View source for BSEP-99-0161, Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V351

{{Adams
| number = ML20217F200
| issue date = 10/13/1999
| title = Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V351
| author name = Jury K
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-99-0161, TAC-MA1115, TAC-MA1116, NUDOCS 9910200250
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 3
| project = TAC:MA1115, TAC:MA1116
| stage = Response to RAI
}}

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LCP&L J Carolina Power & Ught Company P.O. Box 10429 L Southport, NC 28461-0429
                   . October 13,1999_-
SERIAL: BSEP99-0161~
U. S.' Nuclear Regulatory Commission .
A'ITN: Docum~ent Control Desk Washington, DC .20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO REQUEST FOR INFORMATION - INSERVICE TESTING PROGRAM FOR THE THIRD 10-YEAR INTERVAL (TAC NOS. MA1115 AND MA1116)
: Gentlemen:
                  , B'y letter dated February 25,' 1998, as supplemented on August 6,1998, Carolina Power Light (CP&L) Company submitted the third 10-year interval Inservice Testing (IST)
Program for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The NRC's review of
: the relief requests associated with the revised IST Program was documented in a Safety Evaluation and Technical Evaluation Report (TER) that was sent to CP&L by letter dated
                 , ' February 9,1999. Tlie purpose of this letter is to respond to'an NRC request for information
                   . regarding relief request VRR-03.
The 1989 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, Subsection IWV, specifies the inservice testing requirements for valves.
: IWV-1100, '' Valve Testing" of the 1989 Edition of the ASME Code, Section XI states that the inservice testing of valves.should be performed as specified in the American Society of Mechanical Engineers and American National Standards Institute (ASME/ ANSI) Code for Operation and Maintenance (OM) of Nuclear Power Plants, Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants."
VRR-03 requested relief from the full 2 stroke open exercise mquirements of the 1987 Edition of
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ASME/ ANSI OM Code (i.e., OM-1987), Part 10, paragraph 43.2.2(a), for the instrument air                i supply check valves to air-operated valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350,                   I and 1(2)-RNA-V351. The instrument air system supplies operating gas to pneumatically-operated valves. The NRC's approval of VRR-03 was contingent on CP&L conipleting an action identified in the TER and' summarized in Attachment 1 of the Safety Evaluation. Specifically,
                  ; the NRC requested that CP&L provide the acceptance criteria, and the basis for the acceptance
                  ' criteria, to ensure that significant degradation of the valves is detected and corrective action taken when needed. The NRC requested that the information be provided by October 22,1999, i
1 9910200250 991013 PDR P.
ADOCK 05000324-PDR
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Document Control Desk
        . BSEP'/9-0161/ Page 2 :
L CP&L has now determined that testing of the check valves in accordance with OM-1987, Pan 10 cis being achieved and that relief request VRR-03 should be withdrawn. The basis for CP&L's
        - determination is described below.
OM-1987, Pan 10, paragraph 4.3.2.2(a) requires that each check valve be exercised or examined, during plant operation, in a manner which verifies obturator travel to the closed, full-open, or partially open position required to fulfill its function. OM-1987, Part 10, paragraph 4.3.2.4(a) requires that check valve obturator movement be demonstrated by exercising the valve and observing that either the obturator travels to the seat on cessation or reversal of flow, or opens to the position required to fulfill its function. Observation may be by observing a direct indicator, such as a position indicating device, or by other indicators'such as changes in system pressure, flow rate, level, temperature, sea! leakage testing, or other positive means.
        ~
        - A stable, audible sound of gas emanating from the test point provides a positive means of demonstrating the passage of sufficient flow through the check valves. CP&L beheves that use of a stable, audible sound of gas flow satisfies the requirements of OM-1987, Pan 10. The gas flow to the pneumatically-operated valves supplied by the instrument air system is minimal compared to the system capacity. During the 1980s, the instrument air system was modified by installation of a Nitrogen Backup system. The modification conservatively calculated the system usage rate to be 2 scfm.. The pneumatically-operated valves have accumulators directly attached to them that will allow the valves to operate to perform their safety function on a loss of air / nitrogen header pressure. There is no actual design-required flow rate in the air / nitrogen supply system for keeping the accumulators full. The check valves in the system simply throttle open as needed to keep the accumulator pressure equalized with the supply header. The maximum flow, assuming simultaneous actuation of all Safety / Relief Valves and Reactor Building-to-Torus vacuum breakers, would be 2 scfm. The actual flow expected under accident conditions would be less.
On September 14,1999, BSEP performed a laboratory demonstration using a flow of 2 sefm.
1 The equipment used in the demonstration consisted of a 100 psig air supply going to a throttle valve, a flow meter, and a %-inch discharge pipe. This is the same size piping as installed in the field. Themfore, the test equipment simulated the same air pressure and flow (i.e.,2 scfm from a
          %-inch pipe). The flow through the test equipment was audible, but not loud. Personnel who have performed previous exercising of the check valves indicated that the gas flow from the drains used in the field is easily audible during shutdown conditions. On this basis, CP&L has concluded that: (1) a stable, audible gas flow from the test point is a positive means for demonstrating the obturator travel of these check valves, (2) reliance on a stable, audible gas flow from the test point satisfies with the applicable requirements of OM Pan 10, and (3) Relief Request VRR-03 should be _ withdrawn.

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Document Control Deski BSEP 99-0161/ Page 3 Please refer any questions regarding this submittal to Mr. Warren J, Dorman, Supervisor -
Licensing, at (910) 457-2068.
Sincerely, -
Keith R. Jury
        ,                                                      Manager'- Regulatory Affairs Brunswick Steam Electric Plant WRM/wrm -
cc:      U. S. Nuclear Regulatory Commission, Region II ATTN:' Mr. Luis A. Reyes, Regional Administrator Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-3415
                        - U. S.' Nuclear Regulatory Commission
                        ' ATrN: Mr. Theodore A. Easlick, NRC Senior Resident Ir.spector                                  {
8470 River Road 1                                                                              i Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission                                                            l ATTN: Mr. Allen G. Hansen (Mail Stop OWFN 8G9)
                        -:11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford
                        , Chair - North Carolina Utilities Commission P.O. Box 29510
                        . Raleigh, NC 27626-0510 Division of Boiler and Pressure Vessel
                        . Nonh Carolina Department of Labor
                         'ATTNi Mr Jack Given ' Assistant Director of Boiler & Pressure Vesseis
                                                                                                                         ]'
4 West Edenton Street .
Raleigh, NC 27601-1092                                                                          ,
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