ML17223A450

Rev 2 to JNS-PSL-203, Second 10-Yr Inservice Insp Interval Inservice Testing Program for Pumps & Valves.

ML17223A450
Person / Time
Site:	Saint Lucie
Issue date:	12/15/1989
From:	Hayes J, John S FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17223A451	List: ML17223A450 ML17308A485
References
JNS-PSL-203, NUDOCS 9001120169
Download: ML17223A450 (194)

Text

ATTACHMENT 2 FLORIDA POWER and LIGHT COMPANY NUCLEAR ENERGY SERVICES 700 Universe Boulevard Juno Beach, Florida 33408 SEC/~ TEN-YEAR INSERVICE INSPECTION INTERVAL p(O~gASgl4~'NSERVICE TESTING PROGRAM 4 g9~ FOR gQ t,g PUMPS AND VALVES ST. LUCIE NUCLEAR POWER PLANT UNIT NO. 1 NRC DOCKET NUMBER: 50-335 DOCUMENT NUMBER: JNS-PSL-203 REVISION 2 ADMINISTRATIVE APPROVALS:

PREPARED BY: DATE: Dec 12 1989 N PLANT SUPPORT APPROVED BY: DATE: ~+ 4 GER PLANT SUPPORT APPROVED BY DATE:

NS MANA NUCLEAR ENERGY ST. LUCIE PLANT REVIEWS AND APPROVALS:

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REVISION 2 12/12/89 Table of Contents Pacae Table of Contents Record of Revisions 1.0 Introduction 2.0 Applicable Documents 3.0 Inservice Testing Program For Pumps 3.1 Code Compliance 3.2 Allowable Ranges of Test Quantities 3.3 Testing Intervals 3.4 Pump Program Table 3.5 Relief Requests for Pump Testing 4.0 Inservice Testing Program For Valves 4 4.1 Code Compliance 4 4.2 Testing Intervals 4 4.3 Stroke Time Acceptance Criteria 4 4' Check Valve Testing 4 4.5 Valve Program Table 4' 4.6 Relief Requests For Valve Testing A endices A Pump Program Tables B Pump Program Requests For Relief C , Valve Program Tables D Valve Program Requests For Relief E Cold Shutdown Justifications

REVISION 2 12/12/89 RECORD OF REVISIONS REVISION DESCRIPTION OF REVISION DATE NUMBER REASON FOR THE CHANGE REVISED APPROVALS Initial Issue 3/2 1/85 Second 10-year Program 8/11/87 Revised Program per NRC Generic Letter 89-04 12/12/89

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REVIS ION 2 12/12/89 INSERVICE TESTING (IST) PROGRAM PLAN ST. LUCIE UNIT 1

1.0 INTRODUCTION

Revision 2 of the St.. Lucie Unit 1 ASME Inservice Inspection (IST) Program will be in effect through the end of the second 120-month (10-year) interval unless revised and reissued for reasons other than the routine update required at the start of the third interval per 10 CFR 50.55a(g).

The second inspection interval is defined as follows:

Bece1ns Ends February 11, 1988 February 10, 1998 This document outlines the IST Program for St. Lucie Plant, Unit 1, based on the requirements of Section XI of the ASME Boiler and Pressure Vessel Code, 1983 Edition, including all addenda thereto through Summer', 1983 (the Code). References in this document to "IWP" or "IWV" correspond to Subsections IWP and IWV, respectively, of the ASME Section XI, 1983 Edition, unless otherwise noted.

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

REVISION 2 12/12/89 2.0 APPLICABLE DOCUMENTS This Program Plan was developed per the requirements and guidance provided by the following documents:

2.1 Title 10, Code of Federal Regulations, Part 50 2.2 NRC Regulatory Guides Division 1 2.3 Standard Review Plan 3.9.6, "Inservice Testing of Pumps and Valves 2.4 Final Safety Analysis Report, St. Lucie Unit 1 2.5 St. Lucie Plant Unit 1 Technical Specifications 2.6 ASME Boiler and Pressure Vessel Code, Section XI, 1983 Edition and Addenda through Summer, 1983 2.7 NRC Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs"

REVISION 2 12/12/89 3.0 INSERVICE TESTING PROGRAM FOR PUMPS 3.1 Code Compliance This IST Program for pumps meets the requirements of Subsection IWP of the Code and any interpretations or additional requirements imposed by Reference 2.7.

Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant to the requirements of 10 CFR 50.55a(g)(iii) and Reference 2.7.

3.2 Allowable Ranges of Test Quantities The allowable ranges for test parameters as specified.

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

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

Lucie Unit 1 Technical Specifications to provide for operational flexibility.

3.4 Pump Program Table Appendix A lists those pumps included in the IST Program with references to parameters to be measured and applicable requests for relief.

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

REVISION 2 12/12/89 4.0 INSERVICE TESTING PROGRAM FOR VALVES 4.1 Code Compliance This IST Program for valves meets the requirements of Subsection IWV of the Code and any interpretations or additional requirements imposed by Reference 2.7.

Where these requirements have been determined to be impractical, conformance would cause unreasonable hardship without any compensating increase in safety, or an alternative test provides an acceptable level of quality and safety, relief from Code requirements is requested pursuant to the requirements of 10 CFR 50.55a(g)(iii) and Reference 2.7.

4.2 Testing Intervals The test frequency for valves included in the be as set forth in IWP-3400 and related relief Program'ill requests. A band of +25 percent of the test interval may be applied to a test schedule as allowed by the St.

Lucie Unit 1 Technical Specifications to provide for operational flexibility. Where quarterly testing of valves is impractical or otherwise undesirable, testing may be performed during cold shutdown periods as permitted by IWV-3412(a). Justifications for this deferred testing are provided in Appendix E.

4.3 Stroke Time Acceptance Criteria When required, the acceptance criteria for the stroke times of power-operated valves will be as set forth in Reference 2.7.

4.4 Check Valve Testing Full-stroke exercising of check valves to the open position using system flow requires that a test be performed whereby the predicted full accident condition flowrate through the valve be verified and measured.

Any deviation to this requirement must satisfy the requirements of Reference 2.7, Position 1.

4.5 Valve Program Table Appendix C lists those valves included in the IST Program with references to required testing, respective test intervals, and applicable requests for relief.

REVISION 2 12/12/89 4.6 Relief Requests for Valve Testing Appendix D includes all relief requests related to valve testing.

Appendix A Pump Program Tables

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SSCZ50 FLORIDA POWER AND LIGHT COMPANY REVISION: 2 PUMP TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 1 CC5RC 5 5 S5 5S 5R INLET DIFF. FLOW BEARING PUMP NUMBER DESCRIPTION CL COORD SPEED PRES. PRES. RATE VIBRA. TEMP. REMARKS h

AFW 1A AUXILIARY FEEDWATER PUMP 3 M-5 NA Y Y Y:PR-4 Y N:PR-1 AFW 18 AUXILIARY FEEDWATER PUMP 3 K-5 NA Y Y Y:PR-4 Y N:PR-1 AFW 1C AUXILIARY FEEDWATER PUMP 3 H-5 Y Y Y:PR-4 Y H:PR-1 BAM 1A BORIC ACID MAKEUP PUMP 2 8.5 HA H:PR-8 Y Y:PR-5 Y H:PR-1 BAM 18 BORIC ACID MAKEUP PUMP 2 8-5 HA N:PR 8 Y Y:PR-5 Y H:PR-1 CCW 1A COMPONENT COOLING 'WATER PUMP 3 F.16 HA Y Y Y Y N:PR-1 CCW 18 i COMPONENT COOLIHG WATER PUMP 3 F-17 NA Y Y Y Y N:PR.1 CCW 1C COMPONENT COOLING WATER PUMP 3 F-16 HA Y Y Y Y N:PR-1 CG 1A ~ CHARGING PUMP 2 G-2 HA Y Y Y Y Y CG 18 CHARGING PUMP 2 G-2 HA Y Y Y Y Y CG 1C CHARGING PUMP 2 E-2 HA Y Y Y Y CS 1A CONTAIHMENT SPRAY PUMP 2 G-4 NA Y Y:PR-6 Y H:PR-1 CS 18 CONTAINMENT SPRAY PUMP 2 E-2 HA Y Y:PR 6 Y H:PR-1 DOT 1A DIESEL OIL TRANSFER PUMP 3 J-12 NA N:PR-8 Y Y:PR-7 Y N:PR-1 DOT 18 DIESEL OIL TRANSFER PUMP 3 L.12 HA H:PR-8 Y Y:PR-7 Y H:PR-1 HPSI 1A HIGH PRESSURE SAFETY IHJECTIOH 2 C-6 HA Y Y Y:PR-9 Y N:PR-1 HPSI 18 HIGH PRESSURE SAFETY IHJECTIOH 2 8 6 HA Y Y Y:PR-9 Y N:PR-1 HPSI 1C HIGH PRESSURE SAFETY INJECTION 2 C 6 NA Y Y Y:PR-9 Y N:PR.1 ICW 1A INTAKE COOLING WATER PUMP 3 H-4 NA N:PR-11 Y Y Y N:PR 1 ICW 18 IHTAKE COOLING WATER PUMP 3 H.7 HA H:PR-11 Y Y Y H:PR-1 ICW 1C INTAKE COOLING WATER PUMP 3 H-5 HA N:PR-11 Y Y Y H:PR-1 LPSI 1A LOW PRESSURE SAFETY IHJECTIOH 2 F 6 HA Y Y Y:PR-10 Y H:PR-1 LPSI 18 LOW PRESSURE SAFETY IHJECTIOH 2 E-6 NA Y Y Y:PR-10 Y H:PR-1

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REVISION 2 INSERVICE TESTING PUMP TABLES DATE  : 12/12/89 St. Lucie Nuclear Plant Unit 1

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PAGE 2 LEGEND PUMP NUMBER Numerical designator indicated on the respective flow diagram.

DESCRIPTION Generic name/function of the pump.

ISI Classification per the associated ISI boundary drawing(s)

COORD Corresponds to the flow diagram coordinates of the pump.

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

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

Appendix B Pump Program Relief Requests

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REVISION 2 12/12/89 RELIEF REQUEST NO. PR-1 COMPONENTS:

All centrifugal pumps in the Program SECTION XI RE UIREMENT:

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

(IWP-3300, 4310)

BASIS FOR RELIEF:

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

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

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

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

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

ALTERNATE TESTING:

None B-1

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REVISION 2 12/12/89 RELIEF REQUEST NO. PR-2 COMPONENTS:

Various SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

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

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

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

In these cases, high quality calibrated instruments will be used where the "reading" accuracy is at least equal to the Code-requirement for full-scale accuracy. This will ensure that the measurements are always more accurate than the accuracy as determined by combining the requirements of Table IWP-4110-1 and Paragraph IWP-4120.

ALTERNATE TESTING:

Whenever portable instruments are used for measuring pump speed or bearing temperatures, the instruments will be such that the "reading" accuracy is as follows Temperature +5 percent Speed +2 percent B-2

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REVISION 2 12/12/89 RELIEF REQUEST NO. PR-3 COMPONENTS:

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

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

(IWP-3300)

Pump inlet pressure shall be measured before starting a pump and during the test. (Table IWP-3100-1)

BASIS FOR RELIEF:

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

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

ALTERNATE TESTING:

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

B-3

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0 RELIEF REQUEST NO. PR-4 REVISION 2 12/12/89 COMPONENTS:

Auxiliary Feedwater (AFW) Pumps 1A thru 1C (8770-G-080, Sh 3)

SECTION XI RE UIREMENT:

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

(IWP-3300)

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

BASIS FOR RELIEF:

There are only two practical flowpaths available for performing inservice testing of the AFW Pumps. These include the primary flowpath into the main feed supply lines and thence to the steam generator and the minimum-flow recirculation (mini-recirc and bypass test loop) which returns to the condensate tank. The former is provided with flowrate measuring instrumentation however the mini-recirc line is a fixed resistance circuit with no flow instrumentation.

Pumping from the auxiliary feedwater system into the steam generators during plant hot operation is impractical and undesirable for the following reasons:

During auxiliary feedwater injection via the main feedwater lines while the plant is operating at power, a large temperature differential (approximately 375 deg-F) could exist that would result in significant thermal shock and fatigue cycling of the feedwater piping and steam generator nozzles.

Based on the expected duration of the testing and the flowrate of the pumps (275 gpm), it is expected that the cooldown of the steam generator would induce cooldown and contraction of the reactor coolant system resulting in undesirable reactivity variations and power fluctuations.

B-4

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-4 (cont.)

ALTERNATE TESTING:

During quarterly testing of the AFW pumps while the pumps are operating through the fixed-resistance mini-recirc line, pump differential pressure and vibration will be measured and evaluated per.- IWP-3200 and IWP-6000.

During testing performed at cold shutdown, pump differential pressure, flowrate, and vibration will be recorded per IWP-3200 and IWP-6000. Testing during cold shutdowns will be on a frequency determined by intervals between shutdowns as follows:

For intervals of 3 months or longer each shutdown.

For intervals of less than 3 months testing is not required unless 3 months have passed since the last shutdown test.

This alternate testing agrees with the requirements of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

B-5

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e RELIEF REQUEST NO. PR-5 REVISION 12/12/89 2

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COMPONENTS:

Boric Acid Makeup (BAM) Pumps lA and 1B (8770-G-078, Sh 121)

SECTION XI RE UIREMENT!

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

(IWP-3300)

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

BASIS FOR RELIEF!

There are three practical flowpaths available for performing inservice testing of the BAM Pumps. These include the primary flowpath into the charging pump suction header, a recirculation line leading back to the refueling water tank, and the minimum-flow recirculation (mini-recirc and bypass test loop) which returns to -the BAM Tanks.

None of these is totally satisfactory for the following reasons:

Operating the BAM Pumps discharging into the charging pump suction header requires the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps.

This, in turn, would result in the addition of excess boron to the RCS which would adversely affect plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. During cold shutdown, the introduction of excess quantities of boric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry an'd the inherent difficulties that may be encountered during the subsequent startup due to over-boration'of the RCS.

B-6

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-5 (cont.)

• The second circuit that recirculates water to the Refueling Water Tank (RWT) or the Volume Control Tank (VCT). During plant operation undesirable to pump to the RWT at and power it deplete is to BAM Tank inventory. There are, however, situations where makeup is provided to the VCT from the BAM Tanks; duration but of it this is unlikely that the scheduling and evolution presents a practical opportunity for performing pump testing.

• The minimum-flow recirculation flowpath is a fixed resistance circuit containing a flow limiting orifice however no flowrate measuring instrumentation is installed.

ALTERNATE TESTING:

During quarterly testing of the BAM pumps while the pumps are operating through the fixed-resistance mini-recirc line, pump differential pressure and vibration will be measured and evaluated per IWP-3200 and IWP-6000.

During testing performed at cold shutdown, pump differential pressure, flowrate, and vibration will be recorded per, IWP-3200 and IWP-6000. Testing during cold shutdowns will be on a frequency determined by intervals between shutdowns as follows:

For intervals of 3 months or longer each shutdown.

For intervals of less than 3 months testing is not required unless 3 months have passed since the last shutdown test.

This alternate testing agrees with the requirements of NRC.

Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

B-7

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REVISION 2 12/12/89 RELIEF REQUEST NO. PR-6 COMPONENTS:

Containment Spray (CS) Pumps 1A and 1B (8770-G-088)

SECTION XI RE UIREMENT:

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

(IWP-3300)

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

BASIS FOR RELIEF:

There are two practical flowpaths available for performing inservice testing of the CS pumps. These include onelow-borated water from the RWT to the RCS via the that'umps pressure injection header and the, other, minimum-flow recirculation (mini-recirc and bypass test loop) which returns to the RWT The first would require modifying the shutdown cooling lineup while in cold shutdown; however, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function. Thus, the only practical time for testing these pumps via this flowpath to is during refueling outages when water from the RWT is used fill the refueling cavity.

The minimum-flow recirculation flowpath is a fixed resistance circuit containing a flow limiting orifice however no flowrate measuring instrumentation is installed.

ALTERNATE ESTING:

During quarterly testing of the CS pumps while the pumps are operating through the fixed-resistance mini-recirc line, pump differential pressure and vibration will be measured and evaluated per IWP-3200 and IWP-6000.

B-8

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-6 (cont.)

ALTERNATE TESTING:

During testing performed during each reactor refueling, pump differential pressure, flowrate, and vibration will be recorded per IWP-3200 and IWP-6000.

This alternate testing agrees with the requirements of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

B-9

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REVISION 2 12/12/89 RELIEF REQUEST NO. PR-7 COMPONENTS!

Diesel Fuel Oil Transfer Pumps 1A and 1B SECTION XI RE UIREMENTS!

When measurement of bearing temperature is not required, each pump shall be run at least 5 min under conditions as stable as 'the system permits. At the end of this time at least one measurement or observation of each of the quantities specified shall be made and recorded.

(IWP-3500(a))

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

BASIS FOR RELIEF:

only available test circuit for these pumps consists of The the normal day tank fill lines from the diesel oil storage tanks. There is a minimum flow recirculation line however no flow instrumentation installed. Therefore, the only practical method of determining pump flowrate is by calculating the fill rate of the day tanks. Furthermore, due to the capacity of the fuel oil pumps and the available volume of oil from the low-level pump start point to the high-level setpoint, the runtime for a pump is limited, precluding the Code required 5-minute minimum runtime before taking readings.

ALTERNATIVE TESTING:

When testing these pumps, the flowrate will be calculated based on the measured change in the diesel fuel oil day tank level over an elapsed period of pump run time.

The starting point for taking measurements will be when the system conditions have stabilized.

B-10

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-8 COMPONENTS:

Boric Acid Makeup Pumps 1A and 1B .(8770-G-078, Sh 121 Diesel Fuel Oil Transfer Pumps 1A and 1B (8770-G-086, Sh 1)

SECTION XI RE UIREMENTS:

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

BASIS FOR RELIEF:

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

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

ALTERNATE TESTING:

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

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-9 COMPONENTS:

High Pressure Safety .Injection (HPSI) Pumps 1A thru 1C (8770-G-078, Sh 130)

SECTION XI RE UIREMENT:

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

(IWP-3300)

BASIS FOR RELIEF:

During quarterly testing of the HPSI Pumps, the pumps cannot develop sufficient discharge pressure to overcome RCS pressure an allow directing flow through the safety injection line flow measuring instrument, thus flow is routed through a minimum flow test line leading to the suction of the pump being tested. This line has no installed flowrate measuring instrumentation and measuring flowrate during quarterly testing is not practical.

During cold shutdown conditions, full flow operation of the HPSI pumps to the RCS is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.

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

ALTERNATE TESTING:

During quarterly testing of the HPSI Pumps, pump differential pressure and vibration will be recorded per IWP-3200 and IWP-6000.

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

This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-10 COMPONENTS:

Low Pressure Safety Injection (LPSI) Pumps 1A and 1B (8770-G-078, Sh 130)

SECTION XI RE UIREMENT:

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

(IWP-3300)

BASIS FOR RELIEF:

'uring quarterly testing of the LPSI Pumps, the pumps cannot develop sufficient discharge pressure to overcome RCS pressure an allow directing flow through the safety injection line flow measuring instrument, thus flow is routed through a minimum flow test line leading to the suction of the pump being tested. This line has no installed flowrate measuring instrumentation and measuring flowrate during quarterly testing is not practical.

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

ALTERNATE TESTING:

During quarterly testing of the LPSI Pumps, pump differential pressure and vibration will be recorded per IWP-3200 and IWP-6000.

B-13

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-10 (cont.)

ALTERNATE TESTING:

During testing performed at cold shutdown, pump differential pressure, flowrate, and vibration will be recorded per IWP-3200 and IWP-6000. Testing during cold shutdowns will be on a frequency determined by intervals between shutdowns as follows:

For intervals of 3 months or longer each shutdown.

For intervals of less than 3 months testing is not required unless 3 months have passed since the last shutdown test.

This alternate testing agrees with the requirements of NRC Generic Letter 89-04, Position 9 and, as such, is considered to be approved upon submittal.

B-14

REVISION 2 12/12/89 RELIEF REQUEST NO. PR-11 COMPONENTS:

Intake Cooling Water .Pumps 1A, 1B and 1C SECTION XI RE UIREMENT:

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

(IWP-3300)

Pump inlet pressure shall be measured before starting a pump and during the test. (Table IWP-3100-1)

BASIS FOR RELIEF:

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

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

ALTERNATE TESTING:

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

B-15

Appendix C Valve Program Tables

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t Florida Power & Light Company INSERVICE TESTING VALVE TABLES St. Lucie Nuclear Plant Unit 1 REVISION : 2 DATE:

PAGE  :

12/12/89 1

LEGEND VALVE NUMBER The plant alpha-numerical designator for the subject valve COORD The coordinate location of the valve on the designated drawing CL The ISI Classification of the valve as per the respective ISI boundary drawings CAT The valve category per Paragraph IWV-2200 SIZE The valve's nominal size in inches TYPE The valve type A/P The active (A) or passive (P) determination for the valve per IWV-2100.

ACT. TYPE The valve actuato'r type as follows:

AO Air-operated MO Electric motor-operated MAN Manual valve PO Piston-operated S/A Self-actuated SO Solenoid-operated NORM POS. Designates the normal position of the valve during plant operation at power REM IND Notes if a valve has remote position indication FAIL MODE Identifies the failure mode (open or closed) for a valve. FAI indicates the valve fails "as is".

Forida Power & Light Company REVISION : 2

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INSERVICE TESTING VALVE TABLES DATE  : 12/12/89 St. Lucie Nuclear Plant

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Unit 1 PAGE  : 2 LEGEND Cont.

Identifies the test requirements for a valve as follows:

CV/C Check valve exercise to closed position.

CV/0 Check valve full-stroke exercise to open position.

CV/PO Check valve partial-stroke exercise to open position.

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

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

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

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

SRV Set point check for safety/relief valves

Florida Power & Light Company

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REVISION: 2 INSERVICE TESTING VALVE TABLES DATE  : 12/12/89 St. Lucie Nuclear Plant Unit 1

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PAGE  : 3 LEGEND Cont.

TEST FREQ The required test interval as follows:

QR Quarterly (during plant operation)

CS Cold shutdown as defined by Technical Specification 2Y Every 2 years RF Each reactor refueling outage (cycle). In the case where this is designated for safety/relief valves refer, to Table IWV-3510-1.

SP Other (See applicable Request for Relief)

RELIEF REQ Refers to the specific relief request associated with the adjacent test requirement. (See Appendix D)

FLORIDA PSIER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 4 P 8 ID: 3509-0-115 SH 1 SYSTEM: STEAM GEHERATOR BLDHDOMH ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-23-3 E-2 2 B 2.000 GATE A AO 0 YES FC EC QR FS QR PI 2Y FCV-23-5 E-3 2 B 2.000 GATE A AO 0 YES FC EC QR FS QR PI 2Y FCV-23-7 E-5 2 B 0.500 GATE A AO C YES FC EC QR FS QR PI 2Y FCV-23-9 E-6 2 B 0.500 GATE A AO C YES FC EC QR FS QR PI 2Y

FLORIDA POMER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE 5 P F ID: 8770-G-078 SH 110 SYSTEH: REACTOR COOLAHT SYSTEH ACT. HORN REH FAIL TEST RELIEF VALVE HUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAH FREQ REQ. REHARKS V-1200 G 6 1 C 6.000 SAFETY A S/A C NO SRV RF V-1201 G-6 1 C 6.000 SAFETY A S/A C NO SRV RF V-1202 G-6 1 C 6.000 SAFETY A S/A C NO SRV RF V-1402 G-8 1 B 2.500 GLOBE A SO C YES FC EO CS PI 2Y V-1403 G-B 'I 8 2 ~ 500 GATE A HO 0 YES FAI EC QR PI 2Y V-1404 H-8 1 8 2.500 GLOBE A SO C YES FC EO CS Pl 2Y V-1405 H-8 1 8 2.500 GATE A HO 0 'ES FAI EC QR PI 2Y V-1441 D-4 2 B 1.000 GLOBE A -

SO LC YES FC EO CS Pl 2Y V-1442 D-4 2 8 1.000 GLOBE A SO LC YES FC EO CS PI 2Y V-1443 H-6 2 8 1.000 GLOBE A SO LC YES FC EO CS PI 2Y V-1444 H-6 2 8 1.000 GLOBE A SO LC YES FC EO CS Pl 2Y V-1445 F-8 2 8 1.000 GLOBE A SO LC YES FC EO CS Pl 2Y f

V-1446 F-8 2 8 1.000 GLOBE A SO LC YES FC EO CS Pl 2Y V-1449 F-8 2 8 1.000 GLOBE A SO LC YES FC EO CS PI 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Piant - Unit 1 PAGE  : 6 P 8 ID: 8770-G-078 SH 120 SYSTEM: CHEMICAL AND VOLUME CONTROL ACT ~ NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS MV-02-02 C-7 2 8 2.000 GLOBE A MO 0 YES FAI EO CS PI 2Y SE-02-01 B-8 1 B 2.000 GLOBE A SO 0 QR QR QR 2Y SE-02-02 B-8 1 B 2.000 GLOBE A SO 0 YES FO EC QR EO QR FS QR Pl 2Y SE-02-03 C-B 1 B 2.000 GLOBE A SO LC YES FC EC CS EO CS FS CS PI 2Y SE-02-04 C.8 1 8 2.000 GLOBE A SO CS CS CS 2Y V-2430 8-5 1 C 2.000 CHECK A S/A 0 NO CV/0 QR V-2431 C-8 1 C 2.000 CHECK A S/A C NO CV/0 CS V-2432 8.8 1 C 2.000 CHECK A S/A 0/C NO CV/0 QR V-2433 A-8 1 C 2.000 CHECK A S/A 0/C NO CV/0 QR V-2435 A-7 1 C 2.000 RELIEF A S/A C NO SRV RF V-2515 D-8 1 A 2.000 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y V-2516 D-7 1 A 2.000 GLOBE A DO 0 CS CS 2Y 2Y

l C

FLORIDA PONER AHD LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 7 RSSSSCZ'RR5C P 8 ID: 8770-G-078 SH 121 SYSTEM: CHEMICAL AND VOLUME CONTROL SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORS CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-2161 B-4 2 B 1.000 GLOBE A DO 0/C YES FC EC QR FS QR PI 2Y SE-01-01 H-6 2 A 0.750 GLOBE A SO 0 YES FC EC CS FS CS Pl 2Y SLT-1 2Y V-02132 G-2 2 C 2.000 CHECK A S/A 0/C HO CV/C QR CV/0 QR V-02133 G-2 2 C 2.000 CHECK A S/A 0/C HO CV/C QR CV/0 QR V-02134 E-2 2 C 2.000 CHECK "A S/A 0/C NO CV/C QR CV/0 QR V-2177 C-4 2 C 3.000 CHECK A S/A C HO CV/0 RF VR-6 V-2190 D-6 2 C 3.000 CHECK A S/A C NO CV/C RF VR-6 CV/0 RF VR-6 V-2191 E-6 2 C 3.000 CHECK A S/A C HO CV/C RF VR-6 CV/0 RF VR-6 V-2324 F-2 2 C 1 ~ 500 RELIEF A S/A C HO SRV RF V-2325 G-2 2 C 1.500 RELIEF A S/A C HO SRV RF V-2326 H.2 2 C 1.500 RELIEF A S/A C HO SRV RF V-2426 C-4 2 C 0.500 RELIEF A S/A C NO SRV RF V-2436 B-4 2 C 0.500 RELIEF A S/A C NO SRV RF V-2443 8-4 2 C 3.000 CHECK A S/A 0/C NO , CV/C QR CV/0 RF VR-28 CV/PO QR VR-28 V-2444 B-4 2 C 3.000 CHECK A S/A O/C NO CV/C QR CV/0 RF VR-28 CV/PO QR VR-28

FLORIDA POMER.AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 8 OSSA R 2 2 0 5 5 555 CXROORO ZQC P 8, ID: 8770-G-078 SH 121 (cont) SYSTEH: CNEHICAL AND VOLUHE CONTROL SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND HQOE EXAH FREQ REQ. REHARKS V-2501 E-7 2 8 F 000 GATE A HO 0 YES FAI EC CS PI 2Y V-2504 E-5 3 8 3.000 GATE A HO C YES FAI EC CS EO CS PI 2Y V-2505 N-6 2 A 0.750 GLOBE A DO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y V-2508 8-6 2 8 3 ~ 000 GATE A HO C YES FAI EO QR PI 2Y V-2509 8-7 2 8 3.000 GATE 'A HO C YES FAI EO QR PI 2Y V-2510 8-6 2 8 1.000 GLOBE A DO 0 YES FC EC QR FS QR Pl 2Y V-2511 D-5 2 8 1.000 GLOBE A DO 0 YES FC EC QR FS QR PI 2Y V-2512 E-4 2 8 3.000 GLOBE A DO C YES FC EC QR FS QR PI 2Y V-2514 C-4 2 8 3.000 GATE A HO C YES FAI EO QR Pl 2Y V-2525 E-7 2 8 4.000 GATE A HO 0/C YES FAI EC QR Pl 2Y

FLORIDA POMER AND LIGHT CONPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 9 X55 N 5 R5R Z CC5 0SCSC RCSCSR P 8 ID: 8770-G-078 SH 130 SYSTEN: SAFETY INJECTION SYSTEN ACT. HORN REN FAIL TEST RELIEF VALVE NUNBER COORS CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAN FREQ REQ. RENARKS FCV-3306 E-4 2 8 10.000 GLOBE A PO LO YES FO Ec QR Pl 2Y HCV-3657 F-4 2 8 12.000 GLOBE A DO LC YES FAI EO QR Pl 2Y MV.03-2 E-4 2 8 10.000 GLOBE A NO LO YES FAI Ec QR Pl 2Y SR-07-1A F-8 2 C 0.750 RELIEF A S/A C NO SRV RF SR-07-1B E-8 2 C 0.750 RELIEF A S/A C NO SRV RF V-07000 F-7 2 C 14.000 CHECK A S/A C NO CV/0 RF VR.7 CV/PO QR VR-7 V-07001 E-7 2 C 14 F 000 CHECK A S/A C NO CV/0 RF VR-7 CV/PO QR VR-7 V-07009 H-2 2, A 2.000 GLOBE P NAN LC NO SLT-1 2Y VR-5 V-3101 D-5 2 C 2.000 CHECK A S/A C NO CV/C CS VR-29 CV/PO 2A VR.29 INSP RF VR-29 V-3102 D-5 2 C, 2.000 CHECK A S/A C NO CV/C CS VR-29 CV/PO QR VR-29 INSP RF VR-29 V-3103 D-5 2 C 2.000 CHECK A S/A C NO CV/C CS VR-29 CV/PO QR VR-29 INSP RF VR-29 V-3104 E-5 2 C 2.000 CHECK A S/A C NO CV/C CS VR-30 CV/PO QR VR-30 INSP RF VR 30 V-3105 E-5 2 C 2.000 CHECK A S/A C NO CV/C CS VR-30 CV/PO QR VR-30 INSP RF VR-30 V-3106 F-5 2 C 10.000 CHECK A S/A C NO CV/C CS CV/0 CS

FLORIDA POMER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 10 51t52 RECCO 0 0 4 0 0 CS 5 ZRRCCC P 8 ID: 8770-G-078 SH 130 (cont) SYSTEH: SAFETY INJECTION SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HOOE EXAH FREQ REQ. REHARKS V-3107 E.5 2 C 10.000 CHECK A S/A C NO CV/C CS CV/0 CS V-3206 F-4 2 B 10.000 GATE P HO LO YES FAI Pl 2Y V-3207 E-4 2 B 10.000 GATE P HO LO YES FAI PI 2Y V-3401 0-7 2 C 6.000 CHECK A S/A C NO CV/0 RF VR-8 CV/PO QR VR-8 V-3405 C-5 2 C 3.000 STP-CK A S/A 0 NO CV/C QR CV/0 RF VR-9 V-3410 8-7 2 C 8.000 CHECK A S/A C NO CV/0 RF VR-8 CV/PO QR VR-8 V-3412 8-3 2 C 0.500 RELIEF A S/A C NO SRV RF V-3414 B-5 2 C F 000 STP-CK A S/A 0 NO CV/C QR CV/0 RF VR-9 V-3417 C-3 2 C F 000 RELIEF A S/A C NO SRV RF V-3427 C-5 2 C 3.000 STP-CK A S/A 0 NO CV/C QR CV/0 RF VR-9 V-3430 D-7 2 C 0.500 RELIEF A S/A C NO SRV RF V-3431 D.6 2 C 0.500 RELIEF A S/A C NO SRV RF V-3432 E-8 2 B 14.000 GATE A HO LO YES FAI EC QR PI 2Y V-3439 0-3 2 C 0.500 RELIEF A S/A C NO SRV RF V-3444 F-8 2 B 14.000 GATE A HO LO YES FAI EC QR Pl 2Y V-3452 G-8 2 B 12.000 GATE A HO LC YES FAI EO QR PI 2Y V-3453 G-8 2 8 12.000 GATE A HO LC YES FAI EO QR Pl 2Y

FLORIDA POJER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 11 P S ID: 8770-G-078 SN 130 (cont) SYSTEH: SAFETY INJECTION SYSTEH

'CT ~ NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-3456 G-3 2 B 10.000 GATE A HO LC YES FAI EO QR PI 2Y V-3457 0-3 2 B 10.000 GATE A HO LC YES FAI EO QR PI 2Y V-3463 N-2 2 A 2.000 GLOBE P MAX iC NO SLT-1 2Y VR 5 V-3653 B-4 2 B 4.000 GATE A HO LO YES FAI EC QR EO QR PI 2Y V-3654 B-4 2 B 6.000 GATE P HO LO YES FAI Pl 2Y V-3655 C-4 2 B 4 ~ 000 GATE A HO LC YES FAI EC QR EO QR PI 2Y V-3656 C-4 2 B 6.000 GATE P HO LO YES FAI PI 2Y V-3659 H-5 2 B 3.000 GATE A HO LO YES FAI EC CS Pl 2Y V-3660 G-5 2 8 3.000 GATE A HO LO YES FAI EC CS Pl 2Y V-3662 D 7 2 8 4.000 GATE A HO C YES FAI EC QR EO QR PI 2Y V-3663 D 7 2 8 4.000 GATE A HO C YES FAI EC QR EO QR Pl 2Y

FLORIDA PONER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 12 P & ID: 8770-0-078 SH 131 SYSTEM: SAFETY INJECTION SYSTEM ACT. HORN REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-03-1E 8-6 2 A 0.375 NEEDLE A SO C YES FC EC QR FS QR Pl 2Y SLT-1 2Y FCV-03-1F 8-7 2 A 0.375 HEEDLE A SO C YES FC EC QR FS QR Pl 2Y SLT-1 2Y HCV-3615 H-7 2 B 6.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3616 G-7 2 8 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3617 G-7 , 2 B 2.000 GLOBE A MO C YES FAI EO QR Pl 2Y HCV-3618 F-6 1 B 1.000 GLOBE A DO C YES FC EC CS VR-33 FS CS PI 2Y HCV-3625 F-7 2 8 6.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3626 E-7 2 8 2.000 GLOBE A MO C YES FAI EO QR Pl 2Y HCV-3627 E-7 2,, B 2.000 GLOBE A MO C YES FAI EO QR Pl 2Y HCV-3628 F-3 1 B F 000 GLOBE A DO C YES FC EC CS VR-33 FS CS

'R PI 2Y HCV-3635 D-7 2 8 6.000 GLOBE A MO C YES FAI EO PI 2Y HCV-3636 C-7 2 8 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3637 C-7 2 8 2.000 GLOBE A MO C YES FAI EO QR PI 2Y

FLORIDA POMER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE: 13 P 8 ID: 8770-G-078 SH 131 (cont) SYSTEM: SAFETY INJECTION SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS HCV-3638 B-5 1 8 1.000 GLOBE A DO C YES FC EC CS VR-33 FS CS

'Pl 2Y HCV-3645 B-7 2 B 6.000 GLOBE A MO C YES FAI EO QR Pl 2Y HCV-3646 A-7 2 B 2.000 GLOBE A MO C YES FAI EO QR Pl 2Y II HCV-3647 A-7 2 B 2.000 GLOBE A MO C YES FAI EO QR PI 2Y HCV-3648 B-3 1 B 1.000 GLOBE A DO C YES FC EC CS VR-33 FS CS PI 2Y MV-03-1A E-7 2 B 2.000 GLOBE A MO LC YES FAI EC QR EO QR Pl 2Y MV-03-1B D-7 2 B 2.000 GLOBE A MO LC YES FAI EC QR EO QR Pl 2Y V-3113 G-7 1 AC 2.000 CHECK A S/A C NO CV/C 2Y VR-10 CV/0 RF VR-10 SLT-2 2Y VR-2 V-3114 H-7 1 AC 6.000 CHECK A S/A C HO CV/C 2Y VR-11 CV/0 CS VR-11 V-3123 '-7 1 AC 2.000 CHECK A S/A C NO SLT-2 CV/C CV/0 SLT-2 2Y 2Y RF 2Y VR-2 VR-10 VR-10 VR-2 V-3124- F-7 1 AC 6.000 CHECK A S/A C HO CV/C 2Y VR-11 CV/0 CS VR-11 SLT-2 2Y VR-2 V-3133 C-7 1 AC 2.000 CHECK A S/A C HO CV/C 2Y VR-10 CV/0 RF VR-10 SLT-2 2Y VR-2

4 "4

FLORIDA PONER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE: 14 1S>>CSSCNCCS I C5 5 N1 P & ID: 8770-G-078 SH 131 (cont) SYSTEM: SAFETY INJECTION SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-3134 D-7 1 AC 6.000 CHECK A S/A C NO CV/C 2Y VR-11 CV/0 CS VR.11 SLT-2 2Y VR-2 V-3143 8-7 1 AC 2.000 CHECK A S/A C NO CV/C 2Y VR-10 CV/0 RF VR-10 SLT 2 2Y VR-2 V-3144 B-7 1 AC 6.000 CHECK A S/A C NO CV/C 2Y VR-11 CV/0 CS VR-11 SLT-2 2Y VR-2 V-3215 F-5 2 AC 12.000 CHECK A S/A C NO CV/C 2Y VR-12 INSP RF VR 12 SLT-2 2Y VR-2 V-3217 F.4 1 AC 12.000 CHECK A S/A C NO CV/C 2Y VR-13 CV/PO CS VR-13 INSP RF VR-13 SLT-2 2Y VR-2 V-3225 F-2 2 AC 12.000 CHECK A S/A C NO CV/C 2Y VR-12 INSP RF VR-12 SLT-2 2Y VR-2 V-3227 F-2 1 AC 12.000 CHECK A S/A C NO CV/C 2Y VR.13 CV/PO CS VR-13 INSP RF VR-13 SLT-2 2Y VR-2 V-3235 8-5 2 AC 12.000 CHECK A S/A C NO CV/C 2Y VR-12 INSP RF VR-12 SLT.2 2Y VR-2 V-3237 8-4 1 AC 12.000 CHECK A S/A C NO CV/C 2Y VR-13 CV/PO CS VR-13 INSP RF VR-13 SLT-2 2Y VR-2 V-3245 C-2 2 AC 12.000 CHECK A S/A C NO CV/C 2Y VR-12 INSP RF VR-12 SLT-2 2Y VR-2

FLORIDA POMER AHD LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 15 P 8, ID: 8770-G-078 SH 131 (cont) SYSTEH: SAFETY INJECTION SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZP TYPE A/P TYPE POS. IND HODE EXAH FREQ REQ. REHARKS V-3247 8-1 1 AC 12.000 CHECK A S/A C HO CV/C 2Y VR-13 CV/PO CS VR-13 IHSP RF VR-13 SLT-2 2Y VR-2 V-3468 D.7 2 C 2 ~ 000 RELIEF A S/A C NO SRV RF V-3469 E-4 2 C 1.000 RELIEF A S/A C NO SRV RF

~ V-3480 E-5 1 A '0.000 GATE A HO LC YES FAI EO CS PI 2Y SLT-2 2Y VR-2 V-3481 E-5 1 A 10.000 GATE A HO LC YES FAI EO CS Pl 2Y SLT-2 2Y VR-2 V-3482 E-5 2 C 1.000 RELIEF A S/A C NO SRV RF V-3483 E-6 2 C 2.000 RELIEF A S/A C HO SRV RF V-3614 F-5 2 8 12.000 GATE A HO LO YES FAI EC CS PI 2Y V-3624 F-2 2 8 12.000 GATE A HO LO YES FAI EC CS Pl 2Y V-3634 8.5 2 8 12.000 GATE A HO LO YES FAI EC CS PI 2Y V-3644 8-2 2 8 12.000 GATE A HO LO YES FAI EC CS Pl 2Y V-3651 D-4 1 A 10.000 GATE A HO LC YES FAI EO CS Pl 2Y SLT-2 2Y VR-2 V-3652 0-4 1 A 10.000 GATE A HO LC YES FAI EO CS Pl 2Y SLT-2 2Y VR-2

FLORIDA POMER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE: 16 P & ID: 8770-G-078 SH 150 SYSTEH: SAHPLING SYSTEH ACT. NORH REH FAlL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS ~ IND HODE EXAH FREQ REQ ~ REHARKS V-5200 G.7 2 A 0.375 GLOBE A 00 C YES FC EC QR FS QR Pl 2Y SLT-1 2Y V-5201 F-7 2 A 0.375 GLOBE A 00 C YES FC EC QR FS QR Pl 2Y SLT-1 2Y

'-5202 E-7 2 A 0.375 GLOBE A DO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5203 G-7 2 A 0.375 GLOBE A DO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-5204 F-7 2 A 0.375 GLOBE A DO C YES FC EC QR FS QR PI 2Y SLT.1 2Y V-5205 E-7 2 A- 0.375 GLOBE A DO C QR QR 2Y 2Y

FLORIDA POMER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 17 XROCViSIRC C01SS P ~SISQSISS0550SS P 5 ID: 8770-G-078 SN 160 SYSTEH: lJASTE HANAGEHENT SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAH FREQ REQ. REHARKS V-6301 F-6 2 A 3.000 DIAPN A DO 0 YES FC EC QR FS QR Pl 2Y SLT.1 2Y V-6302 F-6 2 A 3.000 DIAPN A DO 0 QR QR 2Y 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE': 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 18 P S ID: 8770-0-078 SH 163 SYSTEM: WASTE MANAGEMENT SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SI2g TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS V-6554 F-7 2 A 1.000 DIAPH A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6555 F-7 2 A 1 F 000 DIAPH A DO 0 YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6741 D-7 2 A 1.000 GLOBE A DO, 0/C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-6779 0-7 2 A 1 F 000 CHECK A S/A 0/C NO CV/C QR SLT-1 2Y

FLORIDA POMER AHD LIGHT COMPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant . Unit 1 PAGE  : 19 P 8 ID: 8770-G-079 SH 1 SYSTEM: MAIN STEAM SYSTEM 5505CXOCRC 0 R5C 55 XII ACT. HORN REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS HCV-08-1A K-12 2 BC 34.000 STPCK A AO 0 YES EC CS PEC PI 2Y HCV-08-18 C-12 2 BC 34.000 STPCK A AO 0 YES EC CS PEC QR Pl 2Y HCV-08-2A J-10 2 B 8.000 GLOBE A AO C YES FC EC QR EO QR FS QR PI 2Y HCV-08.28 C-10 2 8 8.000 GLOBE A AO C YES FC EC QR EO QR FS QR Pl 2Y MV.08.03 M-10 2 B 4.000 GATE A MO C YES FAI EO QR PI 2Y MV-08.13 H-9 2 B 3.000,GATE A MO C YES FAI EO QR Pl 2Y MV-08-14 E-9 2 B 3.000 GATE A 'MO C YES FAI EO QR Pl 2Y MV-08-1A K-12 2 8 3 ~ 000 GATE A MO C YES FAI EC CS Pl 2Y MV.08-18 0-11 2 8 3.000 GATE A MO C YES FAI EC CS PI 2Y V.08117 K.12 2 C 34.000 CHECK A S/A 0 NO CV/C RF VR.14 V-08130 G-9 2 C 4.000 CHECK A S/A 0 HO CV/0 CS CV/PO QR V-08131 G-9 2 8 F 000 GATE A MAH 0 NO EC QR V-08148 C-12 2 C 34.000 CHECK A S/A 0 NO CV/C RF VR-14 V-08163 E-9 2 C 4.000 CHECK A S/A C HO CV/0 CS CV/PO QR

I f 1

FLORIDA POMER AHD LIGHT CONPANY REVISIOH: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 20 P 8 ID: 8770-G-079 SH 1 (cont) SYSTEN: HAIN STEAN SYSTEN ACT. HORN REN FAIL TEST RELIEF VALVE HUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD NODE EXAN FREQ REQ. REHARKS V-08164 F-9 2 B 4.000 GATE A HAH 0 HO EC QR V-08448 E-9 2 C 4.000 CHECK A S/A C NO CV/C CS CV/0 CS CV/PO QR V-08492 J-9 2 C 4.000 CHECK A S/A C HO CV/C CS CV/0 CS CV/PO QR t

V-8201 K-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8202 K-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8203 K-11 2 C 6.000 RELIEF A S/A C HO SRV RF V-8204 K-'11 2 C 6.000 RELIEF A S/A C HO SRV . RF V-8205 C-11 2 C 6.000 RELIEF A S/A C HO SRV RF V-8206 C-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8207 C-11 2 C 6.000 RELIEF A S/A C HO SRV RF V-8208 C-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8209 K-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8210 K-11 2 C 6.000 RELIEF A S/A C HO SRV RF V-8211 K 11 2 C 6.000 RELIEF A S/A C HO SRV RF V-8212 K-11 2 C 6.000 RELIEF A S/A C HO SRV RF V-8213 C-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8214 C-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8215 C-11 2 C 6.000 RELIEF A S/A C NO SRV RF V-8216 C-11 2 C 6.000 RELIEF A S/A C NO SRV RF

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FLORIDA PONER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 21 CRC 5 2 55 I5C5R55N P 8 ID: 8770-G-080 SH 3 SYSTEM: FEEDWATER SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS MV-09-07 E-6 2 8 20 F 000 GATE A MO 0 YES FAI EC CS Pl 2Y MV-09-08 E-11 2 B 20.000 GATE A MO 0 YES FAI EC CS PI 2Y MV-09-09 E-1 3 B 4.000 GLOBE A MO C YES FAI EC, QR EO QR PI 2Y MV-09-10 E-16 3 8 4.000 GLOBE A MO C YES FAI EC QR EO QR Pl 2Y MV-09-11 E-4 3 8 4.000 GLOBE A MO YES FAI EC QR EO QR PI 2Y MV-09-12 E-13 3 8 4 ~ 000 GLOBE A MO C YES FAI EC QR EO QR Pl 2Y MV-09-13 K-2 3 8 2.500 GLOBE A MO C YES FAI EO QR Pl 2Y MV-09-14 M-2 3 B 2.500 GLOBE A MO C YES FAI EO QR Pl 2Y V-09248 E-6 2 C 20.000 CHECK A S/A 0 NO CV/C CS V-09280 E.11 2 C 20.000 CHECK A S/A 0 NO CV/C CS V-12174 K-'11 3 C 8.000 CHECK A S/A C NO CV/0 CS CV/PO QR V-12176 K-11 3 C 8.000 CHECK A S/A C NO CV/0 CS CV/PO QR V-12507 M-9 2 C 0 '50 CHECK A S/A C NO CV/PO QR VR-31 INSP RF VR-31 V-9107 M-4 3 C 4.000 CHECK A S/A C NO CV/C CS CV/0 CS

'V-9119 D-1 2 C 4.000 CHECK A S/A C NO CV/0 CS

FLORIDA PSIER AHD LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 22 P II ID: 8770-0.080 SH 3 (cont) SYSTEM: FEEDllATER SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS V-9123 K-4 3 C 4.000 CHECK A S/A C HO CV/C CS CV/0 CS V-9135 D-16 2 C 4.000 CHECK A S/A C NO CV/0 CS V-9139 H-4 3 C 6.000'CHECK A S/A C- NO CV/0 CS V-9151 E-4 2 C F 000 CHECK A S/A C NO CV/0 CS V-9157 E-13 2 C 4.000 CHECK A S/A C NO CV/0 CS 1

V-9252 A-6 2 C 18.000 CHECK A S/A 0 NO CV/0 QR V-9294 A-11 2 C 18.000 CHECK A S/A 0 HO CV/0 QR V-9303 1-4 3 C 2.000 CHECK A S/A C NO CV/PO QR VR-31 IHSP RF VR-31 V-9304 L.4 3 C 2.000 CHECK A S/A C NO CV/PO QR VR-31 IHSP RF VR.31 V-9305 H-4 3 C 2.000 CHECK A S/A C XO CV/PO QR VR-31 IHSP RF VR.31

FLORIDA POMER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 23 P & ID: 8770-G-082 SH 1 SYSTEM: INTAKE COOLING NATER SYSTEM ACT. NORM REM FAIL . TEST RELIEF VALVE NUMBER COORS CL CAT ~ SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS MV-21-2 E-5 3 8 24.000 BUTFLY A MO 0 YES FAI EC CS PI 2Y MV-21-3 F-4 3 8 24.000 BUTFLY A MO 0 YES FAI EC CS PI 2Y S8-21165 F-5 3 8 36.000 BUTFLY A MAH 0/C NO EC QR EO QR S8-21211 F-6 3 8 36.000 BUTFLY A MAN 0/C NO EC QR EO OR TCV-14-4A 8-3 3 8 30.000 BUTFLY A PO 0 NO FO EE CS VR-35 FS CS TCV-14-48 8-3 3 8 30.000 BUTFLY A PO 0 NO FO EE CS VR-35 FS CS V-21162 H-4 3 C 30.000 CHECK A S/A 0/C NO CV/C QR CV/0 QR V-21205 H-S 3 C 30.000 CHECK A S/A 0/C NO CV/C QR CV/0 QR V-21208 H-7 3 C 30.000 CHECK A S/A 0/C NO CV/C OR CV/0 OR

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FLORIDA POMER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 24 P II ID: 8770-G-082 SH 2 SYSTEM: INTAKE COOLING HATER SYSTEM ACT. HORN REM FAIL TEST RELIEF VALVE NUMBER COORS CL CAT. SIZP TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-21-3A I-4 3 8 F 000 GLOBE A PO 0 NO FC EC QR FS QR FCV-21-38 1-4 3 8 2.000 GLOBE A PO 0 HO FC EC QR FS QR V-21005 H-3 3 C 2.000 CHECK A S/A C NO CV/C QR CV/0 QR V-21010 H-4 3 C 2.000 CHECK A S/A C HO CV/C QR CV/0 QR V-21015 J-4 3 C 2.000 CHECK A S/A C HO . CV/C QR V-21017 J-4 3 C 2.000 CHECK A S/A C NO CV/C QR V-21030 8-15 3 C 1.000 CHECK A S/A 0 HO CV/0 QR V-21032 8 15 3 C 1.000 CHECK A S/A 0 HO CV/0 QR V-21044 8-15 3 C 1.000 CHECK A S/A 0 NO CV/0 QR V-21046 8-16 3 C 1.000 CHECK A S/A 0 NO CV/0 QR V-21058 8-16 3 C 1.000 CHECK A S/A 0 HO CV/0 QR V-21060 8-16 3 C 1.000 CHECK A S/A 0 HO CV/0 QR

FLORIDA POWER AHD LIGHT CONPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 25 P 8 ID: 8770.G.083 SYSTEN: COMPONENT COOLING SYSTEN SORCORSCRR iCCZC I CC SR CCRC 1 RC1C10lSICC ACT. HORN REN FAIL TEST RELIEF VALVE NUNBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IHD NODE EXAN FREQ REQ. REHARKS HCV-14.1 D-6 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-5 HCV-14-10 H-15 3 B 16.000 BUTFLY A PO 0 YES FC EC QR FS QR Pl 2Y

) HCV-14-2 D-2 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y VR.5 HCV-14-3A N-3 3 8 14.000 BUTFLY A PO 0 YES FO EO CS FS CS Pl 2Y HCV-14-3B H-3 3 B 14.000 BUTFLY A PO 0 YES FO EO CS FS CS Pl 2Y HCV-14-6 D-1 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT.1 2Y VR-5 HCV.14.7 D-5 2 A 8.000 BUTFLY A PO 0 YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-5 HCV-14-BA F-14 3 8 16.000 BUTFLY A PO 0 YES FC EC QR FS QR Pl 2Y HCV-14.88 F-15 3 B 16.000 BUTFLY A PO 0 YES FC EC QR FS QR Pl 2Y HCV-14-9 G-15 3 8 16.000 BUTFLY A PO 0 YES FC EC QR FS QR PI 2Y

FLORIDA PCMER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 26 P & ID: 8770-G.083 (cont) SYSTEM: COMPONENT COOLING SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS HV-14-1 D-16 3 8 24 F 000 BUTFLY A HO 0/C YES FAI EC QR EO QR PI 2Y MV-14-2 0-17 3 8 24.000 BUTFLY A HO 0/C YES FAI EC QR EO QR Pl 2Y MV-14-3 0-16 3 8 24.000 BUTFLY A HO 0/C YES FAI EC QR EO QR Pl 2Y HV-14-4 G-17 3 8 24 ~ 000 BUTFLY A HO 0/C YES FAI EC QR EO QR Pl 2Y MV-14-5 G-7 3 8 10.000 BUTFLY A HO 0 YES FAI EO CS Pl 2Y HV-14-6 G-7 3 8 10.000 BUTFLY A HO 0 YES FAI EO CS Pl 2Y MV-14-7 G-7 3 8 10.000 BUTFLY A HO 0 YES FAI EO CS PI 2Y HV-14-8 0-7 3 8 10.000 BUTFLY A HO

' YES FAI EO CS PI 2Y S8-14156 C.17 2 8 24 F 000 BUTFLY A HAN LO NO EC QR EO QR S8-14160 0-17 2 8 24.000 BUTFLY A MAN LO NO EC QR EO QR SB-'l4166 8-15 2 8 24.000 BUTFLY A HAN LO NO EC QR EO QR S8-14167 8-15 2 8 24.000 BUTFLY A HAN LO NO EC QR EO QR S8-14169 8-15 2 8 24.000 BUTFLY A HAN LC NO EC QR EO QR S8-14177 C-15 2 8 24.000 BUTFLY A MAN LO NO EC EO QR

FLORIDA POWER AND LIGHT CONPAHY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 27 P 8 ID: 8770-G-083 (cont) SYSTEN: CONPOHEHT COOLING WATER SYSTEH ACT. HORN REN FAIL TEST RELIEF VALVE HUNBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAN FREQ REQ. REHARKS SB-14178 D.15 2 B 24.000 BUTFLY A NAN LO HO EC QR EO QR SB-14439 C-15 2 8 24.000 BUTFLY A NAN C NO . EC QR EO QR V-14143 E-16 3 C 20.000 CHECK A S/A 0/C HO CV/C QR CV/0 QR V-14147 E-16 3 C 20.000 CHECK A S/A 0/C HO CV/C QR CV/0 QR V-14151 E-'17 3 C 20.000 CHECK A S/A 0/C HO CV/C QR CV/0 QR

FLORIDA POWER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 28 P 8 ID: 8770-G-084 SN 1 SYSTEH: HAKE-UP MATER SYSTEH ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAH FREQ REQ. REHARKS HV-15-1 N-16 2 A 2.000 GATE A HO C YES FAI EC DR PI 2Y SLT.1 2Y V-15328 I-16 2 AC 2.000 CHECK A S/A C NO CV/C 2Y VR-15 SLT-1 2Y

FLORIDA PINER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 29 P 8 ID: 8770-G-085 SH 1 SYSTEH: SERVICE AIR SYSTEH C 5'5 CCRCSCCCCS1ZE ZZ ACT. NORH REH FAlL TEST RELIEF VALVE NUMBER COORD. CL CAT. SI2E TYPE A/P TYPE POS. IND HOOE EXAM FREQ REQ. REMARKS V-18794 G-6 2 A 2.000 GLOBE P HAN LC NO SLT-1 2Y vr-5 V-18796 G-6 2 A 2.000 GLOBE P MAN LC NO SLT-1 2Y VR-5 V-18797 G-6 2 A 1.000 BALL P HAN LC NO SLT-1 2Y V-18798 G-6 2 A 1.000 BALL P HAN LC NO SLT-1 2Y

FLORIDA PONER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE: 30 15~XHS I R5>> I 1C S<<CSCI1501COCCC P 8 ID: 8770-G.085 SN 2 SYSTEH: INSTRUHENT AIR SYSTEH ACT. NORH REH FAlL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAH FREQ REQ. REHARKS HV-18-1 F-6 2 A 2.000 GLOBE A HO 0 YES FAI EC CS Pl 2Y SLT-1 2Y V-18195 E-5 2 AC 2.000 CHECK A S/A 0 NO CV/C 2Y VR-16 SLT-1 2Y V-18279 N-1 2 C 0.500 CHECK A S/A 0 NO CV/C CS V-18283 G-2 2 C 0.500 CHECK A S/A 0 NO CV/C CS

FLORIDA PRIER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 31 P & ID: 8770-6-086 SYSTEH: HISCELLANEOUS SYSTEHS ACT. NORH REH FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAM FREQ REQ. REMARKS V-17204 J-12 3 C 1 ~ 500 CHECK A S/A C NO CV/0 QR V-17214 L.12 3 C 1.500 CHECK A S/A C NO CV/0 QR

FLORIDA POMER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 32 P & ID: 8770-G-088 SYSTEH: CONTAINHENT SPRAY SYSTEH ACT. NORH REH FAlL TEST RELIEF VALVE NUHBER COORS CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAM FREQ REQ. REHARKS FCV-07-1A G-12 2 8 12.000 GLOBE A DO C YES FO EO QR FS QR Pl 2Y FCV-07-18 N-12 2 8 12.000 GLOBE A DO C YES FO EO QR FS QR Pl 2Y LCV-07-11A J.11 2 A 2.000 GLOBE A DO 0/C YES FC EC QR FS QR PI 2Y SLT-1 2Y VR-5 LCV-07-118 J-12 2 A 2.000 GLOBE A DO 0/C YES FC EC QR FS QR Pl 2Y SLT 1 2Y VR-5 MV-07-1A E-3 2 8 24.000 BUTFLY A HO 0 YES FAI EC QR Pl 2Y HV-07-18 E-2 2 8 24.000 BUTFLY A HO 0 YES FAI EC QR Pl 2Y HV-07-2A K-12 2 8 24 ~ 000 BU'TFLY A HO C YES FAI EO CS Pl 2Y MV-07-28 K-12 2 8 24.000 BUTFLY A HO C YES FAI EO ~ CS Pl 2Y HV-07-3A G-13 2 8 12.000 GATE A HO LO YES FAI EC QR PI 2Y HV-07-38 N-13 2 8 12 ~ 000 GATE A HO LO YES FAI EC QR Pl 2Y SE-07-1A N-4 2 8 2.000 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SE-07-18 N-5 2 8 2.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y

FLORIDA POWDER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 33 P 8 ID: 8770-G-088 (cont) SYSTEM: COHTAIHMEHT SPRAY SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS SE-07-2A H-4 2 8 2.000 GLOBE A SO C YES FC EC EO QR FS QR PI 2Y SE-07-28 H-5, 2 8 2.000 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y V-07119 J-7 2 C 24.000 CHECK A S/A C NO CV/PO QR VR-17 IHSP RF VR-17 V-07120 J-7 2 C 24.000 CHECK A S/A C HO CV/PO QR VR-17 INSP RF VR.17 V-07129 H-5 2 C 12.000 CHECK A S/A C NO CV/0 RF VR-18 CV/PO QR VR-18 V-07143 G.5 2 C 12.000 CHECK A S/A C NO CV/0 RF VR-18 CV/PO QR VR-18 V-07170 J-12 2 A 3.000 GATE P MAH LC HO SLT-1 2Y VR-5 V-07172 K.12 2 C 24 F 000 CHECK A S/A C HO IHSP RF VR-19 V-07174 K-12 2 C 24.000 CHECK A S/A C HO IHSP RF VR-19 V-07188 I-14 2 A 3.000 GATE P MAN LC HO SLT-1 2Y VR-5 V-07189 I-14 2 A 3.000 GATE P MAN LC HO SLT-1 2Y VR-5 V-07192 G-14 2 C 10.000 CHECK A S/A C HO IHSP RF VR.20 V-07193 F-14 2 C 10.000 CHECK A S/A C NO INSP RF VR.20 V-07206 1-12 2 A 3.000 GATE P MAH LC NO SLT-1 2Y VR-5 V-07231 K-5 2 C 2.000 CHECK A S/A C HO CV/0 QR V-07232 K-4 2 C 2.000 CHECK A S/A C NO CV/0 QR V-07256 J-1 2 C 2.000 CHECK A S/A C NO CV/C RF VR-21 CV/0 RF VR-21

FLORIDA P(QER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 'AGE: 34 P 8 ID: 8770-G-088 'cont) SYSTEM: COHTAINNEHT SPRAY SYSTEM ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORS CL CAT. SIZE TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS l

V-07258 J-2 2 C 2.000 CHECK A S/A C NO CV/C RF VR-21 CV/0 RF VR-21 V-07269 J-2 2 C 3.000 CHECK A S/A C HO CV/PO QR VR-22 IHSP RF VR-22 V-07270 K-2 2 C 3.000 CHECK A S/A C HO CV/PO QR VR-22 INSP RF VR-22

FLORIDA PSIER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear PLant - Unit 1 PAGE  : 35 P 8 ID: 8770-G-092 SYSTEH: HISCELLANEOUS SAHPLING SYSTEHS ACT. NORH REH FAlL TEST RELIEF VALVE NUMBER, COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAH FREQ REQ. REMARKS FCV-26-1 G-2 2 A 1.000 GLOBE A DO 0 QR QR 2Y 2Y FCV-26-2 G-4 2 A 1.000 GLOBE A DO 0 QR QR 2Y 2Y

'CV-26-3 H-2 2 A 1.000 GLOBE A 00 C QR QR 2Y 2Y FCV-26-4 H-4 2 A 1.000 GLOBE A DO 0 OR QR 2Y 2Y FCV-26-5 I-2 2 A 1 F 000 GLOBE A DO 0 QR QR 2Y 2Y FCV-26-6 I-4 2 A, 1.000 GLOBE A 00 0 QR QR 2Y 2Y FSE-27-1 A-12 2 A 0.375 GLOBE A SO C QR QR QR 2Y 2Y FSE-27-10 C-13 2 A 0.375 GLOBE A SO C QR QR QR 2Y 2Y

FLORIDA POMER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 36 P 8 ID: 8770-G-092 (cont) SYSTEH: HISCELLANEOUS SAHPLING SYSTEHS ACT. NORH REH FAlL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND HODE EXAH FREQ REQ. REHARKS FSE-27-11 C-13 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT-1 2Y FSE-27-2 8-12 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-3 B-12 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT-1 2Y FSE-27-4 B-12 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT-1 2Y FSE-27-5 C-14 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT-1 2Y FSE-27-6 8-14 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT-1 2Y FSE-27-7 8-14 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR Pl 2Y SLT-1 2Y

FLORIDA POWER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE: 37 P F ID: 8770-G-092 <cont) SYSTEM: MISCELLANEOUS SAHPLING SYSTEHS ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND HOOE EXAM FREQ REQ. REMARKS FSE-27-8 C-11 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y FSE-27-9 C-14 2 A 0.375 GLOBE A SO C YES FC EC QR EO QR FS QR PI 2Y SLT-1 2Y V-27101 8-13 2 AC 0.375 CHECK A S/A C NO CV/C RF VR-32 CV/0 QR SLT-1 2Y V-27102 B-13 2 AC 0.375 CHECK A S/A C HO CV/C RF VR 32 CV/0 QR SLT-1 2Y V-27105 E-13 2 C 0.375 CHECK A S/A C NO CV/0 QR V-27110 E-13 2 C 0.375 CHECK A S/A C NO CV/0 QR V-29305 D-8 2 C 0.375 CHECK A S/A HO CV/C QR VR-24 CV/0 QR V-29306 D-8 2 C 0.375 CHECK A S/A HO CV/C QR VR.24 CV/0 QR

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FLORIDA POWER AND LIGHT COHPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucia Nuclear Plant,- Unit 1 PAGE  : 38 IRRR CCRS 0 5 0 0 i5l 0 5515555$ 0 5C 5 51%50NCCtSC C1 I SRCCV P 8 ID: 8770-G-093 SYSTEH: HISCELLANEOUS SYSTEHS ACT ~ NORH REH FAlL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND NODE EXAH FREQ REQ. REHARKS SB-37-1 J-11 3 8 54 F 000 BUTFLY A AO C YES FO EO SP, VR-25 FS SP VR-25 PI 2Y SB-37-2 J-12 3 8 54.000 BUTFLY A AO C YES FO EO SP VR-25 FS SP VR 25 Pl 2Y V-00101 F-11 2 A 8.000 GATE P HAN LC NO SLT-1 2Y V-00139 l-1 2 A 0.375 GLOBE P HAN LC NO SLT-1 2Y VR-5 V-00140 I-1 2 A F 000 GLOBE P HAX LC NO SLT-1 2Y VR-5 V-00143 I-2 2 A 1.000 GLOBE P HAN LC NO SLT-1 2Y VR-5 V-00144 I-2 2 A 0.375 GLOBE P HAN LC NO SLT-1 2Y VR-5

FLORIDA PONER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Piant - Unit 1 PAGE  : 39 P & ID: 8770-G-096 SH 1 SYSTEM: EMERGENCY DIESEL GENERATOR 1A SCCSC50CR 5t ACT ~ NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD MODE EXAM FREQ REQ. REMARKS FCV-59-1A1 K-5 3 8 1.500 GATE A AO C HO EO QR VR 27 FCV-59-2Al K.2 3 8 1.500 GATE A AO C NO EO QR VR-27 FCV-59-3A1 G-9 3 8 1 '00 GATE A AO C HO EO QR VR-27 FCV.59.4A1 B 10 3 8 1.500 GATE A AO C HO EO QR VR-27 SE-59-1A L-1 3 8 2.000 GLOBE A SO C NO FC EE QR VR-26 FS QR SE-59-3A I-6 3 8 1.500 GATE A SO C NO EO QR VR-27 SE-59-4A A-8 3 8 1.500 GATE A SO C NO EO QR VR-27 SE-59-5A I-3 3 8 1.500 GATE 'A SO C HO EO QR VR-27 SE-59-6A H 8 3 B 1.500 GATE A AO C NO EO QR VR-27 SR-59-3A J-12 3 C 0.000 RELIEF A S/A C NO SRV RF SR-59-4A J-11 3 C 0.000 RELIEF A S/A C HO SRV RF SR-59-SA J-9 3 C 0.000 RELIEF A S/A C NO SRV RF SR-59-6A J-8 3 C- 0.000 RELIEF A S/A C HO SRV RF V-59079 J-14 3 C 1.000 CHECK A S/A C HO CV/C QR V-59156 K-14 3 C 1.000 CHECK A S/A C NO CV/C QR

FLORIDA POWER AND LIGHT COMPAHY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucia Nuclear Plant - Unit 1 PAGE  : 40 55155 SSQSOSC 155 5 505$ 510>>ROC P II ID: 8770-G-096 SH 2 SYSTEM: EMERGEHCY DIESEL GENERATOR 18 ACT ~ HORN REM FAIL TEST RELIEF VALVE HUMBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IND MODE EXAM FREQ REQ. REMARKS FCV-59-181 M-9 3 8 1 '00 GATE A AO C HO EO QR VR-27 FCV-59-281 8-9 3 8 1.500 GATE A AO C NO EO QR VR-27 FCV-59-381 J-5 3 8 '1.500 GATE A AO C HO EO QR VR-27 FCV 59-481 J-2 3 8 1.500 GATE A AO C HO EO QR VR-27 SE.59.18 L-1 3 8 2.000 GLOBE A SO C HO FC EE QR VR.26 FS QR SE-59-38 I-3 3 8 1.500 GATE A SO C NO EO QR VR-27 SE-59.48 A-8 3 8 1.500 GATE A SO C HO EO QR VR-27 SE.59.58 ,1-6 3 8 1 ~ 500 GATE .A SO C HO EO QR VR-27 SE-59-68 M-8 3 8 1.500 GATE A SO C HO EO QR VR-27 SR-59-38 J-12 3 C 0.000 RELIEF A 8/A C NO SRV RF SR-59-48 J-11 3 C, 0.000 RELIEF A S/A C NO SRV RF SR-59-58 J-9 3 C 0.000 RELIEF A S/A C HO , SRV RF SR-59-68 J-8 3 C 0.000 RELIEF A S/A C NO SRV RF V-59125 J-14 3 C 1.000 CHECK A S/A C HO CV/C QR V-59158 K-14 3 C 1.000 CHECK A S/A C HO CV/C QR

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FLORIDA PRIER AND LIGHT CONPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 41 P & ID: 8770-G-878 SYSTEN: HEATING, VENT., & AIR COHDITIONIHG aa - -aa-a s -a-aasaass-as- - aaaaaaaaaaaaaaaaas- -

ACT. HORN REN FAlL TEST RELIEF VALVE HUHBER COORD. CL CAT ~ SIZE TYPE A/P TYPE POS. IND NODE EXAH FREQ REQ. RENARKS FCV-25-1 J-15 2 8 48.000 BUTFLY A PO C YES FC EC CS FS CS PI 2Y FCV-25-2 J-15 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y SLT.1 2Y VR-5 FCV-25-3 J-15 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-5 FCV-25-4 K-12 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS PI 2Y SLT-1 2Y VR-5 FCV-25-5 K-11 2 A 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y SLT-1 2Y VR-5 FCV-25-6 K-11 2 8 48.000 BUTFLY A PO C YES FC EC CS FS CS Pl 2Y FCV-25-7 L-12 2 A 24.000 BUTFLY A 00 C YES FC EC FS QR Pl 2Y SLT-1 2Y FCV-25-8 L-12 2 A 24.000 BUTFLY A DO C YES FC EC QR FS QR PI 2Y SLT-1 2Y V-25-11 K-15 2 A 3.000 GATE P NAN LC NO SLT-1 2Y VR-5 V-25-12 K- 15 2 A 3.000 GATE P HAH LC NO SLT-1 2Y VR-5 V-25-13 I-12 2 A 3.000 GATE P HAH LC HO SLT-1 2Y VR-5 P

V-25-14 l-12 2 A 3.000 GATE P NAH LC HO SLT-1 2Y VR-5

FLORIDA POHER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE  : 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 42 R5$ 000 N? i SSS2C555 55 Z5 5 5 5$

P 8 ID: 8770-G-878 (cont) SYSTEM: NEATIHG, VENT., 8 AIR COHDITIOHIHG ACT. NORM REM FAIL TEST RELIEF VALVE NUMBER COORD. CL CAT ~ SIZE. TYPE A/P TYPE POS. IND MODE EXAN FREQ REQ. REMARKS V-25-15 J-11 2 A 3.000 GATE P MAH LC NO SLT-1 2Y V-25-16 J-11 2 A 3.000 GATE P MAH LC NO SLT-1 "

2Y V-25-20 L-12 2 AC 24.000 CHECK A S/A C HO CV/C CS SLT-1 2Y V-25-21 L-12 2 AC 24.000 CHECK A S/A C NO CV/C CS SLT.1 2Y

44 I

FLORIDA POWER AND LIGHT COMPANY REVISION: 2 VALVE TABLES DATE: 12/12/89 Saint Lucie Nuclear Plant - Unit 1 PAGE  : 43 XR515$ %5555 0 R 55555 P & ID: 8770-G-879 SYSTEH: HEATING, VEHT ~ , AND AIR CONDITIONING ACT. NORH REH FAIL TEST RELIEF VALVE NUHBER COORD. CL CAT. SIZE TYPE A/P TYPE POS. IHD HCOE EXAH FREQ REQ. REHARKS FCV-25-11 H-14 2 8 24.000 BUTFLY A HO YES FAI EC QR EO QR Pl 2Y FCV-25-12 J-14 2 8 24 ~ 000 BUTFLY A MO YES FAI EC QR EO QR PI 2Y FCV-25-13 I-16 2 8 12.000 BUTFLY A HO NO YES FAI EO QR Pl 2Y FCV-25-14 E-11 3 8 0 ~ 000 BUTFLY A HO C YES FAI EC QR EO QR Pl 2Y FCV-25-17 E-11 3 8 0.000 BUTFLY A HO C - YES FAI EC QR EO QR Pl 2Y FCV-25-18 A-10 3 8 0.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y FCV-25-19 A-11 3 8 0.000 BUTFLY A HO 0 YES FAI EC QR PI 2Y FCV-25-24 8-10 3 8- 0.000 BUTFLY A HO 0 YES FAI EC QR Pl 2Y FCV-25-25 8-11 3 8 0.000 BUTFLY A HO 0 YES FAI EC QR Pl 2Y V-25-23 'J-14 2 C 24.000 SRCK A S/A NO CV/0 QR V-25-24 H-14 2 C 24.000 SRCK A S/A HO CV/0 QR

Appendix D Valve Program Requests for Relief

0 I

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-1 SYSTEM:

Various COMPONENTS:

Any valves tested during cold shutdown conditions.

CATEGORY:

Various FUNCTION:

I Various SECTION XI RE UIREMENT:

Valves shall be exercised ... unless such operation is not practical during plant operation. If only limited operation is practical during plant operation, the valve shall be part-stroke exercised during plant operation and full stroke exercised during cold shutdowns. Full stroke exercising during cold shutdowns for all valves not full-stroke exercised during plant operation shall be on a frequency determined by the intervals between shutdowns as follows:

For intervals of 3 months or longer exercise during each shutdown. (IWV-3412, IWV-4315 and IWV-3522)

BASIS FOR RELIEF:

In many instances testing of all valves designated for testing during cold shutdown cannot be completed due to the brevity of an outage or the lack of plant conditions needed for testing specific valves. It has been the policy of the NRC that .if testing commences in a reasonable time and reasonable efforts are made to test all valves, then outage extension or significant changes in plant conditions are not required when the only reason is to provide the opportunity for completion of valve testing.

ASME/ANSI OMa-1987, Operation and Maintenance Of Nuclear Power Plants, Part 10 (Paragraphs 4.2.1.2 and 4.3.2.2) recognizes this issue and allows deferred testing as set forth below.

D-1

~ ~

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-1 (cont.)

ALTERNATE TESTING:

For those valves designated to be exercised or tested during cold shutdown, exercising shall commence as soon as practical after the plant reaches a stable cold shutdown condition as defined by the applicable Technical Specification but no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdown. If an outage is sufficiently long enough to provide for testing of all valves required to be tested during the cold shutdown period, then the 48-hour requirement need not apply .if all valves are tested during the outage. Valve testing need not be performed more often than once every three (3) months except as provided for in IWV-3417(a). Completion of all valve testing during a cold .

shutdown outage is not required testing of specific valves period is insufficient to or ifif complete plant conditions preclude the all length of the shutdown testing. Testing not completed prior to startup may be rescheduled for the next shutdown in a sequence such that the test schedule does not omit nor favor certain valves or groups of valves. It should be noted that there are two conditions of cold shutdown identified in the program tables (Appendices D and E), namely pressurized and vented. For the purpose of this requirement, the term 'cold shutdown'efers to the respective condition as noted in the tables. The program tables identify those valves to which cold shutdown testing applies. Refer to Appendix G for discussion of the reasons and justification for allowing cold shutdown vs. quarterly testing.

D-2

C" f,

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-2 SYSTEM:

Safety Injection/Residual Heat Removal (8770-G-078, Sh 131)

COMPONENTS:

V-3 113 V-3134 V-3225 V-3247 V-3 114 V-3143 V-3227 V-3280 V-3 123 V-3144 V-3235 V-3281 V-3 124 V-3215 V-3237 V-3251 V-3 133 V-3217 V-3245 V-3252 CATEGORY:

A/C (Check Valves)

A (Motor-operated valves)

FUNCTION:

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

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Leaktesting of these valves is primarily for the purpose of confirming their capability of preventing'overpressurization and catastrophic failure of the safety injection piping and components. In this regard, special leakage acceptance criteria is established and included in the St. Lucie I Technical Specifications (Table 3.4.6-1) that addresses the question of valve integrity in a more appropriate manner for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing.

1 D-3

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-2 (cont.)

ALTERNATE TESTING:

The leakage rate acceptance criteria for these valves will be established per the St. Lucie Unit 1 Technical Specifications, Table 3.4.6-1.

Leakage rates less than or equal to 1.0 gpm are considered acceptable.

Leakage rates greater than 1.0 gpm but less than 2 ~

or equal to 5.0 gpm are considered acceptable if the latest measured rate,has not exceed the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 504'r greater.

Leakage rates greater than 1.0 gpm, but less than 3 ~

or equal to 5.0 gpm, are unacceptable latest measured rate exceeded the rate, if the determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 504 or greater.

4 ~ Leakage rates greater than 5.0 gpm are unacceptable.

D-4

ip'~so ft a

~1 1

2 VR-3'EVISION 12/12/89 RELIEF REQUEST NO.

SYSTEM:

Various COMPONENTS:

Various CATEGORY:

Various FUNCTION:

This is a generic Request for Relief SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

The stroke time measurements taken during testing of fast-acting valves (those less than 2 seconds) are subject to considerable variation due to conditions unrelated to the material condition of the valve (eg. test conditions, operator reaction time). In accordance with Reference 2.7, Position 6, an. alternate method of evaluating stroke times is considered acceptable.

ALTERNATE TESTING:

The stroke time evaluation for those valves designated in the valve tables (Appendices D 6 E) as "fast-acting" will not account for successive increases of measured stroke time per IWV-3417(a) with the change in test frequency as required. In lieu of this, the assigned maximum limiting value of stroke time will be established at 2 seconds. Upon exceeding the 2-second limit, a valve will be declared inoperable and corrective action taken in accordance with IWV-3417(b). This agrees with Reference 2.7, Position 6, and, as such, is considered to be approved upon submittal.

D-5

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-4 SYSTEM:

Various COMPONENTS:

This is a generic relief request CATEGORY A and B FUNCTION:

Various SECTION XI RE UIREMENT:

r Category A and B valves shall be exercised at least once every 3 months, except as provided by IWV-3412(a), IWV-3415, and IWV-3416. (IWV-3411)

BASIS FOR RELIEF:

There may arrive occasions when, due to the inoperablity of a redundant train of a safeguard system, it is imprudent to perform valve testing in the operable train. The potential of a valve failing in a position whereby both trains of the safety system would be unavailable to respond to an accident condition is unacceptable.

ALTERNATE TESTING:

When one or more components in a redundant system are determined to be inoperable, non-redundant valves in the operable train may not be tested, as required by this Program, but may be exercised after the inoperable train is returned to service.

D-6

ll Iles REVISION 2 12/12/89 RELIEF REQUEST NO. VR-5 SYSTEM:

Primary Containment COMPONENTS:

Containment Isolation Valves per Table VR-5-1 CATEGORY:

A or A/C FUNCTION:

These valves are closed to provide containment isolation.

SECTION XI RE UIREMENT:

Category A valves shall be seat leak tested and a maximum permissible leakage rate shall be specified Individual valve leakage rates shall be evaluated per IWV-3426 and IWV-3427. (IWV-3426, IWV-3427, NRC Generic Letter 89-04)

BASIS FOR RELIEF:

Due to the configuration of the system piping and components, in many cases individual leakage rate tests are impractical. In these cases it is customary to perform tests with the test volume between valves in series or behind valves in parallel paths.

ALTERNATE TESTING:

In those cases where individual valves testing is impractical, valves will be leaktested simultaneously in multiple valve arrangements and a maximum permissible leakage rate will be applied to each combination of valves.

Test results from tests of multiple valves will be evaluated in accordance with IWV-3426 and IWV-3427.

D-7

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-5 (Cont.)

TABLE VR-5-1 PENETRATION NO.. VALVES 8 V-18794 and V-18796 10 FCV-25-4 and FCV-25-5 11 FCV-25-2 and FCV-25-3 23 HCV-14-1 and HCV-14-7 24 HCV-14-2 and HCV-14-6 41 V-3463 and V-07009 42 LCV-07-11A and LCV-07-llB 46 V-07-206 and V-07-189 47 V-07-170 and V-07-188 52d V-00140 and V-00143 52e V-00139 and V-00144 56 V-25-11 and V-25-12 57 V-25-13 and V-25-14 58 V-25-15 and V-25-16 D-8

4

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REVISION 2 12/12/89 RELIEF REQUEST NO. VR-6 SYSTEM Chemical and Volume Control (8770-G-078 Sh 121)

COMPONENTS:

V-2177 V-2190 V-2191 CATEGORY!

FUNCTION:

V-2177 opens to provide a flowpath for emergency boration from the boric acid makeup pumps to the suction of the charging pumps. Likewise, V-2190 opens to provide a flowpath for emergency boration via gravity drain from the boric acid makeup tanks to the suction of the charging pumps. V-2190 closes to prevent recirculation to the boric acid makeup tanks when the boric acid makeup pumps are in operation.

Valve V-2191 opens to provide a flowpath from the refueling water tank (RWT) to the suction of the charging pumps as an alternate supply of borated water for boration and it closes to prevent backflow to the RWT during emergency boration via the BMT's.

SECTION XI REQUIREMENT:

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

BASIS FOR RELIEF Testing these valves in the open direction requires the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which would adversely affect plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. During cold shutdown, the introduction of excess D-9

0 RELIEF REQUEST NO. VR-6 (cont.)

REVISION 2 12/12/89 quantities of boric acid is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup.

Testing V-2190 and V-2191 in the closed direction should be done following the open exercise and is best performed in conjunction with testing of the boric acid makeup pumps during each reactor refueling outage.

ALTERNATE TESTING:

These valves will be exercised as required during each reactor refueling outage.

This request for relief is equivalent to Relief Requests CVCS 1 and 2 previously submitted on September 4, 1987 (Ref FPL Letter L-87-370) and, per Reference 2.7, is approved.

rgb'Qt,.

~ 8

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-7 SYSTEM Safety Injection (8770-G-078 Sh 130)

COMPONENTS:

V-07000 V-07001 CATEGORY:

FUNCTION:

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

SECTION XI RE UIREMENT:

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

BASIS OR RELIEF:

Full stroke exercising these valves to the open position requires injection via the LPCI pumps into the RCS. During plant operation this is precluded because the LPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. At cold shutdown, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function. Thus, essentially, the only practical time for testing these valves is during refueling outages when water from the RWT is used to fill the cavity.

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-7 (cont.)

ALTERNATE TESTING:

These valves will be. partial-flow exercised during quarterly testing of the LPSI pumps via the minimum flow circuit and full-flow exercised during each reactor refueling outage.

This alternate testing satisfies the requirement of Reference 2.7, Position 1. Furthermore, this request for relief is equivalent to Relief Request SIS 3 previously submitted on September 4, 1987 (Ref FPL Letter L-87-370).

Thus, per Reference 2.7, this request for relief is approved.

D-12

0

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REVISION 2 12/12/89 RELIEF REQUEST NO. VR-8 SYSTEM:

Safety Injection (8770-G-078 Sh 130)

COMPONENTS:

V-3401 V-3410 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the RWT and the containment sump to the suction of the associated high-pressure safety injection pump (HPSI).

SECTION XI RE UIREMENT:

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

BASIS OR RELIEF:

Full stroke exercising these valves to the open position requires injection via the HPSI pumps into the RCS. During plant operation this is precluded because the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. During cold shutdown conditions, operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications, Section 3.4.9.

D-13

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-8 (cont.)

ALTERNATE TESTING:

These valves will be partial-flow exercised during quarterly testing of the HPSI pumps via the minimum flow circuit and full-flow exercised during each reactor refueling outage.

This alternate testing satisfies the requirement of Reference 2.7, Position 1. Furthermore, this request for relief is equivalent to Relief Request SIS 2 previously submitted on September 4, 1987 (Ref FPL Letter L-87-370).

Thus, per Reference 2.7, this request for relief is approved.

D-14

~ 9 I

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I P

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-11 SYSTEM Safety Injection (8770-G-078 Sh 131)

COMPONENTS:

V-3114 V-3124 V-3134 V-3144 CATEGORY:

A/C FUNCTION:

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

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

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating a low pressure safety injection (LPSI) pump at nominal accident flowrate and injecting into the reactor coolant system, since no full flow reci'rculation path exists.

At power operation this is not possible because the LPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure.

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. Performing leaktests of these valves involves a considerable effort such that testing during operation or at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-11 (Cont.)

ALTERNATE TESTING:

These valves will be full-stroke exercised to the open position during cold shutdown periods per Relief Request VR-1.

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

D-20

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-12 SYSTEM:

Safety Injection (8770-6-078 Sh 131)

COMPONENTS:

V-3215 V-3225 V-3235 V-3245 CATEGORY:

A/C FUNCTION'hese valves open to provide flowpaths from the safety injection tanks to the RCS and close to isolate the tanks from the high pressure of the reactor coolant system and the safety injection headers.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

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

During cold shutdown or refueling the required test conditions cannot be established and the simulated LOCA test performed without creating an unacceptable transient in the reactor coolant system.

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. Performing leaktests of these valves requires access to the containment building and involves a considerable

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-12 (Cont.)

effort such that testing during operation or at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the remaining three valves will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2.

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

This alternate testing satisfies the requirement of Reference 2.7, Position 1. Furthermore, this request for relief is equivalent to Relief Request SIS 5 previously submitted on September 4, 1987 (Ref FPL Letter L-87-370).

Thus, per Reference 2.7, this request for relief is approved.

D-22

I 4

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-13 SYSTEM:

Safety Injection (87T0-G-078 Sh 131)

COMPONENTS:

V-3217 V-3227 V-3237 V-3247 CATEGORY:

A/C FUNCTION:

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

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

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

During cold shutdown or refueling the required test conditions cannot be established and the simulated LOCA test performed without creating an unacceptable transient in the reactor coolant system.

These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. Performing leaktests of these valves requires access to the containment building and involves a considerable D-23

r,w ly

~

~

REVISION 2 12/ 12/8 9 RELIEF REQUEST NO . VR- 13 ( Cont . )

effort such that testing during operation or at each cold shutdown outage would constitute an unreasonable burden on the plant staff .

ALTERNATE TESTING:

During cold shutdown periods, each of these valves will be partial-stroke exercised with approximately 3,000 gpm (20 percent of maximum accident flow) using the LPSI pumps per Relief Request VR-1.

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the remaining three valves will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, this part of the proposed alternate testing is considered to be approved upon submittal.

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

D-24

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-14 SYSTEM:

Main Steam (8770-G-07'9, Sh 1)

COMPONENTS:

V-08117 V-08148 CATEGORY:

FUNCTION:

These valves closed to prevent unrestricted release of steam from an unaffected steam generator in the event of a steamline rupture upstream of an MSIV.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

There is no practical means or provision for verifying closure of these valves.

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the remaining other valve will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal.

D-25

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-15 SYSTEM:

Makeup Water (8770-G-'084, Sh 1)

COMPONENT:

V-15328 CATEGORY:

A/C FUNCTION:

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

containment building.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

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

ALTERNATE TESTING:

At least once every two (2) years, this valve will be H

verified to close in conjunction with the Appendix J leak testing program.

D-26

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-16 SYSTEM:

Instrument Air (8770-.G-085, Sh 2)

COMPONENT:

V-18195 CATEGORY:

A/C FUNCTION:

l

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

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

This is a simple check valve with'no external means of position indication, thus the only practical means of verifying closure is by performing a leaktest or backflow test. This would require a considerable effort, including entry into the containment building and securing all instrument air to the containment. Due to access limitations and the undesirability of isolating'the air supply for critical equipment, this is impractical during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown.

ALTERNATE. STING:

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

D-27

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-17 SYSTEM:

Containment Spray (8770-G-088)

COMPONENTS:

V-07119 V-07120 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the refueling ~

water tank (RWT) to the containment spray and safety injection suction headers.

XI RE UIREMENT:

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

BASIS OR RELIEF:

Full stroke exercising of these valves would require simultaneous operation of two HPSI pumps, one LPSI pump, and one containment spray pump to verify that each valve could pass the maximum design accident flow. Such a test is not practical during all plant operational modes.

ALTERNATE TESTING:

During quarterly pump testing each of these valves will be partial-stroke exercised via recirculation through the minimum flow test circuits of the various systems.

D-28

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-17 (cont.)

ALTERNATE TESTING cont.

During each reactor z'efueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal.

D-29

F I.+ 'I e 'I.

Ig I ~

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-18 SYSTEMS Containment Spray (8770-G-088)

COMPONENTS:

V-07129 V-07143 CATEGORY:

FUNCTION:

to provide flowpaths from the respective Ml These valves open containment spray pump to the containment spray headers.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating each containment spray pump at nominal accident flowrate. Since exercising these valves through the normal containment spray flowpath would result in spraying down the containment, the only practical flowpath available for such a test requires pumping water from the RWT to the RCS via the shutdown cooling loops. At cold shutdown, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function.

ALTERNATE TESTING:

Each of these valves will be partial-stroke exercised quarterly in conjunction with testing of the containment spray pumps via the minimum flow test. line.

During each refueling outage, each valve will be exercised at least once to demonstrate full stroke capability.

D-30

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-19 SYSTEM:

Containment Spray (8770-G-088)

COMPONENTS:

V-07172 V-07174 CATEGORY:

FUNCTION:

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

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

There are no provisions for exercising these valves.

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal.

D-31

e RELIEF REQUEST NO. VR-20 REVISION 2 12/12/89 SYSTEM:

Containment Spray (8770-G-088)

COMPONENTS:

V-07192 V-07193 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the respective.,

containment spray headers to the containment spray rings.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Full stroke exercising of these valves would require operating each containment spray pump at nominal accident flowrate. Since exercising these valves through the normal containment spray flowpath would result in spraying down the containment this is considered impractical.

Disassembly of either of these valves requires erection of a large scaffold to provide an appropriate work platform.

This results in a considerable expenditure of outage resources. Since these valves are in close proximately to each other it is desirable to combine the inspection of both valves during the same maintenance period. Performing an inspection of both valves on a bi-outage basis will satisfy the requirement of Generic Letter 89-04 Position 1 to ensure valves are inspected at least every six (6) years.

D-32

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-20 (cont.)

ALTERNATE TESTING:

During alternating reactor refueling outages both of these valves will be disassembled, inspected, and manually stroked to verify operability. This agrees with Reference 2.7, Position 2, and, as such, is considered to be approved upon submittal.

D-33

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-21 SYSTEM:

Containment Spray (8770-G-088)

COMPONENTS:

V-07256 V-07258 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the spray additive tank to the respective containment spray pump suction header. They close to prevent reverse flow and recirculation through the eductor leading to an idle containment spray pump.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

Testing these valves during normal plant operation during testing of the containment spray pumps would contaminate the containment spray piping with sodium hydroxide. The only practical means of testing these valves requires connection of a source of demineralized water at the tank discharge then directing water into the containment spray piping.

This place both containment spray train out of service and would entail a somewhat complex procedure that is considered outside the scope of work that is typically performed during a routine cold shutdown period, thus, such a test is impractical during periods other than reactor refueling outages.

D-34

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-21 (cont.)

ALTERNATE TESTING:

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

This request for relief is equivalent to Relief Request CS 1 previously submitted on September 4, 1987 (Ref FPL Letter L-87-370). Thus, per Reference 2.7, this request for relief is approved.

D-35

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-22 SYSTEM:

Containment Spray (8770-G-088)

COMPONENTS:

V-07269 V-07270 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the discharge of the respective containment spray pumps to the spray additive eductors to provide the motive force for sustaining spray additive flow and to provide minimum flow for the containment spray pumps to prevent pump damage under low-flow conditions.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

These valves are normally full stroke tested during testing of the containment spray pumps but there is no flow measuring instrumentation in the line that could provide a quantitative flow measurement as required by NRC Generic Letter 89-04,- Position 1. Thus the test is considered a partial flow (stroke) test.

D-36

REVIS ION 2 12/12/89 RELIEF REQUEST NO. VR-22 (cont.)

ALTERNATE TESTING:

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2 and, as such, is considered to be approved upon submittal.

D-37

4 II

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-23 SYSTEM:

Various COMPONENTS:

Various CATEGORY:

Various FUNCTION:

This is a generic Request for Relief SECTION XI RE UIREMENT:

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

BASIS O'OR RELIEF:

The stroke time measurements taken during testing of fast-acting valves (those less than 2 seconds) are subject to considerable variation due to conditions unrelated to the material condition of the valve (eg. test conditions, operator reaction time). In accordance with NRC Generic Letter 89-04, Position 6, an alternate method of evaluating stroke times is considered acceptable.

ALTERNATE TESTING:

The stroke time evaluation for those valves designated in the valve tables (Appendices D & E) as "fast-acting" will not account for successive increases of measured stroke time per IWV-3417(a) with the change in test frequency as required. In lieu of this, the assigned maximum limiting value of stroke time will be established at 2 seconds. Upon exceeding the 2-second limit, a valve will be declared inoperable and corrective action taken in accordance with IWV-3417(b). This agrees with the guidelines of NRC Generic Letter 89-04, Position 6.

D-38

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-24 SYSTEM:

Hydrogen Sampling System (8770-G-092)

COMPONENTS:

V-29305 V-29306 CATEGORY:

FUNCTION:

These valves open to supply nitrogen zero gas for operation of the containment hydrogen analyzer and close to prevent the loss of gas from the accumulator in the event of depressurization of the upstream piping.

SECTION XI RE UIREMENT:

Valves that are normally open during plant operation and whose function is to close to prevent reversed flow shall be tested in a manner that proves the disk travels to the seat promptly upon cessation or reversal of flow. (IWV-3522(a))

BASIS FOR RELIEF:

These valves are in series for redundancy and act as one barrier for reverse flow with no mechanism to allow verification that both valves seat. Since they are in series, however, in order to perform the safety function only one valve need close.

ALTERNATE TESTING:

These valves will be tested simultaneously in the closed direction to verify that at least one valve closes.

D-39

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REVISION 2 12/12/89 RELIEF REQUEST NO. VR-'25 SYSTEM:

Ultimate Heat Sink (8770-G-093)

COMPONENTS:

SB-37-1 SB-37-2 CATEGORY:

B FUNCTION:

These valves are opened to provide a second source of cooling water from Big Mud Creek.

SECTION XI RE UIREMENT:

Category A and B valves shall be exercised at least once every 3 months, except as provided by IWV-3412(a), IWV-3415, and IWV-3416. (IWV-3411)

BASIS FOR RELIEF:

The operation of these valves is limited for environmental concerns to minimize the quantity of water drawn from the Indian River and discharged to the ocean. For this reason the UFSAR (Section 9.2.7) specifies exercising these valves at six (6) month intervals.

ALTERNATE TESTING:

These valves will be exercised at least once every six (6) months.

D-40

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-26 SYSTEM:

Emergency Diesel Generator (8770-G-096, Sh 1&2)

COMPONENTS:

SE-59-1 A&B CATEGORY:

FUNCTION:

These valves open to provide flowpaths for diesel fuel oil into the respective day tanks and close to prevent draining of the main storage tank and overflow of the day tanks.

SECTION XI RE UIREMENT:

The stroke time of all power operated valves shall be measured to ....., whenever such a valve is full-stroke tested. (IWV-3413(b))

BASIS FOR RELIEF:

These valves are totally enclosed solenoid valves with no means of determining valve position, thus, measuring a stroke time is impractical. It is noted that the stroke times of these valves is not critical from the aspect of accident mitigation.

ALTERNATE TESTING:

During quarterly pump testing each of these valves will be exercised and verified to operate satisfactorily. By local observation, proper operation will be confirmed by the absence of any unusual audible noise or vibration. Valve stroke times will not be measured.

D-41

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REVISION 2 12/12/89 RELIEF REQUEST NO. VR-27 SYSTEM:

Emergency Diesel Generator Air Start System (8770-G-096, Sh 1&2)

COMPONENTS:

FCV-59-1A1 thru FCV-59-4A1 FCV-59-1B1 thru FCV-59-4B1 SE-59-3A thru SE-59-6A SE-59-3B thru SE-59-6B CATEGORY:

FUNCTION:

These valves open to supply. starting air to the emergency diesel generators.

SECTION XI RE UIREMENT:

The stroke time of all power operated valves shall be measured to the nearest second, ..., whenever such a valve is full-stroke tested. (IWV-3413(b))

BASIS FOR RELIEF:

1 These valves are integral with the diesel air start system for each emergency diesel generator with no valve position indication mechanism and, as such; there is no practical method for measuring the stroke times of each individual valve. If a valve were to fail to stroke as required it would be reflected in an unacceptable starting time for the respective diesel generator.

ALTERNATE TESTING:

These valves will be exercised in conjunction with testing of the emergency diesel generators. The stroke times of the individual'valves will not be measured but the starting time for each diesel generator will be verified to be acceptable.

D-42

REVISION' 12/12/89 RELIEF REQUEST NO. VR-28 SYSTEM Chemical and Volume Control System (8770-G-078, Sh 121)

COMPONENT:

V-2443 V-2444 CATEGORY:

FUNCTION:

These valves open to provide a flowpath from the boric acid makeup pumps to the emergency boration header.

SECTION XI RE UIRE ENT:

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

BASIS FOR RELIEF:

Full-stroke testing these valves requires operating the boric acid makeup pumps at or near rated flow and verifying full accident flow through each valve.

Operating the BAM Pumps discharging into the charging pump suction header requires the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which would adversely affect plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. During cold shutdown, the introduction of excess quantities of boric acid is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent sta'rtup.in over-boration of the RCS. In addition to the above, there is no flowrate measurement instrumentation installed in this flowpath.

A second circuit that recirculates water to the RWT has flowrate measuring instrumentation installed however it is 0 limited to 30 gpm (BAM Pump design capacity D-43 is 142 gpm).

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-28 (cont.)

ALTERNATE TESTING:

Each of these valves will be partial stroke exercised quarterly.

During testing of the boric acid makeup pumps performed during each reactor refueling (See Relief Request PR-5),

system flowrate will be measured to verify full stroke of these valves.

D-44

tW e RELIEF REQUEST NO. VR-29 REVISION 2 12/12/89 SYSTEM Safety Injection System (8770-G-078, Sh 130)

COMPONENTS:

V-3101 V-3102 V-3103 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the high-pressure safety injection pumps to the refueling water tank to provide for minimum flow- through the respective pumps in the event they are operating under low or no flow conditions. They close during shutdown cooling and long-term recirculation to prevent recirculation through the idle pump(s) .

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

There is no flowrate instrumentation available to verify valve full-stroke exercising as required by Reference

1. 2.7,'osition Testing these valves to the closed position requires closing one of the mimimum flow isolation valves (V-3659 or V-3660) which isolates all minimum flow from the SI pumps and renders them inoperable.

ALTERNATE TESTING:

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

D-45

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-29 (cont.)

ALTERNATE TESTING:

During cold shutdown,. each valve will be verified to close subject to the conditions of Relief Request VR-1.

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the other valves will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2.

D-46

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REVISION 2 12/12/89 RELIEF REQUEST NO. VR-30 SYSTEM:

Safety Injection System (8770-G-078, Sh 130)

COMPONENTS:

V-3104 V-3105 CATEGORY:

FUNCTION:

These valves open to provide flowpaths from the low-pressure safety injection pumps to the refueling water tank to provide for minimum flow through the respective pumps in the event they are operating under low or no flow conditions.

They close during shutdown cooling and long-term recirculation to p revent recirculation through the idle pump(s) .

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

There is no flowrate instrumentation available to verify valve full-stroke exercising as required by Reference 2.7, Position 1.

Testing these valves to the closed position requires closing one of the mimimum flow isolation valves (V-3659 or V-3660) which isolates all minimum flow from the SI pumps and renders them inoperable.

D-47

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-30 (cont.)

ALTERNATE TESTING:

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

During cold shutdown, each valve will be verified to close subject to the conditions of Relief Request VR-1.

During each reactor refueling outage at least one of these valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six

'6) years. Should a valve under inspection be found to be inoperable, then the other valve will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2.

D-48

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-31 SYSTEM Feedwater System (8770-6-080, Sh 3)

COMPONENTS:

V-9303 V-9304 V-9305 V-12507 CATEGORY:

C FUNCTION:

Valves V-9303 through V-9305 open to provide flowpaths from the auxiliary feedwater pump discharge to the condensate storage tank to ensure adequate pump cooling during low flow conditions. V-12507 opens to provide a discharge flowpath for bearing cooling water from the steam-driven auxiliary feedwater pump.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

There is no flowrate instrumentation available to verify valve full-stroke exercising of these valves as required by Reference 2.7, Position l.

ALTERNATE TESTING:

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

D-49

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-31 (cont.)

ALTERNATE TESTING:

During each reactor refueling outage at least one of the three minimum flow recirculation valves will be disassembled, inspected, and manually stroked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under inspection be found to be inoperable, then the other two valves will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated. This satisfies the requirements of Generic Letter 89-04, Position 2.

During each reactor refueling outage V-12507 will be disassembled, inspected, and manually stroked to verify operability.

D-50

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-32 SYSTEM:

Miscellaneous Sampling (8770-G-092)

COMPONENT:

V-27101 V-27102 CATEGORY:

A/C FUNCTION:

These valves close to provide primary containment.

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

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

ALTERNATE TESTING:

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

D-51

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-33 SYSTEM Safety Injection (8770-G-078, Sh 131)

COMPONENT HCV-3618, HCV-3628 HCV 3628'CV 3638 CATEGORY:

FUNCTION:

These valves close to isolate the SI check valve test line in the event of SI initiation.

SECTION XI RE UIREMENT:

The stroke time of all power operated valves shall be measured to ....., whenever such a valve is full-stroke tested. (IWV-3413(b))

BASIS FOR RELIEF:

These valves are provided with a controller that positions the valve in response to a variable indicator-controller-device. In order to stroke these valves and perform fail safe tests, fuses in the control circuits are removed which, in turn, causes the loss of valve position indication. Thus measurements of valve closure times are not practical.

ALTERNATE TESTING:

During valve exercising and fail safe testing performed under cold shutdown conditions, an individual will be stationed at the valve to verify proper operation. Valve stroke times will not be measured.

D-52

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REVISION 2 12/12/89 RELIEF REQUEST NO. VR-34 SYSTEM Primary Containment COMPONENTS:

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

CATEGORY A/C (Check Valves)

A (Motor-operated valves)

FUNCTION:

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

SECTION XI RE UIREMENT:

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

BASIS FOR RELIEF:

The usefulness of applying this requirement does not justify the burden of compliance. This position is supported by NRC Generic Letter, Position 10 ALTERNATE TESTING:

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

D-53

REVISION 2 12/12/89 RELIEF REQUEST NO. VR-35 SYSTEM:

Intake Cooling Water (8770-G-082, Sh 1)

COMPONENT:

TCV-14-4 A&B CATEGORY:

FUNCTION:

These valves open to provide flowpaths for intake cooling water from the component cooling heat exchangers.

S'ECTION XI RE UIREMENT:

The stroke time of all power operated valves shall be measured to ....., whenever such a valve is full-stroke tested. (IWV-3413(b))

BASIS FOR RELIEF:

These valves are provided with a controller that positions the valve in response to ~: variable indicator-controller device. In order to stroke these valves and perform fail safe tests, fuses in the control circuits are removed which, in turn, causes the loss of valve position indication. Thus measurements of valve closure times are not practical.

ALTERNATE TESTING:

During quartrerly valve exercising and fail safe testing an individual will be stationed at the valve to verify proper operation. Valve stroke times will not be measured.

D-54

Appendix E Valve Program Cold Shutdown Justifications

REVISION 2 12/12/89 Appendix E: COLD SHUTDOWN JUSTIFICATIONS This appendix is intended to provide the justification for performing valve exercising only at cold shutdown conditions as permitted by IWV-3412(a), '3415 and 5322. Specifically included in this category are the following:

• A valve whose failure in a position other than its normal position could jeopardize the immediate safety of the plant or system components;

• A valve whose failure in a position other than its normal position could cause all trains of a safeguard system to be inoperable;

• A valve whose failure in a position other than its normal, position that might cause a transient that could lead to a plant trip; or

• When test requirements or conditions are precluded by system operation or access.

Cold shutdown testing is performed under conditions outlined in Relief Request VR-1.

Reactor Coolant 8770-G-078 Sh 110 V-1402 and V-1404 Power-Operated Relief Valves Due to the potential impact of the resulting transient should one of these valves open prematurely or stick in the open position, it. is considered imprudent to cycle them during plant operation with the reactor coolant. system pressurized.

V-1441 thru V-1446 and V-1449 Reactor Coolant System Vents These valves are administratively controlled in the key-locked closed position with the power supply disconnected to prevent inadvertent operation. Since these 'are Class 1 isolation valves for the reactor coolant system, failure of a valve to close or significant leakage following clo'sure could result in a loss of coolant in excess of the limits imposed by Technical Specification 3.1.3 leading to a plant shutdown.

E-1

REVISION 2 12/12/89 Furthermore, fail to show if a valve were to fail open or valve indication the valve returned to the fully closed position following exercising, prudent. plant operation would probably likely result in a plant shutdown.

Chemical & Volume Control 8770-G-078 Sh. 120 MV-02-02 Charging Line Isolation Valve Closing this valve during operation isolates the charging pumps from the RCS and would result in undesirable pressurizer level transients with the potential for a plant trip and potential damage to the charging pumps. If the valve failed to reopen, then a expedited plant shutdown would be required.,

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

V-2431 Auxiliary Pressurizer Spray Check Valve In order to test this valve, either SE-02-03 or SE-02-04 must be opened. Opening either of these valves (or failure in the open position) during plant operation would cause an RCS pressure transient that could potentially adversely affect plant safety and lead to a plant trip. In addition, the pressurizer spray piping would be subjected to undesirable thermal shock.

V-2515 and V-2516 Letdown Line Isolation Valves Closing either of these valves during operation isolates the letdown line from the RCS and would result in undesirable pressurizer level transients with the potential for a plant trip. If a valve failed to reopen, then a expedited plant shutdown would be required.

E-2

4v' REVISION 2 12/12/89 V-2505 and SE-01-01 RCP Control Bleedoff Isolation Valves Exercising either of .these valves to the closed position when any of the reactor coolant pumps (RCP's) are in operation would interrupt flow from the RCP seals and result in damage to the pump(s).

V-2501 Volume Control Tank Outlet Valve Closing this valve during operation of a charging pump would isolate the VCT from the charging pump suction header damaging any operating charging pumps and interrupting the flow of charging water, flow to the RCS with the potential of RCS.

transients and plant trip.

V-2504 RWT Discharge Valve Opening this valve during operation would result in injection of RWT borated water into the reactor coolant system. This would, in turn, result in overboration with- an adverse reaction in reactor power and the potential for a power transient.

Safet In'ection Residual Heat Removal 8770-G-078 Sh 130 V-3106 and V-3107 LPSI Pump Discharge Check Valves During normal plant operation, the LPSI Pumps cannot develop sufficient discharge pressure to pump through these valves to the RCS and exercise them in the open direction. The only other test flowpath available is through the shutdown cooling line recirculating to the "RWT. This would require opening valves HCV-3657, V-3460 and V-3459. With these valves open, both trains of the LPSI subsystem would be inoperable, thus, this testing scheme is unacceptable.

E-3

REVISION 2 12/12/89 V-3614, V-3624, V-3634 and V-3644 SI Tank Discharge Isolation Valves During normal plant operation, these valves are administratively controlled to be locked open with their breakers racked out to ensure they remain in the open position with no chance of misalignment. Exercising these valves presents the chance of misalignment, thus is not considered to be prudent. Furthermore, during the period of time when a valve is not fully open, the associated SI Tank is not available for safety injection. There is also the possibility of creating a large differential pressure across the valve while it is closed that would preclude reopening or could damage the valve during operation.

V-3659 and V-3660 Minimum Flow/Recirculation Line Isolation Valves Failure of either of these valves in the closed position during testing will render. all unit safety injection pumps inoperable due to the high probability of damage should these pumps be started and operated without sufficient flow for cooling of pump internal components.

V-.3480, 3481, 3651, and 3652 Shutdown Cooling RCS Isolation Valves These valves are provided with electrical interlocks that prevent opening- whenever Reactor Coolant System pressure exceeds 268 psia. This precludes exercising these valves in any other plant condition than cold shutdown.

Safet In ection Residual Heat Removal 8770-G-078 Sh 131 HCV-3618, HCV-3628, HCV-3638, and HCV-3648 Check Valve Leakage Test Valves These valves are provided with a controller that positions the valve in response to a variable indicator-controller device.

In order to stroke these valves and perform fail safe tests, fuses in the control circuits are removed which, in turn, causes the loss of valve position indication. In accordance with Relief Request VR-33, during this exercising an individual will be stationed at the valve to verify proper

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REVISION 2 12/12/89 operation. Since this valve is located inside the containment building with limited access, this is not practical to perform during plant operation.

Main Steam 8770-G-079 Sh 1 HCV-08-1 A&B Main Steam Isolation Valves During plant operation at power, closure of either of these valves is not practical as it would require isolating a steam generator which would result in a severe transient on the steam and reactor systems and a possible plant trip.

MV-08-1A & 1B MSIV Bypass Valves These valves are remain closed except for periods during startup and warmup of the main steam piping. Furthermore, one were to fail in the open position during testing, prevent isolation of the related steam generator in the event.

it if would of an accident.

HCV-08-2A & 2B Main Steamline Atmospheric Dump Valves Opening these valves during plant operation at power will result in an undesirable power transient with the exceeding reactor core power limit or a plant trip.

potential'or V-08448 and V-08492 Steam-Driven AFW Pump Steam Supply Check Valves Verifying closure of these valves during plant operation at normal operating pressures would required isolating the associated steam generator from the steam supply lines and venting the piping between the closed isolation valve and the check valve. It is considered to be imprudent to isolate the steam supply during operation and; in addition, it is undesirable to subject plant personnel to the hazards associated with venting the steam line at these operating conditions. Full-stroke exercising of these valves to the open position would require operation of 1C Auxiliary E-'5

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REVISION 2 12/12/89 Feedwater pump and injection of cold water (85 deg-F) into the hot (450 deg-F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

Feedwater 8770-G-080 Sh 3 MV-09-07 and 08 Main Feedwater Isolation Valves During plant operation at power, closure of either of these valves is not practical as it would require isolating a steam generator which would result in a severe transient on the

, steam and reactor systems and a plant trip.

V-09248 and V-09280 Main Feedwater Supply Check Valves During plant operation at power, testing either of these valves to the closed position is not practical as it would require isolating a steam generator which would result in a severe transient on the steam and reactor systems and a plant trip.

V-12174 and V-12176 Auxiliary Feedwater Pump Suction Check Valves Full-stroke exercising of these valves would require operation of a related auxiliary feedwater pump and injection of cold water (85 deg-F) into the hot (450 deg-F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components. These valves will be partial stroke tested during quarterly testing via the minimum flow recirculation lines.

V-9107, 9123, and 9139 Auxiliary Feedwater Pump Discharge Check, Valves Full-stroke exercising of these valves would require operation of the related auxiliary feedwater pump and injection of cold water (85 deg-F) into the hot (450 deg-F) feedwater supply piping. This, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

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REVISION 2 12/12/89 V-9119, 9135, 9151, and 9157 Auxiliary Feedwater Supply Check Valves Full-stroke exercising of these valves would require operation of a related auxiliary feedwater pump and injection of cold water (85 deg-F) into the hot (450 deg-F) feedwater supply piping. 'his, in turn, would result in unacceptable thermal stress on the feedwater system piping components.

Intake Coolin Water 8770-G-082 Sh 1 MV-21-2 & 3 Turbine Plant Cooling Water Heat Exchanger Supply Valves I

If during testing to the closed position under normal.

operating conditions either of these valves were to fail closed for any extended period of time, the associated turbine generator and various support components could be damaged due to overheating.

TCV-14-4 A&B CCW Temperature Control Valves Failure of either of these valves in the closed position during plant operation would adversely affect the capability of the various safety systems to react to an accident and thus jeopardize plant safety.

Com onent Coolin Water 8770-G-083 HCV 14 1~2~6 & 7 RCP Cooling Water Supply/Return Isolation Valves These valves are required to be open to ensure continued cooling of reactor coolant pump auxiliary components and the control rod drives. Closing any of these valves during plant operation would result in severe RCP and CRD damage leading to plant operation in a potentially unsafe mode and a subsequent plant shutdown.

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0 HCV-14-3 AGB REVISION 12/12/89 2

Shutdown Heat Exchanger Return Valves Testing either of these valves during plant operation would result in an unbalanced flow condition in the affected CCW train and decreased flow to essential equipment. This could result in component damage or an undesirable plant transient.

MV-14-5 thru MV-14-8 Containment Cooler Supply Valves Failure of any one of these valves in the closed position renders two containment coolers inoperable resulting in placing the plant in a 45 minute LCO which allows little time for correcting the apparent problem before commencing the'hutdown.

Instrument Air 8770-G-085 Sh 2 MV-18-1 Primary Containment Instrument Air Supply Closing this valve isolates operating air to critical components in the containment building including the pressurizer spray valves and CVCS letdown isolation valves and could cause severe plant transients and a plant trip.

Failure in the closed position would cause a plant shutdown.

V-18279 and V-18283 Containment Hatch Seal Air Supply Check Valves Verifying closure of these valves would require isolation of the instrument air supply to the containment which would, in turn, isolate operating air to critical components in the containment building including the pressurizer spray valves and CVCS letdown isolation valves and could cause severe plant transients and a plant trip. Failure in the closed position would cause a plant shutdown.

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REVISION 2 12/12/89 Containment S ra and Refuelin Water S stems 8770-G-088 MV-07-2 A&B Primary Containment Sump Suction Valves These are single containment isolation valves such that during the period that they are open as a result of exercising, there are no other designated valves isolating the containment atmosphere from the auxiliary building. Zf either of these valves were to fail open, then the primary containment would be compromised.

Heatin Air Conditionin And Ventilation & Air Conditionin 8770-G-878 FCV-25-1 thru FCV-25-6 Primary Containment Purge and Vent Valves These valves are administratively maintained in the closed position at all times when'he plant is operating in Modes 1,2 or 3 thus they are not required to operate (close) during operational periods. Due to the large size of these valves and the potential for damage as a result of frequent cycling, it is not prudent to operate them more than is absolutely necessary.

V-25-20 and V-25-21 Containment Vacuum Breakers These valves can only be exercised manually requiring direct access to each valve. Since these valves are located within the containment building, access is limited and not routinely practical.

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ATTACHMENT 3 PUMP RELIEF REQUEST

SUMMARY

Previous Date No ~Pum m Code Ref. Relief No. Status*

PR-1 Generic IWP-3300 No Unreviewed 5/16/90 IWP-4310 PR-2 Generic IWP-4120 No Unreviewed 5/16/90 PR-3 Generic IWP-3000 No Unreviewed 5/16/90 PR-4 AFW 1A-1C IWP-3300 YES / 2 Preapproved Position 9 PR-5 BAM 1A & 1B IWP-3300 IWP-3100 YES / 1 Preapproved Position 9 PR-6 CS 1A & 1B IWP-3300 No Preapproved Position 9 IWP-3100 PR-7 DFO 1A & 1B IWP-3500(a) No Unreviewed 5/16/90 IWP-4600 PR-8 DFO 1A & 1B IWP-3300 No Unreviewed 5/16/90 BAM 1A & 1B PR-9 HPSI 1A-1C IWP-3300 YES / 4 Preapproved Position 9 PR-10 LPSI 1A & 1B IWP-3300 YES / 3 Preapproved Position 9 PR-11 ICW 1A-1C IWP-3300 No Unreviewed 5/16/90 IWP-3100

• See Key on Page 6

VALVE RELIEF QUEST

SUMMARY

Previous Date No. Relief No.

Generic IWV-3412 No Unreviewed 5/16/90 IWV-3522 IWV-4315 Pressure Iso. IWV-3521 No Unreviewed 5/16/90 Valves Generic IWV-3417 (a) No Preapproved Position 6 Generic IWV-3411 No Unreviewed 5/16/90 Cont. Isol. IWV-3426 No Unreviewed 5/16/90 IWV-2427 CVCS V-2177 IWV-3522 YES / 1&2 Approved V.-2190 V-2 19 1 Safety V-07000 Inj. IWV-3521 YES / 3 Approved V-07001 Safety V-3401 Inj. IWV-3521 YES / 2 Approved V-3410 Safety V-3405 Inj. IWV-3521 YES / 2 Approved V-3414 V-3427

VALVE RELIEF REQ ST

SUMMARY

(cont.)

Previous Date VR-10 Safety Inj.

V-3 113 IWV-3521 YES / 4 Approved V-3123 V-3133 V-3143 VR-11 Safety V-3114 Inj. IWV-3521 YES / 6 Unreviewed 5/16/90 V-3124 V-3134 V-3144 VR-12 Safety V-3215 Inj. IWV-3521 YES / 5 Preapproved Position 2 V-3225 V-3235 V-3245 VR-13 Safety Inj. IWV-3521 No Unreviewed 5/16/90 V-3217 V-3227 V-3237 V-3247 VR-14 Main Steam.

V-08117 IWV-3521 YES / 1 Preapproved Position 2 V-08148 VR-15 Makeup Wtr. IWV-3521 No Unreviewed 5/16/90 V-15328 VR-16 Inst. Air IWV-352 1 No Unreviewed 5/16/90 V-18195

VALVE RELIEF REQ ST

SUMMARY

(cont.)

Previous Date No. Status VR-17 Cont. Spray V-07119 IWV-3521 YES / 6 Preapproved Position 2 V-07120 VR-18 Revised Cont. Spray IWV-3521 YES / 3 Unreviewed 5/16/90 V-07129 V-07143 VR-19 Position 2 Cont. Spray IWV-3521 YES / 5 Preapproved 5/16/90 V-07172 V-07174 VR-20 Revised Cont. Spray IWV-3521 YES / 4 Unreviewed 5/16/90 V-07192 V-07193 VR-21 Cont. Spray V-07256 IWV-3521 YES / 1 Approved V-07258 VR-22 Cont. Spray V-07269 IWV-3521 YES / 2 Preapproved Position 2 V-07270 VR-23 Generic IWV-3417 (a) No Unreviewed 5/16/90 VR-24 H2 Sampling IWV-3522(a) No Unreviewed 5/16/90 V-29305 V-29306

VALVE RELIEF REQ ST

SUMMARY

(cont.)

Previous Date No.

VR-25 Ultim. Ht Snk IWV-3522(a) No Unreviewed 5/16/90 SB-37-1 SB-37-2 VR-2 6 Emer. D.Gen IWV-3513(b) No Unreviewed 5/16/90 SE-59-1A SE-59-1B VR-27 Emer. D.Gen IWV-3513 (b) No Unreviewed 5/16/90 FCV-59-1A1 thru FCV-59-4A1 FCV-59-1B1 thru~

FCV-59-4B1 SE-59-3A thru SE-59-6A SE-59-3B thru SE-59-6B VR-28 CVCS IWV-3521 No Unreviewed 5/16/90 V-2443 V-2444 VR-29 Safety Inj. IWV-3521 No Unreviewed 5/16/90 V-3101 V-3102 V-3103

VALVE RELIEF REQ ST

SUMMARY

(cont.)

Previous Date No.

VR-25 Ultim. Ht Snk IWV-3522(a) No Unreviewed 5/16/90 SB-37-1 SB-37-2 VR-26 Emer. D.Gen IWV-3513(b) No Unreviewed 5/16/90 SE-59-1A SE-59-1B VR-27 Emer. D.Gen IWV-3513 (b) No Unreviewed 5/16/90 FCV-59-1A1 thru FCV-59-4A1 FCV-59-1B1 thru FCV-59-4B1 SE-59-3A thru SE-59-6A SE-59-3B thru SE-59-6B VR-28 CVCS IWV-352 1 No Unreviewed 5/16/90 V-2443 V-2444 VR-29 Safety Inj. IWV-3521 No Unreviewed 5/16/90 V-3 101 V-3102 V-3103

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