3F1287-32, Forwards Updated ASME Section XI Pump & Valve Program Inservice Insp, Vols I & Ii.Revised Relief Requests & Recommended Schedule for Issuance of NRC Approval Also Encl
Text
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Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Pump & Valve Program (1983 Edition)
Program Submittal
Dear Sir:
Florida Power Corporation (FPC) hereby submits the updated Pump and Valve Program as required by the 1983 Edition of the ASME Boiler and Pressure Vessel Code,Section XI, Article IWA-1400(c).
This program is based on the 1983 Edition through Summer 1983 Addenda of Section XI as required by 10 CFR 50.55a.
Also enclosed are Relief Requests, with minor revisions (Attachment 2) and a recommended schedule for issuance of NRC approval (Attachment 1).
These Relief Requests supercede Relief Requests submitted on November 18, 1987.
The Pump and Valve Program includes currently issued copies of flow diagrams for use during the Staff's evaluation of Relief Requests.
I The program description (Tables) are based on pre-outage, September
- 1987, drawings and thus may not exactly match the submitted drawings.
Pump and Valve testing implementing procedures reflect the current drawings and any additional pending drawing changes which have occurred during the outage as a
result of plant modifications.
Following the outage and issuarce of outage related drawing changes, the program description will be updated.
This should occur during the first quarter of 1988.
If requested, an update will be submitted at that time in lieu of the planned annual update.
The administrative controls, described in the program document, do not require prior Plant Review Committee (PRC) or NRC approval of PBg2 1888K8?asjjga
/(o47 G
Post Office Box 219 + Crystal River, Florida 32629 + Telephone (904) 795 3802
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A Florida Progress Company
December 31, 1987 3F1287-32 Page 2 program changes that meet code requirements.
PRC review cnd approval of changes to the test implementing procedures is required by Technical Specifications.
NRC approval of program changes that require code relief is required and is specified in the program.
Florida Power Corporation may still choose to get PRC concurrence for significant program changes.
Florida Power Corporation's position of not requiring PRC and/or NRC approval is different from the guidelines contained in Inspection Report 87-17 and the Safety Evaluation Report for the 1974 Edition Pump and Valve Program (May 29, 1987).
From correspondence with other utilities, FPC found that PRC review of the program is not a common industry practice.
Various utilities impose different review requirements despite standard regulatory requirements.
Additionally, a requirement for PRC approval prior to implementing program changes increases the PRC workload considerably.
NRC approval is required for Relief Request implementation and associated tests described in Table 2 of the program.
NRC approval is not required for the balance of the program.
Sincerely.
E.C.
Simpson, Director Nuclear Operations Site Support PGH/dhd xc:
Dr.
J.
Nelson Grace Regional Administrator, Region II i
l Mr.
T.
F.
Stetka Senior Resident Inspector Relief Request Schedule Summary A.
The following Relief Requests are generic and apply during plant operation.
They should be scheduled to coincide with the start of the new interval (around mid-January 1988).
V-115 V-320 #
V-330 #
B.
The following Relief Requests concern the quarterly tests of Pumps and Valves.
These Relief Requests should be scheduled for resolution prior to the end of the first testing quarter (eround mid-May 1988).
V-020 #
V-129 #
V-190 V-030 #
V-131 V-195 V-Ill V-132 V-200 V-112 V-150 #
V-210 V-120 #
V-160 #
V-283 V-123 V-170 #
V-128 #
V-181 #
C.
The following Relief Requests concern tests performed each refuel.
These Relief Roquests should be resolved by the next refuel outage (1989).
V-130 V-360 D.
The following Relief Request is submitted in event the next quarterly test is not repeatable due to differing heat load conditions during winter and summer.
A schedule will be provided
)
later, an appropriate.
V-370
- Relief Request is similar or identical to a Relief Request accepted by the 5/29/87 SER for the 1974 Edition Based Program.
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Relief Requests O
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INSERvlCE IwSPECTION l RELIEF REQUEST # l E%3yW()f' PUMP AND YALVE PROGRAM l
V-020 L
CRYSTAL RIVER UNIT 3
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Rev. 1 Page 1 of 1 j
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Reference Code:
ASME Boiler and Pressure Vessel Code, l
Section XI, 1983 edition through
(
summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a)
Name and identification number (component tag):
ASV-23; Steam Supply Isolation Valve from Crystal River Units 1 and 2 to Turbine l Driven Emergency Feedwater Pump Turbine (EFTB-1).
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j b)
Function:
This va1ve serves as the boundary valve between Class 3 l and Quality - Group D systems.
It is located in the Auxiliary l
Steam (AS) system, and allows the AS header to supply steam to j
EFTB-1.
However, this system is a non-safety, non-seismic backup
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supply of steam to EFTB-1.
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c)
ACME Section III Code Class:
3.
I d)
Valve Category:
B.
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II.
Reference Code Requirement That Has Been Determined To Be l
Impractical:
IWV-3411: Juarterly valve exercise requirement.
III.
Basis For Requesting Relief:
This valve is closed during normal plant operation.
Aux 111ary steam is not a safety and seismic class source of power for the emergency feedwater turbine.
{
l IV.
Alternate Examination:
Operational checks with appropriate record j
entries shall record the position of this passive valve before and I
after valve operations that change the position are completed.
I V.
Implementation Schedule:
The alternate examination program require-ments are currently being met.
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Page 240
- Florida InSERv1CE InSPECTIow REtiEr REauEST s
UDr,. [hggyqar PUMP AND VALVE PROGRAM V-030 CRYSTAL RIVER UNIT 3 Rev. 1 a-
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1 Page 1 of 2 I
4 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
BSV-26 L BSV-27, Pump BSP-1B and BSP-1A check valves to spray nozzles.
b)
Function:
Normally closed valves that open for containment building cooling on 30 psig RB pressure signal, which starts the building spray pumps, and allowing flow to the building spray nozzles.
c)
ASME Section III Code Class:
2.
d)
Valve Category:
C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521; Quarterly valve exercise requirement.
IWV-3522(b); Partial stroke valve exercise during normal plant operation and full valve exercise during cold shutdown.
III.
Basis For Requesting Relief:
The stroke of these valves would require initiation of the RB spray system.
This would entall spraying the RB with borated water. No pre-service values were recorded for these valves and identical spares are not available.
Because of this, it is not possible to comply with IWV-3522(b) mechanical exercise procedure for the lift force required to move the disk.
IV.
Alternate Examination:
Each refueling outage, at least one different valve from each group, where a group is a set of valves with the same I
design and service conditions, shall be disassembled and inspected as described below until the entire group has been tested.
If the valve is degraded to the extent that the valve can nnt perform its function, then all other valves in that group shall be inspected as described below.
The subsequent inspections may start again with single valves.
U l
The inspection shall assure that the valve disk has freedom of movement, j
and is capable of a full stroke.
Additionally. the general condition of the valve internals shall be checked for structural degradation in-cluding the presence of any loose parts, debris and abnormal or j
excessive corrosion products, wear and erosion.
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Page 241
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M INSERVICE INSPECTION RELIEF REQUEST #
I@
%gr PUMP AND VALVE PROGRAM V-030 CRYSTAL RIVER UNIT 3 Rev. 1 a-Page 2 of 2 V.
Implementation Schedule:
The alternate examination program require-ments will be met following the start of the next interval.
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Page 241a
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s I' SERVICE INSPECTION PELIEF REQUEST s
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Elk)Thd3 N
[)gggqgy PUMP AND VALVE PROGRAM V-111 CRYSTAL RIVER UNIT 3 Rev. O Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tagt:
EFP-1 and EFP-2 Emergency Feedwater Pumps b)
Function:
Emergency Feedwater pumps provide water to the steam generators upon isolation of main feedwater to mitigate the consequences of a design basis accident.
c)
ASME Section III Code Class:
3.
d) Valve Category:
N/A II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWP-3100; Table IWP-3100-1 requirement for measuring flow rates for pump inservice tests.
III.
Basis For Requesting Relief:
It is not necessary to measure the flow rate of a fixed resistance system as delineated in ASME XI, Table IWP-3100-1 footnote 1, 1974.
Although this stipulation was removed from ASME XI-1983 edition the engineering basis remains valid.
FPC does not currently have the capability to measure flow rate in the emergency feedwater pump recirculation line, but the flow path is a fixed resistance system because it includes a fixed flow orifice, therefore, flow rate measurement is not necessary, IV.
Alternate Examination:
N/A V.
Implementation Schedule:
Requirements for IWP-3100 are currently being met, l
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Page 244a
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INSERVICE INSPECTION RELIEF REQUEST #
j p()ygggy PUMP AND VALVE PROGRAH V-112 CRYSTAL RIVER UNIT 3 Rev. O sa-Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
1 I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
DFP-1A, 1B, 1C and 10 - Diesel fuel oil transfer pumps.
{
b)
Function:
Diesel fuel transfer pumps provide for the makeup and transfer of fuel oil from fuel storage to the diesel day tanks, c)
ASME Section III Code Class:
3.
d) Valve Category:
N/A II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWP-3100: Table IWP-3100-1 requirement for measuring flow rates for pump inservice tests.
III.
Basis For Requesting Relief:
It is not necessary to measure the flow rate of a fixed resistance system as delineated in ASME XI, Table IWP-3100-1 footnote 1, 1974.
Although this stipulation was removed from ASME XI-1983 edition the engineering basis remains valid.
FPC does not currently have the capability to measure the flow rate in the Diesel fuel transfer pumps.
The flow path is a fixed resistance system because it includes a fixed flow path, from the storage tank through the transfer pumps into the day tanks, and therefore, flow rate measurement is not necessary.
Speed is set and differential pressure is measured.
l IV.
Alternate Examination:
N/A V.
Implementation Schedule:
Requirements for IWP-3100 are currently being met.
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El()rkjg INSERVICE INSPECTION RELIEF REQUEST 4 8
%gf PUMP AND VALVE PROGRAM V-115 CRYSTAL RIVER UNIT 3 Rev. O Page 1 of 1 I
Reference Code:
ASME Boiler and Pressure Vessel Code, 3
Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
{
a)
Name and identification number (component tag):
All class 1, 2,
and 3 Relief Valves.
b) Function:
To provide over pressure protection for the ASME class 1,
2, and 3 systems.
c)
ASME Section III Code Class:
1, 2, and 3 as appropriate, d) Valve Category:
C.
II.
Reference Code Requirement That Has Been Determined To Se Impractical:
American National Standards, Performance TEST CODE 25.3, 1976 referenced in IWV-3512, 1983.
III.
Basis For Requesting Relief:
The alternate code is a more recent standard and more appropriate for valve testing in the field.
IV.
Alternate Examination:
Relief is requested to utilize the reference in ASME XI, IWV-3512, 1986, ANSI /ASME OM-1, 1983 for test procedures.
V.
Implementation Schedule:
The alternate examination program require-ments will be implemented upon the beginning of the second ten year inspection program, l
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Ficnicia INSERVICE INSPECTION RELIEF REQUEST #
%gr PUMP AND YALVE PROGRAM V-120 CRYSTAL RIVER UNIT 3 Rev. O n-Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
BSV-150 and 151, BST-1 to BS pump Suction Check Valves.
b) Function:
To prevent backflow of borated water from the BWST into the sodium hydroxide storage tank.
c) ASHE Section III Code Class:
Class 2 d) Valve Categcry:
C II.
Reference Code (requirement That Has Been Determined To Be Impractical:
IWV-3520(b)(2): Partial stroke valve exercise during normal plant operation and full valve exercise during cold shutdown.
III.
Basis For Requesting Relief:
This tank, BST-1, is a storage tank for Sodium Hydroxide (NaOH) that will be used for post-LOCA pH control.
The building spray system is lined up to the borated water storage tank (BWST) which stores borated water for refueling and post-accident in]ection through the HPI, LPI, and BS systems.
The NaOH is not chemically compatible with the borated water, as the bcron is an aqueous solution of boric acid.
Stroking these check valves could only be accomplished by injecting the NaOH into the the borated water at the pumo suction and recirculating this mixture to the BWST. The design basis did not call out the values needed for testing under IWV-3522(b) no flow / mechanical exercising.
No pre-service valves were recorded for these valves and identical spares are not available.
Because of this, j
it is not possible to comply with IWV-3522(b) mechanical exercise pro-Cedure for the lift force required to move the disk.
IV.
Alternate Examination:
Each valve will have a disassembly / inspection utilizing a manual exercising the disk to verify the valve's freedom of movement and full stroke capability, The disk movement for normally closed check valves shall be sufficient to prove that the disk moves freely off the seat.
The disassembly / inspection will be performed at each refueling outage.
V.
Implementation Schedule:
The alternate examination program require-ments will be met following the start of the next interval.
Page 244d
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FlcNicia INSERVICE INSPECTION RELIEF REQUEST #
PUMP AND VALVE PROGRAM V-123
[g)ygggy CRYSTAL RIVER UNIT 3 Rev. 1 u..-
Page 1 of 1 l
Reference Code:
ASME Boiler and Pressure Vessel Code, l
Section XI, 1983 edition through summer 1983 addenda.
1 I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
DHV-93, I
pressurizer spray line to DH "A-Train" discharge check valve.
b) Function:
This is a closed valve during normal plant operation.
It opens to cool the pressurizer from the decay heat removal system when the reactor is in cooldown, and the RC pressure is within design pressure limits of the decay heat removal system.
c) ASME Section III Code Class:
2.
d) Valve Category:
A/C.
I II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3522(b); Partial stroke valve exercise during normal plant operation, i
III.
Basis For Requesting Relief: Opening this valve is impossible during normal plant operation as the decay heat removal system is a lower pressure system than the RC system.
IV.
Alternate Examination:
This valve is sub3ect to 10 CFR 50, Appendix J Type C Leak Rate Testing during each Refueling Outage.
V.
Implementation Schedule:
The alternate examination program require-ments are currently being met.
Page 247
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IN Florida INSERVICE INSPECTION RELIEF REQUEST s
, itTi Power :
PUMP AND VALVE PROGRAM V-128 CRYSTAL RIVER UNIT 3 Rev. O J
Page 1 of 2 j
Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
CFV-1, check valve isolation from "A" train, decay heat and core flood, to reactor vessel: CFV-3, check valve isolation from "B"
train, decay heat and core flood, to reactor vessel, b)
Function:
These valves are in the flow path from the core flood tanks to the reactor coolant system (RCS).
They provide passive isolation from the high pressure RCS to the low pressure core flood tanks and the decay heat system, and between the core flood tanks and the decay heat system.
I c)
ASME Section III Code Class:
1.
I d)
Valve Category:
A/C.
II.
Reference Code Requirement That Has Been Determined To be Impractical:
IWV-3522(b):
Partial stroke during normal plant operation; full stroke valve exercising, either with or without flow (mechanical exercising) during cold shutdown.
III.
Basis for Requesting Relief:
1 1)
Valves cannot be tested with the unit at power, as the Core Flood Tanks are maintained at 700 psig, with the Reactor at 2155 psig.
2)
Due te the magnitude of the design flow for the core flood lines, these" valves cannot be demonstrated to fully open, utilizing a flow test.
1 1
- 3) Valves cannot be scheduled for disassembly during a cold shutdown, as these type outages last for an undetermined amount of time, l
valve disassembly constitutes a ma3or radiological work activity
{
and would stand a very good chance of delaying a restart.
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El()Thdjl INSERVICE INSPECTION RELIEF REQUEST #
[h3ygghy '
PUMP AND VALVE PROGRAM V-128 CRYSTAL RIVER UNIT 3 Rev. 0 l
Page 2 of 2
- 4) Mechanical exercising for no-flow tests require reference values of
- 102 of equivalent force or torque represented by the minimum emergency condition dp acting on the disk" and "200 of actual observed force or torque required to perform the (full-stroke) exercise on the valve when new and in good operating condition, whichever is less".
In the first case, the value is deemed to be negligible, for practical purposes, nearly zero pounds dp.
In the latter case, no values were recorded upon installation and identical replacements are not available for establishing current values.
IV.
Alternate Examination:
Each refueling outage, at least one different valve from each group, where a group is a set of valves with the same design and service conditions, shall be disassembled and inspected as described below until the entire group has been tested.
If the valve is degraded to the extent that the group shall be inspected as de-scribed below.
The subsequent inspections may start again with single valves.
The inspection shall assure that the valve disk has freedom of movement and is capable of a full stroke.
Additionally, the general condition of the valve internals shall be checked for structural degradation including the presence of any loose parts, debris and abnormal or ex-I cessive corrosion products, wear and erosion.
V.
Implementation Schedule:
The alternate examination program require-ments will be met following start of next interval.
Page 247b
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INSERVICE INSPECTION RELIEF REQUEST #
C W{gy)g @@
2 Power!
PUNP AND VALVE PROGRAM V-129 CRYSTAL RIVER UNIT 3 Rev. O
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a*
Page 1 of 2 Reference Code:
ASHE Boiler and Pressure Vessel Code, l
Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
I a) Name and identification number (component tag):
CFV-2, check valve isolation from *A" core flood tank; CFV-4, check valve isolation I
from *B*
core flood tank.
I b)
Function:
These valves are in the flow path from the core flood tanks to the reactor coolant system (RCS).
They provide passive isolation from the high pressure RCS to the low pressure core flood tanks and the decay heat system, and between the core flood tanks and the decay heat system.
c)
ASME Section III Code Class:
1.
di Valve Category:
A/C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3522(b):
Partial stroke during normal plant operation; full stroke valve exercising, either with or without flow (mechanical exercising) during cold shutdown.
III.
Basis for Requesting Relief:
l
- 1) Valves cannot be tested with the unit at power, as the Core Flood l
Tanks are maintained at 700 psig, with the Reactor at 2155 psig.
2)
Due to the magnitude of the design flow for the core flood lines, these valves cannot be demonstrated to fully open, utilizing a flow test.
3)
Valves cannot be scheduled for disassembly during a cold shutdown, I
as these type outages last for an undetermined amount of time.
Valve disassembly constitutes a ma3cr radiological work activity j
and would stand a very good chance of delaying a restart.
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Page 247c l
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9.
Florida INSERVICE INSPECTION RELIEF REQUEST s
- $}
[k}yyq)f PUNP AND VALVE PROGRAM V-129 CRYSTAL RIVER UNIT 3 Rev. O SQfjgg=* ' " '
'a Page 2 of 2
- 4) Mechanical exercising for no-flow tests require reference values of j
"101 of equivalent force or torque represented by the minimum emergency condition dp actang c1 the disk
- and "200 of actual observed force or torque requirid to perform the (full-stroke) exercise on the vr*
when new and in good operating condition, whichever is less".
In the first case, the value is deemed to be negligible, for practical purposes, nearly zero pounds dp.
In the latter case, no values were recorded upon installation and icentical replacements are not available for establishing current values.
IV.
Alternate Examination:
Each refueling outage, at least one different valve from each group, where a group is a set of valves with the same design and service conditions, shall be disassembled and inspected as described below until the entire group has been tested.
If the valve is degraded to the extent that the group shall be inspected as de-scribed below.
The subsequent inspections may start again with single valves.
The inspection shall assure that the valve disk has freedom of movernent '
and is capable of a full stroke.
Additionally, the general condition of the valve internals shall te checked for structural degradation including the presence of any loose parts, debris and abnormal or ex-cessive corrosion products, wear and erosion.
V.
Implementation Schedule:
The alternate examination program require-ments will be met following start of next interval.
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Page 247d
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9pggggggg INSERVICE INSPECTION RELIEF REQUEST s PUMP AND VALVE PROGRAM V-130 pg CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief is Requested:
a) Name and identification number (component tag):
CFV-2, check valve isolation from "A" core flood tank; CFV-4, check valve isolation from "B" core flood tank.
b)
Function:
These valves are in the flow path from the core flood tanks to the reactor coolant system (RCS).
They provide passive isolation from the high pressure RCS to the low pressure core flood tanks and the decay heat system, and between the core flood tanks and the decay heat system.
c) ASME Section III Code Class:
1.
d)
Valve Category:
A/C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3420; Valve Leak Rate Test for CFV-2 and CFV-4.
1 III.
Basis For Requesting Relief:
In each train, two check valves are in j
There is no means to pressurize past the downstream valve.
series.
Therefore, the upstream valves (CFV-2 from CFT-1A, and CFV-4 from CFT-1B) cannot be tested for leak tightness.
IV.
Alternate Examination:
CFV-1 and CFV-3 are leak test per Technical Specification 4.4.6.2.2, 4.4.6.2.3, 3.4.6.2 and Table 3.4-2.
V.
Implementation Schedule:
Alternate Examination program requirements will be initiated with start of next interval.
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Ficnida INSERVICE INSPECTION RELIEF REQUEST s 1
PUMP AND VALVE PROGRAM V-131
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f [c -(yygggy -
CRYSTAL RIVER UNIT 3 Rev. 1
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Page 1 of 2 l
Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
DJV-1, DJV-2, DJV-17, DJV-18, DJV-27, DJV-28, DJV-29, DJV-30, DJV-31, DJV-32 check valves.
l b)
Function: These are the essential valves comprising the coolant water flow path of the emergency diesel and its associated lube oil system.
l c) ASME Section III Code Class:
3.
d)
Valve Category:
C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521; Quarterly valve exercising requirements.
III.
Basis For Requesting Relief:
The emergency diesels are required to be tested monthly in accordance with the facility technical specifications.
The use of this system is required for the startup I
and operation of the Emergency Diesel Generators.
Since these valves were provided as an integral part of the diesel package, no pre-service values were recorded for these valves and identical spares are not available.
Because of this, it is not possible to comply with IWV-3522(b) mechanical exercise procedure for the lift force required I
to move the disk.
IV.
Alternate Examination:
Each diesel will be tested in accordance with plant technical specifications for operability.
Current technical specifications require each diesel generator to be tested monthly.
Each refueling outage, at least one different valve from each group, where a group is a set of valves with the same design and service I
conditions, shall be disassembled and inspected as described below l
until the entire group has been tested.
If the valve is degraded to
{
extent that the valve cannot perform its function, then all other valves in that group shall be inspected as described below.
The sub-sequent inspections may start again with single valves.
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Page 253 i
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i IN 3 hg$h Florida INSERVICE INSPECTION RELIEF REQUEST #
affPOW PUMP AND VALVE PROGRAM V-131
%Q(fy%** ' "er '
CRYSTAL RIVER UNIT 3 Rev. 1 l
Page 2 of 2 The inspection shall assure that the valve disk has freedom of movement and is capable of a full stroke.
Additionally, the general condition of the valve internals shall be check for structural degradation including the presence of any loose parts, debris and abnormal or excessive corrosion products, wear and erosion.
V.
Implementation Schedule:
The 100% disassembly / inspection will be performed at each refueling outage, starting at the next refueling outage.
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og @[gd3 INSERVICE INSPECTION RELIEF REQUEST #
OM/ POV/er PUMP AND VALVE PRDGRAM V-132 l
go CRYSTAL RIVER UNIT 3 Rev. 1 1
'sa-Page 1 of 1 Reference Code:
ASHE Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
1.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
DJV-38 and DJV-39.
Combustion air coolers to diesel generators diesel Jacket cooling
'l radiators check.
1 I
b)
Function:
Provide coolant water for the cornbustion air coolers in the emergency diesels.
q l
c)
ASME Section III Code Class:
3.
d)
Valve Category:
C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521; Quarterly valve exercising requirement.
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I I
III.
Basis For Requesting Relief:
The emergency diesels are required to be tested monthly in accordance with the facility technical specifica-tions.
The use of this system is required for the startup and
)
operation of the Emergency Diesel Generators.
1 IV.
Alternate Examination:
Each diesel will be tested in accordance with
)
plant technical specifications for operability.
Current technical i
specifications require each diesel generator to be tested monthly.
Each refueling outage, each valve shall be disassembled and inspected as described below.
The inspection shall assure that the valve disk has freedom of movement and is capable of a full stroke.
Additionally, the general condition
]
J of the valve internals shall be checked for structural degradation
]
including the presence of any loose parts, debris and abnormal or excessive corrosion products, wear and erosion.
V.
Implementation Schedule:
The alternate examination program require-ments will be met starting at the next refueling outage.
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FicnicLa INSERVICE INSPECTION RELIEF REQUEST #
[hyggggf PUMP AND VALVE PROGRAM V-150 5*"'*"'o" CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code:
ASME Boller and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
DWV-162, Demineralized water supply check valve inside the Reactor Building.
b) Function:
During normal plant operation, this valve is partially open to allow a small quantity of demineralized water to flow to the RC pumps standpipes for flushing.
It is not required to be fully open in any safety mode, but must close in case of containment isolation.
c) ASME Section III Code Class:
2.
di Valve Category:
A/C.
i II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521; Quarterly valve exercising requirement.
III.
Basis For Requesting Relief:
The only safety related function of this valve is to close, This can only be ver1 fled during the 10CFR50 Appendix J, Type C leakage test.
IV.
Alternate Examination:
This valve is sub]ect to 10CFR50 Appendix J type C leak rate testing during each refueling outage.
V.
Implementation Scnedule:
The alternate examination program require-ments are currently being met.
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l Faga 256
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Ficnicia INSERVICE INSPECTION RELIEF REQUEST #
V-160
- 4 Fh0iN4Dr PUMP AND VALVE PROGRAM Rev. 1 c o"c annon CRYSTAL RIVER UNIT 3 Page 1 of 1 l
Deference Code:
ASME Boiler and Pressure Vessel Code, l
Section XI, 1983 edition through j
j summer 1983 addenda, I.
Component For which Exemption / Relief Is Requested:
a)
Name and identification number (component tag): CFV-1T and CFV-20, valves.
core flood tank nitrogen supply line isolation check Provide isolation for penetrations 123 and 124 (Inside b) Function:
containment).
c)
ASME Section III Code Class:
2.
d) Valve Category:
A/C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3522(b): Partial stroke valve exercise during normal plant operation and full valve exercise during cold shutdown.
III.
Basis For Requesting Relief:
The core flood tanks have a static inventory of borated water with 500 psi pressure applied through a regulated nitrogen gas system.
The normal position of these valves and the position to fulfill their function is closed.
Stroke testing would not provide assurance that these valves would perform their intended function.
Therefore, stroke testing is unnecessary.
IV.
Alternate Examination:
This valve is sub3ect to 10CFR50 Appendix J Type C leak rate testing during each refueling which will verify proper valve closure.
V.
Implementation Schedule:
The alternate examination program require-ments are currently being met.
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I rage 2561
i F3CgjC(3 INSERVICE INSPECTION RELIEF REQUEST #
pg3,yg,r PUMP AND VALVE PROGRAM V-170 5c"c"'*a CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief is Requested:
al Name and identification number (component tag):
CFV-18 and CFV-19 core flood tank borated water supply line isolation check valves.
b)
Function:
Provide isolation for penetrations 350 and 372 (inside containment).
j l
c)
ASME Section III Code Class:
2.
l l
d) Valve Category:
A/C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3522(b); Partial stroke valve exercise during normal plant operation and full valve exercise during cold shutdown.
g III.
Basis For Requesting Relief:
The core flood tanks have a static inventory of borated water.
The major loss of inventory results from sampling for chemical assay.
Makeup of borated water is not periodic and is not sufficient to full stroke open these valves.
The normal position of these valves and the position required to fulfill their intended function is closed.
Stroke testing would not provide assurance that these valves would perform their intended function.
Therefore, stroke testing is unnecessary.
IV.
Alternate Examination.:
This valve is subject to 10CFR50 Appendix J Type C leak rate testing during each refueling outage.
V.
Implementation Schedule:
The alternate examination program require-ments are currently being met.
I Page 257 l
S,%f FlcMicLa INSERVICE INSPECTION RELIEF REQUEST #
I PUMP AND VALVE PROGRAM V-181 CRYSTAL RIVER UNIT 3 Rev. 1 c o"oa anoa Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a)
Name and identification number (component tag):
FSV-261 and 262; Fire service supply checks to Reactor Building, b)
Function:
Containment isolation valves for fire service system to the Reactor Building.
c)
ASME Section III Code Class:
2.
di Valve Category:
A/C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521; Quarterly valve exercise requirement.
IWV-3522(b); Partial stroke valve exercise during normal plant operation and full valve exercise during cold shutdown.
III.
Basis For Requesting Relief:
These valves are not used in Modes 1 thru 4 and are classified as passive valves.
IV.
Alternate Examination:
These valves shall be leak rate tested per 10CFR50 Appendix J during refueling.
V.
Implementation Schedule:
The alternate examination program require-ments are currently being met.
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,FlCMiC(8 INSERVICE INSPECTION RELIEF REQUEST #
- PN)vvier PUMP AND VALVE PROGRAM V-190 CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code: ASME Boiler and Pressure Vessel Code.
Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief 1s Requested:
a) Name and identification number (component tag): Makeup system to RCS check valves (MUV-36, 37, 42 and 43 and 160, 161, 163 and 164).
b)
Function:
To prevent backflow from RCS into the makeup system.
c)
ASME Section III Code Class:
1.
d) Valve Category:
C.
Reference Code Requirement That Has Been Determined To Be Impractical.
II.
Full stroke valve exercise for all valves listed in I-a (above) during cold shutdown.
III.
Basis For Requesting Relief: With the exception of MUV-43 and 161, these valves cannot be partial stroked during normal plant operation, and all eight valves cannot be fully stroked during cold shutdown due to the possibility of causing a low temperature over-pressurization transient.
IV.
Alternate Examination:
These valves will be full flow tested during refueling outages.
V.
Implementation Schedule:
The alternate examination program require-ments will be met beginning with Refuel VII.
Page 260
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lRk}rida INSERVICE INSPECTION RELIEF REQUEST #
I
[y)gygmy PUMP AND VALVE PROGRAM V-195 CRYSTAL RIVER UNIT 3 Rev. O Page 1 of 1 Reference Code:
ASME Boiler and Pressure Yessel Code,Section XI, 1983 edition through summer 1983 addenda.
]
1.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
FWV-45 & FWV-46; steam generator feedwater header check valves, j
b)
Function:
These check valves provide protection to the feedwater system by providing backflow and pressure protection and act as containment isolation valves, c) ASME Section III Code Class:
2.
d) Valve Category:
C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521; Quarterly exercising requirements.
III.
Basis For Requesting Relief:
These valves must be tested by cessation or reversal of flow through the Main Feedwater System.
This test cannot be done during normal plant operation as it would require flow of emergency feedwater to the OTSG.
This would cause a severe transient in the Main Steam and Feedwater control system sub]ecting the
{
plant to an unsafe condition.
IV.
Alternate Examination:
In discussions with the NRC, it was determined that valves FWV-45 and FWV-46 need not be designated as one of the two valves required for separation between the high and low pressure sections of the feedwater system.
FPC has designated that FWV-22 and FWV-23 can be tested to satisfy the requirement to test separation of these high and low pressure sections.
FWV-22 and FWV-23 will be tested j
in accordance with ASME XI, IWV-3413 for timestroke, and IWV-3522 for I
reverse flow, at each cold shutdown.
V.
Implementation Schedule:
The alternate examination program require-
)
ments will be met during the next cold shutdown.
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i Page 264a 1
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/N.-...E A Florida INSERVICE INSPECTION RELIEF REQUEST #
Q),.7fff g y g '
PUMP AND VALVE PROGRAM V-200 7
CRYSTAL RIVER UNIT 3 Rev. 1 g
sT.
a -
Page 1 of 2 i
Reference Code:
ASHE Boiler and Pressure Vessel Code, i
Section XI, 1983 edition through I
summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
I a)
Name and identification number (component tag):
Borated Water j
Storage Tank to Hakeup Pumps Suction Header Check Valves (HUV-60 and MUV-T2).
l b)
Function:
To prevent backflow to the BWST after it is drained and HPI/LPI is in the " piggyback" mode.
I I
i c)
ASHE Section III Code Class:
2.
I d)
Valve Category:
C.
l II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3522(b); Partial stroke valve exercise during I
normal plant operation and full valve exercise during cold shutdown.
l III.
Basis For Requesting Relief:
These two valves are normally closed l
l check valves that cannot be stroked during power operation because l
this could upset the reactor coolant system boron concentration and result in a plant shutdown.
During refueling they can be full-stroke exercised.
The design basis does not call out the values needed for for testing under IWV-3522(b) no flow / mechanical exercising.
No pre-service values were recorded for these valves and identical spares are not available.
Because of this, it is not possible to comply with IWV-3522(b) mechanical exercise procedure for the lift force required to I
move the disk.
IV.
Alternate Examination:
Each refueling outage, at least one different I
i valve from each group, where a group is a set of valves with the same I
design and service conditions, shall be disassembled and inspected as I
described below until ine entire group has been tested.
If the valve is degraded to the extent that the valve cannot perform its function, I
then all other valves in that group shall be inspected as described L
j below.
The subsequent inspections may start again with single valves.
The inspection shall assure that the valve disk has freedom of movement l
and is capable of a full stroke.
Additionally, the general condition
]
of the valve internals shall be checked for structural degradation including the presence of any loose parts, debris and abnormal or excessive corrosion products, wear and erosion.
Page 265 u--__________-.---_-.____-.
i 8Nhh Florida INSERVICE INSPECTION RELIEF REQUEST #
T PUMP AND VALVE PROGRAM V-200
!.T78/POVier CRYSTAL RIVER UNIT 3 Rev. 1 hpg ' "
Page 2 of 2 V.
Implementation Schedule:
The alternate examination program require-ments will be met during the next refueling outage.
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Page 265a l
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F1cuichsi INSERVICE INSPECTION l
RELIEF REQUEST #
! PN)vvter PUMP AND VALVE PROGRAM V-210 t o "*"oa CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
1.
Component For Which Exemption / Relief Is Requested:
l j
a)
Name and identification number (component tag):
All power-operated valves with stroke times less than two seconds.
1 b)
Function:
Various.
I c)
ASME Section III Code Class:
2, 3.
I d) Valve Category:
A.
B.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3417(a) rer.uires that valves that increase in I
stroke time 50% or more from a previous test (previous test less than 10 seconds) shall be tested monthly.
I I
I III.
Basis For Requesting Relief:
" Fast acting" valves (those valves which stroke in less than two seconds) are not trended to accurately l
Indicate an increase in stroke time of 50% from a previous test.
l l
Many cf these valves "instantly" stroke and a 502 increase in stroke time is insignificant.
IV.
Alternate Examination:
" Fast acting" valves will have an
- Action
- l limit of two seconds stroke time.
The action required will be to l
investigate for any n9cessary corrective action, and to test monthly l
until the problem is resolved.
V.
Implementation Schedule:
The alternate examination program require-J ments are currently being met.
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Page 266 i
(
Ficniche IscERv!CE In$rECTIDw REtIEr REQUEST i'
h Mr PUM) AND VALVE PROGRAM V-283 CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code:
ASME Boilpr and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief Is Requested:
a) Name and identification number (component tag):
SFV-86, Spent Fuel coolant filter r.$eck valve to DH pump suction.
b)
Function:
Dpens for recirculation of the spent fuel pools by the decay heat system, c) ASME Section !!! Code Class:
2.
d) Valve Category:
(,
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3521-Quarterly valve stroke exercise.
III.
Basis For Requesting Relief:
This is a normally closed check valve to the decay heat pump suculon.
The valve performs no safety function;
- RECIRC* by the DHP's only adds flexibility to the spent fuel system.
Gate valves upstream anc downstream, SFV-85. DHV-39 40 & 41, provide the boundary isolation.
IV.
Alternate Examination:
3ection XI testing of this valve does not add to the safety of this plant.
SFV-SS, DHV-39, 40 & 41 shall be full stroked quarterly.
V.
Implementation Schedule:
The alternate examination program require-ments are currently being met.
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Page 281
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..s..
INSERVICE INSPECTION RELIEF REQUEST #
l{'$
g rl PUMP AND VALVE PROGRAM V-320 unoan o=
CRYSTAL RIVER UNIT 3 Rev. 1 j
Page 1 of 1 1
Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief is Requested:
a) Name and identification number (component tag):
All valves j
2dentified as not practical to be tested during normal plant operation, but are tested during a cold shutdown, b)
Function:
Valve exercising.
c)
ASME Section III Code Class:
1, 2 and 3.
d)
Valve Category:
A, B.
II.
Reference Code Requirement That Has Been Determined To Be l
Impractical:
IWV-3412(a); Valve exercising during every cold l
shutdown that occurs greater than 3 months apart.
IWV-3415: Fail-I safe valve exercising during every cold shutdown that occurs greater than 3 months apart.
IWV-3522; Check valve exercising during I
every cold shutdown that occurs greater than 9 months apart.
I l
III.
Basis For Requesting Relief:
Scheduling difficulties preclude commencing valve testing immediately upon achieving cold shutdown.
Within approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, valve testing will be scheduled and initiated in accordance with good management practices.
IV.
Alternate Examination:
If a cold shutdown extends, or as planned to last beyond 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then the valves in the Pump and Valve Program l
scheduled to be tested during cold shutdowns will be tested.
- However, cold shutuown will not be extended solely because of cold shutdown valve testing.
Those valves not tested will be tested during the next applicable cold shutdown, providing the individual system conditions permit.
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Implementation Schedule:
The alternate examination program require-l ments are currently being met.
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Page 291
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\\
/e' ElCHiCh3 INSERVICE INSPECTION RELIEF REQUEST s E%3yyggf PUMP AND VALVE PROGRAM V-330 CRYSTAL RIVER UNIT 3 Rev. 1 5 ' "* " ' '
- a Page 1 of 1 Reference Code:
ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
1.
Component For Which Exemption / Relief Is Requested:
a)
Name and identification number (component tag):
All valves tested when the unit is in a cold shutdown.
b)
Function:
Various.
c)
ASME Section III Code Class:
1, 2 and 3.
d) Valve Category:
A, B, C.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-341T(b)/IWV-3523; When corrective action is required as a result of tests made during cold shutdown, the condi-tion shall be corrected before startup.
III.
Basis For Requesting Relief:
The Standard Technical Specifications for Crystal River Unit 3 refer to valves either directly, by tag number, or indirectly, by ES Systems operability.
The Technical Speci ications also identify Limiting Conditions for Operation for f
these valves.
The statement in IWV-3412(b)/IWV-3523 listed in Part II of this relief request, to some extent, is redundant with the Technical Specifications.
However, this statement is all inclusive of valves in the Inservice Testing Program, of which some either:
(1) are in systems that are not involved with the safe startup or operation of the Reactor; or (2) supply redundant backup components in systems that are involved with the safe startup and operation of the Reactor.
IV.
Alternate Examination:
Operability status and mode change restrictions to be determined by the Standard Technical Specifications for Crystal River Unit 3.
If a valve is identified as required to be tested for ASME Section XI, but not identified by the Tech Specs, then corrective action shall continue without restricting Unit Startup.
V.
Implementation Schedule:
This alternate examination has already been implemented.
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Page 292 i
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ff.
Ficnicia INSERVICE INSPECTION RELIEF REQUEST #
Mr PUMP AND VALVE PROGRAM V-360 CRYSTAL RIVER UNIT 3 Rev. 1 Page 1 of 1 Reference Code:
ASHE Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.
I.
Component For Which Exemption / Relief is Requested:
al Name and identification number (component tag):
ASV-195, ASV-196, CAV-2, CAV-431 CHV-90 CHV-97, CHV-101, CHV-108. EFV-55, EFV-56, EFV-57, EFV-58.
b) Function:
Valve exercising, c)
ASME Section III Code Class:
Class 2:
CAV-2, CAV-431 EFV-55, EFV-56 EFV-57, EFV-5b.
Class 3:
ASV-195, ASV-196, CHV-90, CHV-97, CHV-101, CHV-108.
d) Valve Category:
Category A:
CAV-2, CAV-431.
Category B:
ASV-195 ASV-196, CHV-90, CHV-97, CHV-101, CHV-108, EFV-55 EFV-56, EFV-57, EFV-58.
II.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3300; Local visual observation of valve position indication for verification of full stroke, III.
Basis For Requesting Relief:
These valves have been manufactured by Target Rock Corporation, The design and assembly of these valves are such that there is no means for visual verification.
IV.
Alternate Examination:
As any of these valves have maintenance performed on them, either repair or preventive, the position switches are checked.
The verification that the valve does indeed perform a full stroke is documented in the Work Request system.
V.
Implementation Schedule:
The alternate examination program requirements are currently being met.
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L Page 295 j
/
@ridg INSERVICE INSPECTION RELIEF REQUEST #
PUMP AND VALVE PROGRAM V-370 8'l)
((1(yj7 gar:
CRYSTAL RIVER UNIT 3 Rev. 0 1 ),
4 Page 1 of 1 l
l Reference Code:
ASHE Boiler and Pressure Vessel Code,Section XI, 1983 edition through j
summer 1983 addanda.
I.
Component For Which Exemption / Relief 1s Requested:
a)
Name and identification number (component tagl:
CHP 1A, 1B Chill Water Pumps.
I b)
Function:
To provide coolir.p water flow to chillers which provide cooling medium for the control complex, including the ES Switchgear Room.
l c)
ASME Section III Code Class:
3.
l d)
Valve Category: N/A 11.
Reference Code Requirement That Has Been Determined To Be Impractical:
IWV-3100 Inservice Test Procedure, Quarterly Pump Testing; measurement of quantities in table IWP-3100-1.
III. Basis For Requesting Relief:
These pumps were not designed with capa-bility for ASME XI testing in a constant flow situation.
System design offers many parallel flow paths, and thus prevents a repeatable set of pump conditions.
The flow conditions in this system are largely set by prevailing ambient temperatures.
Since repeatable conditions can not be set without risking equipment damage, these pumps can not be tested in accordance with Section XI requirements.
IV.
Alternate Examination:
Every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a funct!,onal check will be performed of this system using operating procedures.
This shall also include verification that the system is maintaining Control Room temperature per Technical Specification 4.7.7.1.a.
V.
Implementation Schedule:
Alternate examination program requirements are currently being met.
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Page 296
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