ML17228B346

Rev 0 to Plant Administrative Procedure 2-0010024, Inservice Testing Program for Pumps & Valves.

ML17228B346
Person / Time
Site:	Saint Lucie
Issue date:	11/16/1995
From:	Scarola J FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17228B347	List: ML17228B346 ML17309A807
References
2-0010024, 2-10024, NUDOCS 9512110304
Download: ML17228B346 (214)

Text

Page 1 of 149 FQR INFORMAVIGR GRt.Y This document ts not m'ntrolled. Before um, Yer@ lnforrl28tlon YrSl 8 co roll&w FEQRIDIA POWER 8 LIGHT COMPANY INmAL ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024 REVISION 0

1.0 TITLE

INSERVICE TESTING PROGRAM FOR PUMPS AND VAL'VES 2.0 REVIEW AND APPROVAL:

Reviewed by Facility Review Group 11/16 1995 Approved by J. Scarola Plant General Manager 11/16 1995 Revision Reviewed by 19 Approved by Plant General Manager 19

3.0 SCOPE

3,1 PURPOSE This document outlines the IST Program for St. Lucie Plant, Unit 2 based on the requirements of the ASME Boiler and Pressure Vessel Code.

3.2 DISCUSSION Inservice Testing Requirements 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 IWP-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 S 2 OPS DATE DOCT PROCEDURE DOCN 2-0010024 sYs COMP COMPLETED ITM 0 9Si2ii0304 9S1204 PDR ADOCK 05000389 P, .PDR

Page 2 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

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(continued) 3.2 (continued)

1. (continued)

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. This review eliminated systems (and associated components) that clearly do not fit the basic Code definitions including that of ISI boundary classification.

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. Each 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; A. 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 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.

B. 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.

Page 3 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

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(continued) 3.2 (continued)

1. (continued)

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

1. Updated Final Safety Analysis Report

2. Technical Specifications

3. Plant System Descriptions (Training) Documents

4. Special analysis

5. Commitment correspondence

6. Plant Operating Procedures

7. Emergency Operating Procedures

8. 10 CFR50 Appendix J Leakrate Test Program

9. PSL Design Basis Documents D. 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 3.2.2 to each one.

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

2. IST PROGRAM TESTING REQUIREMENT GUIDELINES The following guidelines are set fo'ith 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.

Page 4 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES .

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(continued) 3.2 (continued)

2. (continued)

A. Where multiple components are capable of performing the same equivalent and redundant specified function (e.g. multiple valves closing in series) and where the components are not supplied by alternate and redundant power supplies, only one need be included in

'he program. The component must be relied upon to perform and not simply have the capability of performance. This exemption only applies where licensing documents do not 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.

B. 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 EOPs) 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.

C. Valves installed primarily for the purpose of providing convenient operational flexibility (e.g. 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.

D. 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 by the Code and is not intended to imply the need for verifying a valve's response to automatic logic system output.

Page 5 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

'.0 SCOPE: (continued) 3.2 (continued)

2. (continued)

E. Valves whose sole functions is to provide system. or component redundancy related to failure of passive components need not be included if a set of all of the active components (pumps and valves) needed to 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.

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

G. 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.

H. 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.

I. Any active Category A valve shall be designated for testing (exercising) to the closed direction.

• J. 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 response or recovery operations, then periodic exercising per the Code is required (i,e. the valve cannot be

. considered passive).

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

Page 6 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 TESTING PROGRAM FOR PUMPS AND VALVES '-'NSERVICE

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(continued) 3.2 (continued)

2. (continued)

L. 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.

M. 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.

N. 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.

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

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

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

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

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

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

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

Page 7 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES 3.0 SCOPE; (continued) 3.2 (continued)

2. (continued)

Q. (continued)

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

3.3 AUTHORITY The St. Lucie Unit 2 IST Program is 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 it was determined that the proposed alternative is in accordance with the requirements 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-1 988, 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 $ IWP-3300 and

$ IWP-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,

$ 4.2.1.2 and 4.3.2.2 will be followed as alternatives to $ IWV-3412(a) and IWV-3522 not including IWV-3522(a) and (b).

0 Page 8 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO, 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

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(continued) 3.3 (continued)

3. The analysis of leakage rate and corrective action requirements of-ASME/ANSI OMa-1 988, Part 10, $ 4.2.2.3 (e) and (f) will be followed-as alternatives to $ IWV-3426 and IWV-3427.

This St. Lucie Unit 2 ASME Inservice Test (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:

Begins Ends August 8, 1993 August 7, 2003

4.0 PRECAUTIONS

NONE

5.0 RESPONSIBILITIES

5.1 The Operations Support and Testing department (OST) is responsible for the following:

A. Ensuring plant changes affecting pumps and valves are reviewed to incorporate any changes into the program for applicable pumps and valves.

B. Obtaining approval for relief of any ASME Code requirements from the NRC.

C. Reviewing this procedure when required as a result of Code updating in accordance with 10 CFR 50.55a.

6.0 REFERENCES

6.1 Title 10, Code of Federal Regulations, Part 50.

6.2 NRC Regulatory Guides - Division 1.

6.3 Standard Review Plan 3.9.6, Inservice Testing of Pumps and Valves.

I 6.4 Final Safety Analysis Report, St. Lucie Unit 2.

Page 9 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES.

6.0 REFERENCES

(continued) 6.5 St. Lucie Plant Unit 2 Technical Specifications.

6.6 ASME Boiler and Pressure Vessel Code,Section XI, 1986 Editio .

6.7 NRC Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs.

6.8 Minutes of the Public Meetings on Generic Letter 89-04.

6.9 Supplement to Minutes of the Public Meetings on Generic Letter 89-04 by J. G. Partlow, September 26, 1991.

6.10 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.

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

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

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

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

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

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

7.0 RECORDS L NOTIFICATIONS:

This procedure shall be maintained in the plant files in accordance with Ql 17-PR/PSL-1, "Quality Assurance Records" ~

I Page 10 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES',

'.0 INSTRUCTIONS:

8.1 INSERVICE TESTING PROGRAM FOR PUMPS Code Compliance This IST Program for pumps meets the requirements af Subsection IWP of the Code and any interpretations or additional requirements imposed by NRC Generic Letter 89-04. Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant to the requirements of 10 CFR 50.55a(f)(iii) and NRC Generic Letter 89-04.

Allowable Ranges of Test Quantities The allowable ranges for test pararrieters 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 range may be determined, on a case-by-case basis, in accordance with IWP-3210.

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.

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.

5. Relief Requests for Pump Testing Appendix B includes all relief requests related to pump testing.

Page 11 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

8.0 INSTRUCTIONS

8.2 INSERVICE TESTING PROGRAM FOR VALVES

1. Code Compliance This IST Program for valves meets the requirements of Subsection-IWV-of Code and any interpretations or additional requirements imposed by

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

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 and refueling periods as permitted by OM-10, paragraph 4.2.1.2 and 4.3.2.2. Justifications for this deferred testing are provided in Appendix E and F, Stroke Time Acceptance Criteria When required, the acceptance criteria for the stroke times of power-operated valves will be set forth in NRC Generic Letter 89-04.

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 NRC Generic Letter 89-04, Position 1.

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.

Relief Requests for Valve Testing Appendix D includes all relief requests related to valve testing.

Page 12 of 149 ST. LUCIE UNIT 2 1A ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX A PUMP PROGRAM TABLES PUMP INLET DIFF./'RES.

FLOW NUMBER DESCRIPTION CL COORD SPEED PRES. RATE . VIBRA AFW 2A AUXILIARYFEEDWATER PUMP B-4 -'Y PRR':PR-4 AFW 28 AUXILIARYFEEDWATER PUMP E-4 Y .

AFW 2C AUXILIARYFEEDWATER PUMP F-3 Y:PR-2 Y:PR-4 BAM 2A BORIC ACID MAKEUP PUMP FA NA Y:PR-8 Y:PR-5 BAM 28 BORIC ACID MAKEUP PUMP G-4 NA Y:PR-8 Y:PR-5 CCW 2A COMPONENT COOLING WATER PUMP 3 E-6 NA CCW 2B COMPONENT COOLING WATER PUMP 3 E-6 CCW 2C COMPONENT COOLING WATER PUMP 3 E-6 CHG 2A CHARGING PUMP G-2 Y:PR-12 CHG 2B CHARGING PUMP E-2 NA Y:PR-12 CHG 2C CHARGING PUMP B-2 NA Y:PR-12 CS 2A CONTAINMENT SPRAY PUMP G-5 Y:PR-15 Y Y:PR-6 CS 28 CONTAINMENT SPRAY PUMP H-5 Y:PR-15 Y:PR-6 HPSI 2A Hl PRESS SAFETY INJECTION PUMP 2 B-3 NA Y:PR-15 Y Y:PR-9 HPSI 2B HI PRESS SAFETY INJECTION PUMP 2 F-3 NA Y:PR-15 Y:PR-9 HYD 2A HYDRAZINE PUMPS G-3 Y:PR-2 N:PR-17 N:PR-17 Y:PR-17 Y:PR-14 HYD 2B HYDRAZINE PUMPS H-3 Y:PR-2 N:PR-17 N:PR-17 Y:PR-17 Y:PR-14 ICW 2A INTAKE COOLING WATER PUMP H-5 Y:PR-11 ICW 2B INTAKE COOLING WATER PUMP H-7 Y:PR-11 ICW 2C INTAKE COOLING WATER PUMP H-6 NA Y:PR-11 LPSI 2A LO PRESS SAFETY INJECTION PUMP 2 EN NA Y:PR-15 Y:PR-10 Y:PR-10 LPSI 2B LO PRESS SAFETY INJECTION PUMP 2 F-3 NA Y:PR-15 Y Y:PR-10 Y:PR-10 LEGEND Pump number Numerical designator indicated on the respective flow diagram.

Description Generic name/function of the pump.

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

Coord Corresponds to the flow diagram coordinates of the pump.

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

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

Page 13 of 149 ST, LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 1 of 26)

RELIEF REQUEST NO. PR-1 (Page 1 of 1)

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

Page 14 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 2 of 26)

RELIEF REQUEST NO. PR-2 (Page 1 of 1)

COMPONENTS Various SECTION XI REQUIREMENT:

The full-scale range of each instrument shall be three times the reference value or less. (IWP-41 20)

BASIS FOR RELIEF:

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

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

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

ALTERNATE TESTING:

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

+M percent.

APPROVAL:

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).

Page 15 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES B 'PPENDIX PUMP PROGRAM RELIEF REQUESTS (Page 3 of 26)

RELIEF REQUEST NO. PR-3 ~

(Page 1 of 1)

'ITHDRAWN (Rev. 0, 07/1 6/93)

Page 16 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0,;;,,, .

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES.-'.".",.

APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 4 of 26)

RELIEF REQUEST NO. PRA (Page 1 of 2)

COMPONENTS:

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

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1 ~ (IWP-3300).

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

BASIS FOR RELIEF:

There are 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'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.

Page 17 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 5 of 26)

RELIEF REQUEST NO. PR-4 (Page 2 of 2)

ALTERNATE TESTING'uring quarterly testing of the AFW pumps while the pumps are operated 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.

APPROVAL:

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

Page 18 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES' APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 6 of 26)

RELIEF REQUEST NO. PR-5 (Page 1 of 2)

COMPONENTS:

Boric Acid Makeup (BAM) Pumps 2A and 2B (2998-6-078, Sh 121 B)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1. (IWP-3300)

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

BASIS FOR RELIEF'here 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.

Page 19 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX 8 PUMP PROGRAM RELIEF REQUESTS (Page 7 of 26)

RELIEF REQUEST NO. PR-5 (Page 2 of 2)

The second circuit recirculates water to the Refueling Water Tank (RWT) or the Volume Control Tank (VCT). During the normal plant operation at power it is undesirable to pump to the RWT and deplete the BAM Tank inventory. One of the two BAM Tanks is maintained at Tech. Spec. level while the other is used as required for plant operation. The Tech. 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. t4o flow rate measuring instrumentation is installed in this line. Pumping boric acid from tank to tank would be possible but the flow rates would be small, limiting pump operation to the high head section of the pump curve. In addition, one of the two BAM Tanks is maintained at Tech. Spec. level while the other is used as required for normal plant operation. The Tech. Spec. BAM Tank cannot be pumped from because it must be maintained at a level near the top of the tank. This narrow band limits the amount that can be pumped to it or from it to only a few hundred gallons. The other BAM Tank's level will vary from test to test by as much as 15 to 20 feet. This variance in pump suction pressure will have a direct affect on pump head and flow such that test repeatability would be questionable.

ALTERNATE TESTING:

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

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

APPROVAL:

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.

Page 20 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 8 of 26)

RELIEF REQUEST NO. PR-6 (Page 1 of 2)

COMPONENTS:

Containment Spray (CS) Pumps 2A and 2B (2998-G-088 Sh 1)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1. (IWP-3300)

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

BASIS FOR RELIEF:

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

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

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

ALTERNATE TESTING'he 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.

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.

h

Page 21 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 9 of 26)

RELIEF REQUEST NO. PR-6 (Page 2 of 2)

APPROVAL:

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.

Page 22 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 10 of 26)

RELIEF REQUEST NO. PR-7 (Page 1 of 1)

WITHDRAWN (Rev. 0, 07/1 6/93)

Page 23 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0  :,

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES B 'PPENDIX PUMP PROGRAM RELIEF REQUESTS (Page 11 of 26)

RELIEF REQUEST NO. PR-8 (Page 1 of 1)

COMPONENTS:

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

SECTION XI REQUIREMENTS:

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

BASIS FOR RELIEF:

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

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

ALTERNATE TESTING:

The boric acid makeup pump suction pressures will be calculated based on the height of liquid in the associated tank once during each inservice test.

Subsequently, these calculated values will be used to determine pump differential pressures for evaluation of pump parameters.

APPROVAL:

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

Page 24 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 12 of 26)

RELIEF REQUEST NO. PR-9 (Page 1 of 2)

COMPONENTS:

High Pressure Safety Injection (HPSI) Pumps 2A and 2B (2998-G-078, Sh 13QA)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1, (IWP-3300)

BASIS FOR RELIEF:

During quarterly testing of the HPSI Pumps, the pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) pressure, Flow is routed through a minimum flow test line leading to the refueling water tank (RWT).

This line has no installed flow rate measuring instrumentation and measuring flow rate during quarterly testing is not practical.

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

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

ALTERNATE TESTING'uring 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.

1 Page 25 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 13 of 26)

RELIEF REQUEST NO. PR-9 (Page 2 of 2)

APPROVAL:

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.

Page 26 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 TESTING PROGRAM FOR PUMPS AND VALVES 'NSERVICE APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 14 of 26)

RELIEF REQUEST NO. PR-10 (Page 1 of 2)

COMPONENTS:

Low Pressure Safety Injection (LPSI) Pumps 2A and 2B (2998-G078, Sh 130B)

SECTION XI REQUIREMENT:

Each inservice test shall include the measurement and observation of all quantities in Table IWP-3100-1. (IWP-3300)

BASIS FOR RELIEF:

During quarterly testing of the LPSI pumps, the pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) 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.

ALTERNATE TESTING:

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

Substantial flow testing will be performed during cold shutdowns. Pump differential pressure, flow rate and vibration (if RCPs secured) will be measured and evaluated per IWP-3100 and IWP-3200. Testing 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.

Page 27 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO, 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 15 of 26)

RELIEF REQUEST NO. PR-10 (Page 2 of 2)

APPROVAL:

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.

Page 28 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO, 2-0010024, REVISION 0(

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES

'PPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 16 of 26)

RELIEF REQUEST NO. PR-'I1 (Page 1 of 1)

COMPONENTS'ntake Cooling Water Pumps 2A, 2B and 2C (2998-G-082 Sh 2)

SECTION XI REQUIREMENT:

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)

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

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

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

APPROVAL:

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).

Page 29 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX 8 PUMP PROGRAM RELIEF REQUESTS (Page 17 of 26)

RELIEF REQUEST NO. PR-12 (Page 1 of 2)

COMPONENTS:

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

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

BASIS FOR RELIEF:

r The reactor coolant charging pumps operate at approximately 210-215 rpm which equates to a rotational frequency of 3.50 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+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). 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:

Page 30 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 18 of 26)

RELIEF REQUEST NO. PR-12 (Page 2 of 2)

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

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 show an increase from both the attenuated sub-synchronous and 1X 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 present use of the Bently Nevada 270 cpm probes with the portable TK-81 instrument is capable of collecting sufficiently reliable data to identify changes from baseline readings to indicate possible problems with the pumps.

ALTERNATE TESTING:

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

APPROVAL:

This revised relief request is pending NRC approval NRC Safety Evaluation of St.

~

Lucie Unit 2 lnservice Testing Program Relief Requests dated August 23, 1993, and May 2, 1994, provided interim approval.

Page 31 of 149 ST, LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B, PUMP PROGRAM RELIEF REQUESTS (Page 19 of 26)

RELIEF REQUEST NO. PR-'I3 (Page 1 of 1)

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

. Page 32 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 20 of 26)

RELIEF REQUEST NO. PR-14 (Page 1 of 1)

COMPONENTS:

Hydrazine Pumps 2A and 2B SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

The 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).

ALTERNATE TESTING:

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

APPROVAL:

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.

Page 33 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 "'"-',:-,l'NSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 21 of 26)

RELIEF REQUEST NO. PR-15 (Page 1 of 2)

COMPONENTS:

Containment Spray Pumps 2A and 2B (2998-G-088 Sh 1)

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

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

SECTION XI REQUIREMENTS:

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

BASIS FOR RELIEF:

The system installation does not provide any 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 test would cause a noticeable head loss in the suction piping.

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

ALTERNATE TESTING:

During the quarterly pump tests, the pump's suction pressures will be calculated based on the height of liquid in the associated RWT.'ubsequently, 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.

Page 34 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 22 of 26)

RELIEF REQUEST NO. PR-15 (Page 2 of 2)

APPROVAL:

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).

Page 35 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page.23 of 26)

RELIEF REQUEST NO. PR-16 (Page 1 of 1)

WITHDRAWN (Rev. 0, 07/16/93)

Page 36 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX 8 PUMP PROGRAM RELIEF REQUESTS (Page 24 of 26)

RELIEF REQUEST NO. PR-17 (Page 1 of 3)

COMPONENTS:

Hydrazine Pumps 2A and 2B (2998-G-088 Sh 1)

SECTION XI REQUIREMENTS:

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

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

P BASIS FOR RELIEF:

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 tow 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 dampening devices.

The installed flow instrumentation has been demonstrated to be inadequate for inservice testing purposes. This 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.

Page 37 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 25 of 26)

RELIEF REQUEST NO. PR>>17 (Page 2 of 3)

Refueling outage testing has demonstrated that techniques used to average the indicated flow readings are inconsistent 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. Even if such instrumentation were found to be available the costs 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 surveillance 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 pump have been performed. The pump discharge was directed to a container of a known volume. The amount of time to fill the container was measured and then used to calculate an average flow rate for the pump. 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 degradation.

Page 38 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0-INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES:,;; .;.

APPENDIX B PUMP PROGRAM RELIEF REQUESTS (Page 26 of 26)

RELIEF REQUEST NO. PR-17 (Page 3 of 3)

ALTERNATE TESTING:

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.

APPROVAL; 1

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.

Page 39 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 1 of 36)

LEGEND VALVE NUMBER The plant alpha-numerical designator for the subject valve 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 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.

Page 40 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES '.',.',

APPENDIX C VALVE PROGRAM TABLES (Page 2 of 36)

LEGEND (continued)

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.

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

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

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

Page 41 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 3 of 36)

LEGEND (continued)

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-1-1987 SD Disassembly, 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)

VALVETABLES P & ID: 2998-6-078 SH 107 SYSTEM: REACTOR COOLANT SYSTEM Valve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type NP Pos. lnd Mode E

Freq Req.

Remarks Number EO CS V1 460 C-5 2 1.000 Globe A SO LC Yes FC Pl 2Y EO CS V1461 DS 2 1.000 Globe A SO LC Yes FC Pl 2Y EO CS V1 462 D-5 2 1.000 Globe A SO LC Yes FC Pl 2Y EO CS V1 463 ~ E-5 2 1.000 Globe A SO LC Yes FC Pl 2Y EO CS V1 464 D-6 2 1.000 Globe A SO LC Yes FC Pl 2Y EO CS V1 465 D-6 2 1.000 Globe A SO LC Yes FC PI 2Y EO CS V1466 E-6 2 1.000 Globe A SO LC Yes FC Pl 2Y

Page 42 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 4 of 36)

P & ID: 2998-G-078 SH 'I08 SYSTEM: REACTOR COOLANT SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Number Type Pos. Ind Mode EO CS V1474 D-4 B 3.000 Globe A SO C Yes FC Pl 2Y EO CS V1475 F-4 B 3.000 Globe A SO C Yes FC Pl 2Y EC QR V1476 D-5 B 3.000 Gate A MO 0 Yes FAI Pl 2Y EC QR V1477 F-5 B 3.000 Gate A MO 0 Yes FAI Pl 2Y P & ID: 2998-G-078 SH 109 SYSTEM: REACTOR COOLANT SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type Remarks Number Type Pos. Ind Mode Freq Req.

V1200 C-4 1 3.000 Safety S/A C No SRV RF V1201 C-4 1 3.000 Safety S/A C No SRV RF V1202 C-4 1 3.000 Safety S/A C No SRV RF P & ID: 2998-G-078 SH 120 SYSTEM: CHEMICAL AND VOLUME CONTROL Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type E Remarks Number Type Pos. Ind Mode Freq Req.

V2345 B-3 3 C 2.000 Relief S/A No N/A SRV RF EC CS FS CS V2522 C-2 2 A 2.000 Globe DO Yes FC Pl 2Y SLT-1 2Y V2531 C-6 3 C 2.000 Relief S/A SRV RF

Page 43 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 5 of 36)

P & ID: 2998-G-078 SH '121A SYSTEM: CHEMICAL AND VOLUME CONTROL Valve Act. Norm Rem Fail Test Relief Coord CL Cat. Size Type Exam Remarks Number Type Pos. Ind Mode Freq Req.

V2115 E-4 C 4.000 Relief A S/A C No SRV RF V2118 E-5 C 4.000 Check A S/A 0 No CV/0 QR E-6 CV/0 RF V2191 C 3.000 Check A S/A C No CV/PO CS V2311 F-5 C 0.500 Relief A S/A C No SRV RF V2446 DA C 0.750 Relief A S/A C No SRV RF V2447 E-3 C 0.750 Relief A S/A C No SRV RF EC CS V2501 D-5 8 4.000 Gate A MO 0 Yes FAI EO CS Pl 2Y EC QR V2504 F-6 B 3.000 Gate A MO C Yes FAI EO QR Pl 2Y EC CS FS CS V2505 C-3 A 0.750 Globe A DO 0 Yes FC Pl 2Y SLT-1 2Y EC QR V2507 B-2 B 0.750 Globe A DO LO Yes FO PI 2Y EC CS FS CS V2524 C-2 A 0.750 Globe A DO 0 Yes FC Pl 2Y SLT-1 2Y EC QR V2525 F-4 B 4.000 Gate A MO C Yes FAI Pl 2Y E-6 CV/0 RF V2526 C 4.000 Check A S/A C No CV/PO CS V2674 D-5 C 4.000 Check A S/A 0 No CV/0 QR

Page 44 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 6 of 36)

P & ID: 2998-6-078 SH 121B SYSTEM: CHEMICAL AND VOLUME CONTROL Valve Act. Norm Rem Fail -Test Relief Coo rd. CL Cat. Size Type A/P Remarks Number Type Pos. Ind Mode Freq Req.

EC QR FCV-2210Y F-6 2 B 1.000 Globe A DO C Yes FC FS QR Pl 2Y CV/0 RF V2177 H-5 2 C 3.000 Check A S/A C No CV/PO CS CV/0 RF V2190 G-2 2 C 3.000 Check A S/A C No CV/PO CS CV/C QR V2443 G-4 2 C 3.000 Check A S/A C No CV/0 RF CV/PO QR V2444 F-4 3 C 4.000 Check A S/A 0 No CV/0 QR EO QR V2508 F-3 2 B 3.000 Gate A MO C Yes FAI Pl 2Y EO QR V2509 F-2 2 B 3.000 Gate A MO C Yes FAI Pl 2Y EO QR V2514 H-5 2 B 3.000 Gate A MO C Yes FAI Pl 2Y EC QR V2650 H-4 2 B 1.000 Globe A DO 0 Yes FC FS QR Pl 2Y EC QR V2651 DP 2 B 1.000 Globe A DO 0 Yes FC FS QR Pl 2Y

Page 45 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES - ':.-

APPENDIX C VALVE PROGRAM TABLES (Page 7 of 36)

P & ID: 2998-6-078 SH 122 SYSTEM: CHEMICAL AND VOLUME CONTROL Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size T'jjpe Exam Remarks Number Tjpe Pos. Ind Mode Freq Req.

EC QR EO QR SE-02-01 D-6 B 2.000 Globe SO 0 Yes FO FS QR Pl 2Y EC QR EO QR SE-02-02 C-6 1 B 2.000 Globe SO 0 Yes FO FS QR Pl 2Y EC CS EO CS SE-02-03 E-6 1 B 2.000 Globe SO LC Yes FS CS Pl 2Y EC CS EO CS SE-02-04 E-6 1 B 2.000 Globe SO LC Yes FC FS CS PI 2Y CV/C QR V2167 B-3 2 C 2.000 Check A S/A C No CV/0 QR CV/C QR V2168 E-3 2 C 2.000 Check S/A C No CV/0 QR CV/C QR V2169 G-3 2 C 2.000 Check S/A C No CV/0 QR V2318 D-2 2 C'.500 Relief S/A C No SRV RF V2321 F-2 2 C 0.500 Relief S/A C No SRV RF V2324 F-3 2 C 1.500 Relief S/A C No SRV RF V2325 D-3 2 C 1.500 Relief .A S/A C No SRV RF V2326 B-3 2 C 1.500 Relief S/A C No SRV RF V2340 A-3 2 B 2.000 Gate MAN C No FAI EE QR V2431 E-6 1 C 2.000 Check S/A C No CV/0 CS V2432 D-6 1 C 2.000 Check S/A 0 No CV/0 QR V2433 C-6 1 C 2.000 Check S/A 0 No CV/0 QR

Page 46 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 8 of 36)

P & ID: 2998-6-078 SH 122 (cont,) SYSTEM: CHEMICAL AND VOLUME CONTROL, Valve Act. Norm Rem Fail Test Relief Coord CL Cat. Size Type A/P Exam Remarks Number Type Pos. Ind Mode Freq Req.

V2440 A-3 2 C 2.000 Check A S/A C No CV/0 CS V2462 B-5 2 C 2.000 Check A S/A 0 No CV/0 QR EC CS V2515 G-7 1 B 2.000 Globe A DO 0 Yes FS CS Pl 2Y EC CS V2516 G-6 1 B 2.000 Globe A DO 0 Yes FC FS CS PI 2Y EC CS FS CS V2523 B-5 2 B 2.000 Globe P DO LO Yes FO Pl 2Y SLT-1 2Y EC QR V2553 2 B 2.000 Globe A MO 0 Yes FAI Pl 2Y EC QR V2554 E-3 2 B 2.000 Globe A MO 0 Yes FAI Pl 2Y EC QR V2555 H-3 2 B 2.000 Globe A MO 0 Yes FAI Pl 2Y V2588 B-1 2 C 0.500 Relief A S/A C No SRV RF

Page 47 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 TESTING PROGRAM FOR PUMPS AND VALVES 'NSERVICE APPENDIX C VALVE PROGRAM TABLES (Page 9 of 36)

P & ID: 2998-G-078 SH 130A SYSTEM: SAFETY INJECTION SYSTEM Norm Rem Fail Test Relief Valve Coo rd. CL Cat. Size Type NP Act. Ind Mode Remarks Number Type Pos. Freq Req.

CV/PO QR V3102 B-3 2 C 2.000 Check A S/A Nos INSP SD CV/PO QR V3103 E-4 2 C 2.000 Check A S/A No INSP SD B-2 CV/0 RF V3401 2 C 6.000 Check A S/A No CV/PO QR F-2 CV/0 RF V3410 2 C 8.000 Check A S/A No CV/PO QR V3412 E-5 2 C 1.000 Relief A S/A No SRV RF CV/C QR V3414 F-4 2 C 3.000 S/Check A S/A No CV/0 RF CV/PO CS V3417 B-5 2 C 1.000 Relief A S/A No SRV RF CV/C QR V3427 2 C 3.000 S/Check A S/A CV/0 RF'S CV/PO V3518 B-6 2 B 2.000 Globe A MAN No FAI EE QR V3519 B-5 2 B 2.000 Globe A MAN No FAI EE QR CV/C CS V3522 2 C 3.000 Check A S/A No CV/0 RF CV/PO CS EC QR V3523 G-7 2 B 3.000 Globe A MO LC Yes FAI EO QR Pl 2Y EC QR V3540 C-7 2 B 3.000 Globe A MO LC Yes FAI EO QR Pl 2Y CV/C CS V3547 C-4 2 C 3.000 Check A S/A CV/0 RF CV/PO CS EC QR V3550 C-6 2 B 3.000 Globe A MO LC Yes FAI EO QR, Pl 2Y EC QR V3551 G-6 2 B 3.000 Globe A MO LC Yes FAI EO QR Pl 2Y V3570 E-6 2 C 1.000 Relief A S/A No SRV RF EC QR V3654 FA 2 B 6.000 Gate A MO LO Yes FAI Pl 2Y EO QR V3656 B-4 2 B 12.000 Gate A MO LC Yes FAI Pl 2Y

Page 48 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES'.';::;

APPENDIX C VALVE PROGRAM TABLES (Page 10 of 36)

P & ID: 2998-G-078 SH 1308 SYSTEM'AFETY INJ ECTION-'.SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type A/P Exam Remarks Number Type Pos. Ind Mode Freq Req.

EC QR FCV-3301 F-5 2 8 10.000 8utfly A MO LO Yes FAI Pl 2Y EC QR FCV-3306 E-5 2 8 10.000 8utfly A MO LO Yes FAI Pl 2Y EO QR HCV-3512 F-6 2 8 10.000 Butfly A MO LC Yes FAI PI 2Y EO QR'Y HCV-3657 D-5 2 8 10.000 8utfly A MO LC Yes FAI Pl EC QR EO QR SE-03-2A 8-7 2 A 2.000 Globe A SO Yes FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR SE-03-28 2 A 2.000 Globe A SO Yes FC FS QR'Y Pl SLT-1 2Y SR-03-1 G-6 3 C 0.750 Relief A S/A No SRV RF SR-07-1A E-1 2 C 0.750 Relief A S/A No SRV RF SR-07-18 G-1 2 C 0.750 Relief A S/A No SRV RF CV/0 RF V07000 E-1 2 C 14.000 Check A S/A No CV/PO QR CV/0 RF.

V07001 F-1 2 C 14.000 Check A S/A No CV/PO QR CV/0 RF V3101 8-6 3 C 2.000 Check A S/A No CV/PO CS CV/C QR V3104 F-3 2 C 2.000 Check A S/A No CV/PO QR CV/0 RF CV/C QR V3105 F-3 2 C 2.000 Check A S/A No CV/PO QR CV/0 RF CV/0 CS V3106 E-4 2 C 10.000 Check A S/A CV/PO QR CV/0 CS V3107 F-4 2 C 10.000 Check A S/A No CV/PO QR V3201 8-6 3 8 2.000 Globe A MAN No FAI EE QR

Page 49 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0,:

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES ' l APPENDIX C VALVE PROGRAM TABLES (Page 11 of 36)

P & ID: 2998-G-078 SH 130B (cont.) SYSTEM: SAFETY INJECTION SYSTEM ""

Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size TYpe Exam Remarks Number Type Pos. Ind Mode Freq Req.

V3407 8-6 3 C 0.500 Relief A S/A C SRV RF V3430 C-3 2 C 1.000 Relief A S/A C SRV RF V3431 A-3 2 C 1.000 Relief A S/A C SRV RF EC QR V3432 F-1 2 8 14.000 Gate A MO LO Yes FAI PI 2Y V3439 D-7 2 C 1.000 Relief A S/A C No SRV RF EC QR V3444 E-1 2 8 14.000 Gate A MO LO Yes FAI Pl 2Y EO QR V3456 C-5 2 8 10.000 Gate A MO LC Yes FAI Pl 2Y EO QR V3457 D6 2 8 10.000 Gate A MO LC Yes FAI Pl 2Y EE QR V3463 8-6 2 A 2.000 Gate A MAN LC No SLT-1 2Y V3466 A-7 3 C 1.500 Relief A S/A C No SRV RF EC QR V3495 8-4 2 8 6.000 Globe A SO LO Yes FC FS QR Pl 2Y V3507 F-7 2 C 1.000 Relief A S/A C SRV RF V3513 C-6 2 C 2.000 Relief A S/A C No SRV RF EO QR V3517 8-2 2 8 2.000 Gate A MO LC Yes FAI Pl 2Y EO QR V3658 D-2 2 8 12.000 Gate A MO LC Yes FAI Pl 2Y EC QR V3659 C-4 2 8 3.000 Gate A MO LO Yes FAI Pl 2Y EC QR V3660 C-3 2 8 3.000 Gate A MO LO Yes FAI Pl 2Y V3668 C-5 2 C 2.000 Relief A S/A C No SRV RF

Page 50 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 12 of 36)

P & ID: 2998-G-078 SH 131 SYSTEM: SAFETY IN JECTION',SYSTEM'alve

. Relief Act. Norm Rem Fail Test Coord. CL Cat. Size Type E Remarks Number Type Pos. Ind Mode Freq Req.

EO QR HCV-3615 A-2 2 6.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3616 B-2 2.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3617 B-2 2 2.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3625 C-2 2 6.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR'R HCV-3626 D-2 2 2.000 Globe MO C Yes FAI EC Pl 2Y EO QR HCV-3627 D-3 2 2.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3635 E-2 2 6.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3636 F-2 2 2.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3637 F-2 2 2.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3645 G-2 2 6.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3646 H-2 2 2.000 Globe MO C Yes FAI EC QR Pl 2Y EO QR HCV-3647 H-2 2 2.000 Globe MO C Yes FAI EC QR Pl 2Y CV/0 RF V3113 B-3 2 C 2.000 Check S/A C No CV/PO CS CV/C CS V3114 A-3 2 6.000 Check S/A C , No CV/0 CS CV/C CS V3124 C-3 2 6.000 Check S/A C No CV/0 CS

Page 51 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 13 of 36)

P & ID: 2998-6-078 SH 131 (cont.) SYSTEM: SAFETY INJECTION SYSTEM Valve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type ~P Ind Mode Remarks Number Type Pos. Freq Req.

CV/0 RF V3133 F-3 2 C 2.000 Check A S/A No CV/PO CS CV/C CS V3134 E-3 2 C 6.000 Check A S/A CV/0 CS CV/0 RF V3143 H3 2 C 2.000 Check A S/A No CV/PO CS CV/C CS V3144 G-3 2 C 6.000 Check A S/A No CV/0 CS V3468 D-2 2 C 2.000 Relief A S/A No SRV RF V3469 D-6 1 C 0.750 Relief A S/A No SRV RF EO CS EC CS V3480 D-7 1 A 10.000 Gate A MO LC Yes FAI Pl 2Y SLT-2 2Y EO CS EC CS V3481 D-6 1 A 10.000 Gate A MO LC Yes FAI Pl 2Y SLT-2 2Y V3482 D-6 1 C 0.7500 Relief A S/A SRV RF

'F V3483 D-2 2 C 2.000 Relief A S/A SRV CV/C CS'F B-5 CV/0 V3524 1 AC 3.000 Check A S/A No CV/PO CS SLT-2 2Y CV/C CS B-6 CV/0 RF V3525 1 AC 3.000 Check A S/A CV/PO CS SLT-2 2Y CV/C CS G-5 CV/0 RF V3526 1 AC 3.000 Check A S/A No CV/PO CS SLT-2 2Y SR-03-2 D-3 3 C 0.750 Relief A S/A No SRV RF

Page 52 of 149 ST, LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES.

APPENDIX C VALVE PROGRAM TABLES (Page 14 of 36)

P & ID: 2998-6-078 SH 131 (cont.) SYSTEM: SAFETY INJECTION SYSTEM Valve Act. Norm Rem Fail Test Relief Remarks Coo rd. CL Cat. Size Type E Number Type Pos. Ind Mode Freq Req.

CV/C CS CV/0 RF V3527 G-6 1 AC 3.000 Check S/A C No CV/PO CS SLT-2 2Y EC QR V3536 D-2 2 B 4.000 Globe MO LC Yes FAI Pl 2Y EC QR V3539 F-2 2 B 4.000 Globe MO LC Yes FAI PI 2Y EO CS.

V3545 D-6 1 B 10.000 Gate MO LC Yes FAI Pl 2Y EC QR V3571 G-6 1 B 1.000 Globe DO C Yes FC FS QR Pl 2Y EC QR V3572 C-6 1 B 1.000 Globe DO C Yes FC FS QR Pl 2Y EO CS V3651 E-5 1 A 10.000 Gate MO LC Yes FAI Pl 2Y'Y SLT-2 EO CS V3652 E-7 1 A 10.000 Gate MO LC Yes FAI PI 2Y SLT-2 2Y EO QR V3664 D-3 2 B 10.000 Gate MO LC Yes FAI Pl 2Y EO QR V3665 E-4 2 B 10.000 Gate MO LC Yes FAI Pl 2Y V3666 D-4 2 C 6.000 Relief S/A C No SRV RF V3667 D-4 2 C 6.000 Relief S/A C No SRV RF CV/0 RF V3766 E-7 2 C 2.000 Check S/A C No CV/PO CS

Page 53 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 15 of 36)

P 8c ID: 2998-6-078 SH 132 SYSTEM: SAFETY INJECTION SYSTEM Valve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type A/P Remarks Number Type Pos. Ind Mode Freq Req.

EC QR HCV-3618 D-5 1 B 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC %R HCV-3628 D-2 1 B 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC QR HCV-3638 H-2 1 B 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC QR HCV-3648 H-5 1 B 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC QR EO QR SE-03-1A 2 B 1.000 GLOBE A SO C YES FC FS QR Pl 2Y EC QR EO QR SE-03-1B 2 B 1.000 GLOBE A SO C YES FC FS QR Pl 2Y EC QR EO QR SE-03-1C G-3 2 B 1.000 GLOBE A SO C YES FC FS QR Pl 2Y EC QR EO QR SE-03-1D G-6 2 B 1.000 GLOBE A SO C YES FC FS QR Pl 2Y V03002 C-5 3 C 1.000 CHECK A S/A C NO CV/0 CS V03003 G-2 3 C 1.000 CHECK A S/A C NO CV/0 CS V03004 C-2 3 C 1.000 CHECK A S/A C NO CV/0 CS V03005 G-5 3 C 1.000 CHECK A S/A C NO CV/0 CS V3211 A-6 2 C 1.500 RELIEF A S/A C NO SRV RF CV/C CS C-6 CV/0 RF V3215 2 AC 12.000 CHECK A S/A C NO INSP VR-13 SLT-2 2Y CV/C CS CV/PO CS V3217 D-7 1 AC 12.000 CHECK A S/A C NO CV/0 RF INSP SD VR-14 SLT-2 2Y V3221 A-3 2 C 1.500 RELIEF A S/A C NO SRV RF

Page 54 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES '::

APPENDIX C VALVE PROGRAM TABLES (Page 16 of 36)

P & ID: 2998-G-078 SH 132 (cont.) SYSTEM: SAFETY INJECTION."SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type Remarks Number Type Pos. Ind Mode Freq Req.

CV/C CS CV/0 RF V3225 C-3 2 AC 12.000 CHECK A S/A C INSP SD VR-13 SLT-2 2Y CV/C CS CV/PO CS V3227 D-4 1 AC 12.000 CHECK A S/A C CV/0 RF INSP SD VR-14 SLT-2 2Y V3231 E-3 2 C 1.5000 RELIEF A S/A C NO SRV RF CV/C CS CV/0 RF V3235 G-3 2 AC 12.000 CHECK A S/A C NO INSP SD VR-13 SLT-2 2Y CV/C CS CV/PO CS V3237 HA 1 AC 12.000 CHECK A S/A C NO CV/0 RF INSP SD VR-14 SLT-2 2Y V3241 E-6 ~ 2 C 1.500 RELIEF A S/A C SRV RF CV/C CS CV/0 RF V3245 G-6 2 AC 12.000 CHECK A S/A C 'NSP SD VR-13 SLT-2 2Y CV/C CS CV/PO CS V3247 H-7 1 AC 12.000 CHECK A S/A C CV/0 RF INSP SD VR-14 SLT-2 2Y CV/C CS V3258 D-3 1 AC 6.000 CHECK A S/A C NO CV/0 CS SLT-2 2Y CV/C CS.

V3259 D-6 1 AC 6.000 CHECK A S/A C NO CV/0 CS SLT-2 2Y CV/C CS V3260 H-3 1 AC 6.000 CHECK A'/A C NO CV/0 CS SLT-2 2Y CV/C CS V3261 H-6 1 AC 6.000 CHECK A S/A C CV/0 CS SLT-2 2Y

Page 55 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES'PPENDIX C

VALVE PROGRAM TABLES (Page 17 of 36)

P & ID: 2998-6-078 SH 132 (cont.) SYSTEM: SAFETY INJECTION SYSTEM Norm Rem Fail Test Relief Valve Coo rd. CL Cat. Size Type NP Act. Pos. Ind Mode E m Freq Req.

Remarks Number Type EC QR V3611 C-6 2 8 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC CS V3614 C-6 1 8 12.000 GATE A MO LO YES FAI Pl 2Y EC QR V3621 C-3 2 8 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC CS V3624 C-3 1 8 12.000 GATE A MO LO YES FAI Pl 2Y EC QR V3631 G3 2 8 1.000 GLOBE A DO C YES FS QR PI 2Y EC CS V3634 G3 1 8 12.000 GATE A MO LO YES FAI Pl 2Y EC QR V3641 G6 2 8 1.000 GLOBE A DO C YES FC FS QR Pl 2Y EC CS V3644 G-6 1 8 12.000 GATE A MO LO YES FAI Pl 2Y EC CS EO CS V3733 8-5 2 8 1.000 GLOBE A SO C YES FS CS Pl 2Y EC CS EO CS V3734 8-5 2 8 1.000 GLOBE A SO C YES FC FS CS Pl 2Y EC CS EO CS V3735 8-2 2 8 1.000 GLOBE A SO C YES FC FS CS PI 2Y V3736 8-2 2 8 1.000 GLOBE A SO C YES FC EC EO FS

'S CS CS PI 2Y EC CS EO CS, V3737 E-2 2 8 1.000 GLOBE A SO C YES FC FS CS Pl 2Y

Page 56 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0, .

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 18 of 36)

P & ID: 2998-G-078 SH 132 (cont.) SYSTEM: SAFETY INJECTION SYSTEM" Valve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size TYPe ~P Ind Mode Remarks Number TYpe Pos. Freq Req.

EC CS EO CS V3738 F-2 1.000 GLOBE A SO YES FC FS CS Pl 2Y EC CS EO CS V3739 E-5 11.000 GLOBE A SO C YES FC FS CS Pl 2Y EC CS EO CS V3740 F-5 1.000 GLOBE A SO C YES FC FS CS Pl 2Y

Page 57 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 19 of 36)

P & ID: 2998-6-078 SH 163 SYSTEM: SAMPLI G SYSTEM, Valve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type Eam Remarks Number Type Pos. Ind Req.

EC QR FS QR SE-05-1A B-2 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR SE-05-1B C-2 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR SE-05-1C E-2 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR SE-05-1D G-2 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR SE-05-IE B4 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR V5200 C-3 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR V5201 D-3 A 0.375 GLOBE A SO C YES PI 2Y SLT-1 2Y EC QR FS QR V5202 F-3 A 0.375 GLOBE A SO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR V5203 C-4 A 0.375 GLOBE A AO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR V5204 D-4 A 0.375 GLOBE A AO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR V5205 F-4 A 0.375 GLOBE A AO C YES FC Pl 2Y, SLT-1 2Y

Page 58 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 20 of 36)

P & ID: 2998-G-078 SH 160A SYSTEM: WASTE MANAGEMENT:SYSTEM Valve Act. Norm Rem Relief Coord. CL Cat. Size Type A/P Exam Remarks Number Type Pos. Ind Mode Freq Req.

EC QR FS QR V6341 G-3 2 3.000 DIAPH A DO 0 YES Pl 2Y SLT-1 2Y EC QR FS QR V6342 G-4 2 3.000 DIAPH A DO 0 YES FC PI 2Y SLT-1 2Y P & ID: 2998-G-078 SH 163A SYSTEM: WASTE MANAGEMENTSYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type A/P Remarks Number Type Pos. Ind Mode Freq Req.

EC QR FS QR V6718 B-3 2 A 1.000 DIAPH A DO 0 YES FC Pl 2Y SLT-1 2Y EC QR FS QR V6750 B-3 2 A 1.000 DIAPH A DO 0 YES FC Pl 2Y SLT-1 2Y P & ID: 2998-G-078 SH 163B SYSTEM: WASTE MANAGEMENTSYSTEM Valve Act. Norm Rem Fail Test Relief Number Coord. CL Cat. Size Type NP Ind Mode Exam Remarks Type Pos. Freq Req.

EC QR D-4 FS QR V6741 A 1.000 GLOBE A AO YES FC Pl 2Y SLT-1 2Y CV/C

• CS V6792 D-3 AC 1.000 CHECK A S/A SLT-1 2Y

Page 59 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 21 of 36)

P 8c ID: 2998-G-079 SH 1 SYSTEM: MAIN STEAM SYSTEM'alve Act. Norm Rem Fail Test Coord. CL Cat. Size Type Number Type Pos. Ind Mode Freq Req.

EC CS PEC QR HCV-08-1A C-6 B 34.000 GLOBE A PO 0 YES FC Pl 2Y FS CS EC CS PEC QR HCV-08-1B E-6 B 34.000 GLOBE A PO 0 YES FC Pl 2Y FS CS EC QR MV-08-12 G-4 B 4.000 GATE A MO C YES FAI EO QR Pl 2Y EC QR MV-08-13 G-4 B 4.000 GATE A MO C YES FAI EO QR Pl 2Y MV-08-14 B-4 EC QR B 8.000 GATE P MO LO YES FAI PI 2Y MV-08-15 B-4 EC QR B 8.000 GATE P MO LO YES FAI Pl 2Y MV-08-1 6 E-4 EC QR B 8.000 GATE P MO LO YES FAI Pl 2Y MV-08-17 E-4 EC QR B 8.000 GATE P MO LO YES FAI Pl 2Y EC QR MV-08-18A A-4 B 10.000 ANGLE A MO C YES FAI EO QR Pl 2Y EC QR MV-08-18B D-4 B 10.000 ANGLE A MO C YES FAI EO QR PI 2Y EC QR MV-08-19A A-4 B 10.000 ANGLE A MO C YES FAI EO QR Pl 2Y EC QR MV-08-19B DA B 10.000 ANGLE A MO C YES FAI EO QR Pl 2Y MV-08-1A C-6 EC QR B 3.000 GLOBE A MO C YES FAI Pl 2Y EC QR MV-08-1B E-6 B 3.000 GLOBE A MO C YES FAI Pl 2Y MV-08-3 G-6 EO QR B 4.000 GLOBE A MO LO YES FAI Pl 2Y EC QR SE-08-1 H-4 B 0.750 GLOBE A SO 0 YES FO Pl 2Y EC QR SE-08-2 H-4 B 0.750 GLOBE A SO 0 YES FO Pl 2Y

I' Page 60 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 22 of 36)

P & ID: 2998-6-079 SH 1 (cont.) SYSTEM: MAIN STEAM SYSTEM Valve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type Remarks Number Type Pos. Ind Mode Freq Req.

CV/0 CS V08130 G-4 3 C 4.000 CHECK A S/A 0 CV/PO QR INSP SD VR-3'I CV/0 -CS V08163 G4 3 C 4.000 CHECK A S/A 0 CV/PO QR INSP SD VR-31 V8201 B-5 2 C 6.000 SAFETY A S/A C SRV RF V8202 B-5 2 C 6.000 SAFETY A S/A C SRV RF V8203 B-5 2 C 6.000 SAFETY A S/A C SRV RF V8204 B-5 2 C 6.000 SAFETY A S/A C SRV RF V8205 E-5 2 C 6.000 SAFETY A S/A C SRV RF V8206 D-5 2 C 6.000 SAFETY A S/A C NO SRV RF V8207 E-5 2 C 6.000 SAFETY A S/A C SRV RF V8208 D-5 2 C 6.000 SAFETY A S/A C SRV RF V8209 B-6 2 C 6.000 SAFETY A S/A C NO SRV RF V8210 B-6 2 C 6.000 SAFETY A S/A C NO SRV RF V8211 B6 2 C 6.000 SAFETY A S/A C NO SRV RF V8212 B-6 2 C 6.000 SAFETY A S/A C NO SRV RF V8213 E-6 2 C 6.000 SAFETY A S/A C NO SRV RF V8214 D-6 2 C 6.000 SAFETY A S/A C SRV RF V8215 E-6 2 C 6.000 SAFETY A S/A C SRV RF V8216 D-6 2 C 6.000 SAFETY A S/A C NO SRV RF

Page 61 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 23 of 36)

P & ID'998-G-080 SH 2A SYSTEM: FEEDWATER SYSTEM'alve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type A/P Exam Number Type Pos. Ind Mode EC CS HCV-09-1 A B-5 2 B 20.000 GATE A PO 0 YES FAI PEC QR Pl 2Y EC CS HCV-09-1 B B-5 2 B 20.000 GATE A PO 0 YES FAI PEC QR Pl 2Y EC CS HCV-09-2A 2 B 20.000 GATE A PO 0 YES FAI PEC QR Pl 2Y EC CS HCV-09-2B C-5 2 B 20.000 GATE A PO 0 YES FAI PEC QR Pl 2Y V09252 B-7 2 C 18.000 CHECK A S/A 0 NO CV/0 QR V09294 C-7 2 C 18.000 CHECK A S/A 0 NO CV/0 QR

Page 62 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPEND1X C VALVE PROGRAM TABLES (Page 24 of 36)

P & ID: 2998-G-080 SH 2B SYSTEM: FEEDWATER SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type A/P Exam Remarks Number Type Pos. Ind Mode Freq Req.

V09107 B-4 3 C 4.000 CHECK A S/A C NO CV/0 CS V09119 B-6 2 C 4.000 CHECK A S/A C NO CV/0 CS V09120 B-7 2 B 4.000 GATE A MAN LO NO FAI EE QR V09123 D4 3 C 4.000 CHECK A S/A C NO CV/0 CS V09135 D6 2 C 4.000 CHECK A S/A C NO CV/0 CS V09136 D7 2 B 4.000 GATE A LO NO FAI EE QR V09139 F-4 3 C 4.000 CHECK A S/A C NO CV/0 CS V09151 F-6 2 C 4.000 CHECK A S/A C NO CV/0 CS V09152 F-7 2 B 4.000 GATE A LO NO FAI EE QR V09157 G6 2 C 4.000 CHECK A S/A C NO CV/0 CS V09158 G7 2 B 4.000 GATE A MAN LO NO FAI EE QR CV/PO QR V09303 G3 3 C 2.000 CHECK A S/A C NO INSP SD VR-27 CV/PO QR V09304 E-3 3 C 1.500 CHECK A S/A C NO INSP SD VR-27 CV/PO QR V09305 C-3 3 C 1.500 CHECK A S/A C NO INSP SD VR-27 EC QR MV-09-09 B-6 2 B 4.000 GLOBE A MO C YES FAI EO QR Pl 2Y EC QR MV-09-10 D6 2 B 4.000 GLOBE A MO C YES FAI EO QR Pl 2Y EC QR MV-09-11 F-6 2 B 4.000 GLOBE A MO C YES FAI EO QR Pl 2Y EC QR MV-09-12 G6 2 B 4.000 GLOBE A C YES FAI EO QR Pl 2Y EC QR EO QR SE-09-2 B-5 3 B 4.000 GATE A SO C YES FC FS QR Pl 2Y EC QR EO QR SE-09-3 D-5 3 B 4.000 GATE A SO C YES FC FS QR Pl 2Y EC QR SE-09-4 F-5 EO QR 3 B 4.000 GATE A SO C YES FC FS QR Pl 2Y EQ QR EO QR SE-09-5 G5 3 B 4.000 GATE A SO C YES FC FS QR Pl 2Y

Page 63 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES, APPENDIX C VALVE PROGRAM TABLES (Page 25 of 36)

P & ID: 2998-G-082 SH 2 SYSTEM: INTAKE COOLING WATER SYSTEM Valve Act. Norm Rem Fail Test Relict Coo rd. CL Cat. Size Type Exam Remarks Number Type Pos. Ind Mode Freq Req.

EC QR MV-21-2 F-4 B 24.000 BUTFLY A MO 0 YES FAI Pl 2Y EC QR MV-21-3 G-4 B 24.000 BUTFLY A MO 0 YES FAI PI 2Y SR21196 B-5 C 3.000 RELIEF A S/A C NO SRV RF SR21243 B-6 C 3.000 RELIEF A S/A C NO SRV RF EO QR TCV-14-4A A-5 B 30.000 BUTFLY A PO 0 FO FS QR EO QR TCV-14-4B A-6 B 30.000 BUTFLY A PO 0 FO FS QR CV/C QR V21162 G-5 C 30.000 CHECK A S/A 0 NO CV/0 QR CV/C QR V21 205 G-6 C 30.000 CHECK A S/A 0 NO CV/0 QR CV/C QR V21208 G-7 C 30.000 CHECK A S/A 0 CV/0 QR

Page 64 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES, APPENDIX C VALVE PROGRAM TABLES (Page 26 of 36)

P & ID: 2998-G-083 SH 1 SYSTEM: COMPONENT COOLING SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type A/P Exam Remarks Number Type Pos. Ind Mode Freq Req.

EO CS HCV-14-3A H-1 3 B 14.000 BUTFLY A DO C YES FO FS CS Pl 2Y EO CS HCV-14-3B H-2 3 B 14.000 BUTFLY A DO C YES FO FS CS PI 2Y EC QR HCV-14-8A E-4 3 B 16.000 BUTFLY A PO 0 YES FC FS QR PI 2Y EC QR HCV-14-8B E-4 3 B 16.000 BUTFLY A PO 0 YES FC FS QR Pl 2Y EC QR HCV-14-9 F-6 3 B 16.000 BUTFLY A PO 0 YES FC FS QR Pl 2Y EC QR HCV-14-10 F-6 3 B 16.000 BUTFLY A PO 0 YES FC FS QR PI 2Y EC QR MV-14-17 E-4 3 B 12.000 BUTFLY A MO 0 YES FAI Pl 2Y EC QR MV-14-18 E-4 3 B 12.000 BUTFLY A MO LC YES FAI Pl 2Y SR14307 A-3 2 C 1.000 RELIEF A S/A C NO SRV RF SR14318 A-3 2 C 1.000 RELIEF A S/A C NO SRV RF SR14329 A-1 2 C 1.000 RELIEF A S/A C NO SRV RF SR14342 A-2 2 C 1.000 RELIEF A S/A C NO SRV RF CV/C QR V14143 D-6 3 C 20.000 CHECK A S/A 0 NO CV/0 QR CV/C QR V14147 D-7 3 C 20.000 CHECK A S/A 0 NO CV/0 QR CV/C QR V14151 D-6 3 C 20.000 CHECK A S/A 0 NO CV/0 QR SR14350 G1 3 C 1.000 RELIEF A S/A C NO SRV RF SR14359 G2 3 C 1.000 RELIEF A S/A C NO SRV RF

Page 65 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 '.

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 27 of 36)

P 8c ID: 2998-G-083 SH 2 SYSTEM: COMPONENT COOLING SYSTEM Norm Rem Fail Test Relief Valve Coo rd. CL Cat. Size Type NP Act. Ind Mode Exam Remarks Number Type Pos. Freq Req.

EC CS FS CS HCV-14-1 D-6 2 A 8.000 BUTFLY A PO 0 YES FC Pl 2Y SLT-1 2Y VR-16 EC CS FS CS KCV-14-2 C-1 2 A 8.000 BUTFLY A PO 0 YES FC Pl 2Y SLT-1 2Y VR-16 EC CS FS CS HCV-14-6 D2 2 A 8.000 BUTFLY A PO 0 YES FC Pl 2Y SLT-1 2Y VR-16 EC CS FS CS HCV-14-7 D-6 2 A 8.000 BUTFLY A PO 0 YES FC Pl 2Y SLT-1 2Y VR-16

Page 66 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 28 of 36)

P & ID: 2998-6-084 SH 1 SYSTEM: MAKEUP WATER SYSTEM Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type Exam Remarks Number Type Pos. Ind Mode Freq Req.

EC QR FS QR HCV-15-1 D-6 2 A 2.000 GLOBE DO 0 YES FC Pl 2Y SLT-1 2Y CV/C RF V1 5328 D-5 2 AC 2.000 CHECK S/A C NO SLT-1 2Y P & ID: 2998-6-085 SH 1 SYSTEM: SERVICE AIR Valve Act. Norm Rem Fail Test Relief

-Remarks Coord. CL Cat. Size Type A/P Exam E

Number Type Pos. Ind Mode Freq Req.

EC QR FS QR HCV-18-2 F-6 2.000 GLOBE A DO YES FC Pl 2Y SLT-1 2Y SH-18797 F-3 1.000 BALL P MAN LC NO SLT-1 2Y CV/C CS V1 81270 E-5 AC 2.000 CHECK A S/A SLT-1 2Y.

P & ID: 2998-6-085 SH 2A SYSTEM'NSTRUMENT AIR Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type A/P Exam Remarks Number Type Pos. Ind Freq Req.

GV/C RF V18195 E-6 2 AC 2.000 CHECK A S/A NO SLT-1 2Y V1 8279 B-2 2 C .500 CHECK A S/A NO GV/G CS V1 8283 A-3 2 C .500 CHECK A S/A GV/C CS SR-18-6A D-2 2 C .500 RELIEF A S/A NO SRV RF SR-18-6B D-1 C .500 RELIEF A S/A SRV RF V1 8290 G2 2 C .750 CHECK A S/A CV/C CS V1 8291 62 2 C .750 CHECK A S/A CV/C CS V1 8294 H2 2 C .750 CHECK A S/A CV/C CS V1 8295 H2 2 C .750 CHECK A S/A GV/C CS

Page 67 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 29 of 36)

P & ID: 2998-G-085 SH 2C SYSTEM: INSTRUMENT,;"AIR Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type NP Remarks Number Type Pos. Ind Mode Freq Req.

EC CS FS CS HCV-18-1 G3 2 A 1.000 GLOBE A DO YES Pl 2Y SLT-1 2Y P & ID: 2998-G-086 SH 1 SYSTEM: MISCELLANEOUS SYSTEMS Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type Remarks Number Type Pos. Ind Mode Freq Req.

EC QR, FCV-23-3 C-6 2 B 3.000 GLOBE A DO 0 YES FC FS QR Pl 2Y EC QR FCV-23-5 C-6 2 B 3.000 GLOBE A DO 0 YES FC FS QR Pl 2Y EC QR FCV-23-7 C-7 2 B 0.500 GLOBE A DO 0 YES FC FS QR Pl 2Y EC QR FCV-23-9 C-7 2 B 0.500 GLOBE A DO 0 YES FS QR Pl 2Y

Page 68 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 30 of 36)

P & ID: 2998-G-088 SH 1 SYSTEM: CONTAINMENTSPRAY;,SYSTEM

'-,,'alve

. Test Relief Act. Norm Rem Fail Remarks Coord. CL Cat. Size Type Exam Number Type Pos. Ind Mode Ffeq Req.

EC QR MV-07-1A E-5 2 24.000 BUTFLY MO 0 YES FAI PI 2Y EC QR MV-07-1B E-5 2 24.000 BUTFLY MO 0 YES FAI Pl 2Y EC QR EO QR SE-07-3A G-3 2 0.500 GLOBE A SO C YES FO FS QR Pl 2Y EC QR EO QR SE-07-3B H-3 2 0.500 GLOBE SO C YES FO FS QR PI 2Y SR-07-1C E-2 2 C 1.000 RELIEF A S/A C NO SRV RF SR-07-2A F-3 2 0.500 RELIEF S/A C SRV RF SR-07-2B G-3 2 0.500 RELIEF S/A C NO SRV RF CV/PO QR V07119 E-6 2 C 24.000 CHECK S/A C VR-20 INSP SD CV/PO QR V07120 E-6 24.000 CHECK S/A C NO VR-20 tl INSP SD CV/PO QR V07129 H6 2 C 12.000 CHECK S/A C NO .-

CV/0 RF V07130 H-6 2 12.000 GATE MAN LO NO EE QR CV/PO QR V07143 G-6 2 12.000 CHECK S/A C CV/0, RF V07145 G-6 2 12.000 GATE MAN LO EE QR V07231 E-2 2 2.000 CHECK S/A C NO CV/0 QR V07232 E-2 2 2.000 CHECK S/A C CV/0 QR V07256 G3 2 0.500 CHECK S/A C NO CV/0 RF V07258 H-3 2 0.500 CHECK S/A C NO CV/0 RF V07412 F-3 0.500 CHECK S/A C NO CV/0 QR

Page 69 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION. 0,-"., -...

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES......-

APPENDIX C VALVE PROGRAM TABLES (Page 31 of 36)

P & ID: 2998-G-88 SH 2 SYSTEM: CONTAINMENTSPRAY SYSTEM,';.-

. Relief

'alve Number Coord. CL Cat. Size Type A/P Act. Norm Rem Fail Type Pos. Ind Mode

~ Test Freq Req.

Remarks V07170 E-3 3.000 GATE P MAN LC SLT-1 2Y V07172 G-2 24.000 CHECK A S/A C NO INSP SD VR-22 V07174 G-2 24.000 CHECK A S/A C NO INSP SD VR-22 V07188 E-4 3.000 GATE P MAN LC NO SLT-1 2Y V07189 E-4 A 3.000 GATE P MAN LC NO SLT-1 2Y V07192 C-4 10.000 CHECK A S/A C INSP SD VR-23 V07193 C-4 10.000 CHECK A S/A C NO INSP SD VR-23 V07206 E-3 A 3.000 GATE P MAN LC SLT-1 2Y EO QR FCV-07-1 A C-3 B 12.000 GATE A DO C YES FO FS QR Pl 2Y EO QR FCV-07-1B D-3 12.000 GATE A DO C YES FO FS QR Pl 2Y EC QR FS QR LCV-07-1 1 A G-4 2.000 GLOBE A DO C YES FC Pl 2Y SLT-1 2Y EC QR FS QR LCV-07-11B G-3 2.000 GLOBE A DO C YES FC Pl 2Y SLT-1 2Y EO QR MV-07-2A G-3 24.000 BUTFLY A MO C YES FAI EC QR Pl 2Y EO QR MV-07-2B G-3 24.000 BUTFLY A MO C YES FAI EC QR PI 2Y EC QR MV-07-3 C-2 12.000 GATE A MO 0 YES FAI PI 2Y EC QR MV-07-4 D-2 12.000 GATE A MO 0 YES FAI Pl 2Y

Page 70 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 32 of 36)

P & ID: 2998-G-09'I SH 1 SYSTEM: MISCELLANEOUS SYSTEM'---

Valve Act. Norm Rem Fail Test Relief Number Coo rd. CL Cat. Size Type ~P Ind Mode Exam Remarks Type Pos. Freq Req.

V00101 B-5 2 A 8.000 GATE P MAN LC SLT-1 2Y VR-16 V00139 C-4 2 A 0.375 GLOBE P MAN LC SLT-1 2Y V00140 D-4 2 A 1.000 GLOBE P MAN LC SLT-1 2Y V00143 D-5 2 A 1.000 GLOBE P MAN LC SLT-1 2Y V00144 C-5 2 A 0.375 GLOBE P MAN LC NO SLT-1 2Y

Page 71 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 33 of 36 )

P & ID: 2998-6-092 SH 1 SYSTEM: MISC: SAMPLING SYSTEM Valve Act. Norm Rem Fail Test Relief Number Coo rd. CL Cat. Size Tg)e ~P T+e Pos. Ind Mode Exam Freq Req.

Remarks EC QR FS QR FCV-26-1 B-2 A 1.000 GLOBE A DO YES FC 2Y PI SLT-1 2Y EC QR FS QR FCV-26-2 B-2 A 1.000 GLOBE A DO YES FC Pl 2Y SLT-1 2Y EC QR FS QR FCV-26-3 B-3 A 1.000 GLOBE A DO YES FC Pl 2Y SLT-1 2Y EC QR FS QR FCV-26-4 B-3 A 1.000 GLOBE A DO YES FC Pl 2Y SLT-1 2Y EC QR FS QR FCV-26-5 B-3 A 1.000 GLOBE A DO YES FC Pl 2Y SLT-1 2Y EC QR FS QR'Y FCV-26-6 B-3 A 1.000 GLOBE A DO YES FC Pl SLT-1 2Y EC QR EO QR FSE-27-8 A-5 A 0.375 GLOBE A SO YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-9 A-5 A 0.375 GLOBE A SO YES FC FS QR Pl -2Y SLT-1 2Y EC QR EO QR FSE-27-10 A-5 A 0.375 GLOBE A SO YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-11 B-5 A 0.375 GLOBE A SO YES FC FS QR Pl 2Y SLT-1 2Y

Page 72 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX C VALVE PROGRAM TABLES (Page 34 of 36 )

P & ID: 2998-G-092 SH 1 (cont.) SYSTEM: MISC. SAMPLING SYSTEM',

'alve Act. Norm Rem Fail Test Relief Coo rd. CL Cat. Size Type A/P Remarks Number Type Pos. Ind Mode Freq Req.

EC QR EO QR FSE-27-12 B-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-13 A-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-14 A-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-15 B-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-16 B-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-17 8-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y EC QR EO QR FSE-27-18 B-6 A 0.375 GLOBE A SO C YES FC FS QR Pl 2Y SLT-1 2Y CV/C CS V27101 B-6 AC 0.375 CHECK A S/A C NO CV/0 QR SLT-1 2Y CV/C CS V27102 B-6 AC 0.375 CHECK A S/A C NO CV/0 QR SLT-1 2Y

0 Page 73 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0, TESTING PROGRAM FOR PUMPS AND VALVES 'NSERVICE APPENDIX C VALVE PROGRAM TABLES (Page 35 of 36)

P & ID: 2998-G-878 SYSTEM: HVAC Valve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size ape A/P Exam Remarks Number T//pe Pos. Ind Mode Freq Req.

EC CS FCV-25-1 C-2 2 B 48.000 BUTFLY A PO YES FC FS CS Pl 2Y EC CS FS CS FCV-25-2 C-3 2 A 48.000 8UTFLY A PO C YES FC Pl 2Y SLT-1 2Y VR-16

. EC CS FS CS FCV-25-3 CA 2 A 48.000 BUTFLY A PO YES FC Pl 2Y SLT-1 2Y VR-16 EC CS FS CS FCV-25-4 C-6 2 A 48.000 BUTFLY A PO C YES FC Pl 2Y SLT-1 2Y VR-16 EC CS FS CS FCV-25-5 C-7 2 A 48.000 BUTFLY A PO YES FC Pl 2Y SLT-1 2Y VR-16 EC CS FCV-25-6 C-8 2 B 48.000 8UTFLY A PO YES FC FS CS.

Pl 2Y EC QR EO QR FCV-25-7 C-15 2 A 24.000 BUTFLY A PO YES FC FS QR Pl 2Y SLT-1 2Y VR-16 EC QR EO QR FCV-25-8 C-15 2 A 24.000 BUTFLY A PO YES FC FS QR, PI 2Y SLT-1 2Y VR-16 CV/C CS V-25-20 C-13 2 AC 24.000 CHECK A S/A NO CV/0 CS SLT-1 2Y VR-16 CV/C CS V-25-21 C-13 2 AC 24.000 CHECK A S/A CV/0 CS SLT-1 2Y VR-16

~,

Page 74 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES C 'PPENDIX VALVE'ROGRAMTASLES (Page 36 of 36)

P & ID: 2998-G-879 SH 2 SYSTEM HVAC'alve Act. Norm Rem Fail Test Relief Coord. CL Cat. Size Type pgp emar s Number Type Pos. Ind Mode Freq Req EC QR FCV-25-14 ,E-6 3 B 12.000 BUTFLY A MO 0 YES FAI EO QR Pl 2Y EC QR FCV-25-15 E-7 3 B 12.000 BUTFLY A MO 0 YES FAI EO QR Pl 2Y EC QR FCV-25-16 E-5 3 B 12.000 BUT FLY A MO 0 YES FAI EO QR Pl 2Y EC QR FCV-25-17 E-8 3 B 12.000 BUT FLY A MO 0 YES FAI EO QR Pl 2Y EC QR FCV-25-18 C-17 3 B 6.000 BUTFLY A MO 0 YES FAI Pl 2Y EC QR FCV-25-19 C-17 3 B 6.000 BUTFLY A MO 0 YES FAI Pl 2Y EC QR FCV-25-24 A-17 3 B 10.000 BUT FLY A MO 0 YES FAI Pl 2Y EC QR FCV-25-25 A-17 3 B 10.000 BUTFLY A MO 0 YES FAI PI 2Y

Page 75 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES ..

APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 1 of 46)

RELIEF REQUEST NO. VR-1 (Page 1 of 1)

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

Page 76 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 2 of 46)

RELIEF REQUEST NO. VR-2 (Page 1 of 1)

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

'age 77 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVE PROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 3 of 46)

RELIEF REQUEST NO. VR-3 (Page 1 of 2)

SYSTEM:

Various COMPONENTS:

Various CATEGORY'arious FUNCTION:

This is a generic request for relief.

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

The stroke time measurements taken during testing of fact-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.

Page 78 of 149 ST, LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES D 'PPENDIX VALVE PROGRAM RELIEF REQUESTS (Page 4 of 46)

RELIEF REQUEST NO. VR-3 (Page 2 of 2)

ALTERNATE TESTING:

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).

APPROVAL:

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 6.

Page 79 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES, APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 5 of 46)

RELIEF REQUEST NO. VR-4 (Page 1 of 1)

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

Page 80 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES.

APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 6 of 46)

RELIEF REQUEST NO. VR-5 (Page 1 of 1)

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

Page 81 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 7 of 46)

RELIEF REQUEST NO. VR-6 (Page 1 of 1)

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

Page 82 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 8 of 46)

RELIEF REQUEST NO. VR-7 (Page 1 of 1)

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

Page 83 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES" APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 9 of 46)

RELIEF REQUEST NO. VR-8 (Page 1 of 1)

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

Page 84 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 10 of 46)

RELIEF REQUEST NO. VR-9 (Page 1 of 1)

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

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VALVE PROGRAM RELIEF REQUESTS (Page 11 of 46)

RELIEF REQUEST NO. VR-'IO (Page 1 of 1)

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

Page 86 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 12 of 46)

RELIEF REQUEST NO. VR-11 (Page 1 of 1)

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

Page 87 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES'-.

D 'PPENDIX VALVE PROGRAM RELIEF REQUESTS (Page 13 of 46)

RELIEF REQUEST NO. VR-12 (Page 1 of 1)

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

Page 88 of 149 ST, LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 14 of-46)

RELIEF REQUEST NO. VR-13 (Page 1 of 3)

SYSTEM:

Safety Injection (2998-G-078 Sh 132)

COMPONENTS:

V3215 V3225 V3235 V3245 CATEGORY:

FUNCTION:

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

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

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

Page 89 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 15 of 46)

RELIEF REQUEST NO. VR-13 (Page 2 of 3)

BASIS FOR RELIEF: (continued)

The only practical method for flow testing the safety injection 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 conditioris of water level and nitrogen pressure int he SIT with its discharge isolation valve closed. The SIT discharge isolation valve is then opened to dump the contents of the SIT to the refueling cavity.

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. FPBL 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.

Jl 0

V

Page 90 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 16 of 46)

RELIEF REQUEST NO. VR-13 (Page 3 of 3) .

ALTERNATE TESTING'uring 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 provided by performing a partial-flow test prior to returning a valve to service following disassembly.

APPROVAL:

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

Page 91 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 17 of 46)

RELIEF REQUEST NO. VR-14 (Page 1 of 3)

SYSTEM:

Safety Injection (2998-6-078 sh 132)

COMPONENTS:

V3217 V3227 V3237 V3247 CATEGORY:

FUNCTION:

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

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

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

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,PPENDIX D

VALVE PROGRAM RELIEF REQUESTS (Page 18 of 46)

RELIEF REQUEST NO. VR<<14 (Page 2 of 3)

BASIS FOR RELIEF: (continued)

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 Mode 6. Shutdown cooling flowrates are not sufficient 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 refueling cavity.

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 vales 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 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.

Page 93 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 19 of 46)

RELIEF REQUEST NO. VR-14 (Page 3 of 3)

ALTERNATE TESTING:

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 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.

APPROVAL:

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

Page 94 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 20 of 46)

RELIEF REQUEST NO. VR-15 (Page 1 of 1)

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

Page 95 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 21 of 46)

RELIEF REQUEST NO. VR-16 (Page 1 of 2)

SYSTEM:

Primary Containment COMPONENTS:

Valves 6-inches NPS and larger subject to leakage rate testing per 10CFR50, Appendix J.

CATEGORY:

A/C (Check Valves)

A (Motor-operated valves)

FUNCTION:

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

SECTION XI REQUIREMENT:

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

~

BASIS FOR RELIEF:

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.

ALTERNATE TESTING:

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

Page 96 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 22 of 46)

RELIEF REQUEST NO. VR-16 (Page 2 of 2)

APPROVAL:

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.

Il rr

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INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES-APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 24 of 46)

RELIEF REQUEST NO. VR-18 (Page 1 of 1)

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

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RELIEF REQUEST NO. VR-19 (Page 1 of 1)

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

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.:,'PPENDIX D

VALVE PROGRAM RELIEF REQUESTS (Page 26 of 46)

RELIEF REQUEST NO. VR-20 (Page 1 of 2)

SYSTEM:

Containment Spray (2998-G-088 Sh 1)

COMPONENTS:

V07119 V07120 CATEGORY'UNCTION:

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

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

BASIS FOR RELIEF:

Full stroke exercising of these valves would require simultaneous operation of one HPSI pump and one LPSI pump injecting into the RCS, and one containment spray pump injecting into its spray header to verify the maximum design accident flow.

Such a test is not practical during any plant operational modes.

ALTERNATE TESTING:

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.

II Page 101 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 27 of 46)

RELIEF REQUEST NO. VR-20 (Page 2 of 2)

ALTERNATE TESTING: (continued)

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.

APPROVAL:

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,

Page 102 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0., :"

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 28 of 46)

RELIEF REQUEST NO. VR-21 (Page 1 of 1)

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

Page 103 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 29 of 46)

RELIEF REQUEST NO. VR-22 (Page 1 of 2)

SYSTEM:

Containment Spray (2998-G-088 Sh 2)

COMPONENTS:

V07172 V07174 CATEGORY'UNCTION:

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

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

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

ALTERNATE TESTING:

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

0 Page 104 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 30 of 46)

RELIEF REQUEST NO. VR-22 (Page 2 of 2)

APPROVAL:

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.

Page 105 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO, 2-0010024, REVISION 0 -'-,; .',

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES-".....':;.

APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 31 of 46)

RELIEF REQUEST NO. VR-23 (Page 1 of 2)

SYSTEM:

Containment Spray (2998-G-088 Sh 2)

COMPONENTS:

V07192 V07193 CATEGORY:

FUNCTION:

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

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

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating 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.

Page 106 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 32 of 46)

RELIEF REQUEST NO. VR-23 (Page 2 of 2)

ALTERNATE TESTING:

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

APPROVAL:

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.

Page 107 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 ', ",

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.'PPENDIX D

VALVE PROGRAM RELIEF REQUESTS (Page 33 of 46)

RELIEF REQUEST NO. VR-24 (Page 1 of 1)

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

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INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES' APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 34 of 46)

RELIEF REQUEST NO. VR-25 (Page 1 of 1)

WITHDRAWN (Rev. 0, 07/1 6/93)

Page 109 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0,;" ";--

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 35 of 46)

RELIEF REQUEST NO. VR-26 (Page 1 of 1)

WITHDRAWN (Rev. 0, 07/1 6/93)

Page 110 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION TESTING PROGRAM FOR PUMPS AND VALVES 0,:.'A'NSERVICE APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 36 of 46)

RELIEF REQUEST NO. VR-27 (Page 1 of 2)

SYSTEM:

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

COMPONENTS:

V09303 V0 9304 V0 9305 CATEGORY:

FUNCTION:

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

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

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

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

Page 111 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 37 of 46) 7 RELIEF REQUEST NO. VR-27 (Page 2 of 2)

ALTERNATE TESTING: (continued)

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.

APPROVAL'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.

Page 112 of 149 ST, LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF'REQUESTS (Page 38 of 46)

RELIEF REQUEST NO. VR-28 (Page 1 of 1)

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

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VALVE PROGRAM RELIEF REQUESTS (Page 39 of 46)

RELIEF REQUEST NO. VR-29 (Page 1 of 1)

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

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TESTING PROGRAM FOR PUMPS AND VALVES 'NSERVICE APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 23 of 46)

RELIEF REQUEST NO. VR-17 (Page 1 of 1)

WITHDRAWN (Rev. 0, 07/1 6/93)

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SYSTEM'age

'PPENDIX VALVE PROGRAM RELIEF REQUESTS (Page 40 of 46)

RELIEF REQUEST NO. VR-30 (Page 1 of 2)

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

COMPONENTS:

V3102 V3103 CATEGORY:

FUNCTION:

These valves open to provide for mini-flow recirculation flow paths from the high pressure injection pumps 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.

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

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

ALTERNATE TESTING:

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.

Page 115 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES'PPENDIX D

VALVE PROGRAM RELIEF REQUESTS (Page 41 of 46)

RELIEF REQUEST NO. VR-30 (Page 2 of 2)

ALTERNATE TESTING: (continued)

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.

APPROVAL:

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.

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VALVE PROGRAM RELIEF REQUESTS (Page 42 of 46)

RELIEF REQUEST NO. VR-31 (Page 1 of 2)

SYSTEM:

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

COMPONENTS:

V08130 V08163 CATEGORY:

FUNCTION:

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

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF:

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

ALTERNATE TESTING:

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 substational flow tests.

Page 117 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 43 of 46)

RELIEF REQUEST NO. VR-31 (Page 2 of 2)

ALTERNATE TESTING: (continued)

During each reactor refueling outage at least one of these valves will be disassembled, inspected and manually stroke 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.

APPROVAL:

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.

Page 118 of,149 ST. LUCIE UNIT 2 ADMINISTRATIVE PROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 44 of 46)

RELIEF REQUEST NO. VR-32 (Page 1 of 1)

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

0 Page 119 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVE.PROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 45 of 46)

RELIEF REQUEST NO. VR-33 (Page 1 of 1)

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

0 Page 120 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 TESTING PROGRAM FOR PUMPS AND VALVES 'NSERVICE APPENDIX D VALVE PROGRAM RELIEF REQUESTS (Page 46 of 46)

RELIEF REQUEST NO. VR-34 (Page 1 of 1)

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

Page 121 of 149 ST. LUCIE UNIT 2 ADIVlINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0,,:

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES, APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 1 of 13)

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.

Reactor Coolant 2998-G-078 Sh 107 V-1460 thru V-1466 Reactor Coolant System Gas Vents These valves are administratively controlled in the keylocked closed position with the power supply disconnected to prevent inadvertent operation. Since these are Class 1 isolation valves for the reactor coolant system, failure closure could result in a loss of coolant in excess of the limits imposed by Technical Specification 3.1.3 leading to a plant shutdown. Furthermore, if a valve were to fail open or valve indication fail to show the valve returned to the fully closed position following exercising, prudent plant operation would probably result in a plant shutdown.

Reactor Coolant 2998-G-078 Sh 108 V-1474 and V-1475 Power-Operated Relief Valves Due to the potential impact of the resulting transient should one of these valves open prematurely or stick in the open position, it is considered imprudent to cycle them during plant operation with the reactor coolant system pressurized.

Page 122 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES E 'PPENDIX VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 2 of 13)

Chemical 8 Volume Control 2998-G-078 Sh 120 V2522 Letdown Line Containment Isolation Valve Closing this valve during operation isolates the letdown line from the RCS and would result in undesirable pressurizer level transients with the potential for a plant trip. If a valve failed to reopen, then an unexpected plant shutdown would be required.

Chemical 8 Volume Control 2998-G-078 Sh 121A V2501 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.

V2505 and V2524 RCP Control Bleedoff Isolation Valves Exercising either of these valves to the closed position when any of the reactor coolant pumps (RCPs) are in the operation would interrupt flow from the RCP seals and result in damage to the pump(s).

V2191 and V2526 CVCS Boron Addition Valve CV/PO test is addressed in Refueling Outage Justification Chemical 8 Volume Control 2998-G-078 Sh 121B V2177, V2190 CVCS Boron Addition Valves CV/PO test is addressed in Refueling Outage Justification

Page 123 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES' APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 3 of 13)

Chemical & Volume Control 2998-G-078 Sh 122 SE-02-03 and SE-02-04 Auxiliary Pressurizer Spray Valves Opening either of these valves (or failure in the open position) during plant operation would cause an RCS pressure transient that could potentially adversely affect plant safety and lead to a plant trip. In addition, the pressurizer spray piping would be subjected to undesirable thermal shock.

V2431 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.

V2440 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.

V2515 and V2516 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.

V2523 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.

Page 124 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 4 of 13)

Safet In'ection/Residual Heat Removal 2998-G-078 Sh 130A V3414 and V3427 HPSI Pump Discharge Check Valves CV/PO test is addressed in Refueling Outage Justification.

V3522 and V3547 HPSI Hot Leg Injection Check Valve CV/PO and CV/C tests are addressed in Refueling Outage Justification.

Safe In'ection/Residual Heat Removal 2998-G-078 Sh 130B V3101 Safety Injection Supply To Volume Control Tank CV/PO test is addressed in Refueling Outage Justification.

V3106 and V3107 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.

Safet In'ection/Residual Heat Removal 2998-G-078 Sh 131 V3113, V3133, V3143 and V3766 HPSI Cold Leg Injection Check Valves CV/PO test is addressed in Refueling Outage Justification.

V3114, V3124, V3134 and V3144 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.

Page 125 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 5 of 13)

Safe In'ection/Residual Heat Removal 2998-G-078 Sh 130 (continued)

V3480, V3481, V3651 and V3652 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.

V3524, V3525, V3526 and V3527 orblack 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 flow test. Performing leak tests of V3524 and V3526 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, V3525 and V3527, 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:

1, At least once per 18 months.

2. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months.

Page 126 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 6 of 13)

Safet In'ection/Residual Heat Removal 2998-G-078 Sh 130 (continued)

V3524, V3525, V3526 and V3527 (continued)

HPSI Hot Leg Injection Check Valves

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.

V3545 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.1 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.

Safet In'ection/Residual Heat Removal 2998-G-078 Sh 132 V03002 thru V03005 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.

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E 'PPENDIX VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 7 of 13)

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

V3215, V3225, V3235 and V3245 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-pressurizing 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.:

1. At least once per 18 months.

2. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and 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.

Page 128 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 8 of 13)

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

V3217, V3227, V3237 and V3247 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.

2. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and 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.

CV/PO test is addressed in Relief Request VR-14

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APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 9 of 13)

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

V3258, V3259, V3260 and V3261 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 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:

1. At least once per 18 months.

2. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and 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.

Page 130 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES.....

APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 9 of 13)

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

V3614, V3624, V3634 and V3644 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 operied. 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.

V3733 thru V3740 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.

Waste Mana ement 2998-G-078 Sh 163B V6792 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.

Main Steam 2998-G-079 Sh 1 HCV-08-1 A&B Main Steam Isolation Valves During plant operation at power, full closure of either of these valves is not practical as it would require isolating a steam generator which would result in a severe transient on the steam and reactor systems and a possible plant trip.

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VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 10 of 13)

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

V08130 and V08163 Steam-Driven AFW Pump Steam Supply Check Valves Full stroke operation of these valves requires operating 2C AFW Pump and full accident flow rate which is not practical during plant operation at power. (See Relief Request PR-4)

Feedwater 2998-6-080 Sh 2A HCV-09-1 A8 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.

Feedwater 2998-G-080 Sh 2B V09107, V09123 and V09139 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'F) into the hot (450'F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

V09119, V09135, V09151 and V09157 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'F) into the hot (450'.F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

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APPENDIX E VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 11 of 13)

Com onent Coolin S stem 2998-G-083 Sh 1 HCV-14-3 A&B Shutdown Heat Exchanger Return Valves Testing either of these valves during plant operation would result in an unbalanced flow condition in the affected CCW train and decreased flow to essential equipment.

This could result in component damage or an undesirable plant transient, Com onent Coolin S stem 2998-G-083 Sh 2 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.

Service Air 2998-G-085 Sh 1 V181 270 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.

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Instrument Air 2998-G-085 Sh 2A V1 8279 and [V1 8283]

Instrument Air Supply To Maintenance Hatch Door Seal A[B] In Annulus V18290, V18291, [V18294 and V18295]

Instrument Air to FCV-25-7 8 [8] (Containment Vacuum Breakers)

Testing of these valves by any method requires isolation of common instrument air header to the Shield Building Annulus so that a vent path may be created on the upstream side of the check valves to determine adequate closure. This test removes one Maintenance Hatch seal and/or Containment Vacuum Relief from service and potentially renders both trains inoperable due to the time that instrument air would be isolated from the common header or use of opposing train as requisite vent path:

Though isolation of instrument air, and subsequent test of a single train, should not keep at least one train from functioning, it requires that both trains of the Shield Building Ventilation System (Technical Specification 3.6.6.1) and Containment Vacuum Relief (Technical Specification 3.6.5) be considered out of service. This could require entry into the Technical Specification applicability statements as non-compliance for Containment Vacuum Relief applicable in Modes 1 through 4.

Testing of these valves requires entry into the Shield Building Annulus for valve lineup and monitoring purposes. If performing quarterly testing, this is a neutron radiation area during Modes 1 and 2. Due to Alara considerations, and the aforementioned dual train operability concerns with components credited for accident mitigation, these valves will be tested at cold shutdown intervals.

Instrument Air 2998-G-085 Sh 2C 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.

Page 134 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES E 'PPENDIX VALVE PROGRAM COLD SHUTDOWN JUSTIFICATIONS (Page 13 of 13)

Miscellaneous Sam lin 2998-G-092 Sh 1 V27101 and V27102 Hydrogen Sampling Return Line Containment Isolation Check Valves This is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is to perform a backleakage test, Performing such a test requires entry into the containment building and breaching of the system, thus it is impractical to do during plant operations.

Heatin Air Conditionin And Ventilation And Air Conditionin 2998-G-878 FCV-25-1 thru FCV-25-6 Primary Containment Purge and Vent Valves These valves are required to remain closed at all times when the plant is operating in Modes 1 through 4, thus they are not required to operate (close) during operational periods. Due to the large size of these valves and the potential for damage as a result of frequent cycling, it is not prudent to operate them more than is absolutely necessary.

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.

0 Page 135 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 1 of 15)

This appendix is intended to provide the justification for performing valve exercising only at refueling outage conditions as permitted by OM-10, +.3.2.2(d), (e) and (h)-and

$ 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.

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VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 2 of 15)

COMPONENTS'2177 V2190 V2191 V2526 SYSTEM:

Chemical and Volume Control (2998-G-078, Sh 121A 8 B)

FUNCTION'2177 and V2526 open to provide a flow path for emergency boration from the boric acid makeup pumps to the suction of the charging pumps. Likewise, V2190 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 V2191 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.

JUSTIFICATION:

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.

Page 137 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 3 of 15)

COMPONENTS:

V2443 V2444 SYSTEM:

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

FUNCTION:

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.

JUSTIFICATION:

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

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

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).

Page 138 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES, APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 4 of 15)

COMPONENTS:

V07000 V07001 SYSTEM:

Safety Injection (2998-6-078, Sh 130B)

FUNCTION:

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

JUSTIFICATION:

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 fill the refueling cavity.

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APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 5 of 15)

COMPONENTS:

V3101 SYSTEM:

Safety Injection (2998-6-078, Sh 130B)

FUNCTION:

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

JUSTIFICATION:

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

Page 140 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 -,:

INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES .:;.;,,

APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 6 of 15)

COMPONENTS:

V3104 V3105 SYSTEM'afety Injection System (2998-G-078, Sh 130B)

FUNCTION:

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.

JUSTIFICATION'here is no flow rate instrumentation available to verify valve full-stroke exercising as required by Generic Letter 89-04, Position 1, ALTERNATE TESTING:

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

Page 141 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0, INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 7 of 15)

COMPONENTS:

V3401 V3410 SYSTEM:

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

FUNCTION:

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

JUSTIFICATION:

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.

Page 142 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0, INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES',

APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 8 of 15)

COMPONENTS:

V3414 V3427 SYSTEM:

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

FUNCTION:

These valves open to provide flow paths from the respective HPSI pumps to the high-pressure safety injection headers. They close to prevent recirculation through an idle pump, JUSTIFICATION:

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 th'ese 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 Specification 3.6.1.1, and therefore use of this flow path is precluded in Modes 1, 2, 3 and 4.

0 Page 143 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 9 of 15)

COMPONENTS:

V3522 V3547 SYSTEM'afety Injection (2998-G-078, Sh 130A)

FUNCTION:

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

JUSTIFICATION:

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 Specification, 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.

Page 144 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 10 of 15)

COMPONENTS:

V3113 V3133 V3143 V3766 SYSTEM; Safety Injection (2998-G-078, Sh 131)

FUNCTION:

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

JUSTIFICATION:

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 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, 2,3and4.

Page 145 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 11 of 15)

COMPONENTS: ,',

V3524 V3425 V3526 V3527 SYSTEM:

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

FUNCTION:

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

JUSTIFICATION:

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 HSPI 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 V3524 and V3526 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.

Page 146 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 12 of 15)

COMPONENTS:

V1 5328 SYSTEM:

Makeup Water (2998-G-084, Sh 1)

FUNCTION:

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

JUSTIFICATION:

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.

Page 147 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 13 of 15)

COMPONENTS:

V18195 SYSTEM:

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

FUNCTION:

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

JUSTIFICATION'his is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. Such a test 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.

Page 148 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES" APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 14 of 15)

COMPONENTS:

V07129 V07143 SYSTEM'ontainment Spray (2998-6-088, Sh 1)

FUNCTION:

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

JUSTIFICATION:

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.

t Page 149 of 149 ST. LUCIE UNIT 2 ADMINISTRATIVEPROCEDURE NO. 2-0010024, REVISION 0 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES APPENDIX F VALVE PROGRAM REFUELING OUTAGE JUSTIFICATIONS (Page 15 of 15)

COMPONENTS:

V07256 V07258 SYSTEM:

Containment Spray (2998-6-088, Sh 1)

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

JUSTIFICATION'esting 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 due 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.