BSEP-97-0408, Informs NRC of Status of BSEP GL 89-10, SR MOV Testing & Surveillance, Program.List of Commitments Provided

Informs NRC of Status of BSEP GL 89-10, SR MOV Testing & Surveillance, Program.List of Commitments Provided

ML20217F921
Person / Time
Site:	Brunswick
Issue date:	10/02/1997
From:	Jury K CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-97-0408, BSEP-97-408, GL-89-10, NUDOCS 9710090099
Download: ML20217F921 (23)

Text

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SERIAL: BSEP 97-0408-OCT 02 #97.

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,DC 20555

- BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 GENERIC LETTER 89-10 MOTOR OPERATED VALVE PROGRAM STATUS Gentlemen:

In letters dated June 21,1995,(BSEP 95 0247) and April 12,1996, (BSEP 96-0138) the NRC

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. was informed that the Brunswick Steam Electric Plant (BSEP) had completed implementing a Motor-Operated Valve (MOV) program in accordance with NRC Generic Letter (GL) 89-10,

" Safety-Related Motor Operated Valve Testing And Surveillance," based on completion of the necessary testing and preparation of MOV setup calculations needed to demonstrate MOV

- capability under design bases conditions. These calculations were prepared using the best

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- available information at the time and, as such, Carolina Power & Light (CP&L) Company considered the BSEP GL 89-10 closure notification letter to be accurate at the time ofissuance.

Since the issuance of the BSEP GL 89-10 closure notification letter, additional information that could potentially impact BSEP MOV setup calculation assumptions has become available, in

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addition, during the NRC GL 89-10 closeout inspection conducted at CP&L's H. B. Robinson i

Steam Electric Plant (HBRSEP) in September through November 1996, programmatic i

implementation concerns were identified, CP&L recognized that some of these concerns were ipotentially applicable to the BSEP GL 89-10 MOV program. The "CP&L GL 89-10 Corporate Improvement Plan" and the "1997 Improvement Plan & Schedule For The Brunswick Motor-

. ;p Operated Valve Program" were developed to address these concerns These plans are currently K

- being implemented to maintain the BSEP MOV setup calculation assumptions current with the

latest industry and NRC accepted practices.

The. RC conducted an inspection of the BSEP GL 89-10 MOV program from August 18 N

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through August 27,1997. During this inspection the NRC identified that although enhancements to the BSEP GL 89-10 MOV program have been initiated since the HBRSEP GL 89-10 Linspection, additional information/ actions are needed to support NRC closure of GL 89-10. The purpose of this letter is to inform the NRC of the status of the BSEP GL 89-10 MOV program and to notify the NRC of actions being taken to further improve the program and to support NRC

~ losure of GL 89-10 for the BSEP. Enclosure 1 provides a listing of the areas for improvement c

- identified during the NRC inspection, as well as the actions taken and those actions which will be

. implemented to affect improvement in each of these areas. Enclosure 2 provides a listing of the regulatory commitments established in this letter.

9710090099 971002 l,

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.Documpnt Control Desk ilSEP.97-0408 / Page 2 -

Please refer any questions regarding this submittal to Mr. Warren Dorman, Supen'isor -

Licensing, at (910) 457-2068.-

Sine rely, k N, Keith R. Jury Manager - Regulatory Affairs SFT/sft -

Enclosures:

1. GL 8910 Areas ForImprovement

2. List of Regulatory Commitments

- i Document Control Desk -

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DSEP 97-0408 / Page 3 T

cc(with enclosures):

U. S. Nuclear Regulatory Commission, Region 11

. ATTN: Mr. Luis A. Reyes, Regional Administrator

- Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85

-Atlanta, GA 30303 U. S. Nuclear Regulatory Commission ATTN: Mr. Charles A. Patterson, NRC Senior Resident inspector 8470 River Road

- Southport, NC. 28461 U. S. Nuclear Regulatory Commission -

ATTN:- Mt David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738

' The Honorable J. A, Sanford Chairman - North Carolina Utilities Commission

. P.O. Box 29510 Raleigh, NC 27626-0510 4

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-ENCLOSURE 1

. BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2

. DOCKET NOS. 50 3'15 AND 50 324 LICENSE NOS. DPR-71 AND DPR 62 GENERIC LE' ITER 8910 AREAS FOR IMPROVEMENT The following is a listing of the areas for improvement iddntified during the NRC Generic Letter

- (OL) 8910, " Safety-Related Motor-Operated Valve Testing And Surveillance," Motor-Operated

~ Valve (MOV) inspection conducted from August 18 through August 27,1997, and the actions needed to affect improvement in each of these areas and to support closure of the GL 89-10 MOV Program at the Brunswick Steam Electric Plant (BSEP).-

1. GL 8910 MOV Capability Table The NRC requested that MOV capability data be assembled in a matrix for those valves included j

in the BSEP GL 89-!0 MOV program.' We agree that the matrix is a beneficial tool and, as such, had a matrix partially developed at the time of the inspection. Completion of the matrix requires revision of the setup calculations for the GL 89-10 program valves. As the setup calculations are revised, the appropri.ite information is being incorporated in the matrix. Data for the original scope of valves will be incorporated in the matrix by January 15,1998. In addition, the matrix will be updated by February 1,1998, to include scope additions (i.e., valves added per the

' discussion in items 26 and 30).

- 2 Valve Operation Test & Evaluation System (VOTES) Open Uncertainty Review Industry data developed over the last several years has indicated that the VOTES for valve testing in the open direction is less accurate than the VOTES accuracy originally provided in 1

vendor instr etions.' The NRC has requested that the VOTES test equipment uncertainties be l incorporated into revised MOV setup calculations.

- An effort is in progress to incorporate VOTES test equipment uncertainties into the BSEP revised MOV setup calculations, This action will be completed by December 15,1997.

In addition, Liberty Technologies has been contracted to perform an independent review of differential pressure test results. A review of the preliminary report from Liberty Technologies has been completed and no operability issues were identified. Discrepancies identified during review of the final report will be addressed during the revision of the MOV setup calculations discussed in item 26.

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3. Basis For GL 89-10 Completion Letters in letters dated June 21,1995,(BSEP 95-0247) and April 12,1996, (BSEP 96-0138) the NRC was informed that an MOV program in accordance with GL 89-10, had been implemented at the BSEP based on completion of the necessary testing and preparation of MOV setup calculations needed to demonstrate MOV capability under design bases conditions; considerable resources were expended in performing these calculations and tests. These calculations were prepared using the best available infonnation at the time and, as such, Carolina Power & Light (CP&L)

Company considered the BSEP GL 8910 closure notification letters to be accurate at the time of issuance.

Since the issuance of the BSEP GL 8910 closure notification letters, additionalinformation that could potentially impact MOV setup calculation assumptions became available to the BSEP and the industry. In fact, changes in test equipment, a more in depth site and industry data bank, and evolving inspection criteria of valve factors and other assumptions continue to drive changes in analysis methodology.

In addition, during the NRC GL 89-10 closeout inspection conducted at CP&L's

11. B. Robinson Steam Electric Plant (HBRSEP) in September through November of 1996, GL 89-10 program concerns were identified. CP&L recognized that some of these NRC identified concems were potentially applicable to the BSEP GL 89-10 MOV program. The "CP&L GL 89-10 Corporate Impmvement Plan" and the "1997 Improvement Plan & Schedule For The Brunswick Motor-Operated Valve Program" were developed to address these concerns.

These plans are currently being implemented in an effort to maintain the BSEP setup calculation assumptions current with the latest accepted practices, all of which are not currently delineated as regulatory requirements.

4. Justify The 0.7 Wedge Gate Valve Factor (VF) Assumption Topical basis calculation, BNP-MECH-MOV-VF, delineates the VF (i.e., friction) values to be used for MOV setup calculations. This calculation addresses the VF values for a variety of valve types and manufacturers, including wedge gate valves, based on as-tested data. The calculation groups valves by manufacturer and valve type and determines a maximum VF value for each valve type (i.e., default value). The default value is conservatively larger than VF values determined via testing and, consequently, is used when calculating thrust requirements for non-tested valves.

The NRC considers the default values potentially nonconservative due to database limitations.

In addition, the NRC also believes that variations in VF values might be obscured based on the grouping of the valves by valve type / manufacturer. The NRC requested that the default values be based on manufacturer, valve typc, valve size, valve pressure class, contact materials, and application. The NRC also requested that an industry survey be performed to obtain supplemental data related to the non-testable valves installed at the BSEP.

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'An industry survey will be performed to obtain test data from both Pressurized Water Reactors (PWRs) and Boiling Water Reactors (BWRs) for wedge gate valves. The survey will include those models of wedge gate valves identined in the BSEP GL 89 10 MOV program, ( i.e.,

Anchor Darling and Velan valves). Test data will include systems with Duid chemistry similar to the BSEP, (i.e., demineralizer quality water). The industry test information will be combined with the USEP test data and evaluated for inclusion into BNP-MECil MOV-VF and the MOV setup calculations. An evaluation of Electric Power Research Institute (EPRI) data will also be perfomied to determine its applicability for those valves which are non testable and for which no industry data can be obtained. BNP-MECH-MOV VF will be updated to reDect more discrete groupings of valves (by manufacturer, type, size, pressure class, contact materials, and application) and to encompass BSEP and industry data. Default values will be determined based on bounding values.

These actions will be completed by December 15,1997.

5. Justify Globe VF Assumptions For Non-Difluential Pressure Tested Valves As noted in item 4, topical basis calculation, BNP-MECH-MOV-VF, delineates the VF values used for setup calculations. This calculation determined the VF values for a variety of valve types and manufacturers, including globe valves based on as tested data. The NRC is concerned that the default values are potentially nonconservative due to database limitations and that VF values might be obscured based on the grouping of the valves by valve type / manufacturer.

There are Anchor Darling and Velan globe valves in the BSEP GL 89-10 MOV program which are diagnostically non-testable under difTerential pressure conditions. A review of the EPRI

" Performance Prediction Program Topical Report," TR-103237, November 1994, Table E-15, determined that there is a valid basis to support the use of a VF value of 1.1 for non-compressible Dow combined with an appropriate assumption for area.

An industry survey will be conducted, by December 15,1997, to obtain additional data on the non-testable globe valves installed at the BSEP. The survey will include those manufacturers of globe valves included in the BSEP GL 89-10 MOV program,(i.e., Anchor Darling and Velan valves).

6. Justify Stem Coefficient Of Friction (COF) < 0.20 Assumptions MOV stem factor and stem COF data was evaluated in BNP-MECH-MOV-SF. This calculation concluded that a COF value of 0.20 should be assumed in MOV setup calculations when valve-specinc stem COF data is unavailable.

The NRC identined that the MOV setup calculations for three valves (i.e.,1-El1-F047A, 2-E51-F007, and 2-G31-F001) assumed a COF value of 0.15. The affected calculations will be revised, by December 15,1997, to use a COF value of 0.20 for these three valves to resolve this Concern.

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In addition, the NRC is concemed that the current program does not address age-related degradation for valves with stem COF values less than 0.20. As part of GL 89-10 MOV preventive maintenance program requirements, valve stems are clean ed and lubricated during refuel outages. These measures provide reasonable assurance that af,c-related degradation is not an issue and that COF values greater than or equal to 0.15 are accef table. To ensure that stem COF values of greater than or equal to 0.15 are applied in MOV sr cup calculations, the stem factor topical calculation, llNP-MECll-MOV-SF, will be revised. This revision will clarify the use of mini-groups in MOV setup calculations. The stem COF value for each group will be the bounding value for that group of valves with no COF value less than 0.15, unless adequate justification for a lower value is provided. In addition, MOV setup calculations will be revised to require the use of either as-tested data with no COF value less than 0.15, unless adequate justification for a lower value is provided, or default to a value of 0.20 for untested valves.

These actions will be completed by December 15,1997.

Calculation DNP-MECil MOV-SP is a living document and will be maintained current as future llSEP and Joint Owners' Group (JOG) test data becomes available,

7. Application Factor (AP) Assumptions For DC MOVs Limitorque Technical Update 93-03, Reliance 3 Phase Limitorque Corporation Actuator Motors (Starting Torque @ Elevated Temperature), discusses the use of AF assumptions for alternating current (AC) motors. An AF value is used to account for uncertainties under degraded voltage conditions. Limitorque allows the use of a 1.0 AF value when the degraded-to-rated voltage is less than 90%, since such a ratio would adequately account for the uncertainties that the AF value is intended to compensate for at voltage ratios above 90%. When the voltage ratio is above 90%, Limitorque requires the AF value to be applied rather than the degraded voltage ratio. This rationale appears to be applicable to AC as well as direct current (DC).

The NRC has requested that the process for applying AF values of 1.0 and 0.9 be clarified for DC MOVs. MOV setup calculations will be revised, as necessary, to require the use of an AF value of 0.9 for DC MOVs. In addition, the guidance p ovided in procedure EGR-NGGC-0203,

" Motor-Operated Valve Performance Prediction, Actuator Settings, And Diagnostic Test Data Reconciliation," will be revised to ermit use of a 1.0 AF value, when allowed by Limitorque r

Technical Update 93-03, for AC motors only. These actions will be completed by December 15,

1997,

8. Justify Data Extrapolation Guidance Procedure EGR-NGGC-0203 currently recommends that tests be performed at a differential pressure of at least 80% of the design basis differential pressure and that the basis for extrapolation from less than 80% of design basis differential pressure be justified in the reconciliation calculation. This guidance is considered reasonable since EPRI and industry testing has concluded that VF values tend to decrease with increasing differential pressure.

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'EGR NGGC-0203 references the extrapolation criteria specified in Revision 1 of TR 103244, "EPRI MOV Performance Prediction Program implementation Guide," as one method that can be used to justify data extrapolation from tests conducted at less than 80% design basis differential pressure, it is recognized that EPRI extrapolation guidance also establishes a lovcer absolute differential pressure as a limit for test reliability due to the potential for data scatter.

Preliminary review of the test data reveals that the extrapolation criteria in Revision 1 of TR 103244 has been satisfied.

The NRC has requested that clearer guidance be established for the extrapolation of differential pressure test data. To resolve this issue, the differential pressure thrust extrapolation guidance currently provided in EGR-NGGC-0203, will be reviewed to determine whether a clarification is needed to more explicitly state that the extrapolation criteria specified in TR-103244 should be applied when evaluating differential pressure test data. This review and procedure revision, if needed, will be completed by December 15,1997.

9. EGR-NGGC-0203 Torque Switch Repeatability Correction The NRC identified that the equation delineated in section 9,6.2.6 of EGR-NGGC-0203 used to determire the closing differential pressure thrust margin for torque-controlled closing strokes does not apply torque switch repeatability to the measured thrust at the torque switch trip actuation point.

MOV design basis thrust and torque margins are determined in the MOV setup calculations in accordance with the guidance contained in EGR-NGGC-0203. These margins are used to assess MOV capability under design bases conditions. The margins calculated in the MOV setup calculations account for relevant uncertainties and allowances including: measurement uncertainty, torque switch repeatability, stem lubrication degradation, rate-of loading, and spring pack relaxation.

Differential pressure thrust margin is determined in the reconciliation calculation for those MOVs that have been differential pressure tested. This margin is intended to represent a " point-in time" margin and is determined for information only. Since these are " point-in-time" margins, torque switch repeatability and stem lubrication degradation are not considered. The differential pressure thrust margin is not used to assess MOV capability under design bases conditions. MOV capability under design bases conditions is assessed in two steps. The initial assessment of MOV capability is performed per procedure OMMM-030, " Motor Operated Valve Analysis, Tracking And Trending Program," prior to retuming an MOV to service following differential pressure testing. A more comprehensive assessment of the differential pressure test data is incorporated in the setup culculation, including determination of the design basis margin.

The evaluations in section 9.6.2.6 of procedure EGR-NGGC-0203 will be revised such that the evaluations are suitable for assessing the design basis capability of an MOV that has been differential pressure tested, prior to returning the MOV to service. In addition, procedure El-5

'0MMM-030 will be revised consistent with EGR NGGC 0203 revisions. These procedure revisions will be completed by December 15,1997.

- 10. Seat Area Determination For Globe Valves -

i Procedure EGR NGGC-0203, paragraph 9.1.15, states that the area to be used for determining the required thrust value for globe valves should be based on the disc guide diameter for those

. globe valves furnished with disc guides. Paragraph 9.1.15 also references TR-103244, which provides criteria for determining whether a globe valve is seat based or guide-based.--The NRC is concemed that the current procedural guidance does not ensure that the appropriate area is i

used for thrust calculations.'

i Procedure EGR-NOGC-0203, paragraph 9.1.15, will be reviewed against TR-103244, Revision i

1, and revised as appropriate to provide clearer guidance for determining whether the seat or -

i guide area should be used to determine the required thrust value for globe valves. This procedure revision will be completed by December 15,1997. In addition, the appropriate area will be included in the revised MOV setup calculations being performed pursuant to item 26.

- 11. Inspection Of Actuators Utilizing Extended Range Values The NRC has identified that the guidance provided in OPM-MO504, " Mechanical Inspection And Lubrication Of Limitorque Operators," could be enhanced to sensitize craft personnel to the need for a detailed examination of those valves which have operated in the extended range.

During the recent NRC GL 89-10 MOV inspection a procedure change request was issued to address this issue, Based on this action the NRC considers this item closed.

12. DC MOV Stroke Time Test Methodology The NRC identified a concern with the methodology used to calculate DC MOV stroke times.

1 The NRC also noted that some of the calculated MOV strcke times were slightly faster than the required values noted in the Technical Specifications.

The existing methodology is considered to be conservative. As an alternative approach, the q

Boiling Water Reactor Owners' Group (BWROG) has developed a DC stroke time methodology.

An evaluation of the BWROG DC MOV stroke time testing methodology will be performed by l

December 15,1997. This short term evaluation will determine if the current BSEP methodology is conservative as compared to the BWROG methodology. The evaluation will also determine if the BWROG methodology is reasonable and appropriate for use. If the current BSEP methodology is determined to be nonconservative, short term corrective actions will be identified and resolved by Jai.uary 15,1998. Iflong term actions are required, the necessary procedure / calculation revisions will be performed to support implementing the BWROG methodology by September 1,1998.

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'13. GL 89-10 Supplement 3 Design Basis Differential Pressure The NRC identified a potential concern regarding liigh Energy Line Break (llELB) events for Reactor Core Isolation Cooling (RCIC), High Pressure Coolant injection (HPCI), and Reactor Water Clean Up (RWCU) system lines which could result in differential pressures greater than the maximum reactor steady state pressure allowed by the Technical Specifications. Based on discussions with the NRC during the recent GL 89-10 MOV inspection, this issue is considered closed and no further actions are required.

14. Response To Information Notices 96-48 and 97-07 Following review of the BSEP's response to Information Notice (IN) 96-48, " Motor Operated Valve Performance," and IN 97-07, " Problems identified During GL 89-10 Closcout Inspections," the NRC indicated that a more definitive response to the ins was needed. To resolve this issue, a more definitive response to ins 96-48 and 97-07 will be developed by January 15,1998.

15. Valve 2-E51-F046 Stall Event On June 8,1994, the RCIC system valve 2 E51 F046 tripped on thermal overload as the valve was being opened. Motor testing performed at the time of the event verified motor integrity.

However, the NRC is concerned that a weak link analysis was not performed at the time of the event to determine potential damage to the operator or the valve. Based on the results of a subsequent weak link evaluation, it has been determined that the stress levels of several weak links were exceeded at maximum theoretical thrust values. However, the valve has operated properly over the last three years and no evidence of operator or valve damage has been observed during performance of routine preventive maintenance and valve stroking activities.

Based on the NRC concerns identified during the recent GL 89-10 inspection, a Corrective Action Program condition report was generated to address the failure to perform a weak link analysis. In addition, an internal inspection of the valve is scheduled to be performed during the

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B213R1 refuel outage currently in progress. To ensme future stall events are p operly evaluated, procedure OMMM-021,"Limitorque Valve Actuator Failure Analysis, And Trouble Shooting Guidelines," will be revised by January 15,1998.

16. Core Spray System Valve 2-E21-F031B During assessment of the operating requirements for the 2-E21-F031B, " Core Spray Minimum Flow Valve," the valve's torque switch settings were determined to be incorrect, rendering the valve inoperable. This issue was determined to be reportable in accordance with 10 CFR 50.73 requirements and reported in Licensee Event Report (LER) 2-97-002. An engineering evaluation has determined that the current torque switch settings are acceptable on a short term basis. Long term resolution of this issue will be included in the review noted in item 17 regarding potential MOV modifications.

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'17 Planned MOV Modification Schedule The NRC requested a schedule of the planned MOV modifications. The following modifications are currently planned to be implemented, during refuel outages, within the next two years:

Engineering Service Rtqtst No.

Description Schedule 97-00337 2-E41-F001, flPCI Turbine Steam Supply Valve Change from torque to limit seat B213R1 97-00158 Unit 1 SMARTSTEM installations Bil2R1 97-00159 Unit 2 SMARTSTEM installations B214R1 MOV modifications may be necessary based on the results obtained from the on-going development of MOV setup calculations. The completed MOV setup calculations will be reviewed, by July 31,1998, to determine if modifications are needed.

In addition, current plans include the installation of.imart couplings to enhance data collection and torque basis requirements for butterfly valves. Since smart coupling installation and removal will occur during valve testing and be controlled by approved test procedures, a modification will not be required to implement this enharecement.

18. MOV Post Maintenance / Modification Testing During the recent GL 89-10 MOV inspection, the NRC reviewed the MOV post-maintenance and modification test process. No concerns were identified during this review. This issue is cor?idered closed.

19. Ball Screw Valve Rate Of Loading (ROL) and Efficiency Justification The NRC expressed the concern that site specific justification does not exist for the efficiency assumptions used as the basis for ball screw valve actuator stem factor and ROL calculations.

The following actions will be taken to resolve this concern:

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A review will be performed of available industry data including available ball screw vahe test results 1 rom other nuclear facilities and vendor test data. Based on this review the assumptions related to ball screw valve performance will be incorporated as appropriate into site specific topical calculations. This review and calculation revision will be completed by December 15,1997, 2.

To provide an improved bases for the ball screw valve assumptions, Teledyne SMARTSTEMs will be installed on selected actuators. The first SMARTSTEMs are El-8

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scheduled to be installed during the 13112RI refuel outage currently scheduled for the second quarter of 1998. The SMARTSTEM installation effort is part of a previous commitment to the NRC for involvement in the JOO cooperative test program. Testing of those valves with the SMARTSTEMs installed during the Bil2R1 refuel outage and evaluation of the test data will be completed by September 1,1998

20. Stub ACME ROL And COF Plan The NRC identified the concern that the GL 89-10 MOVs which are equipped with stub ACME threads cannot be tested under significant differential pressure conditions and therefore, ROL information based on in-situ testing is not available for valves with this configuration.

To resolve this issue, an industry smey will be conducted to obtain additional data with respect to the ROL and COF values of nor-estable valves. This survey will be completed, the results documented, and the necessary chwes incorporated into the appropriate topical calculations by December 15,1997. In addition, the y propriate EPRI data will be evaluated to determine its applicability to those valves which era either non-testable or for which industry data is not available. This evaluation will be esmpleted by December 15,1997.

21. Globe Valve ROL Justification Review of as-tested, ROL performance has identified four globe valves (i.e., the Core Spray (CS) system full flow test valves) which are located in unusual piping configurations, such that these valves are subject to significant difTerential pressure conditions under the normal range of flow conditions. Since process flow is applied under the valve seats, there is continuous stem compression loading, regardless of the actual operating direction of the valves. The NRC is concerned that the continuous stem compression loading appears to have the potential for increasing the ROL effects.

As phrt of the ongoing effort to revise and improve the MOV setup calculations, globe valve piping configurations will be reviewed to determine if there is a potential for conditions similar to the CS system full flow test valves. In addition, the requirements for globe valve ROL i

assumptions will be evaluated as follows:

The as tested information will be considered acceptable basis for ROL assumptions for those globe valves which have been tested at differential pressure and for which ROL effects have been quantified.

If a valve is determined to operate in a severe flow regime, the CS system full flow test valve ROL data will be reviewed for applicability to the severe flow valve.

For non-testable valves which do not operate in a severe flow regime, the bounding ROL values, based on current test data, will be applied to these valves.

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The ROL topical calculation is a living document and will be maintained current as future l

BSEP and JOG test data becomes available.

This evaluation will be completed December 15,1997.

22. Reactor Recirculation System Valves 1/2 B32-F031 A/B Design Basis Differential Pressure The NRC has questioned the value chosen for the design basis differential, pressure for the reactor recirculation pump discharge valves.

To resolve this ccncern an evaluation of the Design Basis Accidents (DBAs) will be performed, by December 15,1997, to determine the impact on differential pressure conditions for these valves.

23. Anchor Darling Double Disc Gate Valve VF The Anchor Darling double-disc gate valve VF assumptions are currently based on vendor test data and infomiation obtained through review of EPRI data. The NRC questioned the adequacy of the current bases.

An evrduation ofindustry data will be performed to support validating the current bases or to obtain information in support of revising the current bases for the Anchor Darling double-disc gate valve VF assumptions. This evaluation will consider the feasibility of using the EPRI Performance Prediction Program (PPM) methodolagy for double disc gate valves to enhance the basis for valve factor assumptions. The evaluation will be completed and included, if deemed appropriate, into the VF topical calculation by December 15,1997.

Data from other nuclear facilities will also be reviewed and this information will be incorporated into the double-disc gate valve VF assumptions as part of the five-year commitment to the JOG program. In addition, SMARTSTEMS will be installed in two Anchor / Darling double-disc gate valves as part of the JOG cooperative test program. Initial testing of those valves and evaluation of the test data will be completed by September 1,1998.

24. Butterfly Valve Torque Requirements The batterfly valve operating torque requirement assumptions are based on vendor information.

The NRC questioned the adequacy of the current bases for these assumptions.

To resolve this concern the following actions will be taken:

An int.ary survey will be performed to obtain additional data on non-testable butterfly valves.

The servey will encompass a suitable range of valve sizes and pressure classes for those models of butterfly valves included in the BSEP GL 89-10 MOV program, (i.e., valves manufactured by El-10

'Jamesbury, Fisher, and llenry Pratt ). The survey will be completed, results documented, and the necessary changes incorporated into appropriate topical calculations by December 15,1997.

In addition, an evaluation of EPRI PPM model and test data will be perfo med, by December 15, 1997, to determine its applicability for those butterfly valves which are non-testable and for which no industry data can be obtained.

Static testing of butterfly valves located in the on-site training facility which are sin:i!ar in design to installed butterfly valves will be performed, by May 1,1998, to provide an initial indication as to whether adjustments to the programmatic assumptions for butterfly valve torque requirements are needed. This testing will be designed to support investigation into determining the required seating and unseating torque vs. lues, the impact that the length of time a valve is closed has on the required unseating torque value, and the acceptable range for closed valve limit switch settings. The lessons learned from this test effort will assist in development of an in situ test program.

Current plans include the installation of teledyne smart couplings on a series of Jamesbury butterfly valves, to evaluate the operating requirements under a variety of conditions. This evolution is currently planned to be initiated in 1998. However, several months will be required before sufficient data can be obtained to support an assessment of valve performance and valve setup requirements. The same or similar evaluation methodology will be applied to those butterfly valves manufactured by the Fisher and llenry Pratt companies which are subjected to significant design basis differential pressures (i.e., > 2 psid).

25. MOV Self-Assessment Issues The Altran Corporation performed a self-assessment of the GL 89-10 MOV program in April 1997. Action items have been established to address the identified issues from this assessment; however, resolution of the issues is not complete. The NRC has requested that an action plan be developed to address each of the findings and the issues requiring management attention identified in the self-assessment.

The "1997 Improvement Plan & Schedule For The Brtmswick Motor Operated Valve Program" currently addresses several of the findings identified by Altran Corporation GL 89-10 MOV program self-assessment; however, this plan will be revised to include corrective actions to address each of the self-assessment findings. In addition, the identified corrective actions will be tracked via the BSEP Corrective Action Program.

26. MOV Setup Calculation Revision During the recent NRC GL 89-10 MOV inspection the NRC reviewed the status of the on-going revision to the GL 89-10 MOV setup calculations and requested that this task be completed in a timely manner. Additionally, the NRC indicated that the BSEP should review the NRC safety evaluation issued by letter dated October 16,1996, " Reclassification Of Generic Letter 89-10 El-11

Motor Operated Valve Active Safety Functions Edwin 1. llatch Nuclear Plant, Units 1 and 2."

This safety evaluation provides GL 8910 valve scope guidance for BWRs.

The import.,nce of completing the on-going revision to the GL 8910 MOV setup calculations is recognized. The MOV setup calculation revision process is incorporating the lessons learned from the NRC GL 89-10 inspection conducted at the llBRSEP in September through November of 1996 and the recent BSEP MOV program self assessment. The MOV setup calculation revision will be completed by December 15,1997, for the scope of valves currently identified in the GL 8910 MOV program, in addition, a preliminary review of the E.1. Ilatch Nuclear Plant safety evaluation has been performed. This review concluded that, in addition to the 190 valves currently included in the GL 89-10 MOV program, the following 12 valves should also be added to the program: 1/2 El1-F004; l/2-El1 F016; l/2 El1 F021; l/2-El1-F027; 1/2-E21-F001; and 1/2 E21-F015. Setup calculations for these valves will be completed by December 15,1997.

In add".isn, as a result of the MOV scope review reviewed as noted in item 30, the MOV setup calculations for any valves added to the GL 8910 MOV program will be completed by February 1,1998,

27. GL 89-10 Scope Changes This item is a duplicate ofitem 30.

28. Periodic Verification Of MOV Settings The controls established, within the preventive maintenance program, for ensuring periodie verification of GL 89-10 MOV related valves and the current plans for implementing the JOG test program were reviewed with the NRC during the recent GL 89-10 MOV inspection. Based on this review the NRC considers this item closed for GL 89-10.

29. RWCU System Valve 1-G31-F004 Packing Adjustment On October 23,1996, the packing nuts installed on valve 1-G31-F004, RWCU Inlet Line Outboud Isolation Valve, were torqued to 33 f1-lbs in an effort to correct a minor packing leak.

The NRC is concemed that no post maintenance VOTES test was performed prior to retuming the valve to service.

Since the unit was on-line at the time the 1-G31-F004 packing was adjusted, VOTES testing (i.e., a packing enforcer test) could not be performed due to the high temperature of the stem.

Therefore, the packing gland nuts were torqued to the same value (i.e.,33 ft-lbs.) used during the last VOTES test performed on August 16,1993. Following the repair, the valve was electrically stroked with no identified problems.

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'Chesterton the packing manufacturer was contact d to v lu te a a e the packing loads for this valve.

e Chesterton indicated that packing load would remain essentially the same provided that a calibrated torque wrench was used each time to achieve the 33 ft lbs. Based on vendor input the valve's current packing loads are considered acceptable.

To resolve the NRC concern, the 1-G31-F004 valve will be VOTES tested to verify the packing load during the Bl12R1 refuel outage currently scheduled for the second quarter of 1998.

30. GL 8910 MOV Scope Validation Procedure ENP 56," Generic Letter 8910 Motor Operated Valve Overview And Guidance Procedure," Revision 0, issued in 1992, contained a listing of the valves included in the GL 89-10 MOV program. Initially this list identified 238 valves. Currently, the list of GL 8910 MOV program valves is contained in procedure, OMMM-32, " Generic Letter 8910 Motor-Operated Valve Overview And Guidance Procedure." This list identifies 190 valves. The valves that were removed from the program between 1992 and the present were evaluated in engineering evaluation EER 94 0145. The NRC has requested a re-evaluation of the scope of the program in view of the information provided in the NRC safety evaluation issued to the E. I, llatch Nuclear Plant by letter dated October 16,1996.

An evaluation will be performed, by December 15,1997, to validate the scope of the GL 89-10 MOV program scope.

31. Residual lient Removal System Valve 2-El 1 F009 Stall Event On March 3,1996, valve 2-El1-F009, Shutdown Cooling Inboard Suction Vahe, motor failed due to hydraulic locking of the spring pack during valve closure. The NRC is concerned that no weak link analysis was performed at the time of the event to determine potential damage to the operator or the valve.

Subsequent to the event, a weak link analysis was performed. The stresses caused by maximum thrust of the motor / operator were determined to be approximately equal to the weak link values.

The valve yoke clamp is the weak link. This valve, including the yoke clamp and packing gland area, has been inspected since the event occurred. No problems were identified during the last inspection. An inspection will be performed during the B213R1 refuel outage, currently in progress, to determine if damage to the yoke clamp occurred due to the stall.

32. Post Maintenance Test Requirements Following Valve Packing Adjustment The NRC is concerned that program controls are not adequate to ensure valve operability through post maintenance testing or evaluation following valve packing adjustments (i.e., new packing, packing tightened, or an extra ring of packing installed).

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'To resolve this concern, an evaluation of procedure OPLP 20, " Post Maintenance Testing Program," will be performed and the necessary revisions to this procedure implemented by December 15,1997. This procedure revision will ensure adequate controls exist to ensure valve operability is verified following valve maintenance involving packing adjustment. The evaluation will also consider requiring either the VOTES packing enforcer test or other attemative test methods to confirm the acceptability of the packing load for the OL 89-10 MOVs.

Additionally, a review of the GL 8910 MOV maintenance history documentation from the past two years will be performed to determine whether valves have had their packing adjusted without the performance of post maintenance testing to determine the acceptability of the as-left packing load. These actions will be completed by December 15,1997.

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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS DPR-71 AND DPR-62 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Carolina Power & Light (CP&L)

Company in this document. Any other actions discussed in the submittal represeni intended or planned actions by CP&L. They are described to NRC for the NRC's information and are not regulatory commitments. Please notify the Manager - Regulatory Affairs of any questions regarding this document or any associated regulatory commitments.

Commitrent Committed date or outage The Motor Operated Valve (MOV) capability matrix will be completed for January 15,1998 the original scope of Generic Letter (GL) 89-10 MOVs.

The MOV capability matrix will be completed for additions to the original February 1,1998 scope of GL 8910 MOVs.

Valve Operation Test & Evaluation System (VOTES) test equipment December 15,1997 uncertainties will be incorporated into the revised MOV setup calculations.

Discrepancies identified during review of the Liberty Technologies final December 15,1997 report will be addressed during the revision of the MOV setup calculations.

Evaluation ofindustry test data and Electric Power Research Institute (EPRI)

December 15,1997 data related to wedge gate valves, including non-testable valves, will be performed and the necessary revisions, to include more discrete grouping of valves, to topical basis calculation, BNP-MECH MOV-VF, and the MOV setup calculations implemented.

An industry survey will be conducted to obtain additional data on non-testable D.cember 15,1997 globe valves.

Affected MOV calculations will be revised to use a stem Coefficient Of Friction December 15,1997 (COF) value of 0.20 for valves 1-El 1-F047A,2-E51-F007, and 2-G31-F001.

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1 Commitment Committed date or outage To ensure that stem COF values of greater than or equal to 0.15 are applied in December 15,1997 MOV setup calculations. the stem factor topical calculation will be revised.

This revision will clarify the use of mini-groups in MOV setup calculations.

The stem COF value for each group will be the bounding value for that group of valves with no COF value less than 0.15, unless adequate justi6 cation for a lower value is provided in addition, MOV setup calculations will be revised to require the use of either as-tested data with no COF value less than 0.15, unless adequate justincation for a lower value is provided, or default to a value of 0.20 for untested valves.

MOV setup calculations will be revised as necessary to require the use of an December 15,1997 Application Factor (AF) value of 0.9 for DC MOVs. In addition, the guidance provided in procedure EGR-NGGC-0203, " Motor-Op. rated Valve Performance Prediction, Actuator Settings, And Diagnostic Test Data Reconciliation," will be revised to permit use of a 1.0 AF value, when allowed by Limitorque Technical Update 93-03, for AC motors only.

The dilTerential pressure thrust extrapolation guidance currently provided in December 15,1997 EGR-NGGC-0203 will be reviewed to detemiine whether a clarincation is needed to more explicitly state that the extrapolation criteria specined in TR-103244, Revision 1, "EPRI MOV Performance Prediction Program implementation Guide," should be applied when evaluating differential pressure test data and the necessary procedure revision implemented.

The evaluations in section 9.6.2.6 of procedure EGR-NGGC-0203 will be December 15,1997 revised such that the evaluations'are suitable for assessing the design basis capability of an MOV that has been differential pressure tested, prior to returning the MOV to service. In addition, procedure OMMM-030, " Motor Operated Valve Analysis, Tracking And Trending Program," will be revised to ensure consistency with the EGR-NGGC-0203 revisions.

The guidance provided in EGR-NGGC-0203, paragraph 9.1.15, will be December 15,1997 reviewed against TR-103244, Revision 1, and revised as appropriate to provide clearer guidance for determining whether the seat or guide area should be used to determine the required thrust value for globe valves.

The appropriate area (i.e., seat or guide) for globe valves will be included in the February 1,1998 revised MOV setup calculations.

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Commitment Committed date or outage An evaluation of the Boiling Water Reactor Owners' Group (BWROG) Direct December 15,1997 Current (DC) MOV stroke time testing methodology will be performed. This short term evaluation will assess if the current BSEP methodology is conservative as compared to the BWROG methodology. The evaluation will also determine if the BWROG methodology is reasonable and appropriate for use.

Based on the results of the evaluation of the BWROG DC MOV stroke time January 15,1998 testing methodology, if the current BSEP methodology is determined to be nonconservative, short term corrective actions will be identified and resolved.

Iflong term actions are required, the necessary procedure / calculation September 1,1998 revisions will be performed to support implementing the BWROG DC MOV stroke time testing methodology.

A more definitive response to information Notice (lN) 96-48, " Motor-January 15,1998 Operated Valve Performance," and IN 97-07, " Problems identified During GL 89-10 Closcout inspections," will be perfermed.

Reactor Core Isolation Cooling system valve 2-E51-F046 will be inspected.

B213R1

Procedure OMMM-021,"Limitorque Valve Actuator Failure Analysis, And January 15,1998 l Trouble Shooting Guidelines," will be revised to ensure future stall events are properly evaluated.

A review will be performed of the MOV setup calculations once they have July 31,1998 been completed to determine if modifications are needed. This review will address long term resolution of the Cere Spray (CS) system valve 2-E21-F031B issue.

A review will be performed of available industry data including available ball December 15,1997 screw valve test results from other nuclear facilities and vendor test data.

Based on this review the assumptions related to ball screw valve performance will be incorporated as appropriate into site specific topical calculations.

Teledyne SMARTSTEMs will be installed on selected ball screw valve September 1,1998 actuators, testing of those valves with the SMARTSTEMs, and evaluation of the test data will be completed.

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Commitment Committed date or outage

- An industry survey will be conducted to obtain additional data with respect to -

December 15,1997 4

the Rate Of Loading (ROL) and COF values of non testable GL 8910 MOVs which are equipped with stub ACME threads. This survey will be completed, the results documented, and the necessary changes incorporated into the appropriate topical calculations. In addition, the appropriate EPRI data will be evaluated to determine its applicability to those valves which are either

+

non-testable or for which industry data is not available, i

As part of the ongoing effort to revise and improve the MOV setup February 1,-1998 i

_ calculations, globe valve piping configurations will be reviewed to determine if there is a potential for conditions similar to the CS system full flow test I

valves.

The requirements for globe valve ROL assumptions will be evaluated.

December 15,1997 An evaluation of Design Basis Accidents (DBAs) will be performed to December 15,1997 determine the actual impact on differential pressure conditions for Reactor Recirculation system valves 1-B32-F031 A,1 B32 F031B,2-B32 F031 A, and 2-B32-F032B.

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-- An evaluation ofindustry data will be performed to support validating the December 15,1997 --

current bases or to obtain information in support of revising the current bases

- for the Anchor Darling double-disc gate valve valve factor (VF) assumptions.

This evaluation will also consider the feasibility of using the EPRI =

Performance Prediction Program (PPM) methodology for double-disc gate

. valves to enhance the basis for VF assumptions. The evaluation will be completed and included, if deemed appropriate, into the VF topical calculation.

f SMARTSTEMS will be installed in two Anchor Darling double-disc gate September 1,1908-valves as part of the Joint Owners' Group (JOG) cooperative test program.

Initial testing of those valves and evaluation of the test data will be

- completed.

An industry survey will be performed to obtain additional data on non-testable

- December 15,1997 butterfly valves. The survey will encompass a suitable range of valve sizes and pressure classes for those models of butterfly valves included in the BSEP i

GL 89 10 MOV program, (i.e., valves manufactured by Jamesbury, Fisher, and Henry Pratt ). The survey will be completed, results documented, and the

. necessary changes incorporated into appropriate topical calculations.

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Commitment Committed date or outage An evaluation of EPRI PPM model and test data will be performed to December 15,1997 detemtine its applicability for those butterfly valves which are non-testable and for which no industry data can be obtained.

Static testing of butterfly valves located in the on-site training facility which May 1,1998 are similar in design to installed butterfly valves will be performed to provide an initial indication as to whether adjustments to the programmatic assumptions for butterfly valve torque requirements are needed.

The "1997 Improvement Plan & Schedule For The Brunswick Motor-December 15,1997 Operated Valve Program" will be revised to include corrective actions to address each of the self assessment findings and the identified corrective actions will be tracked via the BSEP Corrective Action Program.

The MOV setup calculation revision for the scope of valves currently December 15,1997 identified in the GL 89-10 MOV program will be completed.

The MOV setup calculations will be revised to include valves 1/2-El1-F004; December 15,1997 1/2-Ell-F016; 1/2-El1-F021; l/2-El1-F027; l/2-E21-F001 and 1/2-E21-F015.

The Reactor Water Cleanup (RWCU) system valve 1-G31-F004 will be B112R1 VOTES tested to verify the packing load.

An evaluation will be performed to validate the scope of the GL 89-10 MOV December 15,1997 program scope.

An inspection will be performed to determine if damage to the Residual Heat B213R1 Removal (RHR) system valve 2-El1-F009 yoke clamp occurred due to the stall.

As a result of the MOV scope review performed as noted in item 30, the February 1,1998 MOV setup calculations for those valves added to the GL 89-10 MOV program will be completed.

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Commitment Committed date or outage An evaluation of procedure OPLP 20, " Post Maintenance Testing Program,"

December 15,1997 will be perfonned and the necessary revisions to this procedure implemented.

This procedure revision will ensure adequate controls exist to ensure valve operability is verified following valve maintenance involving packing l

adjustment. The evaluation will alsa consider requiring either the VOTEf>

packing enforcer test or other alternative test methods to confinn the acceptability of the packing load for the OL 8910 MOVs.

A review of the OL 8910 MOV maintenance history documentation from the December 15,1997 i

past two years will be perfonned to determine whether valves have had their packing adjusted without the performance of post maintenance testing to determine the ac< eptability of the as le!) packing load.

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