ML20102B863

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Second 10-Yr Pump & Valve Inservice Testing Program
ML20102B863
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 02/20/1985
From:
ARKANSAS POWER & LIGHT CO.
To:
Shared Package
ML20102B860 List:
References
PROC-850220, NUDOCS 8503040460
Download: ML20102B863 (27)
v • d • e


Text

(ATTACHMENT A TO 1CAN028507)

! ARKANSAS POWER & LIGHT COMPANY l

ARKANSAS NUCLEAR ONE l- UNIT ONE l

l SECOND TEN-YEAR PUMP AND VALVE 4

INSERVICE TESTING PROGRAM i

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TABLE OF CONTENTS PAGE I. PHILOSOPHY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 II. VALVE TESTING ........................... 3 A. TABLE A - UNIT 1 VALVES REQUIRING INSERVICE TESTING . . . . . . 6 III. PUMP TESTING ........................... 17 A. TABLE B - UNIT 1 PUMPS REQUIRING INSERVICE TESTING ...... 18 IV. RELIEF REQUESTS .......................... 19 A. VALVES SUBJECT TO SUBSECTION IWV 0F THE CODE ......... 19 B .~ PUMPS SUBJECT TO SUBSECTION IWP OF THE CODE . . . . . . . . . . 22 V. ATTACHMENTS ............................ 23 A. LIST OF P& ids 0F ANO-1 SAFETY-RELATED SYSTEMS . . . . . . . . . 23 B. DESCRIPTION OF SIGNIFICANT CHANGES TO THE ORIGINAL INSERVICE TESTING PROGRAM ............ 24 1

I. PHILOSOPHY 1 l

The Arkansas Nuclear One Unit 1 (ANO-1) Pump and Valve Inservice Testing (IST) Program has been developed to meet the requirements of 10 CFR 50, Section XI of the ASME Boiler and Pressure Vessel Code (the Code), and the ANO-1 Technical Specifications. The purpose of the IST Program is to detect a change in the operating status of equipment based upon a comparison of baseline data (obtained during initial testing or after equipment overhaul) and the data obtained during the performance of periodic testing, and to initiate corrective action when necessary. The IST Program was developed through the joint effort of the AND Operations Superintendent, Plant Analysis Superintendent, I&C Supervisor and Mechanical Engineering Supervisor.

ANO-1 Technical Specification 4.0 requires that " inservice inspection of ASME Code Class 1, 2, 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10 CFR 50, Section 50.55a(g)(6)(i)."

10 CFR Part 50, Section 50.55a(g)(4)(iv) states that "... tests of pumps and valves . . . may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) [Section 50.55a(b)] of this section, subject to the limitations and modifications listed in paragraph (b) of this section, and subject to Commission approval." Section 50.55a(b)(2) of the Code of Federal Regulations presently refers to Section XI including " editions through the 1980 edition and addenda through the Winter 1981 Addenda." In accordance with these requirements, Arkansas Power & Light Company will perform inservice testing of the ANO-1 pumps and valves identified herein using IWP and IWV sections of the referenced edition and addenda of the Code.

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

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

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

The following is a brief explanation of the table headings:

Valve Number - Identification number of each valve.

System - The system to which the valve belongs.

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

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

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

The following is a brief explanation of abbreviations:

Aux Clg - Auxiliary Cooling BS - Building Spray Btfly - Butterfly BW - Borated Water BWST - Borated Water Storage Tank CF - Core Flood Clr. - Cooler CS - Condensate System CV - Control Valve CW - Chilled Water CZ - Clean Liquid Radwaste DH - Decay Heat Disc - Discharge DWD - Dirty Waste Drain 3

EFW - Emergency Feedwater Emerg. - Emergency FW - Feedwater GZ - Waste Gas Radwaste HP - High Pressure HVAC - Heating, Ventilation and Air Conditioning I/C - Inside Containment ICW - Intermediate Cooling Water Iso - Isolation LO - Lube Oil LP - Low Pressure MOV - Motor Operated Valve MS - Main Steam MU - Make Up N/A - Not Applicable NaOH - Sodium Hydroxide N2 - Nitrogen 0/C - Outside Containment PSV - Pressure Safety Valve PZR - Pressurizer R8 -. Reactor Building RCP - Reactor Coolant Pump RCS - Reactor System Rm - Room SG - Sluice Gate 4

SS - Sampling System SW - Service Water VSF - Ventilation Supply Fan i

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TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT PSV-1001 RCS Relief Pressurizer Relief C PSV-1002 RCS Relief Pressurizer Relief C CF-1A RCS Core Flood Discharge Check C CF-1B RCS Core Flood Discharge Check C DH-13A RCS LP Injection Check C 4

DH-138 RCS LP Injection Check C DH-14A RCS LP Injection Check C DH-14B RCS LP Injection Check C I DH-17 RCS LP Injection Check C DH-18 RCS LP Injection Check C MU-34A RCS HP Injection Check C MU-34B RCS HP Injection Check C MU-34C RCS HP Injection Check C MU-34D RCS HP Injection Check C Main Steam to CV-2617 MS EFW Turbine Gate B Main. Steam to CV-2667 MS EFW Turbine Gate B CV-2691 MS Main Steam Isolation Gate B CV-2692 MS Main Steam Isolation Gate B PSV-2684 MS Relief Main Steam Relief C PSV-2685 MS Relief Main Steam Relief C l

PSV-2686 MS Relief Main Steam Relief C PSV-2687 MS Relief Main Steam Relief C PSV-2688 MS Relief Main Steam Relief C PSV-2689 MS Relief Main Steam Relief C 6

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

TABLE.A

UNIT I VALVES REQUIRING INSERVICE TESTING 4'

IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT PSV-2690 MS Relief Main Steam Relief C e

PSV-2691 MS Relief Main Steam Relief C PSV-2692 MS Relief Main Steam Relief C

, PSV-2693 MS- Relief Main Steam Relief C PSV-2694 MS Relief Main Steam Relief C PSV-2695 MS- Relief Main Steam Relief C PSV-2696 MS Relief Main Steam Relief C 1

PSV-2697 MS Relief Main Steam Relief C I PSV-2698 MS Relief Main Steam Relief C PSV-2699 MS Relief Main Steam Relief C t-CV-1214 MU RCS Letdown Gate A CV-1216 MU RCS Letdown Gate A I CV-1219 MU HP Injection Gate B

CV-1220 MU HP Injection Gate B CV-1221- MU RCS Letdown Gate A

-CV-1227 MU HP Injection Gate B CV-1228 - MU HP Injection Gate B CV-1234 MU RCS Makeup Gate B-CV-1270 MU RCP Seal Bleed Off Gate A CV-1271 MU RCP Seal Bleed Off Gate A CV-1272 MU RCP Seal Bleed Off Gate A CV-1273 MU RCP Seal Bleed Off Gate A CV-1274 MU~ RCP Seal Bleed Off Gate A

.CV-1300 MU MU Pump Recirculation Gate B CV-1301 MU MU Pump Recirculation Gate B 4

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' TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT MU-19A MU Pump Discharge Check C MU-19B MU Pump Discharge Check C MU-19C MU Pump Discharge Check C CV-1400 DH Pump Isolation Gate B CV-1401 DH Pump Isolation Gate B CV-1405 DH Sump Suction Gate B CV-1406 DH Sump Suction Gate B CV-1407 DH BWST Outlet Gate B CV-1408 DH BWST Outlet Gate B DH-2A DH Pump Discharge Check C DH-28 DH Pur..p Discharge Check C CV-2400 BS RB Spray MOV Globe B CV-2401 BS RB Spray MOV Globe B BW-6A BS Pump Suction Check C BW-6B BS Pump Suction Check C BS-4A BS Pump Discharge Check C BS-4B BS Pump Discharge Check C CV-2630 FW MFW Isolation Gate B CV-2680 FW MFW Isolation Gate B FW-7A FW MFW to "A" Steam Check C Generator FW-78 FW MFW to "B" Steam Check C Generator FW-13A EFW EFW to "A" Steam Check C Generator FW-13B EFW EFW to "B" Steam Check C Generator CV-2620 EFW P-7A Iso Valve to "B" Gate B Steam Generator 8

TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT CV-2626 EFW P-78 Iso Valve to "B" Gate B Steam Generator CV-2627 EFW P-7A Iso Valve to "A" Gate B ,

Steam Generator CV-2670 EFW P-7B Iso Valve to "A" Gate B Steam Generator CV-1616 CA Na0H Tank Outlet Gate B CV-1617 CA Na0H Tank Outlet Gate B Stop CA-61 CA NaOH Discharge Check C Stop CA-62 CA NaOH Discharge Check C Stop BW-2 BW MU Pump Suction Check C Stop BW-3 BW MU Pump Suction Check C BW-4A BW BWST Outlet Check C BW-4B BW BWST Outlet Check C Letdown CV-2214 ICW Cooler Isolation Gate A Letdown CV-2215 ICW Cooler Isolation Gate A CRD/RCP CV-2220 ICW Cooling Isolation Gate A CRD/RCP CV-2221 ICW Cooling Isolation Gate A Letdown CV-2233- ICW Cooler Isolation Gate A RCP CV-2234 ICW Motor Isolation Gate A CV-2235 ICW CRD Isolation Gate A Quench CV-1052 CZ Tank Drain Gate A 9

TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT Quench CV-1053 CZ Tank Drain Gate A Quench CV-1054 SS Tank Sample Gate A CV-1814 SS Pressurizer Steam Sample Gate B CV-1816 SS Pressurizer Water Sample Gate B Quench CV-1845 SS Tank Sample Gate A CV-5611 Fire RB Isolation Gate A CV-5612 Fire RB Isolation Gate A CV-1065 CS Quench Tank Isolation Gate A low Pressure CV-1667 N2 Nitrogen Supply Gate A CV-6202 CW Inlet Isolation Gate A CV-6203 CW Outlet Isolation Gate A CV-6205 CW Outlet Isolation Gate A "D" DH Room CV-3800 SW Cooler Inlet Gate B "B" DH Room CV-3801 SW Cooler Inlet Gate B "C" DH Room CV-3802 SW Cooler Inlet Gate B "A" DH Room CV-3803 SW Cooler Inlet Gate B E47A Spray Pump CV-3804 SW Inlet Valve Gate B E47B Spray Pump CV-3805 SW Inlet Valve Gate B Emergency Diesel CV-3806 SW "A" Cooler Inlet Gate B 10 c:

TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT Emergency Diesel CV-3807 SW "B" Cooler Inlet Gate 8 MU Pump Lube Oil CV-3808 SW Cooler Inlet A Gate B MU Pump Lube Oil CV-3809 SW Cooler Inlet B Gate B

, MU Pump Lube Oil i CV-3810 SW Cooler Inlet C Gate B CV-3821 SW B-DH Cooler Inlet Btfly B CV-3822 SW A-DH Cooler Inlet Btfly B A-DH Lube Oil I CV-3840 SW Cooler Inlet Gate B l B-DH Lube Oil CV-3841 SW Cooler Inlet Gate B l SW Loop II Iso to ICW CV-3811 SW Btfly B l'

SW Loop I CV-3820 SW Iso to ICW Btfly B

[ Cross-tie SW B to C Discharge CV-3640 SW Btfly B CV-3641 SW Loop II Isolation 8tfly B Cross-tie SW CV-3642 SW B to C Discharge 8tfly B Aux C1g CV-3643 SW Loop Isolation Btfly B Cross-tie SW CV-3644 SW A to B Discharge Btfly B CV-3645 SW Loop I Isolation Btfly B Cross-tie SW CV-3646 SW A to B Discharge 8tfly B RB Cooler CV-3812 SW SW Inlet Btfly B RB Cooler CV-3813 SW SW Inlet Btfly B

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TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT RB Cooler CV-3814 SW SW Outlet 8tfly B RB Cooler CV-3815 SW SW Outlet Btfly B 0/C Hydrogen CV-7443 HVAC Purge Gate A I/C Hydrogen CV-7444 HVAC Purge Gate A 0/C Hydrogen CV-7445 HVAC Purge Gate A I/C Hydrogen CV-7446 HVAC Purge Gate A 0/C Hydrogen CV-7447 HVAC Purge Gate A I/C Hydrogen CV-7448 HVAC Purge Gate A 0/C Hydrogen CV-7449 HVAC Purge Gate A I/C Hydrogen CV-7450 HVAC Purge Gate A Air Particulate CV-7453 HVAC I/C Monitor Gate A Air Particulate CV-7454 HVAC 0/C Monitor Gate A DH Removal CV-1404 DH from RCS Gate B DH Removal CV-1050 DH from RCS Gate B DH Removal CV-1410 DH from RCS Gate B "A" DH RB CV-1414 DH Sump Suction Gate B "B" DH RB CV-1415 DH Sump Suction Gate B 12 m

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TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING VALVE NO. SYSTEM DESCRIPTION TYPE CAT L

0/C RB l CV-4400 DWD Sump Drain Gate A l

i I/C RB j CV-4446 DWD Sump Drain Gate A RB Vent to

CV-4803 GZ Gaseous Waste Gate A i

RB Vent to CV-4804 GZ Gaseous Waste Gate A l

RB Purge

. CV-7401 HVAC Air 0/C Btfly A RB Purge CV-7402 HVAC Air 0/C Btfly A RB Purge l CV-7403 HVAC Air I/C Btfly A RB Purge CV-7404 HVAC Air I/C Btfly A Combined SW Discharge CV-3823 SW to Pond Btfly B Combined SW Loop CV-3824 SW Discharge to Flume Btfly B i

CV-3730 SW Sluice SG B Gate #1 Sluice CV-3731 SW Gate #2 SG B Sluice CV-3732 SW Gate #3 SG B Sluice CV-3733 SW Gate #4 SG B l Sluice CV-3734 SW Gate #5 SG B Sluice CV-3735 SW Gate #6 SG B Sluice CV-3636 SW Gate #7 SG B l

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TABLE A l UNIT I VALVES REQUIRING INSERVICE TESTING  ;

f. IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT Reactor Vessel I Internal Vent Valves N/A RCS (quantity:8) Check C

'SW-1k SW P4A Discharge Check C

.SW-1B SW P48 Discharge Check C SW-1C SW P4C Discharge Check C MU-1211 MU HP Injection Check C MU-1212 MU HP' Injection Check C MU-1213 MU HP Injection Check C MU-1214 MU HP Injection Check C MU-1215 MU HP Injection Check C SV-1077 RCS Pzr Vent Globe B SV-1079 RCS Pzr Vent Globe B SV-1081 RCS "A" Loop T Vent Globe B H

SV-1082 RCS "A" Loop T Vent Globe B H

SV-1083 RCS "A" Loop T Vent Globe B H

SV-1084 RCS "A" Loop T Vent Globe B H

SV-1091 RCS "B" Loop T Vent Globe B H

SV-1092 RCS "B" Loop Tg Vent Globe B SV-1093 RCS "B" Loop TH Vent Globe B SV-1094 RCS "B" Loop T Vent Globe B H

P78 Test Recirc CV-2869 EFW Isolation Gate B P7A Test Recirc CV-2870 EFW Isolation Gate B P7A to "A" Steam Generator Control CV-2645' EFW Valve Globe B 14 c_-_-

TABLE A UNIT I VALVES REQUIRING INSERVICE TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT P78 to "A" Steam Generator Control CV-2646 EFW Valve Globe B P7A to "B" Steam Generator Control CV-2647 EFW Valve Globe B P78 to "B" Stear, Generator Control CV-2648 EFW Valve Globe B CV-2800 EFW P78 Suction from CST Gate B CV-2803 EFW P78 Suction from SW Gate B EFW Suction from CV-3850 EFW SW Loop I Gate B CV-2802 EFW P7A Suction from CST Gate B CV-2806 EFW P7A Suction from SW Gate B EFW Suction from CV-3851 EFW SW Loop II Gate B P7A Discharge / Minimum FW-10A EFW Recirc Valve Check C P78 Discharge / Minimum FW-10B EFW Recirc Valve Check C P7A to "B" FW-55A EFW Steam Generator Check C f

P7A to "A" FW-55B EFW Steam Generator Check C P78 to "A" FW-56A EFW Steam Generator Check C P7B to "B" FW-56B EFW Steam Generator Check C CS-98 EFW EFW Suction from CST Check C CS-99 EFW EFW Suction from CST Check C CS-261 EFW EFW Suction from CST Check C 15

, TABLE A UNIT I VALVES REQUIRING INSERVICE' TESTING IWV VALVE NO. SYSTEM DESCRIPTION TYPE CAT CS-262 EFW EFW Suction from CST Check C EFW Suction from SW-11 EFW SW Loop I Check C EFW Suction from SW-13 EFW SW Loop.II Check C CV-2613 EFW P7A Steam Admission Gate B CV-2663 EFW P7A Steam Admission Gate B SV-2613 EFW P7A Steam Admission Globe B

-SV-2663 EFW P7A Steam Admission Globe B P7A Minimum FW EFW Recirc Valve Check C P78. Minimum FW-62 EFW- Recirc Valve Check C 16

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i III. PUMP TESTING ,

i Subsection IWP of ASME Section XI provides the rules and requirements I for inservice testing to verify operational readiness of Class 1, 2 and i' 3 pumps which are provided with an emergency power source. The purpose of the IST pump program is to identify those pumps and, subsequently,

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to test them according to the applicable Code requirements. The pumps which are covered by the IST Program are listed in Table B.

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

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

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

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TABLE B UNIT I PUMPS REQUIRING INSERVICE TESTING

. PUMP NUMBER DESCRIPTION P34A . . . . . . . . . . DECAY HEAT REMOVAL PUMP P34B . . . . . . . . . . DECAY HEAT REMOVAL PUMP P35A . . . . . . . . . . REACTOR BUILDING SPRAY PUMP t P35B . . . . . . . . . . REACTOR BUILDING SPRAY PUMP P36A.. . . . . . . . . . MAKEUP PUMP P36B . . . . . . . . . . MAKEUP PUMP P36C . . . . . . . . . . MAKEUP PUMP P4A . ......... SERVICE WATER PUMP P4B .......... SERVICE WATER PUMP P4C .......... SERVICE WATER PUMP P7A .......... EMERGENCY F.W. PUMP P7B .......... EMERGENCY F.W. PUMP-1 18 i

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IV. RELIEF REQUESTS A. VALVES SUBJECT TO SECTION IWV 0F THE CODE

1. COMPONENT: All valves stroked per IWV-3413

REFERENCE:

NA CODE REQUIREMENT: Corrective action per IWV-3417 at 25%

increase in stroke time from the previous test (if stroke time greater than 10 seconds) or 50% increase in stroke time from the previous test (if stroke time less than or equal to 10 seconds).

REASON FOR RELIEF REQUEST: Corrective action levels based on stroke times for these valves are incorporated into the test procedures. Literal implementation of the Code requirements would require a procedure revision each time the procedure is performed. The alternative method proposed is considered adequate and conservative.

ALTERNATIVE EXAMINATION: Valve stroke times will be compared to fixed reference values to determine if valve degradation has occurred. The changes in stroke time will be restricted to the 25% and 50% limits specified in IWV-3417 for increasing the frequency of stroke testing.

2. COMPONENT: CF-1A, CF-1B

REFERENCE:

P&ID M-230 CODE REQUIREMENT: IWV-3522 - Valves that cannot be exercised

. during plant operation . . . shall be full-stroke exercised during cold shutdown.

REASON FOR RELIEF REQUEST: Full-stroke testing of these valves during cold shutdown could delay startup more than eight (8) hours and could create as much as 28,000 gallons of liquid waste.

ALTERNATE EXAMINATION: These valves shall be partial-stroke tested during each refueling outage.

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3. COMPONENT: BS-4A, BS-4B

REFERENCE:

P&ID M-236 CODE REQUIREMENT: IWV-3522 - Valves that cannot be exercised during plant operation . . shall be' full-stroke exercised during cold shutdown.

REASON FOR RELIEF REQUEST: These valves are immediately upstream of the Reactor Building spray nozzles (i.e.', no isolation valves between nozzles and BS-4A/48). Water cannot be used to stroke BS-4A and 48 because this would introduce water into containment via the spray headers.

ALTERNATE EXAMINATION: These valves will be disassembled and full-stroke tested once every other refueling outage (i.e.,

one per outage on an alternating basis).

4. COMPONENT: SW-11, SW-13

REFERENCE:

P&ID M-204 CODE REQUIREMENT: IWV-3521 - Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522.

IWV-3522 . . . Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns.

REASON FOR RELIEF REQUEST: These are the check valves in the EFW pumps suction lines from the service water system. Full stroking these valves during power operation or during any cold shutdown is not practical because.it could allow service water to be injected into the steam generators.

ALTERNATE EXAMINATION: These valves will be disassembled and full-stroke tested per the following schedule: both valves will be opened and full-stroked by hand during the next refueling outage, 1R7. If both valves prove operable, we will then manually full-stroke one valve during each refueling outage, alternating between the two valves.

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5. COMPONENT: FW-13A, B

REFERENCE:

P&ID M-204 CODE REQUIREMENT: IWV-3522 - Check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.

IWV-3522 . . . Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and snall be full-stroke exercised during cold shutdowns.

REASON FOR RELIEF REQUEST: These check valves cannot be exercised during plant operation because cold water would be sprayed onto steam generator tubing and tube degradation could result. Moreover, flow testing during cold shutdowns must be done at reduced flow rates (< 500 gpm) to prevent tube degradation due to vibration and to minimize the impact on steam generator chemistry.

ALTERNATE EXAMINATION: None. The valves will be stroked at reduced flow rate (< 500 gpm).

6. COMPONENT: CS-98, 99, 261, 262

REFERENCE:

P&ID M-204 CODE REQUIREMENT: IWV-3522 - Check valves shall be exercised to the position required to fulfill their function unless ,

such operation is not practical during plant operation. '

IWV-3522 . . . Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns.

REASON FOR RELIEF REQUEST: These check valves are in a

, series parallel configuration. They are in the supply line i from the Condensate Storage Tank to the suction of the Emergency Feedwater (EFW) Pumps. Should one of the series

valves fail to open, the other loop would have increased flow to meet the EFW demand. Due to system design, there is no j way to test this single failure configuration.

I ALTERNATE EXAMINATION: None. The valves will continue to be

l. exercised assuming no single failure.

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4 B. PUMPS SUBJECT TO SECTION IWP 0F THE CODE

1. COMPONENT: Service Water pumps (P-4A, P-48, P-4C)

REFERENCE:

P&ID M-209 CODE REQUIREMENTS: Per IWP-4510, the location of vibration measurements shall generally be ". . . on a bearing housing."

REASON FOR RELIEF REQUEST: These pumps are submerged with extended casings and shafts. The radial bearings are water lubricated and located in the fluid flow path.

ALTERNATE TESTING: Vibration readings will be taken at the lower driver bearing (both radial and axial).

2. COMPONENT: Service Water Pumps (P-4A, P-4B, P-4C)

REFERENCE:

P&ID M-209, M-210.

CODE REQUIREMENT: Per Table IWP-3100-1, both pump differential pressure (dP) and flow rate will be measured.

Table IWP-4110-1 requires a flow rate accuracy of i 2%.

REASON FOR RELIEF REQUEST: By letter dated May 19, 1978, AP&L requested a relief from flow rate measurements until venturis and flow indicators were installed. This relief was granted by the NRC by letter dated March 8, 1979. Venturis and flow indicators were installed in 1979 and incorporated into our test procedure in 1980. However, the accuracy and repeatability of the instrumentation has never been consistent. The flow rate instrument accuracy problems have not been resolved.

ALTERNATE TESTING:

a. Continue monthly dP measurements to indicate gross changes in pump performance.
b. Once per refueling cycle, confirm adequate loop flows with a simulated engineered safeguards (ES) lineup using portable flow measuring instruments.

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(ATTACHMENT A TO 1CAN028507)

LIST OF P&lDs OF ANO-1 SAFETY-RELATED SYSTEMS P&ID DESCRIPTION M-204, Sheet 3. . Emergency Feedwater M-209 . .... . Circulating Water and Intake Structure Equipment M-210 . . .... Service Water M-230, Sheet 1. . . Reactor Coolant Syste-M-230, Sheet 2. . Reactor Coolant System M-231, Sheet 1. . Makeup and Purification System M-231, Sheet 2. . Makeup and Purification System M-232 . . ... . Decay Heat Removal System M-236 . . . . . . Reactor Building Spray and Core Flooding Systems 23

, 1 (ATTACHMENT B TO 1CAN028507)

DESCRIPTION OF SIGNIFICANT CHANGES TO THE ORIGINAL INSERVICE TESTING PROGRAM A. Change to the AP&L Response to the NRC Letter of April 22, 1981 (AP&L Letter ICAN078106 Dated July 27, 1981)

Item 1.a) CF-1A, 1B - Core Flood Tank Discharge Check Valves - These valves, in series with DH-14A and B, are tested at power for pressure isolation capability by continuous monitoring of Core Flood Tank pressure and level and the Reactor Coolant System (RCS) leak rate. The valves are not tested according to Section XI of the ASME Code (hereafter, the Code) due to system design and ALARA considerations.

Consequently, we are reclassifying CF-1A and 1B Category C.' We will continue to test the pressure isolation function of the valves as described above.

Item 1.b) DH-14A, 14B - Decay Heat Check Valves - These check valves are the last valves in the Decay Heat piping tying to the Reactor Coolant System (RCS). The pressure isolation capability of these valves (in conjunction with several other valves) is tested continuously at power by monitoring RCS leak rate. Leak rate testing of DH-14A and 148 is also performed during each cold shutdown. Neither of these tests meet the requirements of Section XI of the Code. Such testing is precluded due to system design and ALARA considerations.

Consequently, we are reclassifying DH-14A and 14B Category C. We will continue to test the pressure isolation function of the valves as described above.

Item 1.c) DH-13A, 138 - Decay _ Heat Check Valves - The pressure isolation capability of these valves, in series with DH-14A and B and in parallel with DH-17 and 18, is continuously monitored at power by monitoring RCS leak rate. Leak rate testing of DH-13A and 13B-and DH-17 and 18 is performed during each cold shutdown. Neither of these tests meet the requirements of Section XI of the Code. Such testing is precluded by system design and ALARA considerations. Consequently, we are reclassifying these valves Category C. We will continue to test the pressure isolation function of the valves as described above.

Item 1.d) MU-34A, B, C and D - High Pressure Injection Check Valves - l These check valves, in series with MU-1211, 1212, 1213, 1214 and 1215, are ledk tested quarterly at power by measuring the upstream (non-flow) line pressure. This test provides assurance of the pressure isolation capability of the check valves but does not meet the requirements of Section XI of the Code. Such testing is precluded by system design and 24

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'ALARA considerations. Consequently, MU-1211, 1212, 1213, 1214 and 1215

'have.been added to the IST program. These valves and MU-34A, B, C and D have been reclassified Category.C. We will continue to leak test these valves as described above. Also, CV-1219, 1220, 1227 and

'l _ 1228 have been reclassified Category B since they are open to perform their safety function. MU-19A, B and C have been reclassified Category C since the other check valves upstream provide adequate pressure I isolation from the RCS.

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! Item 1.e and f) DH-17 and 18 - Decay Heat Check Valves - These valves

-are tested as described in Item 1.c, above. These tests do not meet the requirements of Section XI of-the Code. Consequently, we are i- reclassifying these valves Category C. We will continue to test the L valves as described in Item 1.c.

- Item 1.i andj)' CV-1050 and CV-1410 - Decay Heat Suction Line Isolation Valves - The pressure isolation function of.these valves is tested quarterly by monitoring'the downstream' pressure in the piping. This test does not meet Section XI Code requirements. The valves are

, reclassified Category B, and testing will be-continued as described above.

,L Item 1.k) No change.

4 B. Addition of Reactor Coolant System (RCS) Vents to the IST Program i-

' Since the initial IST submittal, RCS vents have been added to the L -Reactor Vessel head, the T leg high points and tha' pressurizer--a total of 10 valves. All okgkhese valves are classifiv Category B per

! NUREG 0737. Due to operational restraints the valves cannot be tested at power, so they will be tested per Section XI of the Code during each

> cold shutdown unless-less than three months have elapsed since the previous test (per Subsection IWV-3412).

C. Addition of Emergency Feedwater (EFW) Valves to the IST Program i

Since the original IST submittal, the EFW system has been upgraded to a

!. safety grade system. Also, a number of new valves have been added to L the system during installation of the Emergency Feedwater Initiation and Control (EFIC) subsystem. All Class 1, 2 or 3 valves in the system

, which are used to bring the plant to cold shutdown or to mitigate the

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consequences of an accident:have been added to the IST program. The valves will be tested'in accordance with Subsection IWV of the Code j except that:

1. Check valves in the EFW pump suction line from the Condensate Storage Tank (CS-98, 99, 261, 262) cannot be full stroked because of the piping configuration. They are stroked monthly with sufficient flow to perform their accident function under normal 25

(non-failure) conditions. However, should one of the check valves fail to open, the other (non-failed) loop must pass increased flow to meet pump demands. The check valves cannot be tested for this condition. A relief request is made for this exception.

2. Certain check valves in the pump discharge line (FW-13A and B) cannot be stroked during the monthly test because cold water would be fed to the steam generators and tube damage could result.

These check valves are stroke tested quarterly during cold shutdown unless they have been tested within the previous three months, or during refueling outages. Allowed flow during testing is less than Code requirements. A relief request is made for this exception.

3. Check valves in the suction piping to the EFW pump from the Service Water System (SW-11 and 13) cannot be full stroke tested during plant operation because lake water would be fed to the steam generators. Both these valves will be manually stroke tested in refueling outage IR7. If the stroke test is satisfactory, each valve will be manually stroked every other refueling outage thereafter.

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