ML17228A836

Rev 1 to JNS-PSL-204, Second Ten-Yr ISI Interval IST Program for Pumps & Valves,St Lucie Nuclear Power Plant Unit 2.

ML17228A836
Person / Time
Site:	Saint Lucie
Issue date:	08/03/1994
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17228A835	List: ML17228A834 ML17228A836
References
JNS-PSL-204, JNS-PSL-204-R01, JNS-PSL-204-R1, NUDOCS 9408290298
Download: ML17228A836 (171)

Text

REVISION 1 08/04/94 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 PLANT UNIT NO. 2 DATE OF COMMERCIAL OPERATION: AUGUST 8I 1983 FLORIDA POWER & LIGHT P.O. BOX 128 FT. PIERCE, FL. 34954 NRC DOCKET NUMBER:

DOCUMENT NUMBER:

ST. LUCIE PLANT REVIEWS AND APPROVALS:

PREPARED BY:

PSL ANT IST ENGINEER (S)

APPROVED BY: DATE: ~

SL EST 6 CODE SUPERVISOR 94082'70298 940822 PDR ADOCK 05000389 PDR

REVISION 1 08/04/94 Table of Contents Table of Contents Record of Revisions 1.0 Introduction 1.1 IST Program Testing Requirement Guidelines 1.2 IST Program Implementation 2.0 Applicable Documents 3.0 Inservice Testing Program For Pumps 3.1 Code Compliance 3.2 Allowable Ranges of Test Quantities 3.3 Testing Intervals 3.4 Pump Program Table 3.5 Relief Requests for Pump Testing 4.0 Inservice Testing Program For Valves 10 4.1 Code Compliance 10 4.2 Testing Intervals 10 4.3 Stroke Time Acceptance Criteria 10 4,4 Check Valve Testing 10 4.5 Valve Program Table 10 4.6 Relief Requests For Valve Testing 10 A Pump Program Tables B Pump Program Requests For Relief C Valve Program Tables D Valve Program Requests, For Relief E Cold Shutdown Justifications F Refueling Outage Justifications

REVISION 1 08/04/94 Second 10 YEAR SUBMITTAL RECORD OF REVISIONS REVISION DESCRIPTION OF REVISION DATE DATE HLH~Z EKIS122 QFMXZ Second 10 Year Submittal 07/16/93 05/02/94 Program Update 08/04/94

REVISION 1 08/04/94 INSERVICE TESTING (IST) PROGRAM PLAN ST. LUCIE UNIT 1

1.0 INTRODUCTION

Revision 1 of the St. Lucie Unit 2 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(f). The second inspection interval is defined as follows:

August 8, 1993 August 7, 2003 This document outlines the IST Program for St. Lucie Plant, Unit 2, based on the requirements of the ASME Boiler and Pressure Vessel Code (the Code),Section XI, 1986 Edition.

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 IST program has been updated to replace the requirements of ASME/ANSI OM-1981, Part 1 with ASME/ANSI OM-1987, Part 1, "Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices".

NRC Safety Evaluations dated August 23, 1993, and May 2, 1994 determined certain relief requests were not required pursuant to 10 CFR 50.55a(f) (4) (iv) where alternative is in it accordance was determined that the with the requirements proposed of the 1989 Edition of Section XI. The 1989 edition provides that the rules for IST of pumps and valves shall meet the requirements set forth in ASME/ANSI OMa-1988, Part 6, "Inservice Testing of Pumps in Light-Water Reactor Power Plants" and ASME/ANSI OMa-1988, Part 10, "Inservice Testing of Valves in Light-Water Reactor Power Plants". Approval was granted to conduct inservice tests in accordance with OM-6 and OM-10, or portions thereof, provided all related requirements are met. Accordingly, the IST Program for the St. Lucie Plant is revised by the following:

1. Measurement of bearing temperatures as required by

'E IWP-3300 and 'KIWP-4310 are not required by ASME/ANSI OMa-1988, Part 6, for inservice testing of pumps.

Therefore, the measurement of bearing temperatures is not a requirement of the IST Program.

2. The valve exercising requirements of ASME/ANSI OMa-1988, Part 10, 9 4.2.1.2 and 4.3.2.2 will be followed as alternatives to '3 IWV-3412(a) and IWV-3522 not including IWV-3522(a) and (b).

REVISION 1 08/04/94

3. The analysis of leakage rate and corrective action requirements of ASME/ANSI OMa-1988, Part 10, 9 4.2.2.3 (e) and (f) will be followed as alternatives to 'J[ IWV-3426 and IWV-3427.

The inservice testing requirements identified in this Plan were prepared to verify the operational readiness of ISI Class 1, 2, and 3 pumps and valves which have a specific function in mitigating the consequences of an accident or in bringing the reactor to a safe shutdown.

In this regard, the general requirements of Paragraphs IWP-1100 and IWV-1100 form the following basic scope document as it applies to ISI Class 1, 2, and 3. Specifically components to be included are:

Centrifugal and positive displacement pumps that are required to perform a specific function in shutting down the reactor or in mitigating the consequences of an =

accident and that are provided with an emergency power source, and Valves (and their actuating and position indicating systems) which are required to perform a specific function in shutting down the reactor to the cold shutdown condition or in mitigating the consequences of an accident.

The general Code requirements were applied to St. Lucie Unit 2 using a systematic approach by first reviewing the function of each of the plant systems as they relate to a limited number of bounding accident scenarios'his review eliminated systems (and associated components) that clearly do not boundary fitclassifications the basic Code definitions including that of ISI Next, a series of rules or guidelines were developed that established the criteria to be used during the review of the remaining systems and components. These rules establish the policies and assumptions that were applied to the foregoing analysis to ensure consistency'ach of these are outlined below. From this point, in a series of steps, each of the individual components in each of the remaining significant safety systems (and supporting systems) were evaluated with respect to the function of each component and the need for its operability as it relates to the scope of Section XI.

These steps included:

1. A review of flow diagrams of each system and identification of any components (pumps or valves) that "could" potentially be included in the IST Program

REVISION 1 08/04/94 scope. Based on the reviewer's experience, valves used for maintenance isolation, vents, drains, etc. were excluded. Typically, all pumps, power-operated valves, check valves, and safety valves remained in the population designated for further evaluation.

2. Each system was broken down by component and, based on general system operational requirements, a narrative description of each component's safety function(s) during the proposed scenarios was drafted.

3. Sequentially, plant documents that refer to or discuss safety-related component or system functions were reviewed in detail and information from these documents was compared to the drafts developed in the above step

2. Where appropriate, corrections and references were applied to the individual narratives. Documents reviewed included the following:

a. Updated Final Safety Analysis Report

b. Technical Specifications C. Plant System Descriptions (Training) Documents

d. Special analyses

e. Commitment correspondence

f. Plant Operating Procedures

g. Emergency Operating Procedures

h. Appendix J Leakrate Test Program

4. Based on the finalized component safety function evaluation derived from the document review and the corrected narratives, the IST Program testing requirements were then established by applying the guidelines listed in Section 1.1 to each one.

5. The functional description of the system components were subjected to a comprehensive review by knowledgeable plant personnel to confirm the accuracy on the document.

REVISION 1 08/04/94 IST PROGRAM TESTING REQUIREMENT GUIDELINES The following guidelines are set forth for evaluation of system components (pumps and valves) with respect to their inclusion in the St. Lucie Unit 2 IST Program and to what extent testing will be performed.

Where multiple components are capable of performing the same equivalent and redundant specified function (eg.

multiple valves closing in series) and where the components are not supplied by alternate and redundant power supplies, only one need be included in the and not simply have the capability of performance. This exemption only applies where licensing documents take credit for the designed redundancy. Components performing a,redundant function shall be included in the testing program if, in the process of analysis or licensing justification, they are relied upon to be operable.

The St. Lucie Unit 2 FUSAR and related design basis documents shall be the primary references for determining which components are required to perform specified functions related to the spectrum of predicated accidents. Although several other plant source documents ( Tech. Specs. and EOP's) identify various components that may be important to plant safety or are to be operated in conjunction with recovery from an accident, unless specific credit is taken in the plant safety analysis (or is implied in the analysis) for a pump or valve, the component need not be included in the IST program. The exceptions to this are those cases where the NRC imposes test requirements at their discretion.

Valves installed primarily for the purpose of providing convenient operational flexibility (eg. system cross-connects) that are not required to operate, assuming that the designated first-line systems and components operate satisfactorily, need not be included in the IST Program. This does not exclude active valves that could be called upon as a result of optional system lineups existing prior to the initiation of an accident, Valves that are actuated as a result of a safety system automatic response shall be included in the IST Program to the extent that the testing shall verify valve operation required as a result of the safety system input. This applies only if valve movement is required to support those functions required as specified by the Code. This requirement extends only to testing defined

REVISION 1 08/04/94 by the Code and is not intended to imply the need for verifying a valve's response to automatic logic system output.

Valves whose sole function is to provide system or component redundancy related to failure of passive components need not be included if active components (pumps and valves) needed to a set of all of the fulfill the specified system (train) function are tested double or unrelated simultaneous failures need not be assumed. In some cases where protection of critical systems from passive failures is a commitment, the components are included in the testing program.

System safety/relief valves shall be included where the function of the valve is to provide overpressure protection.

All valves included in the St. Lucie Unit 2 leakrate testing program complying with 10CFR50, Appendix J shall be included in the IST Program as Category A valves.

All valves designated as high-low pressure interface valves (pressure isolation valves) shall be included in the IST Program as Category A or A/C valves.

Any active Category A valve shall be designated for testing (exercising) to the closed directions When a valve's normal position during operation is its position required to perform its designated safety function and valve movement may be required due to plant evolutions or possible repositioning during accident or recovery operations, then periodic response exercising per the Code cannot be considered passive).

is required (i'he valve Where an air-operated valve is provided with a simple air-pilot valve, the pilot valve need not be that specifically included in the IST Program provided the testing performed on the main valve verifies the proper operation of the pilot valve.

Control valves are specifically excluded from testing per IWV-1200 (a); however, if a control valve must change position to support a safety-related function and it has a fail safe position, then it must be included in the IST Program and tested to the extent practical. Steam turbine governor valves are considered to be an integral part of the turbine and, as such, are not included in the IST Program.

REVISION 1 08/04/94

13. Check valves are included where a valve serves as the only effective boundary between piping associated with a necessary safety function and non-safety grade (non-seismic) piping. Failure of passive system components is assumed only for non-safety grade systems.

14. Where a valve performs a safety function in both directions (open and closed) exercising in both direction is required as described in Reference 1. For these power-operated valves, stroke time measurements in both directions would be required.

15. Pumps and valves whose only safety function is predicated on plant shutdown and recovery from a fire per commitment made as a result on 10CFR50, Appendix R are not included in the IST Program.

16. Pumps and valves that are not categorized as ISI Class 1, 2, or 3 need not be included in the IST Program.

17. Check valves that have a safety function to close should be evaluated with respect to categorization as Category A/C versus C with respect to the following issues:

a. Whether the flow requirements for connected systems can be achieved with the maximum possible leakage through the check valve.

b. The effect on the performance of other components and systems due to the reduced flow resulting from the leakage.

c. The consequences of loss of fluid from the system.

d. The effect that backflow through a valve may have on piping and components, such as the effect of high temperature and thermal stresses.

e. The radiological exposure to plant personnel and the public caused by the leak.

REVISION 1 08/04/94 1.2 IST PROGRAM IMPLEMENTATION A. The requirements of the ASME Code Section XI, subsections IWP and IWV, and OM-1-1987 are implemented at St. Lucie through the Quality Instructions and Administrative Procedures. These instructions and procedures address the Code requirements, the department(s) responsible, and the steps that must be performed to satisfy those requirements.

B. Each of the pumps and valves included in the Unit 2 IST program are tested by a Unit 2 test procedure.

These test procedures are in the form of either Pump Data Sheets, Valve Data Sheets, procedure appendixes, or individual test procedures. All test procedures and their setpoints must be reviewed and approved by the Plant's Procedure Change Request (PCR) process. The PCR process includes a 10 CFR 50.59 review and final review by the Plants Facility Review Group (FRG) ~

C. Plant Changes or Modifications (PC/M) are reviewed by Engineering and/or the plants Technical Staff for any potential effects to the IST program. If changes to the program are required, the plant Technical Staff and/or other applicable departments will initiate the appropriate test procedure changes via a PCR. Any changes to the IST program will be made by the Technical Staff. Periodically, these changes will be incorporated into a new revision to the IST program and submitted to the FRG for review.

'Following the FRG review, the new IST revision will be issued.

REVISION 1 08/04/94 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, 3.9.6, "Inservice Testing of Pumps and Valves 2.4 Final Safety Analysis Report., St. Lucie Unit 2 2.5 St. Lucie Plant Unit 2 Technical Specifications 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 Supplement to Minutes of the Public Meetings on Generic Letter 89-04 by J, G. Partlow, 26 September 1991 2.10 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.

2.11 ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition.

2 '2 ASME/ANSI OM-1987, Part 1, "Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices".

2.13 NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated August 23, 1993.

2. 14 ASME/ANSI OMa-1988, Part 6, "Inservice Testing of Pumps in Light-Water Reactor Power Plants".

2.15 ASME/ANSI OMa-1988, Part 10, "Inservice Testing of Valves in Light-Water Reactor Power Plants".

2.16 NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994.

REVISION 1 08/04/94 3' 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 Reference 2.7. 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(f) (iii) and Reference 2.7.

3.2 Allowable Ranges of Test Quantities 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. In 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.

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.

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.

REVISION 1 08/04/94 4.0 INSERVICE TESTING PROGRAM FOR VALVES 4.1 Code Compliance This IST Program for valves meets the requirements of Subsection IWV of the Code and any interpretations or additional requirements imposed by Reference 2.7. 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(f)(iii) and Reference 2.7.

4.2 Testing Intervals The test frequency for valves (excluding safety/relief valves) included in the Program will be as set forth in IWV-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 Reference 2,7.

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 flowrate through the valve be verified and measured.

Any deviation to this requirement must satisfy, the requirements of Reference 2.7, Position l.

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.

10

REVISION 1 08/04/94 Appendix A Pump Program Tables

REVISION 1 08/04/94 Florida Power & Light Company INSERVICE TESTING PUMP TABLES St. Lucie Nuclear Plant Unit 2 PAGE '

IcR&KD.

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'he 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.

RE VIS ION 1 08/04/94 Appendix B Pump Program Relief Requests

Revision 1 08/04/94 RELIEF REQUEST NO. PR-1 WITHDRAWN (Rev 1, 08/04/94)

Revision 1 08/04/94 RELIEF REQUEST NO. PR-2 Various The full-scale range of each instrument shall be three times the reference value or less. (IWP-4120)

Table 1WP-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.

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.

V NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, authorized this relief request in accordance with 10 CFR 50. 55a (a) (3) (i) .

B-2

Revision 1 08/04/94 RELIEF REQUEST NO. PR-3 WITHDRAWN (Rev 0, 07/16/93)

B-3

Revision 1 08/04/94 RELIEF REQUEST NO. PR-4 Auxiliary Feedwater (AFW) Pumps 2A thru 2C (2998-G-080, Sh 2)

I N XI 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)

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

B-4

Revision 1 08/04/94 RELIEF REQUEST NO. PR-4 (cont.)

ERN During 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.

p v NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 9.

Revision 1 08/04/94 RELIEF REQUEST NO. PR-5 Boric Acid Makeup (BAM) Pumps 2A and 2B (2998-G-078, Sh 121)

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)

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-6

Revision 1 08/04/94 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 it undesirable to pump to the RWT and deplete the BAM Tank is 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. Spec. 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 linc'umping 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-7

Revision 1 08/04/94 RELIEF REQUEST NO. PR-5 (cont.)

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.

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 9.

B-8

Revision 1 08/04/94 RELIEF REQUEST NO. PR-6 Containment Spray (CS) Pumps 2A and 2B (2998-G-088)

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)

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.

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.

B-9

Revision 1 08/04/94 RELIEF REQUEST NO. PR-6 (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.

V NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 9.

B-10

Revision 1 08/04/94 RELIEF REQUEST NO. PR-7 WITHDRAWN (Rev 0, 07/16/93)

Revision 1 08/04/94 RELIEF REQUEST NO. PR-8 N

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

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)

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'ince 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.

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.

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, authorized this relief request in accordance with 10 CFR 50.55a(a)(3) (i) .

B-12

Revision 1 08/04/94 RELIEF REQUEST NO. PR-9 High Pressure Safety Injection (HPSI) Pumps 2A and 2B (2998-G-078, Sh 130)

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

(IWP-3300)

BA I During 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 and measuring flow rate during quarterly measuring'nstrumentation 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.

ALT 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.

B-13

Revision 1 08/04/94 RELIEF REQUEST NO. 'PR-9 (cont.)

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 9.

B-14

Revision 1 08/04/94 RELIEF REQUEST NO. PR-10 Low Pressure Safety Injection (LPSI) Pumps 2A and 2B (2998 G 078'h 131)

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

(IWP-3300)

During quarterly testing of the LPSI 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, 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.

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.

Revision 1 08/04/94 RELIEF REQUEST NO. PR-10 (cont.)

V NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 9.

Revision 1 08/04/94 RELIEF REQUEST NO. PR-11 Intake Cooling Water Pumps 2A, 2B and 2C (2998-G-082)

E Each 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)

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.

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

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, authorized this relief request in accordance with 10 CFR 50.55a(a) (3) (i) .

B-17

Revision 1 08/04/94 RELIEF REQUEST NO. PR-12 E

Reactor Coolant Charging Pumps 2A, 2B, and 2C E TI N XI R IR M 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))

The reactor coolant charging pumps operate at approximately 210-215 rpm which equates to a rotational frequency of 3 '0 Hz. The one-half minimum speed frequency response required for the vibration instrumentation correlates to 1.75 Hz (105 cpm) .

The vibration instrumentation presently in use at St. Lucie is the Bently Nevada model TK-81 with 270 cpm probes. The TK-81 integrator frequency response is essentially flat down to 120 cpm (cycles per minute) where the displayed output of the instrument slightly increases to approximately +ldB at 100 cpm. The -3dB frequency response is reached at approximately 54 cpm. The velocity probes used with the TK-81 are a special low frequency probe nominally rated down to 270 cpm (-3 dB). This is only slightly higher than the expected rotational (1X) speed of the charging pump (205 210 cpm). The 1X (205 cpm.) vibration frequency components will be somewhat attenuated by the probes, but not cut off.

Overall vibration levels would still show an increasing value if some problem developed whose characteristic frequency was 1X running speed.

There are virtually no mechanical degradations where only a sub-synchronous vibration component would develop on the charging pumps. For example:

a. Oil whirl (0.38X 0.48X) is not applicable to a horizontal, triplex, reciprocating pump.

B-18

Revision 1 08/04/94 RELIEF REQUEST NO. PR-12 (cont.)

b. A light rub / impact could generate 0.5X (102.5 cpm) vibration components, but would also usually generate a sequence of integer and half integer running speed components. A heavy rub generates increased integer values of multiple running speed components, as well as precessing the 1X phase measurement. In either case the overall vibration level would still increase from both the attenuated sub-synchronous and 1X show an vibration components as well as the higher harmonic vibration components.

c. Looseness in the power train would likely be indicated by increasing 1X and 2X vibration components.

These signals would be slightly attenuated but again not completely cut off.

Based on the above information, it is our evaluation that the 270 cpm probes with the present use of the Bently Nevada portable TK-81 instrument is capable of collecting sufficiently reliable data to identify changes from baseline readings to indicate possible problems with the pumps.

During testing of these pumps, the vibration instrumentation used will be the Bently Nevada model TK 81 with 270 cpm probes or equivalent.

V This revised relief request is pending NRC approval. NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated August 23, 1993, and May 2, 1994, provided interim approval.

B-19

Revision 1 08/04/94 RELIEF REQUEST NO. PR-13 WITHDRAWN (Rev 1, 08/04/94) s-20

Revision 1 08/04/94 RELIEF REQUEST NO. PR-14 Hydrazine Pumps 2A and 2B I RE IREMEN 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))

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.

The vibration instrumentation presently in use at St. Lucie is the Bently Nevada model TK-81 with 270 cpm probes. The TK-81 integrator frequency response is essentially flat down to 120 cpm (cycles per minute) where the displayed output of the instrument slightly increases to approximately +1dB at 100 cpm. The -3dB frequency response is reached at approximately 54 cpm. The velocity probes used with the TK-81 are a special low frequency probe nominally rated down to 270 cpm (-3 dB).

TIN During testing of these pumps, the vibration instrumentation used will be the Bently Nevada model TK 81 with 270 cpm probes or equivalent.

p v This revised relief request is pending NRC approval. NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated August 23, 1993, and May 2, 1994, provided interim approval.

Revision 1 08/04/94 RELIEF REQUEST NO. PR-15 MP NENT Containment Spray Pumps 2A and 2B (2998-G-088)

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

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

E I E I E 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)

The 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.

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.

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, authorized this relief request in accordance with 10 CFR 50 '5a(a) (3) (i) .

B-22

Revision 1 08/04/94 RELIEF REQUEST NO. PR-16 WITHDRAWN (Rev 0, 07/16/93)

B-23

Revision 1 08/04/94 RELIEF REQUEST NO. PR-17 Hydrazine Pumps 2A and 2B (2998-G-088)

R T 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)

The PSL Unit 2 Hydrazine pumps are reciprocating positive displacement pumps with variable speed control. These pumps are normally in a standby condition and are only operated during surveillance testing. They are classified as metering pumps and are designed to accurately displace a predetermined volume of liquid in a specific period of time. The pump has a single plunger and makes only one suction stroke and only one discharge stroke during each cycle.

The pumps operate at a very slow speed (as low as 37 rpm) to produce the Technical Specification required Hydrazine flowrate of 0.71 to 0.82 gpm. Pump flow is continuously accelerating and decelerating following a sinusoidal waveform. Each cycle of the pump is approximately 1.6 seconds in duration with no flow produced during the pumps 0.8 second suction stroke. This characteristic intermittent and oscillating flowrate is obviously impractical to physically dampen the observed reading to within 2% using symmetrical damping devices.

The installed flow instrumentation has been demonstrated to be inadequate for inservice testing purposes'his instrumentation utilizes a differential pressure orifice located in the suction line common to both pumps to measure flow. Flow through this orifice pulsates sharply with each stroke of the pump. The flow orifice also senses pressure feedback during each cycle of the pump stroke. This feedback has been determined to be echoes of the pressure pulsations produced by the pump stroke which have reflected back to the orifice by the system piping and valves.

B-24

Revision 1 08/04/94 Refueling outage testing has demonstrated that techniques used to average the indicated flow readings are inconsistant and inaccurate when compared to actual flow. Trending the flow rate using the installed instrumentation is impractical due to the inherent inaccuracies and instability in measuring the pump flow as described above. Flow instrumentation which can accurately measure the Hydrazine pump intermittent and oscillating flowrate has not been located.

instrumentation were found to be available the costs Even if such associated with procuring and installing such instrumentation could not be justified. The Hydrazine pumps are standby pumps. There is virtually no means for the mechanical condition of the pump to become degraded between refueling outages with the pump only run for quarterly surviellance testing.

The flow rate of the pumps can be accurately obtained by collecting the pumps output in a container and measuring it.

Several flow tests per hydrazine pumps have been performed.

The pump discharge was directed to a container of a known volume. The amount of time to measured and then used to fill calculate the container was an average flow rate for the pump. 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.

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. Flow measurement performed each refueling outage is considered by PSL to be appropriate for detecting any pump hydraulic degredation.

B-25

Revision 1 08/04/94 During each refueling outage at least one test measuring actual pump flow will be performed for each pump to verify proper performance.

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 discharge pressure and vibration will be measured during both the quarterly and refueling outage tests.

This revised relief request is pending NRC approval. NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated August 23, 1993, and May 2, 1994, provided interim approval.

a-26

REVISION 1 08/04/94 Appendix C Valve Program Tables

REVISION 1 08/04/94 Florida Power & Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit 2 PAGE  : 1 LEZzRHK 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 valve.

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 1 08/04/94 Florida Power 6 Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit 2 PAGE 2 EXAM Identifies the test requirements for a valve as follows:

CV/c Check valve exercise to closed position.

CV/0 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.

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 1 08/04/94 Florida Power & Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit 2 PAGE  : 3 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 SD Disassemble, inspect, and manually exercise one valve from specified group each reactor refueling outage RELIEF REQ Refers to the specific relief request associated with the adjacent test requirement. (See Appendix D)

FLORIDA POWER AND LIGHT COMPANY REVISION:

VALVE TABLES DATE  : 08/04/94 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 9 P a ID: 2998-G-078 SH 121 (cont) SYSTEM: CHEMICAL AND VOLUHE 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 3.000 GATE A MO C YES FAI EO QR PI 2Y V-2509 C-7 2 B 3.000 GATE A HO 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 , EC CS FS CS PI 2Y SLT-1 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 CV/PO CS V-2650 B-4 2 B 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y V-2651 D-4 2 B 1.000 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 NO CV/0 QR

FLORIDA POWER AND LIGHT COMPANY REVISION: 1 VALVE TABLES DATE  : 08/04/94 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 14 P a ID: 2998-G-078 SH 130 (cont) SYSTEH: SAFETY INJECTION SYSTEM ACT. NORH REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM 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 MO LO YES FAI EC QR PI 2Y V-3456 G-4 2 B 10.000 GATE A MO LC YES FAI EO QR PI 2Y V-3457 F-2 2 B 10.000 GATE A MO LC YES FAI EO QR PI 2Y V-3463 G"2 2 A 2.000 GATE A HAN LC NO EE SLT"1

'R2Y V-3466 G-1 3 C 1.500 RELIEF A S/A C NO SRV RF V-3495 G-6 2 B F 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 MO LC YES FAI EO QR PI 2Y V-3518 C-3 2 B 2.000 GLOBE A MAN 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 CV/O RF CV/PO CS V-3523 A-2 2 B 3.000 GLOBE A MO LC YES FAI EC QR EO QR PI 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 1 VALVE TABLES DATE  : 08/04/94 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 16 P 6 ID: 2998-G-078 SH 131 SYSTEM: SAFETY INJECTION SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS HCV-3615 H-7 2 B 6.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3616 G-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3617 G-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3625 F-7 2 B 6.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3626 E-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV"3627 E-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3635 D-7 2 B 6.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3636 C-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3637 C-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3645 B-7 2 B 6.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3646 A-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3647 A"7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y V-3113 G-7 2 C 2.000 CHECK A S/A C NO CV/0 RF CV/PO CS 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 PONER AND LIGHT COMPANY REVISION: 1 VALVE TABLES DATE  : 08/04/94 Saint Lucre Nuclear Plant - Unit 2 PAGE  : 19 P 6 ID: 2998-G-078 SH 132 SYSTEM: SAFETY INJECTION SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS HCV-3618 E-7 1 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y HCV-3628 E-4 1 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y HCV-3638 B-7 1 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y HCV-3648 B-4 1 B 1.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y SE-03-1A F-3 2 B 1.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SE"03-1B F-7 2 B 1.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SE-03-1C C-7 2 B 1.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SE-03-1D C-3 2 B 1.000 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 NO 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

FLORIDA PONER AND LIGHT COHPANY REVISION: 1 VALVE TABLES DATE  : 08/04/94 Saint Lucie Nuclear Plant - Onit 2 PAGE: 23' 6 ID: 2998-G-078 SH 153 SYSTEM: SAMPLING SYSTEM ACT. NORM 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 0.375 GLOBE A SO C YES FC EC QR FS QR PI 2Y Sl T" 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 POWER AND LIGHT COMPANY REVISION: 1 VALVE TABLES DATE  : 08/04/94 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 33 P 4 ID: 2998-G-082 SYSTEM: INTAKE COOLING WATER SYSTEM ACT. NORM REM 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 B 24.000 BUTFLY A MO 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 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 FS QR TCV-14-4B B-4 3 B 30.000 BUTFLY A PO 0 NO FO EO QR 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-1 3 C 30.000 CHECK A S/A 0 NO CV/C QR CV/0 QR

FLORIDA PONER AND LIGHT COMPANY REVISION: 1 VALVE TABLES DATE  : 08/04/94 Saint Lucie Nuclear Plant - Unit 2 PAGE  : 45 P 4 ID: 2998-G-092 SH 1 SYSTEH: MISC. SAHPLING SYSTEMS ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-2 6-1 G-2 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 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 PI 2Y SLT-1 2Y FCV-26-4 H-4 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y FCV-26-5 I-2 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y FCV-26-6 1-4 2 A 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 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 PI 2Y SLT-1 2Y

REVISION l 08/04/94 Appendix D Valve Program Requests for Relief

Revision 1 08/04/94 RELIEF REQUEST NO. VR-1 WITHDRAWN (Rev 1, 08/04/94)

Revision 1 08/04/94 RELIEF REQUEST NO. VR-2 WITHDRAWN (Rev 1, 08/04/94)

D-2

Revision 1 08/04/94 BYSX12L'ELIEF REQUEST NO. VR-3 Various Various Various This is a generic request for relief 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))

E I 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.

The 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-3

Revision 1 08/04/94 VAL'RC Safety Evaluation of St. Lucie Unit 2 lnservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 6.

D-4

Revision 1 08/04/94 RELIEF REQUEST NO. VR-4 WITHDRAWN (Rev 1, 08/04/94)

D-5

Revision 1 08/04/94 RELIEF REQUEST NO. VR-5 WITHDRAWN (Rev 1, 08/04/94)

D-6

Revision 1 08/04/94 RELIEF REQUEST NO. VR-6 WITHDRAWN (Rev 1, 08/04/94)

D-7

Revision 1 08/04/94 RELIEF REQUEST NO. VR-7 WITHDRAWN (Rev 1, 08/04/94)

D-8

Revision 1 08/04/94 RELIEF REQUEST NO. VR-8 WITHDRAWN (Rev 1, 08/04/94)

D-9

Revision 1 08/04/94 RELIEF REQUEST NO. VR-9 WITHDRAWN (Rev 1, 08/04/94)

D-10

Revision 1 08/04/94 RELIEF REQUEST NO. VR-10 WITHDRAWN (Rev 1, 08/04/94)

Revision 1 08/04/94 RELIEF REQUEST NO. VR-11 WITHDRAWN (Rev 1, 08/04/94)

D-12

Revision 1 08/04/94 RELIEF REQUEST NO. VR-12 WITHDRAWN (Rev 1, 08/04/94)

D-13

Revision 1 08/04/94 RELIEF REQUEST NO. VR-13 BEZEL'afety Injection (2998-G-078 Sh 132)

V-3215 V-3225 v-3235 V-3245 A/C 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' E

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

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.

The only practical method for flow testing the safety inje ction header check valves is to dump the contents of the SIT into the reactor coolant system while in Mode 6.

The SIT dump is performed by establishing adequate initial conditions of water level and nitrogen pressure in t he SIT with its discharge isolation'alve closed.

The SIT discharge isolation valve is then opened to dump the contents of the SIT to the the refueling cavity.

Revision 1 08/04/94 RELIEF REQUEST NO. VR-13 (cont.)

The check valves cannot be full stroked open by passing the maximum required accident condition flow to simulate the LOCA flow. Under a large break LOCA accident conditions, the maximum (peak) flow rate through these valves would be approximately 20,000 gpm. The required test conditions for developing this full accident flow cannot be established. The SIT discharge isolation valves are motor operated valves with a nominal stroke time of 52 seconds. 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 peak blowdown rate of 20,000 gpm expected during a large break LOCA.

Analysis has shown that the check valves can be fully exercised open with the lower than accident condition flow during a SIT dump test. Non-intrusive test equipment employing acoustic and eddy-current technology can be used to verify the check valves are stroked fully open during these tests.

Each of these valves are installed in identical orientation and exposed to the same operating conditions. 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.

D-15

Revision 1 08/04/94 RELIEF REQUEST NO. VR-13 (cont.)

During each refueling outage, each of these valves will be stroked to fully exercise the check valves open. Non-intrusive test equipment employing acoustic and eddy-current technology will be used to 'verify the check valves are stroked fully open during these tests.

Should the alternate testing described above be determined to be impractical or an extreme hardship the following will be performed in place of the above described testing.

During each refueling outage, each of these valves will be partial-stroke exercised. 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 valves will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated.

Assurance of proper reassembly will be provided by performing a partial-flow test prior to returning a valve to service following disassembly.

The alternate testing described in this relief request has been revised to comply with NRC Generic Letter 89-04, Positions 1 or 2.

Revision 1 08/04/94 RELIEF REQUEST NO. VR-14 ZXZZEK'afety Injection (2998-G-078 Sh 132)

V-3217 V-3227 V-3237 V-3247 A/C N'hese 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.

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

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.

The only practical method for full flow testing of the safety injection header check valves is to dump the contents of the SIT into the reactor coolant system while in Mode 6. Shutdown cooling flowrates are not suficient to fully open the valves. The SIT dump is performed by establishing adequate initial conditions of water level and nitrogen pressure in the SIT with its discharge isolation valve closed. The SIT discharge isolation valve is then opened to dump the contents of the SIT to the the refueling cavity.

Revision 1 08/04/94 RELIEF REQUEST NO. VR-14 (cont.)

The check valves cannot be full stroked open by passing the maximum required accident condition flow to simulate the LOCA flow. Under 'a large break LOCA accident conditions, the maximum (peak) flow rate through these valves would be approximately 20,000 gpm. The required test conditions for developing this full accident flow cannot be established. The SIT discharge isolation valves are motor operated valves with a nominal stroke time of 52 seconds. 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 peak blowdown rate of 20,000 gpm expected during a large break LOCA.

Analysis has shown that the check valves can be fully exercised open with the lower than accident condition flow during a SIT dump test. Non-intrusive test equipment employing acoustic and eddy-current technology can be used to verify the check valves are stroked fully open during these tests.

Each of these valves are installed in identical orientation and exposed to the same operating conditions. 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.

D-18

Revision 1 08/04/94 RELIEF REQUEST NO. VR-14 (cont.)

E TE TIN During each refueling outage, each of these valves will be stroked to fully exercise the check valves open. Non-intrusive test equipment employing acoustic and eddy-current technology will be used to verify the check valves are stroked fully open during these tests.

Should the alternate testing described above be determined to be impractical or an extreme hardship the following will be performed in place of the above described testing.

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 valves will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. Assurance of proper reassembly will be provided by performing a partial-flow test prior to returning a valve to service following disassembly.

R VAL'he alternate testing described in this relief request has been revised to comply with NRC Generic Letter 89-04, Positions 1 or 2.

D-19

Revision 1 08/04/94 RELIEF REQUEST NO. VR-15 WITHDRAWN (Rev 1, 08/04/94)

D-20

Revision 1 08/04/94 RELIEF REQUEST NO. VR-16 GXSX12L Primary Containment Valves 6-inches NPS and larger subject to leakage rate testing per 10CFR50, Appendix J.

A/C (Check Valves)

A (Motor-operated valves)

Each of these valves is designated as a containment isolation valve maintaining the leakrate integrity of the primary containment in the case of an accident.

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

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

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-21

Revision 1 08/04/94 RELIEF REQUEST NO. VR-16 (cont.)

V NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 10.

D-22

Revision 1 08/04/94 RELIEF REQUEST NO. VR-17 WITHDRAWN (Rev 0, 07/16/93)

D-23

Revision 1 08/04/94 RELIEF REQUEST NO. VR-18 WITHDRAWN (Rev 1, 08/04/94)

D-24

Revision 1 08/04/94 RELIEF REQUEST NO. VR-19 WITHDRAWN (Rev 1, 08/04/94)

D-25

Revision 1 08/04/94 RELIEF REQUEST NO. VR-20 BXZGBL.

Containment Spray (2998-G-088)

V-07119 V-07120 Y'hese valves open to provide flow paths from the refueling water tank (RWT) to the containment spray and safety injection suction headers.

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

Full 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.

During 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-26

Revision 1 08/04/94 RELIEF REQUEST NO. VR-20 (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.

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 2.

D-27

Revision 1 08/04/94 RELIEF REQUEST NO. VR-21 WITHDRAWN (Rev 1, 08/04/94)

D-28

Revision 1 08/04/94 RELIEF REQUEST NO. VR-22 BXZZE'2L',

Containment Spray (2998-G-088)

V-07172 V-07174 These valves open to provide flow paths from the containment sump to the containment spray and safety injection suction headers during. recirculation.

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

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.

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.

D-29

Revision 1 08/04/94 RELIEF REQUEST NO. VR-22 (cont.)

V NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 2.

D-30

Revision 1 08/04/94 RELIEF REQUEST NO. VR-23 Containment Spray (2998-G-088)

V-07192 V-07193 These valves open to provide flow paths from the respective containment spray headers to the containment spray rings.

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

Full stroke exercising of 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.

D-31

Revision 1 08/04/94 RELIEF REQUEST NO. VR-23 (cont.)

N T I 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.

NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 2.

D-32

Revision 1 08/04/94 RELIEF REQUEST NO. VR-24 WITHDRAWN (Rev 1, 08/04/94)

D-33

Revision 1 08/04/94 RELIEF REQUEST NO. VR-25 WITHDRAWN (Rev 0, 07/16/93)

D-34

Revision 1 08/04/94 RELIEF REQUEST NO. VR-26 WITHDRAWN (Rev 0, 07/16/93)

D-35

Revision 1 08/04/94 RELIEF REQUEST NO. VR-27 BXST32L',

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

N v-09303 V-0 9304 V-09305 T

Y'hese 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.

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

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.

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

D-36

Revision 1 08/04/94 RELIEF REQUEST NO. VR-27 (cont.)

N T 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.

NRC Safety Evaluation of St. Lucie Unit 2 .Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 2.

D-37

Revision 1 08/04/94 RELIEF REQUEST NO. VR-28 WITHDRAWN (Rev 1, 08/04/94)

D-38

Revision 1 08/04/94 RELIEF REQUEST NO. VR-29 WITHDRAWN (Rev 1, 08/04/94)

D-39

Revision 1 08/04/94 RELIEF REQUEST NO. VR-30 GXZGBL.

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

V-3102 V-3103 These valves open to provide for mini-flow recirculation flow paths from the high pressure safety injection p'umps to the refueling water tank. This minimum flow through the respective pumps removes pump heat in the event of operation under low or no flow conditions.

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

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

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-40

Revision 1 08/04/94 RELIEF REQUEST NO. VR-30 (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 approximately 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.

PP VAL'RC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 2.

D-41

Revision 1 08/04/94 RELIEF REQUEST NO. VR-31 MOGUL.

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

V-08130 v-08163 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.

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

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

LT During the quarterly 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-42

Revision 1 08/04/94 RELIEF REQUEST NO. VR-31 (cont.)

E NAT 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.

V NRC Safety Evaluation of St. Lucie Unit 2 Inservice Testing Program Relief Requests dated May 2, 1994, approved this relief request pursuant to NRC Generic Letter 89-04, Position 2.

D-43

Revision 1 08/04/94 RELIEF REQUEST NO. VR-32 WITHDRAWN (Rev 1, 08/04/94)

D-44

Revision 1 08/04/94 WITHDRAWN (Rev 1, 08/04/94)

D-45

Revision 1 08/04/94 RELIEF REQUEST NO. VR-34 WITHDRAWN (Rev 1, 08/04/94)

D-46

REVISION l 08/04/94 Appendix E Valve Program Cold Shutdown Justifications

REVISION 1 08/04/94 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.

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 fail to show the valve returnedto to a valve were fail open or valve indication the fully closed position following exercising, prudent plant operation would probably likely result in a plant shutdowns

REVISION 1 08/04/94 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.

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.

V 2177' 2190' 2191 and V 2526 CVCS Boron Addition Valves CV/PO test is addressed in Refueling Outage Justification 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 1 08/04/94 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 shock.

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.

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 Charging Line Isolation Valve Closing this valve 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 the valve failed to reopen, then an unexpected plant shutdown would be required.

E-3

REVISION 1 08/04/94 V-3101 Safety Injection Supply To Volume Control Tank CV/PO test is addressed in Refueling Outage Justification.

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-3414 and V-3427 HPSI Pump Discharge Check Valves CV/PO test is addressed in Refueling Outage Justification.

V-3522 and V-3547 HPSI Hot Leg Injection Check Valve CV/PO and CV/C tests are addressed in Refueling Outage Justification.

V-3113, V-3133, V-3143, and V-3766 HPSI Cold Leg Injection Check Valves CV/PO test is addressed in Refueling Outage Justification.

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 direction. The closure tests can only be performed at the end of the outage after the valves have been exercised open earlier by the partial stroke open tests.

E-4

REVISION 1 08/04/94 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 shutdown.

V 3524' 3525~ V 3526/ V 3527 HPSI Hot Leg Injection Check 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. 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.

Leak testing to verify the closure capability 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, the St. Lucie 2 Technical Specification 4.4.6.2.2 addresses the valve test frequency in a manner appropriate for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing. Therefore, the closure capability of these check valves shall be demonstrated by verifying leakage to be within its limits during cold shutdown outages only when any of the following conditions are met:

At least once per 18 months.

2.

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 ~

Prior to entering MODE 2 whenever the plant has= been in if leakage testing has not been performed in the previous 9 months.

E-5

REVISION 1 08/04/94

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.

CV/PO test is addressed in Refueling Outage Justification.

V-3545 Shutdown Cooling Cross Connect Valve The breaker for this valve is required to be deenergized except during plant cold shutdown or refueling modes to meet position C.l to Regulatory Guide 1.63 revision 2. This is to protect the mechanical integrity of the valves electrical penetration assembly should the maximum short-circuit vs time condition occur given single random failure of circuit overload protection devices.

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.

V-3215, V-3225, V-3235, and V-3245 Safety Injection Discharge Check 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. 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. Leak testing to verify the closure capability 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, the St. Lucie 2 Technical Specification 4.4.6.2.2 addresses the valve test frequency in a manner appropriate for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not E-6

REVISION 1 08/04/94 warranted and implementation would be difficult and confusing. Therefore, the closure capability of these check valves shall be demonstrated by verifying leakage to be within its limits during cold shutdown outages only when any of the following conditions are met:

At least once per 18 months.

2.

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 ~

Prior to entering MODE 2 whenever the plant has been in if leakage testing'has not been performed in the previous 9 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.

V-3217, V-3227, V-3237, and V-3247 Safety Injection Header to RCS Check 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. 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. Leak testing to verify the closure capability 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, the St. Lucie 2 Technical Specification 4.4.6.2.2 addresses the valve test frequency in a manner appropriate for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing. Therefore, the closure capability of these check valves shall be demonstrated by verifying leakage to be within its limits during cold shutdown outages only when any of the following conditions are met:

At least once per 18 months'.

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 ~ if Prior to entering MODE 2 whenever the plant has been in leakage testing has not been performed in the previous 9 months.

E-7

REVISION 1 08/04/94

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.

CV/PO test is addressed in Relief Request VR-14 V-3258, V-3260, V-3259, and V-3261 Safety Injection Header Check Valves 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.

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.

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. Leak testing to veri,fy the closure capability 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, the St. Lucie 2 Technical Specification 4.4.6.2.2 addresses the valve test frequency in a manner appropriate for these valves'atisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing. Therefore, the closure capability of these check valves shall be demonstrated by verifying leakage to be E-8

REVISION 1 08/04/94 within its limits during cold shutdown outages only when any of the following conditions are met:

At least once per 18 months.

2.

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 ~

Prior to entering MODE 2 whenever the plant has been in if leakage testing has not been performed in the previous 9 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.

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 if a valve were to fail to re-close the result would be depressurization of the affected SIT.

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 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.

E-9

REVISION 1 08/04/94 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 steam generator which would result in a severe transient on a

the steam and reactor systems and a possible plant trip.

V-08130 and V-08163 Steam-Driven AFN 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)

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)

'eedwater 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.

REVISION 1 08/04/94 HCV-14-1, 2, 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 train and decreased flow to essential equipment. This CCW could result in component damage or an undesirable plant transient.

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. Testing 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 section of 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 1 08/04/94 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.

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.

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 These valves can only be exercised manually requiring direct access to each valve. Since these valves are located within the containment building, access is limited and not routinely practical.

REVISION 1 08/04/94 Appendix F Valve Program Refueling Outage Justifications

REVISION 1 08/04/94 Appendix F: REFUELING OUTAGE JUSTIFICATIONS This appendix is intended to provide the justification for performing valve exercising only at refueling outage conditions as permitted by OM-10, 'H4.3.2.2 (d), (e), and (h) and '1[4.2.1.2 (d), (e),

and (h)

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.

REVISION 1 08/04/94 V-2177 V-2190 V-2191 v-2526 Chemical and Volume Control (2998-G-078, Sh 121)

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.

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.

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.

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.

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REVISION 1 08/04/94 V-2443 V-2444 Chemical and Volume Control (2998-G-078, Sh 121)

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.

Full-stroke testing these valves requires operating the boric acid makeup pumps at or near rated flow and verifying Cull 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.

A second circuit that circulates water to the VCT has flow rate measuring instrumentation installed 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.).

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REVISION 1 08/04/94 V-07000 V-07001 Safety Injection (2998-G-078 Sh 130)

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

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 function. Thus, the only practical opportunity for testing these valves is during refueling outages when water from the RWT is used to refueling cavity.

fill the

REVISION 1 08/04/94 V-3101 GXSX12L'.

Safety In jection (2998-G-078 Sh 130)

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.

Transferring the large quantity of water from a SIT to the VCT 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.

During cold shutdown, the, introduction of'xcess 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.

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REVISION 1 08/04/94 V-3104 V-3105 BYSXJ' Safety Injection System (2998-G-078, Sh 130)

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.

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

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. During reactor refueling outages these two valves can 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'-6

REVISION 1 08/04/94 V-3401 V-3410 SYZZEZL.

Safety Injection (2998-G-078 Sh 130)

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).

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 3.4.9.

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REVISION 1 08/04/94 V-3414 V-3427 BX.~Z Safety Injection (2998-G-078 Sh 130)

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.

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 3.4.9.

Partial flow exercising of these valves can be performed by 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.

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.

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REVISION 1 08/04/94 v-3522 V-3547 SYST1~

Safety Injection (2998-G-078 Sh 130)

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 the RCS via the HPSI headers.

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.

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.

The closure tests can only be performed at the end of the outage after the valves have been exercised open earlier by the partial stroke open tests.

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REVISION 1 08/04/94 V-3113 V-3133 V-3143 V-3766 BYE~

Safety Injection (2998-G-078 Sh 131)

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

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.

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 isolati'on 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.

REVISION 1 08/04/94 V-3524 v-3525 V-3526 V-3527 GYKXK'afety Injection (2998-G-078 Sh 131)

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.

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.

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.

REVISION 1 08/04/94 BEEZER

'akeup Water (2998-G-084)

V-15328 This valve closes to provide primary containment for the penetration related to the makeup water supply line to the containment building.

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.

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REVISION 1 08/04/94 V-18195 Instrument Air (2998-G-085, Sh 2)

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

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. Such a test necessitates 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.

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.

REVISION 1 08/04/94 V-07129 V-07143 GYGXlRL'ontainment Spray (2998-G-088)

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

Full 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 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 function.

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REVE S XON 1 08/04/94 BYSZl~H'ontainment Spray (2998-G-088)

V-07256 V-07258 These valves open to provide flow paths from the Hydrazine pumps to the respective containment spray pump suction header.

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 Hydrazine is a known carcinogen, with cumulative toxic affects when absorbed through the skin, inhaled, or ingested.

Hydrazine build up in the RWT is undesirable do to the increased potential for exposing personnel to the chemical or releasing it to the environment. Personnel would additionally be exposed to Hydrazine while restoring level in the tank. Due to the personnel hazards associated with handling the hazardous chemical Hydrazine, testing quarterly or during cold shutdowns is impractical.

F-15