ML17349A218

Rev 4 to Second 10-Yr Inservice Insp Interval - Inservice Testing Program for Pumps & Valves.

ML17349A218
Person / Time
Site:	Turkey Point
Issue date:	04/14/1992
From:	FLORIDA POWER & LIGHT CO.
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ML17349A217	List: ML17349A216 ML17349A218
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NUDOCS 9205200059
Download: ML17349A218 (298)

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Revision 4 04/14/92 FLORXDA POWER and LXGHT COMPANY TURKEY POINT NUCLEAR POWER PLANT UNXT NOS. 364 P.O. BOX 3088 FLORIDA CITY, FLORIDA 33034 SECOND TEN-YEAR XNSERVICE XNSPECTION INTERVAL INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES NRC DOCKET NUMBERS: 50-250 50-251 COMMERCIAL SERVICE DATE: PTN-3 DECEMBER 14 1972 COMMERCIAL SERVXCE DATE: PTN-4 SEPTEMBER 14 1973 TURKEY POINT PLANT REVX VS AND APPROVALS:

PREPARED BY: DATE:

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PT S PERFORMANCE SUPERVXSOR APPROVED BY: QF DATE:

PTN HNXCAL DEPT. MANAGER

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Revision 4 04/1 4/92 LIST OF EFFECTIVE PAGES Page Revision I 04/14/92 II 04/1 4/92 III 04/1 4/92 IV 04/1 4/92 1 04/1 4/92 21 04/1 4/92 41 04/14/92 61 04/14/92 81 04/1 4/92 2 04/1 4/92 22 04/14/92 42 04/14/92 62 04/14/92 3 04/14/92 23 04/1 4/92 43 04/14/92 63 04/14/92 4 04/1 4/92 24 04/14/92 44 04/14/92 64 04/14/92 5 04/14/92 25 04/14/92 45 04/14/92 65 04/14/92 6 04/14/92 26 04/14/92 46 04/14/92 66 04/14/92 7 04/14/92 27 04/14/92 47 04/14/92 67 04/14/92 8 04/14/92 28 04/14/92 48 04/14/92 68 04/14/92 9 04/1 4/92 29 04/1 4/92 49 04/14/92 69 04/14/92 10 04/14/92 30 04/14/92 50 04/14/92 70 04/14/92 11 04/1 4/92 31 04/14/92 51 04/14/92 71 04/1 4/92 12 04/14/92 32 04/14/92 52 04/14/92 72 04/14/92 13 04/1 4/92 33 04/14/92 53 04/14/92 73 04/14/92 14 04/1 4/92 34 04/14/92 54 04/14/92 74 04/14/92 15 04/1 4/92 35 04/14/92 55 04/14/92 75 04/14/92 16 04/14/92 36 04/14/92 56 04/14/92 76 04/14/92 17 04/14/92 37 04/14/92 57 04/14/92 77 04/14/92 18 04/14/92 38 04/14/92 58 04/14/92 78 04/14/92 19 04/1 4/92 39 04/14/92 59 04/14/92 79 04/1 4/92 20 04/1 4/92 40 04/14/92 60 04/14/92 80 04/14/92 Appendix A: Pump Program Tables Unit 3 04/14/92 04/1 4/92 Appendix B: Pump Program Tables Unit 4 04/14/92 04/1 4/92

0 Revision 4 04/14/92 LIST OF EFFECTIVE PAGES Appendix C: Valve Program Tables Unit 3 Page Revision 1 04/14/92 11 04/14/92 21 04/1 4/92 31 04/14/92 41 04/1 4/92 2 04/14/92 12 04/14/92 22 04/14/92 32 04/14/92 42 04/14/92 3 04/14/92 13 04/14/92 23 04/14/92 33 04/14/92 43 04/1 4/92 4 04/1 4/92 14 04/14/92 24 04/14/92 34 04/14/92 44 04/14/92 5 04/1 4/92 15 04/14/92 25 04/1 4/92 35 04/14/92 6 04/1 4/92 16 04/14/92 26 04/1 4/92 36 04/14/92 7 04/14/92 17 04/14/92 27 04/14/92 37 04/14/92 8 04/14/92 1 8 04/14/92 28 04/14/92 38 04/14/92 9 04/14/92 19 04/14/92 29 04/14/92 39 04/14/92 10 04/14/92 20 04/14/92 30 04/14/92 40 04/14/92 Appendix D: Valve Program Tables Unit 4 1 04/14/92 11 04/14/92 21 04/14/92 31 04/14/92 41 04/14/92 2 04/1'4/92 12 04/14/92 22 04/14/92 32 04/14/92 42 04/14/92 3 04/14/92 13 04/14/92 23 04/14/92 33 04/14/92 4 04/14/92 14 04/14/92 24 04/1 4/92 34 04/14/92 5 04/14/92 15 04/14/92 25 04/1 4/92 35 04/14/92 6 04/14/92 16 04/14/92 26 04/1 4/92 36 04/14/92 7 04/14/92 17 04/14/92 27 04/1 4/92 37 04/14/92 8 04/1 4/92 18 04/14/92 28 04/14/92 38 04/14/92 9 04/14/92 19 04/14/92 29 04/14/92 39 04/14/92 10 04/14/92 20 04/14/92 30 04/14/92 40 04/14/92

Revision 4 04/14/92 Table of Contents Pacae List of Effective Table of Contents Pages i ill Record of Revisions iv 1.0 Introduction 2.0 Applicable Documents 3.0 Inservice Testing Program For Pumps 3 ' Code Compliance 3 ' Allowable Ranges of Test Quantities 3.3 Testing Intervals 3.4 Legend for Pump Tables Relief Requests for Pump Testing Inservice Testing Program For Valves 22 4.1 Code Compliance 22 4.2 Stroke Time Acceptance Criteria 22 4.3 Check Valve Testing 22 4.4 Testing Intervals 22 4.5 Legend for Valve Tables 22 4.6 Cold Shutdown Testing 25 4.7 Relief Requests For Valve Testing 34 A endices A Pump Program Tables Unit 3 B Pump Program Tables Unit 4 C Valve Program Tables Unit 3 D Valve Program Tables Unit 4

Revision 4 04/14/92 RECORD OF REVISIONS REVISION DESCRIPTION OF REVISION DATE NUMBER REASON FOR THE CHANGE REVISED ORIGINAL ISSUE OF PTN 3/4 IST 06-01-85 PUMP AND VALVE PROGRAM TURKEY POINT PLANT, UNIT 3/4 12-12-88 PUMP AND VALVE TESTING PROGRAM GENERAL REVISION RESPONSE TO 09-19-89 NRC GENERIC LTR 89-04 GENERAL REVISION RESPONSE TO 12-26-91 H.N. BERKOW (NRC) LETTER TO J.H. GOLDBERG DATED AUGUST 20, 1990.

LIMITED REVISION REVISED TEST 01-30-92 FREQUENCY OF SELECT COMPONENTS GENERAL REVISION RESPONSE TO 04-14-92 H.N. BERKOW (NRC) LETTER TO J.H. GOLDBERG DATED JANUARY 23, 1992.

Revision 4 04/14/92 INSERVICE TESTING (IST) PROGRAM PLAN TURKEY POINT UNITS 364

1.0 INTRODUCTION

Revision 4 of the Turkey Point (Units 3&4) ASME Inservice Inspection (IST) Program will be in effect through the end of the second 120-month (10-year) interval unless changed and reissued for reasons other than the routine update required at. the start of the third interval per 10 CFR 50.55a(g). The second inspection intervals are defined as follows:

Beceins Ends Unit 3 February 22, 1984 February 21, 1994 Unit 4 April 15, 1984 April 14, 1994 This document outlines the IST Program for Turkey Point Plant, Units 3 and 4, based on the requirements of Section XI of the ASME Boiler and Pressure Vessel Code, 1980 Edition, including all addenda thereto through Winter, 1981 (the Code). References in this document to "IWP" or "IWV" correspond to Subsections IWP and IWV, respectively, of the ASME Section XI, 1980 Edition (Winter 81), unless otherwise noted.

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

Revision 4 04/14/92 2.0 APPLICABLE DOCUMENTS This Program Plan was developed per the requirements and guidance provided by the following documents:

2.1 Title 10, Code of Federal Regulations, Part 50 2.2 NRC Regulatory Guides Division 1 2.3 Standard Review Plan 3.9.6, "Inservice Testing of Pumps and Valves 2.4 Final Safety Analysis Report, Turkey Point Units 3 & 4 2.5 Turkey Point Plant Unit, 3 Technical Specifications 2.6 Turkey Point Plant Unit 4 Technical Specifications 2.7 ASME Boiler and Pressure Vessel Code,Section XI, 1980 Edition and Addenda through Winter, 1981 2.8 NRC Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs".

Revision 4 04/14/92 3.0 INSERVICE TESTING PROGRAM FOR PUMPS 3.1 Code Compliance This IST Program for pumps meets the requirements of Subsection IWP of the Code and any interpretations or additional requirements imposed by Reference 2.8.

Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant, to the requirements of 10 CFR 50.55a(g)(iii) and Reference 2.8.

3.2 Allowable Ranges of Test Quantities The allowable ranges for test parameters as specified in Table IWP-3100-2 will be used for all measurements of pressure, flow, and vibrations except as provided for in specific relief requests. In some cases the performance of a pump may be adequate to fulfill its safety function even though there may be a value of an operating parameter that falls outside the allowable ranges as set forth in Table IWP-3100-2. Should such a situation arise, an expanded allowable may be determined, on a case-by-case basis, in accordance with IWP-3210 and ASME Code Interpretation XI-1-79-19.

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

Revision 4 04/14/92 3.4 Pump Program Table Appendices A and B list those to pumps included in the IST to be measured Program with references parameters and applicable requests for relief. The legend for the valve tables is provided in Table 3.0-1.

Table 3.0-1: LEGEND FOR PUMP TABLES 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 where there is a deviation regarding the measurement or analysis of a parameter.

Revision 4 04/14/92 3.5 Relief Requests for Pump Testing Relief requests PR-1 through PR-13 are initiated per 10CFR50.55a where appropriate.

Revision 4 04/14/92 RELIEF REQUEST NO. PR-1 COMPONENTS:

Boric Acid Transfer Pumps *-P203 AGB SECTION XI RE UIREMENT:

Flow rate shall be measured using a rate or quantity meter installed in the pump test circuit. (IWP-4600)

An inservice test shall be run on each pump nominally every 3 months during normal plant operation. (IWP-3400)

BASIS FOR RELIEF The normal test loops for these pumps consist of fixed resistance circuits sized to limit flow but with no flow measuring devices installed. Since the system resistance is fixed and can be assumed to be a constant, pump degradation can be monitored by comparing successive measurements of pump differential pressure.

A test circuit is available in which pump flowrate can be measured however it requires injection of highly concentrated boric acid solution into the reactor coolant system. During plant operation, this is not practical since it would upset the reactor coolant boric acid balance and adversely effect reactor power and create a plant power transient. If injection were to be performed during cold shutdown periods (other than refueling) the result would be excessive boration of the RCS and associated potential difficulties during the subsequent plant startup.

ALTERNATE TESTING During quarterly testing of these pumps, differential pressure and vibration measurements will be taken and evaluated in accordance with IWP-3100. At. each reactor refueling these pumps will be tested and all appropriate measurements taken in accordance with IWP-3300. This satisfies the requirements of Reference 2.8, Position 9.

Revision 4 04/14/92 RELIEF REQUEST NO. PR-2 WITHDRAWN

Revision 4 04/14/92 RELIEF REQUEST NO. PR-3 COMPONENTS:

Boric Acid Transfer Pumps *-P203 A&B Diesel Fuel Oil Transfer Pumps 3-P10 AGB SECTION XI RE UIREMENTS:

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 installations do 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 calculation using the height of liquid in the boric acid and diesel oil storage 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.

Note: For the diesel fuel oil pumps this only applies to the suction pressure measured prior to pump start. During pump operation the solenoid-operated suction valves leading from the fuel oil storage tanks are open and representative suction pressure measurements can be made using installed pump suction pressure gauges.

Revision 4 04/14/92 RELIEF REQUEST NO. PR-3 (cont.)

ALTERNATE TESTING:

Boric Acid Transfer Pump suction pressures will be calculated based on the height of liquid in the associated tanks once during each inservice test. Subsequently, these calculated values will be used to determine pump differential pressures used for the evaluation of pump parameters.

Unit 3 EDG Fuel Oil Transfer Pump suction pressures will be calculated prior to pump start, based on the height of liquid in the fuel oil storage tank.

Revision 4 04/14/92 RELIEF REQUEST NO. PR-4 COMPONENTS:

All centrifugal pumps in the Program SECTION XI RE UIREMENT:

The temperature of all centrifugal pump bearings outside the main flowpath and of the main shaft bearings of reciprocating pumps shall be measured at points selected to 1 be responsive to changes in the temperature of the bearings.

(IWP-3300, 4310)

BASIS FOR RELIEF:

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

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

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

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

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

ALTERNATE TESTING:

None 10

Revision 4 04/14/92 RELIEF REQUEST NO. PR-5 COMPONENTS:

Various SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Table IWP-4110-1 requires the accuracy of instruments used to measure temperature and speed to be equal to or better than +5 percent for temperature and +2 percent for speed, both based on the full scale reading of the instrument.

This means that the accuracy of the measurement can vary as much as +15 percent and +6 percent, respectively, assuming the ranges of the instruments are extended to the allowed maximum.

These IST pump parameters are often measured with portable test instruments where commercially available instruments do not necessarily conform to the Code requirements for range.

In these cases, 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 or bearing temperatures, the instruments will be such that the "reading" accuracy is as follows:

Temperature +5 percent Speed +2 percent 11

4 Revision 4 04/14/92 RELIEF REQUEST NO. PR-6 COMPONENTS:

Intake Cooling Water Pumps *-P9 A-C SECTION XI RE UIREMENT:

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 per test.

ALTERNATE TESTING:

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

12

Revision 4 04/14/92 RELIEF REQUEST NO. PR-7 COMPONENTS:

Applicable to all pumps in the Program SECTION XI RE UIREMENT:

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:

If the pumps being tested are in operation as a result of plant or system needs, it is unreasonable to require re-configuring system lineups simply to provide for measurement of static inlet pressure.

Inlet pressure prior to pump startup is not a significant parameter needed for evaluating pump performance or its material condition.

ALTERNATE TESTING:

When performing a test on a pump that is already in operation due to system or plant requirements, inlet pressure will only be measured during pump operation.

13

Revision 4 04/14/92 RELIEF REQUEST NO. PR-8 WITHDRAWN 14

Revision 4 04/14/92 RELIEF REQUEST NO. PR-9 COMPONENTS'esidual Heat Removal (RHR) Pumps *-P210 AGB SECTION XI RE UIREMENT:

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 RHR Pumps, flow is routed through a minimum flow test line leading to the suction of the pump being tested. The main line flow instrument is sized such that flowrate readings taken under minimum flow conditions are inaccurate to the extent of being meaningless. Additional flow instruments are installed in the test line, however they have recently been modified to provide flowrate readings in the proper range, but are not yet considered to be reliable. When the newly installed flowmeters are proven accurate and reliable, flowrate measurements will be recorded during quarterly minimum flow testing.

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

ALTERNATE TESTING:

Until such time. that the test line flow instrumentation is proven to be accurate and reliable, during quarterly testing of the RHR pumps, pump differential pressure and vibration, but not flowrate, will be recorded and evaluated per IWP-3200 and IWP-6000.

15

Revision 4 04/14/92 RELIEF REQUEST NO. PR-9 (cont.)

ALTERNATE TESTING con't:

During testing performed at cold shutdown, pump differential pressure, flowrate, and vibration will be recorded per IWP-3200 and IWP-,6000. 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.

16

0 Revision 4 04/14/92 RELIEF REQUEST NO. PR-10 COMPONENTS:

CVCS Charging Pumps *-P201 A-C SECTION XI RE UIREMENT:

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

(IWP-3300)

BASIS FOR RELIEF:

The CVCS configuration is such that there is no installed instrumentation provided for measuring charging pump suction or differential pressures. Installation of temporary instrumentation is burdensome and there is little value in measuring these parameters.

The charging pumps are multiple plunger, positive-displacement reciprocating pumps where the pump discharge pressure is purely a function of pump design and is independent of suction pressure. This philosophy is reflected in ASME/ANSI OMa-1987, Operation and Maintenance Of Nuclear Power Plants, Part 6 (Table 3b) where this new standard requires measurement and evaluation of pump discharge pressure, and suction pressure measurements are not required.

ALTERNATE TESTING:

During inservice testing of the charging pumps, suction and differential pressures will not be measured nor recorded.

In lieu of this, pump discharge pressure will be measured and pump performance evaluated per IWP-3200 and IWP-6000.

.17

'Revision 4 04/14/92 RELIEF REQUEST NO. PR-11 COMPONENTS:

Residual Heat Removal Pumps *-P210 AGB SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

The installed suction pressure gauges of the RHR pumps are sized to accommodate the pressure range of 4 to 450 psig expected under standby and cold shutdown testing conditions (instrument range is 0-600 psig). As a result, the instrument range exceeds the Code requirement since, under test conditions, the pump suction pressure can be considerably less than 200 psig. or 1/3 times the pressure gauge range.

Suction pressure measurements typically serve two functions.

First, they provide assurance that the subject pump has adequate suction head for proper operation. Secondly, the suction pressure measurement is used to derive the pump differential pressure through calculation.

For determination of suction head, the accuracy and range requirement as set forth in the Code is overly restrictive.

When used in determining pump differential pressure, the accuracy of the suction pressure measurement normally has little or no effect on the results of the calculation since, generally, the pump discharge pressure exceeds the suction pressure by 2 or 3 orders of magnitude.

In this particular case, the gauge range and accuracy are 0-600 psig and +0.25 percent of full scale, respectively.

This results in an absolute accuracy of +1.5 psig that is clearly adequate for determining that a pump has met its I NPSH requirements. When determining pump differential pressure (dP), assuming the most. limiting condition where RHR Pump dP is approximately 150 psig., the maximum effect of this is a reduced accuracy of +1 percent of the calculated dP. This is considered to be negligible when compared to the maximum allowable accuracy (per Code) of the discharge pressure gauge of +2 percent of 450 psig. or +9 pslg,

4 Revision 4 04/14/92 RELIEF REQUEST NO. PR-11 (cont.)

ALTERNATE TESTING:

When measuring the suction pressure of the RHR pumps, in lieu of satisfying the specified instrument range requirement of IWP-4120, the instruments used for measuring suction pressure will meet the following specifications:

Accuracy +0.25 percent of Full Scale (or better)

Range 0-600 psig. (or less) 19

Revision 4 04/14/92 RELIEF REQUEST NO. PR-12 COMPONENTS:

All pumps in the Program SECTION XI RE UIREMENT:

If the presence or absence of liquid in a gage line could produce a difference of more than 0.25% in the indicated value of the measured pressure, means shall be provided to ensure or determine the presence or absence of liquid as required for the static correction used. (IWP-4210)

BASIS FOR RELIEF When this requirement is applied where measured pressures are at relatively low levels, e.g. suction pressure, the 0.254 limit many times results in complicated venting procedures and related health physics risks associated with the disposal of radioactive contaminated water with no commensurate improvement of test reliability.

Normally, the only quantitative use of suction pressure measurements, where significant accuracy is required, is in determining pump differential pressure or head. In most cases the pump discharge pressure exceeds the suction pressure by at least a factor of five (5). This being the case, a .254 error introduced into the suction pressure measurement results in an error of .05% in the differential pressure calculation. This is insignificant in light of the potential 6% error allowance applied to both the suction and discharge pressure instruments (Ref IWP-4110).

In all cases where this relief request is applied the potential error due to the presence of air in a sensing'line is insignificant when compared to the margin between actual suction pressure and minimum NPSH required for pump operation. Minimum NPSH is assured by pre-suction pressure measurements as well as system alignments pertinent to the plant safety analysis.

ALTERNATE TESTING:

If the presence or absence of liquid in a gage line used sensing suction pressure could produce a difference for of pump more than 0.25% in the calculated value of the pump differential pressure, means shall be provided to ensure or determine the presence or absence of liquid as required for the static correction used.

20

0 Revision 4 04/14/92 RELIEF REQUEST NO. PR-13 WITHDRAWN 21

Revision 4 04/14/92 4.0 INSERVICE TESTING PROGRAM FOR VALVES 4.1 Code Compliance This IST Program for valves meets the requirements of Subsection IWV of the Code and any interpretations or additional requirements imposed by Reference 2.8.

Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant to the requirements of 10 CFR 50.55a(g)(iii) and Reference 2.8.

4.2 Stroke Time Acceptance Criteria When required, the acceptance criteria for the stroke times of power-operated valves will be as set forth in Reference 2.8.

4.3 Check Valve Testing Where required, full-stroke exercising of check valves to the open position using system flow requires that a test be performed whereby the predicted full accident condition flowrate through the valve be verified and measured. Any deviation to this requirement must satisfy the requirements of Reference 2.8, Position 1.

4 ' Testing Intervals The test frequency for valves included in the Program will be as set forth in IWP-3400 and related relief requests. A band of +25 percent of the test interval may be applied to a test schedule as allowed by the Turkey Point Technical Specifications to provide for operational flexibility.

4.5 Legend for Valve Tables Appendices C and D list those valves included in the IST Program with references to required testing, respective test intervals, and applicable requests for relief. The legend for the valve tables is provided in Table 4.0-1.

22

Revision 4 04/14/92 Table 4.0 LEGEND FOR VALVE TABLES VALVE NUMBER The plant alpha-numerical designator for the subject valve COORD The coordinate location of the valve on the designated drawing CL The ISI Classification of the valve as per the respective ISI boundary drawings CAT The valve category per Paragraph IWV-2200 SIZE The valve's nominal size in inches TYPE The valve type A/P The active (A) or passive (P) determina-tion for the valve ACT. TYPE The valve actuator type as follows:

AO Air-operated MAN Manual valve MO Electric motor-operated SA 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".

Identifies the test requirements for a valve as follows:

TC Exercise to closed position-stroke time will be measured.

TO Exercise to open position-stroke time will be measured.

EO Exercise to open position-stroke time will not be measured.

23

Revision 4 04/14/92 Table 4.0-1 (cont.)

EC Exercise to the closed position-stroke time will not be measured.

FS Fail safe test INSP Disassembly and inspection of check valves PEO Partial-stroke test to the open position of check valves S/R Safety/relief valve setpoint test SLT-1 Seat leakrate test per 10 CFR 50, App J SLT-2 Seat leakrate test for pressure isolation valves V Position indication verification INSP Disassembly and inspection of check valves TEST FREQ The required test interval as follows:

Each reactor refueling outage (cycle)

Cold shutdown as defined by Tech. Specs.

Quarterly (during plant operation)

During cold shutdown with the reactor coolant system cooled down and vented Every 2 years Prior to placing a system or component in operable status Other (See applicable Request for Relief)

Per Table IWV-3510-1 RELIEF REQ Refers to the specific relief request associated with the indicated test requirement.

Revision 4 04/14/92 4.6 Cold Shutdown Testing Where quarterly testing of valves is impractical or otherwise undesirable, testing may be performed during cold shutdown periods as permitted by IWV-3412(a).

Completion of all valve testing during a cold shutdown outage is not required if plant conditions preclude testing of specific valves or if the length of the shutdown period is insufficient to complete all testing. Testing not completed prior to startup may be rescheduled for the next shutdown in a sequence such that the test schedule does not omit nor favor certain valves or groups of valves. It should be noted that there are two conditions of cold shutdown identified in the program tables (Appendices D and E), namely pressurized and vented. For the purpose of this requirement, the term 'cold shutdown'efers to the respective condition as noted in the tables. The program tables identify those valves to which cold shutdown testing applies. Justification for such testing (arranged by system) follows:

Main Steam 5610-T-E-4061-1)

POV 3 2604 g POV 3 2605 J 6 POV 3 2606 POV 4 2604 g POV 4 2605 g 6 POV 4 2606 Main Steam Isolation Valves During plant operation at power, closure of any one 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.

Feedwater 5610-T-E-4061-4 4062-2 3 10 381 g 3 10 382 g 6 3 10 383 4 10 381 g 4 10 382 g 6 4 10 383 Aux. Feedwater Steam Supply Non-return Valves Verification of closure capability for these valves requires isolation of the respective steam supply line from its associated steam generator and performing a backflow test. Considering the importance of the auxiliary feedwater system and the undesirability of altering system lineups while the plant is operating, it would be imprudent to perform such a test at plant conditions other than cold shutdown.

25

Revision 4 04/14/92 Feedwater 5610-T-E-4061-4 4062-2 con't.

FCV 3 0478 / FCV 3 0488 I & FCV 3 0498 FCV 4 0478 I FCV 4 0488 I & FCV 4 0498 Main Feedwater Flow Control Valves Testing of these valves to the closed position during plant operation at power would result in severe steam generator level transients and a plant trip.

FCV 3 0479 g FCV 3 489 I & FCV 3 499 FCV 4 0479 I FCV 4 489 J & FCV 4 499 Main Feedwater Regulating Valve Bypass Valves Opening these normally closed valves in order to exercise them to the closed position would result in possible steam generator level transients with the potential of a plant trip. These valves are normally closed and remain so except for low-power periods associated with startup and shutdown.

Reactor Coolant 5610-T-E-4501-1 PCV-3-0455C, PCV-3-0456 PCV-4-0455C, PCV-4-0456 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.

SV-3-6318 A&B, SV-3-6319 A&B, SV-3-6611, and SV-3-6612 SV-4-6318 A&B, SV-4-6319 A&B, SV-4-6611, and SV-4-6612 Reactor Coolant System Vents These valves are administratively controlled in the key-locked closed position to prevent inadvertent operation. Since these are Class 1 isolation valves for the reactor coolant system, failure of a valve to close or leakage following closure could result in a loss of coolant in excess of the limits imposed by th the Plant Technical Specifications. Furthermore, failure of the valve to indicate a return to the fully closed position following exercising, could likely result in a contaiment entry at power or a plant shutdown.

26

Revision 4 04/14/92 Reactor Coolant Pum s 5610-T-E-4503-1 MOV-3-626, MOV-3-716 AGB, and MOV-3-730 MOV-4-626, MOV-4-716 AGB, and MOV-4-730 Component Cooling Water Supply/Return Isolation Valves These valves are required to be open to ensure continued cooling of reactor coolant pump auxiliary components including the controlled seal leakage system, the pump seals, and the main drive motors.

Closing these valves during pump operation could result in long term degradation of the RCP seal, eventually resulting in an unacceptable level of primary seal leakage and subsequent plant shutdown.

Chemical & Volume Control Char in Section 5610-T-E-4505-1 3-357 4-357 RWST Discharge Valves Opening these valves during operation would require injection of RWST borated water into the reactor coolant system. This would, in turn, result in over-boration with an adverse reaction in reactor power *and the potential of a power transient.

HCV-3-0121 HCV-4-0121 Charging Line Flow Control Valves Closing these valves during operation would result in undesirable pressurizer level transients with the potential for a plant trip.

LCV-3-0115B LCV-4-0115B RWST Outlet Valves Opening these valves during operation would result in injection of RWST borated water into the reactor coolant system. This would, in turn, result in over-boration with an adverse reaction in reactor power and the potential for a power transient.

27

Revision 4 04/14/92 Chemical E Volume Control Char in Section con't.

5610-T-E-4505-1 LCV-3-0115C LCV-4-0115C Volume Control Tank Outlet Valves Closing these valves during operation of a charging pump would cause damage to the pump and interruption of charging water flow to the RCS and the RCP seals.

Chemical & Volume Control Letdown Section 5610-T-E-4505-2 CV-3-0204 CV-4-0204 Letdown Line Outboard Isolation Valves Closing these valves during operation would result in undesirable pressurizer level transients with the potential for a plant trip. If a valve failed to reopen, then an expedited plant shutdown would be required.

MOV-3-0381 and MOV-3-6386 MOV-4-0381 and MOV-4-6386 RCP Seal Water Return Isolation Valves Exercising these valves. to the closed position when the reactor coolant pumps (RCP's) are in operation would interrupt flow from the RCP seals and result in damage to the pumps.

Safet In'ection Residual Heat Removal 5610-T-E-4510-1 3-0753 AGB 4-0753 AGB Residual Heat Removal Pump Discharge Check Valves The only flowpath available for full-flow exercising these valves to the open position requires pumping from each RHR pump to the reactor coolant system. Since the RHR pumps cannot develop sufficient head to overcome RCS pressure this is impossible to accomplish during other than the cold shutdown modes when the RCS is de-pressurized. Note that these valves will be partial-stroke exercised open on a quarterly basis via the minimum flow test lines.

28

Revision 4 04/14/92 Safet In'ection Residual Heat Removal con't.

5610-T-E-4510-1 MOV-3-0856 A&B MOV-4-0856 A&B Minimum Flow Line Isolation Valves Failure of either of these valves in the closed position during testing will render both unit. safety injection and containment spray pumps inoperable due to the high probability of damage should these pumps be started and operated without sufficient flow for cooling of pump internal components.

MOV-3-0862 A&B MOV-4-0862 A&B RHR Pump Suction Isolation Valves Failure of either of these valves in the closed position during testing will isolate both unit's residual heat removal pumps from the respective refueling water storage tank rendering them inoperable and losing all capability of low-pressure safety injection.

MOV-3-0863 A&B MOV-4-0863 A&B LP-Safety Injection/Recirculation Isolation Valves Failure of either of these valves in the open position during testing will open a recirculation path from the discharge of the RHR heat exchangers to the RWST or suction of the RHR pumps. In the event of a safety injection signal, this would result in diverting flow from the injection flowpath and thus adversely impact the effectiveness of the LP safety injection system function.

MOV-3-864 A&B MOV-4-864 A&B RWST Outlet Isolation Valves During stroke testing of any of these valves, the associated RWST is isolated reducing the capability of the safety injection and containment. spray systems to respond to an accident if a valve could not be reopened after closure. Thus, closing any of these valves while the associated unit is not in a cold shutdown or refueling mode is considered imprudent.

29

Revision 4 04/14/92 Safet In'ection Residual Heat Removal con't.

5610-T-E-4510-1 MOV-878 AGB High Head Safety Injection Pump Discharge Cross-Tie The Turkey Point plant design takes credit for the added redundancy of the shared safety injection systems and the capability of maintaining four (4) pumps capable of taking suction from either refueling water storage tank. The plant Technical Specifications require all four pumps to be operable when either or both of the units is in operation and Tavg greater than 380 deg.-F. Failure of either one of these valves to reopen while testing would significantly reduce the capability of the safety injection system to respond to a LOCA in the operating unit(s).

Safet In'ection Residual Heat Removal 5610-T-E-4510-2 3-0876A 4-0876A Low-head Safety Injection/RHR Injection Check Valves The only flowpath available for full-flow exercising these valves to the open position requires pumping from the RHR pump to the reactor coolant system. Since the RHR pumps cannot develop sufficient head to overcome RCS pressure this is impossible to accomplish during periods other than the cold shutdown modes when the RCS is de-pressurized.

MOV-3-744 AGB MOV-4-744 A&B Low-head Safety Injection/RHR Injection Stop Valves Opening either of these valves while the RCS is at operating pressure subjects the RHR system to a situation where the only isolation between the RCS and RHR systems is established by two check valves.

Failure of these check valves to seat could subject the RHR system to pressures above its design pressure and possibly damage system components. Because of this, opening these motor-operated valves while the RCS is at pressures above 600 psig is considered imprudent.

30

Revision 4 04/14/92 Safet In'ection Residual Heat Removal con't.

5610-T-E-4510-2 MOV-3-750 and MOV-3-751 MOV-4-750 and MOV-4-751 RHR Supply From the Reactor Coolant System Isolation Valves These valves are provided with electrical interlocks that prevent opening when any one of the following conditions exists (in the corresponding unit):

• Reactor Coolant System pressure exceeds 525 psig;

• MOV-*-862 A or B is open; or

• MOV-*-863 A or B is open.

This precludes exercising these valves in any other plant condition than cold shutdown.

MOV-3-866 AGB MOV-4-866 AGB High-Head Hot Leg Safety Injection Isolation Valves Opening either of these valves while the RCS is at operating pressure subjects the SI system to a situation where the only isolation between the RCS and SI systems is established by a single (actually two in parallel) check valve. Failure of either of these check valves to seat could subject the SI system to pressures above its design pressure and possibly damage system components. Because of this, opening these motor-operated valves while the RCS is at pressures above 600 psig is considered to be imprudent.

Com onent Coolin Outside Containment 5610-T-E-4512-1 3-0702A 4-0702A Component Cooling Pump "A" Discharge Check Valves These valves provide flowpaths from the "A" CCW pumps to the CCW headers. Obtaining a design maximum accident flowrate of 8000 gpm requires alignment of two

("A" and "B") CCW heat exchangers to the "A" discharge header, due to the manufacturer's suggested limit of 6,840 gpm per heat exchanger. Aligning the system in this manner is contrary to the Technical Specification requirements for operability of the CCW system.

31

e Revision 4 04/14/92 Com onent Coolin Outside Containment con't.

5610-T-E-4512-1 MOV-3-1417 and MOV-3-1418 MOV-4-1417 and MOV-4-1418 Component Cooling Containment Supply/Return Isolation Valves These valves provide normal cooling to the normal containment coolers, control rod drive mechanism coolers, and the primary shield cooling coils.

Exercising any of these valves during plant operation at power could cause overheating and subsequent damage to these components. Should any one of these valves fail to reopen after closure serious damage to equipment would occur necessitating an immediate plant shutdown and cooldown.

Containment Ventilation & Sam lin 5610-T-E-4534-1 POV-3-2600 and POV-3-2602 POV-4-2600 and POV-4-2602 Containment Bldg. Purge Supply/Exhaust Otbd. Isolation Valves Due to the history of these valves with respect to operational-related seat leakage, the plant staff hasimposed restrictions on their operation whereby unnecessary cycling of the valves is to be avoided and additional leaktests are performed based on cycling frequency. Thus, it is undesirable to cycle these valves more often than is absolutely necessary. In addition, typically these valves are closed (their safety-related position) during plant operation and are opened only for containment ventilation during shutdown periods.

32

Revision 4 04/14/92 Containment Ventilation & Sam lin 5610-T-E-4534-2 POV-3-2601 and POV-3-2603 POV-4-2601 and POV-4-2603 Containment Bldg. Purge Supply/Exhaust Inbd. Isolation Valves Due to the history of these valves with respect to operational-related seat leakage, the plant staff has imposed restrictions on their operation whereby unnecessary cycling of the'alves is to be avoided and additional leaktests are performed based on cycling frequency. Thus, it is undesirable to cycle these valves more often than is absolutely necessary. In addition, typically these valves are closed (their safety-related position) during plant operation and are opened only for containment ventilation during shutdown periods.

33

e Revision 4 04/14/92 4.7 Relief Requests for Valve Testing Relief requests VR-1 through VR-33, provided in the following pages, are initiated per 10CFR50.55a where appropriate.

34

Revision 4 04/14/92 RELIEF REQUEST NO. VR-1 SYSTEM Breathing Air System (5610-M-1315-1)

COMPONENTS:

3-BA-0201 4-BA-0201 CATEGORY:

A/C FUNCTION:

These valves close to provide containment isolation for the breathing air penetration (Pen No. 30) to the primary containment.

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

BASIS FOR RELIEF:

These are simple check valves with no external position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. The valves are normally closed with the outside isolation valves, CV-*-6165 locked closed, thus, in effect, they are passive and exercising is not required per IWV-3700. The primary reason for requiring exercising is to verify that the valves are cycled open then closed prior to leaktesting to ensure they are indeed operable and capable of closing following periods of use during outages. Performing leaktests of these valves at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

ALTERNATE TESTING:

These valves will be exercised and verified to close at least once every two (2) years in conjunction with Appendix J leaktesting activities.

35

Revision 4 04/14/92 RELIEF REQUEST NO. VR-2 SYSTEM Steam Generator Aux. Feedwater Supply (5610-T-E-4062-3)

COMPONENTS CV-*-2816 CV-*-2831 CV-*-2817 CV-*-2832 CV-*-2818 CV-*-2833 CATEGORY'UNCTION:

These valves open to provide flowpaths from the auxiliary feedwater pumps to the respective steam generators.

SECTION XI RE UIREMENT:

If, 50%

for power-operated valves, an increase in stroke time of 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:

These valves open with nitrogen or instrument air pressure from a positioner signal to control auxiliary feedwater flow to the steam generators. In the event of a loss of air or electric power to the valve control system, they will fail to the closed position. When a valve is closed it can be opened by flow from the associated AFW pumps, thus it affords no isolation to prevent over-feeding the steam generators and therefore these valves have no specific safety function in the closed position.

36

Revision 4 04/14/92 RELIEF REQUEST NO. VR-2 (cont.)

BASIS FOR RELIEF cont.

The initial opening signal for these valves comes from a limit switch in the associated AFW pump steam supply motor-operated valve(s). After a valve opens, its position is determined by the automatic flow control system or with a manual controller located in the Control Room. Due to the automatic functioning of the valves and the absence of position indication devices, there is no practical mechanism for accurately measuring valve stroke time.

These valves are subjected to periodic testing that verifies proper operation of the valves upon initiation of an AFW system initiation and proper response and positioning of each valve to a respective control system output air signal.

These tests provide a high level of confidence that the valves will perform their safety function as intended.

Stroke times of these valves are determined by adjusting the manual controller in the Control Room while a local observer at the valve measures the movement time of the valve stem.

The stroke time measurements taken during testing of these valves are expected to be less than 10 seconds. Due to the relative speed of the valves and consideration of the method of measurement of these times, the test data is subject to considerable variation due to conditions unrelated to the material condition of the valve (eg. test conditions, operator reaction time, communication lag).

The proposed alternate testing along with the additional testing performed outside the scope of the IST Program will provide adequate assurance that these valves will perform, as required, with a high degree of reliability.

ALTERNATE TESTING:

The stroke time for these valves will be determined but the evaluation of the stroke times 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, an assigned maximum limiting value of stroke time will be established consistent with the operational requirements for the valve and of the AFW system and the stroke time history of the valves when known to be operating satisfactorily. Upon exceeding that limit, the subject valve will be declared inoperable and corrective action taken in accordance with IWV-3417(b).

37

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-3 SYSTEM Reactor Coolant (RCS) (5610-T-E-4501-1)

COMPONENTS:

3-0518 4-0518 CATEGORY:

A/C FUNCTION:

These valves close to provide primary containment isolation for the penetration associated with the nitrogen supply to the pressurizer relief tank (Pen No. 6).

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. The valves are normally closed with the outside isolation valves, *-550 closed. Performing leaktests of these valves at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

ALTERNATE TESTING:

These valves will be exercised and verified to close at least once every two (2) years in conjunction with Appendix J leaktesting activities.

38

4 Revision 4 04/14/92 RELIEF REQUEST NO. VR-4 SYSTEM:

Chemical 6 Volume Control (CVCS) (5610-T-E-4505-163)

COMPONENTS:

3-0298 A-C 4-0298 A-C CATEGORY:

A/C FUNCTION:

These valves close to provide primary containment isolation for penetrations associated with the CVCS supply to the reactor coolant pump seal injection lines (Pen Nos. 24 A-C).

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. During plant operation, the valves are normally opened supplying seal water to the RCP's. Interruption of this flow during pump operation could result in RCP seal failure. Performing leaktests of these valves involves a considerable effort such that testing at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

ALTERNATE TESTING:

These valves will be exercised and verified to close at least once every two (2) years in conjunction with Appendix J leaktesting activities.

39

I' Revision 4 04/14/92 RELIEF REQUEST NO. VR-5 SYSTEM Chemical & Volume Control (CVCS) (5610-T-E-4505-1&3)

COMPONENTS 3-0312C 4-0312C CATEGORY:

A/C FUNCTION:

These valves open to provide flowpaths to the RCS for emergency boration and close to provide primary containment t

isolation for penetrations associated with the CVCS charging water supply to the reactor coolant system.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. During plant operation, the valves are normally open supplying charging water to the reactor coolant system.

Interruption of this flow during operation would result in a CVCS flow imbalance and a possible plant trip as a result of pressurizer level fluctuations. Performing leaktests of these valves involves a considerable effort such that testing at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

ALTERNATE TESTING:

These valves will be exercised in the open direction quarterly and verified to close at least once every two (2) years in conjunction with Appendix J leaktesting activities.

40

e Revision 4 04/14/92 RELIEF REQUEST NO. VR-6 SYSTEM Chemical & Volume Control (CVCS) (5610-T-E-4505-1&3)

COMPONENTS:

HCV-*-0121 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the charging pumps to the reactor coolant system during emergency boration. They close for containment isolation.

SECTION XI RE UIREMENT:

If, 50%

for power-operated valves, an increase in stroke time of 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:

These valves are subjected to periodic testing that verifies proper operation of the valves and their response and positioning with respect to the control system output air (

signal. These tests provide a high level of confidence that the valves will perform their safety function as intended.

41

Revision 4 04/14/92 RELIEF REQUEST NO. VR-6 (cont.)

BASIS FOR RELIEF cont.

These valves are positioned from the Control Room by manually adjusting a DC electric current signal input to a current-to-air,pressure converter that transmits a pre-determined air pressure to the valve positioner that adjusts valve position and the associated charging and reactor coolant pump seal injection flows. In the event of a loss of air or electric power to the valve control system, they will fail in the open position. Since there is no position indication or specific actuating signal for these valves to effect valve operation, measuring an accurate stroke time per IWV-3413 is not practical however, local observation of valve movement and operation is an effective way of ascertaining the material condition of the valves.

Stroke times of these valves are determined by adjusting the manual controller in the Control Room while a local observer at the valve measures the movement time of the valve stem.

The stroke time measurements taken during testing of these valves are expected to be less than 10 seconds. Due to the relative speed of the valves and consideration of the method of measurement of these times, the test data is subject to considerable variation due to conditions unrelated to the material condition of the valve (eg. test conditions, operator reaction time, communication lag).

ALTERNATE TESTING The stroke time for these valves will be determined but the evaluation for these valves 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, an assigned maximum limiting value of stroke time will be established consistent with the operational requir'ements for the valve and the CVCS system and the stroke time history of" the valves when known to be operating satisfactorily. Upon exceeding that limit, the subject valve will be declared inoperable and corrective action taken in accordance with IWV-3417 (b) .

42

Revision 4 04/14/92 RELIEF REQUEST NO. VR-7 WITHDRAWN 43

Revision 4 04/14/92 RELIEF REQUEST NO. VR-8 SYSTEM Safety Injection (5610-T-E-4510-1)

COMPONENTS:

3-0879 AGB 4-0879 CGD CATEGORY:

FUNCTION These valves open to provide flowpaths from the SIS Pumps to the various safety injection headers and piping. They close to prevent reverse recirculation through an idle safety injection pump.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating each safety injection pump at nominal accident flowrate. The only flowpath available for such operation would necessitate injecting into the reactor coolant system since no full flow recirculation path exists. At power operation this is not possible because the SIS pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. During normal cold shutdown conditions, injection via the SIS pumps is precluded by operational restrictions related to low-temperature over-pressurization protection concerns and Technical Specifications.

ALTERNATE TESTING:

Each of these valves will be partial-stroke exercised quarterly in conjunction with testing of the SIS pumps via the minimum flow test line. During each refueling outage, each valve will be exercised at least once to demonstrate full stroke capability.

44

Revision 4 04/14/92 RELIEF REQUEST NO. VR-9 SYSTEM:

Safety Injection (5610-T-E-4510-1)

COMPONENTS:

3-0890 AGB 4-0890 AGB CATEGORY:

A/C FUNCTION:

These valves open to provide flowpaths from the containment spray pumps to the containment spray headers in containment.

They are required to close for containment isolation.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Exercise-0 en Full-stroke exercising these valves to the open position would require operating each containment spray pump at nominal accident flowrate. Since no recirculation flowpath exists downstream of these valves, the only flowpath available for such a test would result, in injecting radioactive-contaminated borated water into the containment spray headers and thence into the containment building via the spray nozzles. Dousing personnel and equipment in this manner is obviously undesirable.

Partial stroking of the valves can be achieved by pressurizing the upstream piping with air or nitrogen via the air test connection. Performing partial flow exercising by this method during any mode of plant. operation (at power or cold shutdown), however, has the potential of creating an airborne contamination personnel hazard in the auxiliary building or containment.

45

e Revision 4 04/14/92 RELIEF REQUEST NO. VR-9 (Cont.)

BASIS FOR RELIEF cont.

Exercise-Closed Since these are simple-acting check valves with no provision for determining disc position, the only practical means of verifying closure involves performing a leaktest.

Performance of such a test would require considerable effort, including isolation and draining of the containment spray piping, system reconfiguration, hooking up and disconnecting leak testing equipment, and pressurizing the downstream piping with air or nitrogen while venting the upstream piping. Such a test, is not practical during plant operation and could result in delays in the return to power operation during cold shutdown periods to the extent that, would be an undesirable burden on the plant staff. These it valves remain closed at all times except during an MHA in which the Containment Spray system operates for containment cooling and de-pressurization.

The performance of these valves with respect to their capability to close and satisfactorily isolate the containment is adequately verified by the containment isolation valves testing program performed in accordance with 10CFR50, Appendix J.

Back round Each of these valves has been disassembled and inspected in the past and they have not displayed any indication of degradation that would impede their capability to perform their safety function to open. Past inspections were conducted as follows with no indication of a valve in-operability with respect to its capability to full open:

3-0890A 4-7-90 3-0890B 3-24-90 4-0890A 3-18-89 and 3-8-91 4-0890B 3-18-89 and 3-8-91 46

Revision 4 04/14/92 RELIEF REQUEST NO. VR-9 (Cont.)

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually exercised on a sequential and rotating schedule. If, in the course of this inspection a valve is found to be inoperable with respect to its function to fully open, then the other valve will be inspected during the same outage. During activities associated with valve disassembly and inspectionb' and prior-to system'closure, appropriate precautions'ill applied and inspections performed to ensure internal cleanliness. standards are maintained. and. foreign materials,,

are excluded from valve and system internals. These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.

Following valve disassembly; the subject valve will be partial-stroked in the open direction followed by .a seat leakage test. These functional testing activities will ensure that the subject valve has been- re-assembled and aligned properly.

Each of these valves will be verified to be closed at least once every two (2) years in conjunction with Appendix J leaktesting activities..

47

Revision 4 04/14/92 RELIEF REQUEST NO. VR-10 SYSTEM Safety Injection (SIS) (5610-T-E-4510-2)

COMPONENTS 3-0873 A-C 4-0873 A-C CATEGORY'/C FUNCTION These valves open to provide flowpaths for borated water injection .from the SI pumps to each of the RCS cold legs.

t Additionally, they closed to provide isolation. of the SIS system from the. RCS high pressure.,

SECTION XI RE UIREMENT':

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

BASIS FOR RELIEF Full stroke exercising of these valves would require operating a safety injection pump at nominal accident flowrate and injecting into the reactor coolant system since no full flow recirculation path exists. At power operation this is not possible because the SIS pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure. During normal cold shutdown conditions, injection via the SIS pumps is precluded by operational restrictions related. to. low-temperature over.-pressurization.

protection concerns and Technical Specifications.,

Revision 4 04/'14/92 RELIEF REQUEST, NO. VR-10 (Cont.)

BASIS FOR RELIEF cont.

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. During plant operation, access is limited to the system since most of the components needed for leaktesting are located within the containment building. Performing leaktests .of these valves- involves a considerable. effort such that 'testing. at each"cold'hutd'own'utage would constitute an unreasonable burden on the plant staff.

ALTERNATE TESTING:

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

At least, once every two (2) years these valves will be verified to close in conjunction with PIV leaktesting.

49

Revision,4 04'/14/92 RELIEF REQUEST NO. VR-11 SYSTEM:

Safety Injection (SIS) (5610-T-E-4510-2)

COMPONENTS:

3-0874 A&B 4-0874 A&B CATEGORY:

A/C'UNCTION These valves open to provide flowpaths for borated water injection from the. SIS..pumps. to "A" and. "B!'CS hot legs.

Additionally, they close to provide isolation of the SI system from the RCS high pressure.

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

BASIS FOR REL'IEF:

Exercising these valves requires operating a safety injection pump and injecting into the reactor coolant system. At power operation this is not possible because the SIS pumps cannot develop sufficient discharge pressure to overcome reactor coolant system pressure. During normal cold shutdown conditions, injection via the SIS pumps is precluded by operational -restrictions related =to. low.--

temperature over-pressurization protection concerns and Technical Specifications".

0 50

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-11 (cont.)

BASIS FOR RELIEF cont.

Since these are simple-acting check valves with no provision for determining disc position, the only practical means of verifying closure involves performing a leaktest.

Performance of such a test at each cold shutdown would constitute an unreasonable burden on the plant staff. The t Technical Specifications, Section 4.4.6.2.2, establishes a more appropriate frequency far leak testing based on their pressure isolation function. The Technical Specification requirements are adequate to confirm valve operability in the closed position. The requirements of the Technical Specifications are as follows:

At least once every 18 months; 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; Prior to returning a valve to service following maintenance, repair, or replacement work on'he valve; and Following valve actuation due to automatic or manual action or flow through the valve:

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

2. Prior to entering Mode 2 by verifying valve leakrate ALTERNATE TESTING:

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

Valve closure testing will conform to the requirements of Turkey Point Technical Specification, Section 4.4.6.2.2.

51

Revision 4 04/14/92 RELIEF REQUEST NO. VR-12 SYSTEM Safety Injection (SIS) (5610-T-E-4510-2)

COMPONENTS

,3-0875 A-C 4-0875 A-C CATEGORY:

A/C FUNCTION:

These valves open to provide flowpaths for borated water injection from the SIS pumps, the RHR pumps, and the SIS accumulators to each of the RCS cold legs. Additionally, they close to provide isolation of the SI system from the RCS high pressure.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Partial-flow testing of these valves requires injecting fluid into the RCS. At power operation this is not possible because neither the RHR or the SIS pumps can develop sufficient discharge pressure to overcome reactor coolant system pressure. During normal cold shutdown conditions, however, injec'tion via the RHR pumps can be accomplished.

With respect to full stroke exercising of these valves to the open position, in order to satisfy the requirements of Generic letter 89-04, a demonstration of the maximum accident flow must be performed or some other indication of full-stroke of the obturator must be provided. For these valves the maximum accident flowrate is defined as that flowrate resulting from a fully pressurized SIS accumulator injecting into a de-pressurized RCS loop. Achieving this flowrate during power operation is not practical due to limitations associated with the reactor coolant system pressure.

52

Revision 4 04/14/92 RELIEF REQUEST NO. VR-12 (cont. )

BASIS FOR RELIEF cont.

It has been demonstrated, by past testing, that these valves can be opened by blowdown from a partially pressurized ( 100 psi) accumulator to the associated RCS loop. Performing such a test during plant operation is not possible due to the limitations associated with reactor coolant system pressure. The extensive preparations (including insulation removal, erection of scaffolding, etc.) required to perform such a test make shutdown periods.

it impractical to perform during cold The maximum flowrate achievable by means, other than accumulator discharge, is approximately 5000 gpm developed by two RHR pumps injecting into a de-pressurized reactor coolant system. This flowrate results in a flow velocity of approximately 20 feet per second (fps), which equates to approximately 40% of the peak flowrate expected during accumulator injection. Due to the system configuration, the total flow from the two RHR pumps (approximately 5000 gpm) is split between three(3) parallel trains, only one of which can be fully isolated from the remaining trains. Therefore approximately 5000 gpm can be directed through *-875A alone; however, in the case of valves *-875B and *-875C, the flow is split between the two valves, theoretically allowing only 2500 gpm through each valve. This is clearly inadequate to fully open the "B" and "C" valves.

The valve manufacturer's data indicates that approximately 20 fps is the flowrate required to fully open these valves, which roughly equals the total flowrate achievable through

• -875A using two RHR pumps. In as such, sufficient margin does not exist whereby full stroke exercise of the valve can be assured using RHR flow, and therfore it is questionable as to the capability of consistently full-stroking this valve with this limited flowrate such that non-intrusive testing could be employed effectively and reliably.

53

0 0

Revision 4 04/14/92 RELIEF REQUEST NO. VR-12 (cont.)

BASIS FOR RELIEF cont.

Since these are simple-acting check'valves with no provision for determining disc position, the only practical means of verifying closure involves performing a leaktest.

Performance of such a test at each cold shutdown would constitute an unreasonable burden on the plant staff. The Technical Specifications, Section 4.4.6.2.2, establishes a more appropriate frequency for 1eak testing based on their pressure isolation function. The Technical Specification requirements are adequate to confirm valve operability in the closed position. The requirements of the Technical Specifications are as follows:

At least once every 18 months; 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; Prior to returning a valve to service following maintenance, repair, or replacement work on the valve; and Following valve actuation due to automatic or manual action or flow through the valve:

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

2. Prior to entering Mode 2 by verifying valve leakrate ALTERNATE TESTING:

Each of these valves will be partial stroke tested to the open position during cold shutdown.

During each reactor refueling these valves will be full stroke exercised.

Valve closure testing will conform to the requirements of Technical Specification, Section 4.4.6.2.2 54

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-13 SYSTEM:

Safety Injection (SIS) (5610-T-E-4510-2)

COMPONENTS 3-0875 D-F 4-0875 D-F CATEGORY:

FUNCTION'hese valves open to provide flowpaths for borated water injection from the SIS accumulators to each of the RCS cold legs. They close to isolate the SIS accumulators from reactor coolant system pressure and to prevent diversion of flow from the safety injection paths. into a partially full accumulator.

SECTION XI RE UIREMENT:

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 to the open position, based on the maximum accident flowrate resulting from SIS accumulator injection to a de-pressurized RCS loop, is not practical due to limitations associated with the effects of such a test on system components.

It has. been demonstrated, by past testing, that these valves can be-'.,fully opened by blowdown from a partially pressurized (100 psig.) accumulator to the associated RCS loop.

Performing such a test during plant operation is not possible due to the limited pressure capability of the SI tanks. During cold shutdown periods the extensive preparations (including insulation removal, erection of scaffolding, etc.) required to perform such a "dump" test make it impractical to perform during cold shutdown periods.

55

4 Revision 4 04/14/92 RELIEF REQUEST NO. VR-13 (cont.)

BASIS FOR RELIEF cont.

Since these are simple-acting check valves with no provision for determining disc position, the only practical means of verifying closure involves performing a leaktest. It is impractical to to leak test these valves quarterly or during cold shutdowns because many of the required manual isolation valves and test connections are inside containment. Access for testing would present a personnel safety hazard due to hig radiation levels and the presence of high energy systems. Such a test could result in delaying the return to power operaton during cold shutdown periods to the extent that it would be an undesirable burden on the plant staff.

ALTERNATE TESTING:

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

At least once during each reactor refueling these valves will be 'verified to close by means of a leakage rate test.

56

Revision 4 04/14/92 RELIEF REQUEST NO. VR-14 SYSTEM'afety Injection (SIS) (5610-T-E-4510-2)

COMPONENTS:

3-0876 B&C 4-0876 B&C CATEGORY:

A/C FUNCTION:

These valves open to provide flowpaths for borated water injection from the RHR pumps to "B" and "C" RCS cold legs.

Additionally, they close to provide isolation of the RHR system from the reactor coolant system.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Since no recirculation path exists, exercising these valves requires operating an RHR pump and injecting into the reactor coolant system. At power operation this is not possible due to system design pressure and interlocks that prevent operation of the RHR system in cooldown alignment when RCS pressure exceeds 515 psig.

During normal cold shutdown conditions, injection via the RHR pumps is practical and these valves can be full-stroke exercised. Since they have no position indicators and are installed such that the only lineup available causes them to form a'*parallel path,,full accident flow through each valve cannot be confirmed and thus full stroke verification by simple means is not possible. Employing non-obtrusive methods for verifying full stroke would require extensive preparations including containment entry, insulation removal, erection of scaffolding, etc. and thus is not practical during cold shutdown periods.

57

0 I

Revision 4 04/14/92 RELIEF REQUEST NO. VR-14 (Cont.)

cont.

'ASIS FOR RELIEF Since these are simple-acting check valves with no provision for determining disc position, the only practical means of verifying closure involves performing a leaktest.

Performance of such a test at each cold shutdown would constitute an unreasonable burden on the plant staff. The Technical Specifications, Section 4.4.6.2.2, establishes a more appropriate frequency for leak testing based on their pressure isolation function. The Technical Specification requirements are adequate to confirm valve operability in the closed position. The requirements of the Technical Specifications are as follows:

At least once every 18 months; 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 leakage testing has not been performed in the if previous 9 months; Prior to returning a valve to service following maintenance, repair, or replacement work on the valve; and Following valve actuation due to automatic or manual action or flow through the valve:

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying valve closure, and 2 ~ Prior to entering Mode 2 by verifying valve leakrate 58

0 0

Revision 4 04/14/92 RELIEF REQUEST NO. VR-14 (Cont.)

ALTERNATE TESTING:

Each of these valves will be partial stroke tested to the open position during cold shutdown.

During each reactor refueling each of these valves will be full-stroke exercised.

Valve closure testing will conform to the requirements of Technical Specification, Section 4.4.6.2.2 59

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-15 WITHDRAWN 60

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-16 WITHDRAWN 61

l I 0

Revision 4 04/14/92 RELIEF REQUEST NO. VR-17 SYSTEM Safety Injection (SIS) (5610-T-E-4510-2)

COMPONENTS:

3-0876A 4-0876A CATEGORY:

A/C FUNCTION'hese valves open to provide flowpaths for borated water injection from the RHR Pumps to the t

A cold leg and close to provide isolation of the RHR system from the RCS high pressure.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. This would require a considerable effort and access to the containment building which is not practical duping plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown.

ALTERNATE STING:

At least once every two (2) years, each of these valves will be verified to close in conjunction with the PIV leak testing program.

62

f Revision 4 04/14/92 RELIEF REQUEST NO. VR-18 SYSTEM:

Primary and Demineralized Water (5610-T-E-4531-1)

COMPONENTS:

3-10-0567 4-10-0567 CATEGORY:

A/C FUNCTION'hese valves close to provide primary containment for the penetrations related to the primary water supply line to the containment building.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. This would require a considerable effort, including bleeding down the pressure in the primary water supply system, which is undesirable during plant operation and would be an unreasonable burden on the plant staff to perform at coll shutdown.

In addition, these valves are normally closed during plant operation with the inboard manual valves (*-10-0582) also closed. Thus, in effect, they are passive valves and essentially, need not be exercised.

ALTERNATE TESTING:

At least once every two (2) years, each of these valves will be verified to close in conjunction with the Appendix J leak testing program.

63

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-19 SYSTEM Containment Vent & Sampling (5610-T-E-4534-1)

COMPONENTS:

3-11-0003 4-11-0003 3-40-0205 4-40-0205 CATEGORY:

A/C FUNCTION:

These valves close to provide primary containment.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. This would require entry into the containment building and thus is impractical to perform during plant operation and would be an unreasonable burden on the plant.

staff to perform at cold shutdown.

ALTERNATE TESTING:

At least once every two (2) years, each of these valves will be verified to close in conjunction with the Appendix Z leak testing program.

64

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-20 SYSTEM Instrument Air Inside Containment (5610-T-E-4064-8 & 11)

COMPONENTS 3-40-0336 4-40-0336 CATEGORY'/C FUNCTION:

These valves close to provide primary containment.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These valves are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. This would require entry into the containment building and thus is impractical to perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown.

ALTERNATE TESTING:

At least once every two (2) years, each of these valves will be verified to close in conjunction with the Appendix J leak testing program.

65

Revision 4 04/14/92 RELIEF REQUEST NO. VR-21 SYSTEM Safety Injection/Residual Heat Removal (5610-T-E-4510-1&2)

COMPONENTS:

• -875 A-C

• -876 A-E MOV-*-750 MOV-*-751 CATEGORY:

A/C (Check Valves)

A (Motor-operated valves)

FUNCTION:

These check valves open to provide for high-head and low-head safety injection to the RCS. The motor-operated valves open for residual heat removal recirculation during shutdown. Each of these valves is designated as a pressure isolation valve (PIV) and provides isolation of safeguard systems from the RCS.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Leaktesting of these valves is primarily for the purpose of confirming their capability of preventing over-pressurization and catastrophic failure of the safety injection/RHR piping and components. In this regard, special leakage acceptance criteria is established and included into the Turkey Point Technical Specifications that I address the question of valve integrity in a more appropriate manner than that of IWV-3427(b) for these )

valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing.

66

Revision 4 04/14/92 RELIEF REQUEST NO. VR-21 (cont.)

ALTERNATE TESTING:

The leakage rate acceptance criteria for these valves will be established per the Turkey Point Technical Specifications, namely, Leakage rates less than or equal to 1.0 gpm are considered acceptable.

2. Leakage rates greater than 1.0 gpm but, less than or equal to 5.0 gpm are considered acceptable if-the latest measured rate has not exceed the rate determined by the previous test by an amount that reduced the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 504 or greater.

3. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are considered unacceptable the latest measured rate exceeded the rate if determined by the previous test by an amount that reduces the margin between m~as~!red leakage rate and the maximum permissible rate of 5.0 gpm by 50%

or greater.

4. Leakage rates greater than 5.0 gpm are considered unacceptable.

67

Revision 4 04/14/92 RELIEF REQUEST NO. VR-22 WITHDRAWN 68

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-23 SYSTEM:

Various COMPONENTS:

Various CATEGORY:

Various .

FUNCTION:

This is a generic Request for Relief.

SECTION XI RE UIREMENT:

If, for power-operated valves, an increase in stroke time of 504 or more for valves with full-stroke times less than or equal to 10 seconds is observed, the test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed (IWV-3417(a))

BASIS FOR RELIEF:

The stroke time measurements taken during testing of fast-acting valves (those less than 2 seconds) are subject to considerable variation due to conditions unrelated to the material condition of the valve (eg. test conditions, operator reaction time). In accordance with Reference 2.8, Position 6, an alternate method of evaluating stroke times is considered acceptable.

ALTERNATE TESTING:

The stroke time evaluation for those valves designated 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, a valve will be declared inoperable and corrective action taken in accordance with IWV-3417(b).

69

e Revision 4 04/14/92 RELIEF REQUEST NO. VR-24 WITHDRAWN 70

'I Revision 4 04/14/92 RELIEF REQUEST NO. VR-25 WITHDRAWN 71

Revision 4 04/14/92 RELIEF REQUEST NO. VR-26 SYSTEM Instrument Air (Primary Containment) (5610-T-E-4064-8&11)

COMPONENTS:

3-40-340A 4-40-340A CATEGORY:

A/C FUNCTION'hese valves close for containment isolation.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These check valves are normally open. The only effective method of verifying closure of these valves is to perform a reverse flow (leak test). This would require entry into the containment building and thus is impractical to perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdowns.

ALTERNATE TESTING:

At. least once 'every two (2) years, each of these valves will be verified to close in conjunction with the Appendix J leak testing program.

72

t Revision 4 04/14/92 RELIEF REQUEST NO. VR-27 SYSTEM:

Safety Injection System (5610-T-E-4510-2)

COMPONENTS 3-0945E 4-0945E CATEGORY'/C FUNCTION:

These valves close to provide containment isolation for the penetrations supplying nitrogen to the SIS accumulators (Pen No. 42).

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These check valves are normally closed with the associated the outside'isolation valves, CV-*-855 also closed during plant operation. The only effective method of verifying closure of these valves is to perform a reverse flow (leak test). This would require entry into the containment building and thus is impractical to perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdowns.

ALTERNATE TESTING:

These valves will be exercised and verified to close at least once every two (2) years in conjunction with Appendix J leaktesting activities.

73

Revision 4 04/14/92 RELIEF REQUEST NO. VR-28 SYSTEM:

Safety Injection (5610-T-E-4501-1)

COMPONENTS:

3-0519 4-0519 CATEGORY:

A/C FUNCTION'hese valves close for containment isolation.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These check valves are normally closed. The only effective method of verifying closure of these valves is to perform a reverse flow (leak test). This would require entry into the containment building and thus is impractical to perform during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown.

ALTERNATE TESTING:

At least once every two (2) years, each of these valves will be verified to close in conjunction with the Appendix J leak testing program.

Revision 4 04/14/92 RELIEF REQUEST NO. VR-29 SYSTEM Steam Generator Aux Feedwater Supply (5610-T-E-4062-3)

COMPONENTS:

AFWU-3-0017 AFWU-4-0016 CATEGORY:

FUNCTION These valves open to provide pathways for cooling water from the auxiliary feedwater pump bearing coolers to the condensate storage tanks.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF A demonstration of maximum accident flow, in order to achieve full-stroke exercising of these valves, would require simultaneous operation of all three auxiliary feedwater pumps. Operation in such a mode during a test is not practical or desirable.

Due to the presence of a restricting orifice located on the lube water discharge piping of each AFW pump, the flow surge created upon a pump start-up is not sufficient to cause back-stop 'tapping'f the subject valves. Furthermore, based on input from the valve manufacturer, sufficient information does not exist which would identify the flowrate needed to fully open these valves or to make a determination regarding the probability of opening the valves fully with the 16-18 gpm developed by one operating pump. Therefore, there is no assurance that non-intrusive techniques would be successful in this application.

75

Revision 4 04/14/92 RELIEF REQUEST NO. VR-29 (cont.)

ALTERNATE TESTING'uring quarterly testing of the auxiliary feedwater pumps these valves will be part-stroke exercised using the flow from one pump.

During each reactor refueling outage the respective valve will be disassembled, inspected, and manually exercised.

During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions will be applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals. These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.

Following valve disassembly, the subject valve(s) will be partial-stroked in the open direction to verify proper alignment and functionality.

76

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-30 SYSTEM Chemical and Volume Control (CVCS) (5610-T-E-4505-5)

COMPONENTS:

3-0351 4-0351 3-0397 A&B 4-0397 C&D CATEGORY:

FUNCTION:

These valves open to provide pathways for emergency boration from the boric acid pumps to the charging pump suctions.

They close to prevent recirculation through an idle pump.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

3-0397 A&B and 4-0397 C&D During plant operation, due to concerns about over-borating the RCS, the boric acid pumps are tested via a recirculation flowpath that is not provided with any flow indication.

Thus, since flowrate through these valves cannot be measured, in accordance with the provisions of Reference 2.8, it is considered to be a partial-stroke test. At cold shutdown conditions the pumps can be lined up to pump to the charging pumps and thus through an instrumented line, however, testing these valves in this manner would require the introduction of highly concentrated boric acid solution from the boric acid tanks to the suction of the charging pumps and, thence, to the RCS. The additional boric acid introduced into the RCS would cause considerable operational difficulty during the ensuing startup.

77

0 Revision 4 04/14/92 RELIEF REQUEST NO. VR-30 (cont.)

BASIS FOR RELIEF cont.

• -0351 Testing these valves requires the introduction of highly concentrated boric acid solution from the boric acid tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which adversely affects plan't power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. During cold shutdown, the additional boric acid introduced into the RCS would cause considerable operational difficulty during the ensuing startup.

ALTERNATE TESTING:

During quarterly testing of'he boric acid transfer pump discharge check valves 3-0397 A&B and 4-0397 C6D will be part-stroke exercised (open) using the recirculation flowpath to the boric acid tanks.

During each reactor refueling will be full-stroke exercised. outage each of these valves 0 78

Revision 4 04/14/92 RELIEF REQUEST NO. VR-31 WITHDRAWN 79

Revision 4 04/14/92 RELIEF REQUEST NO. VR-32 WITHDRAWN 80

Revision 4 04/14/92 RELIEF REQUEST NO. VR-33 SYSTEMS:

Various COMPONENTS:

Various CATEGORIES' and A/C FUNCTION'alves provide containment isolation when in the closed position.

SECTION XI RE UIREMENT:

Category A valves shall be seat leaktested and a maximum permissible leakage rate shall be specified. Individual valve leakage rates shall be trended and analyzed as required by paragraphs IWV-3426 and IWV-3427.

BASIS FOR RELIEF:

IWV-3427(b) specifies additional maintenance and increased testing frequencies for valves sizes 6-inches and larger.

The usefulness of these additional requirements does not justify the burden of compliance with these requirements.

(Reference NRC Generic Letter 89-04)

ALTERNATE TESTING The corrective action as specified in Subparagraph IWV-3427(b) will not be applied to valve test results. This is consistent with the requirements of Reference 2.8.

81

Revision 4 04/14/92 Appendix A Pump Program Tables Unit 3

e 0

iiI i 0 iiIii ii 4 i 5 Ii5 i i iiiIiiiIB i iiIiIii iii Iii4 Iis i5 i4 i i 't I4 Iiii i 8 ii\IiiI s ii iiiii S ~S E m R R ~ ~5 ~E> R RR S C5~ ~ ~ ~ ~ E ~>~5~ I ~ i ~ i ~ 0 iii i ~ 0 e TURKEY POINT NUCLEAR POWER PLANT PUMP TABLES Turkey Point Nuclear Plant - Unit 3 i S ~5g ii i i5 i i 0 5 8 ii S SZ PUMP NUMBER S S RS 8SS Ii8 S S i8 4 4 S 5 DESCRIPTION m5 ii2 i i S~ S5 NS R 5 i ii 1 i Is I ii 5 S ~ ~ RRS INLET i ii 8 i

~ IIS ~ ~ S DIFF.

nRES.

N ~54555 ~55R54 m FLOW Ii REVISION: 4 DATE:

PAGE i ii 5 R5S 0 ~ mS E~R ~

BEARING I'EMP.

04/:

S~R~8~~4

'/."-2 i

CL COORO SPEED PRES. RATE VIBRA. REMARKS 3-P IOA DIESEL OIL TRANSFER NA 0-10 NA N:PR-3 Y Y Y N:PR-4 3-PIOB DIESEL OIL TRANSFER NA 8-9 NA N:PR-3 Y Y N:PR-4 3-P201A CHARGING 2 G-8 Y N:PR-ION:PR-10 Y 3-P2018 CHARGING 2 E-8 Y N:PR-ION:PR-10 Y 3-P201C CHARGING 2 0-8 Y N:PR-ION:PR-10 Y 3-P203A BORIC ACID TRANSFER 2 G-2 NA N:PR-3 Y N:PR-I N:PR-4 3-P203A,C/D BORIC ACID TRANSFER 2 G-2 NA N:PR-3 Y Y Y N:PR-4 3-P2038 BORIC ACID TRANSFER 2 F-2 NA N:PR-3 Y N:PR-1 Y N:PR-4 3-P2038,C/0 BORIC ACID TRANSFER 2 F-2 NA N:PR-3 Y Y Y N:PR-4 t

3-P210A RESIDUAL HEAT REMOVAL 2 C-6 NA Y:PR-11 Y N:PR-9 Y N:PR-4 3-P210A,C/D RESIDUAL HEAT REHOVAL 2 C-6 NA Y:PR-11 Y Y Y N:PR-4 r

3-P2108 RESIDUAL HEAT REMOVAL 2 8-6 NA Y:PR-11 Y N:PR-9 Y N:PR-4 3-P2108.C/0 RESIDUAL HEAT REMOVAL 2 8-6 NA Y:PR-ll Y Y N:PR-4 3-P211A COMPONENT COOLING 3 E-7 NA Y Y Y N:PR-4 3-P2118 COMPONENT COOLING 3 E-8 NA Y Y, Y Y N:PR-4 3-P211C COHPONENT COOLING 3 E-8 NA Y Y Y Y N:PR-4 3-P212A SPENT FUEL PIT COOLING 3 F-5 NA Y Y Y Y N:PR-4 3-P2128 SPENT FUEL PIT COOLING 2 E-5 NA Y Y Y Y N:PR-4 3-P214A CONTAINHENT SPRAY 2 E-4 NA Y Y Y Y N:PR-4 3-P2148 CONTAINMENT SPRAY 2 E-4 NA Y Y Y Y N:PR-4 3-P215A HIGH HEAD SAFETY INJECT 2 0-8 NA Y Y Y Y N:PR-4 3-P2158 HIGH HEAD SAFETY INJECT 2 0-8 NA Y Y Y Y N:PR-4 3-P9A INTAKE COOLING WATER 3 0-3 NA N:PR-6 Y Y Y N:PR-4 3-P98 INTAKE COOLING WATER 3 0-4 NA N:PR-6 Y Y Y N:PR-4

Revision 4 04/14/92 Appendix B Pump Program Tables Unit 4

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TURKEY POINT NUCLEAR POWER PLANT REVISION: 4 PUMP TABLES DATE ." 04/I '/92 Turkey Point Nuclear Plant - Unit 4 PAGE ssa ss a aasaaasaaassaaaass sssssaassssssssasssssssa ~ sass ss aaasa s ss ss ssssaassssssssasssssssssss s ss a INLET DIFF, FLOW BEARING PUMP NUHBER DESCRIPTION CL COORO SPEED PRES. PRES. RATE VIBRA. TEHP. REMARKS 4-P201A CHARGING 2 G-3 Y N:pR-IOH:PR-10 Y Y Y 4-P2018 CHARGING 2 E-3 Y H:PR-ION:PR-10 Y Y Y 4-P201C CHARGING 2 0-3 Y N:PR-10N:PR-10 Y Y Y 4-P203A BORIC ACID TRANSFER 0-2 NA H:pR-3 Y N:PR-I Y N:PR-4 4-P203A,C/0 BORIC ACID TRANSFER 2 0-2 NA N: PR-3 Y Y H:PR-4 4-P2038 BORIC ACID TRANSFER 2 C-2 HA N.PR-3 Y H:PR-I Y N:PR-4 4-P203B,C/0 BORIC ACID TRANSFER 2 C-2 NA H:PR-3 Y Y N:PR-4 4-P210A RESIDUAL HEAT REMOVAL 2 C-6 NA Y:PR-11 Y H:PR-9 Y N:PR-4 4-P210A,C/0 RESIDUAL HEAT REMOVAL 2 C-6 NA Y:PR-11 Y Y N:PR-4 t

4-P2108 RESIDUAL HEAT REHOVAL 2 8-6 NA Y:PR-11 Y H:PR-9 Y H:PR-4 4-P2108,C/0 RESIDUAL HEAT REHOVAL 2 8-6 NA Y:PR-11 Y Y N:PR-4 4-P211A COHPONEHT COOLING 3 E-7 HA Y Y Y Y:PR-4 4-P2118 COHPONENT COOLING 3 E-B NA Y Y Y H:PRr4 4-PZI IC COHPONENT COOLING 3 E-B HA Y Y Y H:PR-4 4-P212A SPENT FUEL PIT COOLING 3 F-5 HA Y Y Y H:PR-4 4-P2128 SPENT FUEL PIT COOLING 3 E-5 NA Y Y Y H:PR-4 4-P214A CONTAINMEHT SPRAY 2 E-4 NA Y Y Y H:PR-4 4-P2148 CONTAINMENT SPRAY E-4 NA Y Y Y Y N:PR-4 t

4-P21SA HIGH HEAD SAFETY INJECT 0-9 HA Y Y Y Y N:PR-4 4-PZISB HIGH HEAD SAFETY INJECT 2 0-9 NA Y Y Y Y H:PR-4 4-P241A DIESEL OIL TRANSFER 3 C-B HA Y Y Y Y Y 4-P2418 DIESEL OIL TRANSFER 3 G-9 HA Y Y Y Y 4-P9A INTAKE COOLING WATER 3 0-5 NA H:PR-6 Y Y N:PR-4 4-P98 INTAKE COOLING WATER 3 0-6 NA 4:PR-6 Y Y N:PR-4

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Revision 4 04/14/92 Appendix C Valve Program Tables Unit 3

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TURKEY POINT NUCLEAR POWER PLANT REVISION: 4 VALVE TABLES DATE . 04/14/92 Turkey Point Nuclear Plant - Unit 3 PAGE: 2

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P 8 ID: 5610-T-E-4061-1 SYSTEH: MAIN STEAH

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ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HOOK EXAH FREQ REQ. REHARKS 3-10-0004 8-3 NA C 26.000 5/CHK A 5/A NO NO EC 2 NOTE 4 INSP 7 NOTE 4 3-10-i..S 8-2 NA C 26.000 5/CHK A 5/A NO NO EC 2 NOTE 4 INSP 7 NOTE 4 3-10-0006 8-1 NA C 26.000 S/CHK A S/A NO NO EC 2 NOTE 4 INSP 7 NOTE 4 MOV-3-1400 8-3 2 8 2.000 GLOBE A MO NC YES FAI TC 3 V 5 HOV-3-1401 8-2 2 8 2.000 GLOBE A MO NC YES FAI TC 3 V 5 MOV-3-1402 8-1 2 8 2.000 GLOBE A HO NC YES FAI TC 3 V 5 POV-3-2604 8-3 2 8/C 26.000 PA/CHK A A/0 NO YES FAI TC 2 V 5 8-2 2 8/C 26.000 PA/CHK A A/0 NO YES FAI TC 2 V 5 POV-3-2606 8-1 2 8/C 26.000 PA/CHK A A/0 NO YES FAI TC 2 V 5 RV-3-1400 D-3 2 C 6.000 SAFE A 5/A NC NO'/R 8 RV-3-1401 0-3 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1402 D-3 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1403 0-3 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1405 0-2 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1406 0-2 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1407 0-3 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1408 0-2 2 C 6.000 SAFE A 5/A NC NO 5/R 8 RV-3-1410 0-2 2 C 6.000 SAFE A 5/A NC NO 5/R 8

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TURKEY POINT NUCLEAR POWER PLANT REVISION: 4 VALVE TABLES DATE: 04/14/92 Turkey Point Nuclear Plant - Unit 3 PAGE: 4

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P & ID: 5610-T-E-4061-4 SYSTEH: AUXILIARY FEEOWATER PUHPS

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ACT. NORM REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS 3-10-0083 F-3 3 C 4.000 CHECK A 5/A NC NO EO 3 3-10-0087 F-6 3 C 4.000 CHECK A 5/A NC NO EO 6 NOTE 2 3-10-0375 A-1 2 C 3.000 CHECK A 5/A NC NO EO 3 3-10-0376 A-2 2 C 3.000 CHECK A 5/A NC NO EO 3 3-10-0377 A-3 2 C 3.000 CHECK A 5/A NC NO EO 3 3-10-0381 8-2 3 C 4.000 CHECK A 5/A NC NO EC 2 EO 3 3-10-0382 . 8-2 3 C 4. 000 CHECK A 5/A NC NO EC 2 EO 3 3-10-0383 8 3 3 C 4.000 CHECK A 5/A NC NO EC 2 EO 3 AFSS-00038 F-5 3 C 4.000 CHECK A 5/A NC NO EO 3 AFSS-0003C F-6 3 C 4.000 CHECK A 5/A NC NO EO 3 AFSS-3-0005 8-3 3 C 4.000 CHECK A 5/A NC NO EO 3 HOV-3-1403 8-2 2 8 4.000 GLOBE A MO NC YES FAI TO 3 V 5 MOV-3-1404 8-2 2 8 4.000 GLOBE A MO NC YES FAI TO 3 V 5 MOV-3-1405 8-3 2 8 4.000 GLOBE A HO NC YES FAI TO 3 V 5 MOV-6459A E-2 3 8 3.000 GATE A MO NO YES FAI TO 3 V 5 HOV-64598 E-4 3 8 3.000 GATE A HO NO YES FAI TO 3 V 5 HOV-6459C E-5 3 8 3.000 GATE A HO NO YES FAI TO 3 I

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TURKEY POINT NUCLEAR POWER PLANT REVISION: 4 VALVE TABLES DATE  : 04/14/92 Turkey Point Nucleat Plant - Unit 3 PAGE: 7 aaaasssaaasaaasaasaasaaaaaaassaaaaaaaaaaasaaaasaaaaaasaaasaaaaaaaaas aasssaasaaaaaa$ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $

P 8I ID: 5610-T-E-4062-4 SYSTEH: STEAH GEN SLOWDOWN RECOVERY AHD SAMPLING

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ACT ~ NORM REH FAIL TEST RELIEF VALVE NUHBER COORO. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REHARKS CV-3-6275A E-4 2 8 6.000 GLOBE A A/0 NO YES FAI TC 3 V 5 CV-3-62758 D-4 2 8 6.000 GLOBE A A/0 NO YES FAI TC 3 V 5 CV-3-6275C C-4 2 8 6.000 GLOBE A A/0 NO YES FAI TC 3 V 5 HOV-3-1425 G-4 2 8 1.000 GATE A MO NO YES FAI TC 3 V 5 HOV-3-1426 G-4 2 8 1.000 GATE A MO NO YES FAI TC 3 V 5 MOV-3-1427 H-4 2 8 1.000 GATE A HO HO YES FAI TC 3 V 5 SV-3-6275A-I E-4 2 8 0.750 GLOBE A SO HO YES FC FS TC 0-4 2 8 0.750 GLOBE A SO HO YES FC V'V-3-62758-1 FS 3 TC 3 V 5 SV-3-6275C-I C-4 2 8 0.750 GLOBE A SO HO YES FC FS 3 TC 3 V 5

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e TURKEY POINT NUCLEAR POWER PLANT REVISION: 4 VALVE TABLES OATE: 04/14/92 Tvrkey Point Nuclear Plant - Unit 3 PAGE: 8

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P 6 IO: 5610-T-E-4062-6 SYSTEH: CONDENSATE ANO FEEOWATER

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ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORO. CL CAT. S!ZE TYPE A/P TYPE POS. INO HOOE EXAM FREQ REQ. REMARKS 3-20-0401 F-9 3 C 8.000 CHECK A 5/A NC NO EO 3

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~ 55 ~ 55555555555555555555 ~ ESSES ~ Saaasaaaaaasssas ~ ESSE5555555555555 ~ 55555 ~ SSSSSSISSSSSSSSSSSSSSSSSSSSSSSSSSSS P & ID: 5610-T-E-4510-2 SYSTEM: SAFETY INJECTION / RESIDUAL HT. REMOVAL Saasaaaasaaa SSSSSS ~ 555 ~ Eaaassasa ~ 5555555555555 ~ SISS ~ SSESRISS ~ II

~ ~ 555 SSSSSSEIS\555555555555555555555555 ACT. NORH REM FAIL TEST RELIEF VALVE HUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. INO MODE EXAM FREQ REQ. REHARKS 3-0873A D-9 1 A/C 2.000 CHECK A 5/A HC NO EC 5 VR-10 EO 1 VR-10 SLT-2 5 3-08738 0-9 1 A/C 2.000 CHECK A 5/A NC NO EC 5 VR-10 EO I VR-10 SLT-2 5 3-0873C 0-9 1 A/C 2.000 CHECK A 5/A NC NO EC 5 VR-10 EO I VR-10 SLT-2 5 3-0874A 0-3 1 A/C 2.000 CHECK A S/A NC NO EC 7 VR-11 EO I VR-11 SLT-2 5 3-0874B 0-3 I A/C 2.000 CHECK A S/A NC NO EC 7 VR-11 EO 1 VR-11 SLT-2 5 G-I I A/C 10.000 CHECK A S/A NC HO EC VR-12 EO VR-12 PEO VR-12 SLT-2 VR-21 3-08758 G-I I A/C 10.000 CHECK A 5/A NC NO EC 7 VR-12 EO I VR-12 PEO 2 VR-12 SLT-2 5 VR-21 3-0875C H-I 1 C 10.000 CHECK A 5/A HC NO EC 7 VR12 EO I VR-12 PEO 2 VR-12 SLT-2 5 VR-21 3-0875D G-3 I C 10.000 CHECK A 5/A HC HO EC I VR-13 EO I VR-13 3-0875E G-5 I C 10.000 CHECK A 5/A HC HO EC I VR-13 EO I VR-13 3-0875F G-7 I C 10.000 CHECK A S/A HC NO EC I VR-13 EO I VR-13

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$ $ $ $ $ $ $ $ $ SSSSSSCSSS$ $ $ $ $ $ $ $ ~ SSSSSS$ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ ~ $ ~ $ $ $ $ $ $ $ $ 4$ $ $ ~ 4 ~ E ~ $ $ ~ 5$ $ $ ~ 4%$ $ $ $ $ $ $ $ $ 4%%$ %$ $ $ $ $ $

P & IO: 5610-T-E-4512-2 SYSTEM: COMPONENT COOLING - INSIDE CONTAINMENT

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Revision 4 04/14/92 Appendix D Valve Program Tables Unit 4

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DDDEEE EEEE5aEEDEEEEE4EEEDEEEEDDEEEEEEESDEEsDEDEEEEEESaEEEE4EEEEDaDEEE4EEEDEsEE4ESEEEEsE5455515555551514115 ACT. NORM REH FAIL TEST RELIEF VALVE NUMBER COORO. CL CAT. SIZE TYPE A/P TYPE POS. INO MODE EXAM FREQ REQ. REHARKS RV-4-0283A F-2 2 C 0.750 SAFE A S/A NC NO S/R 8 RV-4-02838 E-2 2 C 0.750 SAFE A 5/A NC NO 5/R 8 RV-4-0283C C-2 2 C 0.750 SAFE A S/A NC NO S/R 8

0 41$ 44114 4 SSCSRSSS 4 RSRCSSSSSCSSSSSRCSSSSSSSSSSRSSSCRSSSSSSS1C1SSSSSSSSS$ SSSSSSSSSSSSSSSSSSSSSRSSSSSS4144 TURKEY POINT NUCLEAR POWER PLANT REVISION: 4 VALVE TABLES DATE: 04/14/92 Turkey Point Nuclear Plant - Unit 4 PAGE  : 24 1 4 4444 44444444441444144444C444444444444414444444444444 ~ 4 ~ SSSRSSSSSlt144444444144414R44444S4444444444444 P & ID: 5610-T-E-4510-2 (cont) SYSTEM: SAFETY INJECTION/RESIDUAL HT. REHOVAL I I I I

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Revision 4 04/14/92 Florida Power 6 Light Company INSERVICE TESTING VALVE TABLES Turkey Point Nuclear Plant Unit 4 PAGE '2 NOTES Valves 4-10-004 through 4-10-006 are not included within the ISI class boundaries and, as such, are exempt from the inclusive requirements of the Code.

These components have been included in the Program to ensure that inservice testing is adequate to demonstrate their continued operability. These valves will be tested in accordance with Code requirements, except where determined impractical, in which case specific relief from the Code is not required.

These are large stop check valves in the main steam lines leading to the main turbine generator. There is no practical way of verifying closure of these valves by way of a back seat or reverse flow test. Exercising a valve manually using the hand wheel provides some assurance that the disc moves freely within the valve body. Furthermore, the valves are disassembled, inspected, and manually exercised at least once during each 10-year inspection interval.

2. Auxiliary Feedwater Steam Supply Valve, 4-10-087 will be tested whenever AFW Pump "C" is aligned to Train 1.

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~ saRassRRRsa4a4ssassasssaaRasassasssssassasassRsssRssaasRRsssas5sRasRRsa4saasRsRssssaaassaaasasaass ~ 0 ~ ssaas ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REHARKS 3-4656 0-5 2 A 1.000 DIAPH P MAN NC NO SLT-I 5 CV-3-2821 F-5 2 A 3.000 GLOBE A A/0 NO YES FC FS 3 SLT-I 5 TC 3 V 5 CV-3-2822 F-5 2 A 3.000 GLOBE A A/0 NO YES FC FS 3 SLT-1 5 TC 3 V 5 CV-3-4658A E-5 2 A 1.000 DIAPH A A/0 NO YES FC FS 3 SLT-I 5 TC 3 V 5 CV-3-46588 E-6 2 A 1.000 OIAPH A A/0 NO YES FC FS SLT-I TC V

CV-3-4659A 0-5 2 A 0.750 OIAPH A A/0 NO YES FC FS 3 5LT" 1 5 TC 3 V 5 CV-3-4659B E-5 2 A 0.750 OIAPH A A/0 NO YES FC FS SLT-I TC V

CV-3-4668A F-5 2 A 3.000 OIAPH A A/0 NO YES FC FS 3 5LT-I 5 TC 3 V 5 CV-3-46688 F-5 2 A 3.000 DIAPH A A/0 NO YES FC FS 3 SLT-I 5 TC 3 V 5 PC V-3-1014 D-6 2 A 1.000 GLOBE P A/0 NC NO FC SLT-I 5

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Revision 4 04/14/92 INSERVICE TESTING VALVE TABLES Turkey Point Nuclear Plant Unit 3 PAGE 43 NOTES Deleted

2. Auxiliary Feedwater (AFW) Pump "A" Discharge Check Valve,20-143, will be tested whenever "A" AFW Pump is lined up to operate in parallel with either of the other AFW Pumps. Auxiliary Feedwater Steam Supply Valve, 3-10-087 will be tested whenever AFW Pump "C" is aligned to Train 1.

3 ~ Valves CV-3-2046 A&B, SV-3-2051 A&B, SV-3-3522 A&B are not included within the ISI class boundaries and, as such, are exempt from the inclusive requirements of the Code. These valves have been included in the Program to ensure that inservice testing is adequate to demonstrate their continued operability. These valves will be tested in accordance with Code requirements, except where determined impractical, in which case specific relief from the Code is not required.

These valves will be tested in conjunction with testing of the emergency diesel generators and the associated fuel oil transfer pumps. However, valve stroke time will not be measured. The satisfactory response of the associated diesel generator and the fuel oil transfer pumps will demonstrate valve operability.

4 ~ Valves 3-10-004 through 3-10-006 are not included within the ISI class boundaries and, as such, are exempt from the inclusive requirements of the Code.

These components have been included in the Program to ensure that inservice testing is adequate to demonstrate their continued operability. These valves will be tested in accordance with Code requirements, except where determined impractical, in which case specific relief from the Code is not required.

These are large stop check valves in the main steam lines leading to the main turbine generator. There is no practical way of verifying closure of these valves by way of a back seat or reverse flow test. Exercising a valve manually using the hand wheel provides some assurance that the disc moves freely within the valve body. Furthermore, the valves are disassembled, inspected, and manually exercised at least once during each 10-year inspection interval.

Revision 4 04/14/92 Florida Power & Light Company INSERVICE TESTING VALVE TABLES Turkey Point Nuclear Plant Unit; 3 PAGE 44 NOTES con't

5. Valves 3-70-374 A&B, 3-70-376 A&B, RV-3-210 A&B, RV 211 A&B, RV-3-212 A&B, RV-3-213 A&B, and EXP-REL A&B are not included within the ISI class boundaries and, as such, are exempt from the inclusive requirements of the Code. These valves will be tested in accordance with Code requirements, except where determined impractical, in which case specific relief from the Code is not required.

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