ML20148C032

Forwards Relief Requests Determined to Be Necessary for Implementation of Updated Pump & Valve Program & Supercedes Relief Request Submitted on 871231.Summary of Revs Made to Each Relief Request & of Revs Planned Also Encl

ML20148C032
Person / Time
Site:	Crystal River
Issue date:	03/10/1988
From:	Ken Wilson FLORIDA POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
3F0388-07, 3F388-7, NUDOCS 8803220248
Download: ML20148C032 (34)

Text

- _ _ _ _ _

I s

d....

fe?@?)$*

oOOi~hba,*

E%C50,$*l C).b..($*

Florida Power C O R P O R AT IO N March 10, 1988 3F0388-07 Document Control Desk U.S.

Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Pump and Valve Program (1983 Edition)

Relief Request Submittal

Dear Sir:

By letter dated December 31, 1987 (letter number 3F1287-32) Florida Powcr Corporation (FPC) submitted the updated Pump and Valve Program as required by the 1983 Edition of the ASME Boiler and Pressure Vessel Code,Section XI, Article IWA-1400(c).

Included in that submittal were requests for relief (Helief Requests) from certain Section XI requirements for Inservice Testing of Pumps and Valves.

On February 26, 1988 FPC representatives met with the NDC staff to discuss questions which arose during review of the Relief Roquests.

In accordance with agreements reached during that

eeting FPC is hereby submitting revised Relief Request. to this submittal contains all of the Relief Requests determined to be necessary for implementation of the updated Pump and Valve Program i

and supercedes the Relief Request submitted on December 31, 1987.

It is our understanding that each of the revised Relief Requests now provides acceptable alternatives to the inservice pump and valve testing requirements of Section XI and that approval should be received no later than March 21, 1988. to this letter provides a summary of the revisions made to each Relief Request and a summary of revisions planned for the updated Pump and Valve Program.

The Pump and Valve program revisions will be submitted under separate cover, f0Yl 8803220248 880310 PDR ADOCK 05000302 g

l G

PDR Post Of fice Box 219

• Cestal River, Florida 32629

• Telephone (904) 795 3802 m Florida Progress Company

~

I March 10, 1988 3F0388-07 Page 2 Florida Power Corporation appreciates the attention given to this review by.the NRC staff and the expeditious manner in which the review was completed.

I If you have any questions concerning this submittal, please contact my staff.

Sincerely, P

K.R.

Wilson, Manager Nuclear Licensing EWF/dhd xc:

Dr.

J.

Nelson Grace Regional Administrator, Region II l

Mr.

T.F.

Stetka Senior Resident Inspector l

l 1

l l

l i

l :

g -

0 ATTACHMENT 1

i m mi e um

8 t

RELIEF REQUEST #

INSERVIG INSm;nCN V-030 I W AN WVE IMM PO.. o..e, nWr PAGE 1 OF 2

GYSIAL RIVER UNIT 3 c.3 REvi$lON 1

Reference Code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition throtr;h sinmer 1983 adderda.

I.

Cmponent For Which Exenption/ Relief Is Requested:

a) Name and identification rmber (capanent tag):

BSV-26 & BSV-27, ptmp BSP-1B and BSP-1A chrck valves to spray nozzles, b) Function:

Nomally closed valves that open for containment building coolirg on 30 psig RB pressure signal, which starts the building spray ptmps, and allwing flw to the buildiry spray nozzles.

c) ASME Section III Code Class:

2.

d) Valve Category:

C.

II.

Refemnce Code Requirement Sat Has Been Detemincd 'Ib Be Impractical:

IW-3521; Quarterly valve exercLse requirement.

IW-3522 (b) ; Partial stmke valve exercise during normal plant operation ard full valve exemise durirg cold shutdown.

III. Basis For Requesting Relief:

We stroke of these valves would require initiation of the RB spray system.

Bis would entail sprayirg the RB with borated water.

No pre-service values were recorded for these valves and identical spares are not available.

Because of this, it is not possible to cmply with IW-3522(b) mechanical exercise pmcedum for the lift form required to rave the disk.

z IV.

Alternc.te Examination:

Each refueliry outage, at least one different i

valve irm each group, where a group is a set of valves with the sam design and service conditions, shall be disassmbled and inspected as described belm until the entire gmup has 5.en tested.

If the valve is degraded to the extent that the valve can nr.t perfom its function, then all other valves in that grcup shall be irq>2cted as 6: scribed belw.

2e subsequent inspections may start again wn:h sirgle valves.

he inspection shall assure that the valve disk has freedcm of novement and is capable of a full s*.roke.

Additionally, the general condition of the valve internals shall be checked for structural degradation incitriiry the presence of any loose parts, debris and abnomal or excessive corrosion prodtxts, wear and emsion.

L

RELIEF REQUEST #

@Mg INSHWIG Ikim:nN V-111 0

REP AND VALVE HOGRAM f

GYSIE RIVER UNIT 3 PAGE 1 OF 2

navisen 1

Refererxe Ccde: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through sumer 1983 addeJXla.

I.

Ocuponent For Which Exenptioll Relief Is Requested:

/

a) Name and identification number (ocuponent tag): EFP-I and EFP-2 Ih?.rgency Feedvater Punps b) Function:

Emergency Feedwater punps provide water to the stean generators upon isolation of main feedwater to mitigate the consequences c f an accident, c) ASME Section III Code Class: 3.

d) Valve Category: N/A II.

Reference Code Requirement 'Ihat Has Been Detemined 'Ib Be Impractical:

IWP-3100; Table IWP-3100-1 requirement for measuring flow rates during pmp inservice testa.

III.

Basis For Requesting Relief:

'Ihe recirculation lines used for irservice testirg of these pmps are not equipped with flow rate measuring instruments.

Florida power Corporation is currently investigating installation of the instrumentation nmary to meet ASME Section XI l

Code requirements in these lines or the possibility of corrtucting a more corprehensive test (increased flow test through the main process pipirg which is equippect with flow measurirg instrumentation) on a refueliry cutage fropency.

In either case, it is unlikely that the chosen option can be implemented before the next refueling outage.

Therefore, relief frun the flow rate measurement requirenents of IWP-3100 is required until appropriate instrumentation is installed or an acceptable alternate test is developed.

IV.

Alternate Examination: 'Ihese Pumps are tested in acx:ordance with the requirements of IWP-3100, except for the measurement of ficw rate, on a quarterly basis.

'Ihis testirq will continue until appropriate instrumentation is installed or an alternate test is developod.

If appropriate instrumentation is installed, subsecuent testirg will be conducted in full cmpliance with Section XI requirements.

If an alternate test is developed, the current quarterly test prcgram will continue to be perfonned, ard it will be supplementcd with an increased flow tent each refueling cutage.

FET.TEF REQUEST #

l Florida INSDNIG DEPELTICN V-111

"' "o -==

Po. 2..e. e,wr GUSIAL RIVER UNIT 3 PAGE 2 oF 2

ce.

nevison i

V.

Inplementation Schedule:

The Alternate Examination requirements aru currently beiry met.

Developmnt arri performance of the increased flow

test, or installation of code required instrumntation, will be acomplished prior to startup frm the next refueling outage.

l l

I t

i t,

RELIEF REQUEST #

@@g INSHWIG Dcsm:n0N V-ll2 l

power N AND VAWE HMM QUSIAL RIVD1 UNIT 3 PAGE 1 OF 1

ce.....,n REvtSION 1

Reference Code: ASME Boiler arxl Pressure Vessel Code,Section XI,1983 edition thrcx2gh sunmer 1983 addenda.

I.

Cttponent For Which ExemptiorVRelief Is Requested:

a) Name arxl identification number (cmponent tag): DFP-1A, 1B, 1C, and 1D

- Diesel Fuel Oil Transfer Punps.

b) Function: Diesel fuel transfer pumps transfer fuel oil frtn fuel storage to the diesel day tanks.

c) ASMF Section III Code Class: 3.

d) Valve Category: N/A II.

Reference Code Requirement 'Ihat Has Been Determined 'Ib Be Inpractical:

IWP-4600; Requirement that fl w rate be reasured using a rate or quartity meter installed in the pmp test circuit.

III.

Basis For Requestirg Relief: 'Ihe diesel fuel oil transfer system lines are not equipped with flow neasurement instruments.

Installation of the Code required instruments would require removing an energency diesel generator frun service while the modification was being made.

'Ihis could adversely impact plant operation and safety.

IV.

Alternate Danination: Flow rate within this system will be calculated using a measuttd charge in day tank volume vs. time.

'Ihe n asurement devices used will meet the accuracy requirements of Table La'4600.

V.

Inplementation Schedule:

'Ihe Alternate Examination requirements are currently being met.

l l

RET M RECpEST #

@Q.2..ee, Mg DEHNIG INSPECI'Im V-115 IW AN W NE m m M Pow r mYSIAL RIVER INI'I 3 PAGE 1 OF 1

u nvises o

Reference Code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through sumer 1983 addenia.

I.

Ctanponent For hhicil Exenption/ Relief Is Requested:

a) Name and identification number (ccrnponent tag):

All class 1, 2, ard 3 Relief Valves.

b) Function:

To provide cr/er pressure protection for the ASME class 1, 2, and 3 systems.

c) ASME Section III Code Class:

1, 2, and 3 as appropriate.

d) Valve Category:

C.

II.

Reference Code Requirement That Has Been Detennined To Be Inpractical:

American National Standards, Performance TEST CODE 25.3, 1976 referenced in IW-3512,1983.

III. Basis For Requestirq Relief:

The alternate code is a more recent standard and more appropriate for valve testirg in the field.

IV.

Alternate Examination:

Relief is requested to utilize the reference in ASME XI, IW-3512,1986, ANSI /ASME m -1, 1983 for test procedures.

V.

Inplemntation Schedule:

The alternate examination program require-ments will be inplemented upon the beginning of the second ten year inspection program.

i.

i RETM REQUEST #

9 gg DEHNICE INSFffrIm V-120 RW AND VAWE HOGRM W[

GYSTAL RIVER UNIT 3 PAGE 1 OF 1

REV$ON 1

Reference Code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through

}

summer 1983 adderda.

k I.

Ctrponent For hhich ExemptiorVRelief Is Requested:

a) Name ard identification number (camponent tag): BSV-150 and BSV-151 -

Sodium Hydroxide Storage Tank to BS Pu:tp suction cixr.k valves.

b) Function: Wese valves open to release the contents of the sodium hydroxide storage tank to the buildig spray system for pH control follwirg a IOCA.

c) ASME Section III Code Class: 3.

d) Valve Category: C.

II.

Reference Code Requirement That Has Been Detemined To Be Impractical:

INV-3522; Partial stroke valve exercise during normal plant opeation and full stroke valve exercise during mld shutdwn.

III. Basis For Requestirq Relief: These valves are in the sodium hydroxide storage tank discharge lines to the buildig spray pump suction.

There is no test circuit available which cculd be used to stroke test these valves without introducing sodium hydroxide to the Borated Water Storage Tank or initiatire buildirg spray.

IV.

Alternate Examination: Each refuelirq outage, at least one of these valves (altermte valve each outage) shall be disassembled and inspected as described belw. If the inspected valve is found to be degraded to the extent it cannot perform its function, then the other valve shall be disassembled and inspected as described belw.

The subsequent inspection may start again with a sigle valve.

The inspection shall assure that the valve disk has freedctn of movement and is capable of full stroke.

Additionally, the general condition of the valve internals shall be checkai for structural degradation including the presence of any loose parts, debris and abnormal or excessive corrosion products, wear and erosion.

V.

Implementation Schedule:

The Alternate Examination requirements will be met, beginniry during the next refuelig outage.

l l

PFT.TEF REQUEST #

I9 Florida DEMI DEFECEIN V-128

"' ^"o "8 ""

Po. 2..enwr PAGE 1 OF 2

CMSIAL RIVER LEIT 3 o.

nviso" 1

Reference Code: ASME Boiler ard Pressure Vessel Code,Section XI, 1983 edition through sumer 1983 addenda.

I.

Ct Tponent For Ehich Exemptiorg/ Relief Is Requested:

a) Name and identification number (ccxuponent tag): GV-1, check valve isolatire the "A"

train decay heat and core flood line frcxn the reactor vessel; CEV-3, check valve isolatig the "B" train decay heat ard core flood line frcan the reactor vessel; b) Function: Wese valves are in the flow path from the core flood tanks to the reactor coolant system (RG).

Woy provide isolation frtxn the high pressure RG to the low pressure core flood tanks ard the decay heat removal system.

Wese valves also open to allow the core flood tanks to discharge their contents to the RCS when RCS pressure drops below core flood tank pressure during a IOCA.

c) ASMS Section III Code Class: 1.

d) Valve Category: A/C.

II.

Reference Code Requirement hat Has Been Determined To Be Impractical:

IW-3522; Partial stroke valve exercise during normal plant operation and full stroke valve exercise during cold shutdown.

III. Ba71s For RequestiM Relief:

1) %ese valves cannot be tested durirg plant operation because the Core Flood Tanks are maintained at a pressure of 600 psig while the RG pressure is 2155 psig.

2) Rese valves cannot be denonstrated to fully cpen, using a flow test, due to the magnitude of the system design flow.

3) %ese valves cannot be scheduled for disassembly inspection durire cold shutdowns because these outages last for an indeterminate ancxint of time.

Valve disassembly constitutes a major radiological work activity and would stand a very gcod chance of delaying a plant restart.

IV.

Alternate Examination: Each refueli g outage, at least one of these valves (alternate valve each outage) shall be disassembled and inspectcd as described below.

If the inspected valve is fourd to be degraded to the extent it cannot perform its function, then the other valve shall be dimeled and inspected as described below.

W e subsequent inspection may start again with a single valve.

l l

l l

l REIZEF REQUEST #

Florida INSERVIG INSFECTIN V-128 I

'"' " "8 ""

Po.. a..e. e.,wr GYSIAL RIVER INIT 3 PAGE 2 OF 2

ce arvisen 1

The inspection shall assure that the valve disk has freedcu of movement ard is capable of full stroke.

Additionally, the general condition of the valve internals shall be checked for structural degradation including the presence of any loose parts, debris and abnormal or excessive corrosion products, war arxl erosion.

Additionally, these valves are partial stroke exercisel durirg entry into or return to power frun cold shutdom by conducting a reduced f1w test fram the core flood tanks to the reactor vessel.

These valves are also partial stroke exercised during cold shutdowns, utilizing decay heat renwal flow.

V.

Implementation Schedule:

The Alternate Examination requirements will be met, beginnmJ with the next c,ld shutdown an:1 during the next refueling outage.

1 l

l l

I l

l l

l

\\

l l

)

RFT M REQUEST #

Flo @

DEERVIG INSHDCf1CN V-129 REP AND NE HOGRM Po. o..e, e,wr GYSIAL RIVIR UNIT 3 PAGE 1 OF 2

cc.

navisioN 1

Reference Code: ASME Boiler and Pressure Vessel Cbde,Section XI, 1983 edition through sunraer 1983 addenda.

I.

Cteponent For Which Exemption / Relief Is Requested:

a) Name and identification number (ccuponent tag): CFV-2, check valve isolation fran "A" core flood tank; CFV-4 check valvr isolation from "B" core flood tank.

b) Function: Wese valves are in the flw path from the core flood tanks to the reactor coolant system (RCS). Rese valves open to allw the core flood tanks to discharge their contents to the RCS when RCS pressure drops below core flood tank pressure durity a IOCA.

c) ASME Section III Code Class: 1.

d) Valve Category: C.

II.

Reference Code Requirement hat Has Been Detemined 'Ib Be Impractical:

IW-3522; Partial stroke valve exercise during nomal plant operation and full stroke valve exercise during cold shutdcut.

III. Basis For Requestirg Relief:

1) Rese valves cannot be tested during plant operation because the core Flood Tanks are maintained at a pressure of 600 psig while the RCS pressure is 2155 psig.

2) Rese valves cannot be demonstrated to fully open, using a flow test, due to the magnitude of the system design fl w.

3) These valves cannot be scheduled for disassembly inspection durity cold shutdcuns because these cutages last for an indeterminate ancunt of time.

Valve dimWly constitutes a major radiological work activity and would stand a very good chance of delayirg a plant restart.

IV.

Alternate Examination: Each refueling outage, at least one of these valves (alternate valves each outage) shall be disassembled and inspN as described below.

If the inspected valve is found to be degraded to the extent it cannot perfom its function, then the other valve shall be disassembled and inspected as described below.

Se subsequent inspection may start again with a single valve.

i PFTM REQUEST #

@ Florida mersmerim V-129 I

P M ME 1mM P, o.. w..e. e,r PAGE 2 OF 2

GYSTAL RIVER UNIT 3 c

mwscs i

'Ihe inspection shall assum that the valve disk has freedm of novement and is capable of full stroke.

Additionally, the general condition of the valve internals shall be checked for structural degradation including the presence of any loose parts, debris and abnomal or excessive corrosion products, wear ard erosion.

Additionally, these valves are partial stroke exercised durirq entry into or return to power frm cold shutdown by conductirs a reduced flow test frm the core flood tanks to the reactor vessel.

V.

Inplementation Schedule:

'Ihe Alternate Examination requirements will be met with the next cold shutdown and during the next refueling outage.

i RFT M RB2UEST #

8gg I}ERVIG I}cnu;nCH V-131 REP AND VALVE IBOGRAM

[

QUSIAL RIVER UNIT 3 PAGE 1 oF 1

nwso.

2 Reference code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through su:tmer 1983 addenda.

I.

Caponent For Which Exenption/ Relief Is Requested:

a) Name and identification number (ccuponent tag): DJV-1, DJV-2, DJV-17, ani DIV-18 Diesel Jacket Cooliry System Check Valves.

b) Function: Bese valves open when the emergency diesel generators are in stardby to provide a flow path for engine pre-heating.

Wey close during emergency diesel generator operation to prevent diversion of the diesel coolant to the standby pre-heating flow circuit.

c) ASME Section III Code Class: 3.

d) Valve Category: C.

II.

Reference Code Requirement hat Has Been Determined 'Ib Be Inpractical:

IW-3522; Full stroke valve exercise during cold shutdown.

III. Basis For Requestirg Relief:

'Ihese valves are stroked by operating the emergency diesel generators under loaded conditions, and verifyirq that adequate cooling is being maintained.

Verification that the valves acocmplish a full stroke requires that the diesel generators be run under fully loaded conditions.

Due to limitations associated with the sizirg of the diesel generators at Crystal River Unit 3, the diesels cannot be run under full load nere frequently than once per 18 months.

IV.

Alternate Examination: Each emergency diesel generator is tested renthly under partially loaded (approx. 40 to 50% ES design load) conditions ard once per 18 months under nearly full loaded (approx. 80 to 90% ES design load) in accordance with the Technical Specifications.

Se minimum requiral duration of these tests is 60 minutes.

Verification of adequate diesel generator cooling during these tests provides assurance that these valves are functioning properly.

It should be noted that the Diesel Generator Jacket Cooling System is a closed cycle, chemically controlled system.

Corrosion of these valves is not (and has not historically been) a major factor influencing their service life.

V.

Implementation Schedule:

We Alternate Examination requirenents are currently being met.

\\

RPTTFF REUEST #

8@Po.2..e.e INSER/IG INSPECI'ICH V-132 IWP AND NE NM wr GYSIAL RIVER UNIT 3 PAGE 1 oF 1

cc.

2

_ Reference Ctde: ASME Boiler arxi Pressure Vessel Code,Section XI, 1983 edition through surner 1983 acklenda.

I.

Cccponent For hhich Exemption / Relief Is Requested:

a) Name and identification number (wrent tag):

DJV-27, D]V-28, DJV-29, DJV-30, DIV-31, D]V-32, DJV-38, arx1 DIV-39 Diesel Jacket Cboling System Check Valves.

b) Function: 'Ihese valves operate to provide a f1cu path for the emergency diesel generator coolirg system when the diesel generators are running arx1 close to prevent diversion of the engine pre-heating fluid when the diesels are in standby.

c) ASME Section III Code Class: 3.

d) Valve Category: C.

II.

Reference Code Requirement 'Ihat Has Been Determined 'Ib Be Inpractical:

IhV-3522; Full stroke valve exercise during cold shutdown.

III. Basis For Requestirq Relief:

'Ihese valves are stroked by operating the energency diesel generators urrier loaded ccniitions, and verifyiry that adequate coolirg is beirg maintained.

Verification that the valves accamplish a full stroke requires that the diesel generators be run under fully loaded corrlitions.

Due to limitations associated with the sizirq of the diesel generators at l

Crystal River Unit 3, the diesels cannot be run under full load nere frequently than once per 18 nonths.

IV.

Alternate Examination. Each emergency diesel generator is tested nonthly f

under partially loaded (approx. 40 to 50% Es design load) conditions and l

once per 18 months under nearly full loaded (approx. 80 to 90% ES design I

load) in accordance with the Technical Specifications.

'Ihe minimum required duration of these tests is 60 minutes.

Verification of adequate diesel generator cooling durirq these tests provides assurance that these valves are functioning pI w erly.

It should be noted that the Diesel Generator Jacket Cooliry System is a l

closed cycle, chemically controlled system.

Corrosion of these valves is l

not (and has not historically oeen) a major factor influencing their service life.

V.

Irplenentation Schedule:

'Ihe Alternate Exanination requirvments are currently being met.

l l

l l

RELTEF REQUEST #

INSIRVIG INSPECITCH V-150

"' AN NE NM Po. 2..e, e,wr QUSIAL RIVER UNIT 3 PAGE 1 OF 1 _

ce nevision i

Reference Code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition throdgh summer 1983 adderda.

I.

Caponent For hhich Exemptiort/ Relief Is Requested:

a) Name and identification number (component tag):

IW -162, Demineralized water supply dieck valve inside the Reactor Building.

b) Function:

During nomal plant coeration, this valve is partially open to allw a small quantity of demineralizal water to flw to the RC pu:rps stardpipes for flushirq.

It is not required to be fully i

open in any safety mode, but I:ust close in case of containment isolation.

c) ASME Section III Code Class:

2.

d) Valve Category: A/C.

II.

Reference Code Requirement That Has Been Detemined To Be Impractical:

IW-3521; Quarterly valve exercisirg requirement.

III. Basis For Requestirg Relief:

The only safety related function of this valve is to close.

This can only be verified during the 10CFR50 Appenilx J, Type C leakage test.

IV.

Al* m te Examination: This valve is subject to 10CFR50 Appendix J type C leak rate testing during each refueling cutage.

V.

Implementation Schedule:

The alternate examination program require-ments are currently being mat.

c RET M RBRUEST #

@gg 1NSEVIG DentL:nN V-160

" ' ^ "

"E '*"

Po. 2..e, e,wr GYSTAL RIVm LEIT 3 PAGE 1 oF 1

ce.

nevision i

Reference Code: ASME Boiler and Pressure Vessel Cbde,Section XI, 1983 edition through sumer 1983 adden3a.

I.

Ocxuponent For hhich Exemption / Relief Is Requested:

a) Name and identification number (cct:ponent tag): CFV-17 and CEV-20, com flood tank nitrogen supply line isolation check valves.

b) Function:

Provide isolation for penetrations 123 ard 124 (inside containment).

c) ASME Section III Code Class:

2.

d) Valve Category: A/C.

II.

Faference Code Requirement That Has Been Detemined 7b Be Impractical:

IW-3522 (b) ;

Partial stroke valve exercise durirq normal plant operation and full valve exercise during cold shutdown.

III.

Basis For Requesting Relief:

The core flood tanks have a static inventory of borated water with 600 psi pressure applied through a l

regulated nitrogen gas system.

7be nomal position of these valves and j

the position to fulfill their furx. ion is closed.

Stroke testing would t

I not provide assurance that these valves would perfom their intended function. Therefore, stroke testi2g is unnecessary.

l IV.

Alternate Examination: This valve is subject to 10CFR50 Appendix J Type i

C leak rate testing during each refueling which will verify p mper valve closure.

V.

Implementation Schedule:

The alternate examination program require-i ments are currently beirq met.

l

PET TEF REQUEST #

9@o..o@..e,n INSDNIG INSPHFICH V-170 Pwr I

P M W VE E M GYSTAL RIVER INIT 3 PAGE 1 oF 1

a nwscs 1

Reference Code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through sumer 1983 addenda.

I.

Omponent For Miich ExemptiorVRelief Is Requested:

a) Name ard identification nu:nber (cmponent tag):

CFV-18 and CFV-19, core flood tank borated water supply line isolation check valves.

b) Function:

Provide isolation for penetrations 350 ard 372 (inside containment).

c) ASME Section III Code Class:

2.

d) Valve Category: A/C.

II.

Reference Code Requirement hat Has Been Detemined To Be Impractical:

IW-3522(b); Butial stroke valve exercise during nomal plant operation ard full valve exercise during cold shutdown.

III. Basis For Requesting Relief:

2e core flood tanks have a static inventory of borated water.

We major loss of inventory results from I

sampliry for chemical assay.

Makt.up of borated water is not periodic and is not sufficient to full stroke open these valves.

We rorT:el position of these valves and the position required to fulfill their I

intended function is closed. Stroke testing would not provide assurance that these valves would perfom their intended function.

Werefore,

(

stroke testing is unn - m ry.

l IV.

Alternate Examination: his valve is subject to 10CFR50 Appenlix J 'Iype l

C leak rate testing during each refueling outage.

i V.

Implementation Schcdule:

2e alternate examination program require-l ments are currently being ret.

1 1

l l

l i

l

[

RELIEF RD2UEST #

Fk>rida DEERVICE INSHrfICN V-190 I

P AND ME HMAM Po. 2..enwr PAGE i OF 1

CR(SIAL RIVER I. NIT 3 ce REYlSON 2

Reference Cbde: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.

I.

Ccruponent For hhich Exer:ptiort/ Relief Is Requested:

a) Name and identification number (campcnent tag): MUV-36, MUV-37, MUV-42, MN-43, MUV-160, MUV-161, MUV-163, aM FUV-164 - Makeup System to RCS check valves.

b) Function: These valves operate to supply high pressure injection flow during a ICCA.

c) ASME Section III Cbde Class: 1.

d) Valve Category: C.

II.

Reference Code Requirement That Has Been Detemined 7b Be Impractical:

IWV-3522; Partial stroke valve exercising during nomal operation for all of these valves except MUV-43 and MUV-161 aM full stroke valvo exercise during cold shutdown for all of these valves.

III. Basis For Requestiry Relief:

These valves are check valves which form the reactor coolant pressure bcundary in the high pressure injection lines.

With the exception of l

MUV-43 and MUV-161, which are part of the normal makeup flow path, these l

valves cannot be exercised during plant operation without causing themal cycling at the high pressure injection nozzles. Valves MN-43 and MUV-161 are partial stroke exercised during nomal operation by virtue of the fact that they caprise part of the normal mkeup path and must respond to makeup flow conditions. None of these valves can be full stroke exercised during cold shutdcuns because of lcw-temperature overpressurization (IIIOP) ca cerns.

l l

IV.

Altermte Examination: These valves will be full flow tested each I

refueling outage.

V.

Irplementation Scnedule:

The Alternate Examination requirements will be mt beginning at the next refueling cutage.

PFLTFF REQUEST #

@ @Po..w.e M

INSHNICE INSIECI'ICH V-200 1" " "E ""

er ce 2

es CRYSIAL RIVEit INIT 3 PAGE 1 OF 1

arve.

2 Reference Cod _e_1 ASME Boiler ard Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.

I.

Ctznpanent For Khich Exenptiorg/ Relief Is Requested:

a) Name ard identification number (ccurponent tag): MUV-60 and MUV Borated Water Storage Tank to Makeup lbps Suction Header check valves.

b) RInction: These valves open to allw flow frcxn the Borated Water Storage Tank (BWST) to the Makeup Pu:rps and close to prevent backflw to the WST when HPI/LPI are in the "piggyback" node of opemtion.

c) ASME Section III Code Class: 2.

d) Valve Category: C.

II.

Reference Code Requirement That Has Been Determined Ib Be Irpractical:

IW-3522 ; Partial stroke valve exercising during normal operation and full stroke valva exercise durirg cold shutdwn.

III. Basis For Requesting Relief:

These valves cannot be stroked durirg nomal plant operation because to do so would require injection of water frcan the WST into the reactor vessel.

This could upset reactor boron concentration.

These valves cannot be full stroke exercised durirq cold shutdowns because of lw-temperature overpressurization (LTCP) concerns.

IV.

Alternate Examination: Each refuelirg outage, at least one of these valves (altermte valve each cutage) shall be dimWlod and inspected as describcd belw.

If tha inspected valve is found to be degraded to the extent it cannot perfom its function, then the other valve shall be dimeled and irspected an described belw.

The subsequent inspection may start again with a siryle valve.

The inspection shall assure that the valve disk has freedczn of movemnt I

and is capable of full stroke.

Additionally, the general condition of the valve internals shall be checked for structural degradation including the presence of any lcose parts, debris ard abnorml or excessive corrosion products, wear ard erosion.

l V.

Implenentation Schedule:

The Alternate Dcamination requituments will be met, beginnity during the next refueling cutage.

l l

l RFLTEF RDQUEST #

@@Po..c..e.es INIHNIG I}c5m;nCH V-210

"'^"ov^t" -

wr PAGE 1 OF 1

CRSIAL RIVDt 1 NIT 3 ce as"' "

2 Referenca Ctde: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition thrtogh sumer 1983 acklenda.

I.

Cacponent For Which Dcenption/ Relief Is Requested:

a) Name and identification number (ccarponent tag): All power-operated valves with stroke times of less than two somnds, b) Functiont Various c) ASME Section III Code Class: 2, 3.

d) Valve Category: A, B.

II.

Ecference Code Requirement 'Ihat Has Been Detemined 'Ib Be Impractical IW-3417 (a) requirement that valves (with a stroke cime of less than 10 socords) which exhibit an increase in stroke time of 50% or more frcra a previous test be tested monthly.

III. Basis For Requestirg Relief: "Fast actirg" valves (stroke time of less than two semrxis) are not trended to ao:nrately irdicate an increase in stroke time of 50% frtra a previcus test.

Many of these valves stroke instantly ard a 50% increase is insignificant.

IV.

Alternate D< amination: "Fast acting" valves will be assigned a maximum stroke tine limit of two secords.

Corrective action for valves which exceed this stroke time limit will be initiated in accordance with the requi.mts of IW-3417(b).

V.

Imple:rentation Schedule:

'Ihe Alternate Examination requirenents will be met as applicable.

RELIEF RB2UEST #

O @o.o@..e, n INSmVICE IMPECfICN V-320

" ^"o "8 ""*

P.w r QUSIAL RIVER INIT 3 PAGE 1 OF 2

u n moon 2

Reference Code: ASME Boiler ard Pressure Vessel Code,Section XI, 1983 edition through summer 1983 addenda.

I.

OcInponent For hhich Dcemptiorg/ Relief Is Requested:

a) Name and identification number (cmponent tag): All 71ves identified as not practical to be tested durim nonal plant ope ; 'on, but are tested durity cold shutdowns.

b) Function: Various c) ASME Section III Code Class: 1, 2, and 3.

d) Valvo Category: B, and C II.

Rcference Ccde Requirement That Has Been Determinoi To Be LTractical:

IW-3412(a)- valve exercisirg during every cold shutdown that occurs at intervals exceeding three nonths.

failsafe valve e:<ercisirs duriry every cold shutdc. that IW-3415 occurs at intervals exceedirg three nonths.

IW-3522 - check valve exercisirg durirg every cold shutdown that occurs at intervals exceeding three nonths.

III. Basis For Requesting Relief: Section XI does not provide for avoidance of startup delays khich could occur while ccrpletiry In Service 7bsting (IST) durirq cold shutdcwns. Florida Power Corporation is subnittiry the issue as a Relief Request to define the approach being taken at Crystal River Urit 3 and to obtain rcqulatory concurrence with our posi' ion.

IV.

Alternate Examination: Cold shutdown valve testirg need not be ccx:pleted prior to startup, provided that the prcgram is governed as follows:

1) Cold shutdown valve testing will camence as soon as practical after achievirg cold shutdcun, bat in no case later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after achieving cold shutdown;

2) Valve testiry will continue (on a "best effort" basis) until all testing is ccrplete, or the plant is ready for restart;

3) Orpletion of valve testing is not a prercquisite to return to power;

i RELIEF REQUEST #

i9 @e. 2..e, e-M INSDNIG DEPECnm V-320 r

Pow r

"'ENENM QUSIAL RIWR LNIT 3 PAGE 2 OF 2

c naviscN 2

4) Any testirg not ocmplete (ie. valve tests not finished or valves not tested) should be perfonned during any subsequent cold shutdown, beginninJ with those specific valve tests not capleted in the earlier cutage; If a cold shutdown cutage is planned for a sufficient duration, or if there is a cold shutdcun in whid1 testire is not begun within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then the valve testing must be occpleted prior to startup.

NUIE:

For the purpose of this relief request, the words "cold shutdown" are defined as the Crystal River Unit 3 Technical Specification reactor rode 5.

V.

Irplementation Sctiedule:

'Ihe Alternate Examination requirements will be met as applicable.

l l

l

RELIEF RB20EST #

9 @Po...w..e, n IIEERVIG INSPECI'ICN V-330 IMP AND VAWE EM r

GYSIAL RIVER UNIT 3 PAGE 1 OF 1

ce

""'5*

2 Reference Code: ASME Boiler ard Pressure Vessel Code,Section XI, 1983 edition through sumer 1983 acklenda.

I.

Octaponent For hhich Exemption / Relief Is Requested:

a) Name and identification number (cctnponent tag): All valves tested khen the plant is in cold shutdown.

I b) Function: Various c) ASME Section III Code Class: 1, 2, ard 3.

d) Valve Category: A, B, ard C II.

Reference Ocde Requirunent 'Ihat Has Been Determined 'Ib Be Impractical:

IW-3417(b)/IW-3523; hhen corrective action is required as a result of tests made during cold shutdcun, the cordition shall be corrected before startup.

III. Basis For Requestirg Relief: Section XI does not define often used

1. 1 rases such as "cold shutdown" or "startup".

In the referenced paragraphs, the Code uses the word "startup" in an ambigucus manner. 'Ihe "s+W" sequence is more closely defincd in the CI'/stal River Unit 3 Technical Specifications by referencing reactor operational modes khich are based on measurable parameters (ie. RCS pressure and temperature).

Additionally, the Technical Specifications require the operability of valves, either directly by Tag 1Arnber or iniirectly through system or sub-system operability requirements. Because the 'Ibchnical Specifications provide a more ccr1plete definition, Florida Pcuer Corporation requests substitution of the Technical Specification requirements for the word "startup" in IW-3417(b) ard IW-3523.

IV.

Alternate Examination: Operability status and rode change restrictions I

are to be determined in accorance with the Tec:hnical Specifications. 'Ihe corrective action and subsequent test, required by Section XI, shall be ccrpleted prior to placing the reactor in the applicable operational mode.

If a valve is required to be tested by Section XI, but not identified by the 'Ibchnical Specifications, then corrective action ard subsequent testirg will not restrict mode changes but shall be ccxapleted prior to placim the affected system in service.

V.

Implementation Schedule:

'Ihe Altermte Examination requirements will be met as applicable.

I

RELIEF RD:TdEST #

Florida INSTVICE Desm;nm V-360 I

N AND M E N M Po.. e..e. :r w

PAGE 1 oF i

GYSTAL RIVER INff 3 cc

• 5*"

2 Reference Code: ASME Boiler ard Pressure Vessel Ctde,Section XI, 1983 edition through sumer 1983 adderda.

6 I. Ccxtpornit For hhich Exemption Is Roquested:

a)

Name and identification number (ocanponent tag):

CAV-2, CAV-431-Reactor Coolant Sanple Line isolation valves to the Nuclear Sanple Rocra and Post-Accident Sampling System, respectively.

b)

Function: Reactor Coolant Sample Line Isolation.

c)

ASME Section III Code Class:

2.

d)

Valve Category: A/B.

t II.

Reference Code Requiremnt 'Ihat Has Been Determined 'Ib Be Impractical:

IWP-3300; Observation of valve position to verify accurate ra-ote position irdication.

III. Basis For Roquestirq Relief:

'Iheso are solenoid cperated valves.

Wo solenoid operators e enclosed in a "can" that is seal velded closcd.

'Ihere is nu method to visually verify the valve stem position without cuttirq the closure weld.

IV. Alternate Examination:

Verification that valve position is accurately irdicated by re::ote indicators will be accrrnplished irdirectly by observation of affected system parameters when the valves are manipulated.

'Ihese paramters can include items such as establishment ard cessation of flcu, or change in irdicated system pressure or level.

'Ibese test methods will be incorporated into the plant procedures and the tests will be performed during each refueling outage.

(Crystal River is currently cperatirg on a ncaninal 24 month fuel cycle.)

V.

Irplementation Schedule:

'Ihe Alternate Examination requirements will be met, bcginning durity the next refueliry cutage.

\\

l l

Rn rw Regcest #

1 l

.m l

INSIRVICS INSHDCNCH V-362 IWP MO VA EHMW P, o. 3.. e. e,wr PAGE 1 OF 1

CRYSIAL RIVIR WIT 3 n

amscu o

Reference Ctdel ASME BGiler and Pressure Vessel Code,Section XI, 1983 edition through stmtur 1983 addenda.

I.

Ocuponent For Whidi Exemption Is l<equested:

a) Name ard identification ntmber (ccrponent tag):

O N-90, O N-97, ON-101, ON-108 - EFIC Roca dedicated chillers isolation valves, b) RInction:

Isolation of the EFIC Rocn Coolers frca the normal chillers ard alignment of the "Apperdix R" dedicattd chillers.

c) ASME Section III Code Class:

3.

d) Valve Categorf:

B.

II.

Reference Code Requiremnt That Has Been Deterrained Ib Be Irpractical:

IWP-3300; Observation of valve position to verify accurate remote position irdication.

III. Basis Tor Requestirg Relief:

These are solenoid cperated valves.

The solenoid operators are enclosed in a "can" that is seal welded closcd.

There is no methcd to visually verify the vnive stem positien without cutting the closure weld.

IV.

Alternate Examination:

VerifJcation that valve position is accurately irdicated by remote irdicators will be acomplished inclirectly by observation of affected system parameters wnen the valves are manip 11ated.

These parameters can inchde items such as establishmnt ard cessation of f1cu, or change in irdicated system pressure or level.

These test methods will be incorporated into the plant procedures arl.1 the tests will be perfomed during each refueling cutage.

(Crystal River is currently operating on a ncninal 24 month fuel cycle.)

V.

Irplementation Schedule:

The Altermte Examination requirements will be met, beginnirs during the next refueling outage.

C

I FFTM RDQUIST #

Florida msmv1cs 1amrICs v-3s4 N M ME HUM

! Po. 3..e. e swr PAGE OF GYSIAL RIVER UNIT 3 i

L

e.

• ScN o

Reference Code: ASME Boiler ard Pressurs Vcssel Cbde, Section XT, 1983 cdition through summer 1983 addenda.

I.

Camponent For hhich Exemption Is Requested:

a) Name and identification nutter (cxrponent tag):

EFV-55, EFV-56, EFV-57, EFV Emergency Food'*ater injection flos control valves, b) Function:

Control the flow to the Steam Generators frm the Emergency Feedwater Pumps, c) ASPE Section III Cbde Class:

2.

d) Valve Categol,f:

B.

II.

Reference Code Requirement Eat Has Been Determined 'Ib Be Irpractical:

IWP-3300; Observation of valve position to verify accurate remote position indication.

III. Basis For Requestirg Relief:

Resa are solenoid operatcd valves.

Se solenoid operators are enclosed in a "can" that is seal weldM closed.

Were is to method to visually verify the valve stem position without cutting the closure weld.

IV.

Alternate Examination: Verification that valve position is acuirately irdicated by remote indicators will M accmplished indirectly by observation of affected system parameters when the valves are manipulatcd.

Bese parameters can include items such as establish ent ard cessation of flcw, or charge in irdicated system pressure or level.

mese test methcds will be incorporated into the plant procedures ard the t

tests will be perfomed during each refueling outage.

(Crystal River is currently operating on a rmiml 24 month fuel cycle.)

If no "indirect" test method can be deviscd, then Florida Pty*er l

l Corporation will cut the seal veld and perfom a direct visual verification at each refuelirg.

j V.

Irplementation Schedule:

We Altermte Examimtion regainsnents will be met, bcginning during the next refueli:y3 cutage.

l l

l l

l l

l

EntnN RD20EST #

4 Florida ImmVIG. IEPECPION V-370 MP AND M B0GRM Powe. nr PAGE 1 OF 1

QUSIAL RIVER UNIT 3 ee.o..

es*

0 EeLerence Code: ASME Boiler and Pressure Vessel Code,Section XI, 1983 edition through wmer 1983 acklenda.

I.

Omponent For Which Exe:rption/ Relief Is Requested:

GP-1A, GP-1B, milled Water Pumps.

a) Nam and identification nu:rber (ccuponent tag):

GP-1A, GP-1B, Chilled Water Ptmps.

b) Function: 'Ib pmvide coaling water flw to chillers which cool the control complex, including the ES Switchgear Rracn.

c) ASME Section III Ocrie Class: 3.

d) Valve Category: N/A II.

Peferen Ocde Requixement 'Ihat Has Been Determined To Be Irpractical:

I'dP--3100; Table IWP-3100 requirements for Iraasurity flow rates during pmp inservice tests.

III.

Basis For Requesting Relief: he currently installed flow measurement insttunent has degraded to the point that it no longer mets the accuracy requi2Tments of lWP-4600.

Florida Ebwer Corporation is pursuing a perranent replacemnt flow measuring device.

We instrument manufacturer is present3y reporting a 6 to 8 month lead time for delivery of the new instrument.

Florida Power Corporation is also testing an interim flow measurirq device that can be employed until the pexmanent replacemnt is installed.

However, it is not known whether this device will function properly or meet the accuracy requirements of IWP-4600.

IV.

Altemate F.xamination: We Section XI test will be performed, quarterly, cbtaining all required data, except flcw rate, until the replacement instrument is obtained.

he interim instrument readings will be recorded for "informtion" purposes if the instrument functions properly.

In addition to these tests, the plant operators perform a Technical Specification Itquired functiercil check of this system every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, by observiry Control Ccrplex ait temperatures.

he control cc*rplex air temperature is controlled by heat removal thrmgh the Chilled Water System.

An unacceptable increase in air terperature could be indicative of a degadation in pmp performnce.

Rese alternate examinations will provida resonable assurance of c ntinual proper operation of the chilled Water Pumps until proper 3mr.runentation is obtained arrl installed.

V.

Inplementation Schedule:

he Alternato Examination requiremnts are carrently beirs met.

Installation of the penmnent instrurent will be accomplished prior to return to power irate the next refuelity cutage.

..g i

)

1 1

I i

i ATTACHMENT 2 i

I l

r l

i 1

l 1

I l

i I

l l

l 1

t-k

Request No.

Status Comments V-020 Withdrawn The Pump and valve Program will tus revised to indicate that valve ASV-23 is passive and Section XI test requirements are not applicable.

V-030 No Change V-111 Revised The request now contains a commitment to install flow rate instrumentation or devise an alternate increased flow test for the Emergency Feedwater Pumps.

In either case, schedular exemption is requested until the next refueling outage.

V-112 Revised The request now reflects an alternate method being employed to measure diesel fuel oil transfer pump flow rate.

V-ll5 No Change V-120 Revised The request clearly indicates that one of the two valves (BSV-150 and 151) will be disassembled and inspected each refueling. Reference to valve disk lift force measurement requirements has been deleted.

V-123 Withdrawn The Pump And Valve Program will be revised to indicate that valve DHV-93 is category A/C, passive and Section XI exercise test require-ments are not applicable.

V-128 Revised The request now indicates that valves CFV-1 and CFV-3 are partial stroke exercised during entry into or return to power from cold shutdown and that they are partial stroked utilizing decay heat removal flow.

The request also clearly indicates that one of these two valves will be disassembled and inspected each refueling outage.

t

c.* +

Request No.

Status Comments V-129 Revised The request now indicates that valves CFV-2 and CFV-4 are partial stroke exercised during entry into or return to power form cold shutdown.

The request also clearly indicates that one of these two valves will be disassembled and inspected each refueling outage.

V-130 Withdrawn The Pump and Valve Program will be revised to indicate that CFV-2 and CFV-4 are Category C valves.

V-131/132 Revised The request now indicates that these valves are partial stroke exercised monthly and full stroke exercised once per 18 months during during diesel testing.

V-150 No Change V-160 No Change V-170 No Change V-181 Withdrawn The Pump and Valve Program will be revised to indicate that FSV-261 and FSV-262 are Category A and Category A/C passive valves and as such, have no exercise test requirements.

V-190 Revised This request now indicates that valves MUV-43 and MUV-161 are partial stroke exercised during normal plant operation.

l l

V-195 Withdrawn The Pump and Valve Program will be i

revised to indicate that FWV-45 and FWV-46 are exempt from testing and valves FWV-29, 30, 31, 32, 33, and l

36 will be exercised during cold shutdowns instead.

V-200 Revised This request now indicates that MUV-60 and MUV-72 cannot be full i

stroke exercised during cold shutdown because of low-temperature I

overpressurization concerns.

l l

.* 3 -

Request No.

Status Comments V-210 Revised The request now indicates that corrective action will be taken if "fast acting" valve stroke times-exceed two seconds.

V-283 Withdrawn The Pump and Valve Program will be revised to indicate that valve SFV-86 performs.no safety function and as such, has no inservice testing requiremGnts.

V-320 Revised The request no longer references a nine month test interval for check valve exercising.

V-330 Revised This request now specifically addresses the repairs and post maintenance testing of valves found inoperable during cold shutdown testing.

The effect on plant "startup" vs. mode change of the Technical Specification operability l

requirements is clearly defined.

V-360 Revised This request had been divided into three requests, V-360, Y-362 and V-364. All of these requests I

specify that accurate valve position indication will be l

determined by observing a system parameter affected by the position l

of the valve.

Valves ASV-195 and ASV-196 were determined not to fall within the scope of IWV-1100 and have been withdrawn from the relief request.

V-370 Revised This request now indicates that l

relief from Section XI inservice l

testing requirements is required l

until flow instrumentation can be l

installed in the Chilled Water l

System.

I l

l l

l

,,m

. o o In addition to the items detailed above the Pump and Valve Program will be revised to include justification for each valve that is tested only during cold shutdowns or refueling outages.

The justifications will include the following information:

1) Identification of the valve,

2) Reason the valve can not be tested during plant operation,

3) Description of the alternate test to be performed,

4) The position to which the valve is tested (ie, safety function position).

1 1

1