ML17228A240

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Second Ten Yr Inservice Insp Interval Inservice Testing Program.
ML17228A240
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 07/21/1993
From:
FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17228A243 List:
References
NUDOCS 9308100130
Download: ML17228A240 (211)


Text

St. Lucie Unit 2 Docket No. 50-389 Second Ten-Year Xn-Service Inspection Interval Xn-Serv ce-Testin Pro ram Revision 0 ENCLOSURE 3 SECOND TEN YEAR IN-SERVXCE INSPECTION XNTERVAL IN-SERVICE TESTING PROGRAM 0

9308100130 930803 PDR ADOCK 05000389 PDR 8

t FLORIDA POWER and LIGHT COMPANY NUCLEAR ENERGY SERVICES 700 Universe Boulevard Juno .Beach, Florida 33408 SECOND TEN-YEAR'INSERVICE INSPECTION INTERVAL INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES ST. LUCIE NUCLEAR POWER PL'ANT UNXT NO. 2 DATE OF COMMERCXAL OPERAT ON I AUGUST 8 g 1983 FLORIDA POWER '& LIGHT P.O. BOX 128 FT PIERCEg FL 34 954 NRC DOCKET NUMBER: 50-389 DOCUMENT NUMBER: JNS-PSL-204-2 REVISXON 0 ST. LUCIE PLANT REVIEWS AND APPROVALS:

PREPARED BY: DATE:

PLA T T ENG R APPROVED BY:

P L TEST 8( CODE SUPERVISOR DATE')

Revision 0 07/16/93 Table of Contents Pacae Table of Contents Record of Revisions 1.0 Introduction 2.0 Applicable Documents 3.0 Inservice Testing Program For Pumps

3. 1 Code Compliance 3.2 Allowable Ranges of Test Quantities 3' Testing Intervals 3.4 Pump Program Table 3.5 Relief Requests for Pump Testing 4.0 Inservice Testing Program For Valves 4.1 Code Compliance 4.2 Testing Intervals 4.3 Stroke Time Acceptance Criteria 4.4 Check Valve Testing 4.5 Valve Program Table 4.6 Relief Requests For Valve Testing 4.7 Cold Shutdown Testing A endices A Pump Program Tables B Pump Program Requests For Relief C Valve Program Tables D Valve Program Requests For Relief E Cold Shutdown Justifications

N Revision 0 07/16/93 RECORD OF REVISIONS REVISION DESCRIPTION OF REVISION DATE NUMBER REASON FOR THE CHANGE REVISED APPROVALS 0 Second 10-year submittal 07/16/93

Revision 0 07/16/93 INSERVICE TESTING (IST) PROGRAM PLAN ST. LUCIE UNIT 2

1.0 INTRODUCTION

Revision 0 of the St. Lucie Unit 2 Second 10-Year Interval ASME Inservice Inspection (IST) Program will be in effect through the end of the second 120-month (10-year) interval unless revised and reissued for reasons other than the routine update required at the start of the third interval per 10 CFR 50.55a(g). The second inspection interval is defined as follows:

Beceins Ends August 8, 1993 August 8, 2003 This document outlines the IST Program for St. Lucie Plant, Unit 2, based on the requirements of Section XI of the ASME Boiler and Pressure Vessel Code, 1986 Edition (the Code).

References in this document to "IWP" or "IWV" correspond to Subsections IWP and IWV, respectively, of the ASME Section XI, 1986 Edition, unless otherwise noted.

The inservice testing identified in this Plan are to be performed specifically to verify the operational readiness of pumps and valves which have a specific function in mitigating the consequences of an accident or in bringing the rea'ctor to a safe shutdown.

Revision 0 07/16/93 2.0 APPLICABLE DOCUMENTS This Program Plan was developed per the requirements and guidance provided by the following documents:

2.1 Title 10, Code of Federal Regulations, Part 50 2.2 NRC Regulatory Guides Division 1 2.3 Standard Review Plan 3 '.6, "Inservice Testing of Pumps and Valves 2.4 Final Safety Analysis Report, St. Lucie Unit 2 2' St. Lucie Plant Unit 2 Technical Specifications 2.6 ASME Boiler and Pressure Vessel Code,Section XI, 1986 Edition 2.7 NRC Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs" 2.8 Minutes of the Public Meetings on Generic Letter 89-04 2.9 St. Lucie Unit 1 Interim Relief From the Inservice Testing Program for Pumps and Valves (TAC No. 74794) 2.10 Supplement to Minutes of the Public Meetings on Generic Letter 89-04 by J. G. Partlow, 26 September 1991 2.11 Request for Industry/NRC-Accepted Interpretation on "Practical" as Applied by ASME Code Section XI, IWV-3412(a) by Martin J. Virgilio, Assistant Director for Regions IV and V.

2.12 St. Lucie Unit 2 Inservice Testing (IST) Program Relief Request, 5 December 1991

Revision 0 07/16/93 3.0 INSERVICE TESTING PROGRAM FOR PUMPS

3. 1 Code Compliance This IST Program for pumps meets the requirements of Subsection IWP of the Code and any interpretations or additional requirements imposed by Generic Letter 89-
04. Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii) and Generic Letter 89-04 Allowable Ranges of Test Quantities '.2 The allowable ranges for test parameters as specified in Table IWP-3100-2 will be used for all measurements of pressure, flow, and vibration except as provided for in specific relief requests'n some cases the performance of a pump may be adequate to fulfill its safety function even though there may be a value of an operating parameter that falls outside the allowable ranges as set forth in Table IWP-3100-2. Should such a situation arise, an expanded allowable may be determined, on a case-by-case basis, in accordance with IWP-3210 and ASME Code Interpretation XI-1-79-19.

3.3 Testing Intervals The test frequency for pumps included in the Program will be as set forth in IWP-3400 and related relief requests. A band of +25 percent of the test interval may be applied to a test schedule as allowed by the St.

Lucie Unit 2 Technical Specifications to provide for operational flexibility.

Revision 0 07/16/93 3.4 Pump Program Table Appendix A lists those pumps included in the IST Program with references to parameters to be measured and applicable requests for relief.

3.5 Relief Requests for Pump Testing Appendix B includes all relief requests related to pump testing. For convenience, the sequential numbers of the relief requests are carried-over from the previous submittal for the first inspection interval.

Revision 0 07/16/93 4.0 INSERVICE TESTING PROGRAM FOR VALVES F 1 Code Compliance This IST Program for valves meets the requirements of Subsection IWV of the Code and any interpretations oz additional requirements imposed by Generic Letter 89-

04. Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii) and Generic Letter 89-04.

4.2 Testing Intervals The test frequency for valves included in the Program will be as set forth in IWP-3400 and related relief requests. A band of +25 percent of the test interval may be applied to a test schedule as allowed by the St.

Lucie Unit 2 Technical Specifications to provide for operational flexibility. Where quarterly testing of valves is impractical or otherwise undesirable, testing may be performed during cold shutdown periods as permitted by IWV-3412(a). Justifications for this deferred testing are provided in Appendix E.

4.3 Stroke Time Acceptance Criteria When required, the acceptance criteria for the stroke times of power-operated valves will be as set forth in Generic Letter 89-04.

4.4 Check Valve Testing Full-stroke exercising of check valves to the open position using system flow requires that a test be performed whereby the predicted full accident condition flow rate through the valve be verified and measured.

Alternatively, non-intrusive inspection techniques may be used to verify full stroke with less than full "accident" flow rate.

0 Revision 0 07/16/93 4.5 Valve Program Table Appendix C lists those valves included in the IST Program with references to required testing, respective test intervals, and applicable requests for relief.

4.6 Relief Requests for Valve Testing Appendix D includes all relief requests related to valve testing. For convenience, the sequential numbers of the relief requests are carried-over from the previous submittal for the first inspection interval.

4.7 Cold-Shutdown Testing Where it is determined to be impractical to exercise valves during normal plant operation and exercising can be performed under cold shutdown conditions, the valve program table is so noted and justification for test deferment is provided in Appendix E.

Revision 0 07/16/93 Appendix A Pump Program Tables

FLORIDA POWER AND LIGHT CCMPAHY REVISION:

PUHP TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 1 INLET DIFF. FLOW BEARING PUHP NUMBER DESCRIPTION CL COORD SPEED PRES. PRES. RATE VIBRA. TENT REMARKS AFW 2A AUXILIARY FEEDWATER PUMP 3 N-13 NA Y Y Y:PR-4 Y H:PR-1 AFW 28 AUXILIARY FEEDWATER PUMP 3 M-13 NA Y Y Y:PR-4 H:PR-1 AFW 2C AUXILIARY FEEDWATER PUMP 3 K-13 Y Y Y Y:PR-4 N:PR-1 BAH 2A BORIC ACID HAKEUP PUMP 2 8-5 NA Y:PR-8 Y Y:PR-5 N:PR-1 BAM 28 BORIC ACID MAKEUP PUMP 2 C-5 NA Y:PR-8 Y Y:PR-5 H:PR-1 CCW 2A COMPONENT COOLING WATER PUHP 3 F-16 NA Y Y H:PR-1 CC'LI 28 COMPONENT COOLING WATER PLIMP 3 F-17 NA Y Y N:PR-1 CCW 2C COMPONENT COOLING 'LIATER PUHP 3 F-16 NA Y Y N:PR-1 CHG 2A CHARGING PUMP 2 C-3 NA Y Y Y Y:PR-12 N:PR-1 CHG 28 CHARGING PUMP 2 E.3 NA Y Y Y Y:PR-12 N:PR-1 CHG 2C CHARGING PUMP 2 G-3 NA Y Y Y Y:PR-12 N:PR-1 CS 2A CONTAINMENT SPRAY PUMP 2'-4 NA Y:PR-15 Y Y:PR-6 N:PR-1 CS 28 CONTAINHENT SPRAY PUMP 2 H-4 NA Y:PR-15 Y Y:PR-6 N:PR-1 HPSI 2A HI PRESS SAFETY IHJECTION PUMP 2 D-6 NA Y:PR-15, Y Y:PR-9 H:PR-1 MPSI 28 HI PRESS SAFETY INJECTION PUMP 2 8-6 NA Y:PR-15 Y Y:PR-9 N:PR-1 MYD 2A HYDRAZINE PUHPS 2 C-11 Y H:PR-17N:PR-17 Y:PR-17 Y:PR-14 N:PR-1 MYD 28 HYDRAZIHE PUMPS 2 D-11 Y H:PR-17N:PR-17 Y:PR-17 Y:PR-14 N:PR-1 ICW 2A INTAKE COOLIHG 'LIATER PUMP 3 M-4 NA Y:PR-11 Y Y Y:PR-13 H:PR-1 ICW 28 INTAKE COOLIHG WATER PUMP 3 M-7 NA Y:PR-11 Y Y Y:PR-13 H:PR-1 ICW 2C INTAKE COOLING WATER PUMP 3 M-5 NA Y:PR-11 Y Y Y:PR-'13 N:PR-1 LPSI 2A LO PRESS SAFETY INJECTION PUMP 2 E-6 NA Y:PR-15 Y Y:PR-10 Y:PR-10 N:PR-1 LPSI 28 LO PRESS SAFETY INJECTION PUMP 2 D-6 NA Y:PR-15 Y Y:PR-10 Y:PR-10 N:PR-1

Revision 0 07/16/93 Florida Power & Light Company INSERVICE TESTING PUMP TABLES St. Lucie Nuclear Plant Unit 2 PAGE  : 2 LEGEND PUMP NUMBER Numerical designator indicated on the respective flow diagram.

DESCRIPTION Generic name/function of the pump.

CL ISI Classification per the associated ISI boundary drawing(s)

COORD Corresponds to the flow diagram coordinates of the pump.

Test Parameters The table indicates by a "Y" (yes) or "N" (no) that the specific parameter is measured, evaluated, and recorded per the applicable Code requirement. If a "N" is indicated, the associated relief request number is also noted in the same column.

PR-XX Where indicated this refers to the specific relief request (See Appendix B) related to any deviation regarding the measurement or analysis of a parameter.

Revision 0 07/16/93 Appendix B Pump Program Relief Requests

Revision 0 07/16/93 y>>

RELIEF REQUEST NO. PR-1 COMPONENTS'll pumps in the Program SECTION XI REQUIREMENT'he temperature of all centrifugal pump bearings outside the main flow path and of the main shaft bearings of reciprocating pumps shall be measured at points selected to be responsive to changes in the temperatuze of the bearings.

(IWP-3300, 4310)

BASIS FOR RELIEF:

The data associated with bearing temperatures taken at one-year intervals provides little statistical basis for determining the incremental degradation of a bearing or any meaningful trending information or correlation.

In many cases the pump bearings are water-cooled and thus, bearing temperature is a function of the temperature of the cooling medium, which can vary considerably.

Vibration measurements are a significantly more reliable indication of pump bearing degradation than are temperature measurements. All pumps in the program are subjected to vibration measurements in accordance with IWP-4500.

Although excessive bearing temperature is an indication of an imminent or existing bearing failure, it is highly unlikely that such a condition would go unnoticed during routine surveillance testing since it would manifest itself in other obvious indications such as audible noise, unusual vibration, increased motor current, etc.

Any potential gain from taking bearing measurements, which in most cases would be done locally using portable instrumentation, cannot offset the cost in terms of dilution of operator effort, distraction of operators from other primary duties, excessive operating periods for standby pumps especially under minimum flow conditions, and unnecessary personnel radiation exposure.

B-1

Revision 0 07/16/93 RELIEF REQUEST NO. PR-1 (cont.)

BASIS FOR RELIEF (cont.):

Based on the reasons similar to those set forth above, the ASME deleted the requirement for bearing temperature measurements in ASME OM Code, Subsection ISTB, the revised version of the Code for pump testing.

ALTERNATE TESTING:

None.

B-2

Revision 0 07/16/93 RELIEF REQUEST NO. PR-2 COMPONENTS:

Various SECTION XI REQUIREMENT:

The full-scale range of each instrument shall be three times the reference value or less. (IWP-4120)

BASIS FOR RELIEF:

Table IWP-4110-1 requires the accuracy of instruments used to measure speed to be equal to or better than +2 percent based on the full scale reading of the instrument. This means that the accuracy of the measurement can vary as much

+6 percent, assuming the range of the instrument extended to the allowed maximum.

This IST pump parameter is often measured with portable test instruments where commercially available instruments do not necessarily conform to the Code requirements for range. In this case, high quality calibrated instruments will be used where the "reading" accuracy is at least equal to the Code-requirement for full-scale accuracy. This will ensure that the measurements are always more accurate than the accuracy as determined by combining the requirements of Table IWP-4110-1 and Paragraph IWP-4120.

ALTERNATE TESTING:

Whenever portable instruments are used for measuring pump speed, the instrument(s) will be such that the "reading" accuracy is as follows at least +2 percent.

B-3

Revision 0 07/16/93 RELIEF REQUEST NO. PR-3 WITHDRAWN (Rev 0, 07/16/93)

B-4

Revision 0 07/16/93 RELIEF REQUEST NO. PR-4 COMPONENTS:

Auxiliary Feedwater (AFW) Pumps 2A thru 2C (2998-G-080, Sh 2)

SECTION XI REQUIREMENT'ach inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1.

(IWP-3300)

Pump flow rate shall be measured during the test. (Table IWP-3100-1)

BASIS FOR RELIEF:

There are only two practical flow paths available for performing inservice testing of the AFW Pumps. These include the primary flow path into the main feed supply lines and thence to the steam generator, and the minimum-flow recirculation (mini-recirc and bypass test loop) which returns to the condensate storage tank. The former is provided with flow rate measuring instrumentation however the mini-recirc line is a fixed resistance circuit with no, flow instrumentation.

Pumping from the auxiliary feedwater system into the steam generators during plant hot operation is impractical and undesirable for the following reasons:

During auxiliary feedwater injection via the main feedwater lines while the plant is operating at power, a large temperature differential (approximately 375 deg-F) could exist that would result in significant thermal shock and fatigue cycling of the feedwater piping and steam generator nozzles.

  • Based on the expected duration of the testing and the flow rate of the pumps (150 to 200 gpm),

that the cooldown of the steam generator would induce it is expected cooldown and contraction of the reactor coolant system resulting in undesirable reactivity variations and power fluctuations.

B-5

Revision 0 07/16/93 RELIEF REQUEST NO. PR-4 (cont.)

ALTERNATE TESTING'uring quarterly testing of the AFW pumps while the pumps are operating through the fixed-resistance mini-recirc line, pump differential pressure and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

During testing performed at cold shutdown, pump differential pressure, flow rate, and vibration will be measured and evaluated per IWP-3100 and IWP-3200. Testing during cold shutdowns will be on a frequency determined by intervals between shutdowns as follows:

For intervals of 3 months or longer each shutdown.

For intervals of less than 3 months testing is not required unless 3 months have passed since the last shutdown test.

This alternate testing agrees with the requirements of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

B-6

Revision 0 07/16/93 RELIEF REQUEST NO. PR-5 COMPONENTS:

Boric Acid Makeup (BAM) Pumps 2A and 2B (2998-G-078, Sh 121)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1.

(IWP-3300)

Pump flow rate shall be measured during the test. (Table IWP-3100-1)

BASIS FOR RELIEF:

There are three practical flow paths available for performing inservice testing of the BAM Pumps. These include the primary flow path into the charging pump suction header, a recirculation line leading back to the refueling water tank, and the minimum-flow recirculation (mini-recirc and bypass test loop) which returns to the BAM Tanks. None of these flow paths is totally satisfactory for the following reasons:

Operating the BAM Pumps discharging into the charging pump suction header requires the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps.

This, in turn, would result in the addition of excess boron to the RCS. This rapid insertion of negative reactivity would result in a rapid RCS cooldown and depressurization. A large enough boron addition would result in an unscheduled plant trip and a possible initiation of Safety Injection Systems.

During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-boration of the RCS. The waste management system would be overburdened by the large amounts of RCS coolant that would require processing to decrease its boron concentration.

B-7

Revision 0 07/16/93 RELIEF REQUEST NO. PR-5 (cont.)

The second circuit recirculates water to the Refueling Water Tank (RWT) or the Volume Control Tank (VCT) .

During normal plant operation at power undesirable to pump it is to the RWT and deplete the BAM Tank inventory. One of the two BAM Tanks is maintained at Tech. Spec. level while the other is used as required for plant operation. The Tech'pec. BAM Tank cannot be pumped from because it must be maintained at a level near the top of the tank. The other BAM Tank's level will vary from test to test by as much as 15 to 20 feet. This variance in pump suction pressure will have a direct affect on pump head and flow such that test repeatability would be questionable.

The minimum-flow recirculation flow path is a fixed resistance circuit. No flow rate measuring instrumentation is installed in this line. Pumping boric acid from tank to tank would be possible but the flow rates would be small, limiting pump operation to the high head section of the pump curve. In addition, one of the two BAM Tanks is maintained at Tech. Spec.

level while the other is used as required for normal plant operation. The Tech. Spec. BAM Tank cannot be pumped from because it must be maintained at a level near the top of the tank. This narrow band limits the amount that can be pumped to it or from it to only a few hundred gallons. The other BAM Tank's level will vary from test to test by as much as 15 to 20 feet.

This variance in pump suction pressure will have a direct affect on pump head and flow such that test repeatability would be questionable.

B-8

Revision 0 07/16/93 RELIEF REQUEST NO. PR-5 (cont.)

ALTERNATE TESTING:

During quarterly testing of the BAM pumps, while the pumps are operating through the fixed-resistance mini-recirc line, pump differential pressure and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

During testing performed at each reactor refueling outage, pump differential pressure, flow rate, and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

This alternate testing agrees with the requirements of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

B-9

Revision 0 07/16/93 RELIEF REQUEST NO. PR-6 COMPONENTS:

Containment Spray (CS) Pumps 2A and 2B (2998-G-088)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1.

(IWP-3300)

Pump flow rate shall be measured during the test. (Table IWP-3100-1)

BASIS FOR RELIEF:

There are two practical flow paths available for performing inservice testing of the CS Pumps. These include one that pumps borated water from the RWT to the RCS via the low-pressure injection header and the other, minimum-flow recirculation (mini-recirc and bypass test loop) which returns to the RWT.

The first would require modifying the shutdown cooling lineup while in cold shutdown; however, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function. Thus, the only practical time for testing these pumps via this flow path is during refueling outages when water from the RWT is used to fill the refueling cavity.

The minimum-flow recirculation flow path is a fixed resistance circuit containing a flow limiting orifice however no flow rate measuring instrumentation is installed.

ALTERNATE TESTING:

The CS pumps are operated through the fixed-resistance mini-recirc line during the quarterly pump testing. Pump differential pressure and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

Revision 0 07/16/93 RELIEF REQUEST NO PR-6 (cont.)

ALTERNATE TESTING:(cont.)

During the pump testing performed each reactor refueling, pump differential pressure, flow rate, and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

This alternate testing agrees with the requirements of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

Revision 0 07/16/93 RELXEF REQUEST NO. PR-7 WITHDRAWN (Rev 0, 07/16/93)

B-12

Revision 0 07/16/93 RELIEF REQUEST NO. PR-8 COMPONENTS'oric Acid Makeup Pumps 2A and 2B (2998-G-078, Sh 121)

SECTION XI REQUIREMENTS:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1 except bearing temperatures, which shall be measured during at least one inservice test each year. (IWP-3300)

BASIS FOR RELIEF:

The system installation does not provide any mechanism for measuring pump suction pressures, and thus, the requirement for measuring suction pressure and pump differential pressures cannot be satisfied. A measure of pump suction pressure can, however, be determined by a calculation using the height of liquid in the boric acid makeup tanks. Since there is essentially fixed resistances between the tanks and the pumps this will provide a consistent value for suction pressures.

Since the tank levels are not expected to vary significantly during the tests, tank levels and associated calculations will only be taken once during each test instead of prior to pump operation and during operation as required by Table IWP-3100-1.

ALTERNATE TESTING:

The boric acid makeup pump suction pressures will be calculated based on the height of liquid in the associated tank once during each inservice test. Subsequently, these calculated values will be used to determine pump differential pressures for evaluation of pump parameters.

B-13

Revision 0 07/16/93 RELIEF REQUEST NO. PR-9 COMPONENTS:

High Pressure Safety Injection (HPSI) Pumps 2A and 2B (2998-G-078, Sh 130)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1.

(IWP-3300)

BASIS FOR RELIEF'uring quarterly testing of the HPSI Pumps, the pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) pressure. Flow is routed through a minimum flow test line leading to the refueling water tank (RWT). This line has no installed flow rate measuring instrumentation and measuring flow rate during quarterly testing is not practical.

During cold shutdown conditions, full flow operation of the HPSI pumps to the RCS is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.3.

NRC Generic Letter 89-04, Position 9, allows elimination of minimum flow test line flow rate measurements providing inservice tests are performed during cold shutdowns or refueling under full or substantial flow conditions where pump flow rate is recorded and evaluated.

ALTERNATE TESTING:

During quarterly testing of the HPSI Pumps, pump differential pressure and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

During testing performed at each reactor refueling, pump differential pressure, flow rate, and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

Revision 0 07/16/93 RELIEF REQUEST NO. PR-10 COMPONENTS'ow Pressure Safety Injection (LPSI) Pumps 2A and 2B (2998-G-078, Sh 131)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1.

(IWP-3300)

BASIS FOR RELIEF:

During quarterly testing of the LPSI pumps, the pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) prcssure'low is routed through a minimum flow test line leading to the refueling water tank (RWT). This line has no installed flow rate measuring instrumentation and measuring flow rate during quarterly testing is not practical.

During cold shutdown, the LPSI pumps are used for residual heat removal. The substantial flow tests can be performed at this time. Pump differential pressure and flow rate will be recorded. However, induced vibrations in the system piping while the reactor coolant pumps (RCPs) are running mask any meaningful LPSI pump vibration data.

ALTERNATE TESTING:

During quarterly testing of the LPSI Pumps, pump differential pressure and vibration will be measured and evaluated per IWP-3100 and IWP-3200.

Substantial flow testing will be performed during cold shutdowns. Pump differential pressure, flow rate, and vibration (if RCPs secured) will be measured and evaluated IWP-3200. Testing will be on a frequency per IWP-3100 and determined by intervals between shutdowns as follows:

For intervals of 3 months or longer each shutdown.

For intervals of less than 3 months testing is not required unless 3 months have passed since the last shutdown test.

B-15

Revision 0 07/16/93 RELIEF REQUEST NO. PR-11 COMPONENTS:

Intake Cooling Water Pumps 2A, 2B and 2C (2998-G-082)

SECTION XI REQUIREMENT'ach inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1.

(IWP-3300)

Pump inlet pressure shall be measured before starting a pump and during the test. (Table IWP-3100-1)

BASIS FOR RELIEF:

The pumps listed above are vertical line shaft pumps submerged in the intake structure with no practical means of measuring pump inlet pressure. The inlet pressure, however, can be determined by calculation using, as input, the measured height of water above the pump inlet as measured at the intake.

During each inservice test, the water level in the intake pit remains relatively constant, thus only one measurement of level and the associated suction pressure calculation need be performed.

ALTERNATE TESTING'uring testing of these pumps, one value of inlet pressure will be calculated based on water level at the intake structure.

B-16

Revision 0 07/16/93 RELIEF REQUEST NO. PR-12 COMPONENTS:

Reactor Coolant Charging Pumps 2A, 2B, and 2C SECTION XI REQUIREMENT:

The frequency response range of the readout system (for instrument used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed. (IWP-4520 (b) )

BASIS FOR RELIEF:

The reactor coolant charging pumps operate at approximately 210-215 rpm which equates to a rotational frequency of 3.5 Hz. In accordance with the ASME Code, the frequency response for the vibration instruments would have to be one half of this or 1.75 Hz. Following an investigation of available and potentially suitable instrumentation, it been determined that instruments satisfying this requirement has for the charging pumps are not commercially available.

ALTERNATE TESTING:

For an interim period of seven months (March 1994), during testing of these pumps, vibration will be measured as required by IWP-4510, except that the lower frequency response for the instruments will be 10 Hz. During this time efforts will be made to procure Code-acceptable instrumentation or justify the continued use of non-conforming instruments.

B-17

Revision 0 07/16/93 RELIEF REQUEST NO. PR-13 COMPONENTS'ntake Cooling Water Pumps 2A, 2B, and 2C SECTION XI REQUIREMENT:

The frequency response range of the readout system (for instrument used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed. (IWP-4520 (b) )

BASIS FOR RELIEF'he St. Lucie Plant completed a major upgrade to its ASME pump vibration program in August 1991 to better comply with the Code. As part of the upgrade, new vibration instruments were purchased. The instruments were chosen for their ease of use and reliability; however, the instrument's lower frequency response does not comply with the Code when used on the Intake Cooling Water pumps. The intake cooling water pumps operate at a shaft speed of approximately 885 rpm.

Based on this speed and the Code requirement, the instrumentation used to measure vibration (displacement) would require a response range down to 7.38 hz. The existing instruments are capable of a lower frequency response to 10 hz, 2.62 Hz higher than the Code.

ALTERNATE TESTING'or an interim period of seven months (March 1994), during testing of these pumps, vibration will be measured as required by IWP-4510, except that the lower frequency response for the instruments will be 10 Hz. During this time efforts will be made to procure Code-acceptable instrumentation or justify the continued use of non-conforming instruments.

B-18

Revision 0 07/16/93 RELIEF REQUEST NO. PR-14 COMPONENTS:

Hydrazine Pumps 2A and 2B SECT10N XI REQUIREMENT:

The frequency response range of the readout system (for instrument used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed. (IWP-4520(b))

BASIS FOR RELIEF:

The hydrazine pumps are characterized as metering pumps and operate at extremely slow speed (as low as 37 rpm). This equates to a rotational frequency of 0.62 Hz. In accordance with the ASME Code, the frequency response for the vibration instruments would have to be one half of this or 0.31 Hz.

Instruments satisfying this requirement for the hydrazine pumps are commercially unavailable.

Low frequency vibration of these pumps is considered to be relatively insignificant. Any binding or excessive bearing wear within these pumps would be discovered by audible noise or excessive vibration at the driver and reduction gearing.

ALTERNATE TESTING:

For an interim period of seven months (March 1994), during testing of these pumps, vibration will be measured as required by IWP-4510, except that the lower frequency response for the instruments will be 10 Hz. During this time efforts will be made to procure Code-acceptable instrumentation or justify the continued use of non-conforming instruments.

B-19

Revision 0 07/16/93 RELIEF REQUEST NO. PR-15 COMPONENTS:

Containment Spray Pumps 2A and 2B (2998-G-088)

Hi Press Safety Injects Pumps 2A and 2B (2998-G-078 SH 130)

Lo Press Safety Inject. Pumps 2A and 2B (2998-G-078 SH 130)

SECTION XI REQUIREMENTS:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1 except bearing temperatures, which shall be measured during at least one inservice test each year. (IWP-3300)

BASIS FOR RELIEF'he system installation does not provide any installed suction gages. A measure of pump suction pressure can, however, be determined by calculation using the height of liquid in the refueling water tank (RWT) During the ~

quarterly pump tests, the flow rate through the suction piping is very low, therefore, the amount of head loss is negligible. This is not the case during the substantial flow tests. The flow rates used during these tests would cause a noticeable head loss in the suction piping.

Since RWT level is not expected to vary significantly during the quarterly tests, RWT level and associated calculations will only be taken once during each quarterly test instead of prior to pump operation and during operation as required by Table IWP-3100-1.

ALTERNATE TESTING:

During the quarterly pump tests, the pumps'uction pressures will be calculated based on the height of liquid in the associated RWT. Subsequently, these calculated values will be used to determine pump differential pressures for evaluation of pump parameters.

During the cold shutdown or refueling substantial flow testing of these pumps, temporary suction gages will be installed to measure pump suction pressure.

B-20

Revision 0 07/16/93 RELIEF REQUEST NO. PR-16 WITHDRAWN (Rev 0, 07/16/93)

B-21

Revision 0 07/16/93 RELIEF REQUEST NO. PR-17 COMPONENTS:

Hydrazine Pumps 2A and 2B (2998-G-088)

SECTION XI REQUIREMENTS:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1 except bearing temperatures, which shall be measured during at least one inservice test each year. (IWP-3300)

Symmetrical damping devices or averaging techniques may be used to reduce instrument fluctuations to within 2% of the observed reading. (IWP-4150)

BASIS FOR RELIEF:

The Hydrazine Pumps are positive displacement pumps with a variable speed drive. They operate at a very low rpm and flow rate (0.71 to 0.82 gpm). The flow instrument orifice is located in the pump's suction line. Its output signal pulsates sharply with each stroke and cannot readily be averaged. The flow recorder for the hydrazine pumps, FR 2-2, displays a wide trace for flow rate. The only way to know the true flow rate of the pumps is to collect the pumps output in a container and measure it.

During the 1992 Unit 2 refueling outage, several flow tests per hydrazine pump were performed. The discharge of one pump was directed to a container of a known volume. The amount of time to fill the container was measured and then used to calculate an average flow rate for the pump. Each of the flow tests for each pump were performed at a different pump rpm. A correlation between pump rpm and average flow rate was developed and compared to the expected value. The measured and the expected correlations between rpm and flow rate were in close agreement. The expected correlation was based upon piston diameter, piston stroke, and pump rpm. Based upon these results, hydrazine pump flow rate can be accurately set by selecting the proper pump rpm.

B-22

Revision 0 07/16/93 RELIEF REQUEST NO. PR-17 (cont.)

BASIS FOR RELIEF (cont.):

Frequent performance of the above mentioned flow testing can not be performed. Hydrazine is a highly flammable liquid with cumulative toxic affects when absorbed through the skin, inhaled, or ingested. It has also been identified as a known carcinogen.

ALTERNATE TESTING:

During the quarterly pump tests, each pump's rpm will be measured to verify the required flow rate of 0.71 to 0.82 gpm. Pump flow will be recorded but not alert trended and vibration will be measured during the quarterly tests.

During each refueling outage at least one flow test will be

,performed for each pump to verify proper performance. Pump vibration will be measured during this flow test.

B-23

Appendix C Valve Program Tables

Revision 0 07/16/93 Florida Power & Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit,2 PAGE  : 1 LEGEND VALVE NUMBER The plant alpha-numerical designator for the subject valve COORD The coordinate location of the valve on the designated drawing CL The ISI Classification of the valve as per the respective ISI boundary drawings CAT The valve category per Paragraph IWV-2200 SIZE The valve's nominal size in inches TYPE The valve type A/P The active (A) or passive (P) determination for the valv'e.

ACT. TYPE The valve actuator type as follows:

AO Air-operated DO Diaphragm-operated MO Electric motor-operated MAN Manual valve PO Piston-operated S/A Self-actuated SO Solenoid-operated NORM POS. Designates the normal position of the valve during plant operation at power REM IND Notes if a valve has remote position indication FAIL MODE Identifies the failure mode (open or closed) for a valve. FAI indicates the valve fails "as is".

Revision 0 07/16/93 Florida Power & Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit 2 PAGE  : 2 LEGEND (Cont. )

EXAM Identifies the test requirements for a valve as follows:

CV/C Check valve exercise to closed position.

cv/o Check valve full-stroke exercise to open position.

cv/po Check valve partial-stroke exercise to open position.

Ec Exercise to closed position. For all category A or B power-operated valves stroke times will be measured unless excluded by an associated relief request.

EE Exercise valve to verify proper operation and stroking with no stroke time measurements. Requires observation of system parameters or local observation of valve operation.

EO Exercise to open position. For all category A or B power-operated valves stroke times will be measured unless excluded by an associated relief request.

FS Fail safe test INSP Disassembly and inspection of check valves PEC Partial closure exercise for power-operated valves PI Position indication verification SLT-1 Seat leakrate test per 10 CFR 50, App J SLT-2 Seat leakrate test for pressure isolation valves.

SRV Set point check for safety/relief valves

Revision 0 07/16/93 Florida Power & Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit 2 PAGE LEGEND (Cont.)

TEST FREQ The required test interval as follows:

QR Quarterly (during plant operation)

CS Cold shutdown as defined by Technical Specification 2Y Every 2 years RF Each reactor refueling outage (cycle). In the case where this is designated for safety/relief valves ANSI/ASME OM-1-1981 SP Other (See applicable Request for Relief)

RELIEF REQ Refers to the specific relief request associated with the adjacent test requirement. (See Appendix D)

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 4 P II ID: 2998-0-078 SH 107 SYSTEN: REACTOR COOLANT SYSTEN ACT. KORH REN FAIL TEST RELIEF VALVE NUNBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAN FREQ REQ. RENARKS V-1460 G-6 2 B F 000 GLOBE A SO LC YES FC EO CS PI 2Y V-1461 G-6 2 B 1.000 GLOBE A SO LC YES FC EO CS PI 2Y V-1462 E-6 2 8 F 000 GLOBE A SO LC YES FC EO CS PI 2Y V-1463 E-6 2 8 1.000 GLOBE A SO LC YES FC EO CS PI 2Y V-1464 D-4 2 B 1.000 GLOBE A SO LC YES FC EO CS PI 2Y V-1465 E-4 2 8 1.000 GLOBE A SO LC YES FC EO CS PI 2Y V-1466 G-5 2 B 1..000 GLOBE . A SO LC YES FC EO CS PI 2Y

FLORIDA POHER AHD LIGHT COMPAHY REVI SIGH: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Huclear Plant - Unit 2 PAGE  : 5 P II ID: 2998-G-078 SH 108 SYSTEM: REACTOR COOLAHT SYSTEM ACT. HORM REM FAIL TEST RELIEF VALVE NINBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS V-1474 F-6 1 B 3.000 GLOBE A SO C YES FC EO CS PI 2Y V-1475 D-6 1 B 3.000 GLOBE A SO C YES FC EO CS PI 2Y V-1476 F-5 1 B 3.000 GATE A MO 0 YES FAI EC OR PI 2Y V-1477 D-5 1 B 3.000 GATE A MO 0 YES FAI EC QR PI 2Y

FLORIDA PONER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 6 P S ID: 2998-G-078 SH 109 SYSTEH: REACTOR COOLANT SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAH FRED REQ. REHARKS V-1200 G-6 1 C F 000 SAFETY A S/A C NO SRV RF V-1201 G-6 1 C 3.000 SAFETY A S/A C NO SRV RF V-1202 G-6 1 C 3.000 SAFETY A S/A C NO SRV RF

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 7 P 8 ID: 2998-G-078 SM '120 SYSTEM: CHEMICAL AND VOLUME COHTROL ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-2345 F-8 3 C 2.000 RELIEF A S/A C Ho H/A SRV RF V.2522 E-7 2 A 2.000 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y V-2531 G-5 3 C 2.000 RELIEF A S/A C NO N/A SRV RF

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 8 P 8( ID: 2998-G-078 SH 121 SYSTEM: CHEMICAL AND VOLUME CONTROL ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-2210Y C-2 2 8 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y V-2115 F-5 3 C 4.000 RELIEF A S/A C HO SRV RF V-2118 F-4 2 C 4.000 CHECK A S/A 0 HO CV/0 QR V-2177 C-3 2 C 3.000 CHECK A S/A C NO CV/0 RF VR-5 CV/PO CS VR-5 V-2190 D-6 2 C 3.000 CHECK A S/A C HO CV/C QR VR-5 CV/0 RF VR-5 CV/PO CS VR-5 V-2191 E-3 2 C 3.000 CHECK A S/A C HO CV/0 RF VR-5 CV/PO CS VR-5 V-2311 F-3 2 C 0.500 RELIEF A S/A C NO SRV RF V-2443 C-4 2 C 3.000 CHECK A S/A 0 NO CV/C QR CV/0 RF VR-6 CV/PO QR VR-6 V-2444 8-4 2 C 3.000 CHECK A S/A C HO CV/C QR CV/0 RF VR-6 CV/PO QR VR-6 V-2446 F-5 3 C 0.750 RELIEF A S/A C NO N/A SRV RF V-2447 F-5 3 C 0.750 RELIEF A S/A C HO N/A SRV RF V-2501 F-4 2 8 4.000 GATE A MO 0 YES FAI EC CS EO CS PI 2Y V-2504 F-3 2 B 3.000 GATE A HO C YES FAI EC QR EO QR PI 2Y V-2505 G-7 2 A 0.750 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 9 aa a P & ID: 2998-G-078 SH 121 (cont) SYSTEM: CHEMICAL AND VOLUME CONTROL ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-2507 H-7 2 B 0.750 GLOBE A DO LO YES FO EC QR PI 2Y V-2508 C-6 2 B F 000 GATE A MO C YES FAI EO QR PI 2Y V-2509 C-7 2 B 3.000 GATE A MO C YES FAI EO QR PI 2Y V-2514 C-3 2 B 3.000 GATE A MO C YES FAI EO QR PI 2Y V-2524 F-7 2 A 0.750 GLOBE A DO 0 YES FC CS CS 2Y 2Y V-2525 E-4 3 B 4.000 GATE A MO C YES FAI EC QR PI 2Y V-2526 E-3 2 C 4.000 CHECK A S/A C NO CV/0 RF VR-5 CV/PO CS VR-5 V-2650 8-4 2 8 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y V-2651 D-4 2 B 1 F 000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y V-2674 F-4 3 C 4.000 CHECK A S/A 0 HO CV/0 QR

FLORIDA POHER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE: 10 P B ID: 2998-G-078 SH 122 SYSTEM: CHEMICAL AND VOLUME CONTROL ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORS CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAM FREQ REQ. REMARKS SE-02-01 C-7 1 B 2.000 GLOBE A SO 0 YES FO EC QR EO QR FS QR PI 2Y SE-02-02 8-7 1 B 2.000 GLOBE A SO 0 YES FO EC QR EO QR FS QR PI 2Y SE-02-03 D-7 1 8 2.000 GLOBE A SO LC YES FC EC CS EO CS FS CS PI 2Y SE-02-04 D-7 1 8 2.000 GLOBE A SO LC YES FC EC CS EO CS FS CS PI 2Y V-2167 G-2 2 C 2.000 CHECK A S/A C HO CV/C QR CV/0 QR V-2168 E-2 2 C 2.000 CHECK A S/A C NO CV/C QR CV/0 QR V-2169 C-2 2 C 2.000 CHECK A S/A C NO CV/C OR CV/0 QR V-2318 E-3 2 C 0.500 RELIEF A S/A C NO SRV RF V-2321 D-3 2 C 0 ~ 500 RELIEF A S/A C NO SRV RF V-2324 C 2 2 C 1 '00 RELIEF A S/A C HO SRV RF V-2325 E-2 2 C 1.500 RELIEF A S/A C NO SRV RF V-2326 G-2 2 C 1.500 RELIEF A S/A C NO SRV RF V-2340 G-1 2 8 2.000 GATE A HAH C NO FAI EE QR V-2431 0-8 1 C 2.000 CHECK A S/A C NO CV/0 CS V-2432 C-B 1 C 2.000 CHECK A S/A 0 NO CV/0 QR

0 FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 11 RE LZ 55 RC C5C ZCC 55 CUR CAR CI P 8 ID: 2998-G-078 SH 122 (cont) SYSTEM: CHEMICAL AND VOLUME CONTROL ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-2433 B-B 1 C 2.000 CHECK A S/A 0 NO CV/0 QR V-2440 G-2 2 C 2.000 CHECK A S/A C NO CV/0 CS V-2462 8-6 2 C 2.000 CHECK A S/A C NO CV/0 QR V-2515 F-8 1 8 2.000 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y V-2516 F-7 1 A 2.000 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y V-2523 B-6 2 8 2.000 GLOBE P DO LO YES FO EC CS PI 2Y V-2553 F-2 2 8 2.000 GLOBE A MO 0 YES FAI EC OR PI 2Y V-2554 D-2 2 B 2.000 GLOBE A MO 0 YES FAI EC QR PI 2Y V-2555 C-2 2 8 2.000 GLOBE A MO 0 YES FAI EC QR PI 2Y V-2588 G-3 2 C 0.500 RELIEF A S/A C NO SRV RF V-2598 C-6 2 8 2.500 GATE A MO 0 YES FAI EO CS PI 2Y

FLORIDA POWER AHD LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE: 12 P & ID: 2998-G-078 SH 130 SYSTEH: SAFETY INJECTION SYSTEM ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REHARKS FCV-3301 E-2 2 8 10.000 BUTFLY A MO LO YES FAI EC QR PI 2Y FCV-3306 F-4 2 B 10.000 BUTFLY A MO LO YES FAI EC QR PI 2Y, HCV-3512 E-2 2 8 10.000 BUTFLY A MO LC YES FAI EO QR PI 2Y HCV-3657 F-4 2 8 10.000 BUTFLY A HO LC YES FAI EO QR PI 2Y SE-03-2A G-2 2 A 2.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y VR-4 SE-03-28 G-2 2 A 2.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y VR-4 SR-03-1 A-6 3 C 0.750 RELIEF A S/A C NO SRV RF SR-03-2 A-5 3 C 0.750 RELIEF A S/A C NO SRV RF SR-07-1A E-7 2 C 0.750 RELIEF A S/A C HO SRV RF SR-07-18 D-8 2 C 0.750 RELIEF A S/A C NO SRV RF V-07000 F-7 2 C 14 F 000 CHECK A S/A C NO CV/0 RF VR-7 CV/PO QR VR-7 V-07001 E-7 2 C 14.000 CHECK A S/A C NO CV/0 RF VR-7 CV/PO QR VR-7 V-3101 H-3 3 C 2.000 CHECK A S/A C NO CV/0 RF VR-32 CV/PO CS VR-32 V-3102 D-6 2 C 2.000 CHECK A S/A C NO CV/PO QR VR-30 INSP RF VR-30

FLORIDA PONER AND LIGH1'OHPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 21 0 WCC 1 R1 2

SL 0 1C 5 I 0 51K << ~

PAGE

~M

13 ZR P'8 ID: 2998-G-078 SH 130 (cont) SYSTEH: SAFETY INJECTION SYSTEH 11C 5V CZ CI I Zi55 ACT. HORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. INO HOOE EXAH FREQ REQ. REHARKS V-3103 0-5 2 C 2.000 CHECK A S/A C NO CV/PO QR VR-30 INSP RF VR-30 V-3104 E-6 2 C 2.000 CHECK A S/A C NO CV/C QR CV/0 RF VR-28 CV/PO QR VR-28 V-3105 D-6 2 C 2.000 CHECK A S/A C NO CV/C QR CV/0 RF VR-28 CV/PO QR VR-28 V-3106 F-5 2 C 10.000 CHECK A S/A C NO CV/0 CS CV/PO QR V-3107 E-5 2 C 10.000 CHECK A S/A C NO CV/0 CS CV/PO QR V-3201 H-3 3 B 2.000 GLOBE A HAN C NO FAI EE QR V-3401 0-7 2 C 6.000 CHECK A S/A C NO CV/0 RF VR-8 CV/PO, QR VR-8 V-3407 H-3 3 C 0.500 RELIEF A S/A C NO SRV RF V-3410 B-7 2 C 8.000 CHECK A S/A C NO CV/0 RF VR-8 CV/PO QR VR-8 V-3412 C-4 2 C 1.000 RELIEF A S/A C HO SRV RF V-3414 B-5 2 C 3.000 S/CHEK A S/A C NO CV/C QR VR-9 CV/0 RF VR-9 CV/PO CS VR-9 V-3417 D-4 2 C 1.000 RELIEF A S/A C NO SRV RF V-3427 D-5 2 C 3.000 S/CHEK A S/A C NO CV/C CS VR-9 CV/0 RF VR-9 CV/PO CS VR-9 V-3430 G-6 2 C 1 ~ 000 RELIEF A S/A C NO SRV RF V-3431 H-6 2 C 1.000 RELIEF A S/A C NO SRV RF V-3432 E-7 2 8 14.000 GATE A HO LO YES FAI EC QR PI 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 14 P & ID: 2998-G-078 SH 130 (cont) SYSTEH: SAFETY INJECTION SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND HDDE EXAH FREQ REQ. REMARKS V-3439 F-3 2 C 1.000 RELIEF A S/A C NO SRV RF V-3444 E-7 2 B 14.000 GATE A HO LO YES FAI EC QR PI 2Y V-3456 G-4 2 8 10.000 GATE A HO LC YES FAI EO QR PI 2Y V-3457 F-2 2 B 10 F 000 GATE A MO LC YES FAI EO QR PI 2Y V-3463 G-2 2 A 2.000 GATE A HAN LC NO EE CS SLT-1 2Y V-3466 G-1 3 C 1.500 RELIEF A 8/A C NO SRV RF V-3495 G-6 2 8 6'.000 GLOBE A SO LO YES FC EC QR FS QR PI 2Y V-3496 G-5 2 B 6.000 GLOBE A SO LO YES FC EC QR FS QR PI 2Y V-3507 F-1 2 C 1 ~ 000 RELIEF A S/A C NO SRV RF V-3513 G-3 2 C 2.000 RELIEF A S/A C NO SRV RF V-3517 H-6 2 B 12.000 GATE A HO LC YES FAI EO QR PI 2Y V-3518 C-3 2 8 2.000 GLOBE A HAN C NO FAI EE QR V-3519 D-4 2 B 2.000 GLOBE A HAN C NO FAI EE QR V-3522 B-4 2 C 3.000 CHECK A S/A C NO CV/C CS VR-10 CV/0 RF VR-10 CV/PO CS VR-10 V-3523 A-2 2 B 3.000 GLOBE A HO LC YES FAI EC QR EO QR PI 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE: 15 P 8 ID: 2998-G-078 SN 130 (cont) SYSTEM: SAFETY INJECTION SYSTEH ACT. NORH REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAM FREQ REQ. REMARKS V-3540 C-2 2 8 3.000 GLOBE A HO LC YES FAI EC QR EO QR PI 2Y V-3547 C-5 2 C 3.000 CHECK A S/A C NO CV/C CS VR.10 CV/0 RF VR-10 CV/PO CS VR-10 V-3550 C-2 2 8 3.000 GLOBE A MO LC YES FAI EC QR EO QR PI 2Y V-3551 A-2 2 8 3.000 GLOBE A HO LC YES FAI EC QR EO QR PI 2Y V-3570 C-3 2 C 1'.000 RELIEF

' S/A C NO SRV RF V-3654 8-5 2 8 6.000 GATE A MO LO YES FAI EC QR Pl 2Y V-3656 D-5 2 8 6.000 GATE A HO LO YES FAI EC QR PI 2Y V-3658 G-7 2 8 12.000 GATE A MO LC YES FAI EO QR PI 2Y V-3659 G-6 2 8 3.000 GATE A MO LO YES FAI EC QR PI 2Y V-3660 G-5 2 8 3.000 GATE A MO LO YES FAI EC QR PI 2Y V-3688 H-5 2 C 2.000 RELIEF A 8/A C NO SRV RF

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE: 16 P & ID: 2998-G-078 SH 131 SYSTEM: SAFETY INJECTION SYSTEH ACT. NORM REM FAIL TEST RELIEF VALVE HUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAM FREQ REQ. REHARKS HCV-3615 H-7 2 8 6.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3616 G-7 2 8 2.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3617 G-7 2 8 2.000 GLOBE A HO C YES FAI EO QR Pl 2Y HCV-3625 F-7 2 8 6.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3626 E-7 2 8 2.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV.3627 E-7 2 8 2.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3635 D-7 2 8 6.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3636 C-7 2 8 F 000 GLOBE A HO C YES FAI EO QR Pl 2Y HCV-3637 C-7 2 8 2.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3645 8-7 2 8 6.000 GLOBE A HO C YES FAI EO QR Pl 2Y HCV-3646 A-7 2 8 2.000 GLOBE A HO C YES FAI EO QR PI 2Y HCV-3647 A-7 2 8 2.000 GLOBE A HO C YES FAI EO QR PI 2Y V-3113 G-7 2 C 2.000 CHECK A S/A C NO CV/0 RF VR-11 CV/PO CS VR-11 V-3114 H-7 2 C 6.000 CHECK A S/A C NO CV/C CS CV/0 CS V-3124 F-7 2 C 6.000 CHECK A S/A C NO CV/C CS CV/0 CS

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 17 P S ID: 2998-G-078 SH 131 (cont) SYSTEH: SAFETY INJECTION SYSTEM ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS ~ IND MODE EXAM FRED RED. REMARKS V-3133 C-7 2 C 2.000 CHECK A S/A C NO CV/0 RF VR-11 CV/PO CS VR-11 V-3134 D-7 2 C 6.000 CHECK A S/A C HO CV/C CS CV/0 CS V-3143 A-7 2 C 2.000 CHECK A S/A C NO CV/0 RF VR-11 CV/PO CS VR-11 V-3144 8-7 2 C 6.000 CHECK A S/A C NO CV/C CS CV/0 CS V-3468 D-6 2 C 2.000 RELIEF A S/A C NO SRV RF V-3469 D-3 1 C 0.750 RELIEF A S/A C NO SRV RF V-3480 E-3 1 A 10.000 GATE A HO LC YES FAI EO CS PI 2Y SLT-2 SP VR-29 V-3481 E-4 1 A 10.000 GATE A NO LC YES FAI EO CS PI 2Y SLT-2 SP VR-29 V-3482 E-4 1 C 0.750 RELIEF A S/A C NO SRV RF V-3483 D-8 2 C 2.000 RELIEF A S/A C NO SRV RF V-3524 F-5 1 AC F 000 CHECK A S/A C NO CV/C SP VR-12 CV/0 RF VR-12 CV/PO CS VR-12 SLT-2 SP VR-2 V-3525 F-4 1 AC 3.000 CHECK A S/A C NO CV/C SP VR-12 CV/0 RF VR-12 CV/PO CS VR-12 SLT-2 SP VR-2 8 VR-12 V-3526 C-5 1 AC 3.000 CHECK A S/A C NO CV/C SP VR-12 CV/0 RF VR-12 CV/PO CS VR-12 SLT-2 SP VR-2

FLORIDA PONER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: Or/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE: 18 P II ID: 2998-G-078 SH 131 (cont) SYSTEM: SAFETY INJECTION SYSTEM Z?I CS R5Z CIi HE 0 CN C0CC SCCA I55 RC 0 55 CC ACT. NORM REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FRED REQ. REMARKS V-3527 C-4 1 AC 3.000 CHECK A S/A C NO CV/C SP VR-12 CV/0 RF VR-12 CV/PO CS VR-12 SLT.2 SP VR-2 5 VR-12 V-3536 E-8 2 B 4.000 GLOBE A MO LC YES FAI EC QR PI 2Y V-3539 C-B 2 8 4.000 GLOBE A HO LC YES FAI EC QR PI 2Y V-3545 E-4 1 B 10.000 GATE A HO LC YES FAI EO CS Pl 2Y V-3571 8-4 1 8 1.000 GLOBE A 00 C YES FC EC QR 4 FS QR PI 2Y V-3572 F-4 1 8 1 F 000 GLOBE A DO C YES FC EC QR FS QR Pl 2Y V-3651 D-5 1 A 10.000 GATE A HO LC YES FAI EO CS PI 2Y SLT-2 SP VR-29 V-3652 D-3 1 A 10.000 GATE A HO LC YES FAI EO CS PI 2Y SLT-2 SP VR-29 V-3664 E-6 2 B 10 F 000 GATE A HO LC YES FAI EO CS PI 2Y V-3665 C-6 2 B 10.000 GATE A HO LC YES FAI EO CS PI 2Y V-3666 D-6 2 C 6.000 RELIEF A S/A C NO SRV RF V-3667 E-6 2 C 6.000 RELIEF A S/A C NO SRV RF V-3766 E-7 2 C 2.000 CHECK A S/A C NO CV/0 RF VR-11 CV/PO CS VR-11

FLORIDA POWER AND LIGHT COMPANY REVISIOH: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE: 19 P B ID: 2998-G-078 SH 'I32 SYSTEM: SAFETY INJECTION SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORS CL CAT. SI2E TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS HCV-3618 E-7 1 B F 000 GLOBE A 00 C YES FC EC QR FS QR PI 2Y HCV-3628 E-4 1 B F 000 GLOBE A 00 C YES FC EC QR FS QR PI 2Y HCV-3638 8-7 1 B 1.000 GLOBE A 00 C YES FC EC QR FS QR PI 2Y HCV-3648 B-4 1 8 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y SE-03-1A F-3 2 8 1 F 000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SE-03-18 F-7 2 8 1.000 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SE-03-1C C-7 2 B F 000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SE-03-1D C-3 2 8 F 000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y V-03002 F-7 3 C 1.000 CHECK A S/A C NO CV/0 CS V-03003 C-7 3 C 1.000 CHECK A S/A C NO CV/0 CS V-03004 F-4 3 C 1.000 CHECK A S/A C HO CV/0 CS V-03005 C-4 3 C 1.000 CHECK A S/A C NO CV/0 CS V-3211 H-6 2 C 1.500 RELIEF A S/A C NO SRV RF

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 20 P 8 ID: 2998-G-078 SH 132 (cont) SYSTEM: SAFETY INJECTION SYSTEM CS 5 5 LZ RSI EICOS Z C?V ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-3215 F-6 2 AC 12 F 000 CHECK A S/A C NO CV/C SP VR-13 INSP SP VR-13 SLT-2 SP VR-2 V-3217 E 5 1 AC 12.000 CHECK A S/A C NO CV/C SP VR-14 CV/PO CS VR-14 IHSP SP VR-14 SLT-2 SP VR-2 V-3221 H-3 2 C 1.500 RELIEF A S/A C HO SRV RF V-3225 F-3 2 AC 12,000 CHECK A S/A C HO CV/C SP VR-13 IHSP SP VR-13 SLT-2 SP VR-2 V-3227 E-2 1 AC 12.000 CHECK

' S/A C NO CV/C SP VR-14 CV/PO CS VR-14 INSP SP VR-14 SLT-2 SP VR-2 V-3231 D-6 2 C 1.500 RELIEF A S/A C NO SRV RF V-3235 C-6 2 AC 12.000 CHECK A S/A C NO CV/C SP VR-13 INSP SP VR-13 SLT-2 SP VR-2 V-3237 8-5 1 AC 12.000 CHECK A S/A C NO CV/C SP VR-14 CV/PO CS VR-14 INSP SP VR-14 SLT-2 SP VR-2 V-3241 D-3 2 C 1.500 RELIEF A S/A C NO SRV RF V-3245 C-3 2 AC 12.000 CHECK A S/A C HO CV/C SP VR-13 INSP SP VR-13 SLT-2 SP VR-2 V-3247 8-2 1 AC 12.000 CHECK A S/A C NO CV/C SP VR-14 CV/PO CS VR-14 INSP SP VR-14 SLT-2 SP VR-2

Lit i 0 0 CC 550 Z?Zt I CC 0 ZXC5 FLORIDA PONER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 21 55 Ztl 0 I 5 I Q5 RC ZI5 ICE 5 CZ ID: 299B-G-078 SH 132 (cont) SYSTEM: SAFETY INJECTION SYSTEM P 8

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ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-3258 E-3 1 AC 6.000 CHECK A S/A C NO CV/C SP VR-15 CV/0 CS VR-15 SLT-2 SP VR-2 V-3259 E-6 1 AC 6.000 CHECK A S/A C NO CV/C SP VR-15 CV/O CS VR-15 SLT-2 SP VR-2 V-3260 B-6 1 AC 6.000 CHECK A S/A C NO CV/C SP VR-15 CV/0 CS VR-15 SLT-2 SP VR-2 V-3261 B-3 1 AC 6.000 CHECK A S/A C NO CV/C SP VR-15 CV/0 CS VR-15 SLT-2 SP VR-2 V.3611 F-6 2 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y V-3614 F-6 1 B 12.000 GATE A MO LO YES FAI EC CS PI 2Y V-3621 F-3 2 B 1.000 GLOBE A 00 C YES FC EC FS PI 'Y QR QR V-3624 F-3 1 B 12.000 GATE A MO LO 'YES FAI EC CS PI 2Y V-3631 B-6 2 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y V-3634 B-6 1 B 12.000 GATE A MO LO YES FAI EC CS PI 2Y V-3641 B-3 2 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y V-3644 B-3 1 B 'I2.000 GATE A MO LO YES FAI EC CS PI 2Y

FLORIDA POWER AHD LIGHT COHPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 22 P S ID: 2998-G-078 SH 132 (cont) SYSTEH: SAFETY INJECTION SYSTEH XRE 5i 0 0 0 XV I IC N CC ACT. NORH REN FAIL TEST RELIEF VALVE HUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD NODE FRED REG. RENARKS V-3733 G-7 2 8 1.000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3734 G-7 2 8 1 F 000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3735 G-4 2 8 1.000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3736 G-4 2 8 1.000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3737 D-7 2 8 1.000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3738 0-7 2 8 1.000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3739 D-4 2 8 1 F 000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y V-3740 D-4 2 8 1.000 GLOBE A SO C YES FC EC CS EO CS FS CS PI 2Y

a a a >> a aax aa x a aa a aa aaa t FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 23 P & ID: 2998-G-078 SM 153 SYSTEH: SAHPLING SYSTEH a axaaa aax aa aaaaaaaaaaaxaaaaaaaaxaaaaxaaaaaaaaaaaaaaaaaxaaaaaaaaaaaaaaaaaaaaaaaxaaaaaaaaaaaaa axaaa ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS SE-05-'1A G-7 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y SE-05-1B F-7 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y SE-05-1C E-7 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y SE-05-1D C-7 2 A 0 '75 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y SE-05-1E G-5 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5200 F-6 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5201 E-6 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5202 D-6 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5203 F-5 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y

FLORIDA PONER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 24 P 8 ID: 2998-G-078 SH 153 (cont) SYSTEH: SAMPLING SYSTEM ZtC 551C 05@ 5 Ci C5 L ZC ACT. NORH REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-5204 E-5 2 A 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5205 D-5 2 A 0 '75 GLOBE A SO C YES FC EC QR FS QR PI 2Y SLT-1 2Y

FLORIDA POMER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 25 P 8 ID: 2998-G-078 SH 160 SYSTEH: HASTE NANAGEHENT SYSTEH ACT. HORN REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAH FREQ REQ. REHARKS V-6341 E-7 2 A 3'.000 DIAPH ' DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6342 E-6 2 A 3.000 DIAPH A 00 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 26 5 RL ZZ!52 IERZt CCRC C$ 51SC~CCSCtS 155ÃCCRS SR SC IZ P 8 ID: 2998-G-078 SH 163 SYSTEH: WASTE MANAGEMENT SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-6718 E-7 2 A 1.000 DIAPH A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6741 C-7 2 A 1.000 GLOBE A AO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6750 E.7 2 A 1.000 DIAPH A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6792 C-7 2 AC 1.000 CHECK A S/A C NO CV/C CS SLT-1 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 27 P 8 ID: 2998-G-079 SN 1 SYSTEH: HAIN STEAH SYSTEH ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS.'ND HODE EXAM FREQ REQ. REHARKS HCV-08-1A K.12 2 8 34.000 GLOBE A PO ,

0 YES EC CS PEC QR PI 2Y NCV-08-18 C-13 2 8 34.000 GLOBE A PO 0 YES EC CS PEC QR PI 2Y HV-08-12 N-8 2 8 4.000 GATE A HO C YES FAI EC QR EO QR PI 2Y MV-08-13 N-10 2 8 4.000 GATE A MO C YES FAI EC QR EO QR PI 2Y HV-08-14 K-8 2 B 8.000 GATE P HO LO YES FAI EC QR PI 2Y MV-08-15 K-10 2 8 8.000 GATE P HO LO YES FAI EC QR PI 2Y HV-08.16 D-10 2 8 8.000 GATE P HO LO YES FAI EC QR PI 2Y HV-08.17 D-8 2 B 8.000 GATE P HO LO YES FAI EC QR PI 2Y MV-08-18A J-8 2 8 10.000 ANGLE A HO C YES FAI EC QR EO QR PI 2Y HV-08-18B D-10 2 8 10.000 ANGLE A HO C YES FAI EC QR EO QR PI 2Y HV-08-19A J-10 2 8 10.000 ANGLE A MO C YES FAI EC QR EO QR PI 2Y MV-08-19B D-8 2 8 10.000 ANGLE A HO C YES FAI EC QR EO QR PI 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 28 P & ID: 2998-G-079 SM 1 (cont) SYSTEM: HAIN STEAH SYSTEM SSR CRC ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAH FREQ REQ. REHARKS MV-08-'IA K-13 2 8 3.000 GLOBE A MO C YES FAI EC QR PI 2Y HV-08-1B C-13 2 8 3.000 GLOBE A HO C YES FAI EC QR PI 2Y HV-08-3 N-14 3 8 4.000 GLOBE A HO LO YES FAI EO QR Pl 2Y SE-08-1 N-8 2 B 0.750 GLOBE A SO 0 YES FO EC QR PI 2Y SE-08-2 N-10 2 B 0.750 GLOBE A SO 0 YES FO EC QR PI 2Y V-08130 L-10 3 C F 000 CHECK A S/A 0 NO CV/0 CS CV/PO QR VR-31 INSP RF VR-31 V-08163 L-'10 3 C F 000 CHECK A S/A 0 NO CV/0 CS CV/PO QR VR-31 INSP RF VR-31 V-8201 J-12 2 C 6.000 SAFETY A S/A C NO SRV V-8202 J12 2 C 6.000 SAFETY A S/A C NO SRV RF V-8203 J-12 2 C 6.000 SAFETY A S/A C NO SRV RF V-8204 J-12 2 C 6.000 SAFETY A S/A C NO SRV RF V-8205 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8206 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8207 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8208 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8209 J-12 2 C 6.000 SAFETY A S/A C NO SRV RF V-8210 J-12 2 C 6.000 SAFETY A S/A C NO SRV RF V-8211 J-12 2 C 6.000 SAFETY A S/A C NO SRV RF

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 29 P & ID: 2998-0-079 SH '1 (cont) SYSTEM: MAIN STEAM SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-8212 J-12 2 C 6.000 SAFETY A S/A C NO SRV RF V-8213 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8214 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8215 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF V-8216 C-11 2 C 6.000 SAFETY A S/A C NO SRV RF

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 30 P 5 ID: 2998-G-080 SN 2 SYSTEH: FEEDWATER SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAM FRED REQ. REMARKS HCV-09-1A 8-14 2 8 20 F 000 GATE A PO 0 YES FO EC CS FS CS PEC QR PI 2Y HCV-09-18 8-13 2 8 20 F 000 GATE A PO 0 YES FO EC CS FS CS PEC QR PI 2Y HCV-09-2A E-13 2 8 20.000 GATE A PO 0 YES FO EC CS FS CS PEC QR PI 2Y HCV-09-28 E-13 2 8 20.000 GATE A PO 0 YES FO EC CS FS CS PEC QR PI 2Y MV-09.09 G-16 2 8 4.000 GLOBE A MO C YES FAI EC QR EO QR PI 2Y MV-09-10 I-15 2 8 F 000 GLOBE A HO C YES FAI EC QR EO QR PI 2Y HV-09-11 G-12 2 8 4.000 GLOBE A HO C YES FAI EC QR EO QR PI 2Y HV-09-12 I-12 2 8 4.000 GLOBE A HO C YES FAI EC QR EO QR PI 2Y MV-09-13 H-17 3 8 2.500 GATE A HO C YES FAI EO QR PI 2Y HV-09-14 H-17 3 8 2.500 GATE A MO C YES FAI EO QR PI 2Y

FLORIDA POWER AHD LIGHT COHPAHY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 31 P 8 ID: 2998-G-080 SH 2 (cont) SYSTEH: FEEDWATER SYSTEH ACT ~ NORH REH FAIL TEST RELIEF VALVE NUMBER CODRD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAH FREQ REQ. REHARKS SE-09-2 K-15 3 8 4.000 GATE A SO C YES FC EC CS VR-33 EE QR VR-33 EO CS VR-33 FS QR PI 2Y SE-09-3 J-15 3 8 4.000 GATE A SO C YES FC EC CS VR-33 EE QR VR-33 EO CS VR-33 FS QR PI 2Y SE-09-4 H-11 3 B 4.000 GATE A SO C YES FC EC CS VR-33 EE QR VR-33 EO CS VR-33 FS QR PI 2Y SE-09-5 1-11 3 8 4.000 GATE A SO C YES FC EC CS VR-33 EE QR VR-33 EO CS VR-33 FS QR PI 2Y V-09107 M-14 3 C 4.000 CHECK A S/A C HO CV/0 CS V-09119 G-15 2 C 4.000 CHECK A S/A C NO CV/0 CS V-09120 D-1 2 B 4.000 GATE A MAN LO NO FAI EE V-09123 L-14 3 C ,4.000 CHECK A S/A C NO CV/0 CS V-09'135 1-15 2 C 4.000 CHECK A S/A C NO CV/0 CS V-09136 D-16 2 B 4.000 GATE A HAN LO HO FAI EE QR V-09139 J-14 3 C 6.000 CHECK A S/A C HO CV/0 CS V-09151 G-12 2 C 4.000 CHECK A S/A C NO CV/0 CS V-09152 D-4 2 B 4.000 GATE A MAN LO HO FAI EE QR V-09157 1-12 2 C 4.000 CHECK A S/A C NO CV/0 CS V-09158 D-13 2 8 4.000 GATE A MAN LO NO FAI EE

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 32 P S ID: 2998-G-080 SH 2 (cont) SYSTEM: FEEDWATER SYSTEM ACT ~ NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS ~ IND MODE EXAM FREQ REQ. REMARKS V-09252 8-16 2 C 18.000 CHECK A S/A 0 NO CV/0 QR V-09294 E-16 2 C 18.000 CHECK A S/A 0 NO CV/0 QR V-09303 L-13 3 C 2.000 CHECK A S/A C NO CV/PO QR VR-27 INSP RF VR-27 V-09304 M-12 3 C 1.500 CHECK A S/A C NO CV/PO QR VR-27 INSP RF VR-27 V-09305 N-13 3 C '1.500 CHECK A S/A C NO CV/PO QR VR-27 INSP RF VR-27

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 33 P !L ID: 2998-G-082 SYSTEM: INTAKE COOLING HATER SYSTEM ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS MV-21-2 E-5 3 8 24.000 BUI'FLY A HO 0 YES FAI EC QR PI 2Y MV-21-3 E-4 3 B 24.000 BUTFLY A MO 0 YES FAI EC QR PI 2Y SR-21196 C-4 3 C 3.000 RELIEF A S/A C NO SRV RF SR-21243 C-5 3 C 3.000 RELIEF A S/A C NO SRV RF TCV-'14-4A B-3 3 B 30.000 BUTFLY A PO 0 NO FO EO QR VR-34 FS QR TCV-14-4B B-4 3 B 30.000 BUTFLY A PO 0 NO FO EO QR VR-34 FS QR V-21162 H-4 3 C 30.000 CHECK A S/A 0 NO CV/C QR CV/0 QR V-21205 H-6 3 C 30.000 CHECK A S/A 0 NO CV/C QR CV/0 QR V-21208 H-7 3 C 30.000 CHECK A S/A 0 NO CV/C QR CV/0 QR

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 34 P & ID: 2998-G-083 SYSTEM: COHPONENT COOLING SYSTEM ACT. NORH REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAM FREQ REQ. REMARKS HCV-14-1 C-6 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y lh SLT-1 2Y VR-4 & VR-16 HCV-14-10 H-15 3 B 16.000 BUTFLY ~ A PO 0 YES FC EC QR FS QR PI 2Y HCV-14-2 C-1 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-4 8 VR-16 HCV-14-3A L-3 3 8 14.000 BUTFLY A DO 0 YES FO EO CS FS CS PI 2Y HCV-14-3B M-3 3 8 14.000 BUTFLY A DO 0 YES FO EO CS FS CS PI 2Y HCV-14-6 D-2 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-4 8 VR-16 HCV-14-7 D-6 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-4 8 VR-16 HCV-14-BA G-14 3 8 16.000 BUTFLY A PO 0 YES FC EC QR FS QR PI 2Y HCV-14-88 G-15 3 8 16.000 BUTFLY A PO 0 YES FC EC QR FS QR PI 2Y HCV-14-9 G-15 3 B 16.000 BUTFLY A PO 0 YES FC EC QR FS QR PI 2Y

FLORIDA PONER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 35 P 5 ID: 2998-G-083 (cont) SYSTEM: COMPONENT COOLING SYSTEM ACT. NORM REH FAlL TEST RELIEF VALVE NUMBER COORS CL CAT. SIZE TYPE A/P TYPE POS. IND HOOE EXAM FREQ REQ. REMARKS HV-14-1 D.16 3 8 24.000 BUTFLY A HO 0 YES FAI EC QR EO QR Pl 2Y HV.14.10 C-9 2 8 8.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y HV-14-11 C-10 2 8 8.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y HV.14-12 C-10 2 8 8.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y HV-14-13 C-8 2 8 8.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y MV-14-14 C-B 2 8 8.000 BUTFLY A MO 0 YES FAI EC QR PI 2Y HV-14-15 C-9 2 8 8.000 BUTFLY A MO 0 YES FAI EC QR PI 2Y HV-14-16 C-B 2 8 8.000 BUTFLY A MO 0 YES FAI EC QR PI 2Y HV-14-17 G-13 3 8 12.000 BUTFLY A HO 0 YES FAI EC QR Pl 2Y HV-14-18 G-13 3 8 12.000 BUTFLY A HO LC YES FAI EC QR Pl 2Y HV-14-19 G-12 3 8 12.000 BUTFLY A HO 0 YES FAI EC QR Pl 2Y HV-14-2 D-17 3 8 24.000 BUTFLY A HO C YES FAI EC QR EO QR Pl 2Y HV-14-20 G-12 3 8 12.000 BUTFLY A HO LC YES FAI EC QR PI 2Y HV-14-3 G-16 3 8 24.000 BUTFLY A HO 0 YES FAI EC QR EO QR Pl 2Y

I I I

I 0

FLORIDA POIJER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 36 P 8 ID: 2998.G-083 (cont) SYSTEM: COMPONENT COOLING SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS MV-14-4 G-17 3 8 24 F 000 BUTFLY A MO C YES FAI EC QR EO QR PI 2Y MV-14-9 C-'10 2 8 8.000 BUTFLY A MO 0 YES FAI EC QR PI 2Y SR-14307 8-9 2 C 1.000 RELIEF A S/A C NO SRV RF SR-143'18 8-10 2 C 1.000 RELIEF A S/A C NO SRV RF SR-14329 8-8 2 C 1.000 RELIEF A S/A C NO SRV RF SR-14342 8-8 2 C 1.000 RELIEF A S/A C NO SRV RF V-14143 E-16 3 C 20.000 CHECK A S/A 0 NO CV/C QR CV/0 QR V-14147 E-17 3 C 20.000 CHECK A S/A 0 NO CV/C QR CV/0 QR V.14151 E-16 3 C 20 F 000 CHECK A S/A 0 NO CV/C QR CV/0 QR V-14350 L-1 3 C 1 ~ 000 RELIEF A S/A C NO SRV RF V-14359 M-1 3 C 1.000 RELIEF' S/A C NO SRV RF

P FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 37 L L Bi CL 5 I 1 5Z i2 5C 55 lS I CC HS ZC 22RZC55J C P 8 ID: 2998-G-084 SYSTEH: HAKEUP WATER SYSTEH XCt HLJCQI ZC 0 CIIZ 55ÃiI IZ51ÃCC 11 SCCL55 ORE GER 50 IN R1 5 RI C5 0>> ZC ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAM FREQ REQ. REHARKS HCV-15-1 M-17 2 A 2.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-15328 I-17 2 AC F 000 CHECK A S/A C NO CV/C RF VR-18 SLT-1 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 38 P 8 ID: 2998-0-085 SH 1 SYSTEM: SERVICE AIR ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IND MODE FREQ REQ. REMARKS HCV-18-2 H-6 2 A 2.000 GLOBE A 00 C YES FC EC QR FS QR PI 2Y SLT-1 2Y SH-18797 G-6 2 A 1.000 BALL P MAH LC NO SLT-1 2Y V-181270 H-5 2 AC 2.000 CHECK A S/A C NO CV/C CS SLT-1 2Y

~50 0 C 5R C 5 5 RC CRM 5 5 CL'R CC FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 39 P 8 ID: 2998-0-085 SH 2 SYSTEM: INSTRUMENT AIR CC ACT. NORH REM FAlL TEST RELIEF VALVE HUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REHARKS HCV-18-1 G-7 2 A 1.000 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y V-18195 G-6 2 AC 2.000 CHECK A S/A C NO CV/C RF VR-19 SLT-1 2Y

CRil Z 1 CC 105 C CN t L QCRSEC 55i 5 CCi tL SNCI15C COINS SC CC IR N FLORIDA POWER AND LIGHT CONPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 40 P 8 ID: 2998-G-086 SH 1 SYSTEH: HISCELLANEOUS SYSTEHS ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT ~ SIZE 'YPE 'A/P TYPE POS. IND HDDE EXAH FREQ REQ. REHARKS FCV-23-3 D-14 2 8 3.000 GLOBE A 00 0 YES FC EC QR FS QR PI 2Y FCV-23-5 D-15 2 8 3.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y FCV-23-7 D-17 2 B 0.500 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y FCV-23-9 D-18 2 8 0.500 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y

Z Z I I C 0 St FLORIDA POMER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE: 41 P T ID: 2998-G-088 SYSTEM: CONTAINMENT SPRAY SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER CODRD. CL CAT. SIZE 'YPE A/P TYPE POS ~ IND MODE EXAM FREQ REQ. REMARKS FCV-07-1A F-12 2 8 12.000 GATE A DO C YES FO EO QR FS QR Pl 2Y FCV-07-18 F-12 2 8 12.000 GATE A 00 C YES FO EO QR FS QR Pl 2Y LCV-07-11A I-14 2 A 2.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y LCV-07-118 I-13 2 A 2.000 GLOBE A 00 0 YES FC EC QR FS QR Pl 2Y SLT-1 2Y HV-07-1A HV-07-18 E-3 E-2 2

2 8

8 24 ~ 000 BUTFLY A 24.000 BUTFLY A MO HO LO LO YES FAI YES FAI EC Pl EC

'Y QR QR PI 2Y MV-07-2A l-12 2 8 24.000 BUTFLY A HO C YES FAI EO QR Pl 2Y HV-07-28 J-12 2 8 24..000 BUTFLY. A HO C YES FAI EO QR PI 2Y HV-07-3 F-11 2 8 12.000 GATE A MO 0 YES FAI EC QR Pl 2Y HV-07-4 F-11 2 8 12.000 GATE A MO 0 YES FAI EC QR Pl 2Y SE-07-3A C-9 2 8 0.500 GLOBE A SO C YES FO EC QR EO QR FS QR Pl 2Y SE-07-38 E-9 2 8 0.500 GLOBE A SO C YES FO QR QR QR 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 42 P L'cont) 5 ID: 2998-G-088 SYSTEM: COHTAINHENT SPRAY SYSTEH ACT. NORH REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REHARKS SR-07-1C A-13 2 C 1.000 RELIEF A S/A C NO SRV RF SR-07-2A 8-10 2 C F 500 RELIEF A S/A C NO SRV RF SR-07-2B C-10 2 C F 500 RELIEF A S/A C HO SRV RF V-07119 J-'7 2 C 24.000 CHECK A S/A C NO CV/PO QR VR-20 CV/PO RF VR-20 INSP RF VR-20 V-07120 I-7 2 C 24.000 CHECK A S/A C NO CV/PO QR VR-20 CV/PO RF VR-20 INSP RF VR-20 V-07129 H-5 2 C 12 F 000 CHECK A S/A C NO CV/0 RF VR-21 CV/PO QR VR-21 V-07130 H-6 2 B 12.000 GATE A MAN 0 NO EE QR V-07143 G-5 2 C 12.000 CHECK A S/A C NO CV/0 RF VR-21 CV/PO QR VR-21 V-07145 G-6 2 B 12.000 GATE A HAH 0 NO EE QR V-07170 G-13 2 A 3.000 GATE P HAN LC NO SLT-1 2Y V-07172 J-10 2 C 24.000 CHECK A S/A C NO INSP RF VR-22 V-07174 I-10 '

C 24.000 CHECK A S/A C NO INSP RF VR-22 V-07188 G-14 2 A 3.000 GATE P MAN LC NO SLT-1 2Y V-07189 G-14 2 A 3.000 GATE P HAN LC NO SLT-1 2Y V-07192 E-14 2 C 10.000 CHECK A S/A C NO IHSP RF VR-23 V-07193 E-14 2 C 10.000 CHECK A S/A C NO INSP RF VR-23 V-07206 G-13 2 A 3.000 GATE P MAN LC NO SLT-1 2Y V-07231 A-13 2 C 2.000 CHECK A S/A C NO CV/0 QR V-07232 A-13 2 C 2.000 CHECK A S/A C NO CV/O QR V-07256 E-8 2 C 0.500 CHECK A S/A C NO CV/0 RF VR-24

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 43 P 8 ID: 2998-G-088 (cont) SYSTEM: CONTAINHENT SPRAY SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORS CL CAT. S12E TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-07258 F-8 2 C 0.500 CHECK A S/A C NO CV/0 RF VR-24 V-07412 B-10 2 C 0.500 CHECK A S/A C NO CV/0 QR

CC <<0 0 ZCt55 FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 44 P B ID: 2998-G-091 SYSTEH: HISCELLANEOUS SYSTEHS ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER CODRD. CL CAT. SI2E TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-00-101 B-6 2 A 8.000 GATE P HAN C NO SLT-1 2Y VR-4 8 VR-16 V-00-139 L-10 2 A 0.375 GLOBE P HAN LC NO SLT-1 2Y V-00-140 H-10 2 A 1.000 GLOBE P HAN LC NO SLT-1 2Y V-00-143 H.11 2 A 1.000 GLOBE P HAN LC NO SLT-1 2Y V-00-144 L-11 2 A 0.375 GLOBE P MAN LC NO SLT-1 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 45 P B ID: 2998-0-092 SH 1 SYSTEH: HISC ~ SAMPLING SYSTEMS

$ 51 iCHXSCOC QORZ C1 CC I 5CCC CC5 CS ACT. NORH REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-26-1 G-2 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR Pl 2Y SLT-1 2Y FCV-26-2 G-4 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y FCV-26-3 H-2 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR Pl 2Y SLT-1 2Y FCV-26-4 H-4 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR Pl 2Y SLT-1 2Y FCV-26-5 I-2 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR Pl 2Y SLT-1 2Y FCV.26-6 I-4 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR Pl 2Y SLT-1 2Y FSE-27-10 B-13 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-11 C-13 2 A 0 ~ 375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT.1 2Y

LL I C 5 CC NR FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 46 ICZ P B ID: 2998-G-092 SN 'I (cont) SYSTEM: HISC. SAHPLING SYSTEHS C5 Ei >>ZCCC RV 5 5 N 5 1 ILL 0 EC 0 CCk ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS ~ IND HODE EXAM FREQ REQ. REMARKS FSE-27-12 B-'l5 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-13 8-15 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-14 8-15 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-15 D-'13 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-'16 D-13 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-17 D-14 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-18 D-14 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 47 P B ID: 2998-G-092 SH 1 (cont) SYSTEM: MISC. SAHPLING SYSTEMS ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS ~ IND MODE EXAM FRED REQ. REMARKS FSE-27-8 A-13 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-9 B-13 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y V-27101 8-14 2 AC 0.375 CHECK A S/A C NO CV/C CS CV/0 QR SLT-1 2Y V-27102 8-14 2 AC 0.375 CHECK A S/A C NO CV/C CS CV/0 QR SLT-1 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 48 P F ID: 2998-G-878 SYSTEM: HVAC ACT. NORH REH FAlL TEST RELIEF VALVE NUMBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IND HODE EXAM FRED REQ. REHARKS FCV-25-1 C-2 2 B 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y FCV-25-2 C-3 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-4 8 VR-16 FCV-25-3 C-4 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y SLT.1 2Y VR-4 8 VR-16 FCV-25"4 C-6 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y SLT-1 2Y VR-4 8 VR-16 FCV-25-5 C.7 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y SLT-1 2Y VR-16 FCV-25-6 C-B 2 8 48.000 BUTFLY A PO C YES FC EC CS FS CS PI 2Y FCV-25-7 C-15 2 A 24.000 BUTFLY A PO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y VR-16 FCV-25-8 C-15 2 A 24.000 BUTFLY A PO C YES FC EC QR EO QR FS QR PI 2Y SLT.1 2Y VR-16 V-25-20 C-13 2 AC 24.000 CHECK A S/A C NO CV/C CS CV/0 CS SLT-1 2Y VR-16

FLORIDA POWER AND LIGHT COMPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE: 49 P 8 ID: 2998-0-878 (cont) SYSTEM: HVAC ACT. NORM REM FAIL TEST RELIEF VALVE HUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FRED REQ. REMARKS V-25-21 C-13 2 AC 24.000 CHECK A S/A C NO CV/C CS CV/0 CS SLT-1 2Y VR-16

~1DC SR 5S t R 5 5 Ci555 ROC QEXSCC iRCt5 055CCHR CSS FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE  : 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 50 L 0 ZCZ 2C lQ 5 1 0 CC P 8 ID: 2998-G-879 SH 2 SYSTEH: HVAC ACT ~ NORM REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND HDDE EXAH FREQ REQ ~ REMARKS FCV-25-14 E.6 3 8 12.000 BUTFLY A HO 0 YES FAI EC QR EO QR PI 2Y FCV-25-15 E-7 3 8 12.000 BUTFLY A HO 0 YES FAI EC QR EO QR PI 2Y FCV-25-16 E.5 3 8 12.000 BUTFLY A HO 0 YES FAI EC QR EO QR PI 2Y FCV-25-17 E-8 3 8 12.000 BUTFLY A HO 0 YES FAI EC QR EO QR PI 2Y FCV-25-18 C-17 3 8 6.000 BUTFLY A MO 0 YES FAI EC QR PI 2Y FCV-25"19 C-17 3 8 6.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y FCV-25-24 A-17 3 8 10.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y FCV-25-25 A-17 3 8 10.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 51 P & ID: 2998-0-879 SH 3 SYSTEM: HVAC ACT. NORH REH FAlL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-25-11 H-4 2 8 16.000 BUTFLY A HO C YES FAI EC QR EO QR PI 2Y FCV-25-12 J-4 2 B 16.000 BUTFLY A HO C YES FAI EC QR EO QR PI 2Y FCV-25-13 I-14 2 B 12.000 BUTFLY A HO C YES FAI EO QR PI 2Y FCV-25-20 M-1 2 A 8.000 BUTFLY. A PO C YES FC EC QR FS QR PI 2Y SLT-1 2Y VR-4 & VR-16 FCV-25-21 H-2 2 A 8.000 BUTFLY A PO C YES FC EC QR FS QR Pl 2Y SLT-1 2Y VR-4 & VR-16 FCV-25-26 N-2 2 A 8.000 BUTFLY A PO C YES FC EC QR FS QR PI 2Y SLT-1 2Y VR-4 & VR-16 FCV-25-29 K-3 2 B 4.000 BUI'FLY A HO C YES FAI EC QR Pl 2Y FCV-25-30 H-4 2 8 20.000 BUTFLY A HO C YES FAI EC QR EO QR Pl 2Y FCV-25-31 J-4 2 B 20.000 BUTFLY A HO C YES FAI EC QR EO QR PI 2Y FCV-25-32 H-4 2 B 30.000 BUTFLY A HO 0 YES FAI EC QR EO QR PI 2Y FCV-25-33 J-4 2 8 30.000 BUTFLY' HO 0 YES FAI EC QR EO QR PI 2Y

FLORIDA POWER AND LIGHT COHPANY REVISION: 0 VALVE TABLES DATE: 07/16/93 Saint Lucia Nuclear Plant - Unit 2 PAGE  : 52 P 8 ID: 2998-G-879 SH 3 (cont) SYSTEM: HVAC ACT ~ NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REHARKS FCV-25-34 H-2 2 B 4.000 BUTFLY A HO C YES FAI EC QR PI 2Y FCV-25-36 N-1 2 A 8.000 BUTFLY A PO C YES FC EC QR FS QR PI 2Y SLT-1 2Y VR-4 II VR-16 V-25-23 J-4 2 C 24.000 CHECK A S/A C NO CV/0 QR V-25-24 H-4 2 C 24.000 CHECK A S/A C NO CV/0 QR

Appendix D Valve Program Requests for Relief

Revision 0 07/16/93 RELIEF REQUEST NO. VR-1 SYSTEM:

Various COMPONENTS'ny valves tested during cold shutdown conditions.

CATEGORY:

Various FUNCTION:

Various SECTION XI REQUIREMENT:

Valves shall be exercised ... unless such operation is not practical during plant operation. If only limited operation is practical during plant operation, the valve shall be part-stroke exercised during plant operation and full stroke exercised during cold shutdowns. Full stroke exercising during cold shutdowns for all valves not full-stroke exercised during plant operation shall be on a frequency determined by the intervals between shutdowns as follows:

For intervals of 3 months or longer exercise during each shutdown. (IWV-3412, IWV-3415 and IWV-3522)

BASIS FOR RELIEF'n many instances testing of all valves designated for testing during cold shutdown cannot be completed due to the brevity of an outage. It has been the policy of the NRC that if testing commences in a reasonable time and reasonable efforts are made to test all valves, then outage extension is not required when the only reason is to provide the opportunity for completion of valve testing.

ASME/ANSI OMa-1987, Operation and Maintenance Of Nuclear Power Plants, Part 10 (Paragraphs 4.2.1.2 and 4.3.2.2) recognizes this issue and allows deferred testing as set forth below.

D-1

Revision 0 07/16/93 RELIEF REQUEST NO. VR-1 (cont.)

ALTERNATE TESTING:

For those valves designated t'o be exercised or tested during cold shutdown, exercising shall commence as soon as practical after the plant reaches a stable cold shutdown condition, as defined by the applicable Technical Specification, but no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdowns If the outage is sufficiently long enough for the testing of all the cold shutdown valves, then the 48-hour requirement need not apply. If the 48-hour requirement is waved, then all cold shutdown valves must be tested during the outage.

Valve testing need not be performed more often than once every cold shutdown except as provided for in IWV-3417(a).

Completion of all valve testing during a cold shutdown outage is not required if the length of the shutdown period is insufficient to complete all testing. Testing not completed prior to startup may be rescheduled for the next shutdown in a sequence such that the test schedule does not omit nor favor certain valves or groups of valves.

The program tables identify those valves to which cold shutdown testing applies. Refer to Appendix E for discussion of the justification for allowing cold shutdown vs. quarterly testing for the various affected valves.

D-2

Revision 0 07/16/93 RELIEF REQUEST NO. VR-2 SYSTEM Safety injection (2998-G-078, Sh. 131 & 132)

COMPONENTS:

V-3217 V-3227 V-3237 V-3247 V-3258 V-3259 V-3260 V-3261 V-3215 V-3225 V-3235 V-3245 V-3524 V-3525 V-3526 V-3527 CATEGORY:

A/C (Check Valves)

FUNCTION:

These check valves open to provide for high-pressure and low-pressure safety injection to the RCS. Each of these valves is designated as a pressure isolation valve (PIV) and provides isolation of safeguard systems from the RCS.

SECTION XI REQUIREMENT:

The leakage rate for valves 6-inches or greater shall be evaluated per Subsection IWV-3427(b).

BASIS FOR RELIEF:

Leak testing of these valves is primarily for the purpose of confirming their capability of preventing over-pressurization and catastrophic failure of the safety injection piping and components. In this regard, special leakage acceptance criteria is established and included in the St. Lucie 2 Technical Specifications (Table 3.4-1) that addresses the question of valve integrity in a more appropriate manner for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing. Specifically applying the trending requirements of IWV-3427 (b) would result in frequent and excessive maintenance of these valves. The continuation of a strict leakrate acceptance criteria and more frequent testing than specified by the Code gives a high degree of assurance that these valves will satisfactory perform their safety function.

D-3

Revision 0 07/16/93 RELIEF REQUEST NO. VR-2 (cont.)

ALTERNATE TESTING'he leakage rate acceptance criteria for these valves will be established per the St. Lucie Unit 2 Technical Specifications, Table 3.4-1. Leakage rates greater than 1.0 gpm are unacceptable.

Each of the Reactor Coolant System Pressure Isolation Valve check valve shall be demonstrated operable by verifying leakage to be within its limits:

At least once per 18 months.

2. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and testing has not been performed in the previous 9 if leakage months.
3. Prior to returning the valve to service following maintenance, repair or replacement work on the valve.

4, Following valve actuation due to flow through the valve(s) while in MODES 1,2,3, or 4:

A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying valve closure, and B. Within 31 days by verifying leakage rate.

D-4

Revision 0 Qe 07/16/93 RELIEF REQUEST NO. VR-3 SYSTEM:

Various COMPONENTS:

Various CATEGORY:

Various FUNCTION:

This is a generic request for relief SECTION XI REQUIREMENT If, for power-operated valves, an increase in stroke time of 50% or more for valves with full-stroke times less than or equal to 10 seconds is observed, the test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed (IWV-3417(a))

BASIS FOR RELIEF:

The stroke time measurements taken during testing of fast-acting valves (those less than 2 seconds) are subject to considerable variation due to conditions unrelated to the material condition of the valve (eg. test conditions, operator reaction time). In accordance with Generic Letter 89-04, Position 6, an alternate method of evaluating stroke times is considered acceptable.

ALTERNATE TESTING'he stroke time evaluation for those valves designated in the Plant Test Procedures as "fast-acting" will not account for successive increases of measured stroke time per IWV-3417(a) with the change in test frequency as required. In lieu of this, the assigned maximum limiting value of stroke time will be established at 2 seconds. Upon exceeding the 2-second limit, the valve will be declared inoperable and corrective action taken in accordance with IWV-3417(b) .

D-5

0 RELIEF REQUEST NO. VR-4 Revision 07/16/93 0

SYSTEM:

Primary Containment COMPONENTS:

PENETRATION NO. DRAWING NO. VALVES 10 2998-G-878 FCV-25-4 and Blank Flange 11 2998-G-878 FCV-25-2 and FCV-25-3 23 2998-G-083 HCV-14-1 and HCV-14-7 24 2998-G-083 HCV-14-2 and HCV-14-6 41 2998-G-078 Sh 130 SE-03-2A and SE-03-2B 54 2998-G-091 V-00-101 and Blank Flange 56 2998-G-879 FCV-25-36 and FCV-25-26 57 2998-G-879 FCV-25-20 and FCV-25-21 CATEGORY' or A/C FUNCTION'hese valves are closed to provide containment isolation.

SECTION XI REQUIREMENT:

Category A valves shall be seat leak tested and a maximum permissible leakage rate shall be specified. Individual valve leakage rates shall be evaluated per IWV-3426 and IWV-3427. (IWV-3426, IWV-3427, NRC Generic Letter 89-04)

BASIS FOR RELIEF:

For several containment systems, individual leakage rate tests are impractical due to the configuration of the system's piping and components. In these cases it is customary to perform leakage tests with the test volume between valves in series or behind valves in parallel paths'-6

Revision 0 07/16/93 RELIEF REQUEST NO. VR-4 (cont.)

BASIS FOR RELIEF (cont.):

In these cases'here individual valve testing is impractical, the valves will be leak tested simultaneously in multiple valve arrangements. A maximum permissible leakage rate will be applied to each combination of valves or valve and blank flange'n each of the valve pairs, the two valves are equal in size and type, and the leakage limit is in proportion to their size. The blank flanges used in testing penetrations 10 and 54 have diameters similar in size to their associated valves FCV-25-4 and V-00101. The leakage limit assigned to each pair is such that excessive leakage through any valve, or flange, would be detected and the appropriate corrective action taken.

ALTERNATE TESTING:

The above stated valves and blank flanges will be leak rate tested in pairs. Leakage measurements from tests of multiple valves or blank flanges will be evaluated in accordance with IWV-3426 and IWV-3427.

D-7

Revision 0 07/16/93 RELIEF REQUEST NO. VR-5 SYSTEM:

Chemical and Volume Control (2998-G-078 Sh 121)

COMPONENTS:

V-2177 V-2190 V-2191 V-2526 CATEGORY:

FUNCTION:

V-2177 and V-2526 open to provide a flow path for emergency boration from the boric acid makeup pumps to the suction of the charging pumps. Likewise, V-2190 opens to provide a flow path for emergency boration via gravity drain from the boric acid makeup tanks to the suction of the charging pumps. V-2190 closes to prevent recirculation to the boric acid makeup tanks when the boric acid makeup pumps are in operation. Valve V-2191 opens to provide a flow path from the refueling water tank (RWT) to the suction of the charging pumps as an alternate supply of borated water for boration.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF Testing these valves in the open direction requires the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS. A rapid insertion of negative reactivity could result in a rapid RCS cooldown and depressurization and possibly a plant trip.

D-8

Revision 0 07/16/93 RELIEF REQUEST NO. VR-5 (cont.)

BASIS FOR RELIEF (cont.):

During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-boration of the RCS. The waste management system would also be overburdened by the large amounts of RCS coolant that would require processing to decrease the boron concentration.

Typically, the boron concentration is increased for shutdown margin during cooldown and prior to reaching cold shutdown conditions. This is the only practical time to perform the partial stroke exercise test since boration during shutdown and startup is undesirable. In the event that circumstances prohibit testing during cooldown, testing for that cold shutdown may be deferred to the next cooldown evolution.

ALTERNATE TESTING:

Check valve V-2190 will be verified closed quarterly.

Each of these valves will be part stroke exercised once during each cold shutdown per VR-1 and full stroke exercised during each reactor refueling outage. If exercising during the cooldown evolution is impractical, testing for that cold shutdown period may be deferred.

D-9

Revision 0 07/16/93 RELIEF REQUEST NO. VR-6 SYSTEM:

Chemical and Volume Control System (2998-G-078, Sh 121)

COMPONENT:

V-2443 V-2444 CATEGORY'UNCTION:

These valves open to provide a flow path from the boric acid makeup pumps to the emergency boration header. They close to prevent recirculation flow through an idle pump.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full-stroke testing these valves requires operating the boric acid makeup pumps at or near rated flow and verifying full accident flow through each valve. Such testing would cause the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS. This rapid insertion of negative reactivity would result in a rapid RCS cooldown and depressurization. A large enough boron addition would result in an unscheduled plant trip and a possible initiation of Safety Injection Systems.

During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-boration of the RCS. The waste management system would be overburdened by the large amounts of RCS coolant that would require processing to decrease its boron concentration.

Revision 0 07/16/93 RELIEF REQUEST NO. VR-6 (cont.)

BASIS FOR RELIEF (cont.):

A second circuit that circulates water to the VCT has flow rate measuring instrumentation ins'tailed however it is limited to approximately 30 gpm. During an accident, either pump's discharge check valve must be able to pass a minimum flow capable of matching the demand of the two running charging pumps (greater than 80 gpm.).

ALTERNATE TESTING:

Each of these valves will be partial stroke exercised (open and closed) quarterly.

During testing of the boric acid makeup pumps performed during each reactor refueling (See Relief Request PR-5),

system flow rate will be measured to verify full stroke (open) of these valves.

Revision 0 07/16/93 RELIEF REQUEST NO. VR-7 SYSTEM:

Safety Injection (2998-G-078 Sh 130)

COMPONENTS:

V-07000 V-07001 CATEGORY:

FUNCTION'hese valves open to provide flow paths from the RWT to the suction of the associated low-pressure safety injection pump.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising these valves to the open position requires injection into the RCS via the LPSI pumps . During plant operation this is precluded because the LPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. At cold shutdown, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling functions Thus, the only practical opportunity for testing these valves is during refueling outages when water from the RWT is used to fill the refueling cavity.

ALTERNATE TESTING:

These valves will be partial-flow exercised during quarterly testing of the LPSI pumps via the minimum flow circuit and full-flow exercised during each reactor refueling outage.

Revision 0 07/16/93 RELIEF REQUEST NO. VR-8 SYSTEM:

Safety Injection (2998-G-078 Sh 130)

COMPONENTS'-3401 V-3410 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the RWT and the containment sump to the suction of the associated high-pressure safety injection pumps (HPSI).

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522 'IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising these valves to the open position requires injection via the HPSI pumps into the RCS. During plant operation this is precluded because the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. During cold shutdown conditions, operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4 ALTERNATE TESTING These valves will be partial-flow exercised during quarterly testing of the HPSI pumps via the minimum flow circuit and full-flow exercised during each reactor refueling outage.

This alternate testing satisfies the requirement of Generic Letter 89-04, Position 1.

Revision 0 07/16/93 RELIEF REQUEST NO. VR-9 SYSTEM:

Safety Injection (2998-G-078 Sh 130)

COMPONENTS:

V-3414 V-3427 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the respective HPSI pumps to the high-pressure safety injection headers.

They close to prevent recirculation through an idle pump.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising these valves to the open position requires injection into the RCS via the HPSI pumps. During plant operation this is precluded because the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. During cold shutdown conditions, full flow operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3 ' '

flow exercising of these valves can be performed by

'artial one of the following two methods: when the HPSI pump is used to refill a SIT or when a HPSI pump is recirculated back through the SIT to RWT drain line. Partial-stroke exercising the check valves by filling a SIT can not readily be used because the acceptable SIT level band, specified by the Technical Specifications, is very narrow. The SIT are only refilled on an as needed basis; therefore, the partial flow test cannot readily be incorporated into a quarterly test.

Revision 0 07/16/93 RELIEF=REQUEST NO. VR-9 (cont ~ )

BASIS FOR RELIEF: (cont.)

Partial-stroke exercising of these check valves quarterly can not be performed by using the SIT to RWT drain line.

This method requires that the containment isolation valves, one of them a manual valve, be opened to complete the flow path. This would constitute a breach of containment integrity, as defined in Technical Specifications 3.6.1.1, and therefore use of this flow path is precluded in Modes 1, 2, 3, and 4.

ALTERNATE TESTING:

These valves will be verified closed quarterly and full-flow exercised to the open position during each reactor refueling outage.

These valves will be part-stroked open during cold shutdown per VR-1.

D-15

Revision 0 07/16/93 RELIEF REQUEST NO. VR-10 SYSTEM:

Safety Injection (2998-G-078 Sh 130)

COMPONENTS:

V-3522 V-3547 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the high-pressure safety injection pumps to the RCS for hot-leg injection. Should the normal charging header become disabled, these valves are required to close to direct charging flow to t he RCS via the HPSI headers.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating a high pressure safety injection (HPSI) pump and injecting into the reactor coolant system'through the hot leg injection system. At power operation this is not possible because the HPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. During cold shutdown conditions, full flow operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.

D-16

Revision 0 07/16/93 RELIEF REQUEST NO. VR-10 (cont.)

BASIS FOR RELIEF: (cont.)

Partial-stroke exercising of these check valves quarterly can not be performed by using the SIT to RWT drain line.

This method requires that the containment isolation valves, one of them a manual valve, be opened to complete the flow path. This would constitute a breach of containment integrity, as defined in Technical Specifications 3.6.1.1, and therefore use of this flow path is precluded in Modes 1, 2, 3, and 4.

ALTERNATE TESTING't least once during each reactor refueling outage these valves will be full-stroke exercised to the open position.

These check valves will be partial-stroke exercised to the open position and subsequently stroked closed during cold shutdowns per VR-1.

This alternate testing satisfies the requirement of Generic Letter 89-04, Position 1.

D-17

Revision 0 07/16/93 RELIEF REQUEST NO. VR-11 SYSTEM Safety Injection (2998-G-078 Sh 131)

COMPONENTS:

V-3113 V-3133 V-3143 V-3766 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the high-pressure safety injection headers to the RCS.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating a high pressure safety injection (HPSI) pump at nominal accident flow rate and injecting into the reactor coolant system. At power operation this is not possible because the HPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system cold shutdown conditions, full flow operation of the prcssure'uring HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.

D-18

Revision 0 07/16/93 RELIEF REQUEST NO. VR-11 (cont.)

BASIS FOR RELIEF (cont.):

Partial flow exercising of these valves is performed whenever its associated SIT is-refilled. The acceptable SIT level band specified by the Technical Specification is very narrow. The SITs are only refilled on an as needed basis; therefore, the partial flow test cannot readily be incorporated into a quarterly test.

Partial-stroke exercising of these check valves quarterly can not be performed by using the SIT to RWT drain line.

This method requires that the containment isolation valves, one of them a manual valve, be opened to complete the flow path. This would constitute a breach of containment integrity, as defined in Technical Specifications 3.6.1.1, and therefore use of this flow path is precluded in Modes 1, 2, 3, and 4.

ALTERNATE TESTING:

These valves will be partial flow exercised during cold shutdown periods per VR-1.

At least once during each reactor refueling outage these valves will be full-stroke exercised to the open position.

D-19

Revision 0 07/16/93 RELIEF REQUEST NO. VR-12 SYSTEM:

Safety Injection (2998-G-078 Sh 131)

COMPONENTS:

V-3524 V-3525 V-3526 V-3527 CATEGORY:

A/C FUNCTION:

These valves open to provide flow paths from the high-pressure safety injection pumps to the RCS for hot leg injection and close to isolate the safety injection headers from the high pressure of the reactor coolant system.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating a high pressure safety injection (HPSI) pump at nominal accident flow rate and injecting into the reactor coolant system. At power operation this is not possible because the HPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure.

During cold shutdown conditions, full flow operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.

D-20

Revision 0 07/16/93 RELIEF REQUEST NO. VR-12 (cont.)

BASIS FOR RELIEF (cont.):

Partial-stroke exercising of check valves V-3524 and V-3526 quarterly can not be performed by using the SIT to RWT drain line. This method requires that the containment isolation valves, one of them a manual valve, be opened to complete the flow path. This would constitute a breach of containment integrity, as defined in Technical Specifications 3.6.1.1, and therefore use of this flow path is precluded in Modes 1, 2, 3, and 4.

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. Performing leak tests of V-3524 and V-3526 involves a considerable effort. The test connection for these valves are located in a high radiation area in the pipe penetration room, and one of the two connections is located over 12 feet above the floor. Testing during operation would constitute an unreasonable burden on the plant staff.

The other check valves, V-3525 and V-3527, have upstream pressure alarms. Should either valve leak by, the pressure instruments would detect the increase and alarm in the control room when the alarm setpoint is exceeded.

ALTERNATE TESTING:

These check valves will be partial-stroke exercised to the open position and subsequently stroked closed during cold shutdowns per VR-1.

These valves will be full-stroke exercised to the open position at least once during each reactor refueling outage.

This satisfies the requirements of Generic Letter 89-04, Position 1.

At least once every 18 months these valves will be verified to close in conjunction with PIV leak testing (see VR-2).

In addition, V-3525 and V-3527 will be leak tested if the upstream pressure monitors indicate alarm during normal operation.

Revision 0 07/16/93 RELIEF REQUEST NO. VR-13 SYSTEM:

Safety Injection (2998-G-078 Sh 132)

COMPONENTS:

V-3215 V-3225 V-3235 V-3245 CATEGORY'/C FUNCTION:

These valves open to provide flow paths from the safety injection tanks to the RCS and close to isolate the tanks from the high pressure of the reactor coolant system and the safety injection headers.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising of these valves would require injecting from a tank under nominal pressure into a de-pressurized reactor coolant system. At power operation this is not possible because the SIT pressure is insufficient to overcome reactor coolant system pressure.

Under a large break LOCA accident conditions, the maximum (peak) flow rate through these valves would be approximately 20,000 gpm. During cold shutdown or refueling outages, the required test conditions for developing this full accident flow cannot be established.

D-22

Revision 0 07/16/93 RELIEF REQUEST NO. VR-13 (cont.)

BASIS FOR RELIEF (cont.):

The SIT discharge isolation valves are motor operated valves with a nominal stroke time of 52 seconds. Therefore, the isolation valves cannot be used to simulate the LOCA flow conditions by opening them with a full or partially pressurized SIT. The resulting discharge flow rate would only increase gradually due to the long stroke time of the discharge isolation valve. The flow rate would not be anywhere near the expected peak blowdown rate of 20,000 gpm.

expected during a large break LOCA.

FP&L has reviewed the operating and maintenance history of these valves and similar valves used throughout the industry under comparable conditions. Based on these reviews, there is no evidence of valve degradation with respect to their ability to open and satisfactorily pass the required flow.

It is apparent from the failure data that the primary mode of failure is related to valve leakage both past the seat and external through the body-bonnet and hinge pin gasket joints. It should also be noted that these valves are not subjected to any significant flow during plant operation as well as maintenance periods; thus it is unlikely that these valves would experience any service-related damage or wear.

Although check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition, due to the difficulties associated with these maintenance activities, it should only be performed under the maintenance program at a frequency commensurate with the valve type and service. In this light, FPGL considers the frequency of inspection for these valves of once each 10-year inspection interval to be adequate to ensure the continued operability of these valves'hese are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. The back flow tests are performed as part of the pressure isolation testing per VR-2.

D-23

Revision 0 07/16/93 RELIEF REQUEST NO. VR-13 (cont.)

ALTERNATE TESTING:

At least once during each ISI (10 year) inspection interval each of these valves will be disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the remaining three valves will be inspected during the same outage. Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly.

These valves will be verified closed in conjunction with PIV leak testing. See VR-2 for PIV testing frequency.

D-24

Revision 0 po 07/16/93 RELIEF REQUEST NO. VR-14 SYSTEM Safety Injection (2998-G-078 Sh 132)

COMPONENTS:

V-3217 V-3227 V-3237 V-3247 CATEGORY:

A/C FUNCTION:

These valves open to provide flow paths from the safety injection headers to the RCS and close to isolate the headers from the high pressure of the reactor coolant system.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising of these valves would require injecting from a tank under nominal pressure into a de-pressurized reactor coolant system. At power operation this is not possible because the SIT pressure is insufficient to overcome reactor coolant system pressure.

Under a large break LOCA accident conditions, the maximum (peak) flow rate through these valves would be approximately 20,000 gpm. During cold shutdown or refueling outage the required test conditions for developing this full accident flow cannot be established.

D-25

Revision 0 07/16/93 RELIEF REQUEST NO. VR-14 (cont.)

BASIS FOR RELIEF (cont.):

The SIT discharge isolation valves are motor operated valves with a nominal stroke time of 52 seconds'herefore, the isolation valve cannot be used to simulate the LOCA flow conditions by opening it with a full or partially pressurized SIT. The discharge flow rate would only increase gradually due to the long stroke time of the discharge isolation valve. The flow rate would not be anywhere near the expected peak blowdown rate of 20,000 gpm.

expected during a large break LOCA.

FP&L has reviewed the operating and maintenance history of these valves and similar valves used throughout the industry under comparable conditions'hese four valves have been in operation in Unit 2 since the plant startup in 1983. A total of 3 plant work orders have been initiated for work on these valves. Of the three work orders, one was to repair seat leakage identified by a seat leakage test and the other two were for disassembly and inspection per Generic Letter 89-04. A search of the Nuclear Plant Reliability Data System for problems with valves similar to these revealed 12 reports 7 due to seat leakage and the remaining 5 were related to gasket leaks. Based on these reviews there is no evidence of valve degradation with respect to their ability to open and satisfactorily pass the required flow. It apparent from the failure data that the primary mode of is failure is related to valve leakage either past the seat or externally through the body-bonnet and hinge pin gasket joints.

In order to disassemble and inspect these valves , the reactor coolant system must be placed in mid-loop or "reduced inventory" condition for several days. In response to issues raised in NRC Generic Letter 88-17, FPsL is concerned about continued operations with the plant in a condition of "reduced inventory." During these periods, the risk of over-heating the core is increased due to the higher probability of an incident where shutdown cooling is lost.

This risk is compounded by the reduced volume of water available to act as a heat sink should cooling be lost.

Since 1982 there have been at least six (6) reported events in the industry where cooling flow was lost while a plant was in a "reduced inventory" condition.

Revision 0 07/16/93 RELIEF REQUEST NO. VR-14 (cont.)

BASIS FOR RELIEF (cont.):

Although check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition, due to the difficulties associated with these maintenance activities, it should only be performed under the maintenance program at a frequency commensurate with the valve type and service. Given the lack of evidence that these valves are experiencing significant failures with respect to their capability of passing the design flow rates and the apparent sensitivity of the valves to leak testing, a frequency of inspection for these valves of once each 10-year inspection interval is adequate to ensure the continued operability of these valves.

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. The back flow testing is performed as stated in VR-2 ~

In addition to periodic leak testing, the upstream pressure of each valve is monitored by a pressure indicator and alarm. Should any of these valves experience even minor leakage, the upstream pressure alarm would alert plant personnel.

ALTERNATE TESTING:

During cold shutdown and refueling periods, each of these valves will be partial-stroke exercised with approximately 1,750 gpm (8 percent of maximum accident flow) using the LPSI pumps per Relief Request VR-l.

At least once during each ISI (10 year) inspection interval each of these valves will be disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the remaining three valves will be inspected during the same outage. Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following d'isassembly.

These valves will be verified closed in conjunction with PIV leak testing. See VR-2 for PIV testing frequency.

D-27

Revision 0 07/16/93 RELIEF REQUEST NO. VR-15 SYSTEM:

Safety Injection (2998-G-078 Sh 132)

COMPONENTS'-3258 V-3260 V-3259 V-3261 CATEGORY:

A/C FUNCTION:

These valves open to provide flow paths from the high/low pressure safety injection headers to the RCS and close to isolate the headers from the high pressure of the reactor coolant system.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Since no full flow recirculation path exists, full stroke exercising of these valves would require operating a low pressure safety injection (LPSI) pump at nominal accident flow rate and injecting into the reactor coolant system. At power operation this is not possible because the LPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure.

Partial flow exercising of these valves is performed when ever its associated SIT is refilled. These valves are Pressure Isolation Valves which requires that they are verified closed and leak tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following flow through them. The acceptable SIT level band specified by the Technical Specification is very narrow. The SITs are only refilled on an as needed basis; therefore, the partial flow test cannot readily be incorporated into a quarterly test.

D-28

Revision 0 07/16/93 RELIEF REQUEST NO. VR-15 (cont.)

BASIS FOR RELIEF (cont.):

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test.

ALTERNATE TESTING:

These valves will be partial flow tested and then verified closed whenever its associated SIT is refilled.

These valves will be full-stroke exercised to the open position during cold shutdown periods per Relief Request VR-1.

These valves will be verified closed in conjunction with PIV leak testing. See VR-2 for PIV testing frequency.

D-29

Revision 0 07/16/93 RELIEF REQUEST NO. VR-16 SYSTEM:

Primary Containment COMPONENTS'alves 6-inches NPS and larger subject to leakage rate testing per 10CFR50, Appendix J.

CATEGORY'/C (Check Valves)

A (Motor-operated valves)

FUNCTION:

Each of these valves is designated as a containment isolation valve maintaining the leakrate integrity of the primary containment in the case of an accidents SECTION XI REQUIREMENT:

The leakage rate for valves 6-inches nominal pipe size and larger shall be evaluated per Subsection IWV-3427(b). (IWV-3521)

BASIS FOR RELIEF'he usefulness of applying this requirement does not justify the burden of compliance. This position is supported by the Generic Letter 89-04, Position 10.

ALTERNATE TESTING:

Leakrate test results for containment isolation valves six (6)inches nominal pipe size and greater will be evaluated per IWV-3426 and IWV-3427(a) however, the requirements of IWV-3427(b) will not be applied. This satisfies the requirements of Generic Letter 89-04, Position 10.

D-30

Revision 0 07/16/93 RELIEF REQUEST NO. VR-17 WITHDRAWN (Rev 0, 07/16/93)

D-31

Revision 0 07/16/93 RELIEF REQUEST NO. VR-18 SYSTEM:

Makeup Water (2998-G-084)

COMPONENT:

V-15328 CATEGORY'/C FUNCTION:

This valve closes to provide primary containment for the penetration related to the makeup water supply line to the containment building.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

This is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. Performing such a test demands that the makeup water supply line be isolated. This effectively isolates the sole supply of fire water to the containment which is unacceptable under any plant conditions. Thus, prior to leaktesting in this manner an alternate firewater source must be established by rigging several temporary fire hoses through the maintenance hatch to the various fire fighting stations in the containment building. This is not possible during normal operation when primary containment is required and would constitute an undue burden on plant personnel during cold shutdowns.

ALTERNATE TESTING:

At least once every refueling outage, this valve will be verified to close in conjunction with the Appendix J leak testing program.

0 D-32

Revision 0 07/16/93 RELIEF REQUEST NO. VR-19 SYSTEM:

Instrument Air (2998-G-085, Sh 2)

COMPONENT'-18195 CATEGORY'/C FUNCTION:

This valve closes to provide primary containment for the penetration related to the instrument air supply line to the containment building.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF'his is a simple check valve'with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. Such a test necessates isolation of all instrument air to the containment. There are over 50 valves, instruments, and controllers supplied by this one line.

During a normal refueling outage when leak testing is normally performed, an alternate instrument air compressor must be connected to the isolated section of the instrument air line in order to supply air to critical air-operated components. The supply hose from the air compressor to the instrument air line is typically routed through the containment maintenance hatch.

During normal plant operation this is not practical due to the many critical operational components supplied by the instrument air system, the requirement to maintain primary containment integrity, and the potential for unacceptable plant transients.

D-33

Revision 0 07/16/93 RELIEF REQUEST NO. VR-19 (cont.)

BASIS FOR RELIEF (cont.)

During cold shutdown, the activities associated with entry into the containment building, securing all instrument air inside the containment, and opening the maintenance hatch to provide the alternate air supply are extensive and would likely result in an extension of any interim outage (cold shutdown period). Thus testing this valve during cold shutdown periods is considered to be an unreasonable burden on the plant staff and not commensurate with the potential gain in plant safety afforded by performance of this test.

ALTERNATE TESTING:

At least once every refueling outage, this valve will be verified to close in conjunction with the Appendix J leak testing program.

D-34

Revision 0 07/16/93 RELIEF REQUEST NO. VR-20 SYSTEM:

Containment Spray (2998-G-088)

COMPONENTS:

V-07119 V-07120 CATEGORY:

FUNCTION'hese valves open to provide flow paths from the refueling water tank (RWT) to the containment spray and safety injection suction headers.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR REL1EF'ull stroke exercising of these valves would require simultaneous operation of one HPSI pump and one LPSI pump injecting into the RCS, and one containment spray pump injecting into its spray header to verify the maximum design accident flow. Such a test is not practical during any plant operational modes.

ALTERNATE TESTING'uring quarterly pump testing each of these valves will be partial-stroke exercised via recirculation through the minimum flow test circuits of the various systems. The valves will also be partial-stroke exercised during the series of pump substantial flow tests and check valve exercises performed each refueling outage.

D-35

Revision 0 07/16/93 RELIEF REQUEST NO. VR-20 (cont.)

ALTERNATE TESTING (cont.):

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be re-initiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal.

D-36

Revision 0 07/16/93 RELIEF REQUEST NO. VR-21 SYSTEM:

Containment Spray (2998-G-088)

COMPONENTS:

V-07129 V-07143 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the respective containment spray pump to the containment spray headers.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

-BASIS FOR RELIEF'ull stroke exercising of these valves would require operating each containment spray pump at nominal accident flow rate. Exercising these valves via the normal containment spray flow path would result in spraying down the containment an unacceptable option. The only other practical flow path available for such a test requires pumping water from the refueling water tank (RWT) to the reactor coolant system (RCS) via the shutdown cooling loops.

During plant operation, the containment spray pumps cannot develop sufficient discharge pressure to overcome RCS prcssure't cold shutdown, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function.

D-37

Revision 0 07/16/93 RELIEF REQUEST NO. VR-21 (cont.)

ALTERNATE TESTING:

Each of these valves will be partial-stroke exercised quarterly in conjunction with testing of the containment spray pumps via the minimum flow test line.

During each refueling outage, each valve will be exercised at least once to demonstrate full stroke capability.

D-38

Revision 0 07/16/93 RELIEF REQUEST NO. VR-22 SYSTEM:

Containment Spray (2998-G-088)

COMPONENTS:

V-07172 V-07174 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the containment sump to the containment spray and safety injection suction headers during recirculation.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

There are no provisions for full or partial flow exercising these valves. In order to pass full flow through these valves, the containment'sump must be flooded and followed by simultaneous operation of one HPSI pump injecting into the RCS and one containment spray pump injecting into its spray header. Such a test is not practical during any plant operational mode.

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be repeated. This satisfies the requirements of Generic Letter 89-04, Position 2 and is considered to be approved upon submittal.

D-39

o RELIEF, REQUEST NO. VR-23 Revision 07/16/93 0

SYSTEM'ontainment Spray (2998-6-088)

COMPONENTS:

V-07192 V-07193 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the respective containment spray headers to the containment spray rings.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Full stroke exercising'f these valves would require operating each containment spray pump at nominal accident flow rate. Since exercising these valves through the normal containment spray flow path would result in spraying down the containment, this is considered impractical.

Since flow through these valves is not possible, non-intrusive test methods, should they become approved, would not work on these check valves'-40

Revision 0 07/16/93 RELIEF REQUEST NO. VR-23 (cont.)

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected,'and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be re-initiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal'-41

Revision 0 07/16/93 RELIEF REQUEST NO. VR-24 SYSTEM:

Containment Spray (2998-G-088)

COMPONENTS'-07256 V-07258 CATEGORY:

FUNCTION:

These valves open to provide flow paths from the hydrazine pumps to the respective containment spray pump suction header.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Testing these valves using the only flow path available (via the hydrazine pumps) would contaminate the containment spray system and refueling water tank with hydrazine. Each of the hydrazine pumps discharge through its check valve into the suction piping of its containment spray pump. The hydrazine would then be pumped to the RWT during the quarterly containment spray pump Code test using the mini-flow recirculation line. Continued testing would build up the concentration of hydrazine in the RWT and deplete the level in its storage tank.

ALTERNATE TESTING'uring each reactor refueling outage these valves will be full-stroke exercised.

D-42

Revision 0 07/16/93 RELIEF REQUEST NO. VR-25 WITHDRAWN (Rev 0, 07/16/93)

D-43

Revision 0 07/16/93 RELIEF REQUEST NO. VR-26 WITHDRAWN (Rev 0, 07/16/93)

D-44

Revision 0 07/16/93 RELIEF REQUEST NO. VR-27 SYSTEM:

Feedwater System (2998-G-080, Sh 2)

COMPONENTS'-09303 V-09304 V-09305 CATEGORY'UNCTION:

These valves open to provide flow paths, from the auxiliary feedwater pump discharge to the condensate storage tank to ensure adequate pump cooling during low flow conditions.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

There is no flow rate instrumentation available to verify valve full-stroke exercising of these valves as required by Generic Letter 89-04, Position 1.

ALTERNATE TESTING:

During quarterly pump testing each of these valves will be partial-stroke exercised'ia recirculation through the minimum flow test circuits with no flow measurements.

D-45

Revision 0 07/16/93 RELIEF REQUEST NO. VR-27 (cont.)

ALTERNATE TESTING (cont.):

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other two valves will be inspected during the same outage, after which the rotational inspection schedule will be re-initiated. This satisfies the requirements of Generic Letter 89-04, Position 2.

D-46

0 0 RELIEF REQUEST NO. VR-28 Revision 07/16/93 0

SYSTEM:

Safety Injection System (2998-G-078, Sh 130)

COMPONENTS:

V-3104 V-3105 CATEGORY'UNCTION:

These valves open to provide for mini-flow recirculation flow paths from the low pressure safety injection pumps to the refueling water tank. This minimum flow through the respective pumps removes pump heat in the event they are operating under low or no flow conditions. The valves close to prevent recirculation through the idle pump, and to prevent overpressurization of the LPSI piping from the discharge pressure of the HPSI pump.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

There is no flow rate instrumentation available to verify valve full-stroke exercising as required by Generic Letter 89-04, Position 1.

ALTERNATE TESTING:

During quarterly pump testing each of these valves will be partial-stroke exercised (open) via recirculation through the minimum flow test circuits with no flow measurements.

D-47

Revision 0 07/16/93 RELIEF REQUEST NO. VR-28 (cont.)

ALTERNATE TESTING (cont.):,

During each reactor refueling outage these two valves will be flow tested. The test will calculate the flow through the mini-flow line by draining the reactor coolant system through the line while observing the pressurizer level drop or refueling water tank level increase. The level change divided by the time can be used to verify the full flow exercise of the two check valves.

D-48

Revision 0 07/16/93 RELIEF REQUEST NO. VR-29 SYSTEM:

Safety Injection (2998-G-078, Sh. 131)

COMPONENTS:

V-3480 V-3651 V-3481 V-3652 CATEGORY:

FUNCTION:

The motor-operated valves open for residual heat removal recirculation during shutdown. Each of these valves is designated as a pressure isolation valve (PIV) and provides isolation of safeguard systems from the RCS.

SECTION XI REQUIREMENT:

The leakage rate for valves 6-inches or greater shall be evaluated per Subsection IWV-3427(b). (IWV-3521)

BASIS FOR RELIEF:

Leak testing of these valves is primarily for the purpose of confirming their capability of preventing over-pressurization and catastrophic failure of the low pressure safety injection piping and components. In this regard, special leakage acceptance criteria is established and included in the St. Lucie 2 Technical Specifications (Table 3.4-1) that addresses the question of valve integrity in a more appropriate manner for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing.

D-4 9

Revision 0 07/16/93 RELIEF REQUEST NO. VR-29 (cont.)

ALTERNATE TESTING'he leakage rate acceptance criteria for these valves will be established per the St. Lucie Unit 2 Technical Specifications, Table 3.4-1.

1. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.
2. Leakage rates greater than 1.0 gpm, but less than or equal to 5.0 gpm, are unacceptable if the latest measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.
3. Leakage rates greater than 5.0 gpm are unacceptable.

Each Reactor Coolant System Pressure Isolation Valve motor-operated valves shall be demonstrated operable by verifying leakage to be within its limits:

At least once per 18 months, and

2. Prior to returning the valve to service following maintenance, repair, or replacement work on the valve.

D-50

Revision 0 07/16/93 RELIEF REQUEST NO. VR-30 SYSTEM:

Safety Injection System (2998-G-078, Sh 130)

COMPONENTS:

V-3102 V-3103 CATEGORY:

FUNCTION:

These valves open to provide for mini-flow recirculation flow paths from the high pressure safety injection pumps to the refueling water tank. This minimum flow through the respective pumps removes pump heat in the event of operation under lo w or no flow conditions.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

There is no installed flow rate instrumentation available to verify valve full-stroke exercising as required by Generic Letter 89-04, Position 1.

ALTERNATE TESTING'uring quarterly pump testing each of these valves will be partial-stroke exercised (open) via recirculation through the minimum flow test circuits with no flow measurements.

D-51

Revision 0 07/16/93 RELIEF REQUEST NO. VR-30 (cont.)

ALTERNATE TESTING (cont.):

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every three (3) years. Should a valve be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be resumed. This satisfies the requirements of Generic Letter 89-04, Position 2.

St. Lucie Unit 2 was granted a one time relief by the NRC for the disassembly of V-3103 during the 1992 refueling outage. Both check valves must be disassembled during the next refueling outage,. See NRC SER letter from Herbert N.

Berkow to J. H. Goldberg dated 2 June 1992.

D-52

Revision 0 07/16/93 RELIEF REQUEST NO. VR-31 SYSTEM:

Main Steam (2998-G-079, Sh 1)

COMPONENTS'-08130 V-08163 CATEGORY:

FUNCTION:

These valves open to supply steam to the 2C Auxiliary Feedwater Pump (AFW) turbine. These valves close to prevent unrestricted release of steam from an unaffected steam generator in the event of a steamline rupture upstream of an MSIV.

SECTION XI REQUIREMENT:

Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

There is no practical means or provision for pressurizing the piping downstream of these valves in order to verify closure of these valves.

ALTERNATE TESTING'uring the monthly test of the 2C AFW pump, these valves will be partial-stroke exercised. During each cold shutdown outage both of these valves will be full-stroke exercised during the AFW pump substantial flow tests.

D-53

Revision 0 07/16/93 RELlEF REQUEST NO. VR-31 (cont.)

ALTERNATE TESTlNG (cont.):

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the remaining other valve will be inspected during the same outage, after which the rotational inspection schedule will be re-initiated.

Following valve re-assembly no testing is possible (partial-flow or leak testing) prior to placing the valves in service, thus none will be performed. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal.

D-54

Revision 0 07/16/93 RELIEF REQUEST NO. VR-32 SYSTEM:

Safety Injection (2998-G-078, Sh 130)

COMPONENTS:

V-3101 CATEGORY:

FUNCTION:

This valve opens to provide a flow path for borated water from the safety injection tanks (SIT's) to the volume control tank (VCT) to provide sufficient water inventory for plant cooldown should the refueling water tank (RWT) become unavailable.

SECTION XI REQUIREMENT'heck valves shall be exercised at least once every 3 months, except as provided by IWV-3522. (IWV-3521)

BASIS FOR RELIEF:

Transferring the large quantity of water from a SIT to the VCR needed to verify full stroke would result in a significant increase of the boron concentration within the VCT and in the charging system makeup to the reactor coolant system (RCS) as well.

During normal plant operation, any increase of the VCT boron concentration could result in the excessive boron concentration in the RCS along with the insertion of negative reactivity. Ultimately, the RCS would experience cooldown and depressurization with the potential for a plant trip.

D-55

Revision 0 07/16/93 RELIEF REQUEST NO. VR-32 (cont.)

BASIS FOR RELIEF (cont.)

During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-boration of the RCS. The waste management system could also be overburdened by the large amounts of RCS coolant that would require processing following dilution activities. During cold shutdown, transferring a limited quantity of water (less than that needed to confirm full stroke) from a SIT is practical.

ALTERNATE TESTING:

This valve will be partial flow tested during cold shutdowns per VR-1 and full-flow exercised once every refueling outage.

D-56

Revision 0 07/16/93 RELIEF REQUEST NO. VR-33 SYSTEM:

Feedwater (2998-G-080, Sh 2)

COMPONENTS:

SE-09-2 SE-09-3 SE-09-4 SE-09-5 CATEGORY:

FUNCTION'hese solenoid valves cycle open and closed during an AFAS actuation to control auxiliary feedwater flow to the steam generators.

SECTION XI REQUIREMENT:

If, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 sec. or 50% or more for valves with full-stroke times less than or equal to 10 sec is observed, test frequency shall be increased to once each month until corrective action is taken ... (IWV-3414(a))

BASIS FOR RELIEF:

These valves are pilot-operated, normally closed, solenoid globe valves. When their solenoid coil is energized, the magnetic force lifts the pilot disk, opening the pilot orifice in the main disk. Any pressure in the chamber above the main disk then vents through the pilot orifice to the downstream side of the valve. With the pressure vented above the main disk, the upstream pressure acting on the lower side of the main disk lifts it off the main seat opening the valve. In the absence of a pressure differential, no pressure force exists tending to seat the disc, therefore the magnetic force of the solenoid coil is sufficient, acting through the stem, pilot disc, and pin, to directly lift the main disc off the seat, opening the valve.

D-57

Revision 0 07/16/93 RELIEF REQUEST NO. VR-33 (cont.)

BASIS FOR RELIEF: (cont.)

Due to this arrangement, the stroke times measured without differential pressure are slower and vary significantly from test to test causing the valves to be subjected to increased testing per IWV-3417(a) frequently and unnecessarily.

In order to establish the appropriate pressure conditions needed for proper testing the associated AFW pump must be in operation discharging into the steam generators. Pumping from the auxiliary feedwater system into the steam generators during normal operation is impractical and undesirable. Injecting the relatively cold auxiliary feedwater into the main feedwater lines while the plant is operating at power would cause a large temperature differential (approximately 375 deg-F). Significant thermal shock and fatigue cycling of the feedwater piping and steam generator nozzles could result.

ALTERNATE TESTING:

During quarterly testing, these valves will be exercised and fail-safe tested. During this exercising stroke times will be recorded but the corrective action of IWV-3417(a) will not be applied.

allowed stroke time If it a valve stroke time should the maximum will be placed out of service.

During cold shutdown periods the valves will be exercised per VR-1. During this testing valve stroke times will be recorded and evaluated (including corrective action) in accordance with IWV-3417(a).

D-58

Revision 0 07/16/93 RELIEF REQUEST NO. VR-34 SYSTEM:

Component Cooling Water (2998-G-082)

COMPONENTS:

TCV-14-4A TCV-14-4B CATEGORY:

FUNCTION:

These control valves regulate the flow of intake cooling water through the component cooling system heat exchangers.

In the event of loss of air pr'essure or electric power these valves fail open.

SECTION XI REQUIREMENT:

If, for power operated valves, and increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 sec. or 50% or more for valves with full-stroke times less than or equal to 10 sec is observed, test frequency shall be increased to once each month until corrective action is taken ... (IWV-3414(a))

BASIS FOR RELIEF'hese two valves are operated via air signals from their temperature controllers. In the manual mode of operation the positioning air signal from the controllers is varied by manipulating a rheostat. Due to the slow response time of the controllers, in the manual mode there is the potential for a large variation in valve stroke time from test to test This inherent variability is sufficient to cause a valve to fall into the increased test frequency corrective action range without any significant physical change in the mechanical condition of the valve.

D-59

a Revision 0 07/16/93 RELIEF REQUEST NO. VR-34 (cont.)

BASIS FOR RELIEF: (cont.)

These valves can also be operated (opened) by closing the valve using the manual controller and then isolating and venting the control air signal to the valves. The elapsed time required to isolate and then vent the control air is added to the time required to vent the air pressure from the valve operator to arrive at the measured valve stroke time.

Thus the measured stroke time is as much a function of the capability of the individual operator to manipulate the valves as it is the mechanical condition of the valve.

Typically successive stroke times vary sufficiently to cause the valves to be subjected to increased testing per IWV-3417(a) frequently and unnecessarily.

ALTERNATE TESTING:

During quarterly testing, these valves will be exercised and fail-safe tested. During this exercising stroke times will be recorded but the corrective action of IWV-3417(a) will not be applied.

allowed stroke time If it a valve stroke time should the maximum will be placed out of service.

D-60

Appendix E Valve Program Cold Shutdown Justifications

Revision 0 07/16/93 Appendix E: COLD SHUTDOWN JUSTIFICATIONS This appendix is intended to provide the justification for performing valve exercising only at cold shutdown conditions as permitted by IWV-3412(a), 3415 and 3522. Specifically included in this category are the following:

A valve whose failure in a position other than its normal position could jeopardize the immediate safety of the plant or system components; A valve whose failure in a position other than its normal position could cause all trains of a safeguard system to be inoperable;

  • A valve whose failure in a position other than its normal position that might cause a transient that could lead to a plant trip; or When test requirements or conditions are precluded by system operation or access.

Cold shutdown testing is performed under conditions outlined in Relief Request VR-1.

Reactor Coolant (2998-G-078, Sh 107)

V-1460 thru V-1466 Reactor Coolant System Gas Vents These valves are administratively controlled in the key-locked closed position with the power supply disconnected to prevent inadvertent operation. Since these are Class 1 isolation valves for the reactor coolant system, failure of a valve to close or significant leakage following closure could result in a loss of coolant in excess of the limits imposed by Technical Specification 3.1.3 leading to a plant shutdown. Furthermore, if a valve were to fail open or valve indication fail to show the valve returned to the fully closed position following exercising, prudent plant operation would probably likely result in a plant shutdown.

Revision 0 07/16/93 Reactor Coolant (2998-G-078, Sh 108)

V-1474 and V-1475 Power-Operated Relief Valves Due to the potential impact of the resulting transient should one of these valves open prematurely or stick in the open position, it is considered imprudent to cycle them during plant operation with the reactor coolant system pressurized.

Chemical & Volume Control (2998-G-078 Sh. 120)

V-2522 Letdown Line Containment Isolation Valve Closing this valve during operation isolates the letdown line from the RCS and would result in undesirable pressurizer level transients with the potential for a plant trip. If a valve failed to reopen, then an unexpected plant shutdown would be required.

Chemical & Volume Control (2998-G-078 Sh. 121)

V-2501 Volume Control Tank Outlet Valve Cycling this valve during operation of a charging pump would isolate the VCT from the charging pump suction header damaging any operating charging pumps and interrupting the flow of charging water flow to the RCS with the potential of RCS transients and plant trip.

V-2505 and V-2524 RCP Control Bleedoff Isolation Valves Exercising either of these valves to the closed position when any of the reactor coolant pumps (RCP's) are in operation would interrupt flow from the RCP seals and result in damage to the pump(s).

E-2

Revision 0 07/16/93 Chemical & Volume Control (2998-G-078 Sh. 122)

SE-02-03 and SE-02-04 Auxiliary Pressurizer Spray Valves Opening either of these valves (or failure in the open position) during plant operation would cause an RCS pressure transient that could potentially adversely affect plant safety and lead to a plant trip. In addition, the pressurizer spray piping would be subjected to undesirable thermal shock.

V-2431 Auxiliary Pressurizer Spray Check Valve In order to test this valve, either SE-02-03 or SE-02-04 must be opened. Opening either of these valves (or failure in the open position) during plant operation would cause an RCS pressure transient that could potentially adversely affect plant safety and lead to a plant trip. In addition, the pressurizer spray piping would be subjected to undesirable thermal shocks V-2440 Charging Pump Discharge Check Valve To Safety Injection Opening this valve requires operating a charging pump and discharging into the RCS via the safety injection nozzles.

Thermal cycling of the safety injection nozzles is undesirable and should be avoided.

E-3

Revision 0 07/16/93 V-2515 and V-2516 Letdown Line Isolation Valves Closing these valves during operation isolates the letdown line from the RCS and would result in undesirable pressurizer level transients with the potential for a plant trip. If a valve failed to reopen, then an unexpected plant shutdown would be required.

V-2523 and V-2598 Charging Line Isolation Valves Closing these valves during operation isolates the charging pumps from the RCS and would result in undesirable pressurizer level transients with the potential for a plant trip and potential damage to the charging pumps. If a valve failed to reopen, then an unexpected plant shutdown would be required'afet In'ection / Residual Heat Removal (2998-G-078 Sh 130)

V-3106 and V-3107 LPSI Pump Discharge Check Valves During normal plant operation, the LPSI Pumps cannot develop sufficient discharge pressure to pump through these valves to the RCS and exercise them in the open direction. These valves will be partial flow exercised quarterly and full flow exercised each cold shutdown.

V-3463 Isolation Valve for SIT Test/RWT Return Header Cycling this manual valve would constitute a breach of containment integrity, as defined in Technical Specifications 3 '.1.1, and therefore opening this valve is precluded in Modes 1, 2, 3, and 4.

E-4

Revision 0 07/16/93 Safet In'ection / Residual Heat Removal (2998-G-078 Sh 131)

V-3114, V-3124, V-3134, and V-3144 LPSI Cold Leg Injection Check Valves During normal plant operation, the LPSI Pumps cannot develop sufficient discharge pressure to pump through these valves to the RCS and exercise them in the open directions V-3480, 3481, 3651, and 3652 Shutdown Cooling RCS Isolation Valves These valves are provided with electrical interlocks that prevent opening whenever Reactor Coolant System pressure exceeds 275 psia. This precludes exercising these valves in any plant condition other than cold shutdowns V-3545, 'V-3664, and V-3665 Shutdown Cooling Isolation and Cross Connect Valves The motor-operated valves V-3664 and V-3665 are isolation valves for shutdown cooling and V-3545 is the cross connect valve between the two trains of shutdown cooling. These valves are normally locked closed. A failure of these valves in any other position could jeopardize the integrity of the Low Pressure Safety Injection System.

Safet In'ection / Residual Heat Removal (2998-G-078 Sh 132)

V-03002 thru V-03005 Safety Injection Tank (SIT) Drain Line Check Valves Exercising these valves requires draining of each of the SITs. This is not considered to be an appropriate nor prudent activity to perform during plant operation due to the obvious safety issues related to SIT inventory and chemistry control.

E-5

Revision 0 07/16/93 V-3614, V-3624, V-3634, and V-3644 SIT Discharge Isolation Valves Stroke testing these valves in the closed direction during normal operation is not possible. The valves are normally locked open with their breaker opened. Also they are interlocked with pressurizer pressure to prevent these valves from closing with RCS pressure >276 psia. Therefore, the valves cannot be cycled except during cold shutdowns.

V-3733 thru V-3740 SIT Vent Valves Cycling any of these valves during normal plant operation with the SITs pressurized is undesirable since were to fail to re-close the result would be if a valve depressurization of the affected SIT.

Waste Mana ement (2998-G-078, SH 163)

V-6792 Nitrogen Gas Supply Containment Isolation Check Valve This is a simple check valve with no external means of position indication, thus the only practical mean's of verifying closure is to perform a backleakage test.

Performing such a test requires entry into the containment building and thus is impractical to do during plant operations.

Main Steam (2998-G-079 Sh 1)

HCV-08-1 A&B Main Steam Isolation Valves During plant operation at power, full closure of either of these valves is not practical as it would require isolating a steam generator which would result in a severe transient on the steam and reactor systems and a possible plant trip.

o Revision 07/16/93 0

V-08130 and V-08163 Steam-Driven AFW Pump Steam Supply Check Valves Full stroke operation of these valves requires operating 2C AFW Pump and full accident flow rate which is not practical during plant operation at power. (See Relief Request PR-4)

Feedwater (2998-G-080 Sh 2)

HCV-09-1 A&B and HCV-09-2 A&B Main Feedwater isolation Valves During plant operation at power, closure of any of these valves is not practical as it would require isolating a steam generator which would result in a severe transient on the steam and reactor systems and a plant trip.

V-09107, 09123, and 09139 Auxiliary Feedwater Pump Discharge Check Valves Full-stroke exercising of these valves would require operation of the related auxiliary feedwater pump and injection of cold water (85 deg-F) into the hot (450 deg-F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

V-09119, 09135, 09151, and 09157 Auxiliary Feedwater Supply Check Valves Full-stroke exercising of these valves would require operation of a related auxiliary feedwater pump and injection of cold water (85 deg-F) into the hot (450 deg-F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

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Revision 0 po 07/16/93 Com onent Coolin S stem (2998-G-083)

HCV-14-1,2,6 6 7 RCP Cooling Water Supply/Return Isolation Valves These valves are required to be open to ensure continued cooling of reactor coolant pump auxiliary components and the control rod drives. Closing any of these valves during plant operation would result in severe RCP and CRD damage leading to plant operation in a potentially unsafe mode and a subsequent plant shutdown.

HCV-14-3 A&B Shutdown Heat Exchanger Return Valves Testing either of these valves during plant operation would result in an unbalanced flow condition in the affected CCW train and decreased flow to essential equipment. This could result in component damage or an undesirable plant transient.

Service Air (2998-G-085, Sh 1)

V-181270 Service Air Containment Isolation Check Valve During normal power operation, the service air supply to the containment building is isolated. The containment isolation valves, HCV-18-2, is a normally shut valve used to isolate the service air system inside containment'esting a check valve in an isolated section of a system is not warranted.

The check valve will be back flow tested during cold shutdowns when the sectionof the service air system inside the containment building is in service. This is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is to perform a backleakage test. Performing such a test requires entry into the containment building and thus is impractical to do during plant operations.

Revision 0 07/16/93 Instrument Air (2998-G-085, Sh 2)

HCV-18-1 Primary Containment Instrument Air Supply Closing this valve isolates operating air to critical components in the containment building including the pressurizer spray valves and CVCS letdown isolation valves and could cause severe plant transients and a plant trip.

Failure in the closed position would cause a plant shutdown.

Miscellaneous Sam lin (2998-G-092, Sh 1)

V-27101 and V-27102 Hydrogen Sampling Return Line Containment Isolation Check Valves This is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is to perform a backleakage test.

Performing such a test requires entry into the containment building and breaching of the system, thus it is impractical to do during plant operations.

Heatin , Air Conditionin , And Ventilation, & Air Conditionin (2998-G-878)

FCV-25-1 thru FCV-25-6 Primary Containment Purge and Vent Valves These valves are required to remain closed at all times when the plant is operating in Modes 1 through 4, thus they are not required to operate (close) during operational periods.

Due to the large size of these valves and the potential for damage as a result of frequent cycling, it operate them more than is absolutely necessary.

is not prudent to V-25-20 and V-25-21 Containment Vacuum Breakers valves can only be exercised manually requiring direct

'hese routinely practical.

access to each valve. Since these valves are located within the containment building, access is limited and not E-9