI 2 M M NR M NA A M M 20P ( 3 3,3 6) i RCIC 2 P M NE M NA A M M 20P36 .
Core Spray 2 hF M hR M NA K M M 2 (A, B,C, D) P 3 7 Standby t iquid Contrul 2 NR A A A NA A A M 2 (A, H) P40 Escrgency Service Water 3 ER G G NA NA V O Q O ( A, B) P 57 liigh fressure Service Water (Hlik d.h.) 3 hk N P M NA h M M 2(A,B,C,D)P42 Emergency Coolin; Water 3 NR A A NA NA A A A 00P18t Emergency Service 'aator Eaoster 3 hk A A NA NA A A n O ( A, P) l'I t,3 ..
i i .
PBISI-2 -
Symbcis for Taile 5. 2- 1: ,
N hotative Speed Pi Inlet Pressure P Differential Pressure Qi Flow Bate Tb 8 earing Terptrature V. Vibration Amplitude L/P Lubricant Level or Pressure NA Not Available NH Not Required M Monthly 0 . Quarterly A Once Fer Operating Cycle i
, , . , . . . , , _ . _ . - - - 4 , .
__ _ m_._ _ _ _ _ ._ .._. _ _ __. _ . _. .. _ _ _ . . . . _ _ _ _ _ . . _ _.._m - . .__ . . . . . , . . . _ . . , _. _ . _ _ _
P a l S I- 2
- TABLE 5.4-1 I ..S E R V I CE TESTING Pit 0G R A!! FOR EQU IvaLE!JT AS:lC CLASS 1, 2 AND 3 VALVES Sheet 1 of 11 l TEST i l.D. CATECOHY Fl:EqUliNCY, V A X.V E, ,
TYPE O F TEST, R E ll A,R,K,S
_151-1. .3_51
!!a i n S t e.t i.
AO-1-S6(A,ii,C D) A Q F/P Note (!) J '
A0-1-M0(A,3,C,D) A 4 F/P Note (l) J RV-1-71(A,B,C B/C A Note (2) S/V Note (2)&(3) b,C.F.C,11,J K,L) 110 7 4 A C Note (4) F 'J
- 10 7 / A C Note (4) F J R V 7 t: ( A , h ) C A *!o t e ( 2 ) S Noce(2)
Reactor Ree i reu la t i on
- iu- 2-4 3( A ,15 ) S C Note (4) F tiu 5 J ( A . 6 ) b C Note (4) F lio h 5 ( A ', li ) h C-Note (4) F
.'lo
.* - o o ( A , li ) il C Note (4) F t'e e d w .s t e r VV o-2n(A,B) A/C A Note (5) F J VV-6-9h(A,B) A/C A :? o t e ( 5 ) F J, PI
- lo- a- 3ii( A , B ) A A N o t e ( f; ) 'F J t
Y
4 PBISI-2 ,-
TAhLE 5.4-1 (Cont 'd ) Sheet 2 of !! l i
TEST
,V A l,V E 1.D. CATEGORY FREQUENCY TYPE OF TEST REHARKS I S I -fl.-3 5 4 Reactor tJater Cleanup 30-12-15 A Q F J HO-12-IP, A y F J VV-12-62 C A Note (5) V ltV-12-46 E N N tio-12-68 A y F J 15I . ,3_5_7 1
Cont rol lio d Drive VV-3-ilu C N No.e(7) N VV-3-ll3 C H Note (7) N
.I. S I. -II .3 5 8, S t a n d la y Liquid Control VV-II-17 C A Note (3) -V VV-II-16 A/C A. Note (8) V J, PI RV-II-39(A,B) C A S VV-11-43(A,B) C Note (17) V XV-Il-14(A,B) D A F J , t' l
- VV-Il-15 I: N N l VV-II-26 E N N VV-Il-13(A,h) E N N i VV-!l-12(A U) E N N Vv-Il-25 E N N VV-Il-41 E N N VV-Il-24 C N N V V- ! !- I I E N N
l s,
PhiSI-2 T A L L I. 5.4-1 ( C o n t ' .4 ) S lic e t 3 ot ~ 11 l .* .
TEST
, s. V L 1.o. C AT *Go tty FAL40 E:;CT T,Y_ P L , 0 f T 6 S,T REHARKS 4
151-:1- 3 W
- ~
HCIC
.0-13-15
'> A Q F J 310-13-16 A Q F J.Pl
- 10-13-21 A Q F J, PI l10 41 A Q F J 210-4244 8 Q F A0-13-22 C C Note (9) V Au-4240 A Q Note (10) F J AO-4241 A ) Note (1:1) F J i VV-13-50 A/C Q V J VV-Il-29 C Q V VV-13-32 A/C y V J
.10-13-1J B Q F
!!u 1 11 B Q F
!!O-11-27 . 11 ) F Au-13-32 1; !) F
[ .AO-13-34 L Q F Au-13-35 h Q F V dV 1 19 ( A , C Q V 4 ii C,u) ;
VV-11-40 _C A ::o t e( 13) V-V V l 's C Q- V E li ;; -
- 'VV-13-9 -'
VV-13 L Ie N V V 4.1 ' E i;
.N.
VV-Il-49 L . N ,
4 4
9 --, , , - _,-,e-r --
=e r- -t--t dr---+ 'm- -- - --
+-W - - - ~ - - - - - - - - = - + -+---e--+ = - --v = 't m
PBISI-2 ,
TAhtC 5.4-1 ( C o n t,' d ) Sheet 4 of !! l TEST VALVE 1, . D . CATECORY F_k CQ U Et CY T Y P E O F,,T_ CST RE!! ARK S.
I S. I.-M. .3 6 5 Ill* C l
!!O-23-15 A Q F J 10-23-16 A Q F J.PI Au-23-1B C C Note (9) F VV-23-65 A/C y V J VV-23-56 A/C Q. V J MO-23-53 A y F J MO-23-19 A y F J. PI HO-23-25 B Q F
!!O-23-31 B Q F MO-4244A B Q F A0-4247 A Q I;ote(ll) F J AQ-4248 A Q Note (l1) F J
- 10-23-!7 b Q F HO-23-57 B Q F 110-23-20 A Q F J.PI
- 10- 23-14 h Q F
- 10-23-21 A Q F J,PI
-110-23-24 8 Q F An-23-42 B Q F-A0-23-43 H Q F .
A0-23-53 8 Q F VRV-23-140(A, C Q V B,C,D)
VV-23-32 C 4- V VV-23-61 C A Note (IH) V VV-23-22 C Q V VV-23-u2 C Q V VV-23-12 E N N VV-23"1I E S N' VV-23-51 f. N 'N VV-23-52 E N N
PhtSI-2 ,
TABLE 5.4-1 (Cont'a) Sheez 5 of 11 l ""
TEST VALVE I.D. CATECodY Fl:Ey L' E N,CY TYPE OF T,ES,T .R E;1 A R K,$_
..I S I-il.~.3 b 2 Core S p r os y i
P1 no-14 12(A.B) A 4 F J.
lu-14-26(A B) B Q F Au-14-13(A,B) C C Note (12) F '
tto-14-7(A,B,C.D) B Q F F J,PI MO-14-!!(A.A) A Q
- 10 5 ( b , A , C , D ) B Q F SV-4224 h N Note (13)
SV-4225 B ti Note (13) -
VV-14-lu(A,il,C D) C Q V VV-14-22(A,4,C,0) C I; t;ote(13) -
V V 2 3 ( A . II . C . D ) C N Fote(13) -
214-223 C N tiote(13)
HK-223 C N Note (13) -
V V- 14 -8 ( A , li , C , D ) E N N V V- 14-6 3( A , B ,C ,0 ) E :1 N VV-14-14(A.S) E N N I S I-ti -3 61 H il R MO-lO-13(A,B,C,D) B Q F MO-lu-25(A,B) A 'l F J. PI Au-lu-46(A,B) C C Note (12) P
- -10-10-32 A C Note (14) F J C Note (14) F J. P1
- 10-10-33 A ti<. 17 A C Note (14) F J. P1 MO-lu-la A C Note (14) F J 1u-10-34(\,B) A ) F J
- llu- l u- 31 ( A , B ) A 4 F J
- lo- l u- 3ti( A , B ) A y F J 4
P1,l d i- 2 .
TAnLE 5.4-1 (Cont'd) Slicet b ot !! l- -
TEST VAL.VE 1 . D ., CATEGONY FREQUENCY TYPE OF TEST REHARKS SID-10-15(A,B,C,0) B Q F
!!0-10-20 B Q F
- 10- 15 4 ( A , B ) B t/ F J.PI .
110-10-176 B .: F
- 10-10-174 5 -Q F A0-lu-175 B y F Ho-to-39(A,B) B Q F
!!O- l u- 2 6 ( A , B ) 11 Q F 210-10-16(A,B,C,D) B Q F ,
, SV-4221 b N Note (13) -
I SV-4222 b N Note (13) -
SV-4223 E N Note (13) -
V V- l u-!d 14 tl 3 C C Note (l9) V V V 4 3 ( A ,11,C . D ) C Q V VV-lu-51 C N Note (13) -
VV-lo-63 C N Note (13) -
. VV-lu-64 C N Note (13) - .
VV-!O-73 C N Note (13) -
VV-10-183(A,H) C li Note (13) -
VV-lu-Id4(A,B) C 5 Note (13) -
V V 2 H ( A ,15, C , b ) .E N N V V l il O E N N V V- 10-(,6 E. N N VV-lb-ul(A,B) E N N VV-10 E .N N I S 1 ::. . 3 3 0 il l f,li Pressure Service Water
!!O 89 ( A , H , C ,D ) il Q -F l10- 3 2 - 24 f16 8 Q F VV- 32-11( A , B ) E N N-V V- 32-S l ast 4, B ) E. N .
V V- 3 2 - 2 '. ( A , B , C , D ) 'E N
- 9 P eI S!- 2 ?.
T A li t. t, 5.4-1 (Cont'd) Sheet 7 of I1 {'
TEST V A I. V s; f.D. CATLCui;Y F a t.q C E . CY TY,PC OF TEST, R E?l A RK S t.r e r ge n c y Service LJ a t e r
- 10- u 49 :s b y F 1 :10--2972 is I) F 110-3972 B Q F l
A0-0 2 4 I ( A ,11, C , u ) B Q F l'
An-2334(A,B) S I) F A U- 2 3 3 5 ( A , is , C , b I) F D , E , F , C , 51 )
A0-2333(A,B) 3 Q F Au-2336(A,3,C b i) F D . E , F .C ,il)
V V- 3 3 515 A ,ls *C y V VV-33-2-516 C A Note (20) V VV-33-2-513 C A :;o t e ( 2 6) } V j VV-33-2-514 C A t;o t e ( 2 8-) V :l VV-33-506 E N :: 1 Cne r:;e n c y Cooling 210-4 t:- 2:lH 4 ( A , B ) 3 A ;ote(15) F
- 10-411- 3:104 ( A ,ls ) S A Note (l5) F l10- bri 41 !! .A Note (15) F
- 10-0 5 01 ( A ,1$ , C ) 3 A t;o t c ( 15 ) F l 210-0 5 0 2 ( A , B , C ) B A ;ote(15) F llo-2SO3 d s) F
- 16-3403 B Q F V V- 4 :i- o- S ul. C A Note (20)- V V V- 4 ti- O ' ;0 4 ( A , ti ) C A t;o t e ( 20 ) V V V- 4 ti-o- 30 3( A ,4 ) C :; :;
V V- 4 2,-u- S u S ( A , n ) 1: N :.
o P u l S I- 2 . .
T AisL E 5. 4- 1 (Cont'd) Sheet s of 11 l,,
TEST CATEG01Y F R E,g U,E N CY T Y,P E_ ,0, F (EST RENAMKS,
' V A l.V E I.D.
1S.1-:1.-363 Fuel Pool Cooling ,
V V- ! 9 - flK 2 3 7 513 C Notel21) V V V- 19-:iK 2 3 7113 C Note (21) V V RV 2 2 0 4 ( C ,1)) C A ,
V Nore(16)
E N N VV-19-25 S Yll ijul,S, l
A~ Once per Operating Cycle (or d u r i n y, Hefueling Outage) it tjuarterly C Cold Shutdown E x c e e d i n >; 4d Ilou rs .
H ;J o t Applicable or None P Partial S t rok e Exercise F Full Cycle Exercise, includes S t rok e Tining for Power Operated Valves V Functional Check with Flow 5 Set Point Check J Leak rate t e n. t e d in accorilance with plant Technical Specifications which conforns as far as practical to c li e criteria of Appendix J to 10 CFR $0.
Pi Leak res t e tested in accordance with Section XI of the ASME Code.
d
-m.. , , - - - , -- e ,, rs ,m.-m -
~
PBIsI-2 - -
NOTES FOR TABLE 5.4-1
- 11) In accordance with the plant Technical specifications i
glosure timing will be perforased quarterly when the reactor is below 755 power. In the event that the under 75% power testing l cannot be performed at the guarterly frequency, partial closure of the valves will be performed as an alternate.
- 12) In accord _ance with the plant Technical specifications at least one safety valve and five gelief valves for the RPV will be tested or replaced with bench tested valves once per operatig cycle. 611 valves will be tested or replace 3 every two cycles.
- 13) In accordance with the plant Technical specifications each relief valve f_or the RPV shall be manully opened until steam -
flow is verified by d_ischarge line temperature once per operating cycle when reactor pressure is equal to or greater than 100 paig.
- 14) Exercising of these valves is not practical during power operation. These valves will be exercised during periods of cold l shutdown exceeding 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> b_ut not more often than once every three months. Talves Mo-1-74, 77 are steam line drain valves used during startup; as such, these valves will be functionally exercised but not stroke timed.
- 15) There is no practical way to test this normally open check i valve during reactor operation or cold shutdown. _ Positive - ,
closure of this valve will be verified once per operating cycle during local leak rate testing.
- 16) These valves are used only during startup for heat cycle long path recirculation back to the main condenser, us such they are considered operating convenience valves and will be full stroked once per operating cycle.
l
- 17) Jue to thermal cracking in the CRD return nozzle at the l RPV, flow in this line is blocked off during power operation.* l Functional demonstration of operability and leak rate testing of these check valves is therefore unnecessary.
- 18) Functional operability of this valve will be performed while injecting de.ur.eralized water to the RPV once per operating cycle in accordance with the olant Technical specifications.
, 19) These valves are located in a high -adiation area during l power operatien. It is not practical to xercise the valve other ;
I than when the area is a_ccessible should maintenance be required. l l The valve will be exercised during cold shutdowns exceeding 48 !
hours. !
November 1978 l
{
=
l .
e PSISI-2 110) These valves do not appear on ISI-M-359. They are air operated control valves in the turbine evhaust return line to che turbine gland seal condenser. Ine exhaust return line ir identified as class 2 exempt 13HB-2" in zone K-9 on ISI-l*- 359.
111) These valves do not appear on ISI-M-365. T_ hey are air operated control valves on the turbine ewhaust return line to the gland seal condenser. The exhaust return Iine is identified as class 2 exempt 23HB-2" in zone K-6 on ISI-h-365.
112) These valves are within the drywell and are inaccessible during power pyeration. It is not practical to exercise these valves during pow 1r operation. The valve will be exercised when the drywell is se-inerted and accessible.
113) These saall valves are not testabls to IWV-3520 requirements b,y plant design, however, tne valves are functionally checked continuously during plant operation in accordance with plant Technical Specifications. C_onsequences of failure of any of the small valves does not prevent the safety function af the affected ECCS.
114) System design prevents exercising of these valves with reactor pressure above 75 psig.
during a cold shutdown.
These valves will be exer ~c ised 115) These valves will bn exercised at the same frequency as the f inservice testing of the a:nergency cooling water and emergency service water booster pumps. Technical Specifications for the plant require system operability 1 pumps & valves included) to be checkad once per operating cycle.
116) These vacuum relief valves will be tested by mechanically exercising the valve once oer operating cycle to assure operabiliiy-117} P1 ant design does not al. low exercising of these valves as required in lWV-3520. These valvms will be functionally checked to pass flow during 2anthly pump operacility tests.
118) Exercising of this velve will be performed once per operating cycle. It is not practical to exercise this valve by passing flow through it on a_ quarterly basis because of the potentiel for _ contamination of the condensate storage tank with radioactiva torus water. Eull flow testing of this valve is not practical cince the test line return to the torus cannot pass full fIcw.
November 1978 l 1
l , ,
s- . ,:
l i
PBISI-2 119) Functional exercisincj of this valve will be demonstrated during 3?V head spray operation to accommodate cold shutdown.
Exercising of this valve durha power operation a not gractical.
120) Functional exercising of this valve is not practical during plant operation with the n_orsal plant service water system in service. T_he valve will be exercised once per operating cycle when the emergency cooling system is tested according to plant Technical Specifications.
121) F.xercising of these valves will be demonstrated whenever this line is Aested by providing flow with the RER system intertie. Hormal periodic exercising as required in IWV-3520 is
, not practical due to valve and plant design. Ese of the RSR system intertie to inject into the spent fuel goal to exercise these valves would unnecessarily contaminate the spent fuel 20o1 with corrosion products from the carbon steel piping within the -
RER System.
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l i
November 1978 l 21214
,