1. NEIL Requirements for Testing of FWH Electrical Equipment and AOV’s

2. 2007 - STP self-identified nonrelated NEIL issue that resulted in repeat failure of a critical SSC. 2007 - STP self-identified nonrelated NEIL issue that resulted in repeat failure of a critical SSC. NEIL inspection coming up  comprehensive review of all requirements  found this FWH equipment issue NEIL inspection coming up  comprehensive review of all requirements  found this FWH equipment issue Communicate NEIL requirements regarding FWH electrical equipment/AOV testing Communicate NEIL requirements regarding FWH electrical equipment/AOV testing –NEIL has spent beaucoup dinero on DC Cook event –Have shifted focus to protecting large assets (i.e. Main Turbine) –OE31559 – Reference Nine Mile Point OE Purpose

3. Requirements Feedwater Heater Alarms and Interlocks · Perform observation/Test/ Inspection/Surveillance of Integrity of Electrical Circuits/Heaters. Should ‘NA’, Shall 1 Fuel Cycle LCS 2.2.5.3.2 - 2 (TG/Exciter – Operating Test) · Operating and testing to be conducted: Integrity of electrical circuitry and power supply for heater extreme high level alarms, controls, switches and interlocks by testing. Should – ‘NA’, Shall – ‘1 fuel cycle’ LCS Section 2.2.5.3.2 - 2 Feedwater Heater Level Control Valves · Perform observation/Test/ Inspection/Surveillance of Integrity of Electrical Circuits/ Valves. Should ‘NA’, Shall 1 Fuel Cycle LCS 2.2.5.3.2 -3 (TG/Exciter – Operating Test) · Operating and testing to be conducted: Integrity of electrical circuitry and power supply of all remote operated heater drain and bypass valves by testing. Should – ‘NA’, Shall – ‘1 fuel cycle’ LCS Section 2.2.5.3.2 - 3

4. Typical Heater Drain System Normal Level Control Valve High Level Dump May be digital or Analogue

5. Typical Heater Steam Side Isolation Level Switches that: Shut off Extraction Steam Shut off previous FWH flow Shut off Blowdown flow

6. Typical Tube Side Isolation System Level Switches that: Shut off Condensate flow Open Condensate Bypass Shut off other sources of flow into heater

8. RHDT’s / MSDT’s / Deaerator switches/AOV’s are not applicable RHDT’s / MSDT’s / Deaerator switches/AOV’s are not applicable Alarms are not applicable (per our NEIL rep, though you should ask your rep specifically) Alarms are not applicable (per our NEIL rep, though you should ask your rep specifically) Should be done at beginning of outages to identify scope Should be done at beginning of outages to identify scope You can take credit for SU/SD actuation, PM, or corrective PMT (monitor voltage at the contacts for large MOV’s) You can take credit for SU/SD actuation, PM, or corrective PMT (monitor voltage at the contacts for large MOV’s) Don’t have to test all equipment at the same time Don’t have to test all equipment at the same time No requirement to fill level switch standpipes No requirement to fill level switch standpipes Ops controlled procedure is the easiest way Ops controlled procedure is the easiest way Considerations for Testing

9. Discussion NEIL standards are governed by representatives from each plant NEIL standards are governed by representatives from each plant If a standard is too restrictive or is not effective, the board can change it If a standard is too restrictive or is not effective, the board can change it What is your plant’s strategy? What is your plant’s strategy? What do you think? What do you think?