ML20141C319

Forwards Rev 18 to CNP IST Program

ML20141C319
Person / Time
Site:	Callaway
Issue date:	06/16/1997
From:	Naslund C UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20141C324	List: ML20141C319 ML20141C340
References
ULNRC-3602, NUDOCS 9706250104
Download: ML20141C319 (10)

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June 16, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk i Mail Station P1-137 Washington, DC 20555-0001 i

Gentlemen:

ULRNC-3602 l

l Callaway Plant Docket Number 50-483 Callaway Nuclear Plant Inservice Testing Program Update This letter transmits Revision 18 of the Callaway Nuclear Plant Inservice Testing (IST) Program. IST Program l updates have been made via Revisions 15a, 16, and 17 which

! are included in Revision 18. In accordance with the l guidance provided in NUREG 1482 " Guidelines for Inservice Testing at Nuclear Power Plants," this revision is being 1 provided to reflect major changes to the IST Program.

Attachment 1 is a brief description of the changes, and

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Attachment 2 contains a copy of Revision 18 of the IST Program.

l If you have any questions concerning this l submittal, please contact us.

1 Vr uly y rs

-1 Cha les D. Naslund I

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Attachments I l

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1 9706250104 970616 llllllllllllllllllllfllll ll PDR ADOCK 05000483 P PDR 1

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l Revision 15a Summary of Channes to the IST Program

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l Engineering evaluations have been perfonned for these changes and no Unreviewed Safety j Question exists as a result of this revision. The following table explains all changes by component.  ;

1 Components Affected Description of Chance Justification for channe ENHV0001, ENHV0006, Components were changed from An engineering evaluation determined that ENHV0007. ENHV0012, " passive" to " active" several containment spray valves have an active ENV0002, ENV0003, safety function in the closed direction. These ENV0004, ENV0008, components were already receiving the code '

ENV0009, and ENV0010 required testing for active components and therefore only needed to be administratively changed in the Inservice Test Program component list to be active.

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• g a e Revision 16 Summary of Changes to the IST Program Engineering evaluations have been performed for these changes and no Unreviewed Safety Question exists as a result of this revision. The following table explains all changes by component.

Components Affected Description of Chance Justification for chance PAL 01 A, PAL 0lB, and PALO2 Changed the test frequency of A recent change to the Technical Specifications the AFW pumps from monthly revised the periodicity from 31 days to 92 days to quarterly. Reference OL on a staggexd test basis. Changing the Amendment 108. frequency is in accordance with Technical Specifications and ASME/ ANSI OMa-1988 Pan 6, Section 5.1 PEF 01B, ABPV0002, Changed the drawing This is a clarification to more accurately reflect ABPV0003, ABHV0011, coordinates. the drawing coordinates. There are no changes ABHV0012, BB8948C, to the testing of the components. This change is BB8010A, BB80108, administrative.

BB8010C, BBHV8157B, BBV0474, BBV0476, BBV0479, BBV0480, BBV8001B, BBV8002B, BGV0605, ECV0083, ECV0084, EGHV0054, EJHV0025, EMHV8923 A, EPHV8950A, EPHV8950D, GSHV0004, HBHV7150, SJHV0018, SJHV0019, and SJHV0005 n/a Added a "SV" code for Solenoid "SV" was being used for solenoid valve in Valves to "VLV Type" in Revision 15 and needed to be defined. This is an Section 2.1. administrative change that does not affect valve testing.

ABHV00ll, ABHV0014, Corrected the Actuator Type The actuator type ns incorrectly identified.

ABHV0017, ABHV0020, from AO (Air Operated) to HO This is an administrative change that does not AEFV0039, AEFV0040, (Hydraulic Operated). affect va!ve testing.

AEFV0041, and AEFV0042 ALHV0005, ALHV0006, Changed the safety position This is a change to make this column consistent ALHV0007, AL.HV0008, from "C/O" to "O/C" with the rest of the IST program. This is an ALHV0009, ALHV0010, administrative change that does not affect vahe ALHV0011,and ALHV0012 testing.

ALHV0036, BB8378A, Revised the description to This is a change to make the description BB8379B, BGHV8112, components to match the consistent with the rest of the IST program. This 1 BNHV8813, EFHV0023, description in the Master is an administrative change that does not afTect I EFHV0024, EFHV0025, Equipment List. valve testing.

EFHV0026, EFHV0060, EGHV0060, EJ89698, EJFCV0611, EJHV8804B, EJHV881IB, EM8815, EMHV8801 A, EMHV8801B, i EMHV8803 A, EMHV8803B, EMHV8923 A, and EMHV8843 2

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Components Affected Descrintion of Change Justification for change ,

BBV0ll8, BBV0148, The listed valve size was changed The listed valve size was incorrect. This is an I BBV0178, BBV0208, in accordance with plant administrative change that does not affect valve

BBV0122, BBV0152, drawings. testing. )

i BBVO182, BBV0212, 1 ECV0095, ECV0096, EMHV8923 A, and EMHV8923B BGLCV0459 and BGLCV0460

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Added valves to the IST Program A recent evaluation determined that these and added a" COLD valves have an active safety function to close.

SHUTDOWN JUSTIFICATION" Adding these valves to the IST Program is a "BG-09" conservative change as it increases testing.

l BGV0605 and BGV0606 Corrected the description to This is a correction to a typographical error. I change "UPSTEAM" to This is an administrative change that does not l

" UPSTREAM" afTect valve testing.

BGV0645 Added to the IST Program. The IST program did not indicate that the valve was being tested. However, OSP-BG V001C tests this valve on a quarterly frequency (ST-04054) for closure. This is an administrative change that does not alTect valve testing.

BLilV8047 Changed "SO" to "AO" in the The actuator type was inconectly identified.

"ACF " column. This is an administrative change that does not i

affect valve testing.

i BMHV0019, BMHV0020, Added "FF/Q" to the " TEST The IST program did not indicate that the salve BMHV0021, and BMHV0022 PERF/FREQ." column. was being tested to fail closed. However, this testing was being performed on a quanctly basis in accordance with OSP-BM-V000l(ST-00061). This is an administrative change that does not affect valve testing.

ECHV0011 and ECHV0012 Changed the "VLV TYPE" The valve type was incorrectly identified. This column from "BT" to "BF". is a correction to a typographical error that does not affect valve testing.

EGHV0072, EGHV0073, Corrected an error in the "VLV The valve type was incorrectly identified. This EGHV0074, EGHV0075, and TYPE" column from "GT" to is a correction to a typographical error that does FCHV0312 "G B" not afTect valve testing.

EJHV0023, EJHV0024, Changed the valve function to The safety classification, test performed, EJHV0025, and EJHV0026 " PASSIVE", The following frequency and valve type for these valves were changes to Tests Performed and incorrect. This is an administrative change that frequency were made: Deleted does not affect valve testing.

"FS/Q" and added "LJ/RF" for components EJHV0023 and EJHV0025, and added "PI/RF" to EJHV0024 and EJHV0026.

Changed Valve Type from "GB" to "GT" for EJHV0023, EJHV0024 and EJHV0025.

(Note: Tests Perf/Freq was subsequently revised again in Revision 17.)

EJHV8701A A "/" was placed between "LT This is a correction to a typographical error.

RF" located in the " TESTS This is an administrative change that does not PERF/FREQ" column. affect valve testing.

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Components Affected Descrintion of Chance Justification for chance EMHV8801A Changed the valve category The valve Category was incorrectly identified.

from "A,C" to "B" The correct category is "B" This is an administrative change that does not affect valve testing. Correct testing was performed.

GTHZ0004, GTHZ0005, Corrected the Actuator Type The Actuator Type was incorrectly identified.

GTHZ0006, GTHZ0007, from "SO"(Solenoid Operated) This is an administrative change that does not GTHZ0008, GTHZ0009, to "AO" (Air Operated). affect valve testing GTHZ0010, GTHZO0ll, and GTHZ0012 GTHZ0006, GTHZ0007, Changed the " Active or Passive" The fields were simplified to make them easier to GTHZ0008, and GTHZ0009 field and added Note 1. understand. This is an administrative change that does not affect valve testing.

JEV0086 Changed "SFTY POS" from "0" This was a typographical error. The capital (zero) to "O", letter 'O' is the correct entry C r this field. This is a correction that does not afTect valve testing.

KBV0001 and KBV0002 Added to the IST Program. These are passive containment isolation valves and have been tested by procedure OSP-KB-LLO98. This change is administrative and does not affect valve testing.

KCHV0253 Added "PI/RF" to the " TESTS The Tests Performed list was incomplete. The PERF/FREQ." column. fNote: Leak Test and Position Indication Test are being Tests Perf/Freq was performed on a refueling frequency by procedure subsequently revised again in OSP-KC-LLO67. This is an administrative Revision 17.) change that does not affect valve testing.

LFHV0105, LFHV0106, and Changed "G A" to "GT" in the These were typographical errors This is an LFFV0095 "VLV TYPE" column. administrative change that does not affect valve testing.

LFFV0096, SJHV0005, Changed "GL" to "GB" in the These were typographical errors. This is an SJHV0006, SJHV0127, "VLV TYPE" column. administrative change that does not afTect valve SJHV0128, SJHV0129, testing.

SJHV0130, SJHV0131, and SJHV0132 n/a Revised the labeling format of This is only a clarification to make the IST Relief Requests / Cold Shutdown Program document more consistent. This is an Justifications / Refueling administrative change that does not affect valve Justifications to make them testing.

administratively consistent.

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Revision 17 Summary of Channes to the IST Program Engineering evaluations have been perfonned for these changes and no Unreviewed Safety Question exists as a result of this revision. The following table explains all changes by component.

Components Affected Description of Change Justification for change J n/a Sectica 2.1, page 2, the codes These codes are more consistent by indicating the "2" (for 2 years) and "J" (for required test frequency rather than indicating the Appendix J frequencies) were actual test frequency. This is an administrative added for frequency. clarification.- i n/a Section 2.2, Column " TESTS This was modified to support the changes above.

PERF/FREQ.", changed all This is an administrative change to be consistent l

l Position Indications to "PI/2" with allowed Code specified frequencies.

and changed all Appendix J leak rate valve tests to "LJ/J" BBV0ll8, BBV0148, Valves were changed from an An engineering evaluation determined that these BBV0178 and BBV0208 " Active" closed Safety Position valves have a passive open safety function.

to a " Passive" open Safety 1 Position and removed the l "FS/RF" test requirement.

BGV0135, KAV0039, Added "C" for the "VLV CAT." Even though these valves are passive. the passive KAV0648, KAV0649, check valves will be identified as categon 'C'. This KAV0650, KAV0651, and is an administrative change. This has no impact to KCV0478 the testing of the valves.

n/a Revised the " CATEGORY" This is an administrative change. This has no l I

section of Refuel Justification impact on the testing of the valves.

BB-04, Refuel Justification EM-03, and Cold Shutdown Justification BG-06 to reflect the Valve Category in the corresponding table.

EGLV0001 and EGLV0002 Added to the IST program. An engineering evaluation determined that these valves have a passive safety function in the closed position. Therefore, a position indication test is required. Adding these valves to the IST Program is a conservative change as it adds more testing EGHV0058, EGHV0059, Valves safety position were An engineering evaluation determined that these EGHV0060, EGHV0061, changed from "O/C" to "C" valves only hase the actise function to close.

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i ao t e Revisinn 18 Summary of Changes to the IST Program 4

Engineering evaluations have been performed for these changes and no Unreviewed Safety Question exists as a result of this revision. The following table explains all changes by component.

1 Components Affected Description of Change Justification for chance ABV0085; ABV0087 The safety position of these These valves are normally locked in the open components was revised from position in order to ensure steam supplier are "O/C" to "C", available for the TDAFP. In the event of a SGTR ,

these valves must be closed to stop ofTsite release paths. As these are manual isolation valves without remote position indication there are no testing requirements in the open (passive) position. Thus.

, the safety function column for these valves has been changed to "C"(active position). Verification that these valves can be closed will continue to be done

during refueling outages as stated in Refueling

Justification AB-03.

BGV0135 Changed the SFTY POS column This component has been determined to have an

, from "C" to "O/C" Added active safety function in the partial open position in l "PS/RF" to the TEST PERF/FREQ order for it to relieve pressure between j column. Changed the active or BGHV8100/8112 in the event they become isolated passive column to add " ACTIVE" and pressure between these containment isolation Added BG02 to the RR OR TST valves increases. In the normally closed position I DEF JUST column. this valve serves a passive function for containment isolation. Per Table 1 of OM 10 this valve requires i valve seat leak rate testing (Category A passive i

valve test per parag aph 4.2.2) and exercise testing (Categog C active check valve per OM-10 paragraph 4.3.2). Refueling Justification BG-02 was revised to test the open function of this valve on a extended test frequency. Since this valve does not i have remote position indication it does not require l position indication testing per OM 10 paragraph l 4.1. l BN8717 This valve has beesi added to the This valve prevents RHR inventory from being l

IST program as a passive diverted back to the RWST. During Modes 1,2,3,4 component with remote position this valve is maintained locked closed (padlocked).

indication. During Modes 5 and 6 this valve can be opened for refueling pool inventory changes. Due to the safet) l significance of this flowpath, this valve has been provided with ESFAS status panel indication j (remote position indication). Per OM 10 Table 1 Category B passive valves require position indication testing per paragraph 4.1.

BNV00ll This valve has been added to the This component is the RWST isolation salve. The )

IST program as a passive RWST is the borated water supply to support ECCS component with remote position injection. This valve ensures the ECCS pumps hase indication. a suction flowpath from the RWST. Due to the safety significance of this flowpath, this salve has been provided with ESFAS status panel indication (remote position indication). Per OM-10 Table 1 Category B passive valves require position indication testing per paragraph 4.1.

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Comnonents Affected Descrintion of Chance Justincation for change EGHV0071 & These valves have been added to EGHV0071 and '26 are isolation valves in the EGHV0126 the IST program as passive CCW flowpath to the containment CCW loads.

components with remote position EGHV0071 is normally maintained in the open indication. position as part of the primary CCW flowpath to containment. EGHVol26 is an isolation valve m the bypass line around EGHV0071. EGHVol26 can be opened to maintain CCW flow to containment in the event EGHV0071 is closed. These vahes are considered passive components. Per OM 10 Table I i Category B passive valves require position l indication testing per paragraph 4.1.

EJFCV0618 & These valves have been added to These components are isolation valves on the RHR EJFCV0619 the IST program as passive heat exc' inger bypass line. During the normal components with remote position ECCS lineup these valves are maintained in the indication. closed position. This ensmes that RHR flow is directed through the RHR heat exchanger for maximum RCS cooling for the recirculation phase of RHR operation. These valves are only taken out ,

l of the closed position for testing or RHR flow / temperature control during cold shutdown or l refueling outages. These valves are considered passive components. Per OM-10. Table 1, Category B passive valves require position indication testmg j per paragraph 4.1.

EJHCV0606 & These valves have been added to These components are isolation vahes on the outlet EJHCV0607 the IST program as passive of the RHR heat exchangers. During the normal components with remote position ECCS lineup these valves are maintained in the indication. open position to ensure RHR injection flow to the RCS following a large break LOCA. These sahes are only taken out of the full open posmon for testing or RHR llow/ temperature control during cold shutdown or refueling outages These valves are considered passive components. Per OM-10. Table 1, Category B passive valves require position indication testing per paragraph 4.1.

EJHV0014 & EJHV0015 These valves have been added to These components can be opened to direct a portion the IST program as passive of RHR flow to the nuclear sampling system for components with remote position testing. These valves are assumed closed during all indication. other modes of operation for RHR. These valves are considered passive. Per OM-lo. Table 1. Category B passive valves require position indication testing per paragraph 4.1.

EMHV8889A,B,C,& D These valves have been added to These components are isolation valves in the SIS the IST program as passive test header. They are typically maintained in the components with remote position closed position with air isolated to preclude indication. inadvertent opening . They are normally only opened for RCS pressure isolation leak rate testmg (BB8949A.B,C &D). These vahes are mstalled at a seismic boundary which will ensure that the assumed SI pump flow is directed to the RCS in the event of a line break downstream of these vahes These sahes are considered passh e Per OM In.

Table 1, Category B passive valves require position indication testing per paragraph 41.

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Comnonents Affected Descrintion of Change Justification for change EMHV8924 This valve has been added to EMHV8924 is an isolation valve between the RHR the IST program as passive pumps and SIP /CCP's. This flowpath is used when it component with remote becomes necessary to supply the suction of the CCP's position indication. and SIP's from RHR. Isolation of this valve while in Moder 1,2,3 places the plant in Technical Specification 3.03. Ne to the safety significance of this flawpath the valve handw heel is locked in the open position with the associated supply breaker locked in the open position.

This valve is considered passive. Per OM-10, Table 1.

Category B passive valves require position indication testing per paragraph 4.1.

EMV0006 The ACTIVE or PASSIVE This check valve is a containment isolation valve in the classification for this valve SI Accumulator fill line. Although this penetration is was changed to " ACTIVE" typically isolated by EMHV8888, it is being considered In addition, "FS/RF" was an active valve since this flowpath is routinely used added to the TESTS during normal plant operation. Justification EM-08 was PERF/FREQ column along developed to extend the required testing to refueling with refuelingjustification outages. As an active Category A.C check vahe OM-lu EM-08. This change was requires a leak test per paragraph 4.2.2 and an exercise identified while reviewing test per paragraphs 4.2. I and 4 3.2. Since this valve is changes to EPV0046 which is not equipped with remote position indication n is exempt a similar valve. from position indication test requirements.

EMHV8882 This valve has been added to EMHV8882 is an isolation valve in the SIS test header.

the IST program as a passive it is typically maintained in the closed position.

component with remote EMHV8882 is normally only opened for RCS pressure position indication. isolation leak rate testing (BBV0001,22,40 & $9).

EMHV8882 is installed at a seismic boundary which will ensure that the assumed high head injection flow is directed to the RCS in the event of a line break downstream of this valve. EMHV8882 is considered passive. Per OM 10, Table 1 Category B passne sahes require position indication testing per paragraph 41 EPHV8808A/D Revised the TESTS This change is in accordance with RFR 17044 A.

PERF/FREQ. and SFTY POS EPHV8808A/D are normally open valves with elecincal columns such that testing in power removed. These sah es hase a safety position in the open direction is indicated the open direction (passive function) These valves still as a PASSIVE function. have a safety function in the closed direction-EPHV8808A/D will require position indication testing m both directiens but will only requ e ntroke time testmg in the closed direction.

EPHV8875A,B,C & D These valves have been added These components are isolation salves in the nitrogen EPHV8878A,B,C & D to the IST program as passive supply lines and borated water supply lines to the S1 components with remote Accumulators. These vahes are opened mtermittently position indication. during normal plant operation to adjust the SI Accumulators level and/or pressure. Typically these valves are maintained closed. Since these valves are e!'a located at scismic boundaries they arc assumed to maintain SI Accumulator operability in the esent of a liac break upstream of these valves. These valves are considered passive Per OM-10, Table I, Category B )

passive valves require position indication testing per paragraph 4.1.

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Components Affected Description of Change Justification for change

. EPHV8877A,B,C & D These valves have been added to These components are isolation valves in the SIS j theist program as passive test header. They are typically maintained in the components with remote position closed position and only opened for RCS pressure indication. isolation valve leak rate testing (EP8956A,B,C &

! D). These valves are also installed at a seismic i boundary which will ensure St Accumulator inventory is directed to the RCS in the event of a j line break downstream of these valves. These t components are considered passive. Per OM-10.

Table 1, Category B passive valves require position i indication testing per paragraph 4.1.

EPHV8879A,B,C & D These valves have been added to These components are isolation valves in the SIS the IST program as a passive test header. They are typically maintained in the j j component with remote position closed position with supply air isolated and are only )

j indication. opened following outages for RCS pressure isolation l

! valve leak rate testing (BB8948A.B.C & D). These i i

valves are also installed at a seismic boundary w hich j will ensure SI Accumulator /ECCS inventory is i

! directed to the RCS in the event of a line break j- downstream of these valves. These components are 4

considered passive. Per OM-10, Table 1. Category i B passive valves require position indication testing per paragraph 4.1. j EPV0046 The ACTIVE or PASSIVE This check valve is a containment isolation valve m l classification for this valve was the nitrogen supply line. Although this penetration  ;

changed to" ACTIVE" In is typically isolated by EPHV8880, it is considered I addition,"FS/RF" was added to an active valve since this flowpath is routinely used the TESTS PERF/FREQ column during normal plant operation. Justification EP-06 along with refuelingjustification was developed to extend the required testing to EP-06. refueling outages. As an active Category A C check valve, OM 10 requires a leak test per paragraph 4.2.2 and an exercise test per paragraphs 4.2.1 and 4.3.2. Since this valve is not equipped with remote position indication it is exempt from position indication test requirements.

GSHV0030 & GSHV0035 Valves were added to the IST These valves are required to open to allow samphng program as active Category B of containment atmosphere post accident. These valves. valves are also required to maintain the mlegnty of the hydrogen analyz.crs sample lines by isolauon of tlie non seismic piping downstream. Per OM-10 Category B active valves are subject to quaner13 exercise testing per paragraph 4.2.1 and position indication testing per paragraph 4.1 every 2 years These valves are considered to have open and closed active safety functions 9

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