ML17309A807

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

ML17309A807
Person / Time
Site:	Saint Lucie
Issue date:	12/04/1995
From:	SAGER D A FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17228B347	List: ML17228B346 ML17309A807
References
L-95-320, NUDOCS 9512110297
Download: ML17309A807 (35)

Text

P RIG RITY 3 (ACCELERATED RIDS PROCI'.SSIiG REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9512110297 DOC.DATE: 95/12/04 NOTARIZED:

NO DOCKET N FACIL:50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.05000389 AUTH.NAME AUTHOR AFFILIATION SAGER,D.A.

Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards Rev 0 to Plant Administrative Procedure 2-0010024,"Inservice Testing Program for Pumps&Valves." DISTRIBUTION CODE: A047D COPIES RECEIVED LTR ENCL SIZE: TITLE: OR Submittal:

Inservice/Testing/Relief from ASM Code-GL-89-04/NOTES RECIPIENT ID CODE/NAME PD2-1 LA NORRIS,J INTERNAL: ACRS 01 E EMCB NUDOCS-ABSTRACT RES/DET/EMMEB EXTERNAL: LITCO ANDERSON NRC PDR COPIES LTTR ENCL 1 1 1 1 6 0 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD2-1 PD AEOD/SPD/RAB NRR/DE/ECGB NRR/DE/EMEB OGC/HDS3 RES/DSIR/EIB NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 0 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVKSTE!CONTACT I'I IE DOCL'i!ENT CONTROL DESk, ROOM Pl.37 (EXT.504.~0S3)TO ELI XI!NATE YOL" R iAXIL Pl<Oil DISTRIBUTION LISTS I'OR DOCL MEN'I'S YOL'ON" I'I I~D!TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 14 Florida Power&Light Company, P.O.Box128, Fort Pierce, FL34954-0128 December 4, 1995 r,-95-320 10 CFR 50.4 10 CFR 50.55a U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 RE: St.Lucie Unit 2 Docket No.50-389 In-Service Test Program-Revision 2 Second Ten-Year Interval Res onse to Safet Evaluation 0 en Items On May 2, 1994, NRC issued a safety evaluation (SE)on the second ten-year interval in-service test (IST)program, Revision 0, for St.Lucie Unit 2.Included with the NRC SE was a copy of the NRC contractor's technical evaluation report (TER).For certain relief requests, implementation was granted, authorized, or approved as acceptable provided the action items or anomalies identified in Section 5 of the TER were addressed within one year of the date of the SE or by the end of the next refueling outage, which ever was later.Attachment 1 provides a response or clarification to each TER action item.Several of the items identified in the TER were previously addressed in Revision 1 of the IST program which was submitted to the NRC by FPL letter L-94-212 dated August 22, 1994.This revision of the Unit 2 second ten-year interval IST program has been issued as plant administrative procedure, AP 2-0010024 Revision 0.A copy of this procedure is enclosed for your information.

Please contact us if there are any questions about this submittal.

Very truly yours, D.A.Vice St.L ger esident ie Plant DAS/GRM cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St.Lucie Plant ADGCK pgpp()pBp PDR an FPL Group company h

St.Lucie Unit 2 Docket No.50-389 In-Service Test Program-Revision 2 Second Ten-Year Interval Response to Safety Evaluation Open Items In-Service Test Program Revision 2 Second Ten-Year Interval Response to NRC Safety Evaluation Open Items 12/04/95....

9512110297 BACKGROUND On September 15, 1992, FPL letter L-92-247 transmitted Revision 2 of the first ten-year interval IST program to the NRC.This revision was a complete revision of the program to incorporate the guidance of Generic Letter 89-04, Guidance on developing Acceptable Inservice Testing Programs.On August 3, 1993, FPL letter L-93-184 transmitted Revision 0 of the second ten-year interval IST program to the NRC.The second ten-year interval began on August 8,,1993.On August 23, 1993, NRC issued the safety evaluation (SE)on Revision 2 of the first ten-year interval IST program.This SE included a copy of the NRC contractor's technical evaluation report (TER).Section 4 of the TER included action items which the NRC requested FPL to address within one year of the date of the SE or the next refueling outage which ever was later.On August 22, 1994, FPL letter L-94-212 transmitted Revision 1 of the second ten-year interval IST program to address NRC open items identified in the August 23, 1993 SE and NRC contractor's TER.These open items were carried forward from the first ten-year interval IST program.On May 2, 1994, the NRC issued the SE for Revision 0 of the second ten-year interval IST program.Included with the NRC SE was a copy of the NRC contractor's technical evaluation report (TER).For certain relief requests, implementation was granted, authorized, or approved as acceptable provided the action items or anomalies identified in Section 5 of the TER were addressed within one year of the date of the SE or by the end of the next refueling outage, which ever was later.Several of these items were previously addressed in Revision 1 of the second ten-year interval IST program.This submittal provides a response to the remaining action items and anomalies.

The recommended actions from each subpart of the TER Section 5 have been listed below along with the St.Lucie response.For items which duplicated open items from the August 23, 1993 NRC SE, and which were previously addressed in Revision 1 of the second ten-year interval IST program only a cross reference is provided.TER Section 5.1 NRC Recommended Action: The IST Program does not include a description of: how the components were selected, how testing requirements were identified for each component, or the safety function of the valves.The review performed for this TER did not include verification that all pumps and valves within the scope of 10 CFR 50.55a and Section XI are contained in the IST Program, and did not ensure that all 0

applicable testing requirements have been identified.

The licensee is requested.to include this information in the IST Program.The program should describe the development process, such as a listing of the documents used, the method of the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59.Additionally, for each interval, the licensee should maintain an accurate status of the relief requests including their revision and NRC approval.St.Lucie Response: This action"item is identical to item 4.1 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE and incorporated the changes into Revision 1 of the second ten-year interval IST program which was transmitted by FPL letter, L-94-212 dated August 22, 1994.NRC Recommended Action: The licensee has deleted the diesel air start and fuel oil, and instrument air system from the IST Program.The licensee explains in the summary of changes between Revision 2 of the First Interval to Revision 0 of the, Second Interval that these systems are not required to be built to ASME Class 1, 2, or 3 standards per Regulatory Guide 1.26, but"were built to Class standards at the option of FPL.In accordance with IWA-1300(e)(sic), including the pumps and valves in these systems in the IST program was at the option of FPL and not a requirement.

Paragraph IWA-1320(e) states that"If systems safety criteria permit a system to be nonnuclear safety Class and an Owner optionally classifies and constructs that system, or a portion thereof, to Class 2 or 3 requirements, the application of the rules of (a)above is at the option of the Owner and is not a requirement of this Division." Section 3.2.2 of the FSAR, however, states that the diesel systems are safety-related Quality Group C components and are required to be built to Section III, Class 3 requirements.

Components were classified per the FSAR in accordance with ANSI N18.2, as well as Regulatory Guide 1.26.The regulations require pumps and valves classified by the Owner as Class 1, 2, or 3 to be tested in accordance with Section XI.The regulations do not limit the scope of the IST program to only those systems discussed in Regulatory Guide 1.26.The IST program scope should be consistent with the classification of components in the safety analysis report.The IST Program or FSAR should be revised accordingly.

St.Lucie Response: The diesel air start and fuel oil, and instrument air systems were previously in the IST program because they were built and are maintained to Quality Group B and C requirements.

Additionally, FSAR Table 3.2-1 lists the diesel fuel oil system as Quality Group C (ASME Class 3).However, these classifications were previously considered as optional upgrades since Regulatory Guide 1.26 does not require these systems to be included in Quality Groups A, B, or C.Regulatory Guide 1.26 is the governing document for system Quality Group classifications since FSAR Section 3.2.2 states that"System safety classifications and design and fabrication requirements meet the intent of Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants, February 1976 (R3)." These systems do not require testing per the Code since Paragraph IWA-1320.(e) states that"If systems safety criteria permit a system to be nonnuclear safety Class and an Owner optionally classifies and constructs that system, or a portion thereof, to Class 2 or 3 requirements, the application of the rules of (a)is at the option of the Owner and not a requirement of this Division." In other words, those systems which were constructed to Class 2 or 3 at the option of the Owner do not fall under the scope of Section XI, and therefore are not required to be tested to the Code standards.

The diesel air start and fuel oil system were reviewed by owner engineering evaluation to confirm that the classification as Quality Group C was a result of owner optional upgrade.The evaluation concluded that this was indeed the case based on detailed discussion of the quality group ratings for the diesel generator auxiliary systems in NUREG-0843,"Safety Evaluation Report related to the operation of St.Lucie Plant, Unit No.2" (SE)October 1981.Section 9.5.4 notes that the components are intentionally over designed and are considered equivalent to a system designed to ASME section III Class 3 requirements.

FSAR Section 3.2.2 also states that"Systems important to safety and the containment boundary are classified in accordance with ANSI N18.2,..." The diesel air start and fuel oil systems are classified as Safety Class 3 by ANSI N18.2.Recognizing that the systems are important to nuclear safety, testing of the safety related pumps and valves is required.Appropriate testing'commensurate to the systems safety function have been and will continue to be performed, but not under the jurisdiction of the ASME IST program.The diesel air start and fuel oil systems will still be maintained to the Quality Group 3 classification to which they have been upgraded to.Revision to the FSAR has been made as a result of the evaluation to reflect the optional owner upgrade status of these systems.Though the FSAR design bases states that"The system serves no safety function...", a separate evaluation of the instrument air system could not confirm the status for particular valves as an owner optional upgrade to Quality Group B or C based on the design classification requirements unrelated to the overall system function.Therefore, these quality group B valves which serve a safety function have been included in the scope of the current IST program revision.During the time in which these valves did not appear in the IST program document, St.Lucie continued to test these valves by the existing plant procedures at the frequency and to the requirements of the current IST program.TER Section 5.2 NRC Recommended Acti.on: The IST Program's scope was reviewed for selected systems.The pumps and valves in the Auxiliary Feedwater System, Main Steam, Chemical and Volume Control System and Component Cooling Water System were reviewed against the requirements of Section XI and the regulations.

The FSAR was used to determine if the specified valve categories and valve functions were consistent with the plant's safety analyses.The review results showed compliance with the Code, except for the following items.The licensee should review these items and make changes to the IST Program, where appropriate.

Additionally, the licensee should verify that there are not similar problems with the IST Program for other systems.St.Lucie Response: The functions of all Quality Group A, B, and C valves have recently been reviewed to upgrade the IST Programs Basis Documentation.

This Basis Documentation identifies and explains why individual valves are included or not included in the IST Program.The FSAR and other plant documents were used in this upgrade to determine if the specified valve categories and valve functions warrant the valves inclusion in the IST Program.Many of the valves identified have been included or excluded from the IST Program for one of the following reasons: 1.Where multiple components are capable of performing the same equivalent and redundant specified function (eg.multiple valves closing in series)and where the components are not supplied by alternate and redundant power supplies, only one need be included in the program.The component must be relied upon to perform and not simply have the capability of performance.

This exemption only applies where licensing documents do not take credit for the designed redundancy.

Components performing a redundant function shall be included in the testing program if, in the process of analysis or licensing justification, they are relied upon to be operable.2.Valves installed primarily for the purpose of providing convenient operational flexibility (eg.system cross-connects) that are not required to operate, assuming that the designated first-line systems and components operate satisfactorily, need not be included in the IST Program.This does not exclude active valves that could be called upon as a result of optional system lineups existing prior to the initiation of an accident.NRC Recommended Action:

A.Auxiliary Feedwater and Main Steam Systems-Since part of the Auxiliary Feedwater System is shown on the flow diagram for the Main Steam System, the results of the review for these two systems are presented jointly.The reference drawings are: 2998-G-080, Sheet 2 of 2, Rev.18,"Flow Diagram-Feedwater 8 Condensate Systems," and 2998-G-079, Sheet-1 of 6, Rev.16,"Flow Diagram-Main Steam System-Sheet No.1." The following items were identified:

1.The licensee should review the basis for including and excluding locked open manual valves in the Program.Specifically, the following locked open manual valves which are located on the AFW discharge lines upstream of the steam generators and downstream of normally closed motor operated valves are included in the program: 2I-V-09120, 2I-V-09152, 2I-V-09136, and 2I-V-09158 (The licensee should note that the drawing coordinates are incorrectly listed in the program table for the above valves), while the following valves located immediately upstream of the normally closed motor operated valves are not included in the program: 2I-V-09108, 2I-V-09124, and 2I-V-09140.(There are other locked open manual valves on the AFW pumps'ecirculation lines to the condensate storage tank and also on the pumps'uction lines which are not included in the program)St.Lucie Response: Locked open manual valves are included in the Program only if they are relied upon to perform a specific function in shutting down the reactor to the cold shutdown condition or in mitigating the consequences of an accident.Plant emergency operating procedures direct that the AFW discharge line manual operated valves: V-09120, V-09152, V-09136, and V-09158 be closed to isolate the affected steam generator in the event of a steam generator tube rupture.These valves are relied upon to close to control the unrestricted release of fission products and are therefore included in the program.The program table has been revised to correctly list the drawing coordinates for the above valves.NRC Recommended Action: 2.For the following check valves, the licensee should verify that the valves do not perform a safety function in the closed position: 2I-V-09252 and 09294, steam generator feedwater line check valves inside containment.

2I-V-09107, 09119, 09123, and 09135, AFW pumps'ischarge line check valves downstream of normally closed motor operated valves.2I-V-09139, 09151, and 09157, AFW pumps'ischarge line check valves immediately adjacent to pump discharge.

St.Lucie Response: V-09252 and V-09294: Isolation of the steam generators is provided by the main feedwater block valves and auxiliary feedwater isolation valves, therefore closure of these valves is not required.V-09119, V-09135, V-'09151, and V-09157: The only closure function is to prevent reverse flow in the event of a passive failure of the auxiliary feedwater header upstream of these valves.This is a redundant function to the normally closed auxiliary feedwater isolation motor operated valves, MV-09-09 through MV-09-12 which are located in close proximity within the quality group B boundary and are credited with performing the containment isolation function as well.Therefore, testing the closure function of these valves is not required.V-09107, V-09123, and V-09139: The auxiliary feedwater supply lines are separated by normally closed cross-tie valves, closure of these valve is not relied upon.These valves would only be required to close if is desired to feed the"2B" steam generator with the"2A" auxiliary feedwater pump, or vice-versa.

Since there are already two independent, redundant AFW flow paths to each S/G, this additional flow path is not required.NRC Recommended Action: B.Component Cooling System-The reference drawing for this system is 2998-G-083, Rev.18,"Flow Diagram Component Cooling System." The following items were identified:

1.For the component cooling surge tank, diaphragm'operated vent valve 2-RCV-14-1, and its accompanying solenoid valve RSE-14-1, on top of the tank are shown as interlocked on a high radiation signal, yet neither valve is listed in the program tables.The licensee should verify that these valves do not perform a safety function.St.Lucie Response: RCV-14-1: This quality group D, three way valve normally vents the CCW surge tank to atmosphere.

On a CCW high radiation signal, it shifts to vent the tank to the waste management system in the event that component cooling piping inside containment is damaged.Since passive failure of the CCW piping inside containment is not postulated as a consequence of an accident and, if it occurred, the likely result would be leakage into the containment, testing of this valve is not required.NRC Recommended Acti.on: 2.CCW Pumps suction and discharge header inter-tie valves MV-14-1 and MV-14-3 are shown on the flow diagram as normally closed while the program tables indicate that the normal position is open.Similarly, containment cooling units suction and discharge valves MV-14-9 to MV-14-16 are shown on the flow diagram as locked open while the program tables indicate only that the normal position is open.The licensee should revise either the drawing or the program tables as appropriate.

St.Lucie Response: The CCW Pumps suction and discharge header inter-tie valves MV-14-1 and MV-14-3 and the containment cooling units suction and discharge valves MV-14-9 to MV-14-16 have been removed from the IST Program.The CCW pump suction and discharge header inter-tie valves MV-14-1 and MV-14-3 are opened in the event that either the 2A or 2B CCW pump fails.The 2C pump may then be aligned to the failed pumps header by repositioning, if necessary, the header inter-tie valves.Although this may be'an important function, it is not expected to be required during an accident scenario since two redundant full capacity pumps and essential headers are provided to assure adequate cooling capacity if one system fails.It is not expected that the 2C pump would be required to be aligned to the alternate header during an accident scenario unless the system is subjected to several concurrent active and passive failures, therefore, testing is not required.The containment cooling units suction and discharge valves MV-14-9 to MV-14-16 are locked open to provide containment cooling during a LOCA.This valve is not required to close for containment isolation since the containment fan coolers and associated piping form the containment boundary.NRC Recommended Action: C.Chemical and Volume Control System (CVCS).The reference drawings for this system were: 2998-G-078, Sheet 120, Rev.Control System (Sheet 1)" 2998-G-078, Sheet 121, Rev.Control System (Sheet 2)" 2998-G-078, Sheet 122, Rev.Control System (Sheet 3)" 4,"Flow Diagram-Chemical&Volume 5,"Flow Diagram-Chemical&Volume 5,"Flow Diagram-Chemical&Volume The following items were identified:

1.On Sheet 2, check valves V-2112 (G-3), on the nitrogen supply line to the volume control tank (VCT), V-2188 (F-5), on the boric acid makeup and primary water makeup blending line to the VCT, and V-2308 (F-3), on the discharge of the chemical addition metering pump, form the boundary between safety class and non safety class piping yet none of the three valves are in the IST Program for either an open or close test.The licensee should verify whether 7, these valves should be included in the program, and revise the program, as necessary.

St.Lucie Response: V-2112: This valve opens to admit hydrogen gas to maintain a blanket gas in the VCT during normal operations or to admit nitrogen gas during maintenance periods to control RCS water chemistry.

Neither of these functions are required in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.Failure of this valve to close would not disable the VCT because the gas supply line penetrates the VCT above its normal operating level thus no inventory would be lost.V-2118: This valve opens if the SITs are aligned to the VCT to provide borated water to maintain RCS inventory during plant cooldown.The SIT/VCT intertie is required for plant cooldown should a tornado render the RWT and PWT inoperable.

During an accident this check valve closes to prevent concentrated boric acid from being back fed into the VCT.This function is not required as it is redundant with that of V-2501, VCT discharge isolation valve.V-2308: This stop-check valve is only opened while injecting chemicals into the CVCS system.Adding chemicals to the CVCS is a maintenance item only, and does not perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.Normally, V-2308 is closed using its handwheel to prevent any backflow into the non-seismic chemical addition piping.In this closed position, the valve acts as a passive isolation valve and therefore does not require testing.NRC Recommended Action: 2.In the FSAR,'jl9.3.4.3.2, reference is made to heat-traced piping relief valves which are provided for those portions of the boric acid system that are heat traced and can be isolated individually.

The valves relieve the maximum fluid thermal expansion rate that would occur if maximum duplicate heat tracing power were inadvertently applied to the isolated line.These valves appear'n Sheet 2 as V-2171, V-2631, V-2632, V-2634, V-2636, V-2639, V-2641 and V-2648.However, none of these valves is included in the IST Program.The licensee should verify whether these valves should be included in the program, and revise the program, as necessary.

St.Lucie Response: PSL recently lowered the boric acid concentration requirements for the boric acid makeup system.This change allows for the heat tracing to be deenergized thus eliminating the need for the relief valves to protect the piping from thermal expansion of the boric acid solution.These valves have been physically removed from the CVCS system.These valves do not appear on revision 16 to drawing 2998-G-078, Sheet 121,"Flow Diagram-Chemical&Volume Control System (Sheet 2)".NRC Recommended Action: 3.On Sheet 2, check valves V-2118 and V-2674 (both F-4)are on the outlet line of the VCT leading to the suction of the charging pumps and also upstream of the connection from the boric acid makeup pumpsdischarge to the charging pumps'uction.

Although both valves are included in the program, they are only tested in the open position.The licensee should verify whether the valves perform a safety function in the closed position by preventing backflow into the VCT when the boric acid makeup pumps are in operation, and revise the program, as necessary.

St.Lucie Response: V-2118 and V-2674: These check valves are not required to close because the VCT discharge isolation valve V-2501 can be closed from the control room and automatically closes on SIAS to prevent concentrated boric acid from being back fed into the VCT.NRC Recommended Action: 4.On Sheet 2, check valve V-2191 (E-3)is on a line leading from the refueling water tank (RWT)to outlet line of the VCT which in turn leads to the charging pump suction.It appears that this valve opens to allow the charging pumps to provide boration of the RCS using the RWT to achieve shutdown cooling conditions.

In such a case, the normally closed motor-operated valve V-2504 immediately upstream must be open so that it does not appear that V-2504 could be relied upon to prevent reverse flow.Although V-2191 is in the Program, it is only tested in the open position.The licensee should verify whether V-2191 performs a safety function in the closed position, by preventing reverse flow from other sources such as the chemical addition metering pump and the contents of the VCT, and revise the program, as necessary.

St.Lucie Response: V-2191: Closure of this valve is not required as this function is provided by normally closed isolation valve, V-2504.Additionally, if V-2504 were open and V-2191 failed to close any inventory diverted to the RWT would still be available for emergency boration from the RWT.NRC Recommended Action: 5.In the FSAR, 9 9.3.4.3.2, V-2435 is described as the charging line thermal relief valve which is a spring loaded check valve downstream of the regenerative heat exchanger.

The valve is sized to relieve the maximum fluid thermal expansion rate that occurs if hot letdown flow continued after charging flow was stopped by closing the charging line distribution valves.The valve appears on Sheet 3 (B-7).However, the valve is not included in the program for either an open or close test.The licensee should verify whether this valve should be included in the program, and revise the program, as necessary.

St.Lucie Response: V-2435: In the unlikely event that the charging header is isolated and hot fluid continues, to flow through the letdown side of the regenerative heat exchanger, the fluid in the charging side of the heat exchanger would be subject to expansion.

Under these conditions, this valve is designed to open, thus providing thermal relief protection for the heat exchanger and related piping.During an accident scenario it is not expected that such conditions would exist nor is this considered to be a safety function, thus, testing of this valve to open is not required.The valve is not required to close to perform a safety function.This valve is not at a high pressure/low pressure interface.

Passive failure of, upstream piping is not considered credible as it is designed to operate at pressures exceeding the normal RCS pressure.No single failure of any active component can occur that would divert flow from the RCS through the charging header if this valve were to fail to close.Containment isolation valve V-2523 can also be closed if required.Additionally at least one charging pump will be available to supply flow through this valve during any single failure scenario.NRC Recommended Action: 6.On Sheet 3, check valves V-2431 (D-S), on the pressurizer auxiliary spray line, and V-2432 (C-8)and V-2433 (B-S), on the charging line connections to the RCS, are all located inside containment and appear to form part of the reactor coolant pressure boundary (i.e., forming the boundary between Class 1 and Class 2 piping).Although the valves are included in the program, they are only designated for testing in the open position.The licensee should verify whether the valves perform a safety function in the closed position, and revise the program, as necessary.

St.Lucie Response: V-2431, V-2432, V-2433: These valves are not required to close to perform a safety function.These valves are not at a high pressure/low pressure interface.

Passive failure of upstream piping is not considered credible as it is designed to operate at pressures exceeding the normal RCS pressure.No single failure of any active component can occur that would divert flow from the RCS through the charging header if these valves were to fail to close.Isolation Valves SE-02-1, SE-02-2, SE-02-3, SE-02-4 and V-2523 can also be closed if required.Additionally at least one charging 10 pump will be available to supply flow through this valve during any single failure scenario.TER Section 5.2 NRC Recommended Action: (2nd ste 5.2)As discussed in the TER evaluation for numerous relief requests, specific portions of OMa-1988, Parts 6 and 10 may be utilized without relief, provided all related requirements are implemented.

Approval is recommended pursuant to 5 50.55a%(f)(4)(iv).

The use of specific portions of Part 6 or 10 and any refueling outage justifications should, however, be documented in the IST Program.Implementation of related requirements is subject to NRC inspection.

St.Lucie Response: This action item is identical to item 4.2 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.TER Section 5.3 NRC Recommended Action: Section 4.2 of the IST Program states that the valve test frequency may be extended by 25%, as allowed by the Technical Specifications.

The extension of test intervals should not be applii d to safety and relief valves tested in accordance with the intervals defined in Section XI, because the Technical Specifications do not address these test intervals.

St.Lucie Response: This action item is identical to item 4.3 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.TER Section 5.4 NRC Recommended Action: In Generic Pump Relief Request PR-2, the licensee has requested relief concerning portable instruments used for temperature and speed measurement.

When using temporary instruments, the licensee should ensure that the instruments are calibrated prior to use and are traceable to the inservice test records.(TER Section 2.1.2)St.Lucie Response: This action item is identical to item 4.4 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.11 0

TER Section 5.5 NRC Recommended Action: In Pump Relief Requests PR-8, PR-ll, and PR-15, the licensee is proposing to calculate pump suction pressure based on measuring tank or inlet structure levels.Calculation of inlet pressure based on the measured level provides an acceptable alternative method of determining inlet pressure, provided the calculation is properly proceduralized, and the accuracy is within the accuracy required by the Code using direct measurement.

This should be documented in the test records and be available for review.(TER Sections 2.2.1, 2.3.1, 2.4.1)St.Lucie Response: This action item is identical to item 4.6 of the NRC SE issued August 23, 1993.FPL responded to this action item in'the response to the previous SE.TER Section 5.6 NRC Recommended Action: In Pump Relief Requests PR-12, PR-13, and PR-14, the licensee has requested relief from the ASME Code, Section Xl, 11 IWP-4520(b), which requires that the frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed.Specifically, in PR-12 for the reactor coolant charging pumps, the code-required frequency range is 1.75 Hz to 3.5 Hz.In PR-13 for the intake cooling water pumps, the code-required frequency range is 7.38 Hz to 14.75 Hz.In PR-14 for the containment spray system hydrazine pumps, the code-required frequency range is 0.875 Hz to 1.75 Hz.The licensee claims that instruments satisfying these range requirements are commercially unavailable, and that the lowest available response frequency is 10 Hz.The staff has, however, identified equipment with a frequency response range less than 10 Hz.The licensee should further investigate the procurement of instruments that comply with the Code requirements.

Also, the licensee has not discussed the repeatability and accuracy of the instruments to be used.The licensee should additionally evaluate each pump to determine if the pumps are susceptible to degradation mechanisms that result in increased vibration levels at frequencies lower than 10 Hz.Immediate imposition of the Code requirements is impractical due to limitations in the current instrumentation and it would be an undue burden to require the plant to declare the pumps inoperable until the evaluation of subharmonic frequencies and/or available instrumentation could be reviewed.Relief was recommended for an interim period of one year or until the next refueling outage, whichever is later to perform the evaluations in the August 23, 1993 SE.The interim relief remains in effect into the second ten-year interval.(TER Sections 2.2.2, 2.3.2, 2.4.2)12 St.Lucie Response: This action item is identical to item 4.7 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.TER Section 5.7 NRC Recommended Action: In Pump Relief Request PR-17 for the containment spray hydrazine pumps, the licensee is proposing to measure pump flow rate and vibration quarterly but not alert trend the flow rate.At refueling, the pump flow rate and vibration will be measured.Referring to the licensee's request, it appears that the licensee will not take any corrective actions based on the flow rate measured quarterly exceeding the alert or required action values.The licensee should evaluate the establishment of required action ranges for quarterly testing.The licensee has referenced Section Xl 11 IWP-4150 in the relief request, however the licensee has not discussed the possible use of a symmetrical damping device to provide for flow rate averaging.

Additionally, the licensee has not discussed the impact or burden of installing flow instrumentation that could be used effectively'or the quarterly test.Reference to the licensee's Appendix A, pump program table indicates that the licensee will not measure the pump inlet pressure or differential pressure.The ASME/ANSI Code OMa-1988, Part 6, Table 3b, requires that pump discharge pressure be measured for positive displacement pumps.The licensee has not provided a basis for not measuring pump differential or discharge pressure.Provided the licensee determines that there is no practical means of installing flow instrumentation that is adequate for inservice testing purposes, deferring flowrate measurement to refueling outages may be considered acceptable.

The licensee should evaluate the procurement of damping devices or new flow instrumentation and measure and evaluate quarterly pump differential or discharge pressure as well as vibration.

Immediate imposition of the Code requirements is impractical due to lack of adequate installed flow instrumentation, and it would be an undue burden to require the plant to declare these pumps inoperable until the availability of new instrumentation could be reviewed.Therefore, it is recommended that relief be granted for an interim period of one year, or until the next refueling outage, whichever is later.The interim relief remains in effect into the next ten-year interval due to begin August 9, 1993.In the interim, the licensee should establish acceptance criteria for RPM versus flow rate correlation and take corrective action if needed, and measure discharge pressure, if possible.(TER Section 2.4.3)13 St.Lucie Response: This action item is identical to item 4.8 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.TER Section 5.8 NRC Recommended Action: In Valve Relief Request VR-13, the licensee is proposing to disassemble and inspect every 10 years each of the four 12 in.discharge line check valves in the lines from the safety injection tanks to the reactor coolant system.Exercising closed is to be in accordance with the Technical Specifications regarding pressure isolation valves (P1Vs).Disassembly and inspection should only be used if testing with flow is impractical.

The licensee should provide an analysis or test results to show that the nominal 52 seconds stroke time for the SIT discharge isolation motor-operated valves to open is too long to permit sufficient flow to cause the check valves to reach their full-open position.If a full-open position can be reached, the licensee should perform the test with flow to confirm disk position.To substantiate the acceptability of any alternative technique for verifying that the valves are fully open, licensees must, as a minimum, address and document certain items in the IST program, as described in Position 1.However, if the licensee determines that full-stroke exercising with flow is impractical, the licensee may, as discussed by the NRC in Generic Letter Position 2, perform valve disassembly and inspection as a positive means of determining that a valve's disk will full-stroke exercise open or of verifying closure capability.

The licensee is currently proposing to meet Position 2.Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly.

However, the licensee intends to inspect each check valve only once in the 10 year Inservice Inspection program interval.As defined in Position 2, in order to support extension of the valve disassembly/inspection intervals to longer than once every 6 years, i.e., in cases of" extreme hardship," licensees should perform a review of the installation of each valve addressing the"EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" for problematic locations.

The licensee should justify the extreme hardship, including a discussion on why non-int'rusive techniques cannot be used.Additionally, the licensee states that valves will be leak tested or partial-flow tested following disassembly.

If possible, partial valve stroking quarterly or during cold shutdowns, or after reassembly, must be performed.

Relief is granted per Generic Letter 89-04, Position 1, to full-stroke exercise the valves open with less than the accident flow rate, provided all criteria in Position 1 are met.If the licensee determines that full-stroke exercising is impractical, relief is granted per Position 2 to disassemble/inspect these check valves, provided the licensee meets all the criteria in Position 2, including reviewing the installation of the valves, demonstrating extreme hardship, and partial-stroke exercising following reassembly and at cold shutdown if practical.

With respect to exercising the valve closed, OMa-1988 Part 10, 4.3.2.2 allows full-stroke exercising that is not practicable during operation or cold shutdown to be deferred to refueling outages.Relief to use the Technical Specification requirements is not required pursuant to 550.55a 9(f)(4)(iv), provided the licensee implements 9 4.3.2.2 and all related requirements, including Part 10, 9 4.3.2.2(h) and 96-2.Implementation of these related requirements is subject to NRC inspection.(TER Section 3.2.2)St.Lucie Response: This action item is identical to item 4.9 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.TER Section 5.9 NRC Recommended Action: In Valve Relief Request VR-14, the licensee is proposing to partial-stroke exercise at cold shutdowns and refueling outages the four 12 in.safety injection check valves which open to provide flow paths from 0he safety injection headers to the RCS and close to isolate the headers from the high pressure of the reactor coolant system.The licensee should evaluate if the valves will achieve a full-open position with the proposed reduced test flow rate of 3, 000 GPM.If a full-open position can be reached, the licensee should perform the testing with flow.The use of alternate techniques, such as non-intrusive techniques, to verify that valves will fully open is acceptable, as discussed in Generic Letter 89-04, Position 1.If the valves cannot be full-stroke exercised, the NRC defined an acceptable alternative to'the full-stroke exercising requirement in Position 2, wherein it is stated that the NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full-stroke exercise open or of verifying closure capability.

The licensee is currently proposing to meet Position 2.Assurance of proper reassembly will be provided by performing a leak test or partial-flow test prior to returning a valve to service following disassembly.

However, the licensee intends to inspect each check 15 valve only once in the 10 year inservice inspection program interval.As defined in Position 2, in order to support extension of the valve disassembly/inspection intervals to longer than once every 6 years, i.e., in cases of"extreme hardship," licensees should perform a review of the installation of each valve addressing the"EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" for problematic locations.

The licensee should also include a discussion on why non-intrusive techniques cannot be used.Additionally, the licensee states that the valve will be leak tested or partial-flow tested following disassembly.

Position 2 requires that, if possible, partial valve stroking quarterly or during cold shutdowns, or after reassembly, must be performed.

Relief is granted per Generic Letter 89-04, Position 1, to full-stroke exercise the valves open with less than the accident flow rate, provided all criteria in Position 1 are met.If the licensee determines that full-stroke exercising is impractical, relief is granted per Position 2 to disassemble/inspect these check valves, provided the licensee meets a'll the criteria in Position 2, including reviewing the installation of the valves, demonstrating extreme hardship, and partial-stroke exercising following reassembly and at cold shutdown if practical.

With respect to exercising the valve closed, verification that a valve is in the closed position can be done by visual observation, by an electrical signal initiated by a position-indicating device, by observation of appropriate pressure indication in the system, by leak testing, or by other positive'eans.

The licensee does have instrumentation to continuously monitor upstream pressure.Based on the Technical Specifications, it appears that following the partial-stroke exercise at cold shutdowns, verification that the valves have closed will be performed and relief would not be required.The licensee should exercise these valves closed at cold shutdowns or revise the request accordingly.(TER Section 3.2.3)St.Lucie Response: This action item is identical to item 4.10 of the NRC SE issued August 23, 1993.FPL responded to this action item in the response to the previous SE.TER Section 5.10 NRC Recommended Action: The licensee states in VR-1 that valve testing need not be performed more often than once every cold shutdown, except as provided for in IWV-3417(a), which requires more frequent testing as a result of degraded stroke times.The ASME issued a Code interpretation (Xl-1-92-41) that states that it is the intent of Section Xl, IWV-3410 and 3520, to require testing of valves every three months, including during extended shutdown periods, for valves other than those in systems declared inoperable or not V required to be operable (IWV-3416).

Therefore, during plant shutdown periods, when the valves can be exercised, the licensee should exercise valves every three months in accordance with the Code or provide a relief request.Additionally, if specific valves cannot be tested during any cold shutdown (i.e., due to"the lack of plant conditions needed for testing"), specific approval is required to defer testing.The licensee should revise the cold shutdown justifications, as required, to discuss the conditions under which testing cannot be performed during any cold shutdowns.

St.Lucie Response: Relief request VR-1 has been withdrawn.

OMa-1988, Part 10, 4.2.1.2 (g)and 4.3.2.2 (g)have been authorized for implementation.

The provision that valve testing need not be performed more often than once every cold shutdown has been deleted.Valves that can be exercised during cold shutdown periods will be exercised every three months in accordance with the Code or they will be declared out of service until such testing can be completed.

The plant administrative procedure governing ASME Code testing, of pumps and valves states the following: "If the unit remains in cold shutdown for greater than 90 days, the cold shutdown valves shall be exercised again.Plant startup should not be delayed because of testing as long as a reasonable good faith effort was made." TER Section 5.11 NRC Recommended Action: For the following check valves, the licensee has not identified any closed position testing requirement in the valve program table.The licensee should review the safety functions of these valves and revise the program, if necessary:

VR-5: VR-7'R-8'R-11:

VR-21: VR-32: V-2177, 2190, 2191 and 2526 V-07000 and V-07001 V-3401 and V-3410 V-3113, V-3133, V-3143 and V-3766 V-07129 and V-07143 V-3101 St.Lucie Response: V-2177: Closure is not required as this function is provided by normally closed isolation valve, V-2514.V-2190: There is no requirement for this check valve to close during a SIAS to prevent recirculation of the emergency borate flow back to the BAMTs or the suction of the running BAM pumps.This is because any leakage past the valve would be available to the charging pumps through the gravity feed line.17 V-2191: Closure is not required as this function is provided by normally closed isolation valve, V-2504.Additionally, if V-2504 were open and V-2191 failed to close any inventory diverted to the RWT would still be available for emergency boration from the RWT.V-2526: There is no safety related requirement for this valve to close.The only position this valve is required to be in during an accident is open, allowing boric acid to the suction of the charging pumps via the boric acid makeup pumps or the gravity feed lines from the boric acid makeup tanks.V-07000 and V-07001: Closure is not required as this function is redundantly provided by the LPSI pump suction isolation valves.V-3401 and V-3410: Closure is not required as this function is redundantly provided by the pump discharge check valves.V-3113, V-3133, V-3143 and V-3766: Closure of these valves is not required as this function is redundant to the HPSI header motor operated isolation valves.These valves are not RCS pressure isolation valves.V-07129 and V-07143: Closure function is provided by the pumps discharge manual isolation valves (V-07130 and V-07145)during shutdown cooling.There is no source of backflow in the containment spray mode of operation.

V-3101: Since the valve is normally isolated by an upstream manual isolation valve, exercising in the closed direction is not required.TER Section 5.12 NRC Recommended Action: For relief requests VR-8, VR-10, VR-12, the licensee states that the alternate testing satisfies the requirement of Generic Letter 89-04, Position 1.As discussed in Position 1, the NRC staff position is that passing the maximum required accident condition flowrate through the valve is an acceptable full-stroke.

It is assumed that the full-flow exercise proposed by the licensee complies with this position.If other techniques are used, such as non-intrusive techniques at reduced flow rate, the licensee must comply with the six criteria required by Position 1.The licensee should clarify this statement in each request.St.Lucie Response: Valve relief requests VR-8, 10 and 12 have been deleted with the justifications for testing'the valves during refueling outages now described in Appendix F: Refueling Outage Justifications.

These valves are full stroked by passing the maximum required accident condition flowrate through the valves.OMa-1988, Part 10,%4.3.2.2 is used to justify deferring the testing to refueling outages.18 TER Section 5.13 NRC Recommended Action: The licensee should clarify why the valve program table references VR-19 when it indicates that V-3414 and V-3427 will be tested closed quarterly.

St.Lucie Response: The reference to VR-19 has been removed from the valve program table for valves V-3414 and V-3427.TER Section 5.14 NRC Recommended Action: The licensee has stated that the valves referenced in VR-12"will be partial-stroke exercised to the open position and subsequently stroked closed during cold shutdowns per VR-1" and the basis only discusses the impracticality of testing quarterly.

However, the valve program table identifies the test frequency as"SP" as per VR-12 and not"CS", and the licensee additionally states that the valves will be verified closed during the PIV leak tests.It is assumed that the valves are exercised to the closed position in accordance with the Code during cold shutdowns, in addition to the PIV leak test.If exercising the valves closed at cold shutdowns is impractical, the request's basis must be revised to discuss the impracticality.

St.Lucie Response: The valve program table has been revised to indicate that the valves are to be tested closed during cold shutdowns.

The basis for testing these valves at cold shutdowns is described in Appendix E: Cold Shutdown Justifications.

TER Section 5.15 NRC Recommended Action: From a review of the applicable flow diagrams, 2998-G-078, Sheet 130, Rev.4, and the continuation on flow diagram 2998-G-088, Rev.19, for valves V-3104 and V-3105, it appears that there is a flow element on each recirculation line, i.e., FE-03-1-1 and FE-03-2-1, which could be used to measure the recirculation line flow.The licensee should clarify why these elements cannot be used in Relief Request VR-28.Additionally, the licensee should explain why the quarterly LPSI pump flow test does not result in a recirculation flow sufficient to cause full-stroke exercising of these valves.OMa-1988 Part 10.%4-3-2-2 allows full-stroke exercising that is not practicable during plant operation or cold shutdowns to be deferred to refueling outages.Therefore, provided the licensee furnishes information on why the installed flow elements or non-intrusive techniques cannot be used to verify the valves'ull-stroke open quarterly, the relief requested by the licensee is 19 covered by the rulemaking, effective September 8, 1992, as described above, and approval could be recommended.

However, if quarterly full-stroke exercising is practical, the licensee must comply with the Code requirements.

The licensee should revise the relief request.St.Lucie Response: Flow elements FE-03-1-1 and FE-03-2-1 are strap on ultrasonic flow instruments designed to annunciate low flow alarms in the control room to warn operators of low flow conditions associated with the LPSI pumps.The ultrasonic flow instruments are used exclusively to provide low flow alarms.The flow elements and alarms were added to the original design of the LPSI system to address NRC questions related to ECCS pump operation.

The instruments were designed to alert the operators to pump low flow conditions, but were never intended to have the accuracy needed to quantify the designed flowrates from the pump through the check valves.Actual pump recirculation flow rates are significantly limited by the flow restriction orifices in each recirculation line.Actual flowrates as measured by level increases in the RWT over time have proven to be only minimally greater than the 100 gpm flow rate that the orifice was designed to provide.Since the orifice is such a major contributor to the flow losses in the line with the check valve only contributing a small portion of the flow restriction, a high degree of accuracy in flow measurement is needed to detect degradation of the check valves.Strap on flow elements of the nature of FE-03-1-1 and FE-03-2-1 do not have the required accuracy.Using the acoustic flow elements to verify the check valves open would be impractical.

The accuracy of the strap on ultrasonic devices is questionable for this application and could unnecessarily place the check valves out of service or prevent check valve degradation from being detected.The testing described in the program is adequate to ensure the check valves are performing their required safety function.Precise measurements of pump recirculation flow rates are obtained each refueling outage by measuring the RWT level increase over time while draining the pressurizer or refueling cavity.During the quarterly LPSI pump runs, flow through the recirculation lines is verified by determining that heat is being removed from the pumps.Pump heat removal is the major design criteria for the recirculation lines.Information from the valve manufacturer states that flow velocities of 32.8 ft/sec are required for the check valves to reach their full open position.Due to the flow reducing orifice, flow velocities of only about 10 ft/sec can be achieved.The lack of sufficient flow to cause full-stroke exercising of these valves makes the use of non-intrusive techniques impractical.

TER Section 5.16 NRC Recommended Action: 20

Anomalies identified during the review of cold shutdown justifications are identified below: The following valves are not exercised closed.The licensee should verify that the valves do not perform a safety function in the closed position, or revise the program as appropriate:

RC-1: V-1460 through V-1466, reactor vessel and pressurizer gas vents;1 in.normally-closed, solenoid-operated globe valves.RC-2: V-1474 and V-1475, pressurizer power-operated relief valves;3 in.solenoid-operated, normally closed globe valves.CV-3.2: V-2431, auxiliary pressurizer spray check valve;2 in.normally closed check valve.CV-3.3: V-2440, charging pump discharge check valve to safety injection; 2 in.normally closed check valve.Sl-l.l: V-3106 and V-3107, LPSI pump discharge check valves;10 in.normally closed check valves.Sl-3.1: V-03002 through V-03005, Safety injection tank (SIT)drain line check valves;1 in.normally closed check valves.FW-1.2: V-09107, V-09123, and V-09139, auxiliary feedwater pump discharge check valves;4 in.normally closed check valves.FW-1.3: V-09119, V-09135, V-09151, and V-09157, auxiliary feedwater supply check valves;4 in.normally closed check valves.CC-1.2: HCV-14-3 A&B, shutdown heat exchanger return valves;14 in.normally open, fail open, diaphragm-operated butterfly valves.St.Lucie Response: RC-1: V-1460 through V-1466: Testing in the closed direction is not required as the loss of reactor coolant through the one-inch lines is judged insignificant from the aspect of accident mitigation.

These lines are equipped with flow restricting orifices limiting the loss of coolant liquid to within makeup capacity.RC-2: V-1474 and V-1475: Closure is,not required as this function is provided by the PORV block valves (V-1476 and V-1477)which are credited for isolating the associated PORV.CV-3.2: V-2431: This valve is not required to close to perform a safety function.This valve is not at a high pressure/low pressure interface.

Passive failure of upstream piping is not considered credible as it is designed to operate at pressures exceeding the normal RCS pressure.No single failure of any active component can occur that would divert flow from the RCS through the charging 21

header if this valve were to fail to close.Isolation valves SE-02-3 and SE-02-4 can also be closed if required.Additional'ly at least one charging pump will be available to supply flow through this valve during any single failure scenario.CV-3.3: V-2440: Closure is not required since the line is manually isolated by valve V-2340.V-2340 is only opened to align emergency boration flow from the charging pumps through the HPSI headers.Under this condition V-2440 is required to remain open and has no requirement to close.Sl-1.1: V-3106 and V-3107: These valves are not required to close because the LPSI pumps are operating or are isolated from adjoining systems by shutdown cooling heat exchanger isolation valves, LPSI header isolation valves, and safety injection header check valves during an accident.Thus closure testing is not required.Sl-3.1: V-03002 through V-03005: Closure is not required as this function is provided by valves SE-03-1A through SE-03-1D.FW-1.2: V-09107, V-09123, and V-09139: Closure is not required as this function is provided by valves SE-09-2 through SE-09-5.(see response to section 5.2.A.2).FW-1.3: V-09119, V-09135, V-09151, and V-09157: Closure is not required as this function is provided by valves MV-09-9 through MV-09-12 and manual valves V-09120, V-09136, V-09152, V-09158.(see response to section 5.2.A.2)CC-1.2: HCV-14-3 A&B: These valves are closed during normal operation to divert component cooling water flow from the shutdown cooling heat exchanger to other components requiring cooling to support normal power operations.

The valves opened to supply cooling water to the shutdown cooling heat exchanger for plant cooldown or for cooling containment spray pump discharge for containment cooling.There is no requirement for this valve to close other than to support normal plant operations which is not required to mitigate the consequences of an accident or to shut down the plant.NRC Recommended Action: CV-3.5: V-2523, charging line isolation valve;2 in.diaphragm-operated, locked open globe valve.For V-2523, the failure mode is the open position.Since the valve is only exercised to the closed position, the licensee should explain why no fail safe testing (to the open position)is indicated in the valve program tables.St.Lucie Response':

22 This air operated, fail open valve is locked open to allow boron injection to the reactor coolant system.This valve may be required to close should the alternate boration flowpath via the HPSI header be utilized, in which case the valve would not be required to be reopened.The ability of this valve to stroke to the open position or to fail to the open position is not a safety related function and are not required to be tested.NRC Recommended Action: Sl-1.2: V-3463, Isolation Valve for SIT Test/RWT Return Header;2 in.manually-operated, locked closed gate valve.According to the., flow diagram, 2998-G-078, Sheet'130, the two outboard containment isolation valves for penetration 41, 2I-SE-03-2A and 2B, are normally closed and in parallel to each other and in series with V-3463.The Valve Program Tables indicate that both of the outboard valves are exercised opened quarterly.

Furthermore, Technical Specification Table 3.6-2 for containment isolation valves indicates that V-3463 is testable during plant operation.

Therefore, the licensee should explain why V-3463 cannot be exercised open quarterly.

St.Lucie Response: The justifications for not testing this valve quarterly has been reviewed in response to this SE.The valve program table has been revised to indicate that manually-operated valve V-3463 is to be tested quarterly.

The cold shutdown justification for this valve has been deleted.NRC Recommended Action: Sl-2.1: V-3114, V-3124, V-3134, and V-3144, LPSI cold leg injection check valves;6 in.check valves, normally closed.The licensee has not provided an'explanation of why the valves cannot be verified closed quarterly.

There appear to be drain or test connections available both immediately upstream and immediately downstream of each of these valves which may be able to be used for both a quarterly part-stroke open test and a quarterly test for closure.Therefore, the licensee should explain why such testing could not be performed quarterly.

St.Lucie Response: The justification for not testing these valves quarterly has been included in Revision 1 of the St.Lucie Unit 2 IST Program Second Ten Year Interval.This cold shutdown justification states the following: "During normal plant operation, the LPSI Pumps cannot develop sufficient discharge pressure to pump through these valves to the RCS and exercise them in the open direction.

The closure tests can 23 only be performed at the end of the outage after the valves have been exercised open earlier by the partial stroke open tests." These are simple check valves with no external means of position indication.

To cycle the valves open utilizing the drain or test connections upstream and downstream of each of these valves during normal plant operation is impractical.

The drain valve downstream of the check valves cannot be opened and used as a flow path for part stroking the check valves because they are exposed to the total volume and pressure of the SIT.The only practical means of verifying closure is by performing a leaktest or backflow test.This would only constitute a valid closure stroke test of the valves only if they could be verified open prior to the test.To test the check valves for closure the upstream side of the check valves must be depressurized and drained in order to collect the back leakage through the check valves.Performing this test requires a considerable effort such that testing during operation would constitute an unreasonable burden on the plant staff.In addition, the test personnel must handle up to several gallons of contaminated water per test, some of which could be under pressure when first vented.Performing this test procedure each quarter would result in unnecessary personnel radiation exposures and possible personnel contaminations NRC Recommended Action: Sl-2.3: V-3545, V-3664, and V-3665, shutdown cooling isolation and cross connect valves, 10 in.motor-operated, locked closed gate valves.The licensee should explain why a failure of V-3664 and V-3665 in the open position would jeopardize the integrity of the LPSI System since the Shutdown cooling system valves V-3480, V-3481, V-3651 and V-3652 are immediately upstream and interlocked closed as described for S1-2.2.Similarly, the licensee should describe under what conditions the cross connect valve V-3545 is opened during the shutdown cooling mode of operation and also justify that its failure during normal plant operation would jeopardize the integrity of the LPSI System since the it appears that only shutdown cooling would be affected and that shutdown cooling could still be accomplished with the valve open.St.Lucie Response: The justifications for not testing these valves quarterly have been reviewed in response to this SE.The valve program table has been revised to indicate that shutdown cooling isolation valves V-3664 and V-3665 are to be tested quarterly.

The cold shutdown just).fication for these valves has been deleted.a 24 The revised justification for not testing shutdown cooling cross connect valve V-3545 quarterly has been included in Revision 1 of the St.Lucie Unit 2 IST Program Second Ten Year Interval.This cold shutdown justification states the following: "The breaker for this valve is required to be deenergized'xcept during plant cold shutdown or refueling modes to meet position C.1 to Regulatory Guide 1.63 revision 2.This is to protect the mechanical integrity of the valves electrical penetration assembly should the maximum short-circuit vs time condition occur given single random failure of circuit overload protection devices." NRC Recommended Action: MS-1.1: HCV-08-1 A&B, main steam isolation valves;34 in.normally open, piston-operated'globe valves.The licensee should indicate in the Tables what is the failure mode position of these valves.St.Lucie Response: The Tables have been revised to indicate that the failure mode of the main steam isolation valves, HCV-08-1 A&B, is to fail close in the current revision of the program.The table has also been revised to indicate that the valves are to be fail close tested during the cold shutdown close stroke test.NRC Recommended Action: MS-1.2: V-08130 and V-08163, steam-driven AFW pump steam supply check valves;4 in.normally open check valves.In the valve program tables, these check valves are part-stroke exercised to the open position quarterly, and full-stroke exercised to the open position at cold shutdowns.

Valve relief request VR-31 called for part-stroke exercising to the open position monthly and full-stroke exercising at cold shutdowns.

The licensee should clarify the apparent discrepancies in the testing frequencies.

St.Lucie Response: Valve relief request VR-31 has been revised to indicate that the part-stroke exercising to the open position of the steam-driven AFW pump steam supply check valves, V-08130 and V-08163, is to be performed quarterly.

25