ML17301A111

Forwards Addl Info Re Inservice Testing Program for Pumps & Valves,Per 840412 Request

ML17301A111
Person / Time
Site:	Saint Lucie
Issue date:	07/18/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	John Miller Office of Nuclear Reactor Regulation
References
L-84-179, NUDOCS 8407250219
Download: ML17301A111 (114)

Text

REGULATOR's INFORMATION DISTRIBUTION S'r TEtl (RIBS)

ACCESSION NBR: 8007250219 DOC ~ DATE: GLI/07/18 tVOTAR IZED: NO DOCKET FACIL:50-335 St, Lucio Planti Unit 1< Florida Power 8 Light Co. 05000335 AUTH s NAME AUTHOR AFF ILIATION HILLI,AMSiJ.N. Florida Power 8 Light Co, RECIP,NAME RECIPIENT AFFILIATION MILLERiJ.R. Operating Reactors Branch 3 S UBJECT; Forwards addi info re inservice testing program for pumps

& valvesrper 840412 request.

DISTRIBUTION CODE: A097S COPIES RECEIVED:LTR i ENCL TITLE: OR Submittal: Inservice Inspection/Testing NOTES:

OL:02/01/76 05000335'ECIPIENT COPIES RF C IP IENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR ORB3 BC 01 7 7 INTERNAL; ELD/IIDS2 1 0 NRR/DE/MEB 15 1 1 B fg 1 1 NRR/DL/TAPING 1 1 G FILE 04 1 1 RGN2 1 1 EXTERNAL: ACRS 16 10 10 LPDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1 1 NTIS 1 1 TOTAL NUMBER OF COPIES REQUIRED; LTTR 27 ENCL,, 26

U7 0 x~~l<~~

+i'8<

FLORIDA POWER & LIGHT COMPANY July 18, 1984 L-84-179 Office of Nuclear Reactor Regulation Attention: Mr. James R. Miller, Chief Oper ating Reactors Branch III3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Miller:

Re: St. Luci e Uni 1 t Docket No. 50-335 Inservice Testing PrograII (IST)

For Pum s and Valves Your letter dated April 12, 1984 transmitted the results of your revim of our IST program. You also requested additional information regarding our program. Please find attached our responses to those requests.

Very truly yours, J.~ W.~

Group Willi;

~

~

Vice President Jr.

Nuclear Energy JWW/JEM/js Attachment cc: J. P. O'Reilly, Region II Harold F. Reis, Esquire W. Ross, .Region II PNS-LI-84-238 84072502i9 8407i8 PDR ADOCK 05000335 P PDR M

-1 alt PEOPLE... SERVING PEOPLE

• ~

'E

PAGE 1 OF 4 REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE ST LUCIE UNIT 1 PROGRAM FOR INSERVIGE TESTING (IST) OF PINP AND VALVES NRC QUESTION:

The following valves at St. Lucie Unit 1 are not included in your IST program. Please justify why these valves were omitted or else submit a revision of your program that includes these valves and any additional requests for relief from the ASNE Code that are appropriate.

Chemical Volume and Control System valves SE-02-03, SE-02-04, V-2324, V-2325, V-2326, V-2315, V-2318, V>>2321, V-2435, V-2105, V-2199, V-2118, V-2526, V-03920, and the heat traced piping thermal reliefs.

Safety Injection System val ves V-3211, V-3221, V-3231, V-3241, V-3439, V-3637, V-3647, V-3439, V-3468, V-3483, V-3469, V-3482, V-3430, V-3431, V-3407, V-3417 and V-03920 Containment Spray System valves V-07256 and V-07258 FPL RESPONSE:

1. The Chemical Volume and Control, Safety Injection, and Containment Spray System Valves listed above are addressed in the attached pages, except for the following valves:

Relief Valve No. V-2199 is a flow control valve and does not perform an overpressure protection function.

Relief Valve No. V-2105 is located in a system which is categorized as Quality Level D. Therefore this relief valve is outside the Scope of Section XI. However, we have added Relief Valve No. 2115, the Volume Control Tank (VCT) relief valve.

Check Valve No. V-2526 does not perform a safety-related function to safely shutdown the reactor or mitigate the consequences of an accident. The only flow path, which would be affected by the failure of this check valve in the open position, is isolated on an SIAS Signal. Therefore, this check valve is not included in the St. Lucie Unit No. 1 IST Progran.

NOTE: The attached pages are submitted as a revision to the existing St.

Lucie Unit No. 1 Inservice Test (IST) Progran. These pages supersede and replace the pages previously submitted.

14 tl n

I't I 4 I

~ '

I H )

ff !

I I ~

I I 4 ft' I f It 4

It 4 I H C H t II II 4 p I' H

P 41 tl p

4 It I

O I I

H I s ll 11' l 4 I, I

II I, If N

I 41 t ft I f I

Il llh f I C I b lk I

0 I III I II I

PAGE 2 OF 4 NRC QUESTION:

2. The fol lowing check valves are categorized as C valves in your progr an. These valves perform a pressure isolation function between the high pressure Reactor Coolant System and the lower pressure Safety Injection System. Consequently, maximum leakage limits for these valves are specified by the St. Luci e Uni t 1 Technical Specifications. Please justify why these valves should not be categorized and tested as AC valves or submit a revision to your progran that reflects an AC categori zati on.

Safety Injection System valves V-3113, V-3114, V-3123, V-3124, V-3133, V-3134, V-3143, V-3144, V-3217, V-3227, V-3237 and V-3247 FPL RESPONSE:

2. Please refer to Table I.B and Safety Injection System Relief Request No.

17.

NRC QUESTION:

3. The staff has identified the following eight valves as also performing pressure isolation functions. Please justify why these valves should not have leak test requirements such as those in Technical, Specification 3.4.6.2 or else revise the St. Lucie Unit 1 IST progran accordingly.

Valves V-3215, V-3225, V-3235, V-3245, V-3480, V-3481, V-3651 and V-3652 FPL RESPONSE:

30 Please refer to FPL letter L-80-85 dated March 17, 1980, R. E. Uhrig (FPL) to Mr. Eisenhut (NRC) regarding Reactor Coolant System (RCS)

Pressure Isol ation. The safety concern for the Reactor Cool ant System (RCS) pressure isolation valves, identified in St. Lucie Unit No. 1 Technical Specification 3.4.6.2, was the failure of one of two in-series check valves that could go undetected for a substantial length of time. The worst case scen ari o for these check val ves at St. Luci e Uni t No. 1 would be: (1) the undetected failure of the second of the two in-series check valves, (2) the catastrophic failure of the second in-series check valves, (3) followed by an SIAS signal with normal RCS pressure (invalid SIAS signal) concurrent with loss of offsite power, (4) the automatic opening of the normally closed motor operated isolation valves, during the interval associated with the starting and the loading of the Emergency Diesel Generator, when there is no flow in the safety injection system, and (5) Overpressurization and rupture of the lower pressure safety injection system which results in a Loss of Cool ant Accident (LOCA) that bypasses containment.

i

H M ll M

M V

M I

w l I t H D

H V M II C

ll I I~

a ~

M t M M I M

M 'I

PAGE 3 OF 4 do not agree that leak test requirements are required for the i We following valves because oper ability can be demonstrated by alternate means:

The Safety Injection Tank (SIT) outlet check valves, V-3215, V-3225, V-3235, and V-3245, represent a configuration of two in-series check valve configuration. However, the safety injection header pressure al arm/indicator instruments which annunci ate a high pressure alarm in the control room, with the SIT water level and pressure measurement channels provide an alternate means to detect check valve leakage. Refer to Safety Injection System Relief Request No. 18.-

The two in-series motor operated shutdown cooling system isol ation valves, V-3400, V-3481, V-3651, and V-3652, unlike the check valves, have remote valve position indicators located in the control room. These valves are positioned closed and locked closed to prevent inadvertent operation. Further, these valves are interlocked with two RCS pressure measurement channels to prevent opening these valves until the RCS pressure has been reduced to 268 psi or less. Any leakage through these MOV's would result in an associated increase in pressure. The relief valve located downstrean of the each MOV would actuate to limit the pressure in the associated piping. Any discharge from the relief valve would be collected in the quench Tank (for the valves located inside containment) or the RWM Holdup Tank (for the relief valves located outside containment). Thus leakage through the MOV would be detected by an increasing level in the associated collection tank. Refer to Safety Injection System Relief Request No. 19.

NRC QUESTION:

4~ During the staff's review of the St. Lucie IST program, we were advised that the progran was being revised to propose testing the following valves during cold shutdown and other revisions would also be submitted for these CVCS valves.

Valves SE-02-01, SE-02-02, V-2515, V-2516, V-2501 and V-2504 FPL RESPONSE:

4. Please refer to attached sheets and Chemical Volume and Control Relief Request Nos. 3, 4, 5, and 7.

NRC QUESTION:

5. During the staff's review, we were advised that additional time was needed to provide justification that valves V-2177 and V-2190 cannot be flow tested during refueling outages.

Please provide this justification or commit to a flow test.

/

FPL RESPONSE:

5. Please refer to attached sheets and Chemical Volume and Control Relief Request No. 9.

1 1

I' 1V C

0 II

! 1 f gt ii I~ 1 1

II I I!I

~

VI I I f!

II It 1

1

~ 1! ~

1 II

!! 'I I

a ,,4 1!

t V'

Ih I I, 'I V

I II

~ Ii V V

E ~

II I II II Il

! C,a it  ! IJ I  ! 1 1

Vl' I

Ii ~ II

PAGE 4 OF 4 NRC QUESTION:

6. You have requested relief from requirements of paragraph IWV-3520 of Section XI of the ASME Code for valves V-3215, 3225, 3235 and 3245 (Safety Injection Tank discharge check valves) and propose to part-stroke exercise these valves during refueling outages. This proposed test, alone, is unacceptable; however, the staff will approve your pr opos al i f you commi t to further veri fy oper abi li ty of these val ves by disassembling and manually stroking these valves at 10 year or less intervals. Please provide this commitment or justify the basis for a non-commi tment.

FPL RESPONSE:

6. Because of ALARA considerations, we are investigating alternative means to demonstrate oper ability of these check valves instead of the disassembling and manually stroking these check valves. We anticipate we can provide a response by November 30, 1984.

NRC QUESTION:

7. Justify why valves V-3463 and I-V07009 (di scharge from SIT to RWST) should not be categorized as AE and be given the operational checks required by Par agr aph IWV-3700.

FPL RESPONSE:

7. Refer to attached sheets and Safety Injection System Relief Request No.

10.

NRC QUESTION:

8. You have requested relief from Paragraph IWV-3410 for valves FSE-27-1 through FSE-27-11 (Hydrogen Saopling) and valves I-SE-17-1A and I-SE 1B (Diesel Oil) and propose alternative methods of verifying operability of these valves. We recognize the difficulties involved in stroke-timing solenoid valves; however your proposals address only one limiting value; i.e., veri fying val ve opening and closure. It i s our position that stroke timing also provides information relative to valve degradation. Consequently, we believe that you should seek methods to establish stroke timing through such techniques as fail-safe closure or a coarse stroke time (2 second maximum). Please provide a commitment to investigate further more exact stroke timing methods.

FPL RESPONSE:

8. Refer to Hydrogen Sampling System Relief Request No. 1 and Diesel Oil System Relief Request No. 1.

I C

C t C II ~

ABSTRACT The planned inservice inspection and testing programs, for St. Lucie Unit Ho.

1, were developed employing the Regulatory Guide 1.26, Revision 2, criteria for quality classifications and stadards (guality Group A is the sane as ASIDE Safety Class 1, etc.).

Section I. Valve Test Pro ram Outli ne The valve test program shall be conducted in accordance with Subsection IWV of Section XI of the 1974 Edition of the ASME Boiler and Pressure Vessel Code thru Summer 1975 Addenda, except for specific relief request in accordance with 10CFR50.55a(g) (5) (iii) which is identified in Subsection I.G.. The period for this valve test program starts April 21, 1980 and ends December 21, 1986. The effective date for the revised progran shall be six (6) months after the submittal date.

Section II. Pum Test Pro ran Outline The pump test progran shall be conducted, in accordance with Subsection IWP of Section XI of the 1974 Edition of the ASIDE Boiler and Pressure Vessel Code thru Summer 1975 Addenda, except for specific relief requested in accordance with 10CFR50.55a (g) (iii) which is identified in Subsection II.A.

The period for the pump test program starts Aril 21, 1980, and ends December 21, 1986. The effective date for the revised progran shall be six (6) months after the submittal date.

0 I.E.

~ ~ LEGEND FOR TABLE I - TEST PARAMETERS TO (CODE) OR RELIEF REQUEST EXCEPT AS OTHERWISE NOTED (FPL).

- CATEGORY A-B VALVES-Exerci si n EF-1 Exercise valve (full stroke) for operability every 3 months (Code).

Exercise valve (full stroke) for operability during cold shutdown (Code).

Exercise valve (full stroke) for operability during refueling shutdown (Code).

EF-4 Exercise valve (full stroke) for operability prior to return to service (Code).

EF-5 Exercise valve (with Remote Position Indicator and inaccessible for direct observation) for verification of valve position during refueling but less than every 2 years (Code).

EF-7 Exercise valve (with Fail-Safe Actuators) to observe failure mode every 3 months (Code).

. EF-8 Exercise valve (with Fail-Safe Actuators) to observe mode during cold shutdown (Code).

failure failure EF-9 Exercise valve (with fail-Safe Actuators) to observe mode during refueling shutdown (Code).

OC-1 Operational check of valve (verification of position) before and after oper ation (Code).

Measurement'f Full Stroke Time EST-1 Exercise valve - power operated (full stroke) and measure time (Code) (5 seconds - Max.) (FPL).

EST-2 Exercise valve - power operated (full stroke) and measure time (Code) (10 seconds - Max.) (FPL).

EST-3 Exercise valve - power operated (full stroke and measure time (Code) (60 seconds - Max.) (FPL).

EST-4 Exercise valve - power operated (full stroke) and measure time (Code) (120 seconds - Max.) (FPL).

EST 5 Exercise valve - power operated (full stroke) and measure time (Code) (180 seconds - Max.) (FPL).

a I a

'H j

f ~

a H

,r

'I a

H, a H

H

~

~

O I

I.E.

~ ~ LEGEND FOR TABLE I (CONT )

EST-6 Exercise valve - power operated (full stroke) and measure time (Code) (15 seconds - Max.) (FPL).

EST-7 Exercise valve - power operated (full stroke) and measure time (Code) (30 seconds - Max.) (FPL).

EST-8 Exercise valve - power operated (full stroke) and measure time (Code) (45 seconds - Max.) (FPL).

EST-9 Exercise valve - power operated (full stroke) and measure time (Code) (90 seconds - Max.) (FPL).

- CATEGORY "C" VALVES-EF-1 Exercise valve (full stroke) for operability every 3 months (Code).

EF-2 Exercise valve (full stroke) for operability during cold shutdown (Code).

Exercise valve (full stroke) for oper ability during refueling shutdown (Code).

TF-1 Safety and relief valve tests (Set Point) to ASME Table IMV-3510-1 (Code).

NOTES:

Cold Shutdown - ISI tests scheduled for Test Period 2 (Cold Shutdown) shall commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching MODE 5 (Cold Shutdown) conditions, or no later than 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> if MODE 5 (Col d Shutdown) conditions are reached between Friday 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> and Monday 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />. In the case of frequent Cold Shutdowns, valve testing will not be performed more often than once every three (3) months for Category A, B, and C valves. Valves that are not tested during a specific Cold Shutdown, due to plant startup, will be identified to assure their testing in the event of untimely Cold Shutdowns within the three (3) month time period. In any event, plant startup shall not be delayed to complete valve testing.

2) Corrective Action - klhere a valve fails to meet the requirements of this progr an and/or the reference Code, the condition(s) shall be reviewed by the Facility Review Group for disposition and determination of whether it involves an unreviewed safety question prior to commencing with plant star tup or conti nui ng wi th pl ant operati on.

kh k K

~ II I

) ~

g >/IA,

'<<V V

'I lf V Ml 'l ~

)

f f(V I'h V

I II V

~

Il VI I V

VV

( k, v ~

I g' r k

~ VV k "I Vh (V('

V 'Vv kV g. V kk k I I I I ((I I .'

IC k k

V '\ I I I I

V I CV

( V I

ll V I VV rr(V

~ ~ I W

II I

% (k I 'V I, r ~ I I' II y,hVk V." I ~

k 'I V '

IIV(f ' ( t V(

f

St. Lucie Unit No. 1 Page 1 of 2 TABLE I. B.

REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES MAXIMUM (a) (b) (c)

SYSTEM VALVE NO High-Pr e s suYe Safet In 'ection Loop lA1, cold leg V-3227 5 0 V-3123 5.0 Loop lA2 cold leg V-3 21 7 5.0 V-3113 5.0 Loop 1Bl, cold leg V- 3237 5.0 V-3133 5.0 Loop 1B2, cold leg V-3 247 5.0 V-3143 5.0 Low-Pressure Safety In 'ection Loop lAl, cold leg V-3124 5.0 Loop lA2, cold leg V-3114 5.0 Loop lB1, cold leg V-3134 5.0 Loop 1B2, cold leg V-3144 5.0

(

0

St. Lucie Unit No.

~

~ 1 Page 2 of 2 TABLE I.B. (CON')

REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES NOTES TO TABLE I.B.

(a) Maximum Allowable Leakage (each valve)

l. Leakage rates less than or equal to 1.0 gpm are ac ceptable.

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

3. Leakage rates greater than l. 0 gpm but less than or equal to 5.0 gpm are unacceptable if the latest measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.

4. Leakage rates greater than 5.0 gpm are unacceptable (b) To,satisfy ALARA requirements, leakage may be measured indirectly (as from the performance of pressure indicatior) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demonstrating valve compliance with the leakage criteria.

(c) Minimum test differential pressure shall not be less than 150 psid.

St. Lucie Unit Mo. 1 Page 1 of 6 RELIEF REQUEST BASIS SYSTEM: Reactor Coolant

1. Valve: V-1402 and V-1404 Category: B Class: 1 Function: Provides low-temperature overpressure protection function during cold shutdown to protect against exceeding pressure temperature limits.

Mo credit is taken in the Safety Analysis for any pressure reducing devices, except for the pressurizer safety valves (V-1200, V-1201, and V-1202) and the main steam safety valves (V-8201 through V-8216).

Test Requirement: IWV-3410 Basis for Relief: The failure of either of these valves in non-closed position by testing during plant operation, would require a unit outage to perform maintenance on the The failure of either of these valves in the non-closed position by testing safety fuction because both valves are required to ensure low-temperature overpressure protection during cold Alternate Testing: These valves will be tested during refueling shutdowns.

MOTE: These valves are included in the St. Lucie,Unit Mo. 1 Valve Test Program in accordance with a previoius commitment to MRC Staff.

S t. Luci e Unit No. 1 Page 2 of 6 RELIEF REQUEST BASIS SYSTEM: -Reactor Coolant

2. Valve V-1403 and V-1405 Category: B Class: 1 Func ti on: Provides the flow path from the pressurizer to the associated solenoid operated valve that provides for low-temperature overpressure protection during cold shutdown to protect against exceeding pressure-temperature limits.

No credit is taken in the Safety Analysis for any pressure reducing devices, except for the pressurizer safety valves (V-1200, V-1201, and V-1202) and the main steam safety valves (V-8201 through V-8216).

Test Requirement: IWV-3410 Basis for Relief: The failure of either of these valves in ti the open posi on, by testing during plant operation, would require a unit outage to perform maintenance on the f ailed valve.

The failure of either of these valves in the closed position, by testing during cold shutdown, would result in a loss of system safety fuction because both valves are required to ensure low-temperature overpressure protection during cold shut, downs.

Alternate Testing: These valves will be tested during refueling shutdowns.

NOTE: These valves are included in the St. Lucie Unit No-Valve Test Program in accordance with a previous commitment to NRC Staff.

St. Lucie Unit No. 1 Page 3 of 6 RELIEF REQUEST BASIS SYSTEM: Reactor Coolant

3. Valve: V-1441 and V-1442 Category: B Class: 2 Function: Provides for redundant flow paths from the reactor vessel closure head to the Reactor Coolant Gas Vent System (RCGVS).

Test Requirement: IWV-3410 Basis for Relief: These valves are required to be positioned closed and key locked to prevent i nadvertent operation during normal plant operation.

The f ailure of either of these valves in the non-closed position, coupled with the failure of either V-1445, V-1446,,

or V-1449, while testing during plant operation, could result in the loss of reactor coolant in excess of Technical Specification 3.4.6.2.d limits. This would result in a unit shutdown.

Alternate Testing: These valves will be tested during cold shutdowns when the Reactor Coolant System is depressurized and vented.

St. Lucie Unit No. 1 Page 4 of 6 RELIEF REQUEST BASIS SYSTEM: Reactor Coolant

4. Valve: V-1443 and V-1444 Category: B Class: 2 Function: Provides for redundant flow paths from the pressurizer steam space to the Reactor Coolant Gas Vent System (RCGVS) .

Test Requirement: IWV-3410 Basis for Relief: These valves are required to be positioned closed and key locked to prevent inadvertent operation during normal plant operation.

The f ailure of either of these valves in the non-closed position, coupled with the f ailure of either V-1445, V-1446, or V-1449, while testing during plant operation, could result in the loss of reactor coolant in excess of Technical Speci fication 3. 4. 6. 2. d limits. This would result in a unit shutdown.

Alternate Testing: These valves will be tested during cold shutdowns when the Reactor Coolant System is depressurized and vented.

t I

4 0

St. Lucie Unit No. 1 Page 5 of 6 RELIEF REQUEST BASIS SYSTEM: Reactor Coolant

5. Valve: V-1445 and V-1446 Category: B Class: 2 Func tion: Provides for redundant flow paths from either the reactor vessel closure head or the pressurizer steam space to either the vent directed to the containment or the quench tank.

Test Requirem nt: IWV-3410 Basis for Relief: These valves are required to be positioned closed and key locked to prevent inadvertent operation during normal plant operation.

The failure of V-1445 in the non-closed position, while testing during plant operation, would result in the inability to isolate the quench tank from the RCGVS.

The failure of V-1446 in the non-closed position, while testing during plant operation would result in the inability to isolate to isolate the direct vent flow path to the containment from the RCGVS.

Alternate Testing: These valves will be tested during cold shutdowns when the Reactor Coolant System is depressurized and vented.

St. Lucie Unit No. 1 Page 6 of 6 RELIEF REQUEST BASIS SYSTEM: Reactor Coolant

6. Valve: V-1449 Category: B Class: 2 Function: Provides flow path to either the quench tank or the containment sump to determine leakage rate past any of the RCGVS i solation valves.

Test Requirement: IWV-3410 Basis for Relief: The failure of V-1449 in the non-closed position, by testing during plant operation, would result in the inability to isolate leakage detection from the RCGVS.

Alternate Testing: This valve will be tested during cold shutdown when the Reactor Coolant System is depressurized and vented.

l

)

I l

l t

i I

r

St. Lucie Unit No. 1 Page 1 of 8 RELIEF REQUEST BASIS SYSTEM: Chemical Volume and Control

l. Deleted

2. Valve: . SE-01-01 and V-2505 Category.: A Class: 2 Function: Provides controlled leakoff flow path for the reactor coolant pump seal system.

Test, Requirement: IWV-34 10 Basis for Relief: Testing these valves during plant operation will interupt flow of the controlled leakoff from the reactor coolant pump seals, which could result in damage to the reactor coolant pumps. This could place the plant in an unsafe mode of operation.

Alternate Testing: These valves will be tested during cold shutdowns.

t l

0

St. Lucie Unit No. 1 .Page 2 of 8 RELIEF REQUEST BASIS SYSTEM: Chemical Volume and Control

3. Valve: '; :Ol, SE-.02: and'E-;:02-'02 Category:' B Class:

Function: Provides charging flow path to the Reactor Coolant System.

Test Requirement: IWV-3410 Basis for Relief: Testing these valves during plant operation would isolate charging flow, thus causing an unbalanced flow condition in the Chemical Volume and Control System when charging and letdown flow is required, Modes 1 thru 4.

Alternate Testing: These valves will be tested during cold shutdowns.

4. Valve:; V-2515 and V.-..2516.

Category: A Class: 1 Function: Provides the letdown flow path from the Reactor Coolant System to the Chemical Volume and Control System.

Test Requirement: IWV-3410 Basis for Relief: Testing either of'these valves during plant operation would isolate letdown flow, thus causing an unbalanced flow condition in the Chemical Volume and Control System when charging and letdown flow is required, Modes 1 thru 4.

Alternate Testing: These valves will be tested during cold shutdowns.

1 f

J

(

\

f I

St. Lucie Unit No. 1 Page 3 of 8 RELIEF REQUEST BASIS SYSTEM: Chemical Volume and Control

5. Valve: '-2501 Category: B Class: 2 Function: Provides flow path from Volume Control Tank to the charging pump suction header.

Test Requirement: IWV-3410, Basis for Relief: Failure of this valve in the closed position, by testing during plant operation, would isolate the charging pump suction header from the volume control tank. This could result in damage to'the pumps and place the plant in an unsafe mode of operation.

Alternate Testing: This valve, will be tested during cold shutdowns.

6. Valve: '-2514 Category:' B Class:

Function: Provides flow path from normal boric acid makeup flow path to the emergency boration flow path.

Test Requirement: Il'V-3410 Basis for Relief: Testing this valve during normal plant operation could result in the injection of concentrated boric acid solution into the Reactor Coolant System.

This could place the plant in an unsafe mode of operation.

Alternate Testing: This valve will be tested during cold shutdowns.

St. Lucie Unit No. 1 Page 4 of 8 RELIEF REQUEST BASIS'YSTEM:

Chemical Volume and Control

7. Valve: V-2504 Category: B Class: 2 Function: Provides flow path from the Refueling Water Tank to the charging pump suction header.

Test Requirement: IWV-3410 Basis for Relief: Testing this valve during normal plant operation could result in the injection of concentrated boric acid solution into the reactor coolant system. This could result'in placing the plant in an unsafe mode of operation.

Alteinate Testing: This valve will be tested during gold shutdowns.

8. Valve: V-2191 Category:' C Class:

Function: Prevents reverse flow from the charging'ump suction header to the Refueling Water Tank when V-2504 is open.'est Requirements: IWV-3520 Basis for Relief: Testing this valve during normal plant operation would result in the injection of concentrated boric acid solution into the reactor coolant system. This could result in placing the plant in an unsafe mcde of operation.

Further, failure of of this valve in the open position by testing during cold shutdowns would result in the loss of one of the emergency boration flow paths required during cold shutdowns.

Alternate Testing: This check valve will"-be 'exercised ~ ~

during refueling shutdowns.

St. Lucie Unit No. 1 Page 5 of 8 RELIEF REQUEST BASIS SYSTEM: Chemical Volume and Control

9. Valve: V-2177 and V-2190 Category: C Class: 2 Function: Prevents reverse flow from the charging pump suction header to the emergency boration flow path.

Test Requirement: IWV-3520 Basis for Relief: Testing these valves 'during normal plant operation could result in the injection of concentrated boric acid solution into the reactor coolant system. This could place the plant in an unsafe mode of operation.

Failure, of either of these valves in the closed position, by testing duixng cold shutdowns, would result in the loss of one of the emergency boration flow paths required during cold shutdowns.

Alternate Testing: These valves will be tested during refueling shutdowns.

10. Deleted

St. Lucie Unit No. l Page 6 of 8 RELIEF REQUEST BASIS SYSTEM: Chemical Volume and Control ll. Deleted l2. Valve: V-2430 Category: C Class: 2 Function: Prevents reverse flow from the Reactor Coolant System into the Chemical Volume and Control System, if a component downstream of this valve malfunctions or fails to perform its function.

Test Requirement: IWV-3520 Basis for Relief: There are no provisions for testing this valve to ensure verification that the disk has seated properly upon cessation or reversal of flow.

Alternate Testing: This valve will be disassembled during a refueling shutdown over the ten year Inservice Inspection Interval to inspect the valves'reedom of motion to open and closed positions.

St. Lucie Unit No. 1 Page 7 of 8 RELIEF REQUEST BASIS "SYSTEM: Chemical Volume and Control

13. Valve: SE-02-03 and SE-02-04 Category: B Class: 1 Function: Provides auxiliary spray flow path from the CVCS to the pressurizer during RCS heatup and cooldown operati ons.

Test Requirement: IWV-3410 Basi s for Relief: Testing these valves during plant operation would result in RCS pressure transients. This could place the plant in an unsafe mode of operation.

Alternate Testing: These valves will be tested during cold shutdowns.

14. Valve: V-2435 Category: C Class: 1 Function: . Provides flow path to the RCS should hot letdown continue even though the charging flow has been stopped due the to closure of the control valves to the RCS.

Test Requirement: IWV-3520 Basis for Relief: Testing this spring loaded check valve during plant operation would require isolation of the normal charging flow path to the RCS This would place the plant in an unsafe condition.

Alternate Testing: This valve will be flow tested (exerci sed) during cold shutdowns.

St. Lucie Unit No. 1 RELIEF REQUEST BASIS Page 8 of 8

15. Valve: V-2118 Category: C Class: 2 Func tion Provides flow path from the VCT to the charging pump suction header during normal operation.

Prevents reverse flow to the VCT if V-2501 should fail to close and emergency boration is requi red.

Test. Req'uirement: IWV-3520 Basis for Relief: Testing this valve during plant operation would result in the loss of normal VCT flow path to the charging pump suction header. This would place the plant in an unsafe mode of operation.

Failure of this valve in the closed position by testing during cold shutdown would isolate one of the emergency boration flow paths required during cold shutdowns.

Alternate Testing: This valve will be tested during refueling shutdowns.

16. Valve V-2526 Category: C Class: 3 Function: This check valve provides normal flow path from the VCT to the charging pump suction header.

It does not perform a safety related function to either provide for the safe shutdown of of the reactor or to mitigate the consequences an accident..

Test Requir ement: IWV-3520 Basis for Relief: This valve does not perform a

'safety related function to ei ther pr ovi de for the sa fe shutdown of the reactor or to mitigate the conse-quences of an accident Alternate Testing: None

St. Lucie Uni t No. 1 Page 7 of 14 RELIEF REQUEST BASIS SYSTEM: Safety Injection

13. Valve: V-3206 and V-3207 Category: B Class: 2 Function: Provides for remote isolation of Low Pressure Safety Injection System (LPSI) pump suction headers.

Test Requirement: IWV-3410 Basis for Relief: The failure of either of these valves in the closed position, by testing during plant operation, would result in the loss of function of one of the LPSI pumps, if r equired.

Alternate Testing: These valves will be tested during cold shutdowns.

14. Valve: V-3432 and V-3444 Category: B Class: 2 Function: Provides for, remote isolation of Low Pressure Safety Injection System (LPSI) pump discharge headers.

Test Requirement: IWV-3410 Basi s for Relic f: The failure of either of these valves in the closed position, by testing during plant operation, would result in the loss of function of one of the LPSI pumps, i f required.

Alternate Testing: These valves will be tested during cold shutdowns.

St. Lucie Unit No. 1 Page 8 of 14 RELIEF REQUEST BASIS SYSTEM: Safety In jection

15. Valve: V-3452, V-3453, V-3456, and V-3457 Category: B Class: 2 Function: Provides for remote isolation of the Shutdown Cooling (SDC) heat ezchangers.

Test Requirement: INT-3410 Basis for Relief: The failure of either of these valves in the open position, by testing during plant operation, would result in the diminished function of one of the containment spray headers, if required.

Alternate Testing: These valves will be tested during cold shutdowns.

16. Valve: MV 2 Category: B Class: 2 Function: Provides for a redundant Low Pressure Safety Injection System (LPSI) pump discharge header flow path by bypassing FCV-3306.

Test Requirement: INV-3410 Basi s for Reli e f: The failure of this valve in the closed position, by testing during plant operation, would result in the loss of the redundant LPSI pump discharge header flow path, i f required.

Alternate Testing: These valves will be tested during cold shutdowns.

St. Luci e Unit No. 1 Page 9 of 14 RELIEF REQUEST BASIS SYSTEM: Safety In jection

17. Valve: V-3113 V-3114 V-3 217 V-31 23 V-31 24 V-3 227 V-3133 V-313 4 V-3 237 V-3143 V-3144 V-3 247 Category: AC Class: 1 or 2 Function: These valves provide for pressure isolation between the Reactor Coolant System, the High-Pressure, and Low-Pressure Safety Injection System.

Test Requirement: IWV-3520 Basis for Relief: These valves are required to be tested pursuant to an NRC Order dated April 20, 1981 which modified St. Lucie Unit No. 1 Technical Speci

4. 4.6. 2.

fi cation 3. 4. 6. 2 and Alternate Testing: Continue testing these valves in accordance wi th St. Lucie Unit No. 1 Technical Speci fication 4.4. 6. 2. e.

0 St. Lucie Unit No. 1 Page 10 of 14 RELIEF REQUEST BASIS SYSTEM Safety Injection

18. Valve: V-3215, V-3225, V-3235, and V-3245 Category: C Class: 2 Function: These check valves prevent reverse flow from -the Safety Xnjection System (SIS) header into the associated Safety Injection Tank (SIT).

Test Requirement: INV-3520 Basis for Relief: Any leakage of reactor coolant through the SIS isolation check valves (V-3217, V-3227, V-3237, and V-3247) would be detected by an associated pressure increase on the low-pressure side of the check valves. 'Pressure indicator/alarm instruments (PIA-3319, PIA-3329, PIA-3339, and PIA-3349) monitor SXS header pressure. On high-pressure, these instruments would annuniciate alarms i n the c ontr ol r oom.

If the Safety Injection Tank (SIT) outlet check valve disk is not seated properly, any leakage of reactor coolant through the SIT check valves would be detected by:

1) SIT Water Level Any in-leakage of reactor coolant into the SIT would produce an increase in level in the SIT. This would be detected by the SIT level indicator/alarm instrument s (LIA-3311, L IA-33 21, L XA-3331, and LIA-3341) which indicate SIT level'n the control room. On high SIT level, these instruments would annuniciate alarms in the control room. In addition, level switches (LS-3313, LS-3323, LS-3333, and LS-3343),

which are located on the SIT, would actuate on high level and alarm in the control room.

This provides for redundant and diverse SIT level indication and alarm in the control room Further, high water level in the SIT can be corrected by using the SIT recirculation line to drain excess water to the Radioactive Waste Management (RMS) System. This provides for maintaining proper SIT water level during power, operation.

St. Lucie Uni t No. 1 Page ll of 14 RELIEF REQUEST BASIS (Con ')

SYSTEM: Safety Injection

18. Valve: V-3215, V-3225 V-3235, and V-3245 (Con't)

Basis for Relief (Con't):

2) SIT Pressure Any in-leakage of reactor coolant into the SIT would produce an increase in level in the SIT. This would cause an increase in SIT pressure because the SIT is a relatively small closed volume with a nitrogen cover gas. This increase in pressure would be detected by SIT pressure indicator/alarms (PIA-3311, PIA-3321, PIA-3331, and PIA-3341) which indicate SIT pressure in the control room. On high pressure in the SIT, these instruments would annuniciate alarms in the control room.

In addition, pressure switches (PS-3311, PS-3321, PS-3331, and PS-3341), which are located on the SIT, would actuate on high pressure and alarm in the control room.

This provides for redundant and diverse SIT pressure indication and alarm in the control r oom.

Further, hi gh SIT pressure resulting fr om in-le ak age and an as soci ate d incr ease in SIT water level can be corrected by using the SIT recirculation line to drain excess water from the SIT to the Radioactive Waste Management(RMS) System. This provides for maintaining proper SIT water level and pressure, during power operation.

Alternate Testing Mone.

Periodic review of SIT level and pressure will demonstrate that the SIT outlet check valves are not leaking.

St. Lucie Unit No. 1 Page 12 of 14 RELIEF REQUEST BASIS SYSTEM Safety Injection

19. Valve: V-3480, V-3481, V-3651, and V-3652 Category: B Class: ~

1 Function: These valves provide the flow path from the Reactor Coolant System (RCS) to the Shutdown Cooling (SDC) System.

Test Requirement: IWV 3410 Basis for Relief: These motor operated valves (MOV) are provided with remote valve position indicators located in the control room.

When the SDC System is i solated, during RCS heatup operations, these valves are positioned closed and key-locked closed to prevent inadvertent operation during power oper at i on.

In addition, these valves are inter-locked with two RCS pressure measurement channels to prevent opening these valves unless the RCS pressure is 268 psia or less.

Any leakage from the RCS through these valves would result in an associated pressure increase on the low pressure side of these valves. This increase in pressure would actuate the relief valve located downstream of the valve.

Thus, the associated pressure increase would be limited by the operation of the relief valve.

Any leakage past these valves would be detected because any discharge from the relief valve is collected in the Quench Tank (QT), for those relief valves located inside containment, or the Radioactive Waste Management System Holdup Tank (HT),

for those relief valves located outside containment

I I

I e

St. Lucie Unit No.

~ ~ 1 Page 13 of 14 RELIEF REQUEST BASIS (Con't)

SYSTEM: Safety Injection

19. Valve V-3480, V-3481, V-3651, and V-3652 (Con't)

Basis for Relief (Con't)

The Quench Tank is provided with QT level, pressure, and temperature measurement channels. On high QT level, pressure, or temperature, these instruments annunciate alarms in the control room.

Similarily, the Holdup Tank is provided with level measurement channels. On high level, these instruments would annuniate alarms to alert operating personnel.

Thus, any leakage past these valves would be detected by an increase in level in the associated collection tank Alternate Testing: Mone.

Any pressure increase in the piping down-stream of these valves associated with leakage past the valve would be limited by the relief valve located on the lower pressure side of the valve.

Any leakage past these valves would be detected by an increase in the level of the associated collection tank.

St. Lucie Uni t No.

~ ~ 1 Page 14 of 14 RELIEF REQUEST BASIS SYSTEM Safety Injection

20. Valve: MV-03-lA and MV-03-1B Category: '

Class: 2 Function: Provides for remote operation of valves that that provide for controlled warmup of Shutdown Cooling (SDC) System pumps, heat ex-changers, and associated piping.

Test Requirement: INT-3410 Basis for Relief". The failure of either of these valves in the open position, by testing during plant operation, would result in the diminished flow (due to re-cir'culation) from the Low-pressure Safety Injection System to the reactor, if required.

Alternate Testing: These valves will be tested during cold shutdowns.

l 0

St. Lucie Unit Bo. 1 Page 3 of '4 RELIEF REQUEST BAS1S SYSTEM: Containment= Spray

5. Ualve: U-07174 and U-07172 Category: C Class: 2 Function: Prevents reverse flow from the Refueling Water Tank (RWT) to the containment recirculation sump.

Test Requirement: IWV-3520 Basis for Relief: There are no provi si ons f or testing these check valves to Code requirements.

Alternate Testing: These check valves will be disassembled, during refueling shutdowns, over the Ten { 10) yehr Inservice Insepction Interval to inspect the valves'reedom of motion to open and closed positions.

Any problems found during the inspection of one check valve would be cause for inspection of the other check valve.

6. Valve: V-07256, V-07258, V-07269 and V-07270

'ategory: C Clas s: '2 Function: Provides for redundant flow paths from the Spray Additive System to the Containment Spray Pump suction header.

Test Requirement: IWV 3520 Ba'sis for Relief: Testing these valves, by placing the containment spray system in operation, would result in introducing sodium hydroxide into the containment spray system piping.

Testing these valves by connecting an external water source would result in the loss of ability to supply sodium hydroxide solution to the containment spray system, if required.

Alternate Testing: These valves will be tested in accordance with Technical Specification

4. 6. 2. 2. d.

e St. Lucie Uni t No. l Page 4 of 4 RELIEF REQUEST BASIS SYSTEM: Containment Spray

7. Valve: I-MV-07-3A and I-MV-07-3B Category: B Class: 2 Function: Provides redundant, diverse, and remote containment spray supply header isolation capability.

Test Requirement: INV-34l0 Basi s f or Relic f: The failure of either of these valves in the closed position, by testing during plant operation would result in the loss of one of the containment spray system flow paths.

Alternate Testing: These valve will be tested during cold shutdowns.

St. Lucie Unit No. 1 Page 1 of 1 RELIEF REQUEST BASIS SYSTEM: Hydrogen Sampling

1. Valve:

Category:

J FSE-27-1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and A

ll Class: 2 Function: Provides flow path from each of 7 separate sample points (FSE-27-1.<hru 7, located inside containment) to the hydrogen analyzer located outside containment and the return flow path to containment (FSE-27-8 thru 11).

Test Requirement: IWV-3410 Basis for Relief: These sel f-contained, completely enclosed solenoid valves have remote valve position indicators located in the control room. However, due to the sequential arrangement of the sample valve selector switch, accurate stroke time measurement is impractical.

Alternate Testing: Establishing a flow path, as shown by the valve position indicator lights in the control room, within S seconds or less will demonstrate that the s olenoi d valves function satisfactorily.

Further, during re fueling shutdowns, the valve disk position will be determined while performing the Appendix J, Type C, local leak rate tests.

St. Lucie Unit No. 1 Page 1 of 1 RELIEF REQUEST BASIS SYS TEM: Mi scellaneous Systems (Diesel Oil )

1. Valve: I-SE-17-lA and I-SE-17-1B Category: B Class: 3 Function: These valves function as level control valves=

for the associated Emergency Diesel-generator Diesel Oil Day Tank.

Test Requirement: IWV-3410 Basis for Relief: These self-contained, completely enclosed, solenoid valves have neither external nor remote valve position indicators.

Further, these valves are controlled by level in the Diesel Oil Day Tank and they are interlocked with the Diesel Oil Transfer Pumps.

Therefore, stroke-time measurements and valve position verification is impractical.

Alternate Testing: Establishing a flow path, as shown by an increase in level in the Diesel Oil Day Tank while exercising these valves quarterly, will demonstrate that the moving parts of the solenoid valve function satisfactorily.

f I

St. Lucie Unit No. 1 Page 1 of 2 RELIEF REQUEST BAS38 SYSTEM: Intake Cooling Water Valve: MV-21-2 and MV-21-3 Category: B Class: 3 Function: Provides flow path from the Intake Cooling Water System to the Turbine Cooling Water System.

Test Requirement IWV-3410 Basis for Relief: These valves cannot be tested during plant operation because closing either of these valves would result in the loss of cooling capability to the associated Turbine Cooling Water System heat exchanger. This would cause overheating of secondary plant equipment whi ch could place the plant i n an unsa fe mode o f oper at ion.

Alternate Testing: These valves will be tested during cold shutdowns.

2. Valve: I-FCV-21-3A and I-FCV-21-3B Category: B Class: 3 Function: Provides redundant flow paths from the Intake Cooling Water System to the Intake Cooling Water Pump shaft bearings.

Test Requirement: IWV-3410 Basis for Relief: These valves cannot. be tested during plant operation because closing either of these valves would result in the loss of cooling water to the Intake Cooling Water Pump shaft bearings. This could cause damage to the pumps..

Alternate Testing: These valves will be tested during cold shutdowns.

St. Lucie Unit No. 1 Page 2 of 2 RELIEF REQUEST BASIS SYSTEM: Intake Cooling Water

3. Valve: I-V-21015 and I-V-21017 Category: C Class: 3 Bznction: Prevents reverse flow from the Intake Cooling Water System to the Domestic Water Supply System.

Test Requirement: IWV-3520 Basis for Relief: These c heck. valves c annot be te s ted during plant operation because the Domestic Water (City Water Storage Tanks) System does not develop sufficient discharge head to overcome the discharge head of the Intake Cooling Water Pumps.

Alternate Testing: These valves will be exercised during cold shutdowns.

4. Valve: TCV-14-4A and TCV-14-4B Category: B Class:

Temperature 3'unction:

control valves for the associated Intake Cooling Water System heat. exchanger.

Te st Requirement: IWV-3410 Basis for Relief: These valves are temperature control valves. They do not perform a safety-related functi on to ei ther sa fely shutdown the reactor or mitigate the consequences of an accident.

Alternate Testing: None.

These valves are in continuous service during plant operation and during unit shutdowns. The primary function of these modulating control valves is to control the temperature of the Component Cooling Water System. Any malfunctions of either of these temperature control valves would be noted by abnormal operating conditions.

St. Lucie Unit No. 1 Page 1 of GENERIC RELIEF REQUEST BASIS YSTEM: Various Valve: Various Category: Various Class: Various Function: Various Test Requirement: IWV-341 7, I WV-3 427, IWV-3523, and IWP-3230 Basis for Relief: Paragraph Nos. IWV-3417, IWV-3427, IWV-3523, and IWP-3230 prescribe actions to be taken, limiting time periods for actions to be completed, or limiting conditions for operability if certain conditions are not met.

This could be in conflict with the Plant Technical Specifications.

In addition, certain CODE definitions or terminology may be in conflict with the Plant Technical S peci ficati ons.

Alternate Corrective Action Requirements: Correcti ve Ac ti on Where a valve or pump fails to meet the requirements of the Program and/or the reference CODE, the condition(s) shall be reviewed by the Facility Review Group (FRG) for disposition and determination of whether it involves an unreviewed safety question prior to commencing with plant startup or continuing with pIant operation.'othing in Section XI of the ASME Boiler and Pressure Vessel Code shall be construed as superseding the requirements of the Plant Technical Specifications.

FLORIDA POWER 8, LIGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI IND VALVE REHMKS NUMBER CL. CAT. PAS POS. URE POS. PER. TESTS NO. CUORD MODE aND.

V-1405 2-1/2 GATE MO B A NO FAI YES EF-3 H-8 EST-3 V-1402 2-1/2 GLOBE SO 1 B A NC FC YES EF-9 1 G-8 EST-3 V-1403 2-1/2 GATE MO B A NO FAI YES EF-3 G-8.

EST-3 V-1404 2-1/2 GLOBE SO 1 B A NC FC YES EF-9 1 H-8 EST-3 V-1441 GLOBE SO 2 B A LC FC YES EF-8 D-5 EST-2 V-1442 GLOBE SO 2 B A LC FC YES EF-8 D-5 EST-2 V-1443 GLOBE SO 2 B A LC YES EF-8 H-6 EST-2 V-1444 GLOBE SO 2 B A LC FC YES EF-8 H-6 EST-2 V-1445 GLOBE SO 2 B A LC FC YES EF-8 F-8 EST-2 V-1446 GLOBE SO 2 B A LC FC YES EF-8 F-8 EST-2 V-1449 GLOBE SO 2 B A LC FC YES EF-8 F-8 EST-2 rrrrcM r sr it REACTOR COOLANT SYSTEM ST. LUCIE UNIT NO. 1 TABLE II TO CODE AND rive.c 8770-G-078 SHEET 110 REV. 4 VALVE TEST PROGRAM RELIEF REQUEST Fomerly E-19367-210-110 REV. 1

Jf k

y

~ J

FLORIDA P 8 LIGIIT COMPANY VALVE SIZE TYPE ACTU. CODE CODE Acr/ NORM. PAIL- I<E>I ~ TEST ISI BI~IKS NUMBER CL. CAT. PAS POS. URE POS; PER. TESTS NODE IND.

V-2521 1 Globe DO B A NO FC Yes 3 EF-7 H-2 3 EST-3 V-2345 2 S/R S/A C A NC No TF-1 F-8 0 YS lC%i PllOOAASA Chemical Volume and Control ST. LUCIE UNIT NO. 1 TABLE I C HAlS S 8770-G-078 Sheet 120 Rev. 2 TESTS TO CODE VALVE TES 'ROGRAM (Fomerly E-19367-210-120 Rev. ll)

4 FLORIDA POWER 8, LIGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI VALVE NUMBER CL. CAT. PAS POS. URE POS ~ PER. TESTS COOBD MODE aND.

SE-02-01 2 Globe SO B A NO FO Yes EF-8 A-8 EST-3 SE-02-02 2 Globe SO B' NO FO Yes EF-8 B-8 EST-3 SE-02-03 2 Globe SO B A NO FO Yes EF-8 13 C-8 EST-3 SE-02-04 2 Globe SO B A NO FO Yes EF-8 13 C-8 EST-3 V-2435 2 Check S/A A NO No EF-2 14 A-7 V-2515 2 Globe DO A A NO FC Yes EF-8 D-8 EST-1 V-2516 2 Globe DO A A NO FC Yes EF-8 D-7 EST-1 V-2430 2 Check S/A C A NO No 12 B-5

',;,';;" Chemical- Volume and Control TITI 4 ST ~ LUCIE UNIT NO 1 TABLE II TO CODE AND CH 8770-G-078 Sheet 120 Rev. 2 VALVE TEST PROGRAM RELIEF REQUEST (Fomerly E-19367-210-120 Rev. ll)

~ I wk Jj

FLORIDA POKIER 8, l.lGllT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NOAH. PAIL- REl'l. TEST ISI NUHBER CATo PAS POS. URE POS. PER. TESTS MODE IND.

V-2125 1/2 S/R C A NC No TF-1 A<<4 V-2132 1/2 S/R S/A C A NC No TF-1 B-7 V-2133 1/2 S/R S/A C A NC No TF-1 B-6

'V-2141 1/2 S/R S/A C A NC No C-5 V-2149 1/2 S/R S/A C A NC No TF-1 C-4 V-2150 1/2 S/R S/A C A NC No TF-1 '-'5 V-2157 1/2 S/R S/A C A NC No TF-1 C-4 V-2160 1/2 S/R S/A C A NC No TF-1 B-4 V-2171 1/2 S/R S/A C A NC No TF-1 . B-3 V-2173 1/2 S/R S/A C A NC No TF-1 B-2 V-2311 -1/2 S/R S/A C A NC 'No TF-1 E 4 V-2426 1/2 S/R S/A C A NC No TF-1 C-4 V-2436 1/2 S/R S/A C A NC TF-1 B-4 V-2446 1/2 S/R S/A C A NC No E-6 V-2447 1/2 S/R S/A C A NC No TF-1 E-4 PllOGAA~

Chemical Volume and Control, TIILE ST. LUCIE UNIT NO. 1 TABLE I 8770-G-078 Sheet 121 REV. TESTS TO CODE (Fomerly E-19367-210-121) VALVE TEST PROGRAM

~ '

FLORIDA POWER 8, l.lGI)T COMPANY VALVE SIKE TYPE ACTU. CODE CODE AC r/ NORM. PAT L- REM. TEST ISI NUMBER CL. CAT PAS POS. URE POS. PER. TESTS MODE IND.

V-2115 4 S/R S/A 2 C No F=7 V- 2315 1/2 S/R S/A 2 C NC No TF-1 H-3 V-2318 1/2 S/R S/A 2 C NC No TF-1 . G 3 V-2321 1/2 S/R S/A 2 C NC No TF-1 F-3 V-2324 1-1/2 S/R S/A 2 C NC No TF-1 F-2 V-2325 1-1/2 S/R S/A 2 C NC No TF-1 G-2 V-2326 -1/2 S/R S/A 2 C NC No TF-1 H-2 lT1 tt4 PllOGIlAH Chemical Volume and Control YllLE ST. LUCIE UNIT NO. 1 TABLE I 8770-G-078 Sheet 121 REV. 5 TESTS TO CODE VALVE TEST PROGRAM (Foment 1 v F,-19367-210-121)

FLORIDA POWER d. LIGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI RRD VALVE RENMKS NUMBER CL. CAT. PAS POS. URE POS. PER. TESTS NO. COORD MODE aND.

FCV-2161 Globe DO A NO FC Yes 3 EF-7 B-4 EST-1 SE-01-01 3/4 Globe A NO FC Yes 2 EF-8 H-6 2 EST-1 1 SLT-1 V-2505 3/4 Globe DO A NO FC Yes 2 EF-8 H-6.

2 EST-1 1 SLT-1 V-2501 Gate MO A NO FAI Yes 2 EF-2 5 E-4 2 EST-3 V-2514 Gate- MO A NC FAI Yes EF-3 C-4 EST-3 V-2504 Gate MO A NC FAI Yes EF-2 E-5 EST-3 V-2191 Check S/A A NC No EF-3 E-6 v-2177 Check S/A A NC No EF-3 C-4 V-2190 Check S/A A NC No D-6 V-2118 Check S/A A NC No EF-3 15 F-7 V-2526 Check S/A A NC No 16 F-7

',"'"," Chemical Volume and Control,',";,;'ST. LUCIE UNIT NO. 1 ThDLE II TO CODE AND f$ 'f gg 8770-G-078 Sheet 1 2 1 REV ~ 5 VALVE TEST PROGRAM RELIEF REQUEST

I FLORIDA POYIER 8, LIGIIT COMPANY VALVE $ ?KE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REI'I. TEST ?S?

NUMBER CL. CAT IPAS POS. URE POS. PER. TESTS MODE ?ND.

HCV-3637 2 Globe MO A NC FAI Yes 3 EF-1 C-7 3 EST-2 HCV-3647 2 Globe "'O A NC FAI Yes 3 EF-1 A-7 3 EST-2

""'afety Injection STSSCV CHARS S stem PllO Cn ASS ST ~ LUCIE UNIT NO ~ TABLE I vivs.c 8770-G .078 Sheet 130 Rev. 3 VALVE TES " PROGRAM TESTS TO CODE (Formerly E-19367-210-130 Rev. 12)

~ 'j I

C

FLORIDA P 8 LIGIIT COMPANY VALVE NUMBER SIZE TYPE ACTU. CODE CODE Acr/ HORN.

C'L. CAT.,PAS POS.

I'I L- REH.

POS.

TEST ISI TESTS URE PER.

NODE IND.

V-3407 S/R S/A C A No TF-1 H-3 V-3412 1/2 S/R S/K C A NC No TF-1 B-3 V-3417 S/R S/A C A NC TF-1 C-3 V-3430 1/2 S/R S/A C A No TF-1. D-7 V-3431 1/2 S/R S/A C A NC No TF-1 D-6 V-3439 S/R S/A C A NC No TF-1 D-3 SYS f C% GAAM Safety Injection System vsiia ST. LUCIE UNIT NO. 1 TABLE I CHAL 'I TESTS TO CODE 8770 G-078 Sheet 130 Rev.3 VALVE TES " PROGRAM (Fomerly E-19367-210-130 Rev. 12 )

0 P%

FLORl .>'ltiR L LIG!)T COMPAHY Vh? VE SIKE TYPP ACTU, CODE CODE hCT/ NORM, FAXI' RED. TEST RRB NUHDER CL ~ CAT PAS POS ~ URE POS ~ PERi'SX TESTS, NO. REMARKS NODE IND V-3405 S/CHK S/A 2 C A NC No EF-2 V-3414 S/CHK S/A 2 C. NC No EF-2 V-3427 S/CHK '/A C' NC No EF-2 1 FCV-3306 10 Globe PO 2 B LO FO Yes OC-1 0

'V HCV-3657 12 Globe DO LC FC Yes 0 SEASICK 1'AOOllhll v~vi~ Safety Injection System VALVE TEST PROGRAM T5 GSHE REQUEST AND'ELIEF E-19367-210-130 Rev. 12 w ~eAawaeo~ Wt~

FLOn 0.)'(ER 5 LIGIIT COMPAlhY VALVE SIKE TYPE ACTUe CODE CODE Acr/ NORM. RBH TEST RRB NUHQBR I CXte CATe PAS POS. UM POS e PER('SX TESTS ND. REMARI(S MODE IND.

V-3106 10 Check S/A A NC No EF-1 ~ 2 V-3107 10 Check S/A A NC No 3 EF-1 V-3401 6 Check C NC No EF-1 S/A'/A V-3410 6 Check A NC No 3 EF-1 V-07000 14 Check S/A 2 A NC No EF-1 V-07001 14 . Check S/A A NC No EF 1 . 4 V-3659 3 Gate MO LO FA'I Yes 2 EF-2 8 *< 90 sec.

2 EST

• 8 V-3660 3 Gate MO B'.: A LO FAX Yes 2 EF-2 *~ 90 sec.

2 EST-*

V-3656 6 Gate MO P LO FAI Yes OC-1 0 V-3654 6 Gate MO LO FAI Yes 0 V-3653 4 - Gate MO P LO FAI, Yes OC-1 0 V-3655 4 Gate MO P LC FAI Yes OC-1 0 seS IC~

Safety Injection System PllOOllhll VALVE TEST PROGRAM TABLE II TO CODE aND E-19367-210-130 Rev. 12 RELIEF REQUEST l ~

I

~' ~ ~

1*

0

FLORIDA POWER L LIGHT COMPAHY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI IND VALVE NUMBER CL. CAT. PAS POS. URE POS ~ PER, TESTS NO. COOBD MODE a ND.

V-3463 2 Globe Man P LC FAI No EF

• 10 H-2 Exercise SLT-1 Manual Valve V-07009 Globe Man P LC FAI No EF-* 10 H-2 at SLT-1 Refueling Shutdowns V-03920 2 Gate Man P NC FAI No EF-* 10 H-3 SYST CI4 Safet In'ection S stem ST. LUCIE UNIT NO. 1 TABLE II TO CODE AND CH 8770-G-078 Sheet 130 Rev. 2 VALVE TEST PROGRAM RELIEF REQUEST (Fomerly E-19367-210-130 Rev. 12)

FLORIDA POWER 8, LlGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI INO BEMmS NUMBER CL. CAT. PAS POS. URE POS. PER, TESTS VALVL'O.

CX3OBD MODE sHD.

V-3206 10 Gate MO B A ,LO FAI Yes EF-2 13 F-4 EST-9 V-3207 10 Gate MO B . A LO FAI Yes EF-2 13 E-8 EST-9 V-3432 14 Gate MO B A LO FAI Yes EF-2 EST-3 V-3444 14 Gate MO B LO FAI Yes EF-2 14 F-8 EST-3 V-3452 12 Gate MO B A LC FAI Yes EF-2 15 G-8 EST-9 V-3453 12 Gate MO B A LC FAI Yes EF-2 15 G-8 EST-9 V-3456 10 Gate MO B A LC FAI Yes EF-2 15 G-3 EST-3 V-3457 10 Gate MO B A LC FAI Yes EF-2 15 G-3 EST-3 MV-0'3-2 10 Globe MO B A FAI EF-2 LO Yes 16 E-4 EST-3 svssass Safety Injection System ST. LUCIE UNIT NO. 1 'ghBLE II TO CODE AND 8770-G-078 Sheet 13:0 Rev. 2 VALVE TEST PROGRAM RELIEF REQUEST (Formerly E-19367-210-130)

FLORIDA POWER 8 l.lGI)T COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORN. FAIL- RHl'1 . TEST ISI NUHBER CL ~ ChTe PAS POS. URH POS. PER, TESTS HODH IND.

V-3211 1 S/R S/A 2 C NC No TF-1 H-5 V-3221 S/R S/A 2 C A NC No TF-1 H-2 V-3231 1 S/R S/A 2 C A NC No TF-1 D-5 V-3241 1 S/R S/A 2 C A NC No TF-1 ~ D-2 V-3468 2 S/R S/A 2 C A NC No TF-1 D-6 V-3469 1 S/R S/A C A NC. No TF-1 D-4 V-3482 1 S/R S/A 2 C A NC No TF-1 E-5 V-3483 S/R S/A 2 C NC No TF-1

',;;,","Safety Injection System P I'I 0 C ll A N TI1LC ST. LUCIE UNIT NO. 1 TABLE I 8770-G-078 Sheet 131 REV. 1 VALVE TES " PROGRAM TESTS TO CODE (Fomerly E-19367-210-131)

IL FLORIDA POWER 5, LIGIIT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM.

NUMBER TEST ISI lUU3 VALVE IKMMRS CL. CAT. PAS POS. URE POS. PER. TESTS NO. COOHD MODE <ND.

V-3113 Check S/A 1 C A NC No EF-3 5& G-7 17 V-3123 Check S/A 1 C A NC No EF-3 5& F-7 17 V-3133 Check S/A 1 C A NC No EF-3 '5& D-7 17 V-3143 Check S/A 1 C A NC No EF-3 5& B-7 17 V-3114 Check S/A C NC No EF-2 6& H-7 17 V-3124 Check S/A 1 C A NC No EF-2 6& E-7 17 V-3134 Check S/A 1 C A NC No EF-2 6& E-7 17 V-3144 Check S/A 1 C A NC No EF-2 6& C-7 17 V-3217 12 Check S/A 1 C A NC No EF-2 7&

F-5'-2 17 V-3227 12 Check S/A 1 C A NC No EF-2 7&

17 V-3237 12 Check S/A 1 C A NC No EF-2 7& B-5 17 V-3247 12 Check S/A 1 C A NC No EF-2 7& B-2 17 5YSTEI4 aaocnAM CHAAV Safet In'ection ST LUCIE UNIT NO 1

'I'ADIT TO CODE AND II 8770-G-078 Sheet 131 Rev. 3 VALVE TEST PROGRAM RELIEF REQUEST Formerly E-19367-210-131 Rev. 12

FLORIDA POWER L l.lGIIT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI NUMBER 1NI3 VALVL CL. CAT. PAS POS. URE POS. PER. TESTS NO. CQOBD MODE c ND.

V-3215 12 Check S/A C A NC No EF-3 9a F-5 18 V-3225 12 Check S/A C.ANC No EF-3 96 C-3 18 V-3235 12 Check S/A C A NC No EF-3 9a F-5 18 V-3245 12 Check S/A C A NC No EF.-3 9a C-3 18 SYSTEM Safet In'ection ST. LUCIE UNIT NO. 1 TA13IZ II TO CODE AND

""* 8770-G-078 g H A A 'f Sheet 131 Rev. 3 VALVE TEST PROGRAM RELIEF REQUEST Formerly E-19367-210-131 Rey. 12

f, I

i

'r

je FLORIDA POWER 6, LIGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAXL- REM. TEST ISI NUMBER RRI3 VALVE CL. CAT. PAS POS. URE'ODE POS. PER, TESTS NO. COOBD i ND.

HCV-3618 1 Globe DO 1 NC FC Yes EF-8 F-5 EST-2 HCV-3628 1 Globe DO 1 B NC FC Yes EF-8 F-3 EST-2 HCV-3638 1 Globe . DO 1 B NC FC Yes EF-8 B-5.

EST-2 HCV-3648 1 Globe DO 1 B 'NC FC Yes 2 EF-8 B-3 2 EST-2

.V-3480 10 Gate MO 1 B LC FAI Yes EF-2 12@ E-5 EST-3 19 V-3481 10 Gate MO 1 B LC FAI Yes EF-2 12@ E-5 EST-3 19 V-3651 10 Gate MO 1 B LC FAI Yes EF-2 12a D-4 EST-3 19 V-3652 10 Gate MO 1 B LC FAI Yes 2 EF-2 12'9 D-4 2 EST-3 V-3614 12 Gate MO LO FAI Yes OC-1 .0 F-5 V-3624 12 Gate MO 1 B LO FAI Yes OC-1 F-2 V-3634 12 Gate MO LO FAI Yes OC-1 B-5 V-3644 12 Gate MO 1 B LO FAI Yes OC-1 B-2

"'"'afety SYSTEI4 CHARY Injection ST. LUCIE UNIT NO. 1 TAI3lk.

TO CODE AND II v<v<c 8770 G-078 Sheet 131 Rev. 3 VALVE TEST PROGRAM RELIEF REQUEST Formerly E-19367-210-131 Rev. 12

N FLORIDA POWER 6, I IGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI RRD VALVE BEHAIKS NUMBER CL. CAT. PAS POS. URE POS. PER, TESTS NO. COORD MODE PHD.

MV-03-1A 2 Globe MO A LC FAI Yes EF-2 20 E-7 EST-7 MV-03-1B 2 Globe MO A LC FAI Yes EF-2 20 D-7 EST-7 SYSTEM Safety Injection System ST. LUCIE UNIT NO. 1 TABLE II TO CODE AND CH Rf 8770-G-078 Sheet 131 Rev. 3 VALVE TEST PROGRAM RELIEF REQUEST (Formerly E-19367-210-131)

FLORIDA POWER L LIGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI VALVE NUMBER CL. CAT. PAS POS. URE POS. PER. TESTS COOBD MODE aND.

MV-07-3A. 12 Gate MO B A LO FAI Yes 2 EF-2 G-13

2. EST-9 MV-07-3B 12 Gate MO B A LO FAI Yes 2 EF-2 H-13 2 EST-9 SYSTCN Containment S ra S stem ST. LUCIE UNIT NO. 1 TABLE II TO CODE AND CH A 8770-G-088 Rev. 14 VALVE TEST PROGRAM RELIEF REQUEST

~ ~ ~

~ ~

i ~ ~

t:

I.'

FLORIDA POWER 8, LIG)IT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI IND VALVE RENhIKS NUMBER CL. CAT. PAS POS. URE POS. PER. TESTS NO. CCORD MODE HAND.

V-07256 2 Check S/A C A NC No EF-3* * = Refer to V-07258 2 Check S/A 2 C A NC No EF-3* J-2 RRB No. 6 V-07269 2 Check S/A 2 C A NC No EF-3* J-2 V-07210 2 Check S/A C A NC No EF-3* J-2 SYSTCN Containment Spray System ST. LUCIE UNIT NO. 1 ThBLE II TO CODE AND CH R 8770-G-088 Rev. 12 VALVE TEST PROGRAM RELIEF REQUEST

t L

I>>

FLORIDA POYIER 8, l.lGIIT COMPANY VALVE SIKE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI NUMBER CL. CAT PAS POS. URE POS ~ PER, TESTS NODH IND.

V-21162 30 Check S/A 3 C A NO No EF-1 H-4 V-21205 30 Check S/A 3 C A NO No EF-1 H-5 V-21208 30 Check S/A 3 C A NO No EF-1 H-7

%TSAR

~""'irc a C%

Intake Cooling Water P I'I 0 C 8 A M LUCIE UNIT NO 1 TABLE I C ll4 II 'f vivia 8770-G-082 Sheet 1 Rev. 16 VALVE TEST PROGRAM TESTS TO CODE

FLORIDA POWER L LIGHT COMPANY VALVE SIKE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI RRI3 VALVE NUMBER CL. CAT. PAS POS. URE POS. PER. TESTS NO. KGBD MODE HAND.

MV-21-2 24 Butfy MO 3 B A NO FAI Yes 2 EF-2 1 F-5 2 EST-4 MV-21-3 24 Butfy MO 3 B . A NO FAI Yes 2 EF-2 1 F-4 2 EST-4 TCV-14-4A 30 Butfy PO B A NO FO No 4 B-3 TCV-14-4B 30 Butfy PO A NO FO No 4 B-4 5YSTCM Circ. & Intake Coolin Water PROCllAM

. ST. LUCIE UNIT NO. 1 ThI3LH II TO CODE AND

~

CH Af c

877 p G p82 Sheet 1 Re> 16 VALVE TEST RELIEF REQUEST

FLORIDA POWER 8, LIGHT COMPANY VALVE SIZE TYPE ACTU. CODE CODE ACT/ NORM. FAIL- REM. TEST ISI I&3 BEMAIES NUMBER CL. CAT. PAS POS. URE POS. PER, TESTS NO.

VALVL'OOBD MODE iND.

I-ECV-21-3A 2 Globe PO NO FC Yes EF-8 I-4 EST-2 I-FCV-21-3B 2 Globe PO NO FC Yes 2 EF-8 I-4 2 EST-2 I-V-21015 2 Check S/A NO No EF-2 3 J-4 I-V-21017

'-4 2 Check S/A NO No EF-2 3 Intake Cooling Water & Lube W MP ST. LUCIE UNIT NO. 1 TABLE TO CODE AND II TITLC VALVE TEST PROGRAM RELIEF REQUEST 8770-G-082 Sheet 2 Rev. 1

C' J ~ ~

,1