U-604326, Third Ten-Year Interval Inservice Testing Program Plan Revision 7

Third Ten-Year Interval Inservice Testing Program Plan Revision 7

ML17069A173
Person / Time
Site:	Clinton
Issue date:	03/08/2017
From:	Stoner T Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
U-604326
Download: ML17069A173 (252)

Text

,.:Ti, Clinton Power Station 8401 Power Road Clinton, IL 61727

~* Exelon Ge:neration U-604326 10 CFR 50.55a March 8, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Clinton Power Station Third Ten-Year Interval lnservice Testing Program Plan Revision 7 In accordance with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Subsection ISTA-3200(a),

"Administrative Requirements," attached for your information is a copy of Revision 7 of the lnservice Testing (IST) Program for the third ten-year interval. The third ten-year interval IST Program Plan complies with the requirements of the ASME OM Code 2004 Edition. The third ten-year interval began on July 1, 201 O and concludes on June 30, 2020.

There are no regulatory commitments contained within this letter.

If you have any questions or require additional information, please contact Mr. Dale Shelton, Regulatory Assurance Manager, at (217) 937-2800.

Sincerely, Theodore R. Stoner Site Vice President Clinton Power Station DRA/cas cc: Regional Administrator, Region Ill, USNRC Senior Resident Inspector, Clinton Power Station, USNRC NRR Project Manager, Clinton Power Station, USNRC

___::-__-_*~:~"!'---.::' -

• ___ --=~-- *_:: -*=-**

Facility : CPS Doc Nbr : IST THIRD TEN, YEAR PLAN Sheet Maj Rev : 007 Min Rev Doc Date : 2016-11-17 SRRS ID : 18.100 Title  : THIRD TEN YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN Doc Type : PROC Sub Type : NEP Addi Type:

R Obj ID : 0900e54e81 dc4d02 This Record Cover Sheet data is an aid for initial department handling and records turnover purposes.

The data shown may not reflect the Records Index system data due to further editing and refinement by Records Management.

Exelon Generation Company 4300 Winfield Road Warrenville, IL 60555 Clinton Power Station Unit 1 Docket Number 50-461 8401 Power Road Clinton, II. 61727 April 24, 1987 lnservice Testing (IST) Program Program Plan 3rd Ten-Year Interval 07/01/10- 06/30/20 Revision 7 10/21/2016

REVISION RECORD Effective Revision Description Sign & Date Date Prepared: Reviewed: Approved; Site IST Corporate Engr.

IST Programs Engineer Manaqer Engineer 0912112010 Revision 1 Ted Danley John Dore Steve Clary

• Revised Attachment 16 by replacing the test table for the Reactor Core Isolation Cooling System. This change was made to update the table forvalves 1E51-F061and1E51-F062 to reflect the change in testing requirements resulting from implementation of CMP-13 and CMP-14, respectively.

• Revised CSJ-116 in Attachment 5 to remove valves 1PS043A and 1PS043B from the valve listinq at the too of the oaQe.

0512412011 Revision 2 Ted Danley John Dore Gary

• Revised Attachment 16 to add vacuum Mosley breakers 1SX350A/B that were installed by ECs 369622 and 369868.

• Revised Attachment 16 to show the test frequency for 1C41-F001 A/Band 1E12-F064A/B from Y2 to 3M due to their risk ranking being changed from low to medium in Rev. 12 of NSED Standard MS-07.00, MOV Periodic Verification Program Scope.

• Revised the format for Attachment 14.

Removed Deferral Just. Heading because it is not applicable to pumps. Removed information regarding physical location of the pumps to allow a better presentation of the information and the location information is not required.

• Made non-technical changes identified in ATls 01163088-02, 01011851-26 and 01011851-27. Corrected format, typographical errors, replace non-standard/defined acronyms with standard/defined acronyms. This revision did not change any of the testing requirements for any of the components in the IST Program. Due to the extent of the changes, no revision bars were used.

0511112012 Revision 3 (Editorial) Tom N/A Shane

• Revised CSJ-117 to clarify a packing leak Parrent Mohundro "that requires immediate repair were to occur" in basis for justification for not exercising valves 1B21-F016 and 1821-F019 quarterly(IR 01343842)

• Made non-technical change identified in IR 1132711-12 to add title to Attachment 11:

Revision 7 10/21/2016

"Corcorate Technical Position*

Effective Revision Description Sian & Date Date Prepared: Reviewed: Approved; SitelST Corporate Erigr.

JST Programs Engineer Manaaer Enalneer 05/08/2073 Revision 4 Fred Marcellus Shane (This Is a major revision therefore no rev bars were Sarantakos Ruff Mohundro used)

• Enhancement to Weaknesses In Descriptions and References In CSJs par AR 1343842*03 0 Remowd 1E51*F046and1SX209 from program per ECs 390555 and 392017.

• Added 1SX350AIB to CMP-15 *

• Enhanced the Program Plan to follow the standard template format per AR 1404141*

02.

• Fixed typo In CSJ-107 rel erring to OM-10

.. per AR 1451486-02.

Revise CSJ-114 to an RFJ based on AR 1385038*16.

• Enhance CSJ-115 per AA 1385038-17*

• Enhance CSJ-116 per AR 1385038*18*

• Enhance AFJ-001 oer AA 1385038*19.

6127/2014 Revision 5 Fred Marcellus ,.Christian

• Created CSJ*118for1SX346A/B* Sarantakos Ruff Small 21812016 Revision 6 {editorial) Fred NA Greg Boyd

• Cleaned up lnfonnation contained on the Sarantakos cover caoe.

10/2112016 Revision7 Fred Marcallus Mark

• *Sarantakos r;t ---

Added Renet requests 2203 and 2204 Ruz J.i~ ij( v--,,., lb ~I) .

~~

.lo/lJ/I&.. I\\10\ I lJ ":it;'7{U, Revision 7 10/21/2016

TABLE OF CONTENTS SECTION 1.0

• INTRODUCTION 1.1 Purpose 1.2 Scope 1.3 Discussion 1.4 References 2.0 INSERVICE TESTING PLAN FOR PUMPS 2.1 Pump lnservice Testing Plan 2.2 IST Plan Pump Table Description 3.0 INSERVICE TESTING PLAN FOR VALVES 3.1 Valve lnservice Testing Plan 3.2 IST Plan Valve Table Description 4.0 ATTACHMENTS

1. System Listing

2. Pump Relief Request Index

3. Pump Relief Requests

4. *

• Valve Relief Request Index

5. Valve Relief Requests

6. Relief Request RAls and SER

7. Code Case Index

8. Cold Shutdown Justification Index

9. Cold Shutdown Justifications

10. Refueling Outage Justification Index

11. Refueling Outage Justifications

12. CorporateTechnical Position Index

13. Corporate Technical Positions

14. lnservice Testing Pump Table with P&IO

15. lnservice Testing Valve Table with P&ID

16. Check Valve Condition Monitoring Plan Index Revision 7 10/21/2016

1.0 INTRODUCTION

1.1 Puroose The purpose of this lnservice Testing (IST) Program Plan is to provide a summary description of the Clinton IST Program in order to document its compliance with the requirements of 10 CFR 50.55a(f) for the 3rd 10-year IST interval and to provide requirements for the performance and administration of assessing the operational readiness of those pumps and valves with specific functions that are required to:

• Shutdown the reactor to the safe shutdown condition,

• Maintain the safe shutdown condition, or

• Mitigate the consequences of an accident.

1.2 Scope This lnservice Testing Program Plan identifies all of the testing performed on the components included in the Clinton Power Station (CPS) Unit 1 lnservice Testing (IST) Program for the 3rd ten-year IST interval, which began on July 1, 2010 and is scheduled to end on June 30, 2020.

The Code of Federal Regulations, 10 CFR 50.55a(f)(4), requires that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves which are classified as ASME Code Class 1, Class 2, and Class 3 must meet the inservice test requirements set forth in the ASME OM Code and addenda that are incorporated by reference in paragraph 10 CFR 50.55a(b)(3) for the initial and each subsequent 120-month interval.

Based on the start date identified above, the IST Program for the 3rd ten-year interval is required by 10 CFR 50.55a(f)(4)(ii) to comply with the requirements of the ASME OM Code-2004 no addenda Code for Operation and Maintenance of Nuclear Power Plants, except where relief from such requirements has been granted in writing by the NRC.

The scope of the OM Code is defined in paragraph ISTA-1100 as applying to:

(a) pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident; (b) pressure relief devices that protect systems or portions of systems that perform on or more of the functions listed in (a), above; and (c) dynamic restraints (snubbers) used in systems that perform one or more of the functions listed in (a).

NOTE: This IST Program Plan addresses only those components included in (a) and (b) above. Dynamic restraints (snubbers) are addressed in a separate test program.

In order to determine the scope of the IST Program at CPS, an extensive scope evaluation was performed. This scope evaluation determined all of the functions required to be performed by all ASME Class 1, 2 and 3 systems in shutting down the reactor to the safe shutdown condition, in maintaining the safe shutdown condition or in mitigating the consequences of an accident. The determination of those functions Revision 7 10/21/2016

was accomplished by a thorough review of licensing bases documents such as the UFSAR/FSAR, Plant Technical Specifica,tions and Technical Specification Bases documents, etc. Next, a component-by-component review was performed to determine what function each pump and valve in the system was required to perform in order to support the safety function(s) of the system or subsystem. The results of these efforts are documented in the Station's IST Bases Document. In addition to a description of each component's safety function(s), the Bases Document identifies the tests and examinations that are performed on each component to provide assurance that they will be operationally ready to perform those safety function(s).

The Bases Document identifies those ASME Class 1, 2, and 3 pumps and valves that are in the scope of the IST Program, including those that do and those that do not have required testing. It also identifies those ASME Class 1, 2 and 3 pumps and valves that are outside the scope of the IST Program on the basis that they are not required to perform any specific safety function.

As stated at the beginning of this Section, the scope of this IST Program Plan is to identify all of the testing performed on those components within the scope of the IST Program. This is accomplished primarily by means of the IST Pump and IST Valve Tables contained in Attachments 14 and 15. The remaining Sections and Attachments of this document provide support information to that contained in the Tables. Components that do not require testing are not included in the IST Program Plan document.

In addition to those components that are required to perform specific safety function(s), the scope evaluation often determines that there are also ASME Safety Class 1, 2 and 3 components that are not required to perform a licensing-based safety function but which, nonetheless, may be relied upon to operate to perform a function with some significance to safety. It may also identify non-ASME Safety Class pumps or valves that have a safety function or may be relied upon to operate to perform a function with some significance to safety. None of these components are required by 10 CFR 50.55a to be included in the IST Program. However, such components may require testing in a manner which demonstrates their ability to perform their functions commensurate with their importance to safety per the applicable portions of 10 CFR 50, Appendix A or B. One option is to include pumps or valves that fit these conditions in the IST Program as augmented components.

CPS is licensed with cold shutdown as the safe shutdown condition. Therefore, the scope of the IST Program must include, as a minimum, all of those ASME Class 1, 2, and 3 pumps and valves which are required to shut down the Reactor to the cold shutdown condition, maintain the cold shutdown condition, or mitigate the consequences of an accident.

1.3 Discussion A summary listing of all the pumps and valves that are tested -in accordance with the IST Program is provided in the IST Pump and IST Valve Tables contained in Attachments 14 and 15. The Pump and Valve Tables also identify each test that is performed on each component, the frequency at which the test is performed, and any Relief Request or Technical Position applicable to the test. For valves, the Valve Table also identifies any Cold Shutdown Justification or Refueling Outage Revision 7 10/21/2016

Justification that is applicable to the required exercise tests. Additional information is provided for both pumps and valves. All of the data fields included in the IST Pump and Valve Tables are listed and described in Sections 2 and 3 of this document.

Following Sections 2 and 3 are several Attachments which provide information referenced in the Pump and Valve Tables. includes a system listing. provides an index of the Pump Relief Requests that apply to any of the pumps in the IST Program for this ten-year interval. includes a copy of each of those Relief Requests. provides an index of the Valve Relief Requests that apply to any of the valves in the IST Program for this ten-year interval. includes a copy of each of those Relief Requests. contains the Safety Evaluation Report(s) (SER) that document approval of the Relief Requests contained in Attachments 3 and 5. It also includes Requests for Additional Information .(RAls) received from the NRC regarding the Relief Requests and the responses provided by Exelon. includes a list of the ASME OM Code Cases that are being invoked for this ten-year interval. provides an index of Cold Shutdown Justifications that apply to the exercise testing of any valves in the IST Program for this ten-year interval. includes a copy of each of those Cold Shutdown Justifications. O provides an index of Refueling Outage Justifications that apply to the exercise testing of any valves in the IST Program for this ten-year interval .. 1 includes a copy of each of those Refueling Outage Justifications. 2 provides an index of Technical Positions that apply to the IST Program for this ten-year interval. Technical Positions provide detailed information regarding how Exelon satisfies certain ASME OM Code requirements, particularly when the Code requirement may be ambiguous or when multiple options for implementation may be available. Technical Positions do not take exception t<;> or provide alternatives to Code requirements. 3 includes a copy of each Technical Position listed in Attachment 12.

As described previously, Attachments 14 and 15 include the IST Pump and Valve Tables with their listed P&IDs.

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Attachment 16 provides a listing of Check Valve Condition Monitoring (CVCM)

Program Plans. These plans are maintained in their own controlled document.

This IST Program Plan is a quality-related document and is controlled and maintained in accordance with approved Exelon Corporate Engineering and Records Management procedures.

1.4 References 1.4. 1 Title 10, Code of Federal Regulations, Part 50, Section 55a (10 CFR 50.55a) 1.4.2 ASME OM Code-2004 no addenda Code for Operation and Maintenance of Nuclear Power Plant Components.

1.4.3 Clinton Technical Specification 1.4.4 Exelon Corporation Administrative Procedure ER-AA-321, Administrative Requirements for lnservice Testing 2.0 INSERVICE TESTING PLAN FOR PUMPS 2.1 Pump lnservice Testing Plan The lnservice Test (IST) Program for pumps at Clinton Power Station (CPS), Unit 1, is based on the following: *

• American Society of Mechanical Engineers (ASME) OM Code-2004 Edition no addenda, Code for Operation and Maintenance of Nuclear Plants. 11 11

• Generic Letter No. 89-04, Guidance on Developing Acceptable lnservice Testing Programs 11

• NUREG-1482, Revision 1, 11 Guidelines for lnservice Testing at Nuclear Power Plants" The pumps included in this program are all ASME Class 1, 2 or 3 pumps provided with an emergency power source that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an* accident.

This program plan documents compliance with the requirements of OM Code Subsection ISTB with the exception of specific relief requests contained in Attachment 3.

The hydraulic circuit and location/type of measurement for the required test parameters are specified in station procedures per the requirements of ISTB-9200.

2.2 IST Plan Pump Table Description The pumps included in the CPS lnservice Testing Program are listed in Attachment

14. The information contained in that table identifies those pumps required to be tested to the requirements of the ASME OM Code, the parameters measured, associated Relief Requests and comments, and other applicable information. The Revision 7 10/21/2016

column headings for the Pump Table are listed below with an explanation of the content of each column.

OM Group A Pumps The ASME OM Code defines Group A pumps as those pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations. CPS considers the following Unit 1 pumps as being categorized as Group A:

• Residual Heat Removal (RHR) Pumps A and B

• Control Room HVAC Chilled Water Pumps A and B

• RHR Loop B/C Water Leg Pump

• LPCS and RHR Loop A Water Leg Pump

• HPCS Water Leg Pump

• RCIC Water Leg Pump

• Fuel Pool Cooling Pumps A and B

• Diesel Fuel Oil Transfer Pumps OM Group B Pumps The ASME OM Code defines Group B pumps as those pumps in standby systems that are not operated routinely except for testing. CPS considers the following pumps as being categorized as Group B:

• Residual Heat Removal (RHR) Pump C

• Low Pressure Core Spray (LPCS) Pump

• High Pressure Core Spray (HPCS) Pump

• Standby Liquid Control (SLC) Pumps A and B

• Reactor Core .Isolation Cooling (RCIC) Pump

• Shutdown Service Water Pumps A, B, and C The pumps included in the Clinton Nuclear Power Station IST Plan are listed in 4. The information contained in these tables identifies those pumps required to be tested to the requirements of the OM Code, the testing parameters and frequency of testing, and associated relief requests and remarks. The headings on the pump tables in Attachment 14 are described below. Note not all abbreviations line up directly with the ones found in the ER-AA-321-1002.

Pump EIN The unique identification number for the pump, as designated on the System P&ID or Flow Diagram Description The descriptive name for the pump.

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The ASME Safety Class (i.e., 1, 2 or 3) of the pump. Non-ASME Safety Class pumps are designated "N/A".

The Piping and Instrumentation Diagram or Flow Drawing on which the pump is shown P&ID Coor. The P&ID Coordinate location of the pump.

Pump Type An abbreviation used to designate the type of pump:

C Centrifugal PD Positive Displacement VLS Vertical Line Shaft Driver The type of driver with which the pump is equipped.

A Air-motor D Diesel M Motor (electric)

T Turbine (steam)

Nominal Speed The nominal speed of the pump in revolutions per minute.

Group A or B, as defined in Reference 1.4.2.

Test Type Lists if the pump has a Group A, B, or Comprehensive test.

Lists of each of the test parameters which are required to be measured for pumps. These include:

N Speed (for variable speed pumps, only)

DP Differential Pressure PD Discharge Pressure (positive displacement pumps)

Q Flow Rate V Vibration An abbreviation which designates the frequency at which the associated test is performed:

M3 Quarterly (92 Days)

Y2 Once every 2 years NOTE: All tests are performed at the frequencies specified by Code unless specifically documented by a Relief Request.

Relief Request Identifies the number of the Relief Request applicable to the specified test.

Deferred Just. Provides the deferral justification identification number Revision 7 10/21/2016

applicable to the pump or test.

Tech Pas Provides the Technical Position identification number applicable to the pump or test.

Comments Any appropriate reference or explanatory information (e.g.,

technical positions, etc.)

3.0 INSERVICE TESTING PLAN FOR VALVES 3.1 Valve lnservice Testing Plan The lnservice Test (IST) Program for valves at Clinton Power Station (CPS), Unit 1, is based on the following:

• American Society of Mechanical Engineers (ASME) OM Code-2004 Edition, Code for Operation and Maintenance. of Nuclear Plants."

• Generic Letter No. 89-04, "Guidance on Developing Acceptable lnservice Testing Programs"

• NUREG-1482, Revision 1, "Guidelines for lnservice Testing at Nuclear Power Plants"

• Implementation of ASME OM Code Case OMN-1 in accordance with applicabie Corrective Maintenance Procedures (CMPs). (See Valve Relief Request No.

2201)

The valves included in this program are all ASME Class 1, 2 or 3 required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident. The pressure-relief devices covered are those for protecting systems or portions of systems which perform one or more of the three aforementioned functions at CPS. Exemptions are listed in ISTC-1200.

This plan identifies the test intervals and parameters to be measured, and documents compliance with the requirements of ISTA and ISTC with the exception of the specific relief requests contained in Attachment 5.

Where quarterly frequency requirements for valve testing have been determined to be impracticable, Cold Shutdown or Refuel Outage Justifications have been identified and written. These justifications are provided in Attachments 9 and 11 respectively.

Manual Valves Although ISTC-3540 permits manual valves to be full-stroke exercised at least once *every 5 years; pursuant to 10 CFR 50.55a(b)(3)(vi), manual valves within the Revision 7 10/21/2016

IST program scope that perform an active safety function shall be exercised through a complete cycle at least once every 2 years. Exercise testing shall be considered acceptable if valve stem travel exhibits unrestricted movement with no abnormal resistance or binding through one complete cycle. Where practical, process parameters may be utilized to verify obturator movement. However, where process parameters are utilized to verify obturator movement it is not necessary to be performed simultaneous to manual exercising. This testing methodology is consistent with the discussion provided in NUREG-1482, Revision 1, Section 4.4.4.

If a valve fails to exhibit the required change of obturator position, the valve shall immediately be declared inoperable ..

The use of a valve persuader (cheater) for additional mechanical advantage will not invalidate the test, as it is recognized that larger valves may exhibit increased packing friction and/or increased friction associated with the disk to seat interface.

In addition, a valve persuader may be used for personnel safety depending on a valve's service application (i.e. main steam).

AOVValves Typically,* AOVs have solenoid valves that control the flow of air to the air operator.

These solenoid valves are considered skid mounted. They are exercised when the AOV is exercised.

Check Valves ASME OM Code-2004 no addenda requires each check valve to be exercise tested in both the open and closed directions regardless of their safety function.

Additionally, periodic partial stroke exercising is no longer a Code requirement.

Category C check valves shall be exercised nominally every 3 months, except as provided by ISTC-3522 and ISTC-5221. During operation at power, each check valve shall be exercised or examined in a manner that verifies obturator travel by using the methods in ISTC-5221. Each check valve exercise test shall include an open and closed test. Open and closed tests need only be performed at an interval when it is practicable to perform both tests. Test order (e.g. whether the open test precedes the closed test) shall be determined by CPS.

CPS check valve surveillance testing will be in accordance with the following interpretation: (1) if a check valve can be tested in both directions at the same frequency, then that is the required frequency (e.g., if the valve can be tested in both the open and closed directions on a quarterly frequency, then the Code-required frequency for bidirectional testing is quarterly, (2) if a check valve is not able to be tested in both directions at the same frequency, then the Code-required frequency is the less frequent of the two frequencies (e.g., if a valve can be tested in the open direction quarterly but can only be tested in the closed direction on a refueling outage frequency, then the Code-required frequency for bidirectional testing is the refueling outage frequency).

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Credit can only be taken for a check valve exercise test when it can be tested in both directions. Therefore, the testing frequency is not dependent on safety vs. non-safety direction Revision 7 10/21/2016

Check Valve Condition Monitoring As an alternative to the requirements of paragraphs ISTC-3510, ISTC-3520, ISTC-3530, ISTC-3550, and ISTC-5221, CPS-1 may establish a Check Valve Condition Monitoring (CVCM) Program per ISTC-5222. The purpose of this program is to both (a) improve check valve performance and to (b) optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable performance of a select group of check valves. CPS may implement this program on a valve or a group of similar valves basis.

• Examples of candidates for (a) improved valve performance and (b) optimization of testing, examination, and preventive maintenance activities are provided in footnotes to ISTC-5222.

The CVCM program shall be implemented in accordance with Appendix II, "Check Valve Condition Monitoring Program", of OM-2004. An administrative procedure and site implementing procedures will perform the specified tests identified in the individual Check Valve Condition Monitoring (CVCM) Program Plans.

If the Appendix II CVCM Program for a valve or group of valves is discontinued then the requirements of ISTC-3510, ISTC-3520, ISTC-3530, ISTC-3550, and ISTC-5221 shall apply.

3.2 IST Plan Valve Table Description The valves included in the Clinton Nuclear Station lnservice Testing Program are listed in Attachment 15. The information contained in that table identifies those valves required to be tested to the requirements of the ASME OM Code, the testing methods and frequency of testing, associated Relief Requests, comments, and other applicable information. The column headings for the Valve Table are delineated below with an explanation of the content of each column. Note not all abbreviations line up directly with the ones found in the ER-AA-321-1002.

Valve EIN A unique identifier for the valve. Each EIN is preceded with a Unit designator for the valve:

0 Common Unit 1 Unit 1

• 2 Unit 2 Description The descriptive name for the valve [use PIMS, Passport, etc. names for consistency].

The nominal size of the valve in inches.

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Valve Type An abbreviation used to designate the body style of the valve:

3W 3-Way 4W 4-Way BAL Ball BTF Butterfly CK Check DIA Diaphragm GA Gate GL Globe PLG Plug RPD Rupture Disk RV Relief SCK Stop-Check SHR Shear (SQUIB)

EFC Excess Flow Check Valve Actu Type An abbreviation which designates the type of actuator on the valve. Abbreviations used are:

AO Air Operator DF Dual Function (Self and Power)

EXP Explosive HO Hydraulic Operator M Manual MO Motor Operator SA Self-Actuating SAP Self-Actuated Pilot SO Solenoid Operator The Piping and Instrumentation Diagram or Flow Drawing on which the valve is shown.

SheeVCoord The Sheet number and coordinates on the P&ID or Flow Diagram where the valve is shown.

The ASME Safety Class (i.e., 1, 2 or 3) of the valve.

Non-ASME Safety Class valves are designated by "N/A".

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Positions Abbreviations used to identify the normal, fail, and Nonn/Safe safety-related positions for the valve. Abbreviations used are:

Al As Is c Closed CKL Closed/Actuator Key Locked D De-energized D/E De-energized or Energized E Energized LC Locked Closed LO Locked Open LT Locked Throttled 0 Open 0/C Open or Closed OKL Open/Actuator Key Locked SYS System Condition Dependent T Throttled Category The code category (or categories) as defined in paragraph ISTC-1300.

A Seat Leakage Limited B Seat Leakage Not Required .

C Self-Actuating Valves

• D Single Use Valves Act/Pass "A" or "P", used to designate whether the valve is active or passive in fulfillment of its safety function. The terms "active valves" and "passive valves" are defined in Reference 1.4.2.

Testing Requirements

• Test Type A listing of abbreviations used to designate the types of testing which are required to be performed on the valve based on its category and functional requirements.

Abbreviations used are:

BOC Bidirectional Check Valve test (non-safety related closure test)

BOO Bidirectional Check Valve test (non-safety related open test)

CC Check Valve Exercise Test - Closed CO Check Valve Exercise Test - Open CP Check Valve Partial Exercise Test DI Disassembly and Inspect Revision 7 10/21/2016

DIA Diagnostic Test (Pl/Stroke Time)

OT Category D Test ET Manual Valve Exercise EX Full Exercise without stroke timing FC Fail-Safe Exercise Test - Closed FO Fail-Safe Exercise Test - Open LT 1 Leak Rate Test QPR Routing Operator Rounds (condition monitoring)

Pl Position Indication Verification Test PIV

• Seat leakage rate test (high pressure water)

RT Relief Valve Test SC Exercise Closed (without stroke-timing)

SD De-energize SE Energize SO Exercise Open (without stroke-timing)

SP Partial Exercise (Cat. A or B)

STC Exercise/Stroke-Time Closed STO Exercise/Stroke-Time Open 1

A third letter, following the "LT" designation for leakage rate test, may be used to differentiate between the tests.

For example, Appendix J leak tests will be designated as "LTJ", low pressure (non-Appendix J) leak tests as "LTL", and high pressure leak tests as "LTH".

• Test Freq An .abbreviation which designates the frequency at which the associated test is performed. Abbreviations used are:

AJ Per Appendix J CMP Per Check Valve Condition Monitoring Program CS Cold Shutdown M[x] Once Every x Months M3 Quarterly MOV Program frequency OP Operating Activities RR Refuel Outage R[x] Once Every x Refuel Outages 82 Explosive Charge Sample SA Sample Disassemble & Inspect TS Per Technical Specification Requirements Y[X] Once Every XYears Revision 7 10/21/2016

• Relief Identifies the number of the Relief Request applicable to Request the specified test.

• Deferred Deferred Test Justification. This section refers to Cold Just. Shutdown Justifications and Refuel Outage Justifications.

A Cold Shutdown Justification number is listed when the testing frequency coincides with Cold Shutdowns instead of being performed quarterly. Cold Shutdown Justification numbers for valves are prefixed with "CSJ".

A Refuel Outage Justification number is listed when the testing frequency coincides with Refuel Outages instead of being performed quarterly or during Cold Shutdowns.

Refuel Outage Justification numbers for valves are prefixed with "RFJ".

• Tech. Pas. Provides the Technical Position identification number applicable to the pump or test.

Comments Any appropriate reference or explanatory information (e.g., technical positions, etc.).

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SECTION 4.0 ATTACHMENTS Revision 7 10/21/2016

ATTACHMENT 1 SYSTEM LISTING Revision 7 10/21/2016

SYS NO. SYSTEM NAME cc Component Cooling Water CM Containment Monitoring CY Cycled Condensate DG Diesel Generator - Electrical/Mechanical DO Diesel Fuel Oil FC Fuel Pool Cooling and Clean-up FH Fuel Handling & Transfer FP Fuel Pool Cooling FW Feedwater HG Containment Combustible Gas Control HP High Pressure Core Spray IA Instrument Air IS MSIV Leakage Control LD Leak Detection LP Low Pressure Core Spray MC Makeup Condensate MS Main Steam NB Nuclear Boiler Process Inst PS Process Sampling/PASS RA Breathing Air RD Control Rod Drive RE Cnmt, Aux & Fuel Bldg Equipment Drains RF Cnmt, Aux & Fuel Bldg Floor Drains RG Refrigeration Gas RH Residual Heat Removal RI Reactor Core Isolation Cooling RR Reactor Recirculation RT Reactor Water Cleanup SA Service Air SC Standby Liquid Control SF Suppression Pool Cleanup SM Suppression Pool Makeup sx Shutdown Service Water vc Main Control Room HVAC VP Drywell Cooling HVAC VQ Drywall Purge HVAC VR Containment Building HVAC WO Chilled Water wx Solid Radwaste Reprocessing Revision 7 10/21/2016

ATTACHMENT2 PUMP RELIEF REQUEST INDEX Revision 7 10/21/2016

Relief Request # Description Date Submitted Date Approved Remarks 3201 Flow Rate 6/16/09 6/10/10 Includes RAI Measurement for 3201-001 Water Leg Pumps submitted 3/31/2010 Revision 7 10/21/2016

ATTACHMENT 3 PUMP RELIEF REQUESTS Revision 7 10/21/2016

PUMP RELIEF REQUEST 3201 Proposed Alternative In Accordance with 10CFR50.55a(a){3)(i)

1. ASME Code Component{s) Affected 1E12-C003, Residual Heat Removal (RHR) Loop B/C Waterleg Pump (Class 2) 1E21-C002, Low Pressure Core Spray (LPCS) and AHR A Waterleg Pump (Class 2) 1E51-C003, Reactor Core Isolation Cooling (RCIC) Waterleg Pump (Class 2)

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," 2004 Edition (ASME OM Code-2004).

3. Applicable Code Requirement

Table ISTB-3000-1 specifies the parameters to be measured during IST.

ISTB-3300, "Reference Values," paragraph (e)(2) states, "Reference values shall be established within +/-20% of pump design flow for a Group A test, if practicable. If not practicable, the reference point flow rate shall be established at the highest practical flow rate."

ISTB-3400, "Frequency of lnservice Tests," states, "An inservice test shall be run on each pump as specified in Table ISTB-3400-1." Table ISTB-3400-1, "lnservice Test Frequency," specifies that a Group A pump test shall be performed on a quarterly frequency.

ISTB-5121 requires that Group A tests shall be conducted with the pump operating at a specified reference point. ISTB 5121 (b) requires that the resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value.

Group A pumps are pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations.

4. Reason for Request

The waterleg pumps are continuously-running pumps whose safety function is to keep their supported system 1s pump discharge header piping in a filled condition. This function prevents water hammer and the delay of flow to the reactor upon the supported system's pump start. The actual output and hydraulic performance of the waterleg pumps are not critical to their safety function, as long as the waterleg pumps are capable of maintaining their associated system's pump discharge piping full of water.

The amount of flow delivered by each waterleg pump is dependent upon each supported system's leakage rate.

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The suction pressure for these waterleg pumps is essentially constant; however, quarterly monitoring of discharge pressure and bearing vibration in accordance with Position 9, "Pump Testing Using Minimum-Flow Return Lines With or Without Flow Measuring Devices," of Generic Letter (GL) 89-04, "Guidance On Developing

• Acceptable lnservice Testing Programs," dated April 3, 1989, will be performed to monitor for pump degradation and to assess pump performance (Reference 1). The flowrate for each of these waterleg pumps varies little during normal operation, and testing of these pumps at a predetermined reference point as described in ISTB-5121 (b) is not necessary to detect pump degradation or to establish that these pumps can perform their safety function.

The proposed alternative provides an acceptable level of quality and safety.

5. Proposed Alternative and Basis for Use The CPS waterleg pumps will be monitored for degradation on a quarterly basis by observing pump discharge pressure and bearing vibration during normal operating conditions. This testing will be performed without varying the resistance of the system as discussed in ISTB-5121 (b). These parameters will then be evaluated and trended to assess the pump's performance. The measurement and trending of these parameters under these conditions will provide satisfactory indication of the operational readiness of the pumps and detect degraded performance. These waterleg pumps will be full flow tested every 24 months in conjunction with the comprehensive pump test performed in accordance with the requirements specified in ISTB-5123, "Comprehensive Test Procedure."

In addition to this quarterly testing, each of these waterleg pump's supported system pump discharge headers have sensors that continuously monitor header pressure, and provide an alarm in the main control room when their low pressure setpoint is reached.

This will provide indication that the associated waterleg pump is no longer performing its safety function, and allow CPS operators to respond according to station procedures.

Moreover, these pumps are currently being monitored under the CPS Vibration Monitoring Program, which is not currently required by any Federal, state or industry mandate. Because rotating equipment faults that can be detected by vibration monitoring will show up any time the equipment is operating, returning these pumps to a fixed set of operating conditions is not necessary to detect such faults. Lastly, each of these waterleg pump 1s supported system pump discharge header is verified to be filled with water on a monthly basis in accordance with Surveillance Requirements (SRs) in the CPS Technical Specifications (TS). Any indication that the supported system's pump discharge header piping is not filled with water would provide timely indication that the associated waterleg pump's performance has degraded.

In summary, using the provisions of this relief request as an alternative to the requirements of ISTB-3300(e)(2), ISTB-3400, and ISTB-5121 (b}, provides a reasonable alternative to the ASME OM Code requirements, and an acceptable level of quality and safety. The actual output and hydraulic performance of the waterleg pumps are not critical to their safety function, as long as the pumps are capable of maintaining their Revision 7 10/21/2016

supported system's pump discharge header piping full of water. Alarms would promptly alert plant operators whenever the waterleg pumps do not maintain the piping pressure above a set alarm level. In addition, vibration data trending toward unacceptable values would indicate degradation in pump performance, and allow time for CPS personnel to plan and take corrective actions before the pumps fail.

Therefore, the proposed alternative provides a reasonable assurance of operational readiness of the subject waterleg pumps because (1) discharge pressure and bearing vibration are measured and trended, (2) alarms are present in the Main Control Room, which provide continuous monitoring for degradation in the pressure of the supported system's pump discharge header, and (3) monthly venting of supported system's pump discharge header piping according to CPS TS will verify that the associated waterleg pump is performing its safety function.

6. Duration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the Third 10-Year IST Interval

7. Precedents In Reference 2, the Perry Nuclear Power Plant submitted Request Number PR-1, Revision 0, to request relief from quarterly testing waterleg pumps associated with the Residual Heat Removal, Low Pressure Core Spray, High Pressure Core Spray, and Reactor Core Isolation Cooling systems. This request is similar to that request approved by the NRC in a safety evaluation report dated August 9, 1999 (Reference 3).

8. References

1. Generic Letter 89-04, "Guidance On Developing Acceptable lnservice Testing Programs," dated April 3, 1989 *

2. Letter from Mr. M. Bezilla (First Energy Nuclear Operating Company) to U. S.

NRC, "Eight Separate ln-Servic.e Testing Program 10 CFR 50.55a Requests in Support of the Third Ten-Year Interval," dated November 18, 2008. (Accession Number ML083370198)

3. Letter from U. S. NRC, "Safety Evaluation of the lnservice Testing Program Second Ten-Year Interval for Pumps and Valves-- Perry Nuclear Power Plant (TAC MA3328), dated August 9, 1999 Revision 7 10/21/2016

RAls for Relief Request 3201 RAI 3201-001 Please provide the rated flow and differential pressure for each waterleg pump.

Response

The rated flows and rated differential pressures associated with the subject waterleg pumps are contained in Table 1 below.

Table 1: Rated Flow and Rated Differential Pressure for Waterle Rated Rated Pressure (ft 199 199 130 RA/ 3201 -002 Do pressure taps exist in the waterleg pumps' suction and discharge piping where pump suction and discharge pressure can be measured for calculation of differential pressure?

Response

Yes.* The systems associated with the subject waterleg pumps have been designed with suction pressure instruments on the pump suction headers, and flow and pressure instruments on the pump discharge headers to allow for testing. These instruments are isolated during normal plant operation via closed isolation valves and are only placed into service to support waterleg pump testing. Relief Request 3201 proposes in part, to detect degradation in waterleg pump readiness by recording the associated main system discharge pressure on a quarterly basis. As a point of clarification, the waterleg pump discharge pressure as discussed in this relief request is the main system header pressure resulting from the pressure head supplied by the waterleg pumps. The recorded header pressure will be compared to pressures observed in previous tests, and changes in pressure will be evaluated to determine the cause. Relief is requested due to the impact that traditional waterleg pump testing has on the plant without a compensating increase in the level of quality or safety.

• The Low Pressure Core Spray (LPCS) waterleg pump (i.e., 1E21-C002) services the LPCS system piping and Loop A of Residual Heat Removal (AHR) system, and 1E12-C003 services RHR Loops B and C. Traditional testing of the AHR and LPCS waterleg pumps requires declaring portions of the AHR and LPCS systems inoperable.

Testing of 1E21-C002 as described in the 2004 American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requires disabling the main LPCS pump motor, rendering the LPCS System inoperable.

Additionally, AHR Loop A is required to be isolated from 1E21-C002, and an abnormal Revision 7 10/21/2016

alignment is required to maintain the discharge header pressurized and full of water. A similar alignment is required for testing 1E12-C003, rendering RHR C inoperable during the test.

Testing the Reactor Core Isolation Cooling (RCIC) waterleg pump currently requires the RCIC system to be declared inoperable due to the system configuration changes that are necessary to perform the surveillance.

The RHR and LPCS waterleg pump surveillances will be performed with the suppression pool as the suction source. Suppression pool level at Clinton Power Station (CPS) is maintained within limits according to CPS Technical Specifications Section 3.6.2.2. A review of plant data showed that the suppression pool level over the past year was maintained within a five-inch band. Therefore, the pumps' suction pressures are essentially constant, allowing waterleg pump readiness to be confirmed by monitoring the supported system's main header pressure. Changes in the supported system's main header pressure identified during testing will be evaluated to determine if they are a result of a change in the associated waterleg pump's performance.

The RCIC waterleg pump (i.e., 1E51-C003) surveillance will be performed with the RCIC Storage tank as the suction source for 1E51-C003. RCIC storage tank volume is also controlled. A review of the past year's plant data showed that the RCIC tank water level was maintained within a band of approximately five inches. As such, 1E51-C003 suction pressure is essentially a constant. The readiness of 1E51-C003 will be confirmed by monitoring the main RCIC system header pressure .. Changes in the RCIC system's main header pressure between tests .will be evaluated to determine if they are a result ,of a change in pump performance~

According to the testing methodology proposed in Relief Request 3201, changes iri supported system's main header pressure will be evaluated to determine if they are a result of changes in the waterleg pump performance. Testing the waterleg pumps in this manner ensures a level of quality and safety equivalent fo the testing methodologies described in the ASME OM Code. Moreover, ttie waterleg pumps will be tested in accordance with traditional testing methodologies during the biennial comprehensive pump testing that will

_be performed in accordance with the -ASME OM Code.

In summary, performing the waterleg pump surveillances on a quarterly frequency in accordance with traditional IST pump surveillance methodologies places the unit in a higher risk state without a compensating increase in quality or safety. The testing methodology proposed in Relief Request 3201 would provide an acceptable level of quality and safety without placing the unit in an elevated state of risk.

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RAI 3201-003 Are there throttle valves in the waterleg pumps' discharge piping that can be used to set differential pressure?

Response

Yes.

RAI 3201-004 Are there any flow rate meters, orifices, or other measurement devices installed in the system for measurement of waterleg pump flow rate? *

Response

Yes.

RA/ 3201-005 Have any attempts been made to use portable ultrasonic flow instruments to measure waterleg pump flow rates? If not, explain why not.

Response

No. As previously discussed, the systems were designed and built to allow for waterleg pump testing.

RAJ 3201-006 Is there flow instrumentation in the main header piping? If *so, explain why

• this instrumentation can or cannot be used to measure the waterleg pump flow.

• Response:

Yes. The flow instrumentation ranges for the main system headers are as follows: .

• AHR: 0 - 7000 gpm

• LPCS: 0 - 8000 gpm

• RCIC: 0 - 800 gpm The ranges for these instruments are not suitable for measuring the low flow rates at which the waterleg pumps are tested.

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RAJ 3201-007 At what pressure does each low header pressure annunciator alarm? For each of these values, state what percentage it is of the respective waterleg pump operating differential pressure.

Response

As shown in Table 2 below, Control Room annunciator alarms are based on pressure. The alarm setpoints were compared to the normal operating pressure of their associated headers, and shown as a percentage of that normal operating pressure. As previously disc_ussed, the suction pressures for the waterleg pumps are essentially constant; therefore it is appropriate to consider control room alarm setpoints in relation to normal pump discharge/associate system header pressure versus as a percentage of pump differential pressure.

Table 2: Waterleg Pump Parameters Including Control Room Alarm Setpoint as a Percentage of Normal Discharge Pressure Normal Alarm Setpoint as Alarm Operating Percentage of System ATM Setpoint ATM Pressure Normal Operating (psig) tosia) Pressure (o/o)

RHR"A" E12-N654A 58.4 1E12-N653A -94 62.1 RHR"B" E12-N654B 57.8 1E12-N653B -88 65.7 RHR "C" E12-N654C 21.6 1E12-N653C * - 91 23.7 LPCS E21-N654 35 1E21-N654 -94 37.2 RCIC E51-N652 39 1E51-:N654 -55 70.9 Revision 7 10/21/2016

ATTACHMENT 4 VALVE RELIEF REQUEST INDEX Revision 7 10/21/2016

Relief Request# Description Date Submitted Date Approved Remarks 2201 Use of Code 6/16/09 6/10/10 No RAJs Case OMN-1 2202 Relief From 5- 6/16/09 6/10/10 Includes RAJ Year Test 2202-001 Interval for submitted Safety Relief 3/31/2010 Valves 2203 Defining "refuel 1211/14 7/15/15 Includes RAls only" outage 2203-001 to valve testing 2203-004 submitted 3/26/2015 and 6/3/2015 2204 Setting OMN-1 12/1/14 7/15/15 Includes RAI Valve Exercise 2204-001 tests on 2Y submitted f reauencies 3/26/2015 Revision 7 10/21/2016

ATTACHMENT 5 VALVE RELIEF REQUESTS Revision 7 10/21/2016

VALVE RELIEF REQUEST 2201 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

1. ASME Code Component(s) Affected All ASME Class 1, 2, and 3 motor-operated valves (MOVs) currently included in the Clinton Power Station (CPS) MOV Testing Program.

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," 2004 Edition (ASME OM Code-2004).

3. Applicable Code Requirement

ISTA-3130{b) requires that code cases be appllcable to the edition and addenda specified in the test plan.

ISTC-3100 requires that any motor operated valve (MOV) that has undergone maintenance that could affect its performance after the preservice test be tested in accordance with ISTC-331 O.

ISTC-331 O*requires that a new reference value be determined or the previous reference value be reconfirmed by an inservice test after a MOV has been replaced, repaired, or has undergone maintenance that could affect the valve's performance.

ISTC-3510 requires that active Category A and B MOVs be exerpised nominally every 3 months.

ISTC-3521 requires that active Category A and B MOVs be exercised during cold shutdowns if it is not practicable to exercise the valves at power, or that active Category A and B MOVs be exercised during refueling outages if it is not practicable to exercise the valves during cold shutdowns.

• ISTC-3700 requires that valves with remote position indicators be observed locally at least once every 2 years to verify that valve operation is accurately indicated.

ISTC-5120 requires that MOVs be stroke-time tested when exercised in accordance with ISTC-3510.

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4. Reason for Request

In accordance with 10 CFR 50.55a(a)(3)(i), relief is requested from the requirements of the OM Code, Subsection ISTC-3000, excluding ISTC-3600, "Leak Testing Requirements," and the requirements of Subsection ISTC-5120. The proposed alternative would provide an acceptable level of quality and safety.

5. Proposed Alternative and Basis for Use EGC proposes to adopt the requirements of Code Case OMN-1 as revised in the 2006 Addenda to the ASME OM Code-2004 in lieu of the performance of stroke time testing and position indication testing as described by ASME OM ISTC 2004. The provision to allow for motor control center testing, as contained in Section 6.1 of Code Case OMN-1, is excluded from this request.

The NRC amended its regulations to incorporate by reference the 2004 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants on September 10, 2008. In the latest 10 CFR 50.55(a)(b), it states in part, that Regulatory Guide (RG) 1.192, "Operating and Maintenance Code Case Acceptability, ASME Code", has been approved for incorporation by reference. In RG 1.192, it states within Table 2, "Conditionally Acceptable OM Code Cases," that the alternative rules of ASME Code Case OMN-1, "Alternative Rules for Preservice and lnservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants," Revision 0, when applied in conjunction with the provisions for leakage rate testing in ISTC-3600, may be applied with the following provisions:

1. The adequacy of the diagnostic test interval for each valve must be evaluated and adjusted as necessary but not later than 5 years or three refueling outages (whichever is longer) from initial implementation of ASME Code Case OMN-1.

2. When extending the exercise test intervals for high risk MOVs beyond a quarterly frequency, licensees shall ensure that the potential increase in core damage frequency and risk associated with the extension is small and consistent with the intent of the Commission's Safety Goal Policy Statement.

3. When applying risk insights as part of the implementation of OMN-1, licensees must categorize . MOVs according to their safety significance using the methodology described in Code Case OMN-3, "Requirements for Safety Significance Categorization of Components Using Risk Insights for lnservice Testing of LWR Power Plants," with the conditions discussed in this regulatory guide or use other MOV risk-ranking methodologies accepted by the NRC on a plant-specific or industry-wide basis with the conditions in the applicable safety evaluations.

This conditional acceptance of OMN-1, Revision 0, per RG 1.192 is applicable in lieu of the provisions for stroke-time testing in Subsection ISTC of ASME OM Code-2004.

Since RG 1.192 was last published, Code Case OMN-1 has been updated/modified to address and incorporate all of the original RG 1.192 listed provisions. EGC proposes to adopt the requirements of Code Case OMN-1, Revision 1, as presented in the ASME Revision 7 10/21/2016

OMb Code, "Addenda to ASME OM Code-2004, Code for Operation and Maintenance of Nuclear Power Plants," for 2006, in lieu of the performance of stroke time testing and position indication testing as described by ASME OM Code Subsection ISTC of the 2004 Edition.

The CPS MOV testing program was developed as a result of NRC Generic Letter (GL) 89-10, "Safety Related Motor Operated Valve Testing and Surveillance," and GL 96-05, "Periodic Verification of Design Basis Capability of Safety Related Motor Operated Valves," utilizing Topical Report MPR-1807, "Joint BWR, Westinghouse. and Combustion Engineering Owners' Group Program on Motor-Operated Valve (MOV)

Periodic Verification," Revision 2. CPS is currently utilizing MPR-2524-A, "Joint Owners' Group (JOG) Motor Operated Valve Periodic Verification Program Summary,"

(November 2006) as guidance for the MOV Program. The adoption of OMN-1 will consolidate testing between the station's IST and MOV Programs.

Section 4.2.5 "Alternatives to Stroke-Testing/' of NUREG-1482, "Guidance for lnservice

. Testing at Nuclear Power Plants," Revision 1, states in part that as an alternative to MOV stroke-time testing, ASME developed Code Case OMN-1, which provides periodic exercising and diagnostic testing for use in assessing the operational readiness of MOVs, may be used. Section 4.2.5 recommends that licensees implement ASME Code Case OMN-1 as an alternative to the MOV stroke-time testing. The periodic exercising and diagnostic testing requirements in OMN-1 provide an improved method for assessing the operational readiness of MOVs.

Application of code cases is addressed in 10 CFR 50.55a(b){6) through references to

. RG 1.192, which lists acceptable and conditionally . acceptable code cases for implementation in IST programs. RG 1.192, Table 2, conditionally approves the use of Code Case OMN-1 and states that the code case is applicab.le to the 2000 Addenda and earlier editions and addenda of the Code. There is no technical reason for prohibiting the use of Code Case OMN-1 with ASME OM Code-2004. Therefore, Code Case OMN-1 provides an acceptable level of quality and safety for testing of MOVs and is an acceptable alternative for use in CPS IST program. This conclusion is consistent with the NRC position in NUREG-1482, Revision 1, and AG 1.192.

Code Case OMN-1 was revised in the 2006 Addenda to the ASME OM Code-2004.

Most of the revisions are enhancements such as clarification of valve remote position indication requirements and ball/plug/diaphragm valve test requirements, and the expansion of risk-informed provisions. However, there was one significant revision in Section 6.1, "Acceptance Criteria," that states that motor control center (MCC) testing is acceptable if correlation with testing at the MOV .has been established. MCC diagnostic testing was not specifically addressed in the original version of OMN-1. Historically, diagnostic testing of MOVs has been conducted using at-the-valve tests. Although there may be potential benefits of testing conducted at the MCC, the ASME OM Code does not address any method for the correlation of MCC-based measurements to diagnostic test measurements conducted at-the-valve. For these reasons, EGC has excluded the provision for MCC testing from this relief request. Therefore, the MCC test Revision 7 10/21/2016

method will not be used as an acceptance criterion to determine the operational readiness of MOVs.

Technical Position The following positions describe how EGC interprets and complies with the various requirements of OMN-1 (ASME OMb Code-2006).

1. OMN-1, Section 3. 1 allows for the use of testing that was conducted prior to the implementation of OMN-1 if it meets the requirements of the Code Case. EGC intends to utilize the testing credited under its GL 89-10/96-05 responses to satisfy the requirement for a one-time test to verify the capacity of each individual or group of MOV's safety-related design basis requirements.

2. OMN-1, Section 3.2 requires that each MOV be tested during the preservice test period or before implementing inservice inspection. EGG intends to utilize the testing credited under its GL 96-05 response to satisfy this requirement.

3. OMN-1, Section 3.3(b) states that inservice tests shall be conducted in the as-tound condition, and activities shall not be conducted if they.might invalidate the as-found condition for inservice testing. CPS maintenance activities that would affect the as found condition of the valve, such as motor operator preventive maintenance or stem lubrication, are typically scheduled to occur in conjunction with the performance* of the MOV Periodic* Verification Testing, and are performed after as-found testing. Any other activities that could affect the as-tound test results are not performed until after the as found testing has been con.ducted.

4. OMN-1 Section 3.3(c) requires the inservice test program to include a mix of static and dynamic MOV performance

• testing. CPS has utilized the JOG program's mix of static and dynamic MOV performance testing (i.e., MPR-2524-A) to develop its current MOV testing program. Additionally, CPS will continue to utilize the existing engineering standards, which are consistent with the JOG standards, to justify any changes to the mix of required MOV performance testing. The use of such an evaluation will serve to ensure* CPS continues to meet this requirement.

5. OMN-1, Section 3.3(e) requires that Remote Position Indication shall be verified locally during inservice testing or maintenance activities. EGG will continue to verify the operability of each MOV's position indication system as part of each MOV's diagnostic test. In addition, the function of each MOV's position indication system will be verified during the performance of maintenance activities affecting remote position indication.

6. OMN-1, Section 3.3.1(b) requires MOV inservice testing to be conducted every 2 refueling cycles or 3 years (whichever is longer), if insufficient data exists to determine inservice test frequencies. CPS has sufficient MOV testing data to Revision 7 10/21/2016

justify its current testing frequencies, and therefore meets this requirement. If in the future, modification or replacement results in the necessity to re-baseline a valve or group of valves, the requirements of OMN-1, Section 3.3.1 (b) or 3.7.2.2(c) as applicable, will be followed.

7. OMN-1, Section 6.4.4 requires that calculations for determining the MOV's functional margin are evaluated to account for potential performance-related degradation. The CPS MOV Program, including the corporate MIDAS Software (or similar updated product), takes into account performance-related degradation, to calculate valve margin.

8. The provision of motor control center testing contained

• in Section 6.1

("Acceptance Criteria") is excluded from this request ("i.e., Motor control center testing is acceptable if correlation with testing at the MOV has been established").

6. Duration of. Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the Third 10-Year IST Interval or until the NRC publishes the version of Code Case OMN-1 found in the 2006 addenda to ASME OM Code-2004 in a future revision of Regulatory Guide 1.192.

7. Precedents Similar relief has been approved for LaSalle County Station, Units 1 and 2, Relief

• Request RV*02, in NRC Safety Evaluation Report, dated September 26, 2007 (Reference 1), and Peach Bottom Atomic Power Station, Units 2 and 3, Relief Request GVRR-1, in N_RC Safety Evaluation, dated September 3, 2008 (Reference 2).

8. References

• 1. Letter from R. Gibbs (U.S. NRC) to C. M. Crane (EGC), "Relief Requests for the LaSalle County Station, Units 1 and 2,' Third 10-Year Pump and Valve In service Testing Program {TAC Nos. MD5988,. MD5989, MD5992, MD5993, MD5994, MD5995)," dated September 26, 2007 *

2. Letter from H. K. Chernoff (U.S. NRC) to C. G. Pardee (EGC),* "Peach Bottom Atomic Power Station, Units 2 and 3 - Requests for Relief Associated with the Fourth lnservice Testing Interval (TAC Nos. MD7461 and MD7462)," dated

• September 3, 2008 Revision 7 10/21/2016

VALVE RELIEF REQUEST 2202 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(ii)

1. ASME Code Component(s) Affected Components:

1B21-F041A, 1B21-F041B, 1B21-F041C, 1B21-F041 D, 1B21-F041 F, 1B21-F041G, 1B21-F041L, 1B21-F047A, 1B21-F047B, 1B21-F047C, 1B21-F047D, 1B21-F047F, 1B21-F051B, 1B21-F051C, 1B21-F051D, 1B21-F051G

Description:

Clinton Power Station (CPS) Main Steam Line Safety Relief Valves (SRVs), Dikkers Valves Model G-471 *

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers, "Code for Operation and Maintenance of Nuclear Power Plants," 2004 Edition (ASME OM Code-2004)

3. Applicable Code Requirement

ASME OM Code mandatory Appendix I, "lnservice Testing of Pressure Relief Devices in Light-Water React.or Nuclear Power Plants," Section 1-132.0, "Test Frequencies, Class 1 Pressure Relief Valves," paragraph (a).

• This section states that all Class 1 pressure relief valves shall be tested at least once every 5 years starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each 5-year interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval. This 20% shall consist of valves that have not been tested during the current 5-year interval, if they exist. The test interval for any' individual valve shall not exceed 5 years.

4. Reason for Request

1o CFR 50.55a(f)(4) directs a licensee to meet inservice testing requirements for ASME Code Class 1 valves set forth in the ASME OM Code and addenda. The third 10-year inservice testing (lsn interval for CPS is based on the ASME OM Code-2004; specifically, Mandatory Appendix I, which contains requirements to augment the rules of Subsection ISTC, "lnservice Testing of Valves in Lig~t-Water Reactor Nuclear Power Plants."

ISTC-3200, "lnservice Testing," states that inservice testing shall commence when the valves are required to be operable to fulfill their required function(s). ISTC-5240, "Safety and Relief Valves," directs that safety and relief valves meet the inservice testing requirements set forth in Mandatory Appendix I of the ASME OM Code.

Appendix I, Section 1-1320 of the ASME OM Code states that Class 1 pressure relief Revision 7 10/21/2016

valves shall be tested at least once every 5 years, starting with initial electric power generation.

The Dikkers Model G-471 SRVs have shown exemplary test history at CPS, as described in Section 5 below. However, given the current 24-month operating cycle for CPS, Exelon Generation Company, LLC (EGC) is required to remove and test fifty percent (i.e., eight of 16) of the SRVs every refueling outage, so that all valves are removed and tested every two refueling outages. This ensures compliance with the ASME OM Code requirements for testing Class 1 pressure relief valves every five years. Approval of extending the test interval to 6.5 years would reduce the minimum number of SRVs tested at CPS over three refueling outages by eight.

Without relief, the incremental outage work due to the inclusion of the eight additional SRVs would be contrary to the principles of maintaining exposure to radiation as low as reasonably achievable (ALARA), in that the removal and replacement of an additional eight SRVs over three refueling outages will result in approximately 5.6 person-rem of additional cumulative radiation exposure. In addition, as discussed below, historical SRV test results for the Dikkers Model G-471 SRVs indicate that the CPS SRVs continue to perform well. Therefore, this additional cumulative radiation exposure represents a hardship for CPS without a compensating increase in the level of quality or safety.

• In accordaric.e with.*10 CFR 50.55a, "Codes and standards, 11 paragraph (a)(3)(ii), EGC requests relief from the five-year test interval requirements of ASME OM Code, ISTC Appendix I Section 1-1320, "Test Frequencies, Class 1 Pressure Relief V~lves,"

paragraph (a), for the Dikkers Model G-471 SRVs at CPS. EGC requests ttiat the test.

interval be increased from five years to 6.5 years. All other requirements of the ASME OM Code would be met. Compliance with the applicable requirements of the ASME OM Code for these SRVs results in hardship due to unnecessary personnel radiation exposure without a comper:lsating increase in the level of quality or safety ..

5. Proposed Alternative and Basis for Use For the third 10-year IST interval at CPS, EGC proposes that ASME Class 1 pressure relief valves (i.e., Dikkers Model G-471 SRVs) shall be tested at least once every 6.5 years. A minimum of 20% of the pressure relief valves will be tested within any 24-month interval and this 20% shall consist of valves that have not been tested during the current 6.5 year interval, if they exist. The test interval for any individual valve shall not exceed 6.5 years.

All SRVs are located in the upper elevations of the CPS drywell. The major contributors to radiation exposure are the main steam lines, including the SRVs, along with High Pressure Core Spray system and Low Pressure Core Spray system piping passing through the area.

Removal of an installed SRV and installation of a replacement SRV requires installation of scaffolding, removal of insulation and various appurtenances on the SRV, and unbolting the SRV. Once unbolted, the SRV is maneuvered from its location in the Revision 7 10/21/2016

upper drywall and lowered to the first elevation and transported through the drywall and containment equipment hatches. Each SRV weighs approximately 3050 pounds, and due to its size, a crew of five to seven personnel is required to safely move each valve.

EGC has evaluated the historical cumulative radiation exposure at CPS for removal and replacement of SRVs from the last five CPS refueling outages. The work evolutions necessary to remove and replace these valves each refueling outage, which includes the removal and replacement of eight SRVs, are conducted. under equivalent radiological conditions and with the same personnel requirements. This historical cumulative radiation exposure data is provided in Table 1.

Table 1: Cumulative Radiation Exposure Refueling RF-7 C1R08 C1R09 C1R10 C1R11 OutaQe Number of SRVs 16 16 8 8 8 Replaced Cumulative Person- 8.062 8.837 12.139 5.325 4.9 Rem Based on this data, EGC has concluded that the expected cumulative radiation exposure to remove and replace a single SRV would be approximately 0.7 person-rem.

The outage-specific variability of cumulative radiation exposure is attributed to the location of a particular valve relative to its respective radiation field, the physical configuration of surrounding equipment for a particular valve, and the impact of outage-specific plant configurations. Therefore, absent the requested relief, replacement of eight incremental SRVs would result in approximately 5.6 additional person-rem over three refueling outages.

• The data from the IST history for SRVs at CPS from 2001 to present indicates that 37 of 40, or 92.5% of the SRVs tested have successfully passed the ASME OM Code as-tound acceptance criteria of plus or minus 3%. A majority of the valves tested had been installed for two operating cycles. Historical data also indicates that the as-found set points for 28 of 40 tests remained within the as-left tolerance of plus or minus 1%.

• The as-found test data for the three SRV failures indicates that two of the three SRV test failures did not decrease the level of quality or safety, in that the as-found setpoint for one SRV was within 0.004% of the acceptance criteria, and one SRV exceeded the acceptance criteria in a negative or more conservative direction. The three SRV failures that occurred were SRVs that were as-left setpoint tested using nitrogen by on-site personnel and then as-found setpoint tested by an off-site National Board Code Stamp-certified vendor using steam. CPS has since abandoned on-site nitrogen setpoint testing and refurbishment by on-site personnel, and opted to send the SRVs to a certified off-site vendor for as-found and as-left setpoint testing using steam. No failures Revision 7 10/21/2016

have been noted following the transition to steam as the test medium for as-found and as-left testing.

In addition to the historical test results, the current CPS reload ASME overpressure analysis assumes that two SRVs are out of service, and all of the operable SRVs open to relieve pressure at the upper ASME Code limit of 1375 psig. This value is greater than the plus 3% of the SRV setpoint. These conservative assumptions provide additional assurance that the requested relief from the ASME OM Code requirement for the subject SRVs would not result in a decrease in the level of quality or safety.

CPS currently utilizes a National Board Code Stamp-certified off-site vendor to perform as-found and as-left testing, inspection, and refurbishment of the SRVs. An EGC-approved and qualified procedure is used for disassembly and inspection of the SRVs.

This procedure requires that each SRV be disassembled and inspected upon removal from service, independent of the as-found test results. The procedure identifies the critical components that are required to be inspected for wear and defects, and the critical dimensions that are required to be measured during the inspection. If components are found worn or outside of the specified tolerance(s), the components are either reworked to within the specified tolerances, or replaced. All parts that are defective, outside-of-tolerance, and all reworked/replaced components are identified, and EGC is notified of these components by the off-site vendor. The SRV is then reassembled, the as-left test is performed, and the SRV is returned to CPS.

The ASME OM Sub-Group on Relief Valves developed Code Case OMN-17, "Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves." Code Case OMN-17 allows owners to extend the test interval for safety and relief valves from 60 months to 72 months plus a six-month grace period. This code case imposes a special maintenance requirement to disassemble and inspect each safety and relief valve to verify that parts are free from defects resulting from the time related degradation or service induced wear prior to the start of the extended test interval. The purpose of this maintenance is to reduce the potential for setpoint drift. As noted above, EGC utilizes a National Board Code Stamp-certified off-site vendor to perform as-found and as-left testing, inspection, and refurbishment of the Dikkers Model G-471 SRVs for

• CPS. EGC has verified that the approved and qualified procedure that is used by the off-site vendor for disassembly, inspection, repair, and testing of the SRVs satisfies the special maintenance requirement specified in Code Case OMN-17.

All currently installed SRVs at CPS were disassembled, inspected, repaired, and tested in accordance with the qualified procedure, prior to installation, to verify that parts were free from defects resulting from time-related degradation or maintenance-induced wear.

Therefore, currently installed SRVs at CPS comply with Code Case OMN-17.

Furthermore, each SRV removed from service at CPS will continue to be disassembled, inspected, repaired, and tested in accordance with the qualified procedure prior to reinstallation. Upon approval of the proposed relief request, the test interval (i.e., the frequency for disassembly, inspection, repair, and testing) for any SRV shall not exceed 6.5 years (i.e., 72 months plus a six-month grace period).

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Based upon the estimated cumulative radiation exposure to comply with the ASME OM Code, coupled with historical SRV test results for Dikkers Model G-471 SRVs at CPS, EGC has concluded that compliance with the ASME OM Code would result in hardship, without a compensating increase in the level of quality or safety.

EGC submitted Relief Request No. 221 O on November 3, 2008 (Reference 1) for the remainder of the Second CPS 10-Year IST interval. The circumstances and basis for this request do not differ from those provided in Reference 1.

6. D1,1ration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the Third 10-Year IST Interval.

7. Precedents In Reference 2, the NRC reviewed and approved relief requests for both Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station

{QCNPS), Units 1 and 2 to extend their main steam safety valve (MSSV) test interval duration for individual valves to 6.5 years for the remainder fourth 10-year IST interval.

In Reference 3, the NRC .reviewed and approved a relief request for Susquehanna Steam Electric Station (SSES), Units 1 and 2, to extend the MSSV test interval duration for individual valves to six years for the entire third 10-year IST interval. In Reference 4, the NRC reviewed and approved a relief request for Nine Mile Point Nuclear Power Station, Unit 2 (NMP2) to extend the MSSV test interval duration for individual valves to three refueling outages or approximately six years for the entire third .10-year IST

• interval. In all of these approvals, the NRC allowed for a total installed interval of at least six years.

In Reference 1, EGC requested relief for CPS similar to that approved in Reference 2.

This request was for the Second CPS IST Interval.

This proposed relief request is consistent with the DNPS, QCNPS, SSES and NMP2 precedents, in that it will establish a test interval that would enable EGC to maintain a Dikkers Model G-471 SRV in service for three operating cycles, while also allowing adequate time to transport, test; and refurbish an SRV, at an external facility prior to reinstallation.

8. References

1) Letter from Mr. J. L. Hansen, {Exelon Generation Company, LLC) to the U. S. NRC, "Request for Relief from ASME OM Code 5-year Test Interval for Safety Relief Valves (Relief Request No. 2210)," dated November 3, 2008 (Accession Number ML083090066)

2) Letter from U. S. NRG to Mr. Charles- G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station Units 2 and 3 - Relief Request No. RV-02C from 5-Year Test Interval for Main Steam Safety Valves (TAC Nos. MD8150 and MD8151) and Quad Cities Nuclear Power Station, Relief Requests No. RV-30E and Revision 7 10/21/2016

RV-30F from 5-Year Test Interval for Main Steam Safety Valves (TAC Nos.

MD6682, MD6683, MD8241, and MD8242), 11 dated June 27, 2008

3) Letter from U. S. NRC to Mr. B. L. Shriver (PPL Susquehanna, LLC), "Susquehanna Steam Electric Station Units 1 and 2 -Third 10-year Interval lnservice Testing (IST)

Program .Plans (TAC Nos. MC3382, MC3383, MC3384, MC3385, MC3386, MC3387, MC3388,. MC3389, MC4421, MC4422)," dated March 10, 2005

4) Letter from U. S. NRC to Mr. J. H. Mueller (Niagara Mohawk Power Corporation),

"Nine Mile Point Nuclear Power Station, Unit No. 2 -Alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Regarding lnservice Testing of Main Steam Safety/Relief Valves (TAC No. MB0290)," dated April 17, 2001 Revision 7 10/21/2016

RA/ 2202-001 Request No. 2202 proposes to extend the test inteNa.I for the main steam line safety relief valves to 6.5 years and references Code Case OMN-17, Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves," as a basis for extending the test lnteNal. Code Case OMN-17 allows owners to extend the test inteNal for safety relief valves from 5 years with no grace period to 6 years plus a 6-month grace period. It is preferable to the NRG staff to be consistent with the provisions in Code Case OMN-17.

Please discuss if a 6 year plus a six month grace period safety relief valve test inteNal Is acceptable in lieu of a 6.5 year test inteNal with no grace period.

Response

Clinton Power Station (CPS) would consider a six year frequency with the allowance for a six month grace period an acceptable alternative to the 6.5 year frequency with no grace period that was proposed in 10 CFR 50.55a Request Number 2202. The six year interval with six month grace period will continue to reduce the number of Safety Relief Valves (SRVs) that are tested over three refueling outages and maintain the site's radiation exposure as low as reasonably achievable.

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VALVE RELIEF REQUEST 2203 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(z)(1)

1. ASME Code Component(s) Affected All ASME Class 1, 2, and 3 valves included in a Clinton Power Station (CPS) In-Service Testing (IST) Cold shutdown (CSJ) or Refuel Justification (RFJ).

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME), 11 Code for Operation and Maintenance 11 of Nuclear Power Plants, 2004 Edition (ASME OM Code-2004).

3. Applicable Code Requirement

• ISTC-3521 Category A and Category B Valves ISTC-3521 (e) if exercising is not practicable during operation at power or cold shutdowns; it may be limited to fullstroke during refueling outages.

ISTC-3521 (h) all valve testing required to be performed during a refueling outage shall be completed before returning the plant to operation at power.

ISTC*3522 Category C Check Valves ISTC-3522(c) If exercising is not practicable during operation at power and cold shutdowns; it shall be performed during refueling outages.

ISTC-3522(f) All valve testing required to be performed du.ring a refueling outage shall be completed before returning the plant to operation at power.

4. Reason for Request

In accordance with 10 CFR 50.55a(a)(3)(i), relief is requested from the requirements of the OM Code, Subsection ISTC-3521 (e}, ISTC-3521 (h), ISTC-3522(c) and ISTC-3522(f). The proposed alternative would provide an acceptable level of quality and safety.

These sections require CSJ and RFJ valves to be tested each refueling outage. CPS is currently on a 24 fuel month cycle, thus, CSJ and RFJ valves are currently tested every 24 months. For financial reasons, CPS will be transitioning to a 12 month fuel cycle beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e.,

"refueling/maintenance outages"). Based on the above referenced code requirements,

• Revision 7 10/21/2016

CPS will be required to test all CSJ and RFJ valves every year. This in effect cuts the testing frequency of these valves in half (i.e., one year vs two years). This change in outage scheduling and its OM Code implications do not provide a compensating increase in level of quality or safety.

This relief request is being pursued to maintain the current (i.e., two year) testing frequency for the CPS CSJ and RFJ valves. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the two year frequency that these valves have historically been tested at during the "refueling/maintenance outages."

5. Proposed Alternative and Basis for Use CPS proposes to continue testing CSJ and RFJ valves every two years with the CSJ valves being tested during all cold shutdowns lasting longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and continuing until the plant is ready to retum to operation at power per ISTC-3521 (g) and ISTC-3522(e). Based on the current outage plans, CPS proposes treating the "refueling only outage" as a cold shutdown in accordance with OM Code requirements and not a refueling outage. This will maintain the current time between tests at every two years for the CSJ and RFJ valves.

By maintaining the current testing frequency, CPS maintains the current acceptable level of quality and safety with regards to the CPS RFJ valves. This change in outage schedules will also increase the level of quality and safety for the CPS CSJ valves due to th13 planned outage in between the "refueling/maintenance outages" that will provide time to perform some of the CSJ valve testing. This statement is supported by the years of testing these valves at a 24 month interval.

• In summary, CPS is proposing to test all of its CSJ and RFJ valves every two years during the "refueling/maintenance outages" and continue testing the CSJ valves as time allows during the "refueling only outage" to satisfy the requirements of ISTC-3521 (g) and ISTC-3522(e). This will maintain the current time between tests for the CSJ and RFJ valves at a maximum of two years. *

6. Duration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the Third 10-Year !ST Interval.

Revision 7 10/21/2016

RAl-2203-001 The requests state that the proposed alternatives are tor the third /ST interval at CPS.

Provide the start and end date for the third /ST interval.

Response

CPS is currently in the third IST interval. As documented in Reference 1, the third IST interval started on July 1, 2010 and will end on June 30, 2020.

RA/*2203-002 ASME OM Code exercise test provides an opportunity tor tracking and trending valve and accessory performance. It is recognized there is a possibility that not all valves listed on the CSJ list will be tested during a shorter "refueling only" outage. Section 3. 1. 1. 1, "/ST Cold Shutdown Testing," ofNRC NUREG-1482, Revision 2, "Guidelines for /nservice Testing at Nuclear Power Plants," published October 2013, provides an acceptable method of scheduling valves for testi(lg during a cold shutdown. Use of this method helps* ensure that the selection of valves to be tested during a cold shutdown are diverse and not the same group of valves each time~ Explain how the .valves identified in the CSJ list will be selected for testing during the shorter "re,fueling only" outage. '

Response

CPS currently maintains a list of all CS_J valves that are eligible for testing during an extended cold shutdown (i.e., greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). This list is provided to Operations and Outage Planning before each planned outage arid within one shift in the case of a forced outage. From this list, Operations selects the valves to be tested during the course of the outage .. Engineering coordinates with Operations to ensure testing.of CSJ valves is consistent with the guidance provided in Section 3.1.1.1 of NUREG 1482, Revision 2. In addition to testing the CSJ valves during an extended cold shutdown, the CPS testing program currently requires that all valves on the CSJ list are tested each refu,eling outage to ensure all these valves are te$ted every two years. Once CPS transitions to annual refueling outages, the CPS testing program will continue to require testing of CSJ valves during extended cold shutdowns including the "refueling only outages." In addition, the CPS testing program will continue to require that all CSJ valves are tested during the "refueling/maintenance outages" ensuring that all of these valves are tested every 2 years.

This in tum will reset the CSJ list.

RAl-2203-003:

The OM Code requires exercise testing of valves at least once every 3 months; however, the OM Code permits the testing to be deferred to cold shutdown or refueling outages*

based on practicality. Operating experience indicates that valve reliability is higher with more frequent testing. The application indicates that a test interval of 24 months for RFJ valves "maintains the current acceptable level of quality and safety" for these valves. The application also indicates that testing of the CSJ valves during the "refueling only" outage will "increase the level of quality and safety for the CPS CSJ valves." However, the application does not describe the impact on the reliability of the valves given the intent of the OM code.

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Justify that the CSJ and RFJ valves will be adequately reliable by comparing the reliability based on testing at 3-month, 1-year, and 2-year intervals. Provide additional justification why it is acceptable for valves on the RFJ list to maintain the current 2 year test interval.

Response

As noted above in the response to RAI 2, CPS intends to continue testing CSJ valves during all extended cold shutdowns (i.e., longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). Since EGC intends to treat the 11 refueling only outages" as a cold shutdown in accordance with OM code requirements, CSJ valves will be tested during the "refueling only outages" just as they are tested during any other cold shutdown. Based on this approach, the CSJ valves will continue to be tested at a frequency that will ensure reliability in accordance with the OM code requirements.

As noted in the question, the OM Code permits the testing of valves to be deferred to cold shutdown or refueling outages based on practicality. The CPS valves currently classified as RFJ valves have been tested each refueling outage in accordance with the requirements*

of the OM Code. In support of the response to this question, EGC has reviewed the test history for the RFJ valves to determine if test failures would indicate that more frequent testing of these valves would ensure more reliable performance.

After reviewing the test history for all 70 current RFJ valves for the past 6 refueling outages (i.e., 2003 (C1R09)-2013 (C1 R14)), a total of 11 unsatisfactory tests were identified involving 7 different valves. The valves that had an unsatisfactory test are listed in the table below organized by the outage that the failure occurred in. The other 63 valves have satisfactory test history that supports their continued testing on a 2 year test interval. Of the 7 valves that experienced an unsatisfactory test, 4 valves experienced one failure, 2 valves experienced two failures, and 1 valve was found to have experienced three failures.

By virtue of no reoccurring failures, it has been demonstrated that the corrective actions taken with the 4 single failure valves have fixed their issues. The reactor pressure excess flow check valve 1CM067, which experienced a failure in C1R14 (2013), was replaced with a new valve.

Low Pressure Coolant Injection testable check valve (i.e., 1E12-F041 B) has experienced 2 failures, one on its open test and one on its close test. The open test issue found the packing gland out of alignment. This was repaired in C1R14 (2013). In C1 R11 (2008) the closed test found the clearances between the disk and the valve body to be out of tolerance. The disk hole was re-bored to align the disk and body in C1 R11 . No repeat close test failure has occurred since C1 R11.

High Pressure Core Spray System testable check valve (i.e., 1E22-F005) had back to back failures of its check closed test, one in C1 R11 and again in C1 R12 (2010). Each time, repair work orders where completed. In C1 R11 the valve was disassembled, no issues noted, the valve was reassembled, and passed its post-maintenance testing (PMT). In C1R12 it was disassembled and noted there were out of tolerance gaps between the valve disk and body. This was corrected under the repair work order and no repeat failure has occurred since C1R12.

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Reactor Core Isolation Cooling System testable check valve (i.e., 1E51-F066) has experienced multiple failures with the last two in consecutive outages .. This valve is in a position to be tested during "refueling only outages" in addition to 11 refueling/maintenance outages. 11 Until four consecutive years of tests are passed, this valve will be tested each refueling outage (i.e., 1 year test interval).

Based on test data review, CPS concludes it has adequate justification to support 2 year test interval RFJ valve testing for all current RFJ valves with the exception of 1E51-F066.

Valve (RFJ#) Test Failure Outage (test type) 1E12-F041 B (RFJ-005) C1 R11 (CC) 1E22-F005 (RFJ-005) C1 R11 (CC) 1E51-F066 (RFJ-002) C1R11 (CC) 1B21-F032A (RFJ-003) C1R11 (CC) 1E21-F006 (RFJ-005) C1R12 (CC) ..

1E22-F005 {RFJ-005) C1R12 (CC) . .

1B21-F032B (RFJ-003) C1 R12 (CC).

1 E51-F066 (RFJ-002) C1 R13 {CC) 1CM067 (RFJ-013) C1 R14 (CC) 1E51-F066 (RFJ:-002) C1R14 (CC) 1E12-F041 B (RFJ-005) C1R14-(CO)

CC= Check Valve Exercise Test- Closed CO =Check Valve Exercise Test - Open RAl-2203-004 ,

Describe hqw testing will change if an RFJ valve that is tested once every 2 years fails a test. The response should specify changes in test frequency and the number of consecutive passed tests required to return the valve to a 2-year test interval (i.e.,

information similar to what was provided for the RC/C system testable check valve above).

EGC Response Testing for RFJ valves that fail under the proposed relief will not change from the process currently used. Currently, if a RFJ valve were to fail, it would be tested during the next outage (i.e., 24 months later). During the proposed "refueling only outage" there is no intent to pertorm maintenance on CSJ/RFJ valves other than stroking the valves as required (i.e., those valves classified as CSJ). If a valve were to fail during stroking, corrective action would be implemented, a post-maintenance test would be pertormed prior to returning the valve to service, and any required increase in testing frequency would be implemented to align with refueling/maintenance outages. There would be no change in test frequency and no defined number of consecutive successful tests required to return to a 24 month frequency. History shows that a 24 month testing frequency has been 11 acceptable for these valves. During refueling only outages," testing certain CSJ/RFJ valvE!S would incur system unavailability and possibly increased shutdown risk. The RCIC testable check valve, 1E51 F066, is an exception since this valve is within part of the reactor pressure vessel (RPV) piping that is removed during RPV disassembly and therefore the opportunity exists to pertorm the test without causing system unavailability or increased shutdown risk to perform the testing.

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VALVE RELIEF REQUEST 2204 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(z)(1)

1. ASME Code Component(s) Affected All ASME Class 1, 2, and 3 motor-operated valves (MOVs) currently included in the Clinton Power Station (CPS) MOV Testing Program.

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," 2004 Edition (ASME OM Code-2004) with the 2006 addenda version of OMN-01.

3. Applicable Code Requirement

CODE CASE OMN-1 (2006 addenda)

Subsection 3.6.1 Normal Exercising Requirements:

All MOVs, within the scope of this Code Case, shall be full-cycle exercised at least once per refueling cycle with the maximum time between exercises to be not greater than 24 months. Full-cycle operation of an MOV, as a result of normal plant operations or Code requirements, may be considered an exercise of the MOV, if documented. If full-stroke exercising of an MOV is not practical during plant operation or cold shutdown, full-stroke exercising shall be performed during the plant's refueling outage.

4. Reason for Request

In accordance with 10 CFR 50.55a(a)(3)(i), relief is requested from the requirements of OM Code Case OMN-01, Subsection 3.6.1. The proposed alternative would provide an acceptable level of quality and safety.

Subsection 3.6.1 requires the applicable valves to be tested each refueling outage not to exceed 24 months. CPS is currently on a 24 month fuel cycle, thus, the applicable valves are currently being tested every 24 months. For financial reasons, CPS will be transitioning to a 12 month fuel cycle beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). Based on the above referenced code case requirements, CPS will be required to test all valves every 12 months. This in effect cuts the allowable testing frequency of these valves in half (i.e., 12 months vs 24 months). This change in outage scheduling and its OM Code implications do not provide a compensating increase in level of quality or safety.

Revision 7 10/21/2016

This relief request is being pursued to maintain the current (i.e., 24 month) exercise frequency for the CPS valves covered by OMN-01. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the 24 month frequency that these valves have historically been tested at during the "refueling/maintenance outage."

5. Proposed Alternative and Basis for Use CPS proposes to continue performing the exercise tests required by Subsection 3.6.1 of OMN-01 for the applicable valves every 24 months, as opposed to the required once per refueling cycle not to exceed 24 months.

By maintaining the current testing frequency at once every 24 months, CPS maintains the current acceptable level of quality and safety with regards to valves covered by OMN-01.

This statement is supported by the years of testing these valves at a 24 month interval.

In summary, CPS is proposing to perform the exercise test for all of the valves covered by OMN-01 every 24 months. This will maintain the current time between tests at two years.

6. Duration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the Third 10-Year IST Interval.

Revision 7 10/21/2016

RAl-2204-001 The requests state that the proposed alternatives are for the third /ST interval at CPS.

Provide the start and end date for the third /ST interval.

Response

CPS is currently in the third IST interval. As documented in Reference 1, the third IST interval started on July 1, 2010 and will end on June 30, 2020.

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ATTACHMENTS RELIEF REQUEST RAls AND SERs Revision 7 10/21/2016

In order to cut down on re-copying already presented data RAls can be found with their associated relief request.

Revision 7 10/21/2016

October 11, 2000 Mr. Mike Reandeau Director - Licensing Clinton Power Station P.O. Box 678 Mail Code #V920 Clinton, IL 61727

SUBJECT:

CLINTON POWER STATION- SAFETY EVALUATION OF RELIEF REQUESTS FOR THE INSERVICE TESTING PROGRAM (TAC NO. MA9263)

Dear Mr. Reandeau:

By letter dated June 14, 2000, you submitted two requests for relief from the inservice testing *

(IST) requirements of the American Society of Mechanical Engineers (ASME)/ American National Standards Institute (ANSI), Operations and Maintenance (OM) Standards, Part 10, for the Clinton Power Station. In the Relief Request (RR) 2201 Revision 0 and RR 2202 Revision 0, you proposed alternatives with regard to performing IST activities on-line or during refueling outages and the use of indirect flow measurements, respectively, for certain pump discharge check valves in the shutdown service water system.

The applicable code of record for the Clinton Power Station IST program is the 1989 Edition of the ASME Boiler and Pressure Vessel (B&PV) Code, Section XI, Subsection IWV, which defers to the requirements of the ASME/ANSI OMa-1988 Standard, Part 10. In RR 2201

• Revision O and RR 2202 Revision O, the licensee proposes the alternatives for use at the Clinton Power Station during the second ten-year IST interval.

The Nuclear Regulatory Commission (NRC) staff has evaluated RR 2201 and 2202 including the.proposed alternatives, and the staff finds that the alternatives provide an acceptable level

• of quality and safety. On this basis, the staff concludes that the proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(i) for use at the Clinton Power Station during the second ten-year IST interval. Our safety evaluation is enclosed.

Sincerely, IRA!

Anthony J. Mendiola, Chief, Section 2 Project Directorate 111 Division of Licensing Project Management Office of Nuclear Reactor Regulation

• Docket No. 50-461

Enclosure:

As stated cc w/encl: See next page

Mike Reandeau Clinton Power Station, Unit 1 Illinois Power Company cc:

Michael Coyle Illinois Department of Nuclear Safety Vice President Office of Nuclear Facility Safety Clinton Power Station ATTN: Mr. Frank Niziolek P.O. Box678 1035 Outer Park Drive Clinton, IL 61727 Springfield, IL 62704 Patrick Walsh Kevin P. Gallen Manager Nuclear Station Morgan, Lewis &. Beckius LLP Engineering Department 1800 M Street, NW Clinton Power Station Washington, DC 20036 P.O. Box678 Clinton, IL 61727 Resident Inspector U.S. Nuclear Regulatory Commission RR#3, Box 229 A Clinton, IL 61727 R. T. Hill Licensing Services Manager General Electric Company 175 Curtner Avenue, M/C 481 San Jose, CA 95125 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Chairman of DeWitt County c/o County Clerk's Office DeWitt County Courthouse Clinton, IL 61727 J. W. Blattner Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603

Mr. Mike Reandeau October 11, 2000 Director - Licensing Clinton Power Station P.O. Box678 Mail Code #V920 Clinton, IL 61727

SUBJECT:

CLINTON POWER STATION-SAFETY EVALUATION OF RELIEF REQUESTS FOR THE INSERVICE TESTING PROGRAM (TAC NO. MA9263)

Dear Mr. Reandeau:

By letter dated June 14, 2000, you submitted two requests for relief from the inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME)/ American National Standards Institute (ANSI), Operations and Maintenance (OM) Standards, Part 10, for the Clinton Power Station. In the Relief Request (RR) 2201 Revision O and RR 2202 Revision 0, you proposed alternatives with regard to performing IST activities on-line or during refueling outages and the use of indirect flow measurements, respectively, for certain pump discharge check valves in the shutdown service water system.

The applicable code of record for the Clinton Power Station IST program is the 1989 Edition of the ASME Boiler and Pressure Vessel (B&PV) Code, Section XI, Subsection IWV; which defers to the requirements of the ASME/ANSI OMa-1988 Standard, Part 10. In RR 2201 Revision O and RR 2202 Revision 0, the licensee proposes the alternatives for use at the Clinton Power Station during the second ten-year IST interval.

The Nuclear Regulatory Commission (NRC) staff has evaluated RR 2201 and 2202 including the proposed alternatives, and the staff finds that the alternatives provide an acceptable level of quality and safety. On this basis, the staff concludes that the proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(i) for use at the Clinton Power Station during the second ten-year IST interval. Our safety evaluation is enclosed.

Sincerely, IRA/

Anthony J. Mendiola, Chief, Section 2 Project Directorate Ill Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosure:

As stated cc w/encl: See next page Distribution:

PD3-2 r/f OGC PUBLIC ACRS GGrant, Riii ACCESSION NO.: ML003759246 *see previous concurrence To rece Ive a copy of t his d ocument, Indi ca t e .m th e b ox: "C" = Copy w1"th ou t enclosures "E" = Copyw1'th encos I ures "N" = No copy OFFICE PM:PD3-2 I E LA:PD3-2 I E OGC I SC:PD3-2 I NAME JHOPKINS THARRIS RHoeflino* AMENDIOLA DATE 10/5/00 10/6/00 9127100 10/6/00 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION AMERGEN ENERGY COMPANY. LLC.

CLINTON POWER STATION DOCKET NO. 50-461

1.0 INTRODUCTION

The Code of Federal Regulations, 10 CFR 50.SSa, requires that inservice testing (IST) of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves are performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (B&PV) Co<;le applicable Edition and Addenda, except where. relief has been requested and granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a(f)(6)(i), or (a)(3}(i), or (a}(3)(ii). In order to obtain authorization or relief, the licensee must demonstrate that (1) conformance is impractical for its facility; (2) the proposed alternative provides an acceptable level of quality and safety; or (3) compliance would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a, the Commission may grant relief from or authorize proposed alternatives to the ASME Code requirements upon making the necessary findings. The Nuclear Regulatory Commission (NRC) staff's findings with respect to the proposed alternatives are contained in this safety evaluation (SE).

2.0 LICENSEE'S RELIEF REQUEST SUBMITTAL By letter dated June 14, 2000, AmerGen Energy Company, LLC, submitted two requests for relief from the IST requirements of the ASME/American National Standards Institute (ANSI),

Operations and Maintenance (OM) Standards, Part 10, for the Clinton Power Station. The applicable code of record for the Clinton Power Station IST program is the 1989 Edition of the ASME B&PV Code, Section XI, Subsection IWV, which defers to the requirements of the ASME/ANSI OMa-1988 Standard, Part 10. In the Relief Request (RR) 2201 Revision 0 and RR 2202 Revision 0, the licensee proposes alternatives with regard to performing IST activities on-line or during refueling outages and the use of indirect flow measurements, respectively, for

• certain pump discharge check valves in the shutdown service water (SX) system. In RR 2201 Revision O and RR 2202 Revision 0, the licensee proposes the alternatives for use during the second ten-year IST interval.

3.0 RR 2201 REVISION 0 ln RR 2201, the licensee requests relief from the requirements of ASME/ANSI OMa-1988 Standard, Part 10, paragraphs 4.3.2.2 (e) and 4.3.2.4 (c), for the SX system pump discharge

check valves 1SX001A and 1SX0018. Paragraphs 4.3.2.2 (e) and 4.3.2.4 (c), provide code alternatives for quarterly IST that require full-stroke exercising and for demonstrating valve obturator movement, respectively, during refueling outages. The licensee requests relief from the requirement to only perform the check valve IST activities during the refueling outages. The licensee proposes to perform a quarterly partial-flow test and a full-flow test or valve disassembly during refueling outages or during reactor operation on an 18-month interval basis.

3.1 Licensee's Basis for Relief The pump discharge check valves do not have external disk position indicators or manual disc exerciser capability, and the use of nonintrusive methods are not practicable because the SX system flow through the 30-inch swing check valves is insufficient to effect a disc backstop impact.

Disassembly of the SX system pump discharge valves is an option only when full-stroke exercising on a quarterly basis is not practicable. Disassembly of the valves requires draining a large volume of coolant from the SX system, which increases the system unavailability and introduces the potential for valve damage during the maintenance.

A system configuration which provides full accident flow through all the safety-related components with the plant on-line is possible. IST of valves 1SX001 A and 1SX001 B in this configuration requires pumping lake water into the fuel pool cooHng and cleaning (FPCC}

system, which is cooled by demineralized water. After completion of the IST activities the lake water must be drained from the from the FPCC system heat exchanger. The drained water must be transferred to 55 gallon drums, and tested for contamination prior to release to the onsite sediment pond. This flow test configuration results in the inoperable of two safety-related coolers. Therefore, performance of this full-flow IST activity on a quarterly basis increases plant risk and decreases system availability.

A quarterly partial-flow test will be continued to demonstrate valve operability. The partial IST flow rate is ~pproximately 85 percent of the full accident flow rate. The additional flow rate required to achieve.the full accident flow is expected to produce a very small change in the disc position because of the size of the valves. The partial-flow test will demonstrate proper valve function.

• The.accident condition flow test or disassembly will be performed on the same frequency as required by the code, except that the test may be performed during reactor operation.

3.2 Proposed Alternative In RR 2201, the licensee's proposed alternative for check valves 1SX001A and 1SX 0018 is to perform a quarterly partial-flow test of the valves during the SX pump operability test, and a full-flow test or disassembly of the check valves either during refueling outages as allowed by the Code or on-line every 18-months.

3.3 Evaluation In RR 2201, the licensee proposes as an alternative for the IST of SX system pump discharge check valves 1SX001A and 1SX001 B, to change the time period for the performance of the IST activities required by ASME/ANSI Standard, Part 10, paragraphs 4.3.2.2 (e) and 4.3.2.4 (c).

Paragraph 4.3.2.2 (e) specifies that if valve quarterly full-stroke exercising is not practicable during plant operation or cold shutdowns, it may be limited to refueling outages. Paragraph 4.3.2.4 (c) allows for valve disassembly to verify operability of the valve during refueling outages, as options to the other methods of demonstrating obturator movement by (a) exercising the valve and observing disc movement by a direct indicator, or other positive means or (b) the use of a mechanical exerciser.

The licensee proposes to continue to perform quarterly partial-flow testing of the valves during the SX pump operability tests and also perform a full-flow test or valve disassembly during refueling outages or on-line in lieu of full-flow testing only during refueling outages.

The staff's evaluation of RR 2201, is based on the licensee's proposed alternative and the following considerations that: 1) full-flow quarterly tests increase risk and decrease availability;

2) the check valves do not have external position indicators or manual exercise capability;

3) the lack of sufficient system flow for achieving a backstop impact diminishes the practical use of nonintrusive methods; 4) a quarterly partial-flow test will be continued at 85 percent of full flow; 5) there are no technical barriers to performing these IST activities either during the refueling outages or on-line; and 6) there are only two valves per fuel cycle that require the performance of the alternative IST activities on-line. Based on its evaluation of the proposed alternative and considerations, the staff finds that the alternative proposed in RR 2201 Revision 0 provides an acceptable level of quality and safety, and is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

4.0 R 2202 REVISION 0 In RR 2202, the licensee requests relief from the requirements of ASME/ANSI OMa-1989 Standard, Part 10, paragraph 4.3.2.4 (a), for the SX system pump discharge check valve 1SX001C. Paragraph 4.3.2.4 (a) requires that the check valve obturator movement be demonstrated by direct observation of position indicating devices, or other by other indicators such as flow rate, level, temperature, seat leakage testing, or other positive means.

4.1 Licensee's Basis for Relief Full-stroke exercising of the SX system pump discharge check valve 1SX001C on a quarterly basis can be satisfied by passing the accident flow rate through the valve by aligning system loads that are the same as the accident conditions. However, the worst case assumption during the accident requires initiating backwash flush through the SX backwash strainer. The SX system flow measured by the installed flow element does not account for the flow diverted to flush the backwash strainer. The backwash strainer flush line that diverts the flow is located upstream of the flow measuring element and downstream of the SX system pump discharge valve 1SX001 C. The piping configuration for the flush line does not allow for installing temporary flow measuring equipment.

Valve 1SX001C does not have an external disc position indicator or manual exerciser capability.

Nonintrusive techniques are not practicable because the flow through the system is not sufficient to cause a disc backstop impact. Therefore, full-stroke position of the obturator cannot be verified by these methods.

Passing design flow to all safety-related components with the backwash system in operation duplicates the worst case conditions assumed during the accident. This IST configuration provides assurance that the check valve will perform its intended function because the teSt exercises the valve obturator to the position required to perform its safety function.

4.2 Proposed Alternative In RR 2202, the licensee proposed as an alternative to perform a full-flow test on a quarterly basis with all accident condition flow aligned to the system. The total flow downstream of check valve 1SX001 C, except for the backwash strainer, will be measured at the installed flow measuring element and confirmed to be at or above the total safety-related design flow.

Concurrent full flow through the backwash strainer will be verified by observing that the strainer motor is operating and the backwash strainer valve is in the open position. The acceptance criteria for the IST of check valve 1SX001 C will be that the flow limit to the safety-related components downstream, excluding the strainer backwash flow, is met or exceeded.

4.3 Evaluation In RR 2202, the licensee requests relieffrom the requirements of ASME/ANSI OMa-1988 Standard, Part 10, paragraph 4.3.2.4 (a), for the SX system pump discharge check valve 1SX001C. Paragraph 4.3.2.4 (a) requires that the necessary valve obturator*movement be demonstrated by exercising the valve and observing the obturator travel by direct indicators, or other positive means. The licensee's proposed alternative for demonstrating the SX system pump discharge check valve obturator movement is to use an indirect flow measurement in lieu of direct indications or other positive means. The licensee proposes to measure the flow downstream of the check valve using the installed flow measuring element, but exclusive of the flow diverted via the strainer backwash drain line to the lake. The strainer backwash drain line is located in the discharge line between the check valve and flow measuring element. In the RR 2202, *the licensee indicates that intermittent flow through the strainer during the backwash cycle increases the flow approximately 200 gpm. The flow from the check valve discharge line that passes through the measuring element discharges directly into system safety-related components.

In RR 2202, the licensee proposes to perform a full-flow quarterly test by passing accident flow through the valve by aligning the system so the flow loads are the same as accident conditions.

In addition to the system loads, the worst case assumption includes initiating backwash through the SX strainer during the accident. In the relief request, the licensee indicates that passing the design flow to all safety-related components while the backwash system is operating duplicates .

the conditions assumed during the accident, therefore it is demonstrated that check valve 1SX001C will perform its safety function.

The licensee's acceptance criteria for the IST is that the flow limit to the safety-related components, excluding strainer backwash flow, will be met or exceeded. The total flow to all safety-related components downstream of check valve 1SX001C, except for the backwash strainer, will be measured at the installed flow measuring element and confirmed to be at or above the total safety-related design flow. Concurrent full flow through the backwash strainer will be verified by observation that the strainer motor is operating and the backwash strainer valve is in the open position.

The staff's evaluation is based on the licensee's proposed alternative and the following considerations that: 1) the flow through a check valve includes worst case accident assumptions; 2) the piping configuration does not provide space to install temporary flow measuring equipment; 3) concurrent full flow through the backwash strainer will be verified by observation of the strainer motor operation and the open position of the strainer valve; and

4) the flow from the SX pump discharge valve will be measured and verified to an acceptance criterion that demonstrates that the flow limit to the connected safety-related components downstream of the measuring element is met or exceeded. Based on its evaluation of the proposed alternative and considerations, the staff finds that the alternative proposed in RR 2202 Revision 0, provides an acceptable level of quality and safety, and is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

5.0 CONCLUSION

The NRC staff concludes that the licensee's alternatives to perform a quarterly partial-flow test and a full-flow test or valve disassembly on-line or during refueling outages on an 18-month basis as described in RR 2201 Revision O and to perform a full-flow quarterly test by passing accident flow rate through the valve by aligning system loads that are the same as accident conditions, including the worst case accident assumption of initiating backwash flow through the SX strainer, as described in RR 2202 Revision 0, are authorized pursuant to 10 CFR 50.55a(a)(3)(i) for use at the Clinton Power Station during the second ten-year IST interval, on the basis that the alternatives provide an acceptable level of quality and safety.

Principal Contributor: F. Grubelich Date: October 11, 2000

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 15, 2015 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1 - REQUESTS FOR ALTERNATIVES FROM ASME OM CODE REQUIRED FREQUENCY (TAC NOS. MF5344 AND MF5345)(RS-14-291 AND RS-14-292)

Dear Mr. Hanson:

By two letters dated December 1, 2014, as supplemented by letters dated March 26 and June 3, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML14335A540, ML14335A541, ML15085A458 and ML15154A957, respectively), Exelon Generation Company, LLC (EGC; the licensee), submitted alternatives to the required refueling outage frequency for cold shutdown justification valves and refueling justification valves, and motor-operated valves (MOV) at Clinton Power Station, Unit 1 (CPS).

The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of relief requests (RRs) 2203 and 2204. The details of the NRC staffs review are included in the enclosed safety evaluation. Accordingly, RRs 2203 and 2204 are authorized pursuant to Title 1o of the .Code of Federal Regulations (1 O CFR), Section 50.55a(z)(1 ), based on the NRC staff's determination that the proposed alternatives provide an acceptable level of quality and safety.

Therefore, the NRC staff authorizes the proposed alternatives in RRs 2203 and 2204 for the third 10-year IST program interval, which began on July 1, 2010 and Is currently scheduled to conclude on June 30, 2020.

B. Hanson If you have any questions, please contact Ms. Eva A. Brown, at 301-415-2315 or via e-mail at eva.brown@nrc.gov.

Sincerely, Benjamin G. Beasley, Acting Branch Chief Plant Licensing 111-2 and Planning and Analysis Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosure:

Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555..0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ALTERNATIVE VALVE TEST FREQUENCY RELIEF REQUESTS 2203 AND 2204 EXELON GENERATION COMPANY. LLC CLINTON POWER STATION. UNIT NO. 1 DOCKET NO. 50-461

1.0 INTRODUCTION

By tWo letters dated December 1, 2014, as supplemented by letters dated March 26, and June 3, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML14335A540, ML14335A541, ML15085A458 and ML15154A957, respectively), Exelon Generation Company, LLC (EGC, the licensee}, submitted alternatives to the required refueling outage frequency for cold shutdown justification and refueling justification valves, and motor operated valves (MOV) at Clinton Power Station Unit, 1 (CPS). The alternatives are necessary due to the licensee transitioning the refueling outage (RFO) periodicity from 24 to 12 months.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(z)(1), the licensee proposed alternatives for relief requests (RRs) 2203 and 2204 on the basis that the alternatives provide an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

Section 50.55a(z}(1) to 10 CFR requires that inservice testing (IST) of certain American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) Class 1, 2, and 3 valves be performed in accordance with the specified ASME OM Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to paragraphs (z)(1) or (z)(2) of

• 10 CFR 50.55a. In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety (1 O CFR 50.55a(z)( 1)) or that compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety ( 10 CFR 50.55a(z)(2)).

Section 50.55a(f) to 10 CFR requires, in part, that IST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs 10 CFR 50.55a(z)(1) or 10 CFR 50.55a(z)(2).

Enclosure

Relief requests 2203 and 2204, dated December 1, 2014, cited 10 CFR 50.55a(a)(3)(i), which covered RRs for alternatives on the basis that the proposed alternative would provide an acceptable level of quality and safety. On December 5, 2015 the NRC reorganized 10 CFR 50.55a (79 FR 214), and RRs that had been previously covered by 10 CFR 50.55a(a)(3)(l) are now covered under the equivalent 10 CFR 50.55a(z)(1).

The ASME OM Code establishes the requirements of preservice and IST and examination of certain components to assess their operational readiness in light-water reactor nuclear power plants. It identifies the components subject to test or examination, responsibilities, methods, intervals, parameter to be measured and evaluated, criteria for evaluating the results, corrective action, personnel qualification, and record keeping. These requirements apply to pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

• The proposed alternatives are for the CPS third 10-year ISTprogram interval, which began on July 1, 2010, and is currently scheduled to conclude on June 30, 2020.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternative requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Alternative Request 2203 ASME OM Code (ISTC) Requirements:

ISTC-3521(e), "Category A and Category B Valves," states that if exercising is not practicable during operation at power or cold shutdowns, it may be limited to full stroke during refueling outages.

ISTC-3521(h), "Category A and Category B Valves," states that all valve testing required to be performed during a refueling outage shall be completed before returning the plant to operation at power.

ISTC-3522(c), "Category C Check Valves," states If exercising is not practicable during operation at power and cold shutdowns, it shall be performed during refueling outages.

ISTC-3522(f), "Category C Check Valves," states all valve testing required to be performed during a refueling outage shall be completed before returning the plant to operation at power.

Alternative testing is requested for all ASME Class 1, 2, and 3 valves listed in CPS IST program Cold Shutdown Justification (CSJ) and Refuel Justification (RFJ) section 4 attaehments.

The licensee states in p~ut:

Reason for Request

In accordance with 10 CFR 50.55a(z)(1 ), relief is requested from the requirements of the OM Code, Subsection ISTC-3521(e), ISTC-3521(h), ISTC-3522(c) and ISTC-3522(f). The proposed alternative would provide an acceptable level of quality and safety.

These sections require CSJ and RFJ valves to be tested each refueling outage. CPS is currently on a 24-month fuel cycle, thus, CSJ and RFJ valves are currently tested every 24 months. For financial reasons, CPS will be transitioning to a 12-month fuel cycle*

beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). Based on the above referenced code requirements, CPS will be required to test all CSJ and RFJ valves every year. This in effect cuts the testing frequency of these valves in half (i.e., 1 year vs 2 years). This change in outage scheduling and its OM Code implications do not provide a compensating increase in level of quality or safety.

This RRs '1s being pursued to maintain the current (i.e., 2-year) testing frequency for the CPS CSJ and RFJ valves. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the two year frequency that these valves have historically been tested at during the "refueling/maintenance outages."

Proposed Alternative CPS proposes to continue testing CSJ and RFJ valves every two years with the CSJ valves being tested during all cold shutdowns lasting longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and continuing until the plant is ready to return to operation at power per ISTC-3521(g) and ISTC-3522(e).

Based on the current outage plans, CPS proposes treating the "refueling only outage" as a cold shutdown in accordance with OM Code requirements and not a refueling outage.

This will maintain the current time between tests at every 2 years for the CSJ and RFJ valves. *

• CPS currently maintains a list of all CSJ valves that are eligible for testing during an extended cold shutdown (i.e., greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). This list is provided to Operations and Outage Planning before each planned outage and within one shift in the case of a forced outage. From this list, Operations selects the valves to be tested during the course of the outage. Engineering coordinates with Operations to ensure testing of CSJ valves is consistent with the guidance provided in Section 3.1.1.1 of NUREG 1482, Revision 2.

The OM Code permits the testing of valves to be deferred to cold shutdown or refueling outages based on practicality. The CPS valves currently classified as RFJ valves have been tested each refueling outage in accordance with the requirements of the OM Code.

In response to NRC request for additional information, CPS has reviewed the test history for the RFJ valves to determine if test failures would indicate that more frequent testing of these valves would ensure more reliable performance.

After reviewing the test history for all 70 current RFJ ~alves for the past 6 RFOs (i.e., 2003 (C1 R09) 2013 (C1 R14)), a total of 11 unsatisfactory tests were identified involving 7

• different valves. The valves that had an unsatisfactory test are listed in the table below organized by the outage that the failure occurred in. .*

Valve (RFJ#) Test Failure OutaQe {test tvoe) 1E12-F041 B !RFJ-005) C1R11 (CC 1E22-F005 (RFJ-005) C1R11 <CC) 1E51-F066 (RFJ-002) C1R_t1 (CC) 1B21-F032A (RFJ-003) C1R11(CC 1E21-F006 (RFJ-005) C1R11 (CC 1E22-F005 (RFJ-005) C1R11 (CC) 1821-F032B (RFJ-003) C1R11 (CC) 1E51-F066 (RFJ-002) C1R11 (CC) 1CM067 <RFJ-013) C1R11 (CC) 1E51:..f066 (RFJ-002) C1R11 (CC 1E12-F0418 (RFJ-005) C1R11 (CO

=

CC Check Valve Exercise Test - Closed

=

CO Check Valve Exercise Test- Open .

The other 63 valves have satisfactory test history that supports their continued testing on a

• 2-year test interval. Of the 7 valves that experienced an unsatisfactory test, 4 valves

. experienced one failure, 2 valves experienced two failures, and 1 valve was found to have experienced three failures. By virtue of no reoccurring failures, it has been demonstrated that the corrective actions taken with the 4 single failure valves have fixed their issues.

The reactor pressure excess flow check valve 1CM067, which experienced a failure in C1 R14 (2013), v.ias replaced with a new valve.

Low pressure coolant injection testable check valve (i.e., 1E12-F0418} has experienced 2 failures, one on its open test and one on its close test. The open test issue found the packing gland out of alignment. This was repaired in C1R14. In C1R11 (2008), the closed test found the clearances between the disk and the valve body to be out of toleran~. The disk hole was re-bored to align the disk and body in C1 R11. No repeat close test failure has occurred since C1R11.

High pressure core spray system testable check valve (i.e .* 1E22-F005) had back to back .

failures of its check closed test, one in C1 R11 and again in C 1R12 "(201.0}. Each time, repair work orders where completed. In C1R11 the valve was disassembled, no issues noted, the valve was reassembled, and passed its post-maintenance testing (PMT). In C1R12 it was disassembled and noted there were out of tolerance gaps between the valve disk and body. This was corrected under the repair work order and no repeat failure has occurred since C1R12.

Reactor core isolation cooling (RCIC) system testable check valve (i.e., 1E51-F066) has experienced multiple failures with the last two in consecutive outages. This valve is in a position to be tested during "refueling only outages" in addition to "refueling/maintenance outages." Until four consecutive years of tests are passed, this valve will be tested each refueling outage (i.e., 1 year test interval).

During the proposed "refueling only outage" there is no intent to perlorm maintenance on CSJ/RFJ valves other than stroking the valves as required (i.e. those valves classified as CSJ). If a valve were to fail during stroking, corrective action would be implemented and a post maintenance test would be perlormed prior to returning the valve to service. There would be no change in test frequency and no defined number of consecutive successful tests required to return to a 24 month test frequency. History shows that a 24-month testing frequency has b~en acceptable for these valves.

By maintaining the current testing frequency, CPS maintains the current acceptable level of quality and safety with regards to the CPS RFJ valves. This change in outage schedules will also increase the level of quality and safety for the CPS CSJ valves due to the planned outage in between the "refueling/maintenance outages" that wiU provide time to perform some of the CSJ valve testing. This statement is supported by the years of testing these valves at a 24-month interval.

In summary, CPS is proposing to test all of its CSJ and RFJ valves every 2 years during the "refueling/maintenance outages" and continue testing the CSJ valves as time allows during the "refueling only outage" to satisfy the requirements of ISTC-3521 (g) and ISTC-3522(e). This will maintain the current time between tests for the CSJ and RFJ valves at a maximum of 2 years.

The proposed alternative identified in this relief request shall be utilized during the third 10-Year IST interval.

3.1.2

• NRC Staff Evaluation In the submittal, the licensee indicated that CPS is currently on a 24-month refuel cycle, but is in .

the process of transitioning to a 12-month refueling cycle. The licensee Indicated that the reason for the change was that that a 12-month refueling cycle with an alternating urefueling only outage" followed by a "refueling/maintenance outage" cycle would be financially beneficial.

The ASME OM Code recognizes that not every valve can meet the nominal exercise frequency every 3 months due to the exercise not being practicable during normal plant operation. The ASME OM Code allows extension of the exercise requirement to be perlormed during a cold shutdown event. Valve exercising shall commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving cold shutdown and continue until all testing is complete or the plant is ready to return to operation at power. If valve exercising is not practicable during a cold shutdown then exercising will be limited to refueling outages. All valve tests required to be performed during a refueling outage shall be completed before returning the plant to operation at power.

Section ISTC of the ASME OM Code delineates the requirements for IST of valves in light-water reactor nuclear power plants. The valve testing requirements outlined in section ISTC-3500 of the ASME OM Code can be simply stated as:

Exercise Test (nominally every 3 months)

Leakage Test (nominally once every 2 years)

Valve Obturator Movement (verify during exercise test)

Fail-Safe Actuators (verify during exercise test)

Remote Position Indicator Test (nominally once every 2 years)

In lieu of this requirement, the licensee has proposed an alternative. A 12-month refuel cycle would require all ASME OM Code valve exercise tests that have been justified to be extended to be completed prior to returning the plant to operation at power. CPS proposes to continue testing CSJ and RFJ valves every two years with the CSJ valves being tested during all cold shutdowns lasting longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and continuing until the plant is ready to return to operation at power per ISTC-3521 (g) and ISTC-3522(e).

The NRC staff reviewed the proposed valve scheduling during cold shutdowns longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and valve maintenance history to ensure that the licensee's program will not allow CSJ valves to exceed the 24* month test interval. The NRC staff questioned how the licensee determines scheduling for the CSJ valves during the shorter ~refueling only" outages. In the supplement dated March 26, 2015, the licensee indicated that based on the current outage plans, CPS proposes treating the "refueling only outage" as a cold shutdown in accordance with OM Code requirements and not a refueling outage. Valve selection for testing will be in accordance with the guidance of NUREG-1482 Revision 2 section 3.1.1.1 "IST Cold Shutdown Testing". The NRC staff finds that use of this guidance should ensure that the valves tested in the preceding cold shutdown are the last valves tested during the next cold shutdown with the exception of valves that must be tested during each cold shutdown.

The NRC staff reviewed the proposed testing for the RFJ valves to assess the effectiveness of the proposed test*interval. The NRC staff questioned the maintenance history for the affected valves to assess whether sufficient reliability would be maintained. In the supplement dated March 26, 2015, the licensee indicated that based on the maintenance history 70 valves that have been designated as RFJ valves will maintain their current 24 month test interval with the exception of Reactor Core Isolation Cooling system testable check valve 1E51-F066. This valve has experienced multiple failures with the last two consecutive outages. Corrective maintenance has been performed on this valve. To verify that the corrective maintenance action is effective, CPS proposes to maintain testing check valve 1E51-F066 during each "refueling only outage" and "refueling/maintenance outage" interval until four successful consecutive years of tests are completed. Upon completion, check valve 1 E51-F066 will return to the normal 24 month test interval.

The NRC staff reviewed the maintenance history for 70 RFJ valves to determine whether some valves would benefit from the ASME OM Code required interval test frequency. The NRC staff found that the licensee's corrective maintenance has been sufficient to address almost all identified performance issues for valve IE51-F066, and therefore concludes that maintaining the 24 month test interval for the 70 RFJ valves is acceptable.

Based on the satisfactory maintenance history and valve scheduling for RFJ and CSJ valves, the NRC staff has determined that the alternative provides an acceptable level of quality and safety.

3.2.1 Licensee's Alternative RR 2204 ASME OM Code Requirements:

ASME OM Code Case OMN-1 "Alternative Rules for Preservice and lnservice Testing of Active Electric Motor-Operated Valve Assemblies In Light-Water Reactor Power Plants" Subsection 3.6.1, "Normal Exercising Requirements," states that all MOVs, within the scope of this Code Case, shall be full-cycle exercised at least once per refueling cycle with the maximum time between exercises to be not greater than 24 months. Full-cycle operation of an MOV, as a result of normal plant operations or Code requirements, may be considered an exercise of the MOV, if documented. If full-stroke exercising of an MOV is not practical during plant operation or cold shutdown, full-stroke exercising shall be performed during the plant's refueling outage.

Alternative testing ls requested for all ASME Class 1, 2, and 3 MOVs currently included in the CPS MOV testing program.

The licensee states:

Reason for Request

In accordance with 10 CFR 50.55a(z)(1), relief is requested from the requirements of OM Code Case OMN-1, Subsection 3.6.1. The proposed alternative would provide an acceptable level of quality and safety.

• Subsection 3.6.1 requires the applicable valves to be tested each refueling outage not to exceed 24 months. CPS is currently on a 24 month fuel cycle, thus, the applicable valves are currently being tested every 24 months. For financial reasons, CPS will be transitioning to a 12 month fuel cycle beginning In the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e.,

"refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages").

Based on the above referenced code case requirements, CPS will be required to test all valves every 12 months. This in effect cuts the allowable testing frequency of these valves in half (I.e., 12 months vs 24 months). This change in outage scheduling and its OM Code implications do not provide a compensating increase in level of quality or safety.

This relief request is being pursued to maintain the current (i.e., 24 month) exercise frequency for the CPS valves covered by OMN-01. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the 24 month frequency that these valves have historically been tested at during the "refueling/maintenance outage."

Proposed Alternative CPS proposes to continue performing the exercise tests required by Subsection 3.6.1 of OMN-1 for the applicable valves every 24 months, as opposed to the required once per refueling cycle not to exceed 24 months.

By maintaining the current testing frequency at once every 24 months, CPS maintains the current acceptable level of quality and safety with regards to valves covered by OMN-1.

This statement is supported by the years of testing these valves at a 24 month interval.

In summary, CPS is proposing to perform the exercise test for all of the valves covered by OMN-1 every 24 months. This will maintain the current time between tests at 2 years.

3.2.2 NRC Staff Evaluation The ASME OM Code establishes the requirements of preservice and IST and examination of certain components to assess their operational readiness in light-water reactor nuclear power plants. It identifies the components subject to test or examination, responsibilities, methods, intervals, parameter to be measured and evaluated, criteria for evaluating the results, corrective action, personnel qualification, and record keeping. These requirements apply to pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

Section ISTC-3500 of the ASME OM Code delineates the valve testing requirements, which can be simply stated as:

a) Exercise Test (nominally every 3 months) b) Leakage Test (nominally once every 2 years) c) Valve Obturator Movement (verify during exercise test) d) Remote Position Indicator Test (nominally once every 2 years)

In lieu of the testing requirements of section ISTC of the ASME OM Code, the licensee may implement an alternative provided that the test method has been authorized by NRC staff per 10 CFR 50.55a(z)(1) or 10 CFR 50.55.a(z)(2). Previously, CPS requested and was authorized to use alternative ASME OM Code case OMN-1 on June 10, 2010 (ADAMS Accession No. ML101340691 ). ASME OM Code Case OMN-1 expands the testing requiremen~s to include static and dynamic diagnostic testing of MOVs. The use of diagnostics offers a more comprehensive evaluation of the components health and provides engineering justification for.

extending test intervals. The MOV testing requirements of ASME OM Code Case OMN-1 can be simply stated as:

a) One time design basis verification test b) MOV exercise (once per refuel cycle not to exceed 24 months) c) Diagnostic test (mix of static and dynamic until appropriate test interval is set)

The June 2010, approval allows the licensee to replace the requirements of ASME OM Code Case OMN-1 with the exception of the leakage test requirements.

The NRG staff reviewed the submittal to assess whether the MOV diagnostic test interval remained appropriate. The NRC staff recognizes that the MOV exercise. is not considered to be part of the diagnostic test. It is a preventive maintenance action to maintain proper lubrication of the internal moving parts with the requirement to complete the exercise once every 2 years.

Calculations for determining MOV functional margin shall account for. potential performance related degradation. Maintenance activities and associated intervals. can affect test intervals

and shall be considered. The inservice diagnostic test interval shall be set such that the MOV functional margin does not decrease below acceptance criteria.

Based on the ASME OM Code case OMN-1 permitting the MOV exercise interval to not exceed 24 months and the licensee assertion that the current level of quality and safety will be maintained, the NRC staff finds that maintaining the MOV exercise test interval at 24 months continues to be sufficient to account for potential performance related degradation. Therefore, the NRC staff find:; that the alternative provides an acceptable level of quality and safety.

4.0 CONCLUSION

As set forth above, the NRC staff finds that the proposed alternative described in request 2203 provides an acceptable level of quality and safety for all ASME Class 1, 2, and 3 valves listed in CPS IST program CSJ and RFJ section 4 attachments. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1).

As set forth above, the NRC staff finds that the proposed alternative described in request 2204 provides an acceptable level of quality and safety for all ASME Class 1, 2, and 3 MOV currently .

included in the CPS MOV testing program. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ).

All other ASME OM Code requirements fo*r which relief was not specifically requested and approved in the subject requests for relief remain applicable. *

• Therefore, the NRC staff authorizes the proposed alternatives In RRs 2203 and 2204 for the third IST interval at CPS which began on June 15, 2010, an.dis currently scheduled to end on June 14, 2020 .

. Principle Contributor: Michael Farnan, NRR Date of issuance: July 15, 2015

ML15180A407 *b>V memo OFFICE DORULPL3-2/PM DORULPL3-2/LA EPNB/BC* DORULPL3-2/BC NAME EBrown SRohrer DAiiey BBeasly DATE 7/9/15 7/1/15 6/11/15 7/15/15 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 11, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer (CNO)

Exelon Generation Company, LLC Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT 1 -CORRECTION LETTER FOR SAFETY EVALUATION FOR ALTERNATIVES FROM ASME OM CODE REQUIRED .

FREQUENCY (TAC NOS. MF5344 AND MF5345)(RS-14-291 AND RS-14-292)

Dear Mr. Hanson:

• By letters dated December 1, 2014, as supplemented by letters dated March 26, and June 3, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML14335A540, ML14335A541, ML15085A458 and ML15154A957, respectively) Exelon Generation Company, LLC (EGC), submitted alternatives to the required refueling outage frequency for cold and refueling shutdown justification valves, and motor operated valves at Clinton Power Station, Unit 1. On July 15, 2015, the U.S. Nuclear Regulatory Commission (NRC) staff issued a*safety evaluation (SE) approving the proposed alternatives. On July 23, 2015, Mr. Timothy Byam notified the NRG staff of a minor error in the SE. The Table on page 4 of the SE should be corrected as follows to reflect the appropriate outages for the identified test failures.* The changes to the table below are in bold:

Valve (RFJ#) Test Failure Outage (test tvpe) 1E12-F041B {RFJ-005) C1R11 (CC) 1E22-F005 (RFJ-005} C1R11 (CC) 1E51-F066 (RFJ-002) C1R11 (CC) 1821-F032A (RFJ-003). C1R11 (CC) 1E21-F006 (RFJ-005) C1R12 (CC}

1E22-F005 (RF J-005) C1R12 (CC) 1821-F0328 (RFJ-003) C1R12 (CC) 1E51-F066 (RFJ-002) C1R13 (CC) 1CM067 CRFJ-013) C1R14 (CC) 1E51-F066 (RFJ-002) C1R14 (CC) 1E12-F041 B {RFJ-005) C1R14 (CO)

B. Hanson These corrections do not alter any findings or conclusions Sincerely, IRA/

Eva A. Brown, Senior Project Manager Plant Licensing 111*2 and Planning and Analysis Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461 cc w/encl: Distribution via Listserv

ML15212A916 NRR-028 OFFICE LPL3-2/PM LPL3-2/LA EPNB/BC LPL3-2/BC(A)

NAME EBrown SRohrer DAl!ev BBeasley (BPurnell For)

DATE 8/6/15 8/06/15 8/10/15 8/11/15 ATTACHMENT 7 CODE CASE INDEX Revision 7 10/21/2016

. CODE CASE TITLE NUMBER OMN-1 Alternative Rules for Preservice and lnservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants OM Code-1995, Subsection ISTC Revision 7 10/21/2016

ATTACHMENT 8 COLD SHUTDOWN JUSTIFICATION INDEX Revision 7 10/21/2016

COLD SHUTDOWN JUSTIFICATION INDEX 1B21-F022A, 1B21-F022B, 1B21-F022C, 1821-F022D, 1B21-F028A, 1B21-F028B, 1B21-F028C, 1821-F028D:

Main Steam Isolation Valves (MSIV's)

CSJ-102 1RE019 & 1RF019 - Drywell Isolation Valve Testing Impractical on Quarterly Basis CSJ-103 1SA032 Service air inboard isolation valve CSJ-104 1VR006A/B, 1VR007A/B, 1VR035, 1VR036, 1VR040, 1VR041 1VQ003 Containment HVAC valves CSJ-105 1E 12-FOSOA, 1E 12-FOSOB, 1E51-F066 PIV check valves CSJ-106 1IAOOS, 1IA006, 1IA007, 1 IAOOB: Instrument Air System Isolation Valves CSJ-107 1VQ004A, 1VQ004B, 1VR001 A, 1VR001 B: Containment Ventilation and Purge CIV's CSJ-108 1E31-F014,15,17,18; 1E51-F063, 64 Containment and/or Drywell Isolation Valves CSJ-109 Deleted CSJ-110 1E51-F065: RCIC Injection Line Check Valve CSJ-111 1E12-F042A, 1E12-F042B, 1E12-F042C, 1E21-F005, 1E22-F004, 1E51-F013: RCS PIVs CSJ-112 1G33-F001, 1G33~F004: Reactor Water Cleanup system Cl Vs CSJ-113 1IA012A,1 IA013A: Instrument Air Containment Isolation valves CSJ-114 Deleted CSJ-115 1833-F019, 1833-F020: RR Sample Line Drywell Isolation Valves CSJ-116 1PS004/9/16/22/31/34/37/56/70: PASS Inboard Containment Isolation Valves.

CSJ-117 1821-F016/19: Main Steam Line Drain Valves CSJ-118 1SX346A/B: VX Inlet Vacuum Breakers Revision 7 10/21/2016

ATTACHMENT 9 COLD SHUTDOWN JUSTIFICATIONS Revision 7 10/21/2016

Cold Shutdown Justification CSJ-101 Valve Number System Safety Class Category 1B21-F022A MS 1 A 1B21-F022B MS 1 A 1B21-F022C MS 1 A 1B21-F022D MS 1 A 1B21-F028A MS 1 A 1B21-F028B MS 1 A 1B21-F028C MS 1 A 1B21-F028D MS 1 A Function.: . The Main Steam Isolation Valves (MSIV's) are normally open valves that close to isolate containment from the main steam system .

Basis for . Full stroke exercising the Main Steam Isolation Valves for the Justification: purposes of meeting lnservice Testing Program requirements; is defined as verifying that the valves will fully close in 3 to 5 seconds. Paragraph 2.4.5 of NUREG 1482, Rev. 1, identifies impractical conditions that justify test deferrals including that performing this testing quarterly during normal operation would, increase the possibility of main steam line isolation due to high flow in the other lines and could cause a Reactor scram at full power.

Alternate Test: These valves will receive a partial-stroke test as described above on a quarterly basis, and will be full-stroke exercised during Cold Shutdowns.

Revision 7 10/21/2016

Cold Shutdown Justification CSJ-102 Valve Number System Safety Class Category 1RE019 RE 2 B 1RF019 RF 2 B Function: 1RE019 - Drywall RE Inboard Isolation Control Valve - This valve must close to isolate the drywall from the equipment drain system during emergency and accident conditions.

1RF019 - Drywell RF Inboard Isolation Control Valve - This valve must close to isolate the drywall from the floor drain water system

• during emergency and accident conditions.

Basis for

• These normally open air operated valves have a safety function to Justification:* provide drywell isolation in the event of an accident. They are normally open to allow pumping down and processing the drywell floor and equipment drains sumps during normal operation. Failure of these inaccessible valves during the quarterly test could result in an unnecessary shutdown since the drywall floor/equipment drain

. sumps would not be able to be pumped down for processing.

Based on *the above, these Valves are impractical to test on a quarterly bases as per NUREG 1482, Section 3.1.1.

Th~se valves have no open safety function.*

Alternate Test: The Drywall Isolation valves 1RE019 and1 RF019 will be fail safe tested to the closed position during Cold Shutdown.

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Cold Shutdown Justification CSJ-103 Valve Number System Safety Class Category 1SA032 SA 2 B Function: Valve 1SA032 is the drywall Service Air Inboard Isolation Valve. It must close to isolate the drywell from the service air system during emergency and accident conditions requiring drywell isolation.

Basis for Valve 1SA032 is the drywall Service Air inboard Isolation Valve. It Justification: is required to automatically close within 10 seconds upon receipt of an automatic isolation signal to isolate the drywall from the service air system. It is the drywell isolation val~e for Penetration 1MD-059

[P&ID MOS-1048 Sheet 6]." This valve fails closed on loss of air or electrical power and may be remotely closed by the operator. It forms a part of the drywall boundary. There are requirements that limit total drywall bypass leakage. There are, however, no specific requirements for seat leakage for individual valves [ITS B 3.6.5.3].

This valve opens to provide a flow path for Service Air to the drywall hose stations. This is not a safety function and is not required during normal power operation. During normal power operation the drywall is inaccessible and the hose stations this valve supplies are not used.

The closing safety function for 1SA032 is limited to operating modes 1, 2 and 3. (Ref. Tech Spec 3.6.5.3) Since Service Air through this valve* is not required during Modes 1, ~ and 3, the only time it is cycled is during quarterly stroke time testing. Exercising this valve increases the potential for air leakage inside the drywall with subsequent drywall pressurization. This could increase the frequency for venting the drywall resulting in cycling of the hydrogen mixing compressors and unnecessarily reduce their life expectancy.

Step 8.3, Drywall Venting, of CPS procedure 3316.01, states that each hydrogen mixing compressor should not be run for more than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per month to prevent exceeding the expected 40 year life runtime. In addition, leakage resulting from stroke time testing could require a plant shutdown to implement repairs. This concern would be exacerbated by other conditions inside the drywall also contributing to drywall pressurization that were already existent at the time of the stroke time test.

Revision 7 10/21/2016

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The possibility of stroke time testing resulting in air leakage is documented on IR 519897, issued on 8/14/06. IR 519897 identified a condition of a potential air leak on one or both air operated drywall isolation valves 1VQ002 and 1VQ003. In this event, the frequency of drywall venting increased following IST surveillance* testing in accordance with 9061.03C005. The issue report identified that following valve stroking the venting frequency increased from once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A number of IRs have been generated over the past year as a result of the hydrogen mixing compressors exceeding the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> run time identified in procedure 3316.01.

In addition to the above, instrument air valve 1IA818 in the supply line to the actuator will be maintained in the closed during MODEs 1, 2 and 3. The solenoid valve to the actuator will remain energized because 1SA032 shares a hand switch With containment isolation valve 1SA029, which is maintained in the open position during normal power operation. Since the actuator spring closes, isolating air to its actuator will not impact the Closing safety function for the valve. Therefore although 1SA032 will not be secured in its closed

. safety position, it is *expected it will be.in its closed safety position if called upon fo perform is closing safety function.

Paragraph 2.4.5 of NUREG 1482, Rev. 1, *identifies* impractical conditions justifying test deferrals include those conditions which could cause an unnecessary plant shutdown, cause. unnecessary cycling of equipment or unnecessarily reduce the life expectancy of the plant systems and components. Based on the above discussion and NU REG 1482 quarterly stroke time testing of 1SA032 is considered impractical.

Alternate Test: Valve 1SA032 will be exercise tested closed during Cold Shutdown.

Revision 7 10/21/2016

Cold Shutdown Justification CSJ-104 Valve Number Svstem Safety Class Category 1VR006A/B, VR 2 B 1VR007A/B, 1VR035, 1VR036, 1VR040 1VR041 1VQ003 VQ 2 B Function: 1VR006A. - Continuous* CNMT HVAC Supply Outboard Isolation -

This valve must close to isolate containment from the continuous containment purge system during emergency and accident conditions.

1VR006B - Continuous CNMT HVAC Supply Inboard isolation - This valve must close to isolate containment from the continuous containment purge system during emergency and accident conditions.

• 1VR007 A - CCP Outboard Exhaust Isolation Valve - This valve must close to isolate containment from the continuous containment

• purge system during emergency and accident conditions.

1VR007B - CCP Inboard Exhaust Isolation Valve - This valve must close to isolate containment from the continuous containment purge system during emergency and accident conditions.

1VR035 - 1PDCVR020 Air Line Isolation Valve - This valve must close to isolate containment from the containment building ventilation system during emergency and accident conditions.

1VR036 - 1PDCVR020 CNMT Purge Air Line Isolation Valve - This valve must close to isolate containment from the containment building ventilation system during emergency and accident conditions.

1VR040 - CCP Air Line Isolation Valve - This valve must close to isolate containment from the containment building

• ventilation system during emergency and accident conditions.

1VR041 - 1TSVR166 Isolation Valve - This valve must close to isolate containment from the containment building ventilation system during emergency and accident conditions.

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1VQ003 - Exhaust Outboard Drywall Isolation Valve - This valve must close to isolate the drywell from the primary containment purge system during emergency and accident conditions.

Basis for Valves 1VR006A/B are containment isolation valves on the CCP Justification: inlet to containment. They are normally open to support continuous containment purge (CCP). CCP is used during normal operation to maintain primary to secondary containment differential pressure within Tech Spec limits. A failure of one of them to close during stroke time testing would require the penetration to be administratively isolated, resulting in loss of CCP System function.

Likewise a failure of the valve to open following stroke time testing would result in the loss of CCP System function.

Valves 1VR007A/B are normally open containment isolation valves on the outlet side of the CCP System. A failure of one of them to close during stroke time testing would require the penetration to be administratively isolated, resulting in loss *of system function.

Likewise a failure of the valve to open following stroke time testing would result in the loss of CCP System function.

Valves 1VR036 and 1VR037 are solenoid valves that provide containment isolation for instrument air lines supplying valves 1VR006A/7A. Valves 1VR035 arid 1VR040 are solenoid valves that provide containment isolation for instrument air lines supplying valves 1VR0068/78. A failure of one of these valves during testing would require the penetration t.o be administratively isolated resulting in one of the 1VR006A/B or 1VR007A/B valves closing due*

to loss of air. Consequently failure of one of these valves could result in loss of the CCP System function.

1VQ003 is a normally open drywall isolation valve. This valve is required to automatically close on a drywall isolation signal. This valve is located in the main flow path for the CCP System. If the.

valve failed closed during stroke time testing, CCP operation would be interrupted until the valve could be repaired and reopened. The inboard CCP drywall isolation valves are maintained in the closed position during MODES 1, 2 and 3.

Loss of the CCP system function could result in a plant shutdown.

CCP is used during normal operation to maintain primary to secondary containment differential pressure within Tech Spec limits.

Tech Spec 3.6.1.4 requires the primary containment to secondary containment differential pressure to be ~ -0.25 psid and ~ 0.25 psid ..

If these differential pressure limits are not maintained, there is a 1 hr time limit for restoring them. If the limits are not restored within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, there is a 12 hr time limit for being in MODE 3 and a 36 hr Revision 7 10/21/2016

time limit for being in MODE 4. According to Operations personnel there is no standard alternate method for returning the differential pressure to within limits and it may be difficult to maintain the Tech Spec required primary containment to secondary containment differential pressure if the CCP System is not available. Therefore stroke time testing could result in an unnecessary plant shutdown.

As such, these valves are impractical to test on a quarterly basis per paragraph 2.4.5 of NUREG 1482 because testing them could result in an unnecessary plant shutdown.

Alternate Test: The valves included in this cold shutdown justification will be exercise tested closed during Cold Shutdown Revision 7 10/21/2016

Cold Shutdown Justification CSJ-105 Valve Number System Safety Class Category 1E12-F050A RH 2 A/C 1E12-F050B RH 2 A/C 1E51-F066 RI *1 A/C Function: These check valves are Reactor Coolant Pressure Boundary.

They are required to close to limit leakage between the high pressure Reactor Coolant System and connected systems (RHR and RCIC) in a LOCA.

Basis for These check valves are Reactor Coolant Pressure Boundary.

Justification: They are required to close to limit leakage between the high pressure Reactor Coolant System and connected systems (RHR and RCIC) in a LOCA. It is not practical to perform a full or partial exercise test of these valves quarterly during normal operation.

Opening these valves at power would remove one of the two valves in its respective line from performing its PIV function. If the second valve was in a degraded condition, this could create a pressure spike throughout the system, since each system is maintained filled and pressurized. Depending on the severity of the pressure spike, this could result in an inter-system LOCA with the potential for release of reactor coolant outside the primary containment. . This is considered an impact as per NUREG 1482, R/1, 3.1.1.

Alternate Test: Closure for these valves will be performed during cold shutdown conditions. Additional assurance of proper closure is provided by performance of leak rate testing during refueling outages.

NOTE: Bi-directional exercising in the non-safety related open direction is performed at the same frequency for valves 1E12-F050A and B.

Revision 7 10/21/2016

Cold Shutdown Justification CSJ-106 Valve Number System Safety Class *Category 11A005 IA 2 A 11A006 IA 2 A 11A007 IA 2 B 11A008 IA 2 B Function: Instrument Air System Isolation Valves that are Drywall and Containment Isolation Valves (CIVs).

Basis for These are the Containment and Drywall Isolation Valves for the Justification: Instrument Air System. Exercising these valves quarterly during normal operation would interrupt the air supply to IA System loads Inside Containment, including the MSIV and SRV accumulators, several safety-related air operated isolation valves, and various pneumatic instruments. Repeated pressure fluctuations or the inability to reopen one of these valves following testing would cause a Reactor scram and forced shutdown of the Plant. This would be impractical as p~r NUREG 1482, R/1 2.4.5 and 3.1.1.

The pneumatic actuators for these valves are designed to provide full-stroke capability only; partial-stroke testing is not available.

Alternate Test: These valves will be exercise tested to the closed position during Cold Shutdowns.

Revision 7 10/21/2016

Cold Shutdown Justification CSJ-107 Valve Number System Safety Class Category 1VQ004A VQ 2 A 1VQ0048 VQ 2 A 1VR001A VR 2 A 1VR0018 VR 2 A Function: 1VQ004A/B - These drywell purge containment isolation valves close to isolate containment from the primary containment purge system during emergency and accident conditions.

1VR001 A/8 - These valves close to isolate containment from the containment building ventilation system during emergency and accident conditions.

Basis for These are 36-inch air-operated butterfly Containment Isolation Justification: Valves in the Containment Ventilation and Containment/Drywell Purge Systems. They are required by Technical Specification 3.6.1.3 to be maintained closed in Modes 1, 2 and 3, except during specific, infrequent .evolutions and are normally tagged shut. The safety function of these valves

• is to close for Containment isolation; they receive several isolation signals. In addition, these valves are Secondary Containment valves and are required to be operable in modes 4 and 5 when Secondary Containment is required.

Opening these valves for* quarterly testing takes them out of their normal safety-related position and results in unnecessary cycling of equipment that could lead to damage or shortened life of the valve seat resilient seal. (ref: U-601736, L30-90(09-27)-1 A.120).

In addition, the Technical Specifications recognize the potential for resilient seal damage due to cycling these valves by requiring an LLRT of the affected penetration within 92 days after they are cycled. Due to the limitations on use for these valves, it is likely that the only time these valves would be cycled during power operation would be for stroke time testing. As a result, quarterly testing of these valves during power operation is considered impractical as per NUREG 1482, R/1, Sections 2.4.5, and 3.1.1.

An appropriate level of testing will be maintained because stroke time testing during power operation, in accordance with ASME OM Code ISTC, will be required for these valves prior to use if it has been more than 92 days since they were last stroke time tested.

Revision 7 10/21/2016

Alternate Test: These valves will be full-stroke exercise tested to the closed position during Cold Shutdowns. If these valves are to be opened during Modes 1, 2 and 3, and have not been full-stroke exercise tested to the closed position in the previous 92 days, the valves will be full-stroke exercised individually to the closed position to verify their ability to reposition in order to maintain containment integrity prior to being used.

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Cold Shutdown Justification CSJ-108 Valve Number System Safety Class Category 1E31-F014, F015, LD 2 B F017, F018; 1E51-F063, 1E51- RI 1 A F064 Function: Containment and/or Drywell Isolation Valves Basis for Valves 1E31-F014/15/17/18 are normally open, solenoid actuated, Justification: drywell isolation valves. Should a valve fail during stroke time testing the penetration would be isolated per T.S. 3.6.5.3 and the plant would be forced to operate under the burden of a TS LCO and abnonnal system configuration and associated compensatory actions. In addition, 1E31-F014 and 1E31-F018 are located in the Drywell and should they fail, they cannot be repaired without shutting the plant down.

Valves 1E51-F063 and 1E51-F064 are normally opened motor operated containment isolation valves with a Medium Risk rank.

They are the RCIC turbine steam supply valves. A failure of one of these valves during exercise testing would result in a loss of the RCIC function and could require an immediate plant to affect repairs.

Based on the above discussions, stroking of these valves on a quarterly basis can result in NUREG 1482 impacts, including 2.4.5 unnecessary plant shutdown, and/or 3.1.1. unnecessary challenge to plant safety systems should the valves fail in the non-conservative position (i.e. a primary containment isolation valve fail in the open position requiring isolation of the containment penetration).

Alternate Test: These valves will be full-stroke exercised during Cold Shutdowns.

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Cold Shutdown Justification CSJ-109 DELETED Revision 7 10/21/2016

Cold Shutdown Justification CSJ-110 Valve Number System Safety Class Category 1E51-F065 RI 1 c Function: RCIC Injection Line Check Valve Basis for This valve opens to admit RCIC flow into the Reactor Vessel when Justification: required. It also opens to admit flow from the RHR to RCIC Head Spray line during normal Reactor cooldown; this function, however, is not required to achieve Cold Shutdown.

This valve is located within the Reactor Coolant Pressure Isolation boundary. No credit is taken, however, for this valve to function as a Containment Isolation Valve or Reactor Coolant Pressure Isolation Valve (PIV).

Exercising this valve with flow at power would require injecting cold water from the RCIC System into the dome of the Reactor Vessel via the Head Spray line. This would result in significant thermal and reactivity transients, potentially causing a Reactor scram.

Exercising this valve with a mechanical exerciser during normal operation is impractical because the potential exists for differential pressure equivalent to Reactor pressure across the disc.

Exercising the valve under this condition could result in damage to the valve or in a pressure spike to portions of the RCIC and AHR Systems. These impacts are as per NUREG 1482, R/1, 2.4.5 and 3.1.1.

Alternate Test: This valve will be exercise tested with flow on a Cold shutdown frequency while RHR is providing Head Spray to the Reactor Vessel for Shutdown Cooling.

NOTE: Bi-directional exercising in the non-safety related closed direction is performed at the same frequency.

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Cold Shutdown Justification CSJ-111 Valve Number System Safety Class Category 1E12-F042A RH 1 A 1E12-F042B RH 1 A 1E12-F042C RH .1 A 1E21-F005 LP 1 A 1E22-F004 HP 1 A 1E51-F013 RI 1 A Function: Reactor Coolant system Pressure Isolation Valves (PIV's)

Basis for These valves are Reactor Coolant Pressure Boundary PIV's. They Justification: are required to limit leakage between the high pressure Reactor Coolant System ahd connected systems (RHR, LPCS, HPCS, and RCIC) to prevent an intersystem LOCA. They are also required to open to place or maintain the reactor in Cold Shutdown or to mitigate the consequences of an accident and are PRA risk ranked as High Risk. It is not practical to perform a full or partial exercise test of these valves quarterly during normal operation based on the

• following considerations, as described in NUREG 1482, R/1 ,

Section 3.1 .1 : *

1) Opening any Reactor Coolant PIV at power would remove one of the two valves in its respective line from performing its PIV function. If the second valve was in a degraded condition, this could c~eate a pressure spike throughout the system, since each system is maintained filled and pressurized. Depending on the severity of the pressure spike, this could result in an inter-system LOCA with the potential for release of reactor coolant outside the primary containment.

2) Several MOV's in the above list have operators which are not designed to open against full differential pressure when the Reactor is at power. Furthermore, these valves are interlocked to prevent opening them until pressure drops below a preset value.

3) The shutoff head of the AHR and LPCS Pumps is below the normal operating pressure of the Reactor Coolant System.

Alternate Test: These valves will be full stroke exercise tested during cold shutdowns.

Additional assurance of proper closure is provided by performance of leak rate testing during refueling outages.

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• • =--~---=~ ~.-- -* -*-::.::. .: . --:- -~- - :..:=-* .....:: ... ~ ... --*-- ---~~-**--*-- *:...- ~--------------

Cold Shutdown Justification CSJ-112 Valve Number System Safety Class Category 1G33-F001 RT 1 A 1G33-F004 RT 1 A Function: Reactor Water Cleanup System Containment Isolation Valves Basis for These are the Containment Isolation Valves in the Reactor Water Justification: Cleanup (RT) System and risk ranked as Medium Risk. They isolate automatically on receipt of several Containment and system isolation signals. Exercising these valves requires the RT System to be taken out of service. Isolating the system, performing the testing, and restoring the system to service during power operations is a complex evolution and involves a significant amount of time. The RT System maintains the water quality limits of the Reactor Coolant within ORM limits. Sudden changes in temperature or flow could result in significant water chemistry changes which may require more time than is permitted by the applicable action statements. In addition, instances of resin intrusion into the* RPV have occurred at other Plants while attempting to test RT System valves at power. This cold shutdown justification is allowed by NUREG 1482, R/1, Section 3.1.1 for

.*potential impacts to containment isolation integrity.

Alternate Test. *These valves will be full-stroke exercised during Cold Shutdowns.

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Cold Shutdown Justification CSJ-113 Valve Number System Safety Class Category 11A012A IA 2 A 11A013A IA 2 A Function: Instrument Air Containment Isolation Valves Basis for These valves are the outboard Containment Isolation Valves for Justification: the instrument air line connecting the ADS valves with their air back-up bottles. These valves are PRA risk ranked as High Risk.

1IA012A supplies the Div 1 ADS valves and 1IA013A supplies the Div 2 ADS valves. A failure of one of these valves to open during exercise testing would result in the associated division of. ADS backup air bottles becoming inoperable. The inboard containment isolation valve is check valve that is located in the drywall and is not accessible when the plant is on line. In addition, there are no valves located between the inboard and outboard isolation valves that could be shut in order to allow repair that required disassembly of 1IA012A/13A. Similarly a failure of one of these valves to close during exercise testing would require closing of the manual valve outside containment. Since the manual valve is not located between the outboard containment isolation valve and the containment, in body repair of the containment isolation valve could not be implemented with the plant on line.

For both of the above scenarios, the associated division of ADS back up air supply would be out of service until repairs could be completed. A 30- day allowable outage time is a recommended maximum out-of-service time for removing one ADS backup air supply during plant operation {Ref. Paragraph 6.3 of CPS Procedure 3101.01, Main Steam (MS, IS AND ADS). \,

Based on the above discussion, exercise testing for valves 1IAO 12A and 1IA013A is considered impractical when the plant is on line as per NU REG 1482, R/1, section 3.1.1 for loss of system function; or loss of containment integrity.

Alternate Test: These valves will be full-stroke exercised during Cold Shutdowns.

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Cold Shutdown Justification CSJ-114 DELETED Revision 7 10/21/2016

Cold Shutdown Justification CSJ-115 Valve Number System Safety Class Category 1B33-F019 RR 2 B 1B33-F020 RR 2 B Function: Valves 1B33-F019 and 1B33-F020 are the reactor sample inboard and outboard drywall isolation valves for the reactor sample station.

1B33-F019 is the inboard isolation valve and 1B33-F020 is the outboard Isolation valve. These valves close to isolate the drywall under accident conditions.

Basis for Valves 1B33-F019 and 1B33-F020 are the reactor sample station Justification: drywall isolation valves. They closed automatically upon receipt of an automatic isolation signal to isolate the drywall. They are the drywall isolation valves for Penetration 1MD-013 [P&ID M05-1072 Sheet 1]. They close on loss of air or electrical power and may be remotely closed by the operator. They form part of the drywall boundary. There are requirements that limit total drywall bypass leakage. There are, however, no specific requirements for seat leakage for individual valves [ITS B 3.6.5.3].

These valves are normally open to provide a flow path for sampling the reactor coolant. This is not a safety function and sampling through this line is not required during accident conditions. During normal power operation 1B33-F019 is inaccessible. However 1B33-F20 is accessible during normal power operation.

The closing safety function for these valves is limited to operating modes 1, 2 and 3. (Ref. Tech Spec 3.6.5.3) Exercising 1B21-F019 increases the potential for air leakage inside the drywall with subsequent drywall pressurization. 1B33-F019 would also be required to be stroked closed if 1B33-F020 failed open during stroke time testing, again creating a potential for air leakage inside the drywall. Air leakage inside the drywall could increase the frequency for drywall venting resulting in cycling of the hydrogen mixing compressors and unnecessarily reduce their life expectancy. CPS 4402.01 directs OPS to use the hydrogen mixing compressors to maintain Drywall pressure below 1.68 psig. Step 8.3, Drywall Venting, of CPS procedure 3316.01, states each hydrogen mixing compressor should not be run for more than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per month to prevent exceeding the expected 40 year life runtime. In addition, leakage resulting from stroke time testing could require a plant Revision 7 10/21/2016

shutdown to implement repairs. This concern would be exacerbated by other conditions inside the drywell also contributing to drywell pressurization that were already existent at the time of the stroke time test.

The possibility of stroke time testing resulting in air leakage is documented on IR 519897, issued on 8/14/06. IA 519897 identified a condition of a potential air leak on one or both air operated drywell isolation valves 1VQ002 and 1VQ003. In this event, the frequency of drywell venting increased following IST surveillance testing in accordance with* 9061.03C005. The issue report identified that following valve stroking the venting frequency increased from once ever}' 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Paragraph 2.4.5 of NUREG 1482, Rev. 1, identifies impractical conditions justifying test deferrals include those conditions which could cause an unnecessary plant shutdown, cause unnecessary cycling of equipment or unnecessarily reduce the life expectancy of the plant systems and components. Based on the *above discussion and NUREG 1482 quarterly stroke time testing of 1B33-F019 and

.1 B21-F020 is considered impractical.

Alternate.Test:

• Valves 1B33-F019 and 1B33-F020. will be exercise tested during Cold Shutdown.

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Cold Shutdown Justification CSJ-116 Valve Number System Safety Class Category 1PS004/9/16/22J PS 2 A 31 /34/37/56/70 Function: Valves 1PS004/9/16/22/31/34/37/56/70 are inboard primary containment isolation valves. They are installed in the Post Accident Sampling System. They automatically close on a low reactor water signal or a high drywell pressure signal. Additionally, they can be manually initiated from the control room. The valves also close on a loss of power.

Basis for Failure of one of these valves to close during stroke time testing will Justification: require the corresponding outboard isolation valve to be closed and power removed. The electrical design for the outboard isolation is such that when power is removed from these PS valves, the Division 1 diesel generator starting air compressors will be shunt tripped.

Therefore quarterly stroke time testing for the above valves is considered impracticable, as per NUREG 1482, R/1 , Section 3.1 .1 *.

Altem~te Test: Valves 1PS004/9/16/22/31/34/37/56/70 will be stroke time tested during cold shutdowns.

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Cold Shutdown Justification CSJ-117 Valve Number System Safety Class Category 1B21-F016 MS 1 A 1B21-F019 MS 1 A Function: Valves 1B21-F016 and 1B21-F019 are the containment isolation valves for the main steam line drain, Penetration 1MC-045. 1B21-F016 is the inboard isolation valve and 1B21-F019 is the outboard isolation valve. These valves are required to close for an event requiring containment isolation for the main steam lines.

Basis for Valves 1B21-F016 and 1B21-F019 are containment isolation valves

• Justification: that are inaccessible during power operation (they are located in the drywall and the auxiliary building steam tunnel, respectively). If one of them failed open during exercise testing, the other valve would be required to be closed to maintain containment. As a result, the main steam drain line function would be lost. The same result would occur if one of the valves failed in the closed position during exercise testing. 1B21-F016 and 1B21-F019 in the main steam drain line are used to provide. a method for pressure control following a reactor scram. In addition they can be used to reduce the pressure across the MSIVs so the MSIVs can be opened. The ability to use the steam line drain to perform these functions would be lost if one of these valves failed during IST exercise testing.

In addition to the above, if a packing leak that requires immediate repair were to occur during valve exercising, the plant would be required to be placed in cold shutdown in order to affect repair, as per NUREG 1482, Section 3.1.1.

Based on the above, quarterly exercising of valves 1B21-F016 and 1B21-F019 is considered impractical.

Alternate Test Valves 1B21-F016 and 1B21-F019 will be exercise tested closed during Cold Shutdown.

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Cold Shutdown Justification CSJ-118 Valve Number System Safety Class Category 1SX346A SX 3 c 1SX346B sx 3 c Function: Valves 1SX346A/B are the SX vacuum breakers on 1VX06CA and 1VX06CB. The 1SX346's are the inlet valves. These valves are required to open to allow air to enter the SX piping when under a vacuum and to close to . prevent the loss of ultimate heat sink inventory (SX) and Division 1 and 2 switch gear room flooding.

Basis for Testing these valves online require declaring the VX system Justification: nonfunctional due to the testing lineup. The station has taken a conservative position that when the VX system is nonfunctional, inoperability is needed to be entered for supported systems. Action statements for these systems are in some cases 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less.

This affects the Division. 1 and 2 AC power distribution systems.

Division 1 when testing 1SX346A and Division 2 when testing 1SX346B. Entering into an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less LCO is considered impractical to the station per NUREG 1482, section 3.1.1.

Based on the above, online testing of valves 1SX346A/B is considered impractical.

Alternate Test In place of quarterly testing valves 1SX346A/B will be manually

_stroked to full open and full closed position with the force to crack open the valve being measured during the opening portion. The valve shall return to the closed position without any assistance and with no evidence of binding or restriction of motion. This testing will occur during Cold Shutdown not to exceed a Refuel Outage per ISTC-3522 (b).

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REFUEL OUTAGE JUSTIFICATION INDEX RFJ-001 1C41-F006: Standby Liquid Control System Injection Check Valve RFJ-002 1E51-F066: RCIC Injection Check Valve RFJ-003 1B21-F01 OA, 1B21-F01 OB, 1B21-F032A, 1B21-F032B: Feedwater System Containment Isolation Valves RFJ-004 1B21-F041B, 1B21-F041C, 1B21-F041D, 1B21-F041F, 1B21-F047A, 1B21-F047C, 1821-F051G: Automatic Depressurization System (ADS) Valves RFJ-005 1E12-F041 A, 1E12-F041 B, 1E12-F041 C, 1E21-F006, 1E22-F005: Reactor Coolant System Pressure Isolation Valves (PIV's)

RFJ-006 1B21-F024A, 1B21-F024B, 1B21-F024C, 1B21-F024D, 1B21-F029A, 1B21-F029B, 1B21-F029C, 1B21-F029D: Instrument Air Supply Check Valves to MSIV Accumulators RFJ-007 1B21-F036A, 1821-F036F, 1B21-F036G, 1B21-F036J, 1821-F036L, 1821-F036M, 1821-F036N, 1B21-F036P, 1821-F036R, 1B21-F039B, 1821-F039C, 1B21-F039D, 1B21-F039E, 1B21-F039H, 1B21-F039K, 1B21-F039S: Instrument Air Supply to SRV Accumulator Check Valves RFJ-008 1821-F433A, 1B21-F433B: IA Supply Check Valves to FW Check Valve Accumulators RFJ-009 1C11-114, 1C11-115, 1C11-126, 1C11-127, 1C11-138, 1C11-139: Control Rod Drive System Hydraulic Control Unit Valves RFJ-010 1C11-F376A, 1C11-F3768, 1C11-F377 A, 1C11-F377B: RV Level Instrumentation Reference Leg Keep Fill Check Valves RFJ-011 1C41-F033A, 1C41-F0338: Standby Liquid Control Pump Discharge Check Valves RFJ-012 1C41-F336: Standby Liquid Control System Injection Check Valve RFJ-013 1CM066, 1CM067 Excess Flow Check Valves RFJ-014 1 IA042A, 1IA042B: Instrument Air Supply Header to ADS/LLS Valves RFJ-015 1CM0028, 1E51-F377B, 1SM008: Excess Flow Check Valves Revision 7 10/21/2016

ATTACHMENT 11 REFUELING OUTAGE JUSTIFICATIONS Revision 7 10/21/2016

Refuel Justification RFJ-001 Valve Number System Safety Class Category 1C41-F006 SC 1 c Function: Standby Liquid Control system Injection Check Basis for This valve is. the Standby Liquid Control (SC) System injection flow path Justification: check valve. It is located inside Primary Containment and is accessible during normal operation and Cold Shutdowns.

This valve is equipped with a mechanical exerciser. It has been determined, however, that use of the exerciser to test the valve to the open position does not provide consistent or conclusive results.

Breakaway force required to move the valve off its seat has been measured at 2 in .. lbs. This results in an acceptance range of 1 to 3 in.

lbs. for inservice testing. Due to the low torque valves involved, it is very difficult to distinguish between the force represented by the hinge pin packing load and the actual force required to lift the disc. Thus, there is no direct correlation between breakaway force and valve degradation.

This is a 3-inch stainless steel valve in a stainless steel system containing de-ionized water. During normal plant operation this valve is isolated from reactor pressure and temperature. Because of the* .

stainless steel system, lack of flow, ambient containment temperature, and the use of DI water, corrosion products or other contaminates are minimal and as such this valve will not undergo normal degradation processes.

There is no method to conduct the open (and closed) test on-line except during the firing of the explosive valve, this would inject flow through 1C41-F006 into the RPV. The only way to conduct a closure test is to open the valve. As a result firing of the explosive valve on a quarterly basis or during cold shutdown would not be practical. Therefore the test cannot be conducted except during a refueling outage during the firing of the explosive valve.

This valve will be tested with flow from alternating SC loops during Refueling Outages. One loop will have its valve tested open with flow, while the other loop will be tested closed.

• Revision 7 10/21/2016

Refuel Justification RFJ-002 Valve Number System Safety Class Category 1E51-F066 RI 1 A/C Function: RCIC Injection Check Valve Basis for This *check valve isolates the Reactor Vessel from the RCIC injection Justification: header. Full-stroke exercising of this valve during normal operation would involve the injection of accident-rated flow from the RCIC Pump into the Reactor Vessel. RCIC is normally lined up to take suction from the RCIC Storage Tank, the temperature of which can be as low as 40°F. This would involve the injection of a significant amount of cold water into the vessel at power resulting in a reactivity addition excursion and thermal shock to the HCIC head spray and Reactor Vessel components, and

• • po.ssible damage to turbine blades from the impingement of water droplets carried.through the Mairi 'Steam lines.

This valve is exercise tested to the open* position during Cold shutdowns (refer to CSJ-105) and will be tested in the closed position by means of a Reactor Coolant System Pressure Isolation Valve (PIV) leak rate test during refueling outages.

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Refuel Justification RFJ-003 Valve Number System Safety Class Category 1B21-F01 OA/B FW 2 c 1B21-F032A/B FW 2 A/C Function: Feedwater System Containment Isolation Valves Basis for These are the Reactor Feedwater Inlet Containment Isolation Check Justification: Valves. Shutdown Cooling flow from the RHR System returns. to the Reactor Vessel through these valves.

1B21-F01 OA/B are simple check valves located inside the Drywall. There is no means to exercise test these valves to the closed position during normal operation.

Exercising 1B21-F032A/B to the closed position would interrupt the flow of feedwater to the RPV, which would introduce undesirable operational transients and could result in a Reactor Trip.

Closure of these valves is demonstrated by performance of leak rate tests each refueling outage.

NOTE: Bi-directional exercising in the non-safety related open direction is performed during routine operations. These valves are normally open with flow.

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Refuel Justification RFJ-004 Valve Number System Safety Class Category 1B21-F041 B/C/D/F MS 1 B/C 1B21-F047A/C MS 1 B/C 1B21-F051G MS 1 B/C Function: Automatic Depressurization System (ADS) Valves Basis for These valves depressurize the Reactor in order to allow injection of LPCI Justification: and LPCS flow in the event of a small-break LOCA.

These valves cannot be exercised during normal operation because the resulting pressure fluctuations, particularly if the valve failed to close and reseat in a timely manner, could result in an inadvertent Reactor shutdown and possible ECCS actuation. Exercising these valves during Cold Shutdowns would increase the number of challenges to the Main Steam SRV's in conflict with the recommendations of NUREG-0737.

These valves are tested in' *accordance with the exercise testing requirements for Category B valves per ISTC and with the safety/relief valve requirements for Class 1 valves with auxiliary actuating devices of Appendix I.

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Refuel Justification RFJ-005 Valve Number System Safety Class Category 1E12-F041 A/8/C RH 1 A/C 1E21-F006 RH 1 A/C 1E22-F005 RH 1 A/C Function: Reactor Coolant System Pressure Isolation valves (PIV's)

Basis for These check valves isolate the. Reactor Vessel from the RHR LPCI, LPCS Justification: and HPCS injection headers. Full-stroke exercising of these valves during normal operation would involve the injection of accident-rated flow from the respective pumps into the Reactor Vessel.

Valves 1E12-F041A, B and C and 1E21-F006 cannot be exercised quarterly since the shutoff head of the RHR and LPCS pumps are below normal RV pressure. Testing of 1E22-F005 quarterly would involve the injeption of a significant amount of cold water into the vessel at power resulting in a reactivity addition excursion and thermal shock to the HPCS and Vessel components. Full stroke exercising of these valves during Cold shutdowns would also increase the number of thermal fatigue cycles on the Reactor Vessel nozzles.

These valves are full-stroke exercised during refueling outages.

Satisfactory closure of these valves is also *demonstrated during refueling outages by performance of the PIV leak rate test.

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Refuel Justification RFJ-006 Valve Number System Safety Class Category 1B21-F024A/B/C/D MS 3 c 1B21-F029A/B/C/D MS 3 c Function: Instrument Air Supply Check Valves to MSIV Accumulators Basis for These are the Instrument Air Supply Check valves to the air accumulators Justification: for the MSIV's. They prevent depressurization of the accumulators in the event of a loss of Instrument Air supply.

Excessive leakage past any of these valves would result in depressurization of the accumulator. During normal operation at power, this would lead to closing of the associated MSIV, which would most likely cause a Reactor scram. It is also impractical to test these valves during Cold Shutdowns due to the significant amount* of time and manpower required to set up and perform the test. In addition, 1B21-F024A through D are located in the Drywall which is not accessible during normal operation or most Cold Shutdowns.

These valves will be tested in the closed position by means of a leak rate test during refueling outages.

NOTE: Bi-directional exercising in the non-safety related open direction is performed at the same frequency.

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Refuel Justification RFJ-007 Valve Number System Safety Class Category 1B21-F036A/F/G/J/L MS 3 A/C 1B21-F036M/N/P/R MS 3 A/C 1 B21-F039B/C/D/E/H MS 3 A/C 1B21-F039K/S MS 3 A/C Function: Instrument Air Supply to SRV Accumulator Check Valves Basis for These are the Instrument Air supply check valves to the air accumulators Justification: for the Main Steam SRV's. They prevent depressurization of the accumulators in the event of a loss of Instrument Air supply in order to allow the SRV's to operate in the relief mode. Additionally, some of these valves perform a safety function in the open direction for the purpose of refilling the SRV accumulators. These valves lack design provisions for 11 on-line" testing and are located in the drywall which is inaccessible during

. normal operation.

Exercise testing of these valves in the closed direction is performed by isolating the Instrument Air supply and depressurizing the upstream side of the check valve. The open test is performed by measuring the air flow rate through the check valve. Performance of either of these tests during power operation is impractical. Both open and closed tests require transporting and setting up test equipment in the drywall. NUREG-1482, paragraph 4.1.4 allows these valves to be tested during refueling outages.

Therefore, these valves will be tested, in the open and closed positions during refueling outages.

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Refuel Justification RFJ-008 Valve Number System Safety Class Category 1B21-F433A/B FW 3 c Function: IA Supply Check Valves to FW Check Valve Accumulators Basis for These are the Instrument Air supply check valves to the accumulators for Justification: Feedwater Check Valves 1B21-F032A and 1B21-F032B. They prevent depressurization of the accumulators on loss of Instrument Air in order to assure pneumatic pressure will be available to the closing side of the Feedwater Check Valve air aetuators.

These valves and other valves necessary to perform the exercise test are located in the Steam Tunnel, which is inaccessible during normal operation. It is also impractical to test them during Cold Shutdowns due to the significant amount of time and manpower required to set up and perform the test, which would most likely delay Plant startup.

These valves are tested in the closed position during refueling outages by isolating the Instrument Air supply and depressurizing the upstream side of the check valve.

NOTE: Bi-directional exercising in the non-safety related open direction is performed at the same frequency.

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Refuel Justification RFJ-009 Valve Number System Safety Class Category 1C11-114, 1C11-115 RD 0 c 1C11-126, 1C11-127 RD 0 8 1C11-138, 1C11-139 RD 0 A/C Function: Control Rod Drive System Hydraulic Control Unit Valves Basis for Each EIN listed above actually represents 145 valves (1 valve for each of Justification: 145 Control Rod Drive Hydraulic Control Units [HCU's]) which are required to perform specific functions during a Reactor scram.

1C11-114 is a check valve which opens to permit water from the top of its associated Control Rod Drive piston to be discharged to the Scram Discharge Volume header, and closes to prevent backpressure from the SDV causing an inadvertent withdrawal of a scrammed Control Rod.

1C11-115 is a check valve in the. Charging Water supply to each associated HCU accumulator which closes to assure sufficient pressure to scram its Control Rod in the event of a loss of Drive Water pressure.

1C11-126 and 1C11-127 are the air-operated scram valves which open to direct drive water to the bottom of each Control Rod Drive piston and exhaust water from the top of the piston to the SDV.

1C11-138 is a check valve in the CAD cooling water supply header which prevents diversion of scram flow away from the CAD.

1C11-139 is a pilot valve which exhausts air from the actuators of the scram valves (1C11-126 and 1C11-127), causing them to open.

All of the valves in this Refuel Justification, with the exception of 1C11-115 are verified to perform their required functions by the performance of Control Rod Scram Time testing in accordance with the requirements of the Technical Specifications. This complies with the recommendations of.

Position 7 of NRC Generic Letter 89-04. The 1C11-115 valves are tested in the closed position by performance of a leak rate test using the pressure drop method during each refueling outage.

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Refuel Justification RFJ-010 Valve Number System Safety Class Category 1C11-F376A/8 RD 0 A/C 1C11-F377A/B RD 0 A/C Function: RV Level Instrumentation Reference Leg Keep Fill Check Valve Basis for These valves are located in lines which provide a steady source of keep-fill Justification: water to the Reactor Vessel level instrumentation reference legs during normal operation and Cold Shutdown. They are required to close to prevent backflow and keep the instrument reference leg full of water in order to maintain level indication for the reactor vessel and to prevent a small-break LOCA in the event of a loss of the non-safety related upstream RD piping.

Testing these valves in the closed position during normal operation would require securing the keep fill flow to the reference legs which could result in a false indication of high level in the RV, which in turn could cause a turbine trip at power. Accurate level indication is also required during Cold shutdowns in order to assure that adequate decay heat removal capacity is available.

The only practical method of assuring that these valves are closed is by means of a* leak rate test. These valves are tested in the closed position during refueling outages.

NOTE: Exercising *in the open direction is performed during routine operations.

• Revision 7 10/21/2016

Refuel Justification Valve Number System Safety Class Category 1C41-F033A/B SC 2 c

\

Function: Standby Liquid Control Pump Discharge Check Valves Basis for It is not practical to exercise these valves to the closed position during Justification: normal operation or during Cold Shutdowns, because there is no instrumentation between the pumps and these valves that can be used to detect reverse flow or pressure, nor are there any vents or drains that would indicate excessive reverse flow.

These valves are tested during refueling outages by removing the relief valve (1 C41-F029A or B) while running the pump in the opposite train, and monitoring the open flange connection for back leakage.

Open exercise test is performed quarterly in conjunction with pump testing.

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Refuel Justification RFJ-012 Valve Number System Safety Class Category 1C41- F336 SC 1 c Function: Standby Liquid Control System Injection Check Valve Basis for . This check valve is located in the common Standby Liquid Control System Justification: injection header downstream of explosive injection valves 1C41-F004A and B, inside the drywell. It is a totally enclosed valve with no provisions for external exercising. The only means to test this valve with fl()W is to activate one Train of the SC System which would fire the explosive-actuated Squib valve in the selected Train.

Exercise testing to the open position is accomplished during each refueling outage when one of the explosive valves is fired to satisfy Technical Specification surveillance requirements and flow is injected into the Reactor Vessel from the Test Tank. Testing in the closed position is accomplished by means of the Reactor Coolant System Leakage Test which requ'ires access to the Drywell.

This valve will be tested to the open and closed positions during refueling outages.

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Refuel Justification RFJ-013 Valve Number System Safety Class Category 1CM066 CM 2 A/C 1CM067 CM 2 A/C Function: Excess Flow Check Valves Basis for These are Containment Isolation Valves and provide isolation capability for Justification: various Reactor Vessel and Primary Containment instrument lines in the event of an instrument line break as discussed in US NRC Regulatory Guide 1.11 (Safety Guide 11 ).

These valves communicate directly to the RPV and during operation are exposed to RPV pressure. Testing in such conditions exposes the test performer to unnecessary risk and exposure. Also, testing these valves during normal plant operation requires isolating numerous safety-related instruments associated with scram logic, ECCS activation and accident monitoring. This involves filling, venting and draining operations, breaking connections to the instruments, setting up a test rig, introducing water flow through lines with high potential for contamination, then restoring the instrument to service. These instruments have the potential for scramming the Reactor, causing an 'ECCS actuation, or initiating a Containment Isolation signal. In addition, testing these valves during Plant operation or Cold Shutdown results in numerous LCO entries. These valves cannot be partially exercised.

These valves will be exercised open and closed during refueling outages when they are not required to perform their protective functions.

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Refuel Justification RFJ-014 Valve Number System Safety Class Category 11A042A IA 2 A/C 1 IA042B IA 2 A/C Function: Instrument Air Supply Header to ADS/LLS Valves Basis for These are Containment Isolation Valves which

• are located in the Justification: Instrument Air (IA) supply lines from the Compressors and Emergency Bottle Banks to the Main Steam Safety/Relief Valve accumulators used for ADS and LLS service.

Testing of these valves during normal operation or during unscheduled Cold Shutdowns is impractical because they and others required to perform the test are located in the Drywall, which is inaccessible during these conditions.

Proper functioning of these valves to the open position is confirmed on a continuous basis during normal Plant operaf1on by maintaining pressure in the accumulators. Testing to the open position is accomplished during refueling outages by means of a flow test. Testing of these valves in the closed position is performed by isolating the supply sources,

. depressurizing the upstream side and measuring pressure drop over a 10-minute period.

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Refuel Justification RFJ-015 Valve Number System Safety Class Category 1CM002B CM 2 c 1E51-F377B RI 2 c 1SM008 SM 2 c Function: These are excess flow check valves in low pressure systems.

They are required to close to eliminate a level rise in the instrument standpipe. They are required to reopen to allow operation of the instruments in their associated line.

Basis for Testing these valves during normal plant operation requires Justification: isolating numerous safety-related instruments associated with scram logic, ECCS activation and accident monitoring. This involves filling, venting and draining operations, breaking connections to the instruments, setting up a test rig, introducing water flow through lines with high potential for contamination, then restoring the instrument to service. These instruments have the potential for scramming the Reactor, causing an ECCS actuation, or initiating a Containment Isolation signal. In addition, testing these valves during Plant operation or Cold Shutdown results in numerous LCO entries. As such, quarterly testing of these valves are impacted by NU REG 1482, R/1, Section 3.1.1 (1 ), potential loss of system function; (2), loss of containment integrity, or 2.4.5, potential for reactor trip.

Alternate Test: These valves will be full-stroke exercised during refueling outages when they are not required to perform their protective functions.

Open and close exercising is performed at the same frequency.

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ATTACHMENT 12 CORPORATE TECHNICAL POSITION INDEX Revision 7 10/21/2016

CORPORATE TECHNICAL POSITION INDEX Designator Description Issue Date CTP-IST-001, Rev.1 Preconditioning of IST Components 2/1/2012 CTP-IST-002, Rev.1 Quarterly Pump Testing Under Full Flow Conditions 2/1/2012 CTP-IST-003, Rev.a Quarterly Testing of Group B Pumps 9/10/2009 CTP-IST-004, Rev.1 Classification of Pumps: Centrifugal vs. Vertical Line Shaft 2/1/2012 CTP-IST-005, Rev.1 Preservice Testing of Pumps 211/2012 CTP~IST-006, Rev.1 Testing of Power Operated Valves with both Active and 2/1/2012 Passive Safety Functions (Not implemented at CPS)

CTP-IST-007, Rev.1 Skid-Mounted Components 2/1/2012 CTP-IST-008, Rev.1 Position Verification Testing 2/1/2012 CTP-IST-009, Rev. O ASME Class 2 & 3 Relief Valve Testing Requirements 211/2012 CTP-IST-010, Rev. O ERV and PORV Testing Requirements 2/1/2012 Extension of Exercise Testing Frequencies to Cold Shutdown 2/1/2012 CTP-IST-011, Rev. O or Refueling Outage CTP-IST-012, Rev. O Use of ASME OM Code Cases for lnservice Testing 2/1/2012 CTP-IST-013, Rev. 0 Exercise Testing Requirements for Valves with Fail-Safe 2/1/2012 Actuators CTP-IST-014, Rev.a Bi-directional Testing of Check Valves to Their Safety and 211/2012 Non-Safety Related Positions Revision 7 10/21/2016

ATTACHMENT 13 CORPORATE TECHNICAL POSITIONS Revision 7 10/21/2016

Number: CTP-IST-001, Rev. 1

Title:

Preconditioning of IST Program Components Applicability: All Exelon IST Programs. This issue also applies to other Technical Specification surveillance testing where preconditioning may affect the results of the test. This Technical Position may be adopted optionally by other Exelon organizations.

Background:

There are no specified ASME Code requirements regarding preconditioning or the necessity to perform as-found testing, with the exception of setpoint testing of relief valves and MOV testing performed in accordance with Code Case OMN-1 or Mandatory Appendix Ill. Nevertheless, there has been significant concern raised by the NRC, and documented in numerous publications, over this issue. Section 3.5 of Reference 2 provides guidance on preconditioning as it relates to IST; Section 3.6 provides additional guidance on as-found testing. It is the intent of this Technical Position to provide a unified, consistent approach to the issue of preconditioning as it applies to IST Programs throughout the Exelon fleet.

The purpose of IST is to confirm the operational readiness of pumps and valves within the scope of the IST Program to perform their intended safety functions whenever called upon. This is generally accomplished by testing using quantifiable parameters which provide an indication of degradation in the performance of the component.

Preconditioning can diminish or eradicate the ability to obtain any meaningful measurement of component degradation, thus defeating the purpose of the testing.

Preconditioning is defined as the alteration, variation, manipulation, or adjustment of the physical condition of a system, structure, or component before Technical Specification surveillance or ASME Code testing. Since IST is a component-level program, this Technical Position will address preconditioning on a component-level basis.

Preconditioning may be acceptable or unacceptable.

• Acceptable preconditioning is defined as preconditioning which is necessary for the protection of personnel or equipment, which has been evaluated as having insufficient impact to invalidate the results of the surveillance test, or which provides performance data or information which is equivalent or superior to that which would be provided by the surveillance test.

• Unacceptable preconditioning is preconditioning that could potentially mask degradation of a component and allow it to be returned to or remain in service in a degraded condition.

In most cases, the best means to eliminate preconditioning concerns is to pe*rtorm testing in the as-found condition. When this is not practical, an evaluation must be performed to determine if the preconditioning is acceptable.* Appendix 1 to this Technical Position may be used to document this evaluation.

The acceptability or unacceptability of preconditioning must be evaluated on a case-by-case basis due to the extensive variability in component design, operation, and performance requirements. Preconditioning of pumps may include filling and venting of pump casings, venting of discharge piping, speed adjustments, lubrication, adjustment of seals or packing, etc. Preconditioning of valves may include stem lubrication, cycling of the valve prior to the "test" stroke, charging of accumulators, attachment of electrical leads or jumpers, etc.

Factors to be considered in the evaluation of preconditioning acceptability include component size and type, actuator or driver type, design requirements, required safety functions, safety significance, the nature, benefit, and consequences of the preconditioning activity, the frequencies of the test and preconditioning activities, Revision 7 10/21/2016

applicable service and environmental conditions, previous performance data and trends, etc.

Lubrication of a valve stem provides an example of the variability of whether or not a preconditioning activity is acceptable. For example, lubrication of the valve stem of an AC-powered MOV during refueling outages for a valve that is exercise tested quarterly would normally be considered acceptable, unless service or environmental conditions could cause accelerated degradation of its performance. Lubrication of a valve stem each refueling outage for an MOV that is exercise tested on a refueling outage frequency may be unacceptable if the lubrication is always performed prior to the exercise test. Lubrication of a valve stem for an AOV prior to exercise testing is likely to be unacceptable, unless it can be documented that the preconditioning (i.e.,

maintenance or diagnostic testing) can provide equal or better information regarding the as-found condition of the valve. Manipulation of a check valve or a vacuum breaker that uses a mechanical exerciser to measure breakaway force prior to surveillance testing would be unacceptable preconditioning. Additional information regarding preconditioning of MOVs may be found in Reference 4.

Position:

1. Preconditioning SHALL be avoided unless an evaluation has been pertormed to determine that the preconditioning is acceptable. Appendix 1 to this Technical Position may be used to document this evaluation. In cases where the same information applies to more than one component, a single acceptability evaluation may be*performed and documented

2. Evaluations SHALL be prepared,* reviewed and approved by persons with the appropriate level of knowledge and responsibility. For example, persons preparing an evaluation should hold a current certification in the area related to the activity.

Reviewers should be certified in a related area.

3. The evaluation SHALL be approved by a Manager or designee.

4. If it is determined that an instance of preconditioning has occurred. without prior evaluation, the evaluation SHALL be performed as soon as practicable following discovery. If the evaluation concludes that the preconditioning is unacceptable, an IA shall be written to evaluate the condition and identify corrective actions.

References:

1. NRC Information Notice 97-16, "Preconditioning of Plant Structures, Systems, and Components before ASME C9de lnservice Testing or Technical Specification Surveillance Testing".

2. NUREG-1482, Revision 1 (January, 2005), Section 3.5 "Pre-Conditioning of Pumps and Valves".

3. NRC Inspection Manual Part 9900: Technical Guidance, "Maintenance - Preconditioning of Structures, Systems and Components Before Determining Operability".

4. ER-AA-302-1006, "Generic Letter 96-05 Program Motor-Operated Valve Maintenance and Testing Guidelines"

5. ER-AA-321, "Administrative Requirements for lnservice Testing" Revision 7 10/21/2016

CTP*IST-001 APPENDIX 1 EVALUATION OF PRECONDITIONING ACCEPTABILITY Description of activity:

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Answer the following questions to determine the acceptability of the preconditioning activity based on Section D.2 of Reference 3.

Question Yes No Not Determined

i. Does the alteration, variation, manipulation or adjustment ensure that the component will meet the surveillance test acceptance 0 0 0 criteria?

2. Would the component have failed the surveillance without the 0 0 0 alteration, variation, manipulation or adjustment?

3. Does the practice bypass or mask the as-found condition? 0 0

4. Is the alteration, variation, manipulation or adjustment routinely 0 0 performed just before the testing?

5. Is the alteration, variation, manipulation or adjustment performed 0 0 only for schedulinQ convenience?

If all the answers to Questions 1 thru 5 are No, the activity is acceptable; go to Section 3.

Otherwise, continue to Section 2.

The following questions may be used to determine if preconditioning activities that do not meet the screening criteria of Section 1 are acceptable Question Yes No

6. Is the alteration, variation, manipulation or adjustment required to prevent 0 0 personnel injury or equipment damage? If yes, explain below.

7. Does the alteration, variation, manipulation or adjustment provide performance data or information that is equivalent or superior to that provided by the o 0 surveillance test? If yes. explain below.

8. Is the alteration, variation, manipulation or adjustment being performed to repair, replace, inspect or test an SSC that is inoperable or is otherwise unable o 0 to meet the surveillance test acceptance criteria? If ves, explain below.

9. Is there other justification to support classification of the alteration, variation, manipulation or adjustment as acceptable preconditioning? If yes, explain o 0 below and provide references.

Explanation I Details: (attach additional sheets as necessary)

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==

Conclusion:==

The preconditioning evaluated herein (is I is not} acceptable. (Circle one)

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Revision 7 10/21/2016

Number: CTP-IST-002, Rev. 1

Title:

Quarterly Pump Testing Under Full Flow Conditions Applicability: ASME OM-1995 Code and Later, Subsection ISTB

Background:

Pumps included in the scope of the IST Program are classified as Group A or Group B.

The OM Code defines a Group A pump as a pump that is operated continuously or routinely during normal operation, cold shutdown, or refueling operations. A Group B pump is defined as a pump in a standby system that is not operated routinely except for testing.

Testing of pumps in the IST Program is performed in accordance with Group A, Group B, comprehensive or preservice test procedures. In general, a Group A test procedure is intended to satisfy quarterly testing requirements for Group A pumps, a Group B test procedure is intended to satisfy quarterly testing requirements for Group B pumps and a comprehensive test procedure is required to be performed on a frequency of once every two years for all Group A and Group B pumps. The Code states that when a Group A test is required a comprehensive test may be substituted; when a Group B test is required a comprehensive test or a Group A test may be substituted. A preservice test may be substituted for any inservice test. The Corporate Exelon position on preservice testing requirements for pumps in the IST Program is provided in CTP-IST-005. ~

Subsection ISTB provides different acceptance, alert and required action ranges for centrifugal, vertical line shaft, non-reciprocating positive displacement and reciprocating positive displacement pumps, for Group A, Group B and comprehensive pump tests. In each case, the acceptance bands for flow and differential or discharge pressure for the comprehensive test are narrower than those for the Group A and Group B tests. Since comprehensive pump test requirements did not exist prior to the OM-1995 Code, and since the frequency of comprehensive tests is once every two years, most stations have a limited history of comprehensive pump test performance. Thus, pumps that have demonstrated satisfactory results during quarterly testing over a period of several years may fail a comprehensive test while continuing to operate at the same performance level.

Position: The following points summarize the Exelon position on full-flow testing of pumps:

1. Any specific pump is either Group A or Group B; it cannot be both. Any pump that is operated routinely for any purpose, except for the performance of inservice testing, is a Group A pump. A pump cannot be classified as Group A for certain modes of operation and Group B for other modes of operation (e.g., pumps used for shutdown cooling are Group A pumps), unless authorized by means of an NRC-approved Relief Request.

2. Under certain circumstances, similar or redundant pumps may be classified differently. For example, if a station has four identical AHR pumps with two used for shutdown cooling and two dedicated to ECCS service, the shutdown cooling pumps would be Group A, whereas the dedicated ECCS pumps would be Group B provided they were maintained in standby except when performing inservice testing.

3. Quarterly testing of Group A pumps shall be performed in accordance with a Group A or comprehensive test procedure. Post-maintenance testing of Group A pumps shall be performed in accordance with a Group A, a comprehensive, or a preservice test procedure.

Revision #6 02/08/2016

4. Quarterly testing of Group B pumps shall be performed in accordance with a Group B, Group A, or comprehensive test procedure. Post-maintenance testing of Group B pumps shall be performed in accordance with a Group A, a comprehensive, or a preservice test procedure.

5. Credit can only be taken for a comprehensive test if all of the OM Code requirements for a comprehensive test are met, including flow, instrument range and accuracy, and acceptance limits.

Regardless of test conditions, quarterly pump testing is required to meet the acceptance criteria specified for Group A or Group B pumps, as applicable, in the edition/addenda of the OM Code in effect at the Plant. More restrictive acceptance criteria may be applied optionally if desired to improve trending or administrative control.

The ASME OM Code has identified quarterly and comprehensive pump testing as distinctly separate tests with separate frequency and instrumentation requirements and separate acceptance criteria. When performing a quarterly (Group A or Group B) test under full flow conditions, it may be apparent that a comprehensive test limit was exceeded. In such cases, ISSUE an IR to describe and evaluate the condition and potential compensatory measures (e.g., establishing new reference values) prior to the next scheduled comprehensive test. No additional corrective actions are required.

References:

1. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTB.

Revision 7 10/21/2016

Number: CTP-IST-003, Rev. O

Title:

Quarterly Testing of Group 8 Pumps Applicability: ASME OM-1995 Code and Later

Background:

Pumps included in IST Programs that must comply with the 1995 Edition of the ASME OM Code and later are required to be classified as either Group A or Group B pumps.

The OM Code defines a Group A pump as a pump that is operated continuously or routinely during normal operation, cold shutdown, or refueling operations. A Group B pump is defined as a pump in a standby system that is not operated routinely except for testing.

Testing of pumps is performed in accordance with Group A, Group B, comprehensive or preservice test procedures. In general, a Group A test procedure is intended to satisfy quarterly testing requirements for a Group A pump, a Group B test procedure is intended to satisfy quarterly testing requirements for a Group B pump, and a comprehensive test procedure is required to be performed on a frequency of once every two years for all Group A and Group B pumps. A Group A test procedure may be substituted for a Group B procedure and a comprehensive or preservice test procedure may be substituted for a Group A or a Group B procedure at any time.

A Group A test procedure is essentially identical to the quarterly pump test that was performed in accordance with OM-6 and earlier Code requirements. Group B testing was introduced to the nuclear industry when the NRC endorsed the OM-1995 Edition with OMa-1996 Addenda In 10 CFR 50~55a(b)(3). The intent of the Group B test was to provide assurance that safety related-pumps that sit idle essentially all of the time (e.g.

ECCS pumps) would be able to start on demand and achieve a pre-established reference condition: The requirements for Group B testing were significantly relaxed when compared with the Group A (traditional) pump test requirements based on the assumption that there were no mechanisms or conditions that would result in pump degradation while the pump sat idle.

Strong differences of opinion regarding the intent and requirements for Group B testing developed and have persisted since the beginning. These differences span the industry, the NRC, and even members of the OM Code Subgroup-ISTB who created them. One opinion is that the Group B test is intended to be a "bump" test in which the pump is started, brought up to reference flow or pressure, and then stopped. The opposing opinion is that the Group B test requires the pump to be brought to the reference flow or pressure followed by recording and evaluation of both the flow and pressure readings.

Both opinions can be supported by the applicable OM Code verbiage. However, NRC personnel have expressed a reluctance to accept the "bump" test interpretation.

Position: Group B pump testing should be performed as follows:

1. When performing a Group B pump test, both hydraulic test parameters (i.e., flow and differential pressure OR flow and discharge pressure) shall be measured and evaluated in accordance with the applicable Code requirements for the pump type.

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2. Vibration measurements are not required for Group B pump tests. Vibration measurements may continue to be taken optionally. In the event that a vibration reading exceeds an alert or required action limit for the comprehensive test for the pump being tested, an IR shall be written and corrective action taken in accordance with the CAP process.

References:

1. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTB.

Revision 7 10/21/2016

Number: CTP-IST-004, Rev. 1

Title:

Classification of Pumps: Centrifugal vs. Vertical Line Shaft Applicability: All Exelon IST Programs

Background:

Early Code documents that provided requirements for inservice testing of pumps did not differentiate between pump types. Subsection IWP of the ASME Boiler and Pressure Vessel Code, Section XI, required the measurement of flow, differential pressure and vibration and comparison of the measured data with reference values, similar to the way in which centrifugal pump testing is currently performed. Some additional measurements were required (e.g., bearing temperature, lubrication level or pressure) which were later determined to be of minimal value to IST. A major limitation in the earlier Code was that the same parameters and acceptance criteria were specified for all pumps.

With the development of the OM Standards (OM-1, OM-6, OM-10, etc.), it was recognized that pumps of different design performed differently and required different measurement criteria to determine acceptable performance. For example, discharge pressure was determined to be a more representative measurement of performance for a positive displacement pump than differential pressure. Part 6 of the OM Standards (OM-6), also introduced different criteria for inservice testing of centrifugal and vertical line shaft pumps. Unfortunately, it did not provide any definition for a vertical line shaft pump.

The definition of "vertical line shaft" pump was first incorporated into the OM-1998 Edition of the OM Code as "a vertically suspended pump where the pump driver and pump element are connected by a line shaft within an enclosed column.* This definition failed to eliminate much of the uncertainty in determining whether certain pumps were vertically-oriented centrifugal pumps or vertical line shaft pumps. Further confusion was created by the choice of wording used in the OM Code Tables that specify the acceptance criteria for centrifugal and vertical line shaft pumps.

Position: Code requirements for vibration measurement provide the clearest indication of the difference between a centrifugal pump and a vertical line shaft pump. On centrifugal pumps, vibration measurements are required to be taken in a plane approximately perpendicular to the rotating shaft in two approximately orthogonal directions on each accessible pump-bearing housing and in the axial direction on each accessible pump thrust b,earing housing. On vertical line shaft pumps, measurements are required to be taken on the upper motor-bearing housing in three approximately orthogonal directions, one of which is the axial direction.

• Therefore, a pump which is connected to its driver by a vertically-oriented shaft in which vibration measurements must be taken on the pump motor due to the inaccessibility of the pump bearings will be classified as a vertical line shaft pump.

For plants using the 1998 Edition of the OM Code through the OMb-2003 addenda, Table ISTB-5100-1 applies to all horizontally and vertically-oriented centrifugal pumps; Table ISTB-5200-1 applies to vertical line shaft pumps. For plants using the 2004 Edition of the OM Code and later, Table ISTB-5121-1 applies to all horizontally and vertically-oriented centrifugal pumps; Table ISTB-5221-1 applies to vertical lin~ shaft pumps.

Revision 7 10/21/2016

References:

1. ASME OMa-1988, ASME/ANSI Operation and Maintenance of Nuclear Power Plants, Part 6, lnservice Testing of Pumps in Light-Water Reactor Power Plants.

2. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTB.

Revision 7 10/21/2016

Number: CTP*IST*OOS, Rev. 1

Title:

Preservice Testing of Pumps Applicability: OM-1995 Code and Later

Background:

Requirements for preservice testing of pumps have been stated in ASME Code documents since the beginning. However, the 1995 Edition of the OM Code significantly expanded the scope of preservice testing by introducing the requirement that centrifugal and vertical line shaft pumps in systems where resistance can be .varied establish a pump curve by measuring flow and differential pressure at a minimum of five points.

These points are required to be from pump minimum flow to at least design flow, if practicable. At least one point is to be designated as the reference point for future inservice tests.

The OM Codes further state that it is the responsibility of the Owner to determine if preservice testing requirements apply when reference values may have been affected by repair, replacement, or maintenance on a pump. A new reference value or set of values is required to be determined or the previous reference value(s) reconfirmed by a comprehensive or Group A test prior to declaring the pump operable.

Position: Whenever a pump's reference values may have been affected by repair, replacement, or maintenance, a preservice test SHALL be performed .in accordance with the preservice test. requirements of Reference 1 of this CTP for the applicable pump design. If it is determined through evaluation that the maintenance activity did not affect the existing reference values, then the previous reference value(s) SHALL be reconfirmed by a comprehensive or Group A test prior to declaring the pump operable. Evaluation that the maintenance activity did not affect the* pump's reference values SHALL BE DOCUMENTED. .

Since a preservice test may be substituted for any other required inservice test, this test could be performed in place of any quarterly or comprehensive test. Pertorming it in lieu of a comprehensive test would have minimal. impact on test scope or schedule and would provide valuable information for subsequent evaluations of pump performance.

For centrifugal and vertical line shaft pumps in systems with variable resistance, one of the five points on the preservice test curve (preferably one between 100% and 120% of design flow but in no case less than 80% of design flow) SHALL be selected as the reference point for the comprehensive tests. If quarterly testing will be performed at full flow, then the same point should be selected for the quarterly pump tests. If quarterly

. testing cannot be performed at full flow, then another point on the preservice test curve SHALL be selected as the reference point for the quarterly tests.

References:

1. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTB ..

Revision 7 10/21/2016

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Number: CTP-IST-006, Rev. 1

Title:

Classification and Testing of Class 1 Safety/Relief Valves With Auxiliary Actuating Devices Applicability: All Exelon IST Programs

Background:

The definition for valve categories in the ASME Codes has been consistent since the beginning. Category A, B, C and D valves are basically defined the same now as they were iri early editions/addenda of Section XI of the ASME Boiler and Pressure Vessel Code. Likewise, the requirement that valves meeting the definition for more than one category be tested in accordance with all the applicable categories has been consistent over time.

Due to a lack of clear testing requirements for Class 1 Safety/Relief Valves With Auxiliary Actuating Devices in early ASME Codes, these valves were historically

• classified as Category B/C. As relief valves, they were required to meet the Category C testing requirements; and since the auxiliary operators essentially put them in the classification of power-operated valves, Category B requirements were imposed to address stroke~time and position indication testing considerations.

Position: The B/C categorization of these valves was initially made due to a lack of specific Code requirements. However, with the publication of ASME OM Standard OM-1 in 1981, which identified specific requirements for these valves, it became irrelevant. All applicable testing requirements for these valves were specified in OM-1, which has been superceded by Appendix I of the ASME OM Code. Efforts of the Code to exempt these valves from Category B testing requirements further demonstrate their inapplicability.

Therefore, these valves should be classified as Category C. *

References:

1. ASME OM-1987, ASME/ANSI Operation and Maintenance of Nuclear Power Plants, Part 1, Requfrements for lnservice Performance Testing of Nuclear Power Plant Pressure Relief Devices.

2. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTC and Appendix I. * *

• Revision 7 10/21/2016

Number: CTP-IST-007, Rev. 1

Title:

Skid-Mounted Components Applicability: All Exelon IST Programs

Background:

The term "skid-mounted component" was coined to describe support components, such as pumps and valves for the purposes of IST, that function in the operation of a supported component in such a way that their proper functioning is confirmed by the operation of the supported component. For example, the successful operation of an emergency diesel-generator set confirms that essential support equipment, such as cooling water and lube oil pumps and valves, are functioning as required. The concept of "skid-mounted" is actually irrespective of physical location.

Position: Components that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident are required to tested in accordance with the ASME Code-in-effect for the station's IST Program. It is not the intent of the skid-mounted exemption that it be used in cases where the specific testing requirements of the Code for testing of pumps and valves can be met. For example, if adequate instrumentation is provided to measure a pump's flow and differential pressure, and if required points for vibration measurement can be accessed, then invoking the skid-mounted exemption would be inappropriate.

The "skid-mounted" exclusion as stated in references 2 and 3, below, may be applied to pumps or valves classified as "skid-mounted" in the IST Program provided that they are tested as part of the major component and are justified to be adequately tested. Such components SHALL be listed in the Program Plan document and identified as skid-mounted. Pump or Valve Data Sheets which contain the justification regarding the adequacy of their testing SHALL be provided in the IST Bases Document.

References:

1. NUREG-1482 (Rev.o and Rev.1 ), Section 3.4, Skid-Mounted Components and Component Subassemblies

2. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition OMa-1996 Addenda, !STA 1.7, ISTC 1.2.

3. ASME OM Code; Code for Operation and Maintenance of Nuclear Power Plants, 1998 Edition and later, ISTA-2000 and ISTC-1200.

Revision 7 10/21/2016

Number: CTP-IST-008, Rev. 1

Title:

Position Verification Testing Applicability: All Exelon IST Programs

Background:

Valves with remote position indicators are required to be observed locally at least once every two years to verify that valve operation is accurately indicated. This local observation should be supplemented by other indications to verify obturator position.

Where local observation is not possible, other indications shall be used for verification of valve operation.

Position: All valves within the scope of the IST Program that are equipped with remote position indicators, shall be tested. The testing shall clearly demonstrate that the position

' indicators operate as required and are indicative of obturator position. For example, a valve that has open and closed indication shall be cycled to demonstrate that both the open and closed indicators perform as designed, including both or neither providing indication when the valve is in mid-position. Valves that have indication in one position only shall be cycled to ensure that the indicator is energized/de-energized when appropriate. These requirements apply to all IST valves, regardless of whether they are classified as active or passive.

References:

1. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition with OMa-1996 Addenda, para ISTC 4.1.

2. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1998 Edition and later, para ISTC-3700.

3. NUREG-1482, Rev. 1, Section 4.2.8 Revision 7 10/21/2016

Number: CTP-IST-009, Rev. 0

Title:

ASME Class 2 & 3 Relief Valve Testing Requirements Applicability: All Exelon IST Programs

Background:

The ASME OM Code, Appendix I, provides requirements for lnservice Testing of ASME Class 1, 2, and 3 Pressure Relief Devices. The requirements for Class 1 pressure relief devices are identified separately from those for Classes 2 and 3.

The requirements for Class 2 and 3 pressure relief devices are identified together.

This Technical Position applies only to ASME Class 2 and 3 safety and relief valves. It does not include vacuum breakers or rupture discs. Class 2 PWR Main Steam Safety Valves are also not included in this Technical Position because they are required to be tested in accordance with ASME Class 1 safety valve requirements.

Position: This Technical Position applies to the classification, selection, scheduling and testing of ASME Class 2 and 3 safety and relief valves only. For the purposes of this Technical Position, the term "relief valve" will be used to apply to both types.

Classification .

DETERMINE whether or not the valve may be classified as a thermal relief. A thermal relief valve is one whose only over-pressure protection function is to protect isolated components, systems, or portions of systems from fluid expansion caused by changes in fluid temperature. If a relief valve is required to perform any other function in protecting a system or a portion of a system that is required to place the reactor in. the safe shutdown condition, to maintain the safe shutdown condition, or to mitigate the consequences of an accident, *it cannot be classified as a thermal relief valve.

Class 2 and Class 3 thermal relief valves are required to be TESTED or REPLACED every 1O years unless performance data indicates the need for more frequent testing or replacement. Details regarding whether a Class 2 or Class 3 thermal relief valve is tested or replaced and the bases for the associated frequency SHALL be documented in the IST Bases Document.

Grouping, sample expansion and the requirement to test 20% of the valves within any 48-month period do not apply to Class 2 and Class 3 thermal relief valves.

Class 2 and 3 thermal relief valves may be optionally tested in accordance with the more conservative requirements for non-thermal relief valves if desired.

Non-thermal relief valves shall be grouped in accordance with the grouping criteria of Appendix I (same manufacturer, type, system application, and service media). Groups may range in size from one valve to all of the valves meeting the grouping criteria. Grouping criteria SHALL be documented in the IST Bases Document or other document that controls Class 2 and 3 IST relief valve testing.

If two valves are manufactured at the same facility to the same specifications, dimensions, and materials of construction but under a different manufacturer's name due to a merger or acquisition, the valves may be considered to meet the requirement for same manufacturer.

Valves in systems containing air or nitrogen may be considered to have the same service media.

Revision 7 10/21/2016

--~ :_- -_:._*_:.:_~_- ____-:::: - .:. _ __

_: -~ *:---

Selection Valves SHALL be selected for testing such that the valve(s) in each group with the longest duration since the previous test are chosen first. This SHALL INCLUDE any valves selected due to sample expansion.

IF an exception to this requirement is necessary due to accessibility or scheduling considerations, DOCUMENT the reason and that the valves that should have been selected will not come due prior to the next opportunity to test them (e.g.,

the next outage).

Scheduling Grace is NOT permitted for relief valve testing, unless authorized by an NRC-approved relief request.

• All frequency requirements are test-to-test (i.e., they begin on the most recent date on which the valve was tested per Appendix I requirements and end on the date of the next Appendix I test).

All Class 2 or Class 3 relief valves in any group must be tested at least once every 10 years.

Valves within each group must be tested such that a minimum of 20% of the valves are tested within any given 48-month period.

If all of the valves in a group are removed for testing and replaced with pretested valves, the removed valves shall be tested within 12 months of removal from the system.

If less than all of the valves. in a group are removed for testing and replaced with preteSted valves, the removed valves shall be tested within 3 months of removal from the system or before resumption of electric power generation, whichever is later.

Testing of pretested valves must have been performed such that they will. meet the 1O year and 20% I 48-nionth requirements for the entire time they are in service.

Testing of relief valves that is required to be performed during an outage SHALL BE PERFORMED as early in the outage as practicable in order to allow for contingency testing of additional valves in the event a scheduled valve fails its as-tound test.

• Testing Testing SHALL BE PERFORMED using the same service media wherein the valve was installed.

Testing of additional valves due to failure of a scheduled valve to meet its as-tound setpoint acceptance criteria SHALL BE PERFORMED in accordance with all applicable OM Code and Technical Specification requirements.

Revision 7 10/21/2016

References:

1. ASME OM Code, 1995 Edition and later, Mandatory Appendix I, lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants Revision 7 10/21/2016

Number: CTP-IST-010, Rev. 0

Title:

ERV and PORV Testing Requirements Applicability: Exelon Stations with Electromatic Relief Valves or Power-Operated Relief Valves

Background:

Electromatic Relief Valves (ERVs) and Power-Operated Relief Valves (PORVs) are used at nuclear plants to protect the Reactor Coolant pressure boundary from overpressure under various conditions. This may include preventing excessive challenges to BWR Main Steam Safety Valves and PWR Pressurizer Safety Valves during operation at power or preventing low temperature overpressure (LTOP} conditions from exceeding brittle fracture limits when the plant is cooled down.

ERVs and PORVs come in a variety of designs, which can make their categorization and testing in accordance with OM Code requirements challenging.

Some are actual relief valves that are equipped with air operators to open the valves against spring force upon actuation by some pressure-sensing apparatus in the primary coolant system. Others may be motor-operated gate valves that open and close as a result of signals generated at predetermined pressure settings. The key to determining the proper category of the ERV or PORV is not the nomenclature of the valve (i.e., "relief valve"), but the actual physical design of the valve and its actuator.

Power-operated relief valves were not addressed by the ASME Codes until the OMa-1996 Addenda. Even then, they were only alluded to by the addition of an exclusion to paragraph ISTC 1.2 which stated: "Category A and B safety and relief valves are excluded from the requirements of ISTC 4.1, Valve Position Verification and ISTC 4.2, lnservice Exercising Test." Up to this point, Owners typically categorized these valves as Category B/C, assigned the position verification and exercise test requirements for the Category B portion, and then obtained Relief from the NRC to not perform them due to their impracticability. The Relief Requests provided a detailed description of the proposed alternative techniques, which generally matched Category C requirements for valves with auxiliary actuators.

Paragraph ISTC-5110 was introduced in the OM-1998 Edition of the OM Code which stated: "Power-operated relief valves shall meet the requirements of ISTC-5100 for the specific Category B valve type and ISTC-5240 for Category C valves." This essentially added no value, since this was already the practice.*

OMb-2000 added the following definition of a power-operated relief valve to paragraph ISTC-2000, Supplemental Definitions: "a power-operated valve that can perform a pressure relieving function and is remotely actuated by either a signal from a pressure sensing device or a control switch. A power-operated relief valve is not capacity certified under ASME Section 111 overpressure protection requirements." In addition, OMb-2000 added the following to paragraph ISTC-351 O: "Power-operated relief valves shall be exercise tested once per fuel cycle."

The addition of exclusions, definitions and test requirements to the Code for these valves has only tended to make actual testing requirements more conflicting or confusing. These valves are still being categorized as Category B, C or B/C (with a few A's or A/C's) throughout the industry with testing requirements assigned accordingly and relief still being sought where deemed appropriate.

Revision 7 10/21/2016

Position: Each Station MUST DETERMINE the proper valve category or categories for its ERVs and/or PORVs based on valve and actuator design, and IDENTIFY appropriate testing requirements and methodologies appropriate to that categorization. The following table summarizes the possible categories that can be applied to an ERV or PORV, whether or not the valve meets the definition of a PORV as defined in ISTC-2000, and the associated test requirements:

Meets Category PORV Test Requirements Comments Def.

B c B c x* No ISTC- Valve is not a safety or relief valve; 3700 actuator is MO, AO or HO. Does not ISTC- meet Code definition of PORV (ISTC-5120* 2000). Exercise test quarterly per ISTC- . ISTC-351 O, or defer to Cold Shutdown 5130* or RFO per ISTC-3521.

ISTC-5140*

x Yes ISTC- Valve meets Code definition of PORV 3700 (ISTC-2000). Exercise test once per ISTC- fuel cycle per ISTC-3510 and ISTC-5110 5110.

x No ISTC- Valve is a relief valve with AO or HO 5240 actuator. Does not meet Code App.I definition of PORV (ISTC-2000).

E.Xempt from Cat 8 testing {ISTC-3500/ISTC-3700) oer ISTC-1200.

x x No ISTC* Valve is a relief valve with AO or HO 5240 actuator. Does not meet Code App. I definition of PORV (ISTC-2000).

Exempt from Cat 8 testing (ISTC-3500/ISTC-3700} per ISTC-1200.

x x Yes ISTC- Should not be classified Category C.

3700 Relief valves do not meet the Code ISTC* definition of PORV (ISTC-2000).

5110

• As applicable A Relief Request SHALL BE SUBMITTED for any ERV or PORV that does not meet the applicable test requirements specified in the above table.

A detailed description of the rationale behind the category designation, the assignment of testing requirements, and how they are satisfied SHALL BE PROVIDED on the applicable IST Bases Document Valve Data Sheets.

References:

1. ASME OM Code, 1995 Edition and later, Subsection ISTC, lnservice Testing of Valves in Light-Water Reactor Nuclear Power Plants

2. ASME OM Code, 1995 Edition and later, Mandatory Appendix I, lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants Revision 7 10/21/2016

Number: CTP-IST-011;Rev. 0

Title:

Extension of Valve Exercise Test Frequencies to Cold Shutdown or Refueling Outage Applicability: All Exelon IST Programs

Background:

Requirements for exercise testing of Category A and B power-operated valves and check valves (Category C) are stipulated in the OM Code as follows:

ISTC-3510 states: "Active Category A, Category Band Category C check valves shall be exercised nominally every 3 mo, except as provided by paras. ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221 and ISTC-5222." Plant Technical Specifications for IST identify the 3 month frequency as once per 92 days with allowance for a 25% extension.

ISTC-3520 is divided into ISTC-3521 for Category A and Category B valves, and ISTC-3522 for Category C check valves. ISTC-3521 states: "Category A and B valves shall be tested as follows:

a. fUll-stroke exercising of Category A and Category B valves during operation at power to the position(s) required to fulfill its function(s).

b. if full-stroke exercising during operation at power is not practicable, it may be limited to part-stroke during operation at power and full-stroke during cold shutdowns.

c. if exercising is not practicable during operation at power, it may be limited to full-stroke exercising during cold shutdowns.

d. if exercising is not practicable during operation at power and full-stroke during cold shutdowns is also not practicable, it may be limited to part-stroke during cold shutdowns and full-stroke during refueling outages.

e. if exercising is not practicable during operation at power or cold shutdowns, it may be limited to full-stroke during refueling outages.

Paragraphs {f) through (h) provide additional limitations on cold shutdown and refueling outage exercise testing.

ISTC-3522 provides essentially the same requirements for check valves except that the requirement to consider partial-stroke exercising is not included.

JSTC-3540 stipulates exercise testing frequency requirements for manual valves.

ISTC-3550 discusses valves in regular use, ISTC-3570 addresses valves in systems out-of-service, ISTC-5221 addresses special frequency considerations for check valves in a sample disassembly and inspection program, and ISTC-5222 addresses check valves in a condition monitoring program.

ISTC-3521 makes it clear that the intent of the Code is for valves to be exercised quarterly unless it is impracticable to do so. When it is impracticable, the graduated approach of ISTC-3521 through cold shutdown and refueling frequencies and partial and full-stroke exercising impose an obligation on the owner to perform at least some testing as frequently as practicable.

Revision 7 10/21/2016

The determination of "practicability is left to the owner. The industry has universally adopted the practice of writing Cold Shutdown and Refueling Outage Justifications to document conditions that they believe to be impracticable".

There are no Code or regulatory definitions of impracticability nor are there any Code or regulatory requirements to prepare Cold Shutdown or Refueling Outage Justifications. However, Reference 2 provides a good deal of useful guidance regarding a regulatory opinion of what constitutes it. Merriam-Webster defines "impracticable" as (1) impassable or (2) not practicable; incapable of being performed or accomplished by the means employed or at command".

Position: The following direction SHALL BE IMPLEMENTED when establishing exercise test frequencies for power-operated Category A and B valves and Category C check valves:

1. Stations SHALL DETERMINE the practicability of performing exercise testing of all valves in their IST Programs in accordance with the Code.

2. When preparing or performing a technical revision to a Cold Shutdown or Refueling 0l1tage Justification, the Station IST Engineer SHALL OBTAIN a peer review from the Corporate IST Engineer and at least one other Site IST Program Engineer.

3. Cold Shutdown and Refueling Outage* Justifications SHALL PROVIDE a strong, clear technical case for the testing deferr~I. References to NUREG-1482 may be made to support the justification; however, it is not to be cited as the.justification itself. *

References:

1. ASME OM Code, 1995 Edition and later, Subsection ISTC, lnservice Testing of Valves in Light-Water Reactor Nuclear Power Plants

2. NUREG 1482, Revision 1, Guidelines for lnservice Testing at Nuclear Power Plants, Sections 2.4.5 and 3.1.

• Revision-*7 10/21/2016

Number: CTP-IST-012, Rev. O

Title:

Use of ASME OM Code Cases for lnservice Tes~ing Applicability: All Exelon IST Programs

Background:

Code Cases are issued to clarify the intent of existing Code requirements or to provide alternatives to those requirements. Adoption of the alternative requirements provided by Code Cases are optional; they only become mandatory when an owner commits to them. Code Cases are included as a separate section at the end of published editions/addenda of the OM Code for the user's convenience. They are not a part of any Code edition or addenda and endorsement of specific editions/ addenda of the OM Code by the NRC does not constitute endorsement of the Code Cases.

If the Code Committee desires to make the requirements of a Code Case mandatory, those requirements are incorporated into the Code at a later date. For example, Code Case OMN-1, Alternative Rules for Preservice and lnservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, was incorporated into the 2009 Edition of the OM Code as Mandatory Appendix Ill. Appendix Ill will become mandatory for IST Programs when 10 CFR 50.SSa imposes the requirement that 10-year interval updates meet the requirements of the 2009 Edition of the ASME Code or later. Until such time, plants may optionally implement OMN-1 or may continue to perform stroke-time testing and position indication verification in accordance with Subsection ISTC requirements.

• In order for an OM Code Case to be used in an lnservice Testing Program at a nuclear power plant, it must be authorized by ASME and approved by the NRC. A Code Case is authorized for use by ASME as soon as it is published, provided certain limitations included in the Code Case, such as the applicability statement, are met. OM Code Cases are published on the ASME Web site at http://

cstools.asme.org and in Mechanical Engineering magazine as they are issued.

Efforts to clarify or simplify the use of Code Cases have instead created conflicting requirements which need to be addressed in order to avoid noncompliance with the Code or CFR. These include:

• The Code of Federal Regulations, paragraph 10 CFR 50.55a(b)(6} states that Licensees may apply ASME OM Code Cases listed in Regulatory Guide 1.192 without prior NRC approval subject to certain conditions. One condition states that when a licensee initially applies a listed Code case, the licensee shall apply the most recent version of the Code case "incorporated by reference in this paragraph". A second condition states that if a licensee has previously applied a Code case and a later version of the Code case is "incorporated by reference in this paragraph", the licensee may continue to apply, to the end of the current 120-month interval, the previous version of the Code case or may apply the later version of the Code case, including any NRG-specified conditions placed on its use. A third condition restricts the use of annulled Code cases to those that were in use prior to their annulment.

It is not clear what "incorporated by reference in this paragraph" is referring to. If this paragraph" means 10 CFR 50.55a(b)(6}, this would refer to Reg Revision 7 10/21/2016

Guide 1.192. If it refers more broadly to 10 CFR 50.55a(b), this would also include 10CFR 50.55a(b)(3), which contains the endorsement of the latest edition/addenda of the OM Code approved for use by the NRC. In the first case, Reg Guide 1.192 was published in June 2003 with no revisions to date.

Versions of the Code cases referenced therein have all exceeded their expiration dates and are not applicable to current Code editions. In the latter case, since Code Cases are independent of Code editions/addenda, there is a disconnect between approval of Code versus Code Cases.

• Requirements for the use of Code Cases are stipulated in the body of the OM Code. In all cases from the OM-1995 Edition through the OMa-2011 Addenda, it is required that "Code Cases shall be applicable to the edition and addenda specified in the inservice test plan" and " Code Cases shall be in effect at the time the inservice test plan is filed". These requirements are almost never met.

• Code Cases provided as attachments up to and including the OMb-2006 Addenda contained expiration dates. These dates are usually prior to the time it is desired to use the Code Case.

• Each Code Case contains an applicability statement. Even in the latest Edition/addenda of the Code incorporated by reference in 10 CFR 50.55a, these statements usually indicate that the Code Case applies to earlier versions of the Code than what is required to be used.

Despite the inconveniences in implementing Code Cases, they often provide alternatives to the Code that are technically superior and highly desirable from a cost-efficiency perspective. Therefore, each plant should review the potential use of Code Cases with Corporate Engineering, particularly when in the process of performing 10-year updates.

Position: The following requirements SHALL BE IMPLEMENTED in order to use ASME OM Code Cases at Exelon stations:

1. All Code Cases used by a Station for their IST Program SHALL BE LISTED in the JST Program Plan. *

2. Code Case expiration dates, applicability statements, and the Edition/

addenda of the Code-in-effect for a Station's IST Program SHALL all be compatible tor Code Cases implemented in an IST Program OR a Relief Request SHALL BE SUBMITTED to use the Code Case in accordance with Refere nee 2 of this CTP.

References:

1. ASME OM Code, 1995 Edition and later, Subsection ISTA, General Requirements

2. ER-AA-321, Administrative Requirements for lnservice Testing Revision 7 10/21/2016

Number: CTP-IST-013, Rev. 0

Title:

Exercise Testing Requirements for Valves with Fail-Safe Actuators Applicability: All Exelon IST Programs

Background:

Valves with fail-safe positions usually have actuators that use the fail-safe mechanism to stroke the valve to the fail-safe position during normal operation.

For example, an air-operated valve that fails closed may use air to open the valve against spring pressure. When the actuator is placed in the closed position, air is vented from the diaphragm and the spring moves the obturator to the closed position.

The fail-safe test is generally an integral part of the stroke time exercise test and is thus performed at the same frequency. Where the exercise test is performed less frequent than every 3 months, a cold shutdown justification, refueling outage justification, or relief request is required. The same justification for the stroke time exercise test would also apply to the fail-safe test.

'Position: In cases where normal valve operation moves the valve to the fail-safe position by de-energizing the operator electrically, by venting air, or both (e.g., a solenoid valve in the air supply system of a valve operator moves to the vent position on loss of power), no additional fail-safe testing is required .

. In cases where a fail-safe actuator does not operate as an integral part of normal actuator operation, the fail-safe feature(s) must be tested in a manner that demonstrates proper operation of each component that contributes to the fail-safe operation. The means used to meet this requirement shall be described in the IST Bases Document.

References:

1. ASME OM Code, Code for Operation anc;I Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTC.

Revision 7 10/21/2016

Number: CTP-IST-014, Rev. 0

Title:

Bi-directional Testing of Check Valves to Their Safety and Non-Safety Related Positions

• Applicability: All Exelon IST Programs

Background:

This CTP addresses those cases in which inservice testing of check valves is performed in accordance with the requirements of ISTC-5221. It does not address these issues for check valves that are included in a Condition Monitoring Program. References 2 and 3 of this *CTP provide additional information regarding check valve testing and Condition Monitoring.

The OM Code changed the focus of inservice testing of check valves from the ability to demonstrate that a check valve was capable of being in its safety-related position to demonstrating that the obturator was capable of free, unobstructed movement in both directions. This was accomplished by introducing a bidirectional testing requirement to inservice testing of check valves. Confirmation of this change in focus is evidenced by the fact that the Code required frequency for bi-directional testing of check valves is the lesser of the frequencies that the open direction and close direction tests can be performed. In other words, if a check valve is capable of being tested in the open direction quarterly but can only be tested closed during refueling outages, the Code required frequency for the bidirectional test is every refueling outage irrespective of the valve's safety position(s).

Condition Monitoring is the preferred method for check valve testing and inspection. For check valves that are not in a Condition Monitoring Program, the OM Code provides three options: flow/flow reversal, use of an external mechanical exerciser, and sample disassembly/examination. Of these, the flow and mechanical exerciser methods are preferred; the Code limits sample disassembly/ examination to those cases where the others are impractical. In all of these non-Condition Monitoring methods, demonstration of unobstructed obturator travel in the open and closed directions is required.

Position: The following requirements SHALL BE MET when implementing this CTP:

1. When using flow to demonstrate opening of a check valve with an open safety function, OBSERVE that the obturator has traveled to EITHER the full open position OR to the position required to perform its intended safety function(s).

• Travel to the position required to perform its intended safety function(s) is defined as the minimum flow required to mitigate the system's most limiting accident requirements. For example, if three different accident scenarios called for flows of 300, 600 and 1000 gpm respectively, the required test flow would be 1000 gpm.

The full open position is defined as the point at which the obturator is restricted from further travel (e.g., hits the backstop). Methods for demonstrating travel to the full open position must be qualified if less than required accident flow is used.

Revision 7 10/21/2016

2. When using flow to demonstrate that the obturator of a valve that does not have an open safety function has traveled open, the test MUST DEMONSTRATE that the obturator is unimpeded.

3. Tests for check valve closure MUST DEMONSTRATE that the check valve has travelled to the closed position, not merely that it is in the closed position.

4. Whenever design requirements are used for IST acceptance criteria, instrument accuracy MUST BE CONSIDERED. This can be accomplished by determining that sufficient margin was included in the design calculation or by adding a correction to the IST acceptance criteria.

5. Non-intrusive methods used to credit obturator position SHALL BE QUALIFIED. Documentation of the means used to qualify the test method(s) shall be documented in the IST Bases Document

6. The Code requirement satisfied for each check valve, identification of the method used to satisfy the Code requirement, and a description of how the method satisfies the requirement SHALL BE PROVIDED OR RERENENCED on the Valve Data Sheet in the IST Bases Document for each check valve.

References:

1. "* ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition and later, Subsection ISTC. *

2. ER-AA-321, Administrative Requirements for lnservice Testing

3. ER-AA-321-1005, Condition Monitoring for lnservice Testing of Check Valves Revision 7 10/21/2016

ATTACHMENT 14 INSERVICE TESTING PUMP TABLE with P&ID Revision 7 10/21/2016

Clinton Station IST PROGRAM PLAN Dlesel Fuel 011 (Page 1)

PumpEIN Class P&ID P&IO Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Jusl Pos.

1D001PA 3 1036, 1 B1 PD MOTOR 1750 A Comprehensive Y2 A Group A M3 Pump Name Diesel OD Transfer Pump A 10001PB 3 1036, 1 BS PD MOTOR 1750 A Comprehensive Y2 A Group A M3 Pump Name Diesel 011 Transfer Pump B 10001PC 3 1036,2 B4 PD MOTOR 1750 A Comprehensive Y2 A Group A M3 Pump Name Diesel 011 Transfer Pump C Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Fuel Pool Cooling (Page 1)

Pump EIN Class P&ID P&ID Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just. Pos.

1FC02PA 3 1037 *3 E*7 c MOTOR 1780 A Compmhenslve Y2 A Group A M3 Pump Name Fuel Pool Cooling and Clean-Up Pump A 1FC02PB 3 1037-3 B-7 c MOTOR 1780 A Comprehensive Y2 A Group A M3 Pump Name Fuel Pool Cooling and Clean-Up Pump B Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN High Pressure Core Spray (Page 1)

PumpEIN Class P&ID P&ID Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just. Pos.

1E22-C001 2 1074 B3 VLS MOTOR 1780 B Comprehensive Y2 B Group B M3 Pump Name High Pressure Core Spray (HPCS) P1111p 1E22-C003 2 1074 cs c MOTOR 3500 A Comprehensive Y2 A Group A M3 Pump Name HPCS Water Leg Pump Revision Date: 10/21/2016

<;:linton Station IST PROGRAM PLAN Low Pressure Core Spray (Page 1)

PumpEIN Class P&ID P&ID Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just. Pos.

1E21-C001 2 1073 E7 VLS MOTOR 1780 B Comprehensive Y2 B Group B M3 Pump Name Low Pressure Core Spray (LPCS) Pump 1E21-C002 2 1073 07 c MOTOR 3500 A Comprehensive Y2 A Group A M3 3201 Pump Name LPCS and AHR Loop A Water Leg Pump Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 1)

PumpEIN Class P&ID P&ID Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just. Pos.

1E12*C002A 2 075Sht: A*7 VLS MOTOR 1780 A Comprehensive Y2 A Group A M3 Pump Name Residual Heat Removal (AHR) Pump A 1E12-C002B 2 075Sh1.: B-4 VLS MOTOR 1780 A Comprehensive Y2 A Group A M3 Pump Name Residual Heat Removal (AHR) Pump B 1E12-C002C 2 075 Sht.: 8*3 VLS MOTOR 1780 B Comprehensive Y2 B Group B M3 Pump Name Residual Heat Removal {AHR) Pump C 1E12*C003 2 075Sht.: C-3 c MOTOR 3500 A Comprehensive Y2 A Group A M3 3201 Pump Name AHR LOOP B/C Water Leg Pump Revision Date: 10121/2016

Clinton Station IST PROGRAM PLAN Reactor Core Isolation Cooling (Page 1)

Pump EIN Class P&ID P&IO Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just. Pos.

1E51-C()01 2 1079, 2 E1 c TURBINE 2550 B Comprehensive Y2 B GroupB M3 Pump Name Reactor Core Isolation Cooling (RCIC) Pump 1E51.C003 2 1079,2 85 c MOTOR 3500 A Comprehensive Y2 A Group A M3 3201 Pump Name RCIC Water Leg Pump Revision Date: 10121/2016

Cllnton Station IST PROGRAM PLAN Standby Liquid Control (Page 1)

PumpEIN Class P&ID P&ID Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just. Pos.

1C41*C001A 2 1on cs PD MOTOR 368' B Comprehensive Y2 B Group B M3 Pump Name Standby Liquid Control (SLC) Pump A 1C41-C001B 2 10n ES PD MOTOR 368' B Comprehensive Y2 B Group B M3 Pump Name Standby Liquid Control (SLC) Pump B Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Shutdown Service Water (Page 1)

Pump EIN Class P&ID P&ID Pump Driver Nominal Group Test Type Freq. Relief Deferred Tech.

Coor. Type Speed Request Just Pos.

1SX01PA 3 1052 07 VLS MOTOR 895 B Comprehensive Y2 B Group B M3 Pump Name Shutdown Service Water Pump A 1SX01PB 3 1052 07 VLS MOTOR 895 B Comprehensive Y2 B Group B M3 Pump Name Shutdown Service Water Pump B 1SX01PC 3 1052 07

• VLS MOTOR 1760 B Comprehensive Y2 B Group B M3 Pump Name Shutdown Service Water Pump C Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Control Room Ventllatlon (Page 1)

Pump EIN Class P&ID P&ID Pump Driver Nomlnal Group Test Type Freq. Rellel Deferred Tech.

Coor. Type Speed Request Just Pos.

OVCOBPA 3 1102,5 07 c MOTOR 1770 A Comprehensive Y2 A Group A M3 Pump Name Conlrol Room HVAC Chilled Water Pump A .

OVCOBPB 3 1102, 6 07 c MOTOR 1770. A Comprehensive Y2 A Group A M3 Pump Name Control Room HVAC Chilled Water Pump B Revision Date: 10121/2016

ATTACHMENT 15 INSERVICE TESTING VALVE TABLE with P&ID Revision 7 10/21/2016

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Revision 7 10/21/2016

Clinton Station IST PROGRAM PLAN Component Cooling Water (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request J4sl Pos.

1CC049 10 GA MO 1032,3 CB 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CCW SUPPLY CMNT OUTBOARD ISOLATION VALVE 1CC050 6 GA MO 1032, 3 C7 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CCWCNMT FEED LINE INBOARD ISOL VALVE 1CC053 6 GA MO 1032, 3. C3 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CCW RETURN LINE CNMT INBOARD ISOLATION VALVE 1CC054 10 GA MO 1032,3 C1 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CCW CNMT RETURN LINE OUTBOARD ISOLATION VALVE 1CC057 8 GA MO 1032, 3 D-8 2 0 c B A DIA MDV EX Y2 2201&04 Valve Name CCW DRYWELL ISOLATION VALVE 1CC060 8 GA MO 1032,3 C-2 2 0 c A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name CCW RETURN FROM NRHX INBOARD ISOLATION VALVE 1CC071 4 GA MO 1032, 3 E2 2 c c A p LTJ AJ Valve Name SSW CNMT FEED LINE INBOARD !SOL VALVE 1CC072 4 GA MO 1032,3 E1 2 c c A p LTJ AJ Valve Name SSW CNMT FEED LINE OllTBOARD !SOL VALVE 1CC073 4 GA MO 1032, 3 F1 2 c c A p LTJ AJ Valve Name SSW CNMT FEED LINE OUTBOARD ISOL VALVE 1CC074 4 GA MO 1032, 3 F2 2 c c A p LTJ AJ Valve Name SSW CNMT FEED LINE INBOARD !SOL VALVE 1CC075A 14 BTF MO 1032, 2 E3 3 0 c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name FC HEAT EXCHANGER 1A CCW INLET VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Component Cooling Water (Page 2)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relfef Deferred Tecfl.

Type Coord Position Position Type Freq. Request Just. Pos.

1CC075B 14 BTF MO 1032, 2 C3 3 0 c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name FC HEAT EXCHANGER 1B CCW INLETVALVE 1CC076A 14 BTF MO 1032, 2 D2 3 0 c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name FC HEAT EXCHANGER 1A CCW OUTLET VALVE 1CC076B 14 BTF MO 1032,2 C2 3 O* c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name FC HEAT EXCHANGER 1BCCWOUTLET VALVE 1CC127 8 GA MO 1032, 3 0-8 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CCW CONTAINMENT INBOARD ISOL VALVE 1CC128 8 GA MO 1032, 3 C-2 2 0 c B A DIA MOV EX Y2 2201&04 Valve Name CCW DRYWELL ISOLATION VALVE 1CC185A 0.75x1 RV SA 1046, 1 F1 3 c 0 c A RT Y10 Valve Name FPC&C HX 1A SHELL RELIEF VALVE 1CC185B 0.75x1 RV SA 1046, 1 F3 3 c 0 c A AT Y10 Valve Name FPC & C HX 1B SH Ell RELIEF VALVE 1CC280A 0.75x1 RV SA 1032, 6 E4 3 c 0 c A RT Y10 Valve Name 1FC02PA MOTOR HX SHELL SIDE RELIEF VALVE 1CC2BOB 0.75x1 RV SA 1032, 6 C4 3 c 0 c A RT Y10 Valve Name 1FC02PB MOTOR HX SHELL SIDE RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Containment Monitoring (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1CM002B 0.75 EFC SA 1034, 1 A-7 2 0 O/C c A cc AR 2203 RFJ-015 co RR 2203 RFJ-015 Pl Y2 Valve Name SUPP POOL LEVEL STP EXCESS FLOW CHECK VALVE 1CM011 0.75 GA so 1034,2 C-7 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name OUTBOARD CONT. MONITORING CONT. ISOL VALVE DIV.1 1CM012 0.75 GA so 1034, 2 C-6 2 c c A A FC M3 LTJ AJ Pl Y2 Yaiva Name INBOARD CONT. MONITORING CONT. ISOL VALVE DIV.f 1CM022 0.75 GA so 1034, 2 D-3 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name OUTBOARD CONT. MONITORING CONT. ISOL VALVE DIV. 2 1CM023 0.75 GA so 1034, 2 0-3 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name INBOARD CONT. MONITORING CONT. ISOL. VALVE DIV. 2 1CM025

• 0.75 GA so 1034,2 C-3 2 c .C A A FC M3 LTJ AJ Pl Y2 Valve Name OUTBOARD CONT. MONITORING CONT. ISOL. VALVE DIV. 2

• 1CM026 0.75 GA so 1034, 2 C-3 2 c c A A FC M3 LTJ AJ Pl Y2 Yaiva Name INBOARD CONT. MONITORING CONT. ISOL VALVE DIV. 2 1CM047 0.75 GA so 1034, 2 D-6 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name INBOARD CONT. MONITORING CONT. ISOL VALVE DIV.f 1CM048 0.75 GA so 1034, 2 D-7 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name OUTBOARD CONT. MONITORING CONT. ISOL. VALVE DIV.1 Revision Date: 10/21/2016

C!!nton Station IST PROGRAM PLAN Containment Monitoring (Page 2)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1CM066 0.75 EFC SA 1071, 1 F*3 2 0 c AJC A BOO RR 2203 RFJ-013 cc RA 2203 RFJ-013 Pl Y2 Valve Name REACTOR PRESSURE EXCESS FLOW CHECK VALVE 1CM067 0.75 EFC SA 1071, 2 E-6 2 0 c AJC A BOO RR 2203 RFJ-013 cc RR 2203 RFJ.013 Pl Y2 Valve Name REACTOR PRESSURE EXCESS FLOW CHECK VALVE 1E22*F332 0.75 EFC SA s 1074,1 C4 2 0 0 c A BOC M3 co M3 Pl Y2 Valve Name SUPP POOL WATER LVL SENSOR EX FL CHECK VLV 1E51*F377B 0.75 EFC SA S 1079,: C11 2 0 DIC c A cc RA 2203 RFJ.015 co RR 2203 RFJ.015 Pl Y2 Valve Name SUPP POOL INSTR EXCESS FLOW CHECK VALVE 1SM008 0.75 EFC SA 1069, 1 A*3 2 0 O/C c A cc RR 2203 RFJ-015 co RR 2203 RFJ-015 Pl Y2 Valve Name SUPP POOL LVL EXCESS FLOW CHECK VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Cycled Condensate (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1CY016 6.0 GA MO 1012,6 cs 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CYCLED COND OUTBOARD INLET ISOL VALVE 1CY017 6.0 GA MO 1012,6 C6 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CYCLED COND INBOARD INLET ISO VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Diesel Generator (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1DG006A 0.75x1 RV SA 1035, 1 E-6 3 c O/C c A RT Y10 Valve Name 10G04TA STARTING AIR RCVR 1A1 RELIEF VALVE 10G006B 0.75x1 RV SA 1035, 1 C-6 3 c O/C c A RT Y10 Valve Name 10G04TB STARTING AIR RCVR 1A2 RELIEF VALVE 1DG006C 0.75x1 RV SA 1035, 2 E-6 3 c OIC c A RT Y10 Valve Name 1DGOSTA STARTING AIR RCVR 181 RELIEF VALVE 1DG0060 0.75x1 RV SA 1035, 2 C-6 3 c O/C c A RT Y10 Valve Name 1DG05TB STARTING AIR RCVR 182 RELIEF VALVE 1DG006E 0.75x1 RV SA 1035, 3 E-6 3 c O/C c A RT Y10 Valve Name 1DG06TASTARTINGAIR RCVR 1C1 RELIEF VALVE 1DG006F 0.75x1 RV SA 1035, 3 0-6 3 c O/C c A RT Y10 Valve Name 1DG06TB STARTING AIR RCVR 1C2 RELIEF VALVE 1DG008A 2 DIA AO 1035, 1 E-3 3 c 0 B A SC M3 CTP-IST-007 so M3 CTP-IST-007 Valve Name 1DG16MNML 16CYLINDERAIR START VALVE 1000088 2 DIA AO 1035, 1 C-3 3 c 0 8 A SC M3 CTP-IST-

. 007 so M3 CTP-IST*

007 Valve Name 1DG16MB/MM 12 CYLINDER AIR START VALVE 1DGOOBC 2 DIA AO 1035, 1 F-3 3 c 0 B A SC M3 CTP*IST-007 so M3 CTP*IST*

007 Valve Name 1DG16MC 16 CYLINDER AIR START VALVE 1DGOOBD 2 DIA AO 1035, 1 B-3 3 c 0 B A SC M3 CTP-IST-007 so M3 CTP-IST-007 Valve Name 1DG16MD 12 CYLINDER AIR START VALVE 1DG008E 2 DIA AO 1035, 2 E-3 3 c 0 B A SC M3 CTP-IST-007 so M3 CTP*IST-007 Valve Name 1DG16ME/MN STARTING AIR SUPPLY VALVE 1DG008F 2 DIA AO 1035, 2 C-3 3 c 0 B A SC M3 CTP-IST*

007 so M3 CTP-IST*

007 Valve Name 1DG16MF/MP STARTING AIR SUPPLY VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Diesel Generator (Page 2)

Valve EIN Size Valve Type Actu P&JD Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1DGOOBG 2 DIA AO 1035, 2 F-3 3 c 0 B A SC M3 CTP-IST*

007 so M3 CTP-IST*

007 Valve Name 1DG16MG STARTING AIR SUPPLY VALVE 1DGOOBH 2 DIA AO 1035,2 B*3 3 c 0 B A SC M3 CTP-IST*

007 so M3 CTP-IST*

007 Valve Name 1DG16MH STARTING AIR SUPPLY VALVE 1DGOOBJ 2 DIA AO 1035, 3 E-3 3 c 0 B A SC M3 CTP-IST*

007 so M3 CTP-IST-007 ValveName 1DG16MJ/MRAIRSTARTVALVE 1DGOOBK 2 DIA AO 1035, 3 D*3 3 c 0 *B A SC M3 CTP-IST*

007 so M3 CTP*IST*

007 Valve Name 1DG 16MK/MS AIR START VALVE 1DG168 125 CK SA 1035, 1 E*7 3 SYS c c A BOO M3 cc M3 Valve Name 1DG04TA AIR RECEIVER INLET CHECK VALVE 1DG169 1.25 CK SA 1035, 1 C-7 3 SYS c c A BOO M3 cc M3 Valve Name 1DG04TB AIR RECEIVER INLET CHECK VALVE 1DG170 1.25 CK SA 1035, 2 E*7 3 SYS c c A BOO M3 cc M3 Valve Name 1DG02CA DISCHARGE TO i DGOSTA VALVE 1DG171 1.25 CK SA 1035, 2 C-7 3 SYS c c A BOO M3 cc M3 Valve Name 1DG02CB DISCHARGE TO 1DGOSTB VALVE 1DG172 1.25 CK SA 1035, 3 E-7 3 SYS c c A BOO M3 cc M3 Valve Name 1DG03CA STARTING AIR COMPRESSOR DISCHARGE 10G173 1.25 CK SA 1035, 3 C-7 3 SYS c c A BOO M3 cc M3 Valve Name 1DG03CB STARTING AIR COMPRESSOR DISCHARGE Revision Date: 10121/2016

Clinton Station IST PROGRAM PLAN Diesel Generator (Page 3)

Valve EIN Slze Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Positlon Position Type Freq. Request Just Pos.

1DG646A 0.375 3W so 1035, 1 D-4 3 D EID B A SC M3 CTP*IST*

007 so M3 CTP-tST*

007 Valve Name AIR START VALVE 1DG008A SOLENOID VALVE 1DG646B 0.375 3W so 1035, 1 C-4 3 D EID B A SC M3 CTP-tST*

007 so M3 CTP-IST*

007 Valve Name AIR STAFIT VALVE 1DG008B SOLENOID VALVE 1DG646C 0.375 3W so 1035, 1 E-4 3 D EID B A SC M3 CTP-IST*

007 so M3 CTP*IST*

007 Valve Name AIR START VALVE 1DG008C SOLENOID VALVE 1DG646D 0.375 3W so 1035, 1 B-4 3 D EID B A SC M3 CTP-IST*

007 so M3 CTP-IST*

007 Valve Name AIR START VALVE 1DGOOBD SOLENOID VALVE 1DG646E 0.375 3W so 1035, 2 0-4 3 D EID B A SC M3 CTP-tST*

007 so M3 CTP-tST*

007 Valve Name AIR START VALVE 1DG008E SOLENOID VALVE 1DG646F 0.375 3W so 1035,2 C-4 3 D EID B A SC M3 CTP-IST*

007 so M3 CTP-IST*

007 Valve Name AIR START VALVE 1DG008F SOLENOID VALVE 1DG646G 0.375 3W so 1035, 2 E-4 3 D EID B A SC M3 CTP-IST*

007 so M3 CTP-tST-007 Valve Name AIR START VALVE 1DG008G SOLENOID VALVE 1DG646H 0.375 3W so 1035, 2 B-4 3 D EID B A SC M3 CTP-IST*

007 so M3 CTP-IST*

007 Valve Name AIR START VALVE 1DG008H SOLENOID VALVE 1DG646J 0.375 3W so 1035, 3 0-4 3 D EID B A SC M3 CTP-IST*

007 so M3 CTP*IST*

007 Valve Name AIR STAFIT VALVE 1DGOOBJ SOLENOID VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Diesel Generator (Page 4)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Poslllon Position Type Freq. Request Just. Pos.

1DG646K 0.375 3W so 1035, 3 C-4 3 D EID B A SC M3 CTP-IST*

007 SO M3 CTP-IST*

007 Valve Name AIR START VALVE 1DGOOSK SOLENOID VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Diesel Fuel Oil (Page 1)

Valve EIN Size Valve Type Actu P&ID Sh eel/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1D0001A 1.5 CK SA 1036, 1 B1 3 SYS 0 c A BOC M3 co M3 Valve Name 10001PA DISCHARGE CHECK VALVE 100001B 1.5 CK SA 1036, 1 BS 3 SYS 0 c A BOC M3 co M3 Valve Name 10001 PB FUEL OIL DISCHARGE CHECK VALVE 100001C 1.5 CK SA 1036, 2 83 3 SYS 0 c A BOC M3 co M3 Valve Name 10001PC FUa OIL TRANSFER PUMP DISCHARGE VLV 1DOD05A 0.75x1 RV SA 1036, 1 C1 3 c O/C c A RT Y10 Valve Name 10001 PA DISCHARGE RELIEF VALVE 1D0005B 0.75x1 RV SA 1036, 1 cs 3 c O/C c A RT Y10 Valve Name 10001 PB DISCHARGE RELIEF VALVE 1DOOOSC 0.75x1 RV SA 1036,2 C3 3 c O/C c A RT Y10 Valve Name 10001 PC DISCHARGE RELIEF VALVE Revision Date: 10/21/2016

CPS Station IST PROGRAM PLAN Fuel Pool Cooling (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pas.

1E12*F066 14 GA M 1075,1 8-4 3 LC 0 B A ET Y2 Valve Name AHR to FC Manual CrossTie 1E12-F099 14 GA M 1075,1 C-6 3 LC 0 B A ET Y2 Valve Name AHR to FC Manual CrossTie 1FC002 14 GA M 1037,2 92 3 LC 0 B A ET Y2 Valve Name AHR to FC Suction Manual Isolation 1FC004A B GL AO 1037,3 E*5 3 0 0 B A FO M3 Pl Y2 Valve Name FC DEMINERALIZEA BYPASS FLOW CONTROL VALVE 1FC0048 8 GL AO 1037,3 A*5 3 0 0 B A FO M3 Pl Y2 Valve Name FC OEMINERALIZEA BYPASS FLOW CONTROL VALVE 1FC007 10 GA MO 1037, 1 B-2 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name FC RETURN INSIDE CNMT ISOL VALVE 1FCOOB 10 GA MO 1037, 1 B-1 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name FC RETURN OUTSIDE CNMT ISOLATION VALVE 1FC011A 14 BTF MO 1037,3 E*7 3 0 O/C B A Pl Y2 SC M3 so M3 Valve Name FPC & C PUMP 1A SUCTION ISOL VALVE 1FC011B 14 BTF MO 1037,3 A*7 3. 0 O/C B A Pl Y2 SC M3 so M3 Valve Name FPC & C PUMP 18 SUCTION ISOLATION VALVE 1FC013A 14 CK SA 1037, 3 E*7 3 0 O/C c A cc M3 co M3 Valve Name 1FC02PA DISCHARGE CHECK VALVE 1FC0138 14 CK SA 1037, 3 A*7 3 0 O/C c A cc M3 co M3 Valve Name 1FC02PB DISCHARGE CHECK VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Fuel Pool Cooling (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonna! Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1FC015A 14 BTF MO 1037,3 E-2 3 o 0 8 A Pl Y2 so M3 Valve Name FPC & C HX 1A INLET ISOLATION VALVE 1FC015B 14 8TF MO 1037,3 A-2 3 0 0 8 A Pl Y2 so M3 Valve Name FPC & C HX 18 INLET ISOLATION VALVE 1FC016A 8 BTF MO 1037, 3 D-6 3 0 c B A DIA MOV EX Y2 2201&04 Valve Name FILTER DEMIN SUPPLY ISOLATION VALVE 1A 1FC016B 8 BTF MO 1037, 3 C-6 3 0 c B A DIA MOV EX Y2 2201&04 Valve Name FILTER DEMIN SUPPLY ISOLATION VALVE 10 1FC024A 8 8TF MO 1037,3 E-2 3 o c 8 A DIA MOV EX Y2 2201&04 Valve Name ALTER DEMIN RETURN ISOLATION VALVE 1A 1FC024B 8 BTF MO 1037,3 C*2 3 0 c 8 A DIA MOV EX Y2 2201&04 Valve Name FILTER DEMIN RETURN ISOLATION VALVE 18 1FC026A 14 8TF MO 1037, 3 E-2 3 0 O/C B A Pl Y2 SC M3 so M3 Valve Name FPC & C HX 1A OUTLET ISOLATION VALVE 1FC026B 14 BTF MO 1037, 3 B*2 3 0 O/C B A Pl Y2 SC M3 so M3 Valve Name FPC&C HX 1BOUTLETISOLATIONVALVE 1FC036 8 GA MO 1037, 1 E-1 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name FC SUPPLY CNMT OUTBOARD ISOLATION VALVE 1FC037 8 GA MO 1037, 1 E-2 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name FC SUPPLY CNMT INBOARD ISOLATION VALVE 1FC090 14 GA M 1037,3 01 3 LC 0 B A ET Y2 Valve Name RHR to FC Manual Isolation Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Fuel Pool Cooling (Page 3)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1FC091 4x6 RV SA 1037, 3 E*1 3 c 0 c A RT Y10 Valve Name FC TO AHR HX RELIEF VALVE 1FC095A 0.75x1 RV SA 1046, 1 F-2 3 c NIA c A RT Y10 Valve Name 1FC01AA TUBE SIDE RELIEF VALVE 1FC095B 0.75x1 RV SA 1046, 1 F-3 3 c NIA c A RT Y10 Valve Name 1FC01AB TUBE SIDE RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Fire Protection (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd PoshIon Position Type Freq. Request Just. Pos.

1FPOSO 6 GA MO 1039, 9 E3 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CNMT FP SYS INBOARD ISOLATION VALVE 1FP051 10 GA MO 1039, 9 CB 2

• LC c A p LTJ AJ Valve Name CNMT FP SYS OUTBOARD ISOLATION VALVE 1FP052 10 GA MO 1039, 9 CG 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CNMT FP SYS INBOARD ISOL VALVE 1FP053 10 GA MO 1039,9 C4 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CNMT FP SYS INBOARD ISOL VALVE 1FP054 10 GA MO 1039,9 C2 2 LC c A p LTJ AJ Valve Name CNMT FP SYS OUTBOARD ISOLATION VALVE 1FP092 6 GA MO 1039,9 E2 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CONTAINMENT FP SYS OUTBOARD ISOLATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Feedwater (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Rellef Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1B21*F010A 18 CK SA 1004 C7 0 c c A BOO RR 2203 RFJ-003

• cc RR 2203 RFJ-003 Valve Name REACTOR FEEDWATER HEADER CHECK VALVE 1B21-F010B 18 CK SA 1004 A7 0 c c A BOO RR 2203 RFJ-003 cc RR 2203 RFJ-003 Valve Name REACTOR FEEDWATER HEADER CHECK VALVE 1B21*F032A 20 CK SA/AO 1004 C6 0 c AIC A BOO RR 2203 RFJ-003 cc RR 2203 RFJ-003 LTJ AJ Valve Name FEEDWATEA OBD. CONT ISOL AIR OP CHECK VALVE 1B21-F032B 20 CK SA/AO 1004 AS 0 c A/C A BOO RR 2203 RFJ-003 cc RR 2203 RFJ-003 LTJ AJ Valve Name FEEDWATER 080. CONT ISOL AIR OP CHECK VALVE 1B21*F065A 20 GA MO 1004 C5 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name FEED WATER INLET SHUTOFF VALVE A 1B21-F065B 20 GA MO 1004 A5 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name FEED WATER INLET SHUTOFF VALVE B 1B21-F433A 0.5 CK SA 9004,8 05 3 0 c c A BOO RR cc RR 2203 RFJ-008 Valve Name 1821A300A AIR SUPPLY CHECK VALVE TO ACCUMU 1821*F4338 0.5 CK SA 9004, 8 OS 3 0 c c A BOO RR cc RR 2203 RFJ-008 Valve Name 1821 A3008 AIR SUPPLY CHECK VALVE TO ACCUMU Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Containment Combustible Gas Control (Page 1)

Valve ElN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1HG001 2 BTF MO 1063 D3 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CGCS CONTAINMENT ISOLATION VALVE 1HG004 2 BTF MO 1063 C3 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CGCS CONTAINMENT ISOLATION VALVE 1HG005 2 BTF MO 1063 E3 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CONTAINMENT ISOLATION VALVE 1HG008 2 BTF MO 1063 E3 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name CONTAINMENT ISOLATION VALVE 1HG009A 6 GA MO 1063 E4 2 c O/C B A DIA MOV EX Y2 2201&04 Valve Name COMPRESSOR SUCTION VALVE 1A 1HG009B 6 GA MO 1063 ES 2 c O/C B A DIA MOV

. EX Y2 2201&04 Valve Name COMPRESSOR SUCTION VALVE 10 1HG010A 10 CK AO 1063 C4 2 c O/C c A cc M3 co M3 Pl Y2 RT Y2 Valve Jl!ame H2 VACUUM RalEF VALVE CHECK VALVE 1HG010B - 10 CK AO 1063 C7 2 c OIC c A cc M3 co M3 Pl Y2 AT Y2 Valve Name H2 VACUUM RELIEF Revision Date: 10/21/2016

Clinton Station IST PROGRAM PL.AN Containment Combustrbre Gas Control (Page 2)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Rerret Deferred Tech.

rype Coo rd Position Position Type Freq. Request Just Pos.

1HG010C 10 CK AO 1063 84 2 c O/C c A cc M3 co M3 Pl Y2 RT Y2 Valve Name H2VACUUM RELIEF VALVE 1HG010D 10 CK AO 1063 87 2 c O/C c A cc M3 co M3 Pl Y2 RT Y2 Valve Neme H2VACUUM RELIEF VALVE 1HG011A 10 CK AO 1063 C4 2 c O/C c A cc M3 co M3 Pl Y2 RT Y2 Valve Name H2VACUUM RalEFVALVE 1HG0118 10 CK AO 1063 cs 2 c O/C. c A cc M3 co M3 Pl Y2 RT Y2 Valve Name H2 VACUUM RELIEF 1HG011C 10 CK AO 1063 84 2 c O/C c A cc M3 co M3 Pl Y2 RT Y2 Valve Name H2 VACUUM RELIEF VALVE 1HG011D 10 CK AO 1063 86 2 c O/C c A cc M3 co M3 Pl Y2 RT Y2 Valve Name H2 VACUUM RELIEF Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN High Pressure Core Spray (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request JusL Pos.

1E22*F001 16 GA MO 1074 A6 2 0 O/C A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name HPCS SUCTION FROM RCIC STORAGE TANK VALVE 1E22*F002 16 CK SA 1074 ~ 2 c OIC c A cc CMP co CMP Valve Name HPCS SUCTION CHECK VALVE FROM RCIC STOATANK 1E22-F004 10 GA MO 1074 E7 c O/C A A DIA Mov*

EX cs 2201&04 CSJ-111 Relief2203 LTJ AJ PIV Y2 Valve Name HPCS PUMP DISCH VALVE 1E22*F005 10 CK AO 1074 EB c O/C A/C A cc RR 2203 RFJ.-005 co RR . 2203 RFJ..005 PIV Y2 Valve Name HPCS RX PRESS VESSEL .CHECK VALVE 1E22-F006 2 SCK SA 1074 04 2 SYS O/C c A cc M3 co M3 Valve Name HPCS WATER LEG PUMP DISCHARGE STOP CK VLV 1E22-F007 2.5 CK SA 1074 04 2 SYS O/C c A cc M3 co M3 Valve Name HPCS WATER LEG PUMP DISCHARGE CHECK VALVE 1E22-F010 10 GL MO 1074 D6 2 c c B p Pl Y2 Valve Name STORAGE TANK TEST BYPASS VALVE 1E22*F011 10 GL MO 1074 05 2 c c A A DIA MOV EX Y2 2201&04 LT Y2 LTJ AJ Valve Name COND STORAGE TANK TEST VALVE 1E22*F012 4 GA MO 1074 03 2 c O/C A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name SUPPRESSION POOL MIN FLOW BYPASS VALVE 1E22-F014 1x0.75 RV SA 1074 cs 2 c O/C A/C A LTJ AJ RT Y4 Valve Name HPCS PUMP SUCTION HEADER RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN High Pressure Core Spray (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E22-F015 20 GA MO 1074 67 2 c O/C A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name SUPPRESSION POOL PUMP SUCTION VALVE 1E22*F016 20 CK SA 1074 B6 2 c 0 c A BOC M3 co M3 Valve Name HPCS PUMP SUCTION CHECK VALVE 1E22*F023 10 GL MO 1074 D6 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name SUPPRESSION POOL TEST BYPASS VALVE 1E22*F024 14 CK SA 1074 E3 2 c O/C c A cc M3 co M3 Valve Name HPCS PUMP DISCHARGE CHECK VALVE 1E22*F035 1x0.75 RV SA 1074 E3 2 c O/C A/C A LTJ AJ RT Y10 Valve Name HPCS INJ LINE RELIEF VALVE 1E22-F036 12 GA M 1074 EB LO 0 B p Pl Y2 Valve Name HPCS MAN INJ ISOL VALVE 1E22*F039 1x0.75 RV SA 1074 C6 2 c O/C A/C A LTJ AJ RT Y10 Valve Name RETURN TO RCIC TANK RalEF VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Instrument Air (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category AcUPass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

11A005 3 GL AO 1040, 5 D2 2 0 c A A FC cs 2203 CSJ-106 LTJ AJ Pl Y2 Valve Name CONTAINMENT IA ISOLATION CONTROL VALVE 11A006 3 GL AO 1040,5 03 2 0 c A A FC cs 2203 CSJ-106 LTJ AJ Pl Y2 Valve Name CONTAINMENT IA ISOLATION CONTROL VALVE 11A007 3 GL AO 1040, 5 D5 2 0 c B *A FC cs 2203 CSJ-106 Pl Y2 Valve Name DRYWELL IA OUTBOARD !SOLATION CONTROL VALVE 11A008 3 GL AO 1040,5 D7 2 0 c B A FC cs 2203 CSJ-106 Pl Y2 Valve Name DRYWELL IA INBOARD ISOLATION CONTROL VALVE 11A012A GL MO 1040, 7 02 2 c O/C A A DIA MOV EX cs 2201&04 CSJ-113 Rellel2203 LTJ AJ Valve Name ADS 1A CNMT OUTBOARD ISOLATION VALVE 11A0128 GL MO 1040,7 C3 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name ADS 1A CNMT INBOARD ISOLATION VALVE 11A013A GL MO 1040, 7 D7 2 c OIC A A DIA MOY EX cs 2201&04 CSJ-113 Relief2203 LTJ AJ Valve Name ADS 18 CNMT OUTBOARD ISOLATION VALVE 11A0138 GL MO 1040, 7 C6 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name ADS 18 CNMT INBOARD ISOLATION VALVE 11A042A CK SA 1040, 7 D6 2 SYS O/C A/C A cc RR 2203 RFJ-014 co RR 2203 RFJ-014 LTJ AJ Valve Name IA TO DIV 2 ADS VALVES CHECK VALVE Revision Date: 1012112016

Clinton StaHon IST PROGRAM PLAN Instrument Air (Page 2)

ValveEIN Size Valve Type Actu P&ID SheeU Class Normal Safety Category AcUPass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

11A042B CK SA 1040, 7 04 2 SYS O/C AJC A cc RR 2203 RFJ-014 co RR 2203 RFJ-014 LTJ AJ Valve Name IA TO DIV 1 ADS VALVES CHECK VALVE 11A128A 1.5x3 RV SA 1040, 7 E7 3 c OIC c A RT Y10 Valve Name 11A10TA*H DIV 2 ADS BACKUP HEADER RELIEF VALVE 11A128B 1.5x3 RV SA 1040, 7 E2 3 c OIC c A RT Y10 Valve Name 11A11TA*H DIV 1 ADS BACKUP HEADER RELIEF VALVE 11A175 0.5 CK SA 1040, 5 E3 2 SYS c A/C A BOO CMP cc CMP LTJ AJ Valve Name IA SYS PISTON CHECK VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN MSIV Leakage Control (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1E32-F001A 1.5 GL MO 1070 c:7 c c A p LTJ AJ Pi Y2 Valve Name MSIV LEAK CONTROL SYSTEM INBOARD VALVE 1E32-F001E 1.5 GL MO 1070 E7 c c A p LTJ AJ Pl Y2 Valve Name MSIV LEAK CONTROL SYSTEM INBOARD VALVE 1E32-F001J 1.5 GL MO 1070 67 c c A p l.:TJ AJ Pl Y2 Valve Name MSIV LEAK CONTROL SYSTEM INBOARD VALVE 1E32-F001N 1.5 GL MO 1070 D7 c c A p LTJ AJ Pl Y2 Valve Name MSIV LEAK CONTROL SYSTEM INBOARD VALVE Revision Date: 10/2112016

Clinton Statton IST PROGRAM PLAN Leak Detection (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E31-F014 GA so 1041,4 E8 2 0 c B A FC cs 2203 CSJ-108 Pl Y2 Valve Name DRYWELLISOLATION VALVE 1E31-F015 GA so 1041,4 E7 2 0 c B A FC cs 2203 CSJ-108 Pl Y2 Valve Name DRYWELL ISOLATION VALVE 1E31*F017 GA so 1041,4 C7 2 0 c B A FC cs 2203 CSJ-108 Pl Y2 Valve Name DRYWELL ISOLATION VALVE 1E31*F01B GA so 1041,4 C8 2 0 c B A FC cs 2203 CSJ-108 Pl Y2 Valve Name DRYWELL ISOLATION VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Low Pressure Core Spray (Page 1)

Valve EIN Size Valve Type Actu P&JD Sheet/ Class Nonnal Safety category Act/Pass Test Test Relief Deferred Tech.

Type Coard Position Position Type Freq. Request Just. Pos.

1E21-F001 20 GA MO 1073 B4 2 0 OIC A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name LPCS SUCTION FROM SUP POOL VALVE 1E21*F003 12 CK SA 1073 ES 2 SYS O/C c A cc M3 co M3 Valve Name LPCS PUMP DISCHARGE CHECK VALVE 1E21*F005 10 GA MO 1073 E4 c O/C A A DIA MDV EX cs 2201 &04 CSJ-111 Relief 2203 LTJ AJ PIV Y2 Valve Name LPCS INJECTION SHUTOFF VALVE 1E21*F006 10 CK SA 1073 E2 SYS O/C AIC A cc RR 2203 RFJ*OOS co RR 2203 RFJ*OOS PIV Y2 Valve Name LPCS INJECTION TESTABLE CHECK VALVE 1E2H007 10 GA M 1073 E2 LO 0 B p Pl Y2 Valve Name LPCS MAN INJ ISOL VALVE 1E21*F011 4 GA MO 1073 D6 2 0 DIG A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name LPCS MIN FLOW BYPASS TO SUP POOL VALVE 1E21*F012 10 GL MO 1073 DS 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name LPCS TEST RETURN TO SUPPRESSION POOL VALVE 1E2H018 1.Sx2 RV SA 1073 E5 2 c OIC AIC A LTJ AJ RT Y10 Valve Name INJECTION HEADER RELIEF VALVE 1E2H031 1.Sx1 RV SA 1073 ca 2 c OIC AIC A LTJ AJ RT Y10 Valve Name LPCS PUMP SUCTION HEADER RELIEF VALVE 1E2H033 2 CK SA 1073 D6 2 SYS OIC c A cc M3 co M3 Valve Name LPCS WATER LEG PUMP DISCH CHK VLV TO LP Revision Date: 1012112016

Clinton Station IST PROGRAM PLAN Low Pressure Core Spray (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coon! Position Position Type Freq. Request Just. Pos.

1E2H034 2 CK SA 1073 06 2 SYS O/C c A cc M3 co M3 Valve Name LPCS WATER LEG PUMP DISCH CHK VALVE TO LP 1E21*F303 10 CK SA 1073 cs 2 SYS 0 c A BOC M3 co M3 Valve Name LPCS TEST LINE CHECK VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Clean Condensate Storage (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

OMC009 4 GA MO 1042,4 E5 2 0 c A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name OUTBOARD DEMIN WATER CNMT ISOL VLVE OMC010 4 GA MO 1042,4 DS 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name INBOARD DEMIN WATER CNMT ISOLATION VALVE 1MC090 3/4 RV SA 1042,4 -E4 2 *c DIC AJC A LTJ AJ AT Y10 Valve Name Make-up Condensa1e Containment Pen Relief Valve Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Posmon Posltlon Type Freq. Request Just Pos.

1B21-F016 3 GA MO 1002, 1 81 0 c A A DIA MOV EX cs 2201&04 CSJ-117 Rellef2203 LTJ AJ Valve Name MAIN STEAM LINE INB. DRAIN !SOL. VALVE 1B2H019 3 GA MO 1002, 2 B6 0 c A A DIA MOV EX cs 2201&04 CSJ-117 Rellef2203 LTJ AJ Valve Name MAIN STEAM LINE OUTB. DRAIN ISOL. VALVE 1B21*F022A 24 GL AO 1002, 1 C2 0 c A A CP M3 FC cs 2203 CSJ-101 LTJ AJ Pl Y2 Velve Name MAIN STEAM INBOARD ISOL VALVE 1B21-F022B 24 GL AO 1002, 1 F2 0 c A A CP M3 FC cs* 2203 CSJ-101 LTJ AJ Pl Y2 Valve Name .MAIN STEAM INBOARD ISOL VALVE 1B21*F022C 24 GL AO 1002, 1 A2 0 c A A CP M3 FC cs 2203 CSJ-101 LTJ AJ Pl Y2 Valve Name MAIN STEAM INBOARD ISOL VALVE 1B21*F022D 24 .. GL AO 1002, 1 02 0 c A A CP M3 FC cs 2203 CSJ*101

• LTJ AJ Pl Y2 Valve Name MAIN STEAM INBOARD ISOL VALVE 1B21-F024A 0.5 CK SA 9002,5 C7 3 SYS c c A BOO RR 2203 RFJ-006 cc RR 2203 RFJ-006 Valve Name 1B21A001A INST AIR SUPPLY CKVLVTO ACCUMU 1B2H024B 0.5 CK SA 9002,5 C7 3 SYS c c A BOO RR 2203 AFJ-006 cc RR 2203 RFJ-006 Valve Name 1B21 A001 B INST AIR SUPPLY CK VLV TO ACCUMU Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1B21*F024C 0.5 CK SA 9002,5 C7 3 SYS c c A BOO RR 2203 RFJ-006 cc RR 2203 RFJ-006 Valve Name 1B21A001C INST AIR SUPPLY CK VLV TO ACCUMU 182H024D 0.5 CK SA 9002,5 C7 3 SYS c c A BOO RR 2203 RFJ-006 cc RR 2203 RFJ-006 Valve Name 1B21A001D INST AIR SUPPLY CKVLV TO ACCUMU 1B21*F02BA 24 GL AO 1002, 2 C5. 0 c A A CP M3 FC cs 2203 CSJ-101 LTJ AJ Pl Y2 Valve Name MAIN STEAM OUTBOARD ISOLATION VALVE 1B2H02BB 24 GL AO 1002, 2 F5 0 c A A GP M3 FC cs 2203 CSJ*101 LTJ AJ Pl Y2 Valve Name MAIN STEAM OUTBOARD ISOLATION VALVE 1B2H02BC 24 GL AO 1002, 2 BS 0 c A A CP M3 FC cs 2203 CSJ-101 LTJ AJ Pl Y2 Valve Name MAIN STEAM OUTBOARD ISOLATION VALVE 1B21-F02BD 24 GL AO 1002,2 ES 0 c A A CP M3 FC cs 2203 CSJ-101 LTJ AJ Pl Y2 Valve Name MAIN STEAM OUTBOARD ISOLATION VALVE 1821*F029A 0.5 CK SA 9002, 5 03 3 SYS c c A BOO RR 2203 RFJ-006 cc RR 2203 RFJ-006 Valve Name 1B21A002A INST AIR SUPPLY CK VLVTO ACCUMU 1B21*F029B 0.5 CK SA 9002, 5 03 3 SYS c c A BOO RR 2203 RFJ.006 cc RR 2203 RFJ-006 Valve Name 1821 A002B INST AIR SUPPLY CK VLV TO ACCUMU 1821*F029C 0.5 CK SA 9002,5 03 3 SYS c c A BOO RR 2203 RFJ*OOG cc RR 2203 RFJ-006 Valve Name 1B21A002C INST AIR SUPPLY CK VLV TO ACCUMU Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 3)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief. Deferred tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1B21-F0290 0.5 CK SA 9002, 5 03 3 SYS c c A BOO RR 2203 RFJ-006 cc RR 2203 RFJ*006 Valve Name 1B21A0020 INST AIR SUPPLY CK VALVE TO ACCUMU 1821-F036A 0.5 CK SA 9002,2 C3 3 SYS c c A BOO RR 2203 RFJ.007 cc RR 2203 AFJ.007 Valve Name 1B21A004A INSTAIR SUPPLY CK VALVE TO ACCUMU 1B21-F036F 0.5 CK SA 9002,2 C3 3 SYS c c A BOO RR 2203 RFJ.007 cc RR 2203 RFJ-007 Valve Name 1B21A004F INST AIR SUPPLY CK VALVE TO ACCUMU 1B21*F036G 0.5 CK SA 9002,2 C3 3 SYS c c A BOO RR 2203 RFJ-007 cc *RR 2203 RFJ-007 Valve Name 1821A004G INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-F036J 0.5 CK SA 9002,2 C3 3 SYS c c A BOO AR 2203 RFJ*007 cc RR 2203 RFJ*007 Valve Name 1B21A004J INST AIR SUPPLY CK VALV.E TO ACCUMU 1B21-F036L 0.5 CK SA 9002,2 C3 3 SYS c c A BOO RR 2203 RFJ-007 cc RR 2203 RFJ.007 Valve Name 1B21A004l INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-FD36M 0.5 CK SA 9002,2 C3 3 SYS c c A BOO RR 2203 RFJ.007 cc RR 2203 RFJ.007 Vaive Name 1B21A004M INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-F036N 0.5 CK SA 9002, 2 C3 3 SYS c c A BOO RR 2203 RFJ.007 cc RR 2203 RFJ--007 Valve Name 1B21A004N INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-F036P 0.5 CK SA 9002, 2 C3 3 SYS C/O c A cc RR 2203 RFJ*007 co RR 2203 RFJ--007 Valve Name 1B21A004P INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-F036R 0.5 CK SA 9002, 2 C3 3 SYS C/O c A cc RR 2203 RFJ--007 co RR 2203 RFJ--007 Valve Name 1B21A004R INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-F037A 10 CK SA 1002, 1 C6 3 c OIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 4)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category AcUPass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1B21*F037B 10 CK SA 1002, 1 E6 3 c OIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037C . 10 CK SA 1002, 1 A7 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B2H0370 10 CK SA 1002, 1 07 3 c OIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037E 10 CK SA 1002, 1 E4 3 c OIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037F 10 CK SA 1002, 1 AS 3 c DIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037G 10 CK SA 1002, 1 A4 3 c DIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037H 10 CK SA 1002, 1 cs 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VAl VE 1B21*F037J 10 CK SA 1002, 1 E7 3 c DIC c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21-F037K 10 CK SA 1002, 1 AS 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE Reviswn Date: 10/2112016

Cllnton Station IST PROGRAM PLAN Main Steam (Page 5)

Valve EIN Size Valve Type Actu P&JD Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1B21-F037L 10 CK SA 1002, 1 06 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SAV VACUUM RELIEF VALVE 1B21*F037M 10 CK SA 1002, 1 E3 3 c O/C c A cc CMP co CMP AT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037N 10 CK SA 1002, 1 E5 3 c O/C c A cc CMP co CMP AT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F037P 10 CK SA 1002, 1 A6 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SAV VACUUM RELIEF VALVE 1B21*F037A 10 CK SA 1002, 1 05 3 c O/C c A cc CMP co CMP AT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21-F037S 10 CK SA 1002, 1 /!o:3 3 *C O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F039B 0.5 CK SA 9002, 1 C4 3 c O/C c A cc RR 2203 RFJ*007 co RR 2203 RFJ-007 Valve Name 1921 A003B INST AIR SUPPLY CK VALVE TO ACCUMU 1B21*F039C 0.5 CK SA 9002, 1 C4 3 c O/C c A cc RR 2203 RFJ-007 co RR 2203 RFJ-007 Valve Name 1B21A003C INST AIR SUPPLY CK VALVE TO ACCUMU 1B21*F039D 0.5 CK SA 9002, 1 C4 3 c OIC c A cc RR 2203 RFJ-007 co RR 2203 RFJ-007 Valve Name 1B21A003D INST AIR SUPPLY CK VALVE TO ACCUMU 1B21*F039E 0.5 CK SA 9002, 1 C4 3 c OIC c A cc AR 2203 RFJ-007 co AR 2203 AFJ-007 Valve Name 1B21A003E INST AJA SUPPLY CK VALVE TO ACCUMU Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Main Steam (Page 6)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1B2H039H 0.5 CK SA 9002, 1 C4 3 c O/C c A cc RR 2203 RFJ*007 co RR 2203 RFJ*007 Valve Name 1B21A003H INST AIR SUPPLY CK VALVE TO ACCUMU 1B21-F039K 0.5 CK SA 9002, 1 C4 3 c O/C c A cc RR 2203 RFJ-007 co RR 2203 RFJ-007 Valve Name 1B21A003K INST AIR SUPPLY CK VALVE TO ACCUMU 1B21*F039S 0.5 CK SA 9002, 1 C4 3 c O/C c A cc RR 2203 RFJ-007 co RR 2203 RFJ-007 Valve Name 1B21A003S INST AIR SUPPLY CK VALVE TO ACCUMU 1B21*F041A 8x10 RV AO 1002, 1 C6 c O/C c A Pl Y2 RT Y6.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1B2H041B 8x10 RV AO 1002, 1 F7 c O/C c A FO RR 2203 RFJ-004 RT Y6.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1B21*F041C 8x10 RV AO 1002, 1 BS c O/C c A FO RR 2203 RFJ-004 RT YS.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1B21*F041D 8x10 RV AO 1002, 1 08 c O/C c A FO RR 2203 RFJ-004 RT YS.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 182H041F 8x10 RV AO 1002, 1 F5 c O/C c A FO RR 2203 RFJ-004 RT Y6.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1B21*F041G Bx10 RV AO 1002, 1 BS c O/C c A Pl Y2 RT Y6.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1821*F041L 8x10 RV AO 1002, 1 64 c O/C c A Pl Y2 RT Y6.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1B21*F047A 8x10 RV AO 1002, 1 cs c DIC c A FO RR 2203 RFJ-004 RT YS.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE 1B21*F0478 8x10 RV AO 1002, 1 F8 c DIC c A Pl Y2 RT Y6.5 2202 Valve Name MAIN STEAM SAFETY/RELIEF VALVE Revision Date: 10/21/2016

Revision Date: 10/21/2016 Clinton Station IST PROGRAM PLAN Main Steam (Page 8) .

Valve EIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1B21-F067D 1.5 GL MO 1002, 2 06 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name OUTBOARD MSIV ABOVE SEAT DRAIN VALVE 1B21*F078A 10 CK SA 1002, 1 C6 3 c ore c A cc CMP co CMP AT CMP Valve Name MAIN STEAM SAV VACUUM RELIEF VALVE 1B21-F0788 10 CK SA 1002, 1 E6 3 c ore c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRVVACUUM RELIEF VALVE 1821*F078C 10 CK SA 1002, 1 A7 3 c ore c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SAV VACUUM RELIEF VALVE 1B21-F078D 10 CK SA 1002, 1 07 3 c ore c A cc CMP co CMP AT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F078E 10 CK SA 1002, 1 E4 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F07BF 10 CK SA 1002, 1 AS 3 c ore c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SAV VACUUM RELIEF VALVE 1B21-F078G 10 CK SA 1002, 1 A4 3 c ore c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21-F078H 10 CK SA 1002, 1 cs 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 9)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1821*F078J 10 CK SA 1002, 1 E7 3 c O/C c A cc CMP co CMP AT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F078K 10 CK SA 1002, 1 AS 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F078L 10 CK SA 1002, 1 06 3 c O/C c A cc CMP co CMP

• ~,.,.

AT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1821*F078M 10 CK SA 1002, 1 E3 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1821*F078N 10 CK SA 1002, 1 ES 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRVVACUUM RELIEF VALVE 1B21-F078P 10 CK SA 1002, 1 AS 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1821*F07BR 10 CK SA 1002, 1 DS 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21*F078S 10 CK SA 1002, 1 A3 3 c O/C c A cc CMP co CMP RT CMP Valve Name MAIN STEAM SRV VACUUM RELIEF VALVE 1B21-F379A 2 CK SA 1002, 1 F7 3 c O/C c A cc CMP co CMP Valve Name 1821-F0478 SRV VENT LINE VAC BKA VALVE Revision Date: 10121/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 10)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonna! Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1B21-F379B 2 CK SA 1002, 1 F6 3 c O/C c A cc CMP co CMP Valve Name 1B21-F041B SRV VENT LINE VAC BKR Vf>J..VE 1B21*F379C 2 CK SA 1002, 1 FS 3 c O/C c A cc CMP co CMP Valve Name 1B21-F051B SRV VENT LINE VAC BKA VALVE 1821*F379D 2 CK SA 1002, 1 F4 3 c O/C c A cc CMP co CMP Valve Name 1B21-F041F SRV VENT LINE VAC 8KRVALVE 1B21-F379E 2 CK SA 1002, 1 F3 3 c O/C c A cc CMP co CMP Valve Name 1B21*F047F SRV VENT LINE VAC BKR VALVE 1B21-F379F 2 CK SA 1002, 1 E7 3 c O/C c A cc CMP co CMP Valve Name 1B21-F0410 SRV VENT LINE VAC BKR Vf>J..VE 1B2H379G 2 CK SA 1002, 1 E6 3 c O/C c A cc CMP co CMP Valve Name 1821*F047D SRV VENT LINE VA.C 8KR VALVE 1821*F379H 2 CK SA 1002, 1 E5 3 c O/C c A cc CMP co CMP Valve Name 1B21*F051D SRV VENT LINE VAC BKRVALVE 1B21-F379J 2 CK SA 1002, 1 cs 3 c O/C c A cc CMP co CMP Velve Name 1B21-F041A SRV VENT LINE VAC 8KAVALVE 1B21-F379K 2 CK SA 1002, 1 C5 3 c O/C c A cc CMP co CMP Valve Name 1B21*F047A SRV VENT LINE VAC 8KR V&VE 1B2H379L 2 CK SA 1002, 1 B7 3 c O/C c A cc CMP co CMP Valve Name 1821-F041C SAV VENT LINE VAC 8KR V&VE 1B21-F379M 2 CK SA 1002, 1 86 3 c O/C c A cc CMP co CMP Valve Name 1B21*F051C SRV VENT LINE VAC BKA VALVE 1B21*F379N 2 CK SA 1002, 1 85 3 c O/C c A cc CMP co CMP Valve Name 1B21-F041G SRV VENT LINE VAC BKA VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Main Steam (Page 11)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1B21*F379P 2 CK SA 1002, 1 85 3 c OJC c A cc CMP co CMP Valve Name 1821*F047C SRV VENT LINE VAC BKRVALVE 1B21*F379Q 2 CK SA 1002, 1 B4 3 c OJC c A cc CMP co CMP Valve Name 1B21-Rl41L SRVVENT LINE VAC BKRVALVE 1B21*F379R 2 CK SA 1002, 1 83 3 c O/C c A cc CMP co CMP Valve Name 1B21*F051G SRVVENTUNE VAC BKRVALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Nuclear Boiler (Page 1)

Valve EIN Size Valve Type Actu P&lD Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type. Coo rd Position Position Type Freq. Request Just. Pos.

1B21-F001 2 GL MO 1071, 2 D4 c c A p LT Y2 Pl Y2 Valve Name RPV HEAD VENTILATION VALVE 1B21-F002 2 GL MO 1071, 2 E4 c c A p LT Y2 Pl Y2 Valve Name RPV HEAD VENTILATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Process Sampllng (Page 1)

Valve EIN Size Valve Type Actu P&ID SheeU Class Normal Safety Category Act/Pass Test Test Rellef Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1PS004 0.75 GA so 1045, 12 E6 2 c c A A FC cs 2203. CSJ-116 LTJ AJ Pl Y2 Valve Name DRYWELL RF SUMP SAMPLE INBOARD ISOLATION VALVE 1PS005 0.75 GA so 1045, 12 E6 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name DRYWELL RF SUMP SAMPLE OUTBOARD ISOLATION VALVE 1PS009 0.75 GA so 1045, 12 ES 2 c c A A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name DRYWELL RE SUMP SAMPLE INBOARD ISOLATION VALVE 1PS010 0.75 GA so 1045, 12 ES 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name DRYWELL RE SUMP SAMPLE OUTBOARD ISOLATION VALVE 1PS016 0.75 GA so 1045, 12 .E5 2 c c A A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name CNMT FLOOR DRAIN SUMP SAMPLE INBO~RD ISOLATION 1PS017 0.75 GA so 1045, 12 ES 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name CNMT FLOOR DRAIN SUMP SAMPLE OUTBOARD ISOLATION 1PS022 0.75 GA so 1045, 12 E4 2 c c A .A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name CNMT EQUIPT DRAIN SUMP SAMPLE INBOARD ISOLATION 1PS023 0.75 GA so 1045, 12 E4 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name CNMT EOUIPT DRAIN SUMP SAMPLE OUTBOARD ISOLATION 1PS031 0.75 GA so 1045, 12 E2 2 c c A A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name DRYWELL SAMPLE INBOARD ISOLATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Process Sampling (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coonl Position Posltlon Type Freq. Request Just. Pos.

1PS032 0.75 GA so 1045, 12 E2 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name DRYWELL ATMOSPHERE SAMPLE OUTBOARD ISOLATION VLV 1PS034 0.75 GA so 1045, 12 E1 2 c c A A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name CNMT ATMOSPHERE SAMPLE INBOARD ISOLATION VALVE 1PS035 0.75 GA so 1045, 12 E1 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name CNMT ATMOSPHERE SAMPLE OUTBOARD ISOLATION VALVE 1PS037 0.75 GA so 1045, 12 ES 2 c c A A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name RX SAMPLE INBOARD ISOLATION VALVE 1PS038 0.75 GA so 1045, 12 ES 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name AX SAMPLE OUTBOARD ISOLATION VALVE 1PS043A 0.75 GA so 1045, 12 F2 2 c c B A FC M3 Pl Y2 Valve Name AHR PUMP 1A SAMPLE IB ISOLATION VALVE 1PS043B 0.75 GA so 1045, 12 F3 2 c c B A FC M3 Pl Y2 Valve Name RHR PUMP 1BSAMPLE IB ISOLATION VALVE 1PS044A 0.75 GA so 1045, 12 E2 2 c c B A FC M3 Pl Y2 Valve Name AHR PUMP 1A SAMPLE OB ISOLATION VALVE 1PS044B 0.75 GA so 1045, 12 E3 2 c c B A' FC M3 Pl Y2 Valve Name AHR PUMP 18 SAMPLE OB ISOLATION VALVE 1PS055 0.75 GA so 1045, 12 C3 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name GAS SAMPLE RETURN OUTBOARD ISOLATION VALVE*

Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Proce9s Sampling (Page 3)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1PS056 0.75 GA so 1045, 12 C3 2 c c A A FC cs 2203 CSJ-116 LTJ AJ Pl Y2 Valve Name GAS SAMPLE RETURN INBOARD ISOLATION VALVE 1PS069 0.75 GA so 1045, 12 B3 2 c c A A FC M3 LTJ AJ Pl Y2 Valve Name LIQUID SAMPLE RETURN OUTBOARD ISOLATION VALVE 1PS070 0.75 GA so 1045, 12 B3 2 c c A A FC cs 2203 CSJ-116 LTJ AJ' Pl Y2 Valve Name LIQUID SAMPLE RETURN OUTBOARD ISOLATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Breathing Air (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Posltlon Position Type Freq. Request Just. Pos.

ORA026 GA AO 1065, 7 DB 2 c c A p LTJ AJ Pl Y2

• Valve Name CONTAINMENT RA OUTBOARD ISOLATION VALVE ORA027 GA AO 1065, 7 D7 2 c c A p LTJ AJ Pl Y2 Valve Name CONTAINMENT RA INBOARD ISOlATION VALVE ORA028 GA AO 1065, 7 E5 2 c c B p Pl Y2 Valve Name DRYWELL RA OUTBOAflD ISOLATION VALVE ORA029 .1 GA AO 1065, 7 E2 2 c c B p Pl Y2 Valve Name DRYWELL RA INBOARD ISOLATION VALVE 1RA016A 1x1.5 AV SA 1065, 8 C7 3 c DIC c A RT Y10 Valve Name DIV 1 RA BOTILES UPSTRM PRESS REGULATOR RELIEF VLV 1RA016B 1x1.5 RV SA 1065,8 C3 3 c O/C c A RT Y10 Valv~ Name ON 2 RA BOTILES UPSTRM PRESS REGULATOR RELIEF VLV Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Control Rod Drive (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Rellef Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1C11*114 0.75 CK SA 1078, 2 E-3 0 c O/C c A cc RR 2203 RFJ-009 CTP-IST-007 co AR 2203 RFJ-009 CTP-IST-007 Valve Name CAD HCU SCRAM DISCHARGE CHECK VALVE (Typ. 145) 1C11-115 0.5 CK SA 1078, 2 E-6 0 0 c c A BOO RR 2203 RFJ-009 CTP*IST-007 cc RR 2203 RFJ--009 Valve Name CAD HCU CHARGING WATER CHECK VALVE 1C11*126 1 DIA AO 1078, 2 E-5 0 c 0 B A FO

• RR 2203 RFJ-009 CTP-IST" 007 so RR 2203 RFJ-009 CTP-IST-007 Valve Name CAD SCRAM INLET VALVE (Typ. 145) 1C11*127 0.75 DIA *AO 1078, 2 F-4 0 c o. B A FO RR 2203 RFJ-009 CTP-IST*

007 so RR 2203 RFJ.009 CTP-IST*

007 Valve Name CAD SCRAM OUTLET VALVE {Typ.145) 1C11*138 0.5 CK SA 1078, 2 . E-5 0 0 c A/C A BOO AR 2203 AFJ-009 CTP-IST-007 cc AR 2203 AFJ-009 CTP*IST*

007 Valve Name CAO HCU COOLING WATER CHECK VALVE (Typ. 145) 1C11*139 0.75 3W so 1078, 2 F-3 0 E D B A FO RR 2203 RFJ--009 CTP*IST-007 SD RR 2203 RFJ-009 CTP*IST*

007 Valve Name. CAD HCU SCRAM PILOT VALVE (fyp. 145) 1C11-F010 GL AO 1078,3 F*7 2 0 c B A FC M3 Pl V2 Valve Name SCRAM VENT LINE FLOW CONTROL VALVE 1C11-F011 2 GL AO 1078,3 B-8 2 0 c B A FC M3 Pl V2 Valve Name SCRAM DRAIN LINE FLOW CONTROL VALVE 1C11-F083 2 GL MO 1078, 1 E-1 2 0 c A A CIA MOV EX V2 2201&04 LTJ AJ Valve Name CAD CONTAINMENT ISOLATION VALVE 1C11-F122 2 CK SA 1078, 1 C*7 2 0 c A/C A cc CMP co CMP Valve Name CRDORIVEWATEASUPPLVHDR CHECK VALVE Revision Date: 1012112016

Clinton Station IST PROGRAM PLAN Control Rod Drive (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1C11*F180 GL AO 1078,3 F-7 2 0 c B A FC M3 Pl Y2 Valve Name SCRAM VENT LINE FLOW CONTROL VALVE 1C11*F181 2 GL AO 1078, 3 B-8 2 0 c B A FC M3 Pl Y2 Valve Name SCRAM DRAIN LINE FLOW CONTROL VALVE 1C1H376A 0.25 CK SA 1078, 1 C*6 0 0 O/C NC A cc RR 2203 RFJ-010 co NO LT Y2 Valve Name RPV LEVEL CONDENSING CHAMBER KEEP-FILL CHECK VLV 1C11-F376B 0.25 CK SA 1078, 1 B-6 0 0 O/C A/C A cc RR 2203 RFJ-010 co NO LT Y2 Valve Name RPV LEVEL CONDENSING CHAMBER KEEP.fill CHECK VLV 1C11-F3nA 0.25 CK SA 1078, 1 C-6 0 0 O/C NC A cc RR 2203 RFJ-010 co NO LT Y2 Valve Name RPV LEVEL CONDENSING CHAMBER KEEP-FILL CHECK VLV 1C11*F377B 0.25 CK SA 1078, 1 B-6 0 0 OIC A/C A cc RR 2203 RFJ*010 co NO LT Y2 Valve Name RPV LEVEL CONDENSING CHAMBER KEEP-FILL CHECK VLV Revision Date: 10/21/2016

Cfinton StaUon

!ST PROGRAM PLAN Equipment Drains (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Jusl Pos.

1RE019 3.0 GL AO 1046,4 A7 2 0 c B A FC cs 2203 CSJ-102 Pl Y2 Valve Name DRYWELL RE INBOARD ISOLATION CONTROL VALVE 1RE020 3.0 GL AO 1046,3 A4 2 0 c B A FC M3 Pl Y2 Valve Name DRYWELL RE OUTBOARD ISOLATION CONTROL VALVE 1RE021 3.0 GL AO 1046,3 B5 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name EQUIP DRAIN SUMP DISCHARGE CNMT INBOARD ISOlATIQN 1RE022 3.0 GL AO 1046,3 86 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name EQUIP DRAIN SUMP DISCHARGE CNMT OUTBOARD ISOLATION Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Floor Drains (Page 1)

• ValveEIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1RF019 3.0 GL AO 1047,3 82 2 0 c B A FC cs 2203 CSJ*102 Pl Y2 Valve Name DRYWELL RF INBOARD ISOLATION CONTROL VALVE 1RF020 3.0 GL AO 1047, 3 83 2 0 c B A FC M3 Pl Y2 Valve Name DRYWELL RF OUTBOARD ISOLATION CONTROL VALVE 1RF021 3.0 GL AO 1047,3 B6 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name CONTAINMENT RF INBOARD ISOLATION CONTROL VALVE 1RF022 3.0 GL AO 1047,3 B7 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name CONTAINMENT RF OUTBOARD ISOLATION CONTROL VALVE Revision Date: 1012112016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category ActJPass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E12*F003A 14 GL MO 1075,4 C*2 2 0 0 B A DIA MOV EX Y2 2201&04 Valve Name RHR HX 1A SHELL SIDE OUTLET VALVE 1E12*F003B 14 GL MO 1075,4 C-7 2 0 0 B A DIA MOV EX Y2 2201&04 Valve Name AHR HX 1B SHELL SIDE OUTLET VALVE 1E12*F004A 20 GA MO 1075, 1 A-4 2 0 O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RtiR PUMP 1A SUCTION VALVE 1E12-F004B 20 GA MO 1075, 2 A-6 2 .0 O/C A A. DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RHR PUMP 1B SUCTION VALVE 1E12*FOOS 1.Sx2 RV SA 1075, 1 B-5 2 c O/C A/C A RT Y10 Valve Name SOC SUCTION RELIEF TO SUPPRESSION POOL 1E12*F006A 16 GA MO 1075, 1 A*S 2 c c A p LTJ AJ Pl Y2 Valve Name RHR SHUTDOWN COOLING SUCTION VALVE 1E12*F006B 16 GA MO 1075, 2 A-6 2 c c A p LTJ AJ Pl Y2 Valve Name RHR SHUTDOWN COOLING SUCTION VALVE 1E12*F008 18 GA MO 1075, 1 B-4 c c A A DIA MOV EX Y2 2201&04 LTJ AJ PIV Y2 Valve Name SHUTDOWN COOLING OUTBOARD SUCT ISOL VALVE 1E12*F009 18 GA MO 1075, 1 B*2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ PIV Y2 Valve Name SHUTDOWN COOLING INBOARD SUCT ISOL VALVE 1E12*F010 12 GA M 1075,1 C-2 LO 0 B p Pl Y2 Valve Name SHUTDOWN COOLING MANUAL SHUTOFF VALVE 1E12-F011A 4 GL M 1075,4 D-4 2 c c A p LTJ AJ Valve Name RHR HEAT EXCHANGER 1A FLOW TO SUP POOL VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 2)

Valve ElN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1E12-F011B 4 GL M 1075,2 C-3 2 c c A p LTJ AJ Valve Name RHR HEAT EXCHANGER 10 FLOW TO SUP POOL VALVE 1E12-F014A 18 GA MO 1052, 1 D-2 3 c 0 B A DIA MOV EX M3 2201&04 Valve Name RHR HEAT EXCHANGER 1A SSW INLET VALVE 1E12-F0148 18 GA MO 1052, 2 D*2 3 c 0 B A DIA MOV EX M3 2201&04 Valve Name AHR HEAT EXCHANGER 18 SSW INLET VALVE 1E12-F017A 1.5x2 RV SA 1075, 1 B-6 2 c O/C A/C A LTJ AJ RT Y10 Velva Name AHR PUMP A SUCTION RELIEF VLV TO SUPPRESSION POOL 1E12*F017B 1.5x2 RV SA 1075, 2 8-6 2 c O/C A/C A LTJ AJ RT Y10 Valve Name AHR PUMP B SUCTION RELIEF VLV TO SUPPRESSION POOL 1E12*F021 14 GL MO 1075, 3 D-3 2 c c A A DIA MOV EX Y2 . 2201&04 LTJ AJ Valve Name AHR PUMP 1C TEST RETURN TO SUP POOL VALVE .

1E12-F023 4 GL MO 1075, 2 C-5 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ PIV Y2 Valve Name RHB SUPP TO AX HEAD SPRAY VALVE 1E12*F024A 10 GA MO 1075, 1 C-7 2 c O/C A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name RHR PUMP 1A TEST RET TO SUP POOL VALVE 1E12*F0248 10 GA MO 1075,2 C-2 2 c OIC A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name RHR PUMP 1BTEST RETURN TO SUP POOL VALVE 1E12*F025A 1x1.5 RV SA 1075, 1 D-4 2 c O/C A/C A LTJ AJ AT Y10 Valve Name AHR PUMP A DISCHARGE RELIEF VALVE TO SUPASN POOL Revision Date: 10/21/2016

cnnton Station IST PROGRAM PLAN Residua! Heat Removal (Page 3)

Valve EIN Size Valve Type Ac1u P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E12*F025B 1x1.5 AV SA 1075, 2 E*S 2 c O/C AJC A LTJ AJ RT Y10 Valve Name AHR PUMP B DISCHARGE RELIEF VALVE TO SUPRSN POOL 1E12*F025C 1x1.5 RV SA 1075, 3 F-3 2 c O/C AJC A LTJ AJ RT Y10 Valve Name AHR PUMP C DISCHARGE RELIEF VLV TO SUPRSION POOL 1E12-F027A 12 GA MO 1075, 1 D*4 2 0 O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name AHA PUMP 1A LPCI INJ SHUTOFF VALVE 1E12-F027B 12 GA MO 1075, 2 D-5 2 0 OIC A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name AHR PUMP 1B LPCI INJ SHUT OFF VALVE 1E12-F028A 10 GA MO 1075, f F-3 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name AHR SYS 1A CNMT SPRAY VALVE 1E12-F028B 10 GA MO 1075, 2 F-6 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name AHR SYS 19 CNMT SPRAY VALVE 1E12*F031A 14 CK SA 1075, 1 B-8 2 c O/C c ~ cc M3 co M3 Valve Name RHR PUMP A DISCHARGE CHECK VALVE 1E12-F031B 14 CK SA 1075,2 B-1 2 c O/C c A cc M3 co M3 Valve Name AHR PUMP B DISCHARGE CHECK VALVE 1E12-F031C 14 CK SA 1075,3 0-1 2 c O/C c A cc M3 co M3 Valve Name AHR PUMP C DISCHARGE CHECK VALVE 1E12-F036 4x6 RV SA 1075, 4 E-5 2 c OIC A/C A LTJ AJ RT Y10 Valve Name AHR CONDENSATE TO ACIC PUMP SUCTION RELIEF VLV Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Residua! Heat Removal (Page 4)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request JusL Pos.

1E12*F037A 10 GL MO 1075, 1 F-2 2 c c A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name AHR SYS 1A SHUTDOWN CLG UPPER POOL VALVE 1E12*F037B 10 GL MO 1075, 2 F-7 2 c c A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name RH SYSTEM 18 SHUTDOWN CLG UPPER POOL VALVE 1E12-F039A 12 GA M 1075, 1 01 LO 0 B p Pl Y2 Valve Name AHR MAN INJ ISOL VALVE 1E12*F039B 12 GA M 1075, 2 D-7 LO 0 B p Pl Y2 Valve Name AHR MAN INJ ISOL VALVE 1E12*F039C 12 GA M 1075, 3 E-7 LO 0 B p Pl Y2 Valve Name RHR MAN INJ ISOL VALVE 1E12-F040 3 GL MO 1075, 2 E-1 2 c c B A DIA MOV EX Y2 2201&04 Valve Name AHR SYS IB RADWASTE DRAIN OUTBD ISOL VALVE 1E12-F041A 12 CK SA 1075, 1 D-2 c O/C A/C A cc RR 2203 RFJ-005 co RR 2203 RFJ.005 PIV Y2 Valve Name AHR A REACTOR PRESS VESSEL ISOLCHECK VALVE 1E12-F041B 12 CK SA 1075, 2 D-7 c OIC A/C A cc RR 2203 RFJ*OOS co RR 2203 RFJ-005 PIV Y2 Valve Name RHR B REACTOR PRESS VESSEL ISOL CHECK VALVE 1E12-F041C 12 CK SA 1075, 3 E-7 c O/C A/C A cc RR 2203 RFJ-005 co RR 2203 RFJ.005 PIV Y2 Valve Name AHR C REACTOR PRESS VESSEL ISOL CHECK VALVE 1E12-F042A 12 GA MO 1075, 1 D*3 c DIC A A DIA MDV EX cs 2201&04 CSJ* 111 Relief 2203 lTJ AJ PIV Y2 Valve Name AHR PUMP 1A LPCI INJECTION VALVE Revision Date: 10/21/2016

cnnton Statlon IST PROGRAM PLAN Residual Heat Removal (Page 5)

Valve l:IN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Re Ref Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E12*F042B 12 GA MO 1075, 2 0.0 c O/C A A DIA MOV EX cs 2201&04 CSJ*111 Relief2203 LTJ AJ PIV Y2 Va1ve Name AHR PUMP 1B LPCI INJECTION VALVE 1E12-F042C 12 GA MO 1075, 3 E-5 c O/C A A DIA MOV EX cs 2201&04 CSJ-111 Rellef2203 LTJ AJ PIV Y2 Valve Name AHR PUMP 1C LPCI INJECTION VALVE 1E12-F048A 4 CK SA 1075, 1 B-7 2 c 0 c A BOC M3 co M3 Valve Name RHR PUMP A MIN FLOW LINE CHECK VLV 1E12-F046B 4 CK SA 1075, 2 B*2 2 c 0 c* A BOC M3 co M3 Valve Name AHR PUMP B MIN FLOW LINE CHECK VALVE 1E12*F046C 4 CK SA 1075, 3 B-2 2 c 0 c A BOC M3 co M3 Valve Name AHR PUMP C MIN FLOW LINE CHK VALVE 1E12*F047A 14 GA MO 1075,4 C-2 2 0 0 B A DIA MOV EX Y2 2201&04 Valve Name AHR HX 1A SHELL SIDE INLET VALVE 1E12*F047B 14 GA MO 1075,4 C-8 2 0 0 B A DIA MOV EX Y2 2201&04 Valve Name AHA HX 1B SHELL SIDE INLET VALVE 1E12*F04BA 14 GL MO 1075, 1 C-8 2 0 O/C B A DIA MOV EX M3 2201&04 Valve Name AHA HX 1A SHELL SIDE BYPASS VALVE 1E12-F048B 14 GL MO 1075, 2 C-1 2 0 O/C B A DIA MOV EX M3 2201&04 Valve Name AHR HX 18 SHELL SIDE BYPASS VALVE 1E12*F049 3 GA MO 1075, 2 E-1 2 c c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name AHA SYS 18 RAOWASTE DRAIN INBO ISOL VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 6)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E12-F050A 10 CK SA 1075, 1 D-5 2 c c NC A BOO cs 22.03 CSJ-105 cc cs 2203 CSJ-105 PIV Y2 Valve Name AHR A SHUTDOWN COOLING RETURN LINE CHECK VLV 1E12-F050B 10 CK SA 1075, 2 E-5 2 c c NC A . BOO cs. 2203 CSJ-105 cc cs 2203 CSJ-105 PIV Y2 Valve Name AHR B SHUTDOWN COOLING RETURN LINE CHECK VLV 1E12-F051A 6 GL AO 1075,4 F-2 2 c c A p LT Y2 Valve Name SPLY STEAM TO AHR HT EXCH 1A PRESSURE CONTROL VLV 1E12-F051B 6 GL AO 1075, 4 F-6 2 c c A p LT Y2 Valve Name SUPP STEAM TO AHR HT EXCH 1B PRESS CONTROL VALVE 1E12-F053A 10 GL MO 1075, 1 D*6 2 c c A A DIA MDV EX Y2 2201&04 LTJ AJ PIV Y2 Valve Name AHR SHUTDOWN COOLING INJECTION VALVE 1E12*F053B 10 GL MO 1075, 2 E-4 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ PIV Y2 Valve Name AHR SHUTDOWN COOLING INJECTION VALVE 1E12-F055A Bx12 RV SA 1075, 4 C-2 2 c c A p LTJ AJ Valve Name AHR HEAT EXCHANGER 1ASTEAM SUPPLY RELIEF VALVE 1E12-F055B Bx12 RV SA 1075,4 C*7 2 c c A p LTJ AJ Valve Name AHR HEATEXCHANGER 18 STEAM SUPPLY RELIEF VALVE 1E12*F060A 0.75 GL so 1075, 4 B-4 2 c c B A FC M3 Pl Y2 Valve Name AHR A HX OUT TO PROCESS SAMP PNL VALVE 1E12-F060B 0.75 Gl so 1075, 4 B-5 2 c c B A FC M3 Pl Y2 Valve Name AHR B HX OUTLT TO PROCESS SMPL PNL VALVE 1E12-F063A 3 GA M 1075,1 EB 2 c c A p LTJ AJ Valve Name CY to AHR FILL VALVE 1E12-F063B 3 GA M 1075,2 F4 2 c c A p LTJ AJ.

Valve Name CY TO AHR FILL VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 7)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class NonnaI Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coore! Position Positkin Type Freq. Request Just. Pos.

1E12-F063C 3 GA M 1075,3 FS 2 c c A p LTJ AJ Valve Name CY to AHR Fill VALVE 1E12*F064A 4 GA MO 1075, 1 B-8 2 0 O/C A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name AHR PuMP 1A MINIMUM FLOW VALVE 1E12-F0648 4 GA MO 1075;2 B-1 2 0 DIC A A DIA MDV EX M3 2201&04 LTJ AJ Valve Name RHR PUMP 1B MINIMUM FLOW VALVE 1E12-F064C 4 GA MO 1075,S. B-1 2 0 OIC A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name RHR PUMP 1C MINIMUM FLOW VALVE 1E12*F068A 18 GA MO 1052, 1 C-1 s c 0 B A DIA MDV EX MS 2201&04 Valve Name RHR HX 1A SSW OUTLET VALVE 1E12-F068B 18 GA MO 1052, 2 C-1 s c 0 B A DIA MDV EX M3 2201&04 Valve Name RHR HX 18 SSW OUTLET VALVE 1E12-F075A 0.75. Gt so 1075, 4 B-4 2 c c B A FC MS.

Pl Y2 Vatva Name AHR A HX OUTLT TO PROCESS SAMP PNL VALVE 1E12-F075B 0.75 GL so 1075,4 B-5 2 c c B A FC M3 Pl Y2 Valve Name RHR B HX OUTLT TO PROCESS SAMP PNL VALVE 1E12-F084A 2 CK SA 1075, 1 B*7 2 0 O/C c A cc MS co MS Valve Name LPCS WATER LEG PUMP DISCH CHK VLV TO AHR A 1E12-F084B 2 CK SA 1075,2 B-2 2 0 OIC c A cc MS co M3 Valve Name RH C WATER LEG PUMP DISCH CHK VLVTO AHR B 1E12-F084C 2 CK SA 1075,3 E-2 2 0 O/C c A cc MS co MS Valve Name RH C WATER LEG PUMP DISCH CHK VLV TO AHA C Revision Date: 10/21!2016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 8)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request JusL Pos.

1E12*F085A 2 CK SA 101s, 1 a.a 2 0 DIC c A cc M3 co M3 Valve Name LPCS WATER LEG PUMP DISCH CHK VLV TO RHR A 1E12*F085B 2 CK SA 1075,2 B*1 2 0 O/C c A cc M3 co M3 Valve Name RH C WATER LEG PUMP DISCH CHK VLV TO RHR B 1E12*F085C 2 CK SA 1075,3 E-1 2 0 O/C c A cc M3 co M3 Valve Name RH C WATER LEG PUMP DISCH CHK VLV TO RHR C 1E12-F086 3 GA M 1075,2 C4 2 c c A p LTJ AJ Valve Name CY to AHR FILL VALVE 1E12*FOB7A 6 GL M 1075,4 E*3 2 c c A p LTJ AJ Valve Name RCIC STEAM TO AHR HEAT EXCH IA VALVE 1E12*F087B 6 GL M 1075,4 E-7 2 c c A p LTJ AJ Valve Name RCIC STEAM TO AHR HEAT EXCH 18 VALVE 1E12*F094 4 GA MO 1075,4 E*7. 3 c O/C A A DIA MOV EX M3 2201&04 LT Y2 Valve Name AHR SSW CROSS TIE VALVE 1E12*F096 4 GA MO 1075,4 E-7 2 c O/C A A DIA MOV EX M3 2201&04 LTJ AJ Valve Name AHR/SSW CROSS TIE VALVE 1E12-F098 4 CK SA 1075,4 D-7 2 c 0 c A BOC M3 co M3 Valve Name AHR CONTAINMENT FLOODING LINE CHECK VALVE 1E12-F101 1x1.5 RV SA 1075,3 C-5 2 c O/C NC A LTJ AJ RT Y10 Valve Name AHR PUMP C SUCTION RELIEF VALVE 1E12-F105 20 GA MO 1075,3 B-5 2 0 O/C A a DIA MOV EX Y2 2201&04 LTJ AJ Valve Name AHR PUMP 1C SUCTION VALVE 1E12*F112A 0.75x1 RV SA 1075,4 C-2 2 c O/C AJC A LTJ AJ RT Y10 Valve Name AHR A HX Thermal Relief Valve Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Residual Heat Removal (Page 9)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coard Position Position Type Freq. Request Just. Pos.

1E12*F112B 0.75x1 RV SA 1075,4 C-7 2 c O/C AJC A LTJ AJ RT Y10 Valve Name AHR B HX Thermal Relief Valve 1E12*F495A 2 CK SA 1075, 2 E-3 2 c O/C A/C A cc CMP co CMP PIV Y2 Valve Name AHR TO FEEDWATER KEEP FILL CHECK VALVE 1E12-F4958 2 CK SA 1075,2 E-3 2 c O/C A/C A cc CMP co CMP PIV Y2 Valve Name AHR TO FEEDWATER KEEP FILL CHECK VALVE 1E12-F496 2 GL MO 1075, 2 E-4 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ PIV Y2 Valve Name RHRTO FEEDWATER 'B' KEEP FILL VALVE 1E12*F497 2 GL MO 1075, 1 E-7 2 c O/C A A DIA MOV EX Y2 2201&04 LTJ AJ .

PIV Y2 Valve Name RHRTO FEEDWATER 'A' KEEP FILL VALVE 1E12*F499A 2 CK SA 1075, 1 E-7 2 c O/C A/C A cc CMP co CMP PIV Y2 Valve Name AHR TO FEEDWATER KEEP FILL CHECK VALVE 1E12*F499B 2 CK SA 1075, 1 E-7 2 c O/C AJC A cc CMP.

co CMP PIV

• Y2 Valve Name AHR TO FEEDWATER KEEP FILL CHECK VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Reactor Core Isolation Cooling (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E51-C002E 4 GA MO 1079,1 03 2 0 c B A Pl Y2 SC M3 Valve Name RCIC TURB TRIP & THROTTLE VALVE 1E51-D001 8 RPO SA 1079, 1 F1 2 c O/C D A OT Y5 Valve Name RCIC VENT/DRAIN LINE RUPTURE DISC (DRAIN SIDE) 1E51-D002 8 RPO SA 1079, 1 F1 2 c O/C D A DT Y5 Valve Name RCIC VENTIDRAIN LINE RUPTURE DISC(VENT SIDE) 1E51-F004 GL AO 1079, 1 B-1 2 0 c B A FC M3

.Pl .Y2 Valve Name RCIC TURBINE EXHAUST DRAIN CONTROL VALVE 1E51*F005 GL AO 1079, 1 B-2 2 c c B A FC M3 Pl Y2 Valve Name RCIC TURBINE EXHAUST DRAIN CONTROL VALVE 1E51-F010 6 GA MO 1079,2 A6 2 0 O/C B A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RCIC SUCTION FROM RCIC STOR TANK VALVE 1E51*F011 6 CK SA 1079,2 A4 2 SYS 0 c A BOC M3 co M3 Valve Name RCIC PUMP SUCTION TESTABLE CHECK VALVE

. 1E51-F013 6 GA MO 1Q79, 2 F6 c O/C A A DIA MOV EX cs 2201&04 CSJ-111 Rellef2203 LTJ AJ PIV Y2 Valve Name RCIC INJECTION SHUT OFF VALVE 1E51-F018 2x3 RV SA 1079,2 cs 2 c O/C c A RT Y10 Valve Name RCIC TURBINE LUBE OIL COOLING CIRCUIT PRESS RELIEF 1E51-F019 3 GL MO 1079,2 06 2 c O/C A A* DIA MOV EX M3 2201&04 LTJ AJ Valve Name RCIC RECIRC TO SUPP POOL VALVE 1E51*F021 2.5 CK SA 1079, 2 05 2 SYS 0 c A BDC M3 co M3 Valve Name RCIC RECIRC TO SUPPRESSION POOL CHECK VALVE 1E51-F022 4 GL MO 1079,2 ES 2 c c B p Pl Y2 Valve Name RCIC TEST RETURN TO RCIC STOR TANK VALVE Revision Date: 1012112016

Revision Date: 10/21/2016 Clinton Station IST PROGRAM PLAN Reactor Core Isolation Cooling (Page 3)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1E51-F063 8 GA MO 1079, 1 EB 0 OIC A A DIA MOV EX cs 2201&04 CSJ*1OB Relief 2203 LTJ AJ Valve Name RCIC STEAM LINE INBOARD ISOLATION VALVE 1E51-F064 B GA MO 1079, 1 ES 0 OIC A A DIA MOV EX cs 2201&04 CSJ-10B Rellef2203 LTJ AJ Valve Name RCIC STEAM LINE OUTBOARD ISOLATION VALVE 1E51*F065 4 CK SA 1079,2 E6 SYS 0 c A BOC cs 2203 CSJ.110 co cs 2203 CSJ*110 Valve Name RCIC PUMP DISCHARGE HEADER CHECK VALVE 1E51*F066 4 CK SA 1079,2 FB SYS 0 A/C A cc RR 2203 RFJ-002 co cs 2203 CSJ*105 PIV Y2 Valve Name RCIC RPV ISOLATION CHECK VALVE 1E51*F06B 12 GA MO 1079, 1 cs 2 0 OIC A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RCIC TURBINE EXHAUST TO SUPP POOLVALVE 1E51-F076 GL MO 1079, 1 EB c c A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name RCIC STM LINE WARMUP INBOARD ISOL VALVE 1E51*F077 1.5 GL MO 1079, 1 cs 2 0 DIC A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RCIC EXHAUST VACUMM BKR OUTBOARD ISOL VALVE 1E51*F07B 3 GA MO 1079, 1 C6 2 0 OIC A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RCIC EXH VACUUM BKR INBOARD ISOL VALVE 1E51-F079 2 CK SA 1079, 1 cs 2 c DIC c A cc CMP co CMP RT Y4 Valve Name RCIC TURB EXH VAC BRKR CHECK VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Reactor Core Isolation Cooling (Page 4)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1E51*F081 2 CK SA 1079, 1 ca 2 c O/C c A cc CMP co CMP RT Y4 Valve Name RCIC TURB EXH VAC BAKR CHECK VALVE 1E51-F090 0.7Sx1 RV SA 1079,2 ES 2 c O/C A/C A LTJ AJ RT Y10 Valve Name RCIC STORAGE TANK BYPASS LINE RELIEF ANGLE VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Reactor Recirculation (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1833*F019 0.75 GL AO 1072, 1 ES 2 0 c B A . FC cs 2203 CSJ*115 Pl Y2 Valve Name RR SAMPLE LINE DRYWELL INBOARD ISOL VALVE 1833-F020 0.75 GL AO 1072, 1 EB 2 0 c B A FC cs 2203 CSJ-115 Pl Y2 Valve Name RR SAMPLE LINE DRYWELL OUTBOARD ISOL VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Reactor Water Cleanup (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1G33*F001 6 GA MO 1076,4 BB 0 c A A DIA MOV EX cs 2201&04 CSJ-112 Relief 2203 LTJ AJ Valve Name RWCU PUMP SUCTION INBOARD ISOL VALVE 1G33-F004 6 GA MO 1076,4 BS 0 c A A DIA MOV EX cs 2201&04 CSJ-112 Relief2203 LTJ AJ Valve Name RWCU PUMP SUCTION OUTBOARD ISOL VALVE 1G33-F028 4 GA MO 1076, 4 EB 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RWCU TO CONDENSER INBOARD !SOL VALVE 1G33*F034 4 GA MO 1076,4 E7 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RWCU TO CONDENSER OUTBOARD ISOL VALVE 1G33-F039 4 GA MO 1076,4 D7 2 0 c A A DIA MOV EX Y2 2201&04 lTJ AJ Valve Name RWCU RETURN LINE OUTBOARD ISOLATION VALVE 1G33*F040 4 GA MO 1076,4 DB 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name AWCU RETURN LINE INBOARD ISOL VALVE 1G33-F051 4 CK SA 1076, 4 06 2 0 c c A cc CMP co CMP Valve Name RWCU CK VLV TO AHR SHUTDOWN COOLING RETURN 1G33-F052A 4 CK SA 1076, 4 D5 2 0 c c A cc CMP co CMP Valve Name RWCU CHECK VALVE TO AHA SUCTION STRNNEA 1G33-F052B 4 CK SA 1076,4 D5 2 0 c c A cc CMP co CMP Valve Name RWCU CHECK VALVE TO AHR SUCTION STRNNER Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Reactor Water Cleanup (Page 2)

Valve EIN Size Valve Type Actu P&IO Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Oeferred Tech.

Type Coard Position Position Type Freq. Request Just. Pos.

1G33-F053 4 GA MO 1076,4 ca 2 0 c A A OIA MOV EX Y2 2201&04 LTJ AJ Valve Name RWCU PUMP DISCH INBOARD ISOL VALVE 1G33-F054 4 GA MO 1076,4 C7 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name RWCU PUMP DISCH OUTBD ISOLATION VALVE Revision Date: 10/21/2016

Cllnton Statlon IST PROGRAM PLAN Service Air (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safely Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1SA029 3.0 GL AO 1048,6 02 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name CNMT SA OUTBOARD ISOLATION VALVE 1SA030 3.0 GL AO 1048,6 D3 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name CNMT SA INBOARD ISOLATION VALVE 1SA031 3.0 GL AO 1048, 6 D4 2 c c B A FC M3 Pl Y2 Valve Name DRYWELL SA OUTBOARD ISOLATION CONTROL VALVE 1SA032 3.0 GL AO 1048,6 05 2 c c B A FC cs 2203 CSJ 103 Pl Y2 Valve Name DRYWELL SA INBOARD ISOLATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Standby Liquid Control (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety CategOfY Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1C41*F001A 3 GL MO 1077 C6 2 c 0 B A DIA MOV EX M3 2201&04 Valve Name STANDBY LIQUID CONTROL TANK OULET VALVE A 1C41-F001B 3 GL MO 1077 E6 2 c 0 B A DIA MOV EX M3 2201&04 Valve Name STANDBY LIQUID CONTROL TANK OULET VALVE B 1C41-F004A 1.5 SHA EXP 1077 C3 c 0 D A OT S2 Valve Name SLC PUMP A DISCHARGE EXPLOSNE VALVE 1C41*F0048 1.5 SHA EXP 1077 03 c 0 D A DT S2 Valve Name SLC PUMP B DISCHARGE EXPLOSIVE VALVE 1C41-F006 3 CK SA 1077 D2 c O/C c A cc RR 2203 RFJ-001 co RR 2203 RFJ-001 Valve Name STBY LIQUID CONTROL PUMP DISCHARGE CK VLV 1C41*F029A 1.5x2 RV SA 1077 C4 2 c ore c A RT Y10 Valve Name STBY LIQUID CONTROL PUMP 1A RELIEF VALVE 1C41*F029B 1.5x2 RV SA 1077 E4 2 c O/C c A RT Y10

. Valve Name STBY LIQUID CONTROL PUMP 1B RELIEF VALVE 1C41-F033A 1.5 CK SA 1077 C4 2 SYS O/C c A cc RR 2203 AFJ-011 co RR 2203 RFJ-011 Valve Name STBY LIQUID CONTROL PUMP 1A DISCHARGE CK VLV 1C41*F033B 1.5 CK SA 1077 D4 2 SYS OIC c A cc RR 2203 RFJ-011 co RR 2203 RFJ.011 Valve Name STBY LIQUID CONTROL PUMP 1B DISCHARGE CK VLV 1C41-F336 4 CK SA 1077 E1 SYS O/C c A cc RR 2203 RFJ-012 co RR 2203 RFJ-012 Valve Name STBY LIQUID CONTROL INJECTION CHECK VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Supp;ession Pool Cleanup & Transfer (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1SF001 10 GA MO 1060 ES 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name SF RETURN LINE OUTBOARD ISOLATION 1SF002 10 GA MO 1060 ES 2 c c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name SF RETURN LINE INBOARD ISOLATION 1SF004 12 GA MO 1060 cs 2 c c A A DIA MDV EX Y2 2201&04 LTJ AJ Valve Name SF SUCTION LINE OUTBOARD !SOLATION VALVE Revision Date: 10121/2016

Clinton Station IST PROGRAM PLAN Suppression Pool Makeup (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Jusl Pos.

1SM001A 24 BTF MO 1069 D5 2 c 0 B A DIA .MOV EX Y2 2201&04 Valve Name SUP POOL MAKE-UP SYS DUMP SHUTOFF VALVE 1SM001B 24 BTF MO 1069 D4 2 c 0 B A DIA MOV EX Y2 2201&04 Valve Name SUP POOL MAKE-UP SYS DUMP SHUTOFF VALVE 1SM002A 24 BTF MO 1069 DS 2 c 0 B A DIA MOV EX Y2 2201&04 Valve Name SUP POOL MAKE-UP SYS DUMP SHUTOFF VALVE 1SM002B 24 BTF MO 1069 D4 2 c 0 B A DIA MOV EX Y2 2201&04 Valve Name SUP POOL MAKE-UP SYS DUMP SHUTOFF VALVE 1SM003A 0.75x1 RV SA 1069 D5 2 c 0 c A RT Y10 Valve Name SUPP POOL MAKE-UP FUEL POOL DUMP LINE RELIEF VALVE 1SM003B 0.75x1 RV SA 1069 D4 2 c 0 c A RT Y10 Valve Name SUPP POOL MAKE-UP FUEL POOL DUMP LINE RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Shutdown Service Water (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coon! PoslUon Position Type Freq. Request Just. Pos.

1SX001A 30 CK SA 1052, 1 07 3 SYS O/C c A cc CMP co CMP Valve Name SHUTDOWN SERV WATER PUMP 1A DISCHG CHK VALVE 1SX001B 30 CK SA 1052,2 D7 3 SYS OIC c A cc CMP co CMP Valve Name SHUTDOWN SERV WATER PUMP 18 DISCHG CHK VALVE 1SX001C 10 CK SA 1052,3 D7 3 SYS O/C c A cc CMP co CMP Valve Name SHUTDOWN SERV WATER PUMP 1C DISCHG CHK VALVE 1SX003A 30 BTF MO 1052, 1 OS 3 0 0 B p Pl Y2 Valve Name SSW STRAINER 1A INLET VALVE 1SX003B 30 BTF MO 1052,2 OS 3 0 0 B p Pl Y2 Valve Name SSW STRAINER 1B INLET VALVE 1SX003C 10 BTF MO 1052,3 06 3 0 0 B p Pl Y2 Valve Name SSW STRAINER 1C INLET VALVE 1SX004A 30 BTF MO 1052, 1 05 3 0 0 B p Pl Y2 Valve Name SSW STRAINER 1AOUTLETVALVE 1SX0048 30 BTF MO 1052, 2 05 3 0 0 B p Pl Y2 Valve Name SSW STRAINER 1B OUTLET VALVE 1SX004C 10 BTF MO 1052, 3 05 3 0 0 B p Pl Y2 Valve Name SSW STRAINER 1C OUTLET VALVE 1SX006C 8 BTF MO 1052, 3 02 3 c o B A DIA MDV EX M3 2201&04 Valve Name DG 1C HEAT EXCHANGER OUTLET VALVE

.1SX008A 20 BTF MO 1052, 1 E6 3 c 0 B A DIA MDV EX Y2 2201&04 Valve Name SSW STRAINER 1A BYPASS VALVE 1SX008B 20 BTF MO 1052. 2 E6 3 c 0 B A DIA MDV EX Y2 2201&04 Valve Name SSW STRAINER 1B BYPASS VALVE 1SX008C 8 BTF MO 1052,3 ES 3 c 0 B A DIA MDV EX Y2 2201&04 Valve Name SSW STRAINER 1C BYPASS VALVE 1SX010A 2 GL AO 1052, 1 E3 3 c o B A FD M3 Valve Name 1VH07SA FLOW CONTROL VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Shutdown Service Water (Page 2)

Valve EIN Size Valve Type Ac tu P&IO Sheet/ Class Normal Safety Category Act/Pass Test Test Rellef Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1SX010B 2 GL AO 1052,2 E3 3 c 0 B A FO M3 Valve Name 1VH07SB FLOW CONTROL VALVE 1SX010C 1.5 GL AO 1052,3 E4 3 c 0 B A FO M3 Valve Name 1VH07SC SX PUMP RM 1C FLOW CONTROL VALVE 1SX011A 16 BTF MO 1052, 1 D3 3 c c A p LT Y2 Pl Y2 Valve Name DIV I CROSS TIE VALVE 1SX011B 16 BTF MO 1052,2 E3 3 c c A p LT Y2 Pl Y2 Valve Name DIV 2 CROSS TIE VALVE 1SX012A 14 BTF MO 1052, 1 C3 3 c 0 B A DIA MOV EX Y2 2201&04 Valve Name FC HX 1A SSW INLET VALVE 1SX0128 14 BTF MO 1052,2 C3 3 c 0 B A DIA MDV EX Y2 2201&04 Valve Name FC HX 16 SSW INLET VALVE 1SX013D 3 PLG MO 1052, 1 05 3 c 0 B A DIA MOV EX Y2 2201&04 Valve Name SSW STRAINER 1A BACKWASH VALVE 1SX013E 3 PLG MO 1052,2 D5 3 c 0 B A DIA MOV EX Y2 2201&04 Valve Name SSW STRAINER 18 BACKWASH VALVE 1SX013F 2 PLG MO 1052,3 cs 3 c DIC B A DIA MOV EX Y2 2201&04 Valve Name SSW STRAINER 1C BACKWASH VALVE 1SX014A 20 BTF MO 1052, 1 F3 3 0 c A A DIA MDV EX M3 2201&04 LT Y2 Valve Name SSW SYSTEM 1A ISOLATION VALVE 1SX014B 20 BTF MO 1052,2 F3 3 0 c A A DIA MOV EX M3 2201&04 LT Y2 Valve Name SSW SYS 1B ISOLATION VALVE Revision Date: 10/21/2016

Clinton Station

!ST PROGRAM PLAN Shutdown Service Water (Page 3)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1SX014C B BTF MO 1052,3 E4 3 0 c A A DIA MOV EX M3 2201&04 LT Y2 Valve Name SSW SYS 1C ISOLATION VALVE 1SX016A 2.5 GA MO 1052, 1 03 3 c O/C B A DIA MOV EX Y2 2201&04 Valve Name DIV 1 FUEL POOL MAKE-UP INLET VALVE 1SX0168 2.5 GA MO 1052,2 03 3 c O/C B A DIA MOV EX Y2 2201&04 Valve Name DIV 2 FUEL POOL MAKE-UP INLET VALVE 1SX017A B BTF MO 1052, 1 88 3 0 0 B p Pl Y2 Valve Name HVAC UNIT 1A HEAT EXCH INLET VALVE 1SX017B 8 BTF MO 1052, 2 BB 3 0 0 B p Pl Y2 Valve Name HVAC UNIT 18 HEAT EXCH INLET VALVE 1SX020A 12 BTF MO 1052, 1 C4 3 0 c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name ON I DRYWELL CHILLER ISOLATION VALVE 1SX020B 12 BTF MO 1052,2 C4 3. 0 c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name DIV 2 ORYWELL CHILLER ISOLATION VALVE 1SX023A 2 GL AO 1052, 1 C2 3 c 0 B A FO M3 Valve Name 1VY03S FLOW CONTROL VALVE 1SX023B 2 GL AO 1052,2 C2 3 c 0 B A FO M3 Valve Name 1VY05S FLOW CONTROL VALVE 1SX027A 2.5 GL AO 1052,4 06 3 c 0 B A FO M3 Valve Name 1VY02S FLOW CONTROL VALVE 1SX027B 2.5 GL AO 1052,4 02 3 c 0 B A FO M3 Valve Name 1VY06S FLOW CONTROL VALVE 1SX027C 2.5 GL AO 1052,4 C2 3 c 0 B A FO M3 Valve Name 1VY07S FLOW CONTROL VALVE 1SX033 2.5 GL AO 1052,4 cs 3 c 0 B A FO M3 Valve Name 1VY01S FLOW CONTROL VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Shutdown Service Water (Page 4)

Valve EIN Size Valve Type Actu P&IO Sheet/ Class Nonnal Safety category Act/Pass Test Test Relief Deferred Tech.

rype Coo rd Position Position Type Freq. Request Just Pos.

1SX037 1.5 GL AO 1052, 4 86 3 c 0 8 A FO M3 Valve Name 1VY04S FLOW CONTROL VALVE 1SX041A 2.5 GL AO 1052,3 C2 3 c 0 8 A FO M3 Valve Name 1VY08SA HPCS PUMP ROOM SX OUTLET FLOW CONTROL VlV 1SX0418 2.5 GL AO 1052,3 B2 3 c 0 B A FO M3 Valve Name 1VYOBS8 HPCS RM EAC 18 SX OUTLET FLOW CONTROL VlV 1SX062A 14 8TF MO 1052, 1 B4 3 c 0 8 A DIA MOV EX Y2 2201&04 Valve Name FC HX 1A SSW OUTLET VALVE 1SX062B 14 BTF MO 1052,2 84 3 c 0 B A DIA MOV EX Y2 2201&04 Valve Name FC HX 18 SSW OUTLET VALVE 1SX063A 8 BTF MO 1052, 1 C2 3 c 0 B A DIA MOV EX M3 2201&04 Valve Name DIESEL GEN 1A HEAT EXCH OUTLET VALVE 1SX063B 8 BTF MO 1052,2 C2 3 c 0 8 A DIA MOV EX M3 2201&04 Valve Name DIESEL GEN 18 HEAT EXCH OUTLET VALVE 1SX071A 3 GA MO 1052,5 F7 3 c c B p Pl Y2 Valve Name SBGT TRAIN A FIRE PROTECT DELUGE VALVE

~1SX0718 3 GA MO 1052,5 F3 3 c c 8 p Pl Y2 Valve Name SBGT TRAIN B FIRE PROTECT DELUGE VALVE 1SX073A 3 GA MO 1052,5 F5 3 c c A p LT Y2 Pl Y2 Valve Name SBGT TRAIN A FIRE PROTECT DELUGE VALVE 1SX073B 3 GA MO 1052,5 F2 3 c c A p LT Y2 Pl Y2 Valve Name SBGT TRAIN B FIRE PROTECT DELUGE VALVE 1SX074A 3 GA MO 1052,5 E7 3 c c B p Pl Y2 Valve Name CONT RM TRAIN A SUPPLY FILTER FP DELUGE VALVE 1SX074B 3 GA MO 1052,5 E3 3 c c 8 p Pl Y2 Valve Name CONT RM TRAIN B SUPPLY FILTER FP DELUGE VALVE 1SX076A 3 GA MO 1052,5 D7 3 c c A p LT Y2 Pl Y2 Valve Name CONT RM TRAIN A SUPPLY FILTER FP DELUGE VALVE Revision Date: 10/21/2016

Cllnton Station IST PROGRAM PLAN Shutdown Service Water (Page 5)

ValveEIN Size Valve Type Actu P&ID Shee!/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1SX076B 3 GA MO 1052,5 03 3 c c A p LT Y2 Pl Y2 Valve Name CONT RM TRAIN B SUPPLY FILTER FP DELUGE VALVE 1SXOS2A 3 GA MO 1052, 1 D1 3 0 c A A DIA MOY EX Y2 2201&04 LT Y2 Valve Name RHR HX 1A DEMINWATER INLET VALVE 1SXOB2B 3 GA MO 1052,2 01 3 0 c A A DIA MOV EX Y2 2201&04 LT Y2 Valve Name AHR HX 16 DEMIN WATER INLET VALVE 1SX105A 3 GA MO 1052, 5 07 3 c c B p Pl Y2 Valve Name CONT RM TRAIN A MAKEUP FILTER FP DELUGE VALVE 1SX105B 3 GA MO 1052, 5 03 3 c c B p Pl Y2 Valve Name CONT RM TRAIN B MAKEUP FILTER FP DELUGE VALVE 1SX107A 3 GA MO 1052,5 D7 3 c c A p LT Y2 Pl Y2 Valve Name CONT RM TRAIN A MAKEUP FILTER FP DELUGE VALVE 1SX107B 3 GA MO 1052,5 03 3 c c A p LT Y2 Pl Y2 Valve Name CONT RM TRAIN B MAKEUP FILTER FP DELUGE VALVE 1SX149 0.75x1 RV SA 1052, 4 C6 3 c 0 c A RT Y10

• Valve Name LPCS PUMP ROOM COOLER RELIEF VALVE 1SX150 0.75x1 RV SA 1052,4 BB 3 c 0 c A RT Y10 Valve Name RCIC PUMP ROOM COOLER RELIEF VALVE 1SX151A 0.75X1 RV SA 1052,4 E6 3 c 0 c A RT Y10 Valve Name RHR PUMP ROOM COOLER 1A RELIEF VALVE 1SX151B 0.7SX1 RV SA 1052,4 E2 3 c 0 c A RT Y10 Valve Name RHR PUMP ROOM COOLER 16 RELIEF VALVE 1SX151C 0.75x1 RV SA 1052,4 C2 3 c 0 c A RT Y10 Valve Name AHR PUMP ROOM COOLER 1C RELIEF VALVE 1SX152A 0.75X1 RV SA 1052, 1 C3 3 c 0 c A RT Y10 Valve Name AHR HX ROOM 1A COOLER RELIEF VALVE 1SX152B 0.75X1 RV SA 1052,2 C2 3 c 0 c A RT Y10 Valve Name AHR HX ROOM 1B COOLER RELIEF VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Shutdown Service Water (Page 6)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1SX153A 0.75x1 AV SA 1052, 1 C7 3 c 0 c A RT Y10 Valve Name CONTROL ROOM CHILLER RELIEF VALVE 1SX153B 0.75x1 AV SA 1052,2 cs 3 c 0 c A RT Y10 Valve Name CONTROL ROOM CHILLER RELIEF VALVE 1SX154A 0.75x1 RV SA 1052,4 ES 3 c 0 c A RT Y10 Valve Name SWGR HEAT REMOVAL UNIT RELIEF VALVE 1SX154B 0.75x1 RV SA 1052,4 E2 3 c 0 c A . RT Y10 Valve Name SWGR HEAT REMOVAL UNIT RELIEF VALVE 1SX154C 0.75x1 RV SA 1052, 3 C2 3 c 0 c A RT Y10 Valve Name DIV Ill SWGR COND UNIT SX OUTLET RELIEF VALVE 1SX155A 0.75x1 AV SA 1052, 1 E4 3 c 0 c A RT Y10 Valve Name SX PUMP ROOM 1A COOLER RELIEF VALVE 1SX155B 0.75x1 RV SA 1052,2 E3 3 c 0 c A RT Y10 Valve Name SX PUMP ROOM 1B COOLER RELIEF VALVE 1SX155C 0.75x1 RV SA 1052,3 04 3 c 0 c A RT Y10 Valve Name SX PUMP ROOM 1C COOLER RELIEF VALVE 1SX156A 0.75x1 RV SA 1052,3 B2 3 c 0 c A AT Y10 Valve Name HPCS PUMP ROOM COOLER 1A RELIEF VALVE 1SX15SB 0.75x1 RV SA 1052, 3 B2 3 c 0 c A RT Y10 Valve Name HPCS PUMP ROOM COOLER 1B RELIEF VALVE 1SX169A 0.75x1 AV SA 1052, 1 C3 3 c 0 c A RT Y10 Valve Name DIV 1 DIG HX RELIEF VALVE 1SX169B 0.75x1 RV SA 1052,2 C3 3 c 0 c A RT Y10 Valve Name DIV 2 D/G HX RELIEF VALVE 1SX169C 0.75x1 RV SA 1052, 3 02 3 c 0 c A AT Y10 Valve Name DIV 3 D/G HX RELIEF VALVE 1SX170A 0.75x1 RV SA 1052, 1 B3 3 c 0 c A AT Y10 Valve Name DIV 1 D/G HX RELIEF VALVE 1SX170B 0.75x1 AV SA 1052, 2 B3 3 c 0 c A RT' Y10 Valve Name DIV 2 D/G HX RELIEF VALVE 1SX181A 2.5 GA AO 1052, 1 F1 3 c 0 B A FO M3 Valve Name OVG05SA FLOW CONTROL VALVE 1SX181B 2.5 GA AO 1052,2 Fl 3 c 0 B A FO M3 Valve Name OVG05SB FLOW CONTROL VALVE Revision Date: 10/21/2016

Cfinton Station IST PROGRAM PLAN Shutdown Service Water (Page 7)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Rellef Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1SX185A 2.5 GL AO 1052, 1 E1 3 c 0 B A FO M3 Valve Name OVG07SA FLOW CONTROL VALVE 1SX185B 2.5 GL AO 1052,2 El 3 c 0 B A FO M3 Yaiva Name OVG07SB FLOW CONTROL VALVE 1SX189 2.5 GL AO 1052, 2 A4 3 c 0 B A FO M3 Valve Name DIV IV INVERTER RM COOLER CONTROL VALVE 1SX193A 1.5 GL AO 1052, 1 B7 3 c 0 B A FO M3 Valve Name DIV I INVERTER RM COOLING COIL CONTROL VALVE 1SX193B 1.5 GL AO 1052, 2 B4 3 c *o B A FO M3 Valve Name DIV II INVERTER RM COOL COIL CONTROL VALVE 1SX197 2 GL AO 1052, 1 B4 3 c 0 B A FO M3 Valve Name 1VY09S FLOW CONTROL VALVE 1SX200A 0.75x1 RV SA 1052, 1 F1 3 c 0 c A RT Y10 Valve Name SBGT RM 1A COOLING COIL RELIEF VALVE 1SX200B 0.75x1 RV SA 1052,2 F1 3 c 0 c A RT Y10 Valve Name SBGT AM 1B COOLING COIL RELIEF VALVE 1SX201A 0.75x1 RV SA 1052, 1 El 3 c 0 c A RT Y10 Valve Name H2 RECOMB AM 1A COOLING COIL RELIEF VALVE 1SX201B 0.75X1 RV SA 1052, 2 E1 3 c 0 c A RT Y10 Valve Name H2 AECOMB RM 1B COOLING COIL RELIEF VALVE 1SX202A 0.75x1 RV SA 1052, 1 A7 3 c a c A RT Y10 Valve Nalll& INVERTER RM IA COOLING COIL RELIEF VALVE 1SX202B 0.75x1 AV SA 1052, 2 cs 3 c 0 c A RT Y10 Valve Name INVERTER RM 16 COOLING COIL RELIEF VALVE 1SX203 0.75X1 RV SA 1052, 2 BS 3 c 0 c A AT Y10 Valve Name DIV IV INVERT RM COOLING COIL RELIEF VALVE 1SX204 0.75X1 RV SA 1052, 1 BS 3 c a c A RT

• Y10 Valve Name SX OUTLET RELIEF MSIV LEAKAGE RM COOLING COIL 1SX207 0.75X1 RV SA 1052,2 B2 3 c 0 c A RT Y10 ValVe Name MSIV LEAKAGE OUTBD RM COOLING COIL RELIEF VALVE 1SX208A 4x8 RV SA 1052, 1 C1 3 c 0 c A RT Y10 Valve Name AHR HX 1A RELIEF VALVE 1SX2088 4x6 RV SA 1052, 2 D1 3 c 0 c A RT Y10 Valve Name AHR HX 1B RELIEF VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Shutdown Service Water (Page 8)

Valve EIN Size Yalve Type Aclu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Teeh.

Type Coord Position Position Type Freq. Request Just. Pos.

1SX225 3.00 GA M 1052, 3 04 3 c c A p LT Y2 Valve Name PASS SYSTEM SX INLET ISOLATION VALVE 1SX294 0.75x1 RV SA 1052, 1 07 3 *c 0 c A RT Y10 Valve Name OPR13A SX RELIEF VALVE 1SX303A 4 CK SA 1052, 1 57 3 SYS OIC B A cc CMP co CMP Valve Name OVC13CA SSW INLET LINE VACUUM BREAKER VALVE 1SX303B 4 CK SA 1052, 2 C6 3 SYS O/C B A cc CMP co CMP Valve Name OVC13CB SSW INLET LINE VACUUM BREAKER VALVE 1SX315A 314 CK SA 1052, 3 C2 3 SYS O/C c A cc CMP co CMP Valve Name DIV. Ill SG RM COND. SX OUTLET VACUUM BAKR VALVE 1SX315B 314 CK SA 1052, 3 C2 3 SYS O/C c A cc CMP co CMP Valve. Name DIV. HI SG RM COND. SX OUTLET VACUUM BAKR VALVE 1SX316A 314 CK SA 1052,3 C3 3 SYS O/C c A cc CMP co CMP Valve Name DIV. Ill SG RM COND. SX INLET VACUUM BRKR VALVE 1SX316B 3/4 CK SA* 1052, 3 C3 3 SYS O/C c A cc CMP co CMP Valve Name DIV. Ill SG RM COND. SX INLET VACUUM BAKR VALVE 1SX346A 4 CK SA 1052,4 F7 3 OIC c A cc cs 2203 CSJ-118 co cs 2203 CSJ-118 Valve Name 1VX06CA SSW INLET LINE VACUUM BREAKER VALVE 1SX346B 4 CK SA 1052,4 E3 3 O/C c A cc' cs 2203 CSJ*118 co cs 2203 CSJ*118 Valve Name 1VX06CB SSW INLET LINE VACUUM BREAKER 1SX348A 4 CK SA 1052,4 F5 3 O/C c A cc CMP co CMP Valve Name 1VX06CA SSW OUTLET LINE VACUUM BREAKER VALVE 1SX348B 4 CK SA 1052,4 F2 3 OIC c A cc CMP co CMP Valve Name 1VX06CB SSW OUTLET LINE VACUUM BREAKER Revision Date: 10/2112016

CPS Station IST PROGRAM PLAN Shutdown Service Water (Page 9)

Valve EIN Slie Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relfef Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1SX350A 3/4 CK SA 1052,1 A6 3 SYS OIC c A cc CMP co CMP Valve Name Vacuum Bkr Relief for Supply Side of Div. 1 SX 1SX3508 314 CK SA 1052,2 A7 3 SYS - O/C c A cc CMP co CMP Valve Name Vacuum Bkr Relief for Supply Side of Div. 2 SX Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Control Room Ventllatlon (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet! Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

OVC010A 2 GL AO 1102, 5 A7 3 0 0 B A FO M3 Valve Name AUTO FLOW REGULATOR VAL VE OVC010B 2 GL AO 1102, 6 A7 3 0 0 B A FO M3 Valve Name AUTO FLOW REGULATOR VALVE OVC016A 2 GL M 1102,5 F6 3 c OfC B A ET Y2 Valve Name MCA CWS MIU MANUAL ISOL VALVE OVC016B 2 GL M 1102,6 F6 3 c OfC B A ET Y2 Valve Name MCA CWS MIU !SOL VALVE OVC017A 2 CK SA 1102,5 F7 3 SYS 0 c A BOC M3 co M3 Valve Name MCA CWS MIU CHECK VALVE OVC017B 2 CK SA 1102,6 F7 3 SYS 0 c A BOC M3 co M3 Valve Name MCA CWS MIU CHECK VALVE OVC020A 2 CK SA 1102,5 F7 3 SYS c c A BOO M3 cc M3 Valve Name MCA CWS MAKE UP CHECK VALVE OVC020B 2 CK SA 1102,6 F7 3 SYS c c A BOO M3 cc M3 Valve Name MC MAKE UP CHECK VALVE OVC022A 1.5 GL AO 1102, 5 F7 3 c 0 B A FO M3 Valve Name MCA CHILLED MIU WATER CONTROL VALVE OVC022B 1.5 Gl AO 1102,6 F7 3 c 0 B A FO M3 Valve Name MGR CHILLED MIU WATER CONTROL VALVE OVC025A 1x1.5 RV SA 1102,5 E6 3 c 0 c A RT Y10 Valve Name COMPRESSION TANK A RELIEF VALVE OVC025B 1x1.5 RV SA 1102,6 E6 3 c 0 c A RT Y10 Valve Name COMPRESSION TANK B RELIEF VALVE Revision Date: 10(21/2016

Clinton Station IST PROGRAM PLAN Drywell Cooling (Page 1)

ValveEIN Size Valve Type Actu Pl!D Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coon! Position Position Type Freq. Request Just Pos.

1VP004A 10 GA MO 1109, 2 03 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CHILLED WATER A SUPPLY OUTBOARD ISOLATION WP0048 10 GA MO 1109, 3 03 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CHILLED WATER B SUPPLY OUTBOARD ISOLATION 1VPOOSA 10 GA MO 1109, 2 02 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CLG 1A SPLY INBOARD ISOL VALVE 1VP005B 10 GA MO 1109,3 02 2 0 c A A OJA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CHILLED WATER B SUPPLY INBOARD ISOLATION 1VP014A 10 GA MO 1109,2 E3 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CHILLED WATER A RETURN INBOARD ISOLATION 1VP0148 10 GA MO 1109, 3 *E2 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CLG 1B RTAN INBOARD ISOL VALVE 1VP015A 10 GA MO 1109,2 E3 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CHILLED WATER A RETURN OUTBOARD ISOLATION 1VP015B 10 GA . . MO 1109,3 E3 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name DRYWELL CHILLED WATER B RETURN OUTBOARD ISOLATION 1VP023A 0.75x1 RV SA 1109, 2 D3 2 c O/C A/C A LTJ AJ RT Y10 Valve Name 'ow CHILLED WATER A SUPPLY LINE RELIEF VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Drywall Cooling (Page 2)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just Pos.

1VP0238 0.75x1 RV SA 1109,3 D3 2 c O/C AJC A LTJ AJ RT Y10 Valve Name OW CHILLEOWATER B SUPPLY LINE RELIEF VALVE 1VP027A 0.75x1 RV SA 1109,2 F3 2 c O/C AJC A LTJ AJ RT Y10 Valve Name OW COOL SYS COIL CAB 1C RELIEF VALVE 1VP027B 0.75x1 RV SA 1109, 3 F3 2 c O/C AJC A LTJ AJ RT Y10 Valve Name OW COOL SYS COIL CAB 1D RELIEF VALVE Revision Date: 10/2112016

Clinton Station IST PROGRAM PLAN Primary Containment Purge (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord Position Position Type Freq. Request Just. Pos.

1V0001A 24 BTF AO 1110,2 CB 2 c c B p Pl Y2 Valve Name OW PURGE TO CONTAINMENT EXHAUST FAN ISOLATION DMPR 1V0001B 24 BTF AO 1110, 2 C7 2 c c B p Pl Y2 Valve Name DW PURGE MOIST SEP B INLET DAN VALVE 1VQ002 24 BTF AO 1110,2 C6 2 c c B p Pl Y2 Valve Name DRYWELL PURGE SYS EXHAUST DRYWELL ISOLATION VALVE 1V0003 36 BTF AO 1110, 2 C5 2 c c B A FC cs 2203 CSJ-104 Pl Y2 Valve Name EXHAUST OUTBOARD DRYWELL ISOLATION VALVE 1VQ004A 36 BTF AO 1110, 2 04 2 c c A A FC cs 2203 CSJ-107 LTJ AJ Pl Y2 Valve Name OW PURGE CONTAINMENT OUTBOARD ISOLATION DAMPER 1V0004B 36 BTF AO 1110, 2 DS 2 c c A A FC cs 2203 CSJ-107 LTJ AJ Pl Y2 Valve Name CONTAINMENT BUll.DING EXH PURGE INBOARD ISOL VALVE WOODS 10 BTF AO 1110, 2 DB 2 c c B p Pl Y2 Valve Name EXHAUST INBOARD SYSTEM DRYWELL ISOL VALVE 1V0006A 4 GL MO 1110,2 C4 2 c c A p LTJ AJ Pl Y2 Valve Name CNMT EXHAUST OUTBOARD ISOLATION BYPASS VALVE 1V0006B 4 GL MO 1110,2 C4 2 c c A p LTJ AJ Pl Y2 Valve Name CNMT EXHAUST INBOARD ISOLATION BYPASS VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Containment Building Ventilation (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coord PosiUon Position Type Freq. Request Just. Pos.

1VR001A 36 BTF AO 1111, 1 E2 2 c c A A FC cs 2203 CSJ-107 LTJ AJ Pl Y2 Valve Name CONTAINMENT VENT OUTBOARD ISOLATION VALVE 1VR001B 36 BTF AO 1111, 1 E1 2 c c A A FC cs 2203 CSJ-107 LTJ AJ Pl Y2 Valve Name CONTAINMENT VENT INBOARD ISOLATION VALVE 1VR002A 4 GL MO 1111, 1 E2 2 c c A p LTJ AJ Pl Y2 Valve Name FUEL BLDG VA SUPPLY OUTBOARD ISOL. BYPASS VALVE 1VR002B 4 GL MO 1111, 1 E1 2 c c A p LTJ AJ Pl Y2 Valve Name CNMT VR SUPPLY INBOARD ISOLATION BYPASS VALVE 1VR006A 12 BTF AO 1111, 5 E3 2 0 c A A FC cs 2203 CSJ-104 LTJ AJ Pl Y2 Valve Name CONTINUOUS CNMT HVAC SUPPLY OUTBOARD !SOLATION 1VR006B 12 BTF AO 1111,5 E2 2 0 c A A FC cs 2203 CSJ-104 LTJ AJ Pl Y2 Valve Name CONTINUOUS CNMT HVAC SUPPLY INBOARD ISOLATION 1VR007A 12 BTF AO 1111,5 87 2 0 c A A FC cs 2203 CSJ-104 LTJ AJ Pl Y2 Valve Name CCPOUTBOARD EXHAUST ISOLATION VALVE 1VR007B 12 BTF AO 1111,5 B7 2 0 c A A FC cs 2203 CSJ-104 LTJ AJ Pl Y2 Valve Name CCP INBOARD EXHAUST ISOLATION VALVE 1VR035 0.75 PLG so s 1111.~ B22 2 0 c A A FC cs 2203 CSJ.104 LTJ AJ Pl Y2 Valve Name 1PDCVR020 AIR LINE !SOLATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Containment Bulldlng Ventilation (Page 2)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Nonna! Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just. Pos.

1VR036 0.75 PLG so 51111,~ 822 2 0 c A A FC cs 2203 CSJ.104 LTJ AJ Pl Y2 Valve Name 1PDCVR020 CNMT PURGE AIR LINE ISOLATION VALVE 1VR040 0.75 PLG so 81111.~ 822 2 0 c A A FC cs 2203 CSJ*104 LTJ AJ Pl Y2 Valve Name CCP AIR LINE ISOLATION VALVE 1VR041 0.75 PLG so s 1111.~ 822 2 0 c A A FC cs 2203 CSJ*104 LTJ AJ Pl Y2 Valve Name 1TSVR166 ISOLATION VALVE Revision Date: 10/21/2016

Clinton Station IST PROGRAM PLAN Plant Chilled Water (Page 1)

Valve EIN Size Valve Type Actu P&ID Sheet/ Class Normal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1W0001A 6 GA MO 1117,19 ES 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name PLANT CHILLED WATER OUTBOARD ISOLATION VALVE 1W0001B 6 GA MO 1117,19 E6 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name PLANT CHILLED WATER INBOARD ISOLATION VALVE 1W0002A 6 GA MO 1117,19 F5 2 0 c A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name PLANT CHILLED WATER OUTBOARD ISOLATION VALVE 1W0002B 6 GA MO 1117,19 F6 2 0 c *A A DIA MOV EX Y2 2201&04 LTJ AJ Valve Name PLANT CHILLED WATER INBOARD ISOLATION VALVE 1W0551A 4 GA MO 1117,26 E7 2 0 c B A DIA MOV EX Y2 2201&04 Valve Name DRYWELL OUTBOARD ISOL VALVE 1W0551B 4 GA MO 1117, 26 E7 2 0 c B A DIA MOV EX Y2 2201&04 Valve Name DRYWELL INBOARD ISOL VALVE 1W0552A 4 GA MO 1117,26 D7 2 0 c B A DIA MOV

• EX Y2 2201&04 Valve Name PLANT CHILL WATER OUTBOARD ISOLATION VALVE 1W0552B 4 GA MO 1117,26 D7 2 0 c B A DIA MOV EX Y2 2201&04 Valve Name PLANT CHILL WATER INBOARD ISOLATION VALVE 1W0570A 0.75x1 RV SA 1117, 26 F7 2 c O/C c A RT Y10 Valve Name PLANT CHILLED WATER SYSTEM SAFETY RELIEF VLV 1W0570B 0.75x1 RV SA 1117,26 D7 2 c DIC c A AT Y10 Valve Name PLANT CHILLED WATER SAFETY RELIEFVLV Revision Date: 10/21/2016

Clinton Station lST PROGRAM PLAN Solid Radwaste Reprocessing and Disposal (Page 1)

ValveEIN Size Valve Type Actu P&ID Sheet/ Class Nonnal Safety Category Act/Pass Test Test Relief Deferred Tech.

Type Coo rd Position Position Type Freq. Request Just Pos.

1WX019 2 PLG AO 1089,2 FG 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name INBOARD CNMT ISOLATION VALVE 1wxo20 2 PLG AO 1089,2 F5 2 0 c A A FC M3 LTJ AJ Pl Y2 Valve Name OUTBOARD CNMT ISOLATION VALVE 1WXOBO 3/4 RV SA 1089,2 F5 2 c OIC AIC A LTJ AJ RT Y10 Valve Name RADWASTE CONT. PEN RELIEF VALVE Revision Date: 10/2112016

ATTACHMENT 16 CHECK VALVE CONDITION MONITORING PLAN INDEX Revision 7 10/21/2016

CVCM PLAN REV NUMBER # TITLE CMP-01 0 Control Rod Drive Containment Isolation Check Valve CMP-02 1 Instrument Air Containment Isolation Check Valve CMP-03 0 4" Service Water System Vacuum Breakers CMP-04 0 3/4" Service Water System Vacuum Breakers CMP-05 0 Shutdown Service Water Pump Discharge Check Valves CMP-06 0 RCIC Turbine Exhaust Vacuum Breakers CMP-07 0 RHR to Feedwater Keep Fill Check Valves CMP-08 0 RWCU Check Valves to RHR CMP-09 0 Safety Relief Valve Vacuum Breakers CMP-10 0 Safety Relief Valve Vent Line Vacuum Breakers CMP-11 0 Shutdown Service Water Pump Discharge Check Valve CMP-12 0 HPCS Suction Check Valve from RCIC Storage Tank CMP-13 1 RCIC Water Leg Pump Discharge Check Valve CMP-14 1 RCIC Water Leg Pump Discharge Stop Check Valve CMP-15 0 New 3/4" Service Water System Vacuum Breakers Revision 7 10/21/2016