ML20005E997

Technical Evaluation Rept Pump & Valve Inservice Testing Program,Brunswick Steam Electric Plant,Units 1 & 2.

ML20005E997
Person / Time
Site:	Brunswick
Issue date:	11/30/1989
From:	Cook T, Hartley R EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20005E995	List: ML20005E997
References
CON-FIN-A-6812 EGG-NTA-8420, TAC-63523, TAC-63524, NUDOCS 9001120157
Download: ML20005E997 (97)

Text

. .

v EGG-NTA 8420 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 Docket Nos. 50 32; and 50-324 R. S. Hartley

, T. L. Cook Published November 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Cor tract No. DE AC07-761001570 FIN No. A6812

)

001 $$0bb ' ,[4 P

o .

=.

ABSTRACT

.This EGSG Idaho, Inc.,' report presents the results,of our evaluation of the Brunswick Steam Electric Plant, Units 1 and 2, Inservice Testing Program for pumps and valves'whose function is safety-related.

4 FOREWORD-This-report is supplied as part of the " Review of Pump and Valve

. Inservice _ Testing Programs for Operating Reactors-(III)" program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor P.egulation, Mechanical Engineering Branch,'by EG&G Idaho, Inc.,

Regulatory and Technical Assistance.

FIN No. A6812 B&R No. 920-19-05-02-0 Docket Nos. 50-325 and 50-324 TAC Nos. 63523 and 63524 ii

9. -t CONTENTS ABSTRACT .............................................................. ii FOREWORD .............................................................. ii

1. INTRODUCTION ..................................................... 1

2. SCOPE ............................................................ 3

3. PUMP TESTING PROGRAM ..*.............s............................ 7 3.1 Pump Bearing Temperature Measurement ....................... 7-3.1.1 Relief Request ..................................... 7 3.2 Standby Liquid Control System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3.2.1 Relief Request ..................................... 10 3.2.2 Reliof Request ..................................... 11 3.3 Diesel Fuel Oil System ..................................... 13 3.3.1 Relief Request ..................................... 13 3.4 Service Water System ....................................... 15 3.4.1 Reli'ef Request ..................................... 15

4. VALVE TESTING PROGRAM ............................................. 17 4.1 General Valve Relief Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.1.1 Power Operated V al ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.1.2 Solenoid Operated Valves ........................... 19 4.1.3 Containment Isol ation Valves . . . . . . . . . . . . . . . . . . . . . . . 20 4.1.4 Exces s Fl ow Check Val ves . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 4.1.5 Containment Isol ation Check Valves . . . . . . . . . . . . . . . . . 25 4.1.6 Keep F ill Check Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 4.2 Con trol Rod Dri ve Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 4.2.1 Category B and C Valves ............................ 30 4.3 Nuclear Steam Supply System ................................ 33 iii 1

4.3.1 C a t eg o ry B/ C V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 4.4 Core' Spray System .......................................... 35 4.4.1 C a t eg o ry A/C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 4.5 Re s idu al Heat Removal Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . ... 38 4.5.1 Category A/C Valves ........................ . ..... 38 4.6 Diesel Generating System ................................... 40 4.6.1 C a t eg o ry B V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 4.6.2 Category C Valves .................................. 41 4.7 Standby Liquid Control System ............................. 43 4.7.1 Category A/C Valves ................................ 43 4.7.2 Category C Valves ....... ......................... 44 4.8 Service Water System ........................ .......... . 46 4.8.1 Category B Valves .................................. 46 4.8.2 Category C Valves .................................. 48 4.9 High Pressure Cool ant Injection System . . . . . . . . . . . . . . . . . 59 4.9.1 Category C Valves . ........ ................ .... 59 4.10 Emergency Service Water System ......... ... ............. 66 4.10.1 C a t e g o ry B V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 4.10.2 Category C Valves .......... .................. . . 67 4.11 Various Emergency Core Cooling Systems ..................... 69 4.11.1 C a t eg o ry A V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 APPENDIX A--VALVES TESTED DURING COLD SHUTDOWN ................. ..... A-1

1. REACTOR RECIRCULATION SYSTEM .. .................. .. .... A-3 1.1 Category A Valves .......................... ... .. A-3 1.2 Category B Val ves . . . . . . . . . . . . . ....... .... . A-3

2. NUCLEAR STEAM SUPPLY SYSTEM . . . . . . ..... A-4 2.1 Category A Valves . A-4 2.2 Category C Valves . .. . .. .... A-4 iv

O-

3. ~ FEEDWATER SYSTEM ........................................... A-5 3.1 Category.A/C Valves ................................ A-5

4. -RESIDUAL HEAT REMOVAL SYSTEM ............................... A.6 4.1 Category A' Valves .................................. A-6 4.2 C atego ry A/C V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6 4.3 C a t ego ry B V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6

5. REACTOR BUILDING CLOSED CDOLING WATER SYSTEM ............... A-7 5.1 Category A Valves .................................. A-7

o. NON-INTERRUPTIBLE INSTRUMENT AIR SYSTEM .................... A-8 6.1 C a t eg o ry A V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-8

7. CONTAINMENT ATMOSPHERE MONITORING SYSTEM ................... A-8 7.1 C a teg ory A V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A- 8

8. HIGH PRESSURE COOLANT INJECTION SYSTEM ..................... A-8

. 8.1 C a t eg o ry A V al v e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-8 8.2 Category A/C Valves ................................ A-9 8.3 Category C Valves .................................. A-9

9. REACTOR CORE ISOLATION COOLING SYSTEM . . . . . . . . . . . . . . . . . . . . . . A- 10 9.1 C at eg o ry A V al v e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A- 10 9.2 C a t e g o ry A/ C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A - 10 APPENDIX B--P&ID AND FIGURE LIST ...................................... B'- l APPENDIX C--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW ........ C-1 e

i V

L.-

TECHNICAL EVALUATION REPORT ,

4 PUMP AND VALVE INSERVICE TESTING PROGRAM BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1 AND 2 g

1. INTRODUCTION j Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by Carolina Power and Light Company for its Brunswick Steam Electric Plant, Units 1 and 2. .;

By a letter dated October 23, 1986, Carolina Power and Light Company submitted an IST Program for Brunswick Steam Electric Plant, Units 1 and 2. l A working meeting with Carolina Power and Light Company and Brunswick Steam Electric Plant, Units 1 and 2, NRC, and EG&G representatives was conducted July 21 and 22, 1987. The licensee's IST Program for pumps and valves, Revision 2, as revised by Carolina Power and Light Company and attached to R. B. Richey letter to NRC, dated November 24, 1987 and additional changes _j to their program, dated March.28, 1988, November 2, 1988, and September 8,  ;

, 1989 were reviewed to verify compliance of proposed tests of pumps and i valves whose function is safety related with the requirements of the ASME Boiler and Pressure Vessel Code (the Code),Section XI, 1980 Edition through Winter 1981 Addenda. Any.IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER). The NRC staff position is that program changes, such as additional relief requests or the deletion of any components from the IST program, should be submitted to the NRC under separate cover in order to receive prompt attention, but should not be implemented prior to review and approval by the NRC. .

In their submittal, Carolina Power and Light Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine if the required testing is indeed impractical for the specific pumps and valves.

This review was performed utilizing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and Value/ impact Statement titled " Identification of Valves for inclusion in Inservice Testing Program". The IST Program ~ testing requirements apply only to 1 I h-..__ _.mm_ _ _ _mm._-m. __mm-

• ' = l

- l g

component testing (i.e., pumps .and valves) and are not intended to provide the basis to change the licensee's current technical specifications for ]

system test r'equirements. ,

1 Section 2 of this report presents 'a discussion of the scope of this review.

r t

Section 3 of this report presents the Brunswick Steam Electric Plant, Units 1 and 2, relief requests and EG&G's evaluations and conclusions ,

regarding these requests for the pump testing program. Similar information is presented in Section 4 for the valve testing program. [

This TER, including all relief request evaluations and component identification numbers, is applicable to Units 1 and 2. Where a discussion is plant specific, the plant designator (i.e., Unit 2) has been placed in parentheses or is placed before the component identifier (i.e.,1-SLC-P-2A for Unit 1 or 2-SLC-P-2A for Unit 2.)

Category A, B, and C valves that meet the requirements of the ASME ,

- Code,'Section XI,. and are not exercised quarterly are addressed in Appen' dix A.

A listing of P&lDs and Figures used for this review is contained in Appendix B.

. Inconsistencies and omissions in the licensee's program noted during the course of this review are listed in Appendix C. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

2

, l-.-

2. SCOPE The EG&G Idaho review of the Carolina Power and Light Company, Brunswick Steam Electric Plant, Units 1 and 2, inservice testing (IST) program for pumps and valves was begun in 1987. The program initially examined was Revision 1, dated October 23, 1986, which identified the licensee's proposed testing of safety related pumps and valves in the plant systems listed in Appendix B.

The proposed IST program was reviewed by identifying the affected components on the appropriate system P&lDs and determining their system function. The proposed testing was evaluated to determine if it was in compliance with the ASME Code, S ction XI, requirements. During the review, questions and comments were made relative to unclear or potential problem areas in the licensee's IST program. These were transmitted to the licensee in the form of a request for additional information (RA1). This served as the agenda for the working meeting between the licensee, NRC, and EG&G reviewers.

Relief requests were evaluated and relief was either recommended to be denied or granted as requested or with provision under the applicable provisions of 10 CFR 50.55. Each relief request was evaluated to determine if the licensee had demonstrated that the Code requirements are impractical for the identified components, and/or if the proposed alternate testing method / frequency would provide a reasonable assurance of component operational readiness. Consideration was given to.the burden on the licensee on the licensee if the Code requirements were imposed. Where the licensee's technical basis or alternate testing method or frequency was insufficient or unclear, clarification was requested. Further, where measurements are necessary to verify component operability, the system P& ids were examined to determine instrumentation availability. If it was determined that it may not be possible or practical to make the measurements identified in the IST program, a question or comment was generated.

For pumps, it was verified that each of the seven inservice test quantities of Table IWP-3100-1 were indicated to be measured or observed.

3

For Code required test quantities that were not being measured or observed

-quarterly it was' verified that a request for relief from the Code requirements had been submitted. Further, questions were asked if testing ,

was not being performed in accordance with the Code and a relief request had not been submitted.

For valves, it was verified that all appropriate ASME Code testing for each valve is performed as required except where' specific relief had been requested. The proposed testing was evaluated to determined if all valves judged to be active Category A, B, and/or C, (other than safety and relief valves) are exercised quarterly in accordance with IWV-3410 or 3520. If any active safety related-valve is not full-stroke exercised quarterly as required, then the licensee's justification for the deviation, either in the form of a cold shutdown justification or a relief request, was examined to determine its accuracy and adequacy. The proposed alternate testing was also evaluated to determine if all testing was being performed that can reasonably be phrformed on each valve to bring its testing as close to compliance with the Code requirements as practical.

Safety-related safety valves and relief valves, excluding those that perform only a thermal relief function, were confirmed to be included in the IST program and tested in accordance with IWV-3510. Safety-related explosively actuated valves were verified to be included in the IST program and tested in accordance with IWV-3610.

For valves with remote position indication, the reviewer confirmed that the valve remote position indication is identified to be verified in accordance with IWV-3300. The reviewer verified that the licensee had assigned limiting values of full-stroke times for all power operated valves in the IST program, as required by IWV-3413. For valves having a fail-safe actuator, the reviewer confirmed that the valve's fail-safe actuator is identified to be tested in accordance with IWV-3415.

4

e +

1:

Each check valve was evaluated to. determine if the proposed testing would verify its ability to perform its safety functi,on(s). Extensive system knowledge and experience with other similar f acilities is employed' to

' determine whether the proposed tests would full-stroke the check valve disks open or verify their reverse-flow closure capability. If there was any doubt'about the adequacy of the identified-testing, questions were included in the RAI.

Further evaluation was performed on all valves in the program to determine' that the identified testing could practically and safely be conducted as described. If the licensee's ability to perform the testing was in doubt, a question was formulated to alert the licensee to the suspected problem.

Once all the components in the licensee's IST program had been identified on the P& ids and evaluated as described above,.the P& ids were examined closely by at least two trained and experienced reviewers to identify any additiona'. pumps or valves that may perform a safety function which were not included in the licensee's program. The licensee was asked to reconcile any components that were identified by this process which were not included in 'the IST program. Also, the list of systems included in the licensee's program was compared to a system list in the Draft Regulatory Guide and Value/ Impact Stateme.nt titled, " Identification of Valves for Inclusion in Inservice Testing Programs". Systems that appear in the Draft Regulatory Guide list but not in the licensee's program were evaluated and, if appropriate, questions were added to the RAI.

Additionally, if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their past experiences, questions were included in the RAI. Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this TER.

At the completion of the review, the RAI was transmitted to the licensee. These questions were later used as the agenda for the working meeting with the licensee on July 21 and 22, 1987. At the meeting, each 5

question and connent was discussed in detail and resolved as follows:

a. . The licensee agreed to make the necessary IST program corre'etions #

or changes to' satisfy the concerns of the NRC and their reviewers.

-b. The licensee provided additional information or clarification about their IST program that satisfied the concerns of the NRC and their reviewers, and no program change is required.

c. The item remained open for the licensee to investigate further and propose a solution to the NRC.

d. The. item remained open for further investigation by the NRC.

e._ The item remained open for further investigation and discussion by_

both the NRC and the licensee.

The licensee responded to the RAI and the working meeting discussions in a revised program submitted November 24, 1987 and additional program- .

changes dated March:28, 1988, November 2, 1988, and September 8, 1989.

These' changes _were evaluated for acceptability and if not, contributed to the-items remaining open from the meeting.

This TER is based on information contained in the submittals and obtained during conference calls and the working meeting.

6

3. PUMP TESTING PROGRAM.

The. Bru'nswick Steam Electric Plant, Units 1 and 2, IST program submitted by the Carolina Power and Light Company _was examined to verify that all pumps that are included are subjected to the periodic tests

~

required by the ASME Code,Section XI, 1980 Edition through Winter 1981 Addenda, except for those pumps identified below for which specific relief.

from-testing has been requested and is summarized in Appendix C. Each Carolina Power and Light Company basis for requesting relief from the pump testing requirements and the reviewers' evaluation of that request is summarized below.

3.1 Pumo Bearina Temoerature Measurement 3.1.1 Relief Reouest The licensee has requested relief from the annual measurement of bearing temperature in accordance with the requirements of Section XI, '

. Subarticle IWP-3100, and proposed to perform vibration monitoring for the following pumps in accordance with OM-6: -

Pumo Number Pumo Descriotion 1-SW-N-P-1A and IB Nuclear service water pumps 2-SW-N-P-2A and 2B Nuclear service water pumps-1-SW-C-P-1A, IB, and IC Conventional service water pumps 2-SW-C-P-2A, 28, and 2C Conventional service water pumps 1-CS-P-1A and IB Core spray pumps 2-CS-P-2A and 2B Core spray pumps 1-RHR-SW-P-1A, 18, 10, and ID Residual heat removal service water pumps 2-RHR-SW-P-2A, 2B, 2C, and 2D Residual heat removal service water pumps 1-SLC-P-1A and IB Standby liquid control pumps 2-SLC-P-2A and 2B Standby liquid control pumps 7

p L ,-

Pumo Number Pumo Descriotion _

l-HPCI-P MN-1 High pressure coolant injection main 1-HPCI-P-BST-1 and booster pumps .

High pressure coolant injection main HPCI-P-MN 2 2-HPCI-P-3ST-2 and booster pumps 1-SW-LW-P-1A and IB Service water lubrication water pumps 2-SW-LW-P 2A and 28 Service water lubrication water pumps 2-DG-Oll-P-1A, IB, 2A, 2B, Diesel fuel oil transfer pumps 3A, 38, 4A, and 4B Diesel fuel oil transfer pumps 1-RHR-P-1A, IS, IC and ID Residual heat removal pumps 2-RHR-P-2A, 2B, 2C and 2D Residual heat removal pumps 1-RCIC-P-1 Reactor core isolation cooling pump 2-RCIC-P-2 Reactor core isolation cooling pump 3.1.1.1 Licensee's Basis for Reauestina Relief. The referenced edition of the Code requires bearing temperature to be recorded annually.

It has been demonstrated by experience that bearing temperature rise occurs only minutes prior to bearing failure. Therefore, the detection of possible bearing failure by a yearly temperature measurement is extremely unlikely. A bearin'g will be seriously degraded prior to the detection of increased heat at the bearing housing. Quarterly vibration readings will achieve a much higher probability of detecting developing problems than annual bearing temperature readings. The small probability of detecting bearing failure by temperature measurement does not justify the additional pump operating time required to obtain the measurements. Finally, IWP-3500 requires "three successive readings taken at ten minute intervals that do.not vary more than three percent." Meeting this requirement for pumps having no recirculation test loop would be very difficult because the system water temperature, and consequently the lubricant temperature, are expected to drift more than 3% during 20 minutes. Also, the temperature of the lubricating fluid will vary with ambient- conditions and -

make meaningful data trending impractical.

As described above, a program of bearing temperature trends,and the evaluation of the results would, in some cases, be difficult to analyze.

Improper interpretation of results could result in unnecessary pump 8

maintenance. In addition it is impractical to measure bearing temperatures on many of the pumps in the program. Some specific examples are as follows: ,

- 1. ~ Core Sorav (CS): The pump bearings are water lubricated with suppression pool water.

2. Residual Heat Removal (RHR): The pump bearings are water lubricated -

with suppression pool water.

3. Hiah Pressure Coolant In.iection (HPCI): This pump is driven by a steam turbine which exhausts steam into the pressure suppression chamber. Extended run times to stabilize bearing temperatures could heat the suppression pool water to a temperature exceeding the Technical Specification limit.

Alternate Testina: Perform vibration testing on the pumps in accordance with OM-6, " Inservice Testing on Pumps in Light-Water Reactor

. Power Plants."

3.1.1.2 Evaluation. The licensee has requested relief from the Code requirements for annual bearing temperature measurements for the above listed. pumps. It is widely recognized pump bearing temperatures taken annually are unlikely to aid in the detection of bearing degradation and, further, that quarterly measurement of vibration displacement will be more likely to indicate bearing degradation.

As an alternative to the annua 1' measurement of pump bearing temperature,-the licensee has proposed to perform measurement of pump v'ibration in accordance with ANSI /ASME, OM-6, " Inservice Testing on Pumps in Light-Water Reactor Power Plants." The OM-6 pump vibration testing program incorporates a sensitive vibration velocity measurement procedure in addition to monitoring at more locations on the bearing housing.

5 Performance of pump testing quarterly in accordance with the OM-6 l

_=

-guidelines for measuring pump vibration and determining the allowable ranges and action levels has been demonstrated to provide better indication of pump degradation than performing pump bearing. vibration and annual measurement of. temperature in accordance with Section XI. Testing to these OM-6 guidelines provides an improvement in the ability to detect ,

and monitor pump degradation and, therefore, presents a reasonable alternative to the Code requirements.

Based on the determination that the licensee's proposal provides an acceptable alternative to the Code requirements, relief should be granted as requested.

3.2 Standby Liouid Control System 3.2.1 Relief Reauest

' The licensee has requested relief from measurement of suction a 1 differential pressure in accordance with the requirements of Section XI, Table IWP-3100-1.and IWP-3400(a), for the standby liquid control pumps, 1-SLC-P-1A, IB, 2-SLC-P-2A, and 2B, and has proposed to evaluate these positive displacement pumps using discharge pressure-and to verify adequate suction pressure via storage tank level.

3.2.1.1 Licensee's Basis for Reauestina Relief. No suction tap or inlet pressure instrumentatioa is provided for the standby liquid control pumps. Suction pressure when testing is small (2-3 psig) compared to

-discharge pressure (1200-1300 ps;g) and is not a significant test parameter. The pumps are pcsitive displacement pumps and since the suction pressure is low, the differential pressure is essentially equal to discharge pressure. The discharge pressure provides the information necessary to access pump condition.

10

Alternate Testino: Discharge pressure will'be utilized in lieu of differential pressure during inservice testing. Adequate suction head will be verified to ensure safe pump operation by level in the storage -

tank.

3.2.1.2 - Evaluation. lhese standby liquid control pumps are positive displacement type. Their outlet pressure is dependant on the pressure of ,

the system.into which they are pumping and is not affected significantly by inlet pressure (providing_ adequate suction pressure is available), it t is impractical to obtain inlet pressure and differential pressure measurements since no instrumentation is installed in the system.

Further, installation of instrumentation would require system modification with little increase in the quality of information gathered to evaluate these pumps. For these pumps differential pressure and flowrate are not dependant variables, as they are for centrifugal type pumps. Differential pressure is not a meaningful parameter in determining if hydraulic degradation is occurring. Measurement of discharge pressure in lieu of differential pressure for these positive displacement pumps provides enough information to evaluate to determine the hydraulic condition of these pumps and presents a reasonable alternative to the Code requirements.

Based on the determination that the Code requirements are impractical, and that the licensee's proposal provides a reasonable alternative to the Code requirements, and giving due consideration to the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.

3.2.2 Relief Reauest The licensee has requested relief from the measurement of pump flow rate and run time, in accordance with the requirements of Section XI, Subarticles IWP-3500 and IWP-4600, during quarterly testing of the Unit 2 standby liquid control pumps, 2-SLC-P-2A, and 2B, and has proposed to install the necessary instrumentation duri'ng the refueling outage scheduled to end in May 1988.

11

i

^

3.2.2.11 Licensee's Basis for Reauestino Relief. Two different pump tests are performed on the standby liquid control pumps. The quarterly. l

. test recirculates water from the test tank through the pumps back to the ,

test tank. The five-minute test requirement is observed during this  ;

quarterly test. The second test is performed'at refueling when water is pumped from the test tank into the Reactor Coolant System.

t There is no~ installed instrumentation to directly measure flow rate; therefore, flowrate can only be calculated by firing one of the squib valves and injecting water, using the pumps, into the Reactor Coolant System and measuring the decrease in test tank level during injection versus time. Additionally, the test tank volume is insufficient to, provide water for more than two minutes of pump operation. These are  :

~'

positive displac'ement type pumps. They do not require a specified operating time to reach stable conditions, and there is no method available to achieve stable conditions due to flow path used.

Elf: Flow instrumentation will be installed during the next Unit 2 refueling outage, scheduled to end 5-20-88, which will eliminate  ;

the need for.this relief request.  ;

Alternate Testina: Flow rate measurement will be performed in conjunction with the firing of one squib valve and injection into the Reactor Coolant System per plant Technical Specification 4.1.5(c). Flow rate measurements will be performed at refueling outages by measuring change in the test

- tank level over a period of time.

Pumps will be operated for a minimum of five minutes during quarterly pump testing. Operating time for the-refueling test will be determined by test tank volume.

3.2.2.2 Evaluation, prior to completion of this modification these pumps had no instrumentation installed to directly measure pump flowrate during quarterly pump testing, however, a method could be utilized to determine the pump flowrate such as pumping demineralized water from the supply line to the test tank and calculating the flowrate. Therefore, the 12

e:

l; measurement of flowrate is not considered to be impractical.- However, the licensee has stated that flowrate instrumentation will be installed during the Unit 2 refueling outage which is scheduled to end 05/20/88 and will eliminate the'need for this relief request. At the time of this writing this refueling outage schould be completed and the licensee should have completed the modifications and be measuring flowrate and testing these pumps to the Code requirements, therefore, relief need not be granted.

Based on the determination that instrumentation should currently be installed which will allow compliance with the Code requirements relief is unnecessary and should not be granted.

3.3 Diesel Fuel Oil System 3.3.1 Relief Reauest The licensee has requested relief from the measurement of pump inlet pressure, differential pressure, and flow rate in accordance with the requirements of Section XI, Subarticle IWP-3100, for the following diesel fuel oil transfer pumps, and proposed to install instrumentation by the end of 1988 which will facilitate taking these measurements:

Pumo Pumo 2-DG-Oll-P-1A 2-DG-OlL-P-1B 2-DG-0!L-P-2A 2-DG-Oll-P-2B 2-DG-Oll-P-3A 2-DG-Oll-P-3B 2-DG-Oll-P-4A 2-DG-Oll-P-4B .

3.3.1.1 Licensee's Basis for Reauestina Relief. There is no installed instrumentation to measure pump suction pressun, differential pressure, or flow rate. The inability of any given fuel oil transfer pump to operate-would not prevent the Emergency Diesel Generator System from performing its intended function. Each diesel generator has two fuel oil transfer pumps, one of which serves as the lead and the other as the' backup, to ensure that adequate fuel inventory is maintained in the day 13

. q t

tank 'at all times. ' A low level alarm is actuated if day tank level -

-decreases to less than 100 gallons. Also, the generator emergency buses can be el'ectrically interconnected, if necessary, so that any one of the >

.four diesel generators can supply the required loads of either Unit.

L liQII: Plant modifications, installing instrumentation required for pump testing, will be initiated by the end of 1987 and implementation '

completed by the end of 1988, which will obviate the necessity for .this relief request.

Alternate Testino: Each diesel fuel oil transfer pump will be tested for vibration amplitude quarterly. In addition, the diesel fuel oil transfer pumps for each diesel generator are functionally tested monthly '

during the diesel generator load tests. This testing involves verifying that each pump starts and stops automatically to maintain level in the day tank. Any significant degradation in pump performance would be observable.by corresponding variations in vibration. s 3.3.1.2 Evaluation. Prior to completion of this modification quarterly measurement of pump suction pressure, differential pressure, or ,

flow rate was not practical since there was no installed-instrumentation.

Measurement of vibration amplitude alone does not provide the information.

necessary to detec't small changes in pump hydraulic characteristics which may be indicative of degradation. The licensee performs diesel generator

" functional" testing per Technical Specifications on a monthly basis and has stated that this testing verifies that gash pump starts and stops to maintain diesel fuel oil level in the day tank. Further, the licensee has stated that instrumentation will be installed starting in late 1987 to be completed by the end of.1988 that will allow measurement of pump iniet pressure, differential pressure, and flowrate, making this relief request unnecessary. At the time of this writing these instruments should be installed and the licensee. should be able to comply with the Code requirements for these pumps, therefore, it is not necessary to grant relief from the Code requirements.

~

14

- Based on the determination that instrumentation should currently be f

installed which will allow compliance with the Code requirements relief is  :

unnecessary and should not be granted. ,5 3.4 Service Water System 3.4.1 Relief Reauest The licensee has requested relief from the measurement of pump inlet pressure, differential pressure, and flow rate quarterly in accordance with requirements of Section XI, Subarticle IWP-3100, for the service water lube water pumps,1-SW-LW-P-1 A,18, 2-SW LW-P-2A, and 2B, and proposed to measure pump vibration amplitude quarterly until modifications are completed which will allow the service water pumps to-self lubricate.

3.4.1.1 Licensee's Basis for Reauestina Relief. There-is no installed instrumentation to measure pump suction pressure, differential pressure, or flow rate. Each pump has capability of supplying all lubricating water requirements with one pump normally in service and the other pump being a backup. In addition, lubricating water can be supplied from either unit via a manually operated cross-tie valve. In accordance l' with paragraph 9.2.1.3 of the. updated FSAR, "Should all lubricating water pumps fail, the lube water can still be supplied as the nuclear and L conventional supply is 50 psi. Loss of lubricating water to the Service L Water Pumps will not result in shutdown. The Service Water Pumps are also capable of pumping water (unfiltered) over the bearings, thus, providing adequate lubrication." The Service Water Pumps are also capable of providing cooling water to the Service Water Pump motor upper (thrust) bearing without Lube Water pumps in operation. The Service Water Lub,e Water Pumps will be removed when the self lubrication modifications are complete. Current plans are to complete these modifications on all pumps by December 31, 1990.

15

g h

A1.t.p nate Testina: Each Service Water Lube Water Pump will be tested for vibration amplitude quarterly until the plant modifications have been completed.

3.4.1.2- Evaluation. These pumps supply lubricating water to the service water pump bearings. The licensee has proposed to measure only pump vibration quarterly and to perform system modifications by the'end of 1990 which will allow the service water pumps to provide self  ?

lubrication. Quarterly measurement of pump suction pressure, differential pressure, or flow rate for these service water lube water pumps is impractical since there is no installed instrumentation. The installation of instrumentation for measurement of these parameters would require system design changes and would be burdensome to the licensee, especially for the term involved. However, measurement of vibration parameters alone does not provide the information necessary to detect small changes in pump hydraulic characteristics, which may be indicative of degradation.

Assessment of pump hydraulic condition is necessary to evaluate the

~

operational readiness of these pumps and may be practicable to some extent. A possible technique might be to establish a predetermined system lineup and measure the lubricating water pressure supplied to a representative service water pump bearing. This would then be evaluated for indication of excessive hydraulic degradation quarterly for each of ,

these pumps.

Based on the determination that the Code requirements are i;9racticable and considering the burden on the licensee if the Code requirements are imposed and since the licensee is modifying the system to address this concern interim relief should be granted, provided the licensee develops and implements an alternative method for evaluating the hydraulic condition of these pumps.

16

I i

-.. l

4. _ VALVE TESTING PROGRAM' ,

The Brunswick Steam Electric Plant, Units 1 and 2, IST program submitted by the' Carolina Power and Light Company was examined to verify- 4

' that all valves that are included in the program are subjected to the periodic tests required by the ASME Coda,Section XI, 1980 Edition through .

- the Winter 1981 Addenda, and the NRC positions and guidelines. The  ;

reviewers found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are tested to the -!

Code requirements and the NRC positions and guidelines. Each Carolina Power and Light Company basis for requesting relief from the valve testing requirements and the reviewers' evaluation of that request is summarized

• below and grouped according to the system and valve Category.

4.1 General Valve Relief Recuests 1 4.1.1 Power Ooerated Valves 4.1.1.1 Relief Reauest. The licensee has requested relief from the trending _ requirements of Section XI Paragraph IWV-3417(a), for power operated valves, including those with stroke times less than or equal to two seconds (rapid acting valves), and proposed to base their stroke time '

limits on reference stroke times and assign a maximum limiting stroke time of two seconds to the rapid acting valves.

4.1.1.1.1' Licensee's Basis for Reauestina Relief--The trending requirements of. IWV-3417(a) are impractical for valve stroke time testing. By comparing the current measurement to the previous measurement plus 25 or 50%, the acceptable stroke times are allowed to increase over a

. period of time. A valve with an initial stroke time of two seconds, for example, could increase 500% in one year and still be considered acceptable per Section XI.

4 4

+

17

V .

.i

~

A more conservative approach would be comparing the current stroke- -

} ,

time to a reference stroke time. Increases in acceptable stroke time, as

, illustrated in:the previous example, could not occur using this approach. .

In the case of valves with very short stroke times (less than two seconds), a comparison with either the last measurement or a reference value is impractical. The variation in stroke time is primarily a.

function of the operator's' reaction time. For these valves, maximum limiting stroke time would be established to determine valve operability. ,

Alternate Testina: Valves with reference stroke times >10 seconds shall exhibit no more than a 25% change in stroke time when compared to the reference value.

4 Valves with reference stroke times >2 seconds and $10 seconds shall exhibit no more than a 50% or 1 second change in stroke time,.whichever is greater when compared to the reference value.

Valves that stroke in $2 seconds may be exemptec' from IWV-3417(a). In such cases, the maximum limiting stroke time shall be two seconds.

4.1.1.1.2 Evaluation--Utilizing the trending criteria outlined in Section XI could allow significant increases in valve stroke times over several tests without requiring corrective- action. The licensee has proposed to assign maximum limiting values of full-stroke times utilizing reference values based on data derived from in-situ valve stroke time i testing performed prior to or during service. This approach can be more conservative than the Code since it can facilitate valve repairs from stroke time variations less those allowed by the Code. Further, it may i prevent unnecessary valve maintenance resulting from stroke time differences from test to test caused by system variables such as; air operated valves' air supply pressure variations, fluid pressures or temperatures, ambient temperatures, etc., which are not indicative of valve degradation. i 18

'r t - _

%f '

The licensee has proposed to assign limiting values of full-stroke k, times to power operated valves as follows:

Valves that normally stroke in two seconds or less may be assigned a maximum limiting stroke time of two seconds.

For' valves with reference stroke times >2 seconds and 110 seconds the limit will be reference stroke time 50%.

For valves with reference stroke times >10 seconds the limit will be-reference stroke time 25%.

Assigning.a maximum limiting value of two seconds to valves that normally stroke in two seconds or less is' reasonable since the major component of differences noted in stroke timing can be introduced by the operator, timing method, or other causes unrelated to valve performance.

For .the other two categories above, the licensee's comparison of actual stroke times to reference stroke times, rather than trending, can allow for maintenance to be performed on these valves in many cases earlier than would be required by the Code and provides an acceptable level of safety and= quality and a reasonable alternative to the Code requirements.

Based on the determination that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

4.1.2 Solenoid-Ocerated Valves 4.1.2.1 Relief'Reauest. The licensee has requested relief from the position indicator verification requirements of Section XI, Subarticle IWV-3300, for solenoid operated valves, and proposed to verify valve position indication accuracy utilizing system parameters during operation or by leak testing or.other positive means at refueling.

4.1.2.1.1 Licensee's Basis for Reauestina Relief--These valves require disassembly of actuator components to verify operation.

19 i

m .

. Additionally, most:of these valves have minimal stroke times (less than one second)- and stem travel (approximately 0.75' inch). The accurate-visual verification of valve operation is not possible due to the minimal .

stem travel and short stroke time. This visual observation would not contribute significantly to the assurance of safe and proper valve operation.-

Alternate Testina: The valve open indication /open position is verified by normal system parameters during operation. The valve shut indication / shut position is verified by 10CFR50 Appendix J testing during refueling outages or by other positive means.

4.1.2.1.2 Evaluation--These solenoid operated valves are enclosed with no provision for external verification of position ,

indication accuracy and, therefore, compliance with the Code requirements is impractical. Disassembling these valves to verify' their position would be very burdensome to the licensee with little or no compensating increase in the level of quality or safety. System response to valve position changes can accurately reflect valve position. Leak testing provides a'n acceptable method for ensuring the accuracy of the closed position indication. The licensee's proposed alternative, to verify the open indication for these valves during operation utilizing system response and by leak testing per Appendix J or using other positive means to determine the accuracy of the closed indication, provides an acceptable level of quality and safety and a reasonable alternative to the Code requirements.

Based on the determination that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as reques'ed.

t 4.1.3 Containment isolation Valves 4.1.3.1 Relief Reauest. The licensee has requested relief from the leak testing requirements of Section XI, Paragraph IWV-3420, for all Category A valves, and proposed to perform seat leakage testing in accordance with 10CFR50 Appendix J.

20

I~ 4.1.3.1.1 . Licensee's Basis for Reouestino Relief--Title 10 of the Code of Federal Regulations Part 50 (10CFR50), Appendix J maintains the containment within the limits specified in the Technical Specifications. Many conservatisims exist in this program which allow for and monitor valve degradation. This includes a local leak rate program

' leakage. limit of 60% of the allowable containment leakage (ACL) and an integrated leakage limit of 75% of the ACL. Premaintainance tests are performed prior to any maintenance which could affect the leak tightness of the valve to monitor valve degradation and totally account for any leakage savings resulting from the repair. In addition, anytime the Technical Specif.ication limit is exceeded, a Licensee Event Report is issued reviewing the failure modes, material, and actions to prevent recurrence. These reports are reviewed by plant management and the NRC, After each integrated leak rate, a full report of all leak rate tests, dates, and leakage values is submitted to the NRC.

In summary, the Appendix J program contains many controls to monitor containment and the Section Xs requirements do not appetr to significantly increase the containment-integrity safety factor.. Historical leakages recorded do not appear to have trendable results. Therefore, the Section XI requirements would not be effective for this application.

Alternate Testina:. Testing will be performed in accordance with 10CFR50 Appendix J.

4.1.3.1.2 Evaluation--The leak test procedures and requirements for containment isolation valves identified by 10CFR50, Appendix J, are essentially equivalent to those contained in Section XI, Paragraphs IWV-3421 through 3425. Appendix J, Type C, leak rate testing adequately determines the leak-tight integrity of these . valves. However, ,

the 10CFR50, Appendix J, leak testing does not trend or establish corrective actions based on individual valve leakage rates. Technical Specification leakage rate limits are assigned to limit site boundary radiation doses to within the limits of 10 CFR 100 during and following an accident and are not intended to evaluate degradation of single components: Therefore, Technical Specification limits on leakage are not 21

a: .

e adequate to replace t.he ASME Code specified limits which are component oriented and designed to monitor and take corrective actions based on the  !

changes in component performance. .

Leak testing containcient isolation valves in accordance with the i requirements of both-Appendix J and Section XI, Paragraphs IWV-3421 through 3425, is impractical since it would result in duplication of effort with little or no increase in quality or_ safety and would be a significant burden on the licensee. However, the licensee has not. 1 demonstrated that the requirements of IWV-3426 and 3427(a) are impractical and since testing to Appendix J, Type C, does not identify leakage rate limits or require corrective actions to be taken on degraded valves it does not provide a reasonable alternative to the Code requirements.

Based on the determination that leak testing in accordance with  !

10CFR50, Appendix J, provides a reasonable alternative to the requirements  !

of Paragraphs IWV-3421 through 3425 and considering the burden on the l licensee of leak testing these valves to the requirements of both Section l XI and Appendix J, relief should be granted from the requirements of l Paragraphs IWV-3421 through 3425. However, the licensee must comply with '

the requirements of Paragraphs IWV-3426 and 3427(a), Analysis of leakage .

p Rates and Corrective Actions.

4.1.4 Excess Flow Check Valves  !

4.1.4.1 Relief Reauest. The licensee has requested relief from the requirements of Section XI, Paragraph IWV-3411, 3521 (quarterly exercising), and IWV-3420 (leak test), for all excess flow check valves, and proposed to perform check valve functional testing in accordance with Brunswick Technical Specifications every eighteen months.

4.1.4.1.1 Licensee's Basis for Reauestina Relief--The subject valves are installed on instrument lines . connected to the reactor coolant 22 4

boundary. Their function is that in the event of an instrument piping line rupture outside containment flow is sensed causing the valves to close.

More frequent testing than currently required by plant Technical Specifications is not warranted for the following reasons:

1. Due to the small diameter of the lines (3/4"), the lines are sized and/or orificed in accordance with Regulatory Guide 1.11 such that in the event of a rupture, off-site doses will be substantially below 10CFR100 guidelines (i.e.,1% of limits assuming no restricting orifice).

In the event of a line break, the maximum break flow rate with a restricting orifice is 29 gpm. If the valve was stuck in the full open position at a 10 psid, the flow rate obtained would be approximately 3.25 gpm. This is well within the normsl reactor coolant makeup (Reactor Core Isolation Cooling system) which has a maximum flow rate of 425 gpm. Thus should the valve not perform its intended function, there are no significant safety consequences.

2. These valves have no safety function during a (Loss of Coolant Accident). They do not normally isolate during this type of accident as they are on the instrument lines which provide information essential to the operator for determining corrective actions during an accidont.

Since instrument lines remain in service during an accident, it is more appropriate to perform a primary containment integrated leak rate test (ILRT) with these lines unisolated as this more accurately reflects the conditions that will exist during a LOCA. This position is stated in NRC standard Review Plan 6.2.6 which states " Leak testing of instrument lines that penetrate containment may be done in conjunction with either the local leak rate tests or the containment integrated leak rate test." Brunswick satisfies this leak testing requirement during the ILRT.

23 1

1

3. The excess flow check valves are normally open during all plant conditions. These valves can only be stroked when flow is sensed across the valve. As there are no test connections on these lines, flow can only be obtained by disconnecting these lines from the instrumentation. This functional testing to verify operability is performed every 18 months as required by plant Technical Specifications. More frequent testing increases the potential for damage to bath the instrument lines and essential instrumentation with no commensurate increase in safety.

Alternate Testino: In lieu of the testing requirements described above, CP&L proposes to perform functional testing to verify operability of the applicable valves every 18 months in accordance with the Brunswick Technical Surveillance Requirement No. 4.6.3.4. Otring this functional test, the valve will be determined to be operable if the following acceptance criteria are satisfied.

1. During a vacuum test, less than a 2-inch loss of vacuum is obtained over a one-minute period.

2. During a leakage test performed in conjunction with a Class 1 system pressure test, a leakage rate of less than 0.5 gpni is obtained.

4.1.4.1.2 Evaluation--These valves are excess flow check valves on instrument sensing lines which penetrate the primary containment building. Their function is to close against excessive flow to perform a containment isolation function. The testing specified in the Brunswick Steam Electric Plant Technical Specifications is a modified leak test which is performed once each 18 months. Performance of valve closure verification on a quarterly or cold shutdown basis is impractical since this would isolate various instruments and could result in loss of control signals to vital instrumentation and subsequent unnecessary initiation of automatic safety systems, etc. The licensee's proposal to leak test these 24 3

e ,_

s j ..

valves once each 18 months utilizing the procedures and acceptance criteria outlined above provides a reasonable alternative to the Code

,requ irement s.  ;

I Based on the determination that the Code requirements are impractical, ,

and that the licensee's proposal provides a reasonable alternative to the l Code requirements, relief should be granted as requested.

4.1.5 Containment Isolation Check valvt1  !

4.1.5.1 Relief Recuest. The licensee has requested relief from the

• exercising frequency requirements of Section XI, Paragraph IWV-3522, for the following containment isolation check valves and proposed to verify their closure capability during Appendix J Type C, leak testing during refueling outages

• Valve identifier Valve Identifier B32 V24 B21-F010A B32 V3' .B21-F010B -

E41 F M E51.F028 E41 F049 B51-F040 4

- TIP NC B51-V88 4.1.5.1.1 Licensee's $ asis for Reduestino Relief--The only way to verify closure is by leak testing during Appendix J Type C, testing at refueling.  :

Alternate Testina: The valve open indication /open position is verified by normal system parameters during operation. The valve shut indication / shut position is verified by 10CFR50 Appendix J, testing during refueling outages.

4.1.5.1.2 Evaluation -Check valves which perform a safety function in both the open and closed position are required to be full stroke exercised to both positions. The licensee has stated that >

25

.._..--....q.--.--._,- .._- _e.-- - . . - -

.n--

r .

i these valves' open indication /open position will be verified utilizing i normal system parameters. NRC's position is that to verify a check >

valve's full; stroke open capability utilizing flow the licensee must pass ,

l and verify, through the valve, the maximum flow rate for which credit is taken in any of their accident analys'es.

These check valves can be verified closed only by performance of leak testing. NRC staff's position is that check valves inside containment  ;

whose closure function can be verified only by leak testing may be granted '

relief to verify their closure position during leak rate testing at refueling outages. The performance of leak testing on these valves each cold shutdown is time consuming and could result in an extension of the down time and would be burdensome to the licensee. The licensee's proposal.to verify these valves' closure during leak testing per  :

Appendix J testing at refueling outages provides a reasonable alternative

. to the Code required frequency, t

Based on the determination that the proposed testing frequency provides a reasonable alternative to the Code requirements and considering  !

the burden on the licensee if the Code' requirements were imposed, relief should be granted as requested. [

4.1.6 Keen Fill Chec'k Valves -

L t

4.1.6.1 Relief Reauest. The licensee has requested relief from the exercising requirements of Section XI Paragraph IWV 3522, for the ,

following keep fill check valves and proposed to verify their closure

capability by check valve sample disassemoly/ inspection every two years.

Yalve Identifier Valve Identifier -

l L Ell-F089 (Unit 1) Ell-F090 (Unit 2) l E21-F030A E21 F0308 I Ell Vl93 E41-V93 26

o I 4.1.6.1.1 Licensee's Basis for Reauestino Relief--These check ,

valves isolate the app,11 cable system from the demineralized water (keepfill) system upon loss of demineralized water or the applicable  ;

system injection. There is no external / remote means to verify the check j valves' position during system operation or an external means to cycle the [

valves while the system is shut down.

There are pressure gauges on the applicable systems and the demineralized system. Therefore, it can be determined that there is l isolation between the two systems. However, all these check valves have another check valve in series with it (sic), therefore, it can not be determined which of the two valves, or both, actually close.

Alternate Testino: Valves will be incorporated in a disassembly program and manually cycled (Ref: V 08). ,

Disassembly grouping characteristics: i Ell-F090 and Ell-Vl93 '

l Type: swing cheik  ;

Size: Tour inch Operating Medium: demineralized water Manufacturer: Anchor E21-F030A, E21-F030B, and E41-V93  ;

Type: piston check t Size: two inch

• Operating Medium: demineralized water Manufacturer: Velan 1

NOTE: The following has been excerpted from the Brunswick IST program.

" PROGRAM REMARKS NO. V-08"

, The check valves included in the check valve disassembly program are grouped according to type, size, operating medium, and manufacturer. The groupings are listed below.

t v.

27

1

- I

~

Group Aeolicable Valves j SDG-1-1 E11 F089 SDG-1-2 E11 F090 l SDG-1-1(2) Ell-V 193 l

SDG-3-1 E21-F030A SDG 3-1 E21 F0308 SDG-3 1 E41 V93 l a

One ch-n valve of each group will be disassembled and manually ]

exercised wsfy two years for the respective unit.

l If any check valve fails, another check valve from the same group shall be tested. If this valve fails, the remaining check valves in the applicable group shall be tested.

4.1.6.1.2 Evaluation--These series check valves function to ,

maintain injection piping filled with water prior to injection. It is f impractical to verify their closed position individually either quarterly or during cold shutdowns since they have no provision for external verification of valve position (position indicators, pipe taps). ,

Installation of instrumentation to verify valve position would involve system redesign and be burdensome to the licensee. However, by verifying  !

that the demineralized water system is isolated from the respective ,

systems, utilizing installed pressure gages, these series valves can be ,

determined operable as a pair.

The licensee has proposed to verify these valves' closure capability by performing a sample disassembly program including a manual exercise of at least one valve every two years for each unit. These valves have been divided into two disassembly groups. However, the licensee's testing proposal conflicts in both method and frequency with the NRC staff position from Generic Letter No. 89-04, Position 2, on check valve sample disassembly / inspection which is as follows:

22 l

l l

+

The sample disassembly and inspection program involves grouping I similar valve's and testing one valve in each group during each refueling outage. The sampling technique requires that each valve in i the group be the same design (manufacturer, size, model number, and '

. materials of construction) and have the same service conditions  ;

including valve orientation. Additionally, at each disassembly the  ;

licensee must verify that the disassembled valve is capable of

]

full-stroking and that the internals of the valve are structurally sound (no loose or corroded parts). Also, if the disassembly is to j verify the full-stroke capability of the valve, the disk should be manually exercised.  !

A different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage, until the entire group has been tested. If the disassembled valve is not capable of being full-stroke exercised or '

there is binding or failure of valve internals, the remaining valves in that group must also be disassembled, inspected, and manually full-stroke exercised during the same outage. Once this is completed, the sequence of disassembly must be repeated unless extension of the '

interval can be justified.

Check valve disassembly / inspection appears to be the only method available to verify the individual full-stroke capability of these valves. Further, the licensee's grouping is consistent with the staff position for these valves. However, the licensee's proposed sampling method is not reasonable. The purpose of grouping like valves in similar service conditions is to ensure that common mode failures are detected and corrective action is taken on all like components if any one exhibits

. evidtnce of degradation. Degradation of one valve in the group could indicate similar degradation of the remaining members of the group and further investigation and corrective actions should be made for all members of the group. The licenseefs proposal does not take action on the group until two consecutive valves fail the sample disassembly / inspection and is, therefore, unacceptable. Also the Staff position states that r

29

l disassembly will be performed every refueling outage whereas the licensee's proposal states that this will be d6ne every two years.

The NRC staff position, concerning these keep fill valves, is that the licensee may verify their operability as a pair, quarterly, and if there is evidence of excessive leakage through these valves then halb valves  !

must be disassembled, inspected, and repaired as necessary. The licensee may test in accordance with this NRC Staff position and need not perform check valve sample disassembly / inspection. However, if the licensee chooses to perform check valve sample disassembly / inspection it must be performed in accordance with the NRC staff position as discussed above in addition to quarterly operational verification of closure of at least one valve of the pair.

It is impractical to test these valves in accordance with the Code requirements. However, limited testing, verifying operability of the pair, is practical and can and should be performed quarterly. The licensee's proposal to perform sample disassembly / inspection as stated does not provide a reasonable alternative to the Code requirements. -

However, relief from the Code requirements should be granted, provided, the licensee verifies valve operability as a pair quarterly and either, (a) upon evidence of excessive degradation performs check valve disassembly, inspection, and repair as necessary, or (b) performs valve sample disassembly / inspection in accordance with the NRC staff position.

These evaluations and recommendations are made giving due consideration to the burden on the licensee if the Code requirements were imposed. '

4.2 Control Rod Drive System 4.2.1 Cateaory B and C Valves l

l 4.2.1.1 Relief Reauest. The licensee has requested relief from the requirements of Section XI, Paragraphs IWV-3412 and 3522, for the ,

following control rod drive hydraulic control unit (137 units per plant) yalves and proposed to verify valve operability during control rod scram testing:

30

Valve Functional Descriotion Cll/C12-CV126 Open to admit scram water to the closing chamber of the rod drive unit. .

^

Cll/Cl2 CV127 Open to allow discharge water to the discharge volume.

Cll/C12-SVll7 Both solenoid valves open to bleed air C11/Cl2-SV118 from the operators on Cll/12-CV126 and CV127 C11/Cl2-138 Shuts to prevent diversion of scram water-from accumulator to cooling water header.

C11/C12-114 Opens to allow discharge water flow to the discharge volume.

. 4.2.1.1.1 Licensee's Basis for Reauestina Relief--There is no accurate means to individually stroke time Cll/Cl2 CV126 and Cll/Cl2-CV127. There is only one indicating light for both valves which illuminates when halb valves are fully open. Also the stroke time for these valves is very short. For solenoid valves Cll/Cl2 SV117 and Cll/Cl2-SVll8, there is no indicating light or external stem to verify stroke / stroke timing. Also, for these valves the stroke time is very short. For check valves C11/Cl2-114 and C11/C12-138, there is no flow indication to verify flow or cessation of flow, respectively.

In order for a control rod to be inserted, the following occurrentes must happen:

1. Solenoid valves Cll/Cl2-SV117 and Cll/Cl2-SV118 open which cause scram valves Cll/Cl2-CV126 and Cll/Cl2-CV127 to open.

2. Check valve C11/C12114 has to open to allow flow to the scram discharge volume.

3. Check valve Cll/Cl2 138 has to close in order to stop insert water from being diverted to thn cooling water header.

31 W

~

o I

.o .

If any of the valves do not operate properly, the control rod would not be able to be inserted or would not inser.t in the minimum time reouired by Technical Specifications. Therefore, the proper operation of each o'f these '

valves is demonstrated during scram testing. During scram testing, each  ;

drive's scram insertion time is measured and a fail-safe actuator test is ,

performed. The Technical Specifications provide a limit for individual CRD scram insertion times to specific values. If a particular CRD's scram insertion time is less than the specified limit, the eteve v:1ves are functioning properly.

Alternate Testina: The frequency of individual scram insertion tests is:

1. 100% of control rod drives following core alterations or after a reactor shutdown greater that 120 days with reactor power equal or less than 40% and

2. 10% of control rods on a rotating basis, at.least once every 120 days of operation, per Technical Specification 4.1.3.2.

4.2.1.1.2 Evaluation -These valves must operate for repid insertion (scram) of control rods and are tested by scram timing the control rods. The licensee will test 10% of the CRDs each 120 days of operation, and 100% each time the core is altered or after a reactor shutdown of greater than 120 days with reactor power equal to or less than 40%.

Technical Specifications specify the minimum time for rod insertion. Should either the scram insert valve, Cll/Cl2-CV126, the cooling water check valve, C11/C12-138, or the scram exhaust valve, C11/C12-CV127, scram discharge check, C11/C12-114, or the associated solenoid valves, Cll/Cl2-SVll7 and C11/C12-SV118, fail to operate in a timely manner the CRDs may not be able to meet the Technical Specification requirements. These valves cannot be exercised without causing the associated control rod to scram and the valves must operate properly in order that the associated control rod meets the scram insertion time limits defined in the Technical Specifications.

32

j s

c -

L ,

The alternate exercising frequency required by Technical Spec,1fications  ;

has been previously approved by the NRC staff to reduce wear on the control l rod drive mechanisms and to reduce the number of rapid reactivity transients '

f .to which the reactor core is exposed. Based on the determination that the L. Code requirements are impractical and that the licensee's proposal provides  !

a reasonable alternative to the Code requirements, relief-should be granted l as requested. .

4.3 Nuclear Steam Supoly System ,

4.3.1 Cateoorv B/C Valves 4.3.1.1 Relief Reouest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3412, for t'e h automatic depressurization system (ADS) valves, B21-F013A thru H, J, K, and L, and proposed to exercise these valves once each 18 months with reactor supplied steam.

4.3.1.1.1 Licensee's Basis for Reouestino Relief--Opening an ADS - '

valve during normal operation would place the plant in a " mini LOCA" >

condition if the ADS valves.were to fail in the open position. The amount ,

of steam injected into the suppression pool could cause a rise in suppression pool temperature beyond the Technical Specification operating limits, it is impractical to measure stroke times for the ADS valves, since the stroke times are on the order of 100mS. Steam flow measurements and/or turbine bypass valves position will verify that the ADS valves have performed their function in less than five seconds. Time "zero" for this  ;

stroke time measurement corresponds to the instant the ADS hand switch is aligned in the "open" position.

Alternate Testina: Each valve will be exercised at least once per 18 months when the reactor is operating at sufficient power to bypass a quantity of steam through the turbine bypass valve (s) equal to or greater 33

. , j than the capacity of an ADS valve. Since the turbine bypass valves respond -

automatically to RPV dome pressure, the actuation of an ADS valve will

- result in rapid closure.of the turbine bypass valves. Conversely, closing the ADS valve will be accommodated by rapid opening of the turbine bypass valves. ' A change in turbine bypass valve position can be ditectly l associated with a certain steam flow rate. This flow rate would be equal to  !

the quantity of steam discharged by the ADS.

No stroke time measurements will be performed.- An abrupt change in turbine bypass valve position or steam line flow (per-Technical Specification 4.5.2.b) within five seconds will be adequate to demonstrate' valve operability. .

4.3.1.1.2 Evaluation--The ADS valves act both as power operated valves in response to a manual or automatic control signal and as safety relief valves. As a result, these valves should be tested to both the Category B and C requirements. Full-stroke exercising these valves quarterly during power operations is impractical as this greatly increases the risk of creating a mini loss-of-coolant accident. NUREG-0626 " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and Near Term Operating License Applications" recommends reduction of challenges to relief valves to lessen the risk of Small Break LOCA (see also NUREG 0737,Section II.K.3.16).

To full-stroke exercise these valves requires reactor steam pressure and is not practical during cold shutdowns when the reactor pressure is low. Accurate stroke times for these valves cannot be obtained since their stroke times are on the order of 100 milliseconds and there is no direct position indication. The licensee's proposal to verify these valves' operability once each 18 months with the reactor at power by passing reactor' ,

steam through the valves and to verify the valve strokes in less than five seconds utilizing turbine bypass valve position'provides an acceptable level l of quality and safety and a reasonable alternative to the Code requirements.  ;

l 34 i

c Based on the. determination that the Code requirements are impractical, that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

.- 4.4 Core Sorav System 4.4.1 Cateoorv A/C Valves 4.4.1.1 Relief Reauest. The licensee has requested relief from the exercising (open) frequency requirements of Section XI, Paragraphs IWV-3412 and 3522, for the core spray injection isolation valves, E21-F006A and F006B, and proposed to exercise these valves during each refueling outage.

4.4.1.1.1 Licensee's Basis for Reauestina Relief--These valves open to allow core spray injection into the reactor vessel.

Testing of these valves requires initiating core spray and injection into the reactor vessel.

l Core spray is a low pressure system, therefore, for system protection the inboard and outboard isolation valves (E21-F004A&B and E21-F005A&B) are interlocked to allow only one valve to open at a time when the reactor vessel's pressure is greater than 410 psi.

During reactor operation, the reactor vessel is at approximately 1000 psi.

Introducing nonpreheated water into the reactor vessel requires the vessel shell temperature to be less than 200 0 F to limit possibility of

' thermal shock, which could cause reactor vessel nozzle cracking. During normal cold shutdown, the reactor vessel shell temperature does not get below 2000F, i

35

l

.' I Core spray takes suction from the suppression pool. Suppression pool water conductivity and impurities are at levels that would have to be removed prior to starting u'p the plant which would affect startup. l l

1 Alternate Testino: Full stroke exercise valves to the open position at ,

each refueling.

1 4.4.1.1.2 Lyaluation--These check valves open to allow low '

pressure core spray to the reactor vessel in an accident. It is impractical to full-stroke exercise these check valves quarterly during plant operations since the core spray system pressure cannot overcome the reactor coolant ,

system pressure to establish flow. Further, in-line motor operated valves are interlocked to prevent operation with reactor system pressure greater than 410 psi.

It is impractical to full-stroke exercise these valves during cold shutdowns because the suction source, suppression pool, is of comparatively low quality and relatively cold with no provision for preheat. Further, the low quality, i.e., salts and other impurities, water would have to be flushed from the system due to water chemistry requirements and could  ;

increase the length of the outage. The licensee's proposal to full-stroke exercise these valves at each refueling outage provides an acceptable level of quality and safety and a reasonable alternative to the Code requirements.

Based on the determination that the Code requirements are impractical, and that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

4.4.1.2 Relief Reauest. The licensee has requested relief from the exercising (closed) frequency requirements of Section XI, Paragraph IWV-3522, for the core spray injection isolation check valves, E21-F006A and F006B, and proposed to exercise these valves and confirm closure during pressure isolation valve testing at refueling outages.

36

< - 1 r

1

. ]

4.4.1.2.1 Licensee's Basis for Reauestina Relief-- )

L

1. Test at power: The RHR and core spray systems are low pressure l systems. The two automatic valves upstream of the check valves )

. (Ell-F015A, B and Ell-F017A, B in RHR; E21-F004A, B and E21-F005A/B in core spray) are interlocked during power operation to maintain one valve closed for overpressurization protection. This precludes opening the check valves at power to verify closure.

2. Testing at cold shutdowns:

a. Core Spray Testing at cold shutdown would require injection of cold water into the vessel causing undesireable thermal cycling of the '

nozzles (ref. VR 09).

b. RHR - The valves have no position indication, thus closure verification must be by a leakage test. Such a test would require opening a 3/4" test connection upstream of the check valve. Using only the static water head of the reactor vessel to close the valve would likely result in the leakage past the check valves (24" RHR, 10" core spray) excceding the capacity of the test connection. Performing a [

leakage test at function pressure differential would entail numerous plant evolutions including mul'tiple loop swaps, significant draining, test pumps, and fill and venting which would significantly impact a nonrefueling outage.

Alternate Testino: Exercise valves and confirm valve closure during pressure isolation valve leak testing at refueling.

4.4.1.2.2 Evaluation--It is impractical to verify closure of .

these valves quarterly during power operation. These valves are in line with valves that are maintained closed by an interlock with plant pressure and pressure differential cannot be observed. It is impractical to verify these valves closed during cold shutdowns since the test connection for these valves is small 3/4" and the static head provided by the water level

~

37

.,a

fk- .

in the vessel may not be. sufficient to firmly backseat these 24" valves.

The only practical method, for confirming closure of these valves is by performing a leak test. This is not practical during cold shutdow.ns since '

it would require system reconfiguration, test pump hookup, system draining and venting, etc. and could result in delay in returning to power operation. The licensee's proposal to verify the closure capability of these v&lves by leak testing during refueling outages provides adequate assurance of operational readiness and a reasonable alternative to the Code requirements.

I Based on the determination that the Code requirements are impractical,  :

and that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested, l 4.5 Residual Heat Removal System l

4.5.1 Cateaory A/C Valves 4.5.1.1 Relief Reauest. The licensee has requested relief from the exercising (closed) frequency requirements of Section XI, Paragraph IWV-3522, for the residual heat removal injection isolation check valves, '

Ell-F050A and F0508, and. proposed to exercise these valves during pressure isolation valve testing at refueling outages.

4.5.1.1.1 Licensee's Basis for Reauestina Rel'ief--

1. Test at power: The RHR and core spray systems are low pressure systems. The two automatic valves upstream of the check valves (Ell-F015A,-B and E11-F017A, B in RHR; E21-F004A, 8 and E21-F005A/B in core spray) are interlocked during power operation to maintain one valve closed -

for overpressurization protection. This precludes opening the check valves at power to verify closure.

38

= w - e

t

2. Testin'g at cold shutdowns:

a. Core spray - Testing kt cold shutdown would require injection of cold water into the vessel causing undesireable thermal cycling of the nozzles (ref. VR-09),

b. RHR The valves have no position indication, thus clocure verification must be by a leakage test. Such a test would require opening a 3/4" test connection upstream of the check valve. Using only the static water head of the reactor vessel to close the valve would likely result in the leakage past the check valves (24" RHR,10" core spray) exceeding the capacity of the test connection. Performing a-leakage test at _ function pressure differential would entail numerous plant evolutions including multiple loop swaps, significant draining, test pumps, and fill and venting which would significantly impact a nonrefueling outage. ,

Alternate Testina: Exercise valves and confirm valve closure during pressure isolation valve leak testing at refueling.

4.5.1.1.2 Evaluation--These check valves open to allow low pressure core spray to the reactor vessel in an accident. It is impractical to full-stroke exercise these check valves quarterly during plant operations since the core spray system pressure cannot overcome the reactor coolant system pressure to establish flow. Further, in-line motor operated valves are interlocked to prevent operation with reactor system pressure greater than 410 psi.

It is impractical to verify these valves closed during cold shutdowns since the test connection for these valves is small 3/4" and the static head provided by the water level in the vessel may not be sufficient to firmly backseat these 10" valves. The only practical method for confirming closure of these valves is by performing a leak test. This is not practical during cold shutdowns since it would require system reconfiguration, test pump hookup, system draining and venting, etc. and could result in delay in 39

returning to power operation. The licensee's proposal to verify the closure ,

capability of these valves by leak testing during refueling outages provides adequate assurance of operational readiness and a reasonable alternative to I the Code requirements.

Based on the determination that the Code requirements are impractical, I and that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

4.6 Diesel Generatina System j l

1 4.6.1 Cateaory B Valves j l

)

4.6.1.1 Relief Raouest. The licensee has requested relief from l quarterly full-stroke exercising and stroke timing the following diesel generator air start valves in accordance with the requirements of Section XI, Paragraph IWV-3412, and proposed to verify operability based on air supply header pressure readings on a quarterly basis:

Valve Valve l

)

1 2 DSA SV6552-1 2-DSA-SV6553-1 2-DSA SV6552-2 2 DSA-SV6553-2 l 2-DSA-SV6552-3 2-DSA-SV6553-3 2-DSA SV6552 4 2-DSA SV6553 4 l 2-DSA SV6554-1 2-DSA SV6555-1 2-DSA-SV6554-2 2 DSA-SV6555 2 2-DSA-SV6554-3 2-DSA-SV6555-3 2-DSA-SV6554-4 2-DSA.SV6555-4 NOTE: These valves are all prefixed with 2 (i.e., 2 DSA-SV6553-1), I however, are applicable to both Units 1 and 2.

4.6.1.1.1 Licensee's Basis for Reauestino Relief- Since these solenoid valves do not have position indicators, no reliable method is ,

available for timing the valve stroke. Decreasing air supply header pressure obsPved on each starting air header's pressure instrument & tion is  ;

used to independently verify that each valve strokes to the open position.

40

=--.mAm. 4.- --.__2 .__e w .. o g,cm - ,, qw--e..* f r* M*" * * - - W*** + ~ * " " ' "

• T iT89'**** e J m =

pr--- V Alternate Testina: Full-stroke exercise valves to the open position t

< quarterly.

4.6.1.1.2 Evaluation--These solenoid valves supply pressurized air to start the emergency diesels. It is ' impractical to obtain accurate [

stroke time measurements for these enclosed solenoid valves since there is l no provision for stroke timing (i.e., position indicating lights, external I operators,etc.). The failure of one of these valves to open in a timely manner could be indicated by an increase in the diesel generator start time or a difference in starting air header pressures. Installation of position indicators on these valves for stroke timing purposes would be burdensome to the licensee. The licensee's proposal to verify the full-stroke capability of these valves quarterly, by observing the starting air headers' pressure provides an acceptable level of quality or safety a reasonable alternative to the Code requirements' .

Based on the determination that the Code requirements are impractical, -

that the licensee's proposal provides a reasonable alternative to the Code requirements, and giving due consideration to the burden imposed on the l

licensee if the Code requirements were imposed, relief should be granted as requested. -

4.6.2 Cateaory C Valves ,

4.6.2.1 Relief Reauest. The licensee has requested relief from the exercising frequency and method requirements of Section XI, Paragraph IWV-3522, for the following diesel generator starting air (jet assist) check valves and proposed to verify valve operability by performing check valve disassembly / inspection and manual cycling on all of these valves every 18 months.

Valve Valve DSA-V141 DSA-V149 DSA-V142 DSA-VISO DSA V145 DSA-V153 DSA V146 DSA-V154 41 w - - - - -- - - - - _ _ _ _ _ _ _

t

+

a 4.6.2.1.1 Licensee's Basis for Reauestina Relief--There is no means to verify valve position during system operation.nor is there an t external means to manually cycle these valves and no test / vent connection to verify valve closurs. These valves are presently disassembled every 18 months in accordance with BSEP T'echnical Specification 4.8.1.1.2.d.1. i Alternate Testine: Disassemble and manually cycle valves every 18 months. l t

4.6.2.1.2 Evaluation--These check valves open to admit air to the ,

diesel generator jet assist line. The closure position of these valves is important for conservation of system function upon loss of one of the starting air headers. These jet assist check valves have no provision (test taps, external position indication, etc.) for the verification of full-stroke capability. Further, significant degradation or failure of l these valves should be evidenced by increased diesel generator starting i times during periodic diesel generator operability testing. The licensee's ,

L proposal to verify these valves' closure capability by performing valve disassembly and manual cycling of the valve disk every eighteen months i provides an acceptable demonstration of operational readiness and provides a i

! reasonable alternative to the Code requirements.

T l Based on the determination.that the Code requirements are impractical and that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

4.6.2.2 Relief Reauest. The licensee has requested relief from quarterly full-stroke exercising the diesel generator starting air compressor discharge check valves, DSA-V21, V33, V51, V63, V81, V93, V111, and V123, in accordance with Section XI, Paragraph IWV-3522, and proposed to disassemble and manually cycle these valves every 18 months.

4.6.2.2.1 Licensee's Basis for Reauestina Relief--There is no external / remote means to verify valve position during system operation nor is there an external means to manual.ly cycle these valves. There are no 42

, _ . _-' - _ m ____ ._ e_ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _

O i -

l

~

, existing vent paths upstream to perform a reverse flow test. These valves ,

are presently disassembled every 18 months in accordance with BSEP Technical l Specification 4.8.1.1.2.d.l. I Alternate Testina: Disassemble and manually cycle valves every 18 months.  !

4.6.2.2.2 Evaluation--These compressor discharge check valves for l the emergency diesel generators have no provision (test taps, external position indication, etc.) for the verification of full-stroke capability.

The licensee's proposal to verify these valves' closure capability by j performing valve disassembly and manual cycling of the valve disk every eighteen months provides an acceptable demonstration of operational .

readiness and provides a reasonable alternative to the Code requirements. -

Based on the determination that the Code requirements are impractical j and that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

4.7 Standby Liouid Control System

! . 4.7.1 Ci:teaory A/C Vr1ves l

l 4.7.1.1 Relief Reauest. The licensee has requested relief from the exercising frequency requirements of Section XI, Paragraph 3522, for the l

standby liquid control injection check valves, C41-F006 and F007, and proposed to verify the full-stroke (open) capability of these valves utilizing flow at least once e'ach 18 months and to verify the closure capability of thase valves during the performance of Appendix J, Type C, testing at refueling.

4.7.1.1.1 Licensee's Basis for Reauestino Relief--Forward flow verification can only be performed by firing one of the squib valves and injecting water using the standby liquid control (SLC) pumps into the Reactor Coolant System. The only way to verify reverse flow closure is by '

leak testing during Appendix J, Type C testing.

i l

43 l

..- . n

-..- y. , _ _ . . . - _ .

-- .-- ... =._.-

o .

Alternate Testino: forward flow verification will be performed in' >

conjunction with the firing of one squib valve and injection into the Reactor Coolant System at least once every 18 months per plant Technical .

l Specification 4.1.5(c). Reverse flow testing will be performed in l conjunction with Appendix J, Type C test at refueling.

4.7.1.1.2 Evaluation--These check valves are in the common lir.e i to the nuclear boiler, downstream from the explosively actuated squib [

valves. It is impractical .to full-stroke exercise these valves open with flow, either quarterly during operations or at _ cold shutdown, since this requires the firing of at least one squib valve (which destroys the valve) and pumping highly borated SLC system water into the reactor system.

Further,. full-stroke exercising these valves during cold shutdowns would be burdensome to the licensee since this testing could result in an extension .

of the cold shutdown. .

The licensee's proposal to full-stroke exercise these valves open at least once each 18 months by firing one of the squib valves and injecting into the reactor coolant system,provides an acceptable level of quality and safety and a reasonable alternative to the Code requirements. The only method available to verify the closure capability of these valves is leak testing. The licensee's proposal to verify these valves' closure capability on a refueling outage frequency provides a reasonable alternative to the Code requirements.

Based on the determination that the Code requirements are impractical, that the licensee's proposed testing provides a reasonable alternative to the Code requirements, and giving due consideration to the burden on the licensee if the Code requirements were imposed, relief should be granted as requested.

4.7.2 Cateoory C Valves >

4.7.2.1 Relief Reouest. The licensee has requested relief from the i exercising frequency requirements of Section XI, Paragraph 3522, for the 44

~

standby liquid control puenp discharge check valves, C41-F033A and F0338 (both Unit 2 only), and proposed to verify their full stroke open capability during refueling outage pump testing and ve'rify their closed position utilizing test connections that will be installed in early 1988.

4.7.2.1.1 Licensee's Basis for Reauestina Relief -There is no external / remote indication to verify valve position during system operation or no external means to manually cycle the valves. There is no

~ flow instrumentation to verify adequate flow through these valves and no vent / test connections, upstream the valves (sic), to verify valve closure.

HQlE: Flow instrumentation and test connections will be installed during the next refueling outage, scheduled to end May 20, 1988, which will eliminate the need for this relief request.

Alternate Testina: Full-stroke exercise valves to the open position each refueling during pump testing (reference Relief Request PR-03).

4.7.2.1.2 Evaluation These standby liquid control (SLC) pump discharge check valves open to allow system flow and shut to prevent loss of fluid through a failed open discharge relief valve on one pump. There

! are no test connections, pressure gages, or other provisions for verification of these valves' closed position during quarterly SLC pump testing. Further, there is no installed flow rate meter presently installed in the pump test circuit for verifying the full stroke open capability of these valves.

The licensee has proposed to install the flowrate instrumentation and test connections necessary to allow testing these valves to both positions and expects tiiese modifications to be completed during the refueling outage scheduled to be completed in May 1988. At the time of this writing these modifications should be complete. This should allow the licensee to meet the Code requirements for testing these valves and, therefore, relief from the Gode requirements should not be required and need not be granted.

45

Based on the determination that system modifications should be completed that will allow the licensee to test these valves in accordance with the Code requirements, relief from the' Code requirements should not ,

be necessary and should not be granted:

4.8 Service Water System 4.8.1 Cateoory B Valves 4.8.1.1 Relief Raouest. .The licensee has requested relief from quarterly full-stroke exercising of the residual heat removal service water booster pumps' motor cooler inlet valves, SW V136,137,138, and 139, in accordance with Section XI, Paragraph IWV 3412, and proposed to visually observe valve stem movement to verify valve stroke quarterly.

4.8.1.1.1 Licensee's Basis for Reouestina Relief--These valves

'do not have position indicators. When the respective RHR SW pump starts, the service water inlet valve opens to establish flow through the motor cooler. No accurate method for timing the valve stroke is available.

Visual observation of the valve stem movement is used to verify that the valves full stroke to the open position.

Alternate Testina: Full stroke exercise valves to the open pnsition quarterly.

4.8.1.1.2 Evaluation--These valves are in the supply 1.ne to the residual heat removal pumps' motor cooler. These valves have no position indicators installed and it is impractical to accurately stroke time these valves. To obtain accurate stroke time measurements would require system redesign and would be burdensome to the licensee. The licensee's proposal to verify by visual observation of the valve's stem that the valve moves to the open position on a quarterly basis and not perform stroke timing provides a reasonable alternative to the Code requirements. However, some

, acceptance criteria must be developed and utilized so that when necessary the valves in question will be declared inoperable and corrective action taken in accordance with the requirements of IWV-3417(b). This acceptance

. 46

-. - ~ . . . . - -.

.4 criteria need not be included with the IST program but must be part of the documentation that allows acceptance of the testing performed.

Based on the determination that the Code requirements are impractical, l that the licensee's proposal (with stipulations) provides a reasonable alternative to the Code requirements, and giving due consideration to the l burden on the licensee if the Code requirements were imposed, relief j should be granted, provided, the licensee establishes and implements reasonable acceptance criteria for verification of these valves' operability and if excessive valve degradation is indicated the valve is i declared inoperable and corrective action is taken in accordance with the requirements of IWV-3417(b).

4.8.1.2 Relief Reauest. The licensee has requested relief from the quarterly full-stroke exercising and timing of the residual heat removal L heat exchanger outlet flow control valves, Ell-F068A and F0688 (both  ;

Unit 2), in accordance with Section XI, Paragraph IWV-3412, and proposed to , install system modifications during the Unit 2 outage scheduled to end ,

in May 1987(sic).

l

+

l 4.8.1.2.1 Licensee's Basis for Reauestina Relief--E11-F068A (Unit 2) and Ell-F0688 (Unit 2) are interlocked with the service water booster pumps. To cycle these valves leads are required to be lifted.

HQII: A keylock switch will be installed during the next Unit 2 refueling outage, scheduled to end May 20, 1987, which will eliminate the need for this relief request.

Alternate Testina: None(referenceNoteabove).

4.8.1.2.1 Evaluation- With these valves interlocked with the service water booster pumps it was impractical to stroke time test them without lifting leads. However, the licensee proposed to install system modifications that will allow the testing of these valyes and has 47

stated that this modification should be installed during the refueling outage scheduled to end May 1987 (the reviewer suspects that this is a  ;

typographical error and should actually be 1988). These system  ;

modifications will allow testing these valves as required by the Code and should have been completed at the time of this writing. Therefore, since the licensee should be able to comply with the Code requirements, relief ,

from tne Cods requirements should not be necessary and need not be l granted. ,

i Based on the determination that system modifications should be ,

completed that will allow the licensee to test these valves in accordance with the Code requirements, relief from the Code requirements should not be necessary and should not be granted.

4.8.2 Cateoory C Valves 4.8.2.1 Relief Reauest. The licensee has requested relief from the >

exercising (open) frequency and method requirements of Section XI, Paragraph IWV-3522, for the suction check valves for the service water lubricating pumps, SW-V201, 204, and 205, and proposed to part-stroke exercise these valves to the open position quarter 1'y and verify their l full-stroke capability by sample disassembly / inspection every two years.

4.8.2.1.1 Licensee's Basis for Reauestina Relief-'The service ,

L water lube water pumps have four independent suction flow paths, each one containing check valves, three of which are listed above (SW-V201, 204, and 205).

l In Unit 1 there are no isolation valves in these flow paths to isolate three of the four flow paths to verify the nonisolated path is ,

unobstructed, therefore, verifying the applicable valve opens.

Neither unit's Service Water Lube Water System pumps have any flow instrumentation; therefore, the check valve can be verified only to .

partially open.

48

a . A f . ,

l 3

o  ;

Alternate Testina:J In Unit 2 the valves will be partial-stroke exercised quarterly. For both Units, the valves will be incorporated in a  !

sample disassembly program and manually cycled upon disassembly (Ref: l V-08) until the Service Water Lube Water pump self lubrication f

, modification is complete and the Lube Water pumps. and Suction Check valves i are removed.

Disassembly grouping characteristics: l Type: wafer check Size: 4 inch Operating medium: saltwater ,

Manufacturer: Techno NOTE: The following has been excerpted from the Brunswick IST program

" PROGRAM REMARKS NO. V-08" - -

l The check valves included in the check valve disassembly progr~am are. I grouped according to type, size, operating medium, and manufacturer. The i groupings are listed below.

r Group Anolicable Valves ,

p

! SDG-5-1(2 1(2)-SW-V200 1(2)-SW V201 SDG-5-1(2 1(2)-SWV202 1(2)-SW-V203 SDG-5-1(2 1(2)-SW-V204 1(2)-SW-V205 i

j One check valve of each group will be disassembled and manually i exercised every two years for the respective unit. .

If any check valve fails, another check valve from the same group shall be tested. If- this valves fails, the remaining check valves in the

[ applicable group shall be tested.

I 4.8.2.1.2 Evaluation--Valves SW-V201, 204, and 205 are pump l suction checks in the service water pump lubricating water system. There is no provision for position indication for these valves and installation of the instrumentation necessary to make this observation would require significant system redesign and be burdensome to the licensee. Also, 49

e these valves cannot be verified to full stroke open quarterly utilizing l flow during operations or cold shutdowns since there is no installed flow '

rate instrumentation. A check valve sample disassembly / inspection program

{

could provide a reasonable alternative to the Code requirements (see NRC staff position on check valve sample disassembly / inspection discussed in Section 4.1.6.1.2 of this report).  !

i The licensee has proposed to verify these valves' full-stroke open capability by performing a check valve sample disast,embly program. Every I two years, one valve of the group will be disassembled. If the tested valve fails another valve from the same group will be disassembled; if the I

second valve fails all valves of the group will be tested. Further, the licensee has included in this sample disassembly group a total of six valves.

The licensee's proposal to include six valves in this group is unacceptable for the following reasons: If only one valve was ,

l disassembled each two years then each valve's test frequency could be I extended from quarterly as recommended by the Code to once each 12 years.

And, the service conditions of these six valves are significantly ,

different (e.g., a valve on a pump discharge sees service significantly l

different than that seen by a pump suction). Further, the licensee's ,

proposed sampling method is' not reasonable (see discussion on sampling method in Section 4.1.6.1.2 of this report).

l Testing these valves quarterly in accordance with the Code l- requirements is impractical, however, the licenset's proposal (to p'erform sample disassembly / inspection) does not provide a reasonable alternative O the Code requirements, as discussed above. Relief from the Code requirements should be granted provided the licensee performs valve sample disassembly / inspection on the three groupings identified below in l accordance with the NRC staff's position (see Section 4.1.6.1.2 of this report). These evaluations and recommendations are made giving due consideration to the burden on the licensee if the Code requirements were imposed.

50 -

1 .

Groun Apolicable Valves Group 1 Sk'-V200 Group 1 SW V201 Group 2 SW-V202 Group 2 SW-V203 Group 3 SW-V204 Group 3 SW V205 4.8.2.2 Rgljef Reaueil. The licensee has requested relief from the exercising (closed) frequency and method requirements of Section XI,

. Paragraph IWV 3522, for the service water system nuclear header to conventional header isolation check valve, SW-V200, and proposed to verify its full-stroke capability by a sample disassembly / inspection program every two years.

4.8.2.2.1 Licensee's Basis for Recuestina Relief There is no means within the system to isolate this valve and perform a reverse flow (exercise valve to the closed position) test. Adequate / proper testing requires terminating all pumps on the Service Water conventional header, pressurizing the Service Water nuclear header, and observing the pressure in the conventional header.

The probability of obtaining accurate test results is unlikely and actual. check valve operability' inclusive d'ue in part to the following:

o 1. The SW 200 is a 4" wafer check valve. The conventional header l could be out of service for an extended period of time waiting for a verifiable increase on the 30" header.

l

2. All conventional pumps operating on the nuclear header would be required to have their header crosstie valves to be in the closed position. These 20" butterfly valves are not designed to be seal tight. Leakage past valves would contribute to erroneous test -

results.

3. Additional contingent conventional header inleakage points:

a. 30" conventional header cross-tie between units to TBCCW.

l 51

r e p

b. 10" conventional header cross-tie between units to i chlorinator system.

c. 3" conventional header cross-tie between units. These valves are also butterfly-type and are not designed to completely seal tight.

Alternate Testina: This valve will be incorporated in a disassembly f program and manually cycled upon disassembly (Ref: V-08) until completion oftheServiceWaterLubeWatermodifications(anticipatedin1990). l l

Disassembly grouping characteristics:

Type: wafer check Size: 4 inch ,

Operating medium: saltwater  !

Manufacturer: Techno NOTE: See excerpt, " PROGRAM REMARKS NO. V-08" from the Brunswick IST  !

. program, concerning these valves in Section 4.8.2.1.1 of this report, t.

4.8.2.2.2 Evaluation- Valve SW 200 is the cross connect check valve between the conventional and nuclear service water headers. There is no direct position indication for this valve and verification of this ,

valve using installed instrumentation and monitoring system parameters  ;

requires depressurization of the conventional header and the per formance of a type of leak test. This is a complex test and the results may not ,

provide a positive indication of the condition of this valve.

A practical method of testing that will verify the full-stroke closed  ;

capability of this valve would be disassembly / inspection and manual full-stroke of the disk. The licensee has proposed to perform a sample disassembly / inspection of this valve and grouped it with five other , ,

similar valves. A check valve sample disassembly / inspection program performed each refueling outage could provide a reasonable alternative to

the Code requirements (see NRC staff position on check valve sample disassembly / inspection discussed in Section 4.1.6.1.2 of this report).

52 1

f.

x ,

s t

q .

The licensee has. proposed to verify this valve's full-stroke closed

~

capability by performin'g a check valve sample disassembly program. Every  :

two years,;one valve of.the group will' be disassembled. If the tested ,

, valve-failsf another valve from the same group will be disassembled; if the .

second valve' fails all valves of the group will be tested. Further, the

-licensee has included in this sample disassembly group a total of six valves.

The licensee's proposal to include six valves in this group is-unacceptable for the following reasons: If only one valve was disassembled each two years then each valve's test frequency could be extended from quarterly as recommended by the Code to once each 12 years.

. And, the service conditions of these six valves are considerably

, dissimilar (e.g., a valve on a pump discharge sees service different than that seen by a pump = suction). Further, the licensee's proposed sampling '

method is not. reasonable (see discussion on' sampling method in Section 4.1.6.1.2 of this report).

Testing this valve quarterly in accordance with the. Code requirements

.is. impractical, however, the licensee's proposal (to perform sample -

.disassemtly/ inspection) does not provide a reasonable alternative to the Code requirements, as discussed above. Relief from the Code requirements should be granted provided the licensee performs valve sample disassembly / inspection in accordance with the NRC staff's position (see-Section 4.1.6.1.2 of this report) on this val >c and groups this valve with

.. valve SW-V201, as identified below, which sees similar service conditions (see also grouping in Section 4.8.2.1.2 of this report). These evaluations and recommendations are made giving due consideration to the '

burden on the licensee if the Code requirc;nents were imposed.

Group Acolicable Valves Group 1 SW-V200

' Group 1 SW-V201 53

t L  :

4.8.2.3 Relief Reauest. The licensee has requested relief from the .

exercising frequency and method requirements of Section XI, Paragraph IWV-3522, for the service water lubricating water system checks, SW-V202 and 203, and proposed to verify their full-stroke capability by a sample

. disassembly / inspection program every two years.

4.8.2.3.1 Licensee's Basis for Reauestina Relief--There are no i p

test connections and/or pressure instrumentation on the backside of these valves to verify closure. Neither is there pump flow instrumentation to verify one check valve full-stroke exercises the open position and the other to the closed position, s Alternate Testina: Partial stroke the valves to the open position  ;

- quarterly. Incorporate the valves in a disassembly program and manually cycle upon disassembly (Ref: V-08) until the Service Water pump self lubrication modification is complete and the lube water pumps and  ;

discharge check valves are removed.

Disassembly grouping characteristics:

Type: wafer check Size: - 4 inch Operating medium: saltwater Manufacturer: Techno NOTE: See excerpt, " PROGRAM REMARKS NO. V-08" from the Brunswick IST program, concerning these valves in Section 4.8.2.1.1 of this report.

4.8.2.3.2 Evaluation--Valves SW-V202 and 203 open to allow lubricating water flow to the service water pumps and close to prevent diversion of flow to a ruptured supply line or through a failed pump.

There is no direct position indication for these valves and there are no flow instruments or pressure taps in the system that would facilitate verification of full-stroke capability in either direction.

The only practical method of testing that will verify the full-stroke

exercise capability of these valves would be disassembly / inspection and 54 a

F. .

v >.

manual full-stroke of the disks. The licensee'has proposed to perform a

sample disassembly / inspection of these valves and grouped them with four l other similar valves. A check valve sample disassembly / inspection program ,

could provide a reasonable alternative to the Code requirements (see NRC staff position on check valve sample disassembly / inspection discussed in Section 4.1.6.1.2 of this report),

t The licensee has proposed to verify this valve's full-stroke closed capability by performwg a check valve sample disassembly program. Every two years, one valve of the group will be disassembled. If the testea valve fails another valve tTom the same group will be disassembled; if the second valve fails all valves of the group will be tested. Further, the licensee has included in this scmple disassembly group a total of six valves.

The licensee's proposal to include-cix valves in this group.is unacceptable Nr two reasons: First, if o.'ly one valve is disassembled each two years then each valve's test frequer.*y could be extended from quarterly as recommended by the Code to once each 12 years. Secondly; the service conditions of these six valves are significantly different (a valve on a pump discharge sees service sicnificantly different than that seen by a pump suction). Further, the licensee's proposed sampling method is not reasonable (see discussion on sampling method in Section 4.1.6.1.2 of this report).

Testing these valves quarterly in accordance with the Code requirements is impractical, however, the licensee's proposal (to perform sample disassembly / inspection) does not provide a reasonable alternative to the Code requirements, as discussed above. Relief from the Code requirements should be granted provided the licensee performs valve sample disassembly / inspection in accordance with the NRC staff's position (see

-Section 4.1.6.1.2 of this report) on a group containing only valves, SW-V202 and 203, as identified below (see also valve grouping in Section

~4.8.2.1.2 of this report). These evaluations and recommendations are made 55

, giving due consideration to the burden on the,-licensee if the Code

' requirements were imposed.

Group- , Aeolicable Valves Group 2 SW-V202 Group:2 SW-V203 4.8.'2.4 Relief Reauest. The licensee has requested relief from the exercise frequency and method requirements of Section XI, Paragraph IWV 3522,- for the service water nuclear header, Unit I and 2, cross connect / isolation check valves, SW-V272, V273, V274,and 275, and proposed to verify their full-stroke capability by a sample disassembly / inspection program every two years.

4.8.2.4.1 Licensee's Basis for Reauestina Relief--There is no means within the system to isolate these valves and perform a reverse flow (exercise valves to closed position) test. The only means to test these valves in the system is to terminate all pumps on one units service water nuclear header, pressurize the other unit's service water nuclear header, and observe the pressure in the inoperative (terminated pumps) service water nuclear header.

The probability of obtaining accurate test results is unlikely and actual check valve operability inconclusive due to possible erroneous readings from nuclear header inleakage paths past butterfly isolation valves on the conventional to nuclear header cross-tie piping and unit to unit nuclear header cross-tie piping. In addition, leakage past these same type valves from nuclear header to lube water pump suction will decrease pressure in the nuclear header and create possible false readings.

To see an increase in nuclear header (30") pressure past the check ,

valves (6"), even if stable conditions could be ensured, may require the nuclear header to remain inoperable for an extended period of time. This test wIll not be able to determine which of the four valves is failing to go to the closed position.

56 h- _--m__.:.____2.-.-a._m__m.a: -.-.__ -_,._--_u. ..~__m - __ _ - _ . _

t g,  :]

ge There is no external / remote indication to verify valve position during

- system operation or no external means to manually cycle the valves. The '

valves are verified to open during diesel generator _ operation but due to lack of. flow instrumentation the valves can not be verified to go to the

. -full-open position. -

l-Alternate Testina: Partial stroke exercise valves to the open position quarterly and incorporate the valves in a disassembly program and

= manually cycled upon disassembly (Ref: V-08).

Disassembly grouping characteristics:

Type: wafer check Size: six inch Operating Medium: saltwater Manufacturer: Techno l

- NOTE: The following has been excerpted from the Brunswick IST program l

" PROGRAM REMARKS NO. V-08" The check valves included in the check valve disassembly program are L

grouped according to type, size, operating medium, and manufacturer. The I

groupings are listed below.

Group ADolicable Valves i

SDG-4-1(2) SW-V272 SDG-4-1(2) SW-V273

. SDG-4-1(2) SW-V274 l SDG-4-1(2) SW-V275 One check valve of each group will be disassembled and manually e'xercised every two years for the respective unit.

If any check valve fails, another check valve from the same group  !

shall be tested. If this valves fails, the remaining check valves in the

! applicable group shall be tested.

l l

57 l

l l l

l.

l 1 1

[D .  ;

l . ,

~

4.8.2.4.2 Evaluation--These are check valves on the redundant service water cooling water supply lines _to the diesel generators. There f is no direct position indication for these valves and there are no flow ,

instruments. To test closure of these valves requires one unit's header to be depressurized with the other at pressure and would not provide'a very good indication of which valve if any was degrading. There is no  ;

flow instrumentation in the line to verify that these valves are full-stroking in the open position. It would be burdensome for the licensee to install the instrumentation necessary to perform this test.

A practical method of testing that will verify the full-stroke exercise capability of these valves would be disassembly / inspection and manual full-stroke of the disks. The licensee has proposed to perform a sample disassembly / inspection of 'chese valves and placed all four of these i valves in one group. A check valve sample disassembly / inspection program performed at each refueling outage could provide a reasonable alternative to the Code requirements (see NRC staff position on check valve sample

- disassembly / inspection discussed in Section 4.1.6.1.2 of this report).

The licensee has proposed to verify this valve's closure capability by performing a check valve sample disassembly program. Every two years, one valve of the group will be disassembled. If the tested valve fails another valve from the same group will be disassembled; if the second valve fails all valves of the group will be tested. Further, the licensee has included in this sample disassembly group a total of four valves.

The licensee's proposal to include these four valves in one group is acceptable because these valves meet the NRC staff's criteria for type, service, size, etc. However, the licensee's proposed sampling method is not reasonable (see discussion on sampling method in Section 4.1.6.1.2 of this report). l

\

Testing these valves quarterly in accordance with the Code I requirements is impractical, however, the licensee's proposal (to perform 58

I ,,

i :*-

sample disassembly / inspection) does not provide a reasonable alternative to the Code requirements, as'discusse'd above. Relief from the Code

' requirements should be_ granted provided the licensee performs valve sample disassembly / inspection _each refueling outage in accordance with the NRC staff's position (see Section 4.1.6.1.2 of_this report). These evaluations and _ recommendations are made giving due consideration to the burden on the licensee if the Code requirements were imposed.

4.9 Hiah Pressure Coolant In.iection System 4.9.1 Cateoory C Valves 4.9.1.1 Relief-Reauest. The licensee has requested relief from the exercising (open) frequency and method requirements of Section XI, Paragraph IWV-3522,. for the high pressure coolant injection (HPCI) and residual-heat removal (RHR) minimum flow check valves, E41-F046, E11-F046A, F046B, F046C, and F0460, and proposed to perform check valve sample disassembly / inspection every two years.

4.9.1.1.1 Licensee's Basis for Reauestina Relief--The minimum flow check valves are to open on pump starts and during pump operation while discharge valve is closed for pump protection. There are no external / remote means to verify the check valves position during system operation or an external means to cycle the valves while the system is shut down. During system operation, the check valves can be audibly  :

-verified to partially open; however, due to inadequate instrumentation, the flow through the check valves can not be quantified, therefore, the check valves can not be verified to go to full open. ,

alf.ernate Testino: Partial stroke exercise check valves to the open positiun quarterly and incorporate valves in a disassembl.y program and  :

manually cycle upon disassembly (Ref: V-08).

59 1

{

l l

L Grouping characteristics: ,

.. Type: swing Size: RHR 3", HPCI 4" Operating Medium:~ water Manufacturer: Anchor NOTE: The following has been excerpted from the Brunswick IST program

" PROGRAM REMARKS NO. V-08" The check valves included in the check valve disassembly program are -

grouped according to type, size, operating medium, and manufacturer. The groupings are listed below.

Groun Aeolicable Valves SDG-6-1(2) 1(2)-E11-F046A 1(2)-E11-F046B SDG-6-1(2) 1(2)-E11-F046C 1(2)-E11-F046D SDG-6-1(2) 1(2)-E41-F046 One check valve of each group will be disassembled and manually exercised every two years for the respective unit.

If any check valve fails, another check valve from the same group shall be tested. If this valves fails, the remaining check valves in the applicable group shall be tested.

4.9.1.1.2 Evaluation--These check valves must open to allow cooling water flow through the RHR and HPCI pumps when they operate against a closed discharge valve or high pressure. There is no direct position indication for verification of these valves' closed position.

Further, there is no flow instrumentation in the line that can be used to verify that these valves are being full-stroke. exercised in the open position. It would be burdensome for the licensee to install the instrumentation necessary to perform this test.

60 .

r '.

O --

t. ,

.,4 A practical method of testing that will verify the full-stroke exercise capability of these valves would be disassembly / inspection and manual full . stroke of the disks. A check valve sample

-disassembly / inspection program could provide a reasonable alternative to the Code requirements (see NRC staff position on check valve sample disassembly / inspection discussed in Section 4.1.6.1.2 of this report).

t The licensee has proposed to verify this valve's closure capability by performing a check valve sample disassembly program. Every two years, one valve of the group will be disassembled. If the tested valve fails

. another. valve from the same group will be disassembled; if the second valve fails all valves.of the group will be tested. Further, the licensee has included in this sample disassembly group a total of five valves. ,

The licensee's proposal to include these five valves in one group is unacceptable since valve E41-F046 differs from the others in size.

Further, the licensee's proposed sampling method is not reasonable (see discussion on sampling method in Section 4.1.6.1.2 of this report). Also, audible ' indication of part-stroke is not reliable since in many of the failure modes for check valves a clank'can be heard even though the disk may have changed position relative to the hinge or seat.

Testing these valves quarterly in accordance with the Code requirements is impractical, however, the licensee's proposal (to perform sample disassembly / inspection) does not provide a reasonable alternative to the Code requirements, as discussed above. Relief from the Code requirements should be granted provided the licensee performs valve sample disassembly / inspection each refueling outage in accordance with the NRC L staff's position and divides these valves into two groups one containing E11-F046A, F046B, F046C, and F0460, the other containing only E11-F046.

These evaluations and recommendations are made giving due consideration to the burden on the licensee if the Code requirements were imposed.

L 61

.- 7 1; , .

4.9.1.2' Relief Reauest.. The licensee has requested relief from the- -

exercising (closed). frequency.and method requirements of Section XI,.

Paragraph' IWV-3522, for the high pressure coolant injection suction from ,

t'he condensate storage tank check valve, E41-F019, and proposed to perform

' check ~ valve sample disassembly / inspection every two years.

4.9.1.2.1 Licensee's Basis for Reauestina Relief--These check

. valves (sic) are necessary to prevent flow of pressurized-suppression pool inventory into the condensate storage tank while the system suction flow '

3 ,

paths are being swapped. No pressure instrumentation or vents exist upstream of the valve to assist in veri _fying closure. There is no +

external / remote means to verify the check valve position during system operation or an external means to cycle the valve while the. system is shut.

down.

Alternate Testina: Incorporate valve in a disassembly program and r manually cycle upon disassembly (Ref: V-08).

Grouping characteristics:

Type: swing -

Size: 16 inch Operating Medium: water Manufacturer: Anchor ,

NOTE: The following has been excerpted from the Brunswick IST program

" PROGRAM REMARKS NO. V-08" The check valves included in the check valve disassembly program are grouped according to type, size, operating medium, and manufacturer. The groupings are listed below. -

Group Acolicable Valves ,

SOG-2-1(2) Ell-F019 SDG-2-1(2) E11-F045 62 I

g i One check valve of each group will be disassembled and manually

, q exercised every two years for the respective unit.

l If any check valve fails, another check valve'from the same group l

,. shall be' tested. If this valves fails, the remaining check valves in the applicable group shall be-tested.

4.9.1.2.2 Evaluation--Check valve E41-F019 must shut to prevent diversion of suppression pool water to the condensate storage tank when. s switching suction sources. No direct position indication is installed to verify this valve's closed position. The licensee has proposed to perform a sample disassembly / inspection of this valve every two years and proposed grouping it with a similar valve, E41-F045. A check valve disassembly / inspection can provide a reasonable alternative to the Code requirements (see NRC staff position on check valve sample disassembly / inspection discussed in Section 4.1.6.1.2 of this report) when no other method of testing is feasable.

A review of the system prints (Piping Diagram D-2523, SHT 1, as built dated 5/14/1986) shows multiple pressure indicators, in the line between E41-F019 and the injection point of the keep fill line, and a high point vent on the suction line from the condensate storage tank upstream of valve E41-F019. Since the keep fill line maintains the pump discharge line filled with water the pressure source (demineralized water) must be at a pressure higher than the system. The pressure supplied to the suction of the high pressure coolant injection pump by the condensate storage tank can be determined through calculation or by isolating the keep fill system and observing a pressure instrument at the pump suction.

The licensee should then be able to verify closure of valve E41-F019 quarterly by observing that the keep fill system maintains a pressure , ,

above that provided by the condensate storage tank.

Since the reviewer feels that this valve can be verified in its closed position on a quarterly basis di.sassembly/ inspection and manual full-stroke of the disk every two years does not provide a reasonable alternative to the Code requirements.

63

K . .I e

Based on the determination that'it may not be impractical to test this- =

' valve quarterly in accordance with the Code requirements and giving due  !

consideration to the burden on the licensee if the Code requirements were imposed, relief should not be granted from the Code requirements as requested.,

4.9.1.3 Relief Reouest. The licensee has requested relief from the >

exercising (open) frequency and method requirements of Section XI, Paragraph'IW-3522, for the high pressure coolant injection suction from the suppression pool check valve, E41-F045, and proposed-to:part-stroke exercise this valve open quarterly utilizing the minimum flow line and verify the' full-stroke _ capability by performance of check valve sample disassembly / inspection every two years.

4.9.1.3.1 Licensee's Basis for Reauestina Relief--During I quarterly pump testing the system is -lined up to take suction from the condensate storage tank (CST) and discharge back into the CST. Because the return to the CST-is the only full flow-test line, to test check valve E41-F045 under full flow conditions would require lining the system to take suction from the suppression pool and discharging back into the CST.

This will contaminate (radiological and chemical) the CST.

Alternate Testino: Partially exercise the check valve quarterly and incorporate valve in a disassembly program, manually cycling the valve upon disassembly (Ref: V-08).

Disassembly grouping characteristics:

Type: swing check Size: 16 inch Operating Medium: suppression pool water .

Manufacturer: Anchor / Darling NOTE: See excerpt, " PROGRAM REMARKS N0. V-08" from the Brunswick IST program, concerning these valves in Section 4.9.1.2.1 of this report.

4.9.1.3.2 Evaluation--This check valve must open to allow HPCI suction from the suppression pool. It is impractical to full-stroke 64

e

, s, exercise this valve.on a quarterly basis since this would result in chemical and radiological ' contamination of the condensate storage tank (the only available full-flow path other than the reactor coolant system) due to the contaminants present in the suppression pool water. The licensee's proposal, to verify the part-stroke capability of this valve on a quarterly basis utilizing the minimum flow line back to the suppression pool, will provide an acceptable level of quality and safety and a reasonable alternative to the Code requirements.

l A practical- method of testing that will verify the full-stroke open ]

exercise capability of this valve would be disassembly / inspection and manual full-stroke of the disk. The licensee has proposed to perform a sample disassembly / inspection of this valve and placed two similar valves in this group. A check valve disassembly / inspection can provide a reasonable alternative to the Code requirements (see NRC staff position on check valve sample disassembly / inspection discussed in Section 4.1.6.1.2 l

of this report).

L '

The licensee has proposed to verify this valve's full-stroke open '

capability by performing a check valve sample disassembly program. Every l

two years, one valve of the group will be disassembled. If the tested 1 valve fails the other valve in the group will be disassembled. However, the licensee's proposal to include this valve and valve E41-F019 in a sample disassembly group is unacceptable since the reviewer feels that  !

valve E41-F019 can be verified in the closed position and full-stroke L

_ exercised open with flow on a quarterly basis. Therefore, valve E41-F019 L should not be included in the group with valve E41-F045.

L Testing this valve quarterly in accordance 'with the Code requirements ,

is impractical, however, the licensee's proposal (to perform sample disassembly / inspection) does not provide a reasonable alternative to the Code requirements, as discussed above. Relief from the Code requir n ats ,

should be granted provided the licensee performs. valve

? disassembly / inspection in accordance with the NRC staffs position and l

l 65 I

f

i. -. .. . . . ..

1 ,

disassembles valve E41-F045 each refueling outage.. These evaluations and_

recommen'dations'are made giving due consideration to the bu'rden on.the licensee if the Code requirements were imposed. .

4.10 Emeraency Service Water Iniection System 4.10.1 Cateaory B Valves 4.10.1.1 Relief Reauest. The licensee has requested relief from the exercising frequency requirements of Section XI, Paragraph IWV-3412, for the residual heat removal service water injection isolation motor operated-valves, E11-F073 and F075, and proposed to full-stroke exercise and stroke time these valves during refueling outages.

4.10.1.1.1 Licensee's Basis for Reauestina Relief--In the event of a loss of cooling accident and the failure of the Emergency Core Cooling Systems to maintain adequate vessel ' level, the RHR Service Water System (saltwater) pumps B & D can be used to provide a last resort backup supply of water to flood the reactor vessel via crossconnect valves

'E11~-F073, F075, and F078. These valves link the discharge side of one-loop of the RHRSW System with the B loop Low Pressure Coolant Injection line of1the RHR System. Exercising these valves quarterly may introduce untreated saltwater directly into the RHR System. This activity would constitute a degradation of the reactor coolant' which .is monitored for conductivity and chloride concentration in accordance with plant Technical Specification. To' facilitate testing of these valves, it will be necessary to isolate and drain a substantial portion of the Service Water System. In addition, the RHR Keepfill System maintains the E11-F078 check valve in the closed direction making' manual cycling of the 16" valves by

, mechanical lever iinprobable.

Alternate Testina: Full stroke exercise valves to the open position and stroke time power valves at refueling.

4.10,1,1.2 Evaluation--Valves E11-F073, F075, and F078 isolate the RHR service water from the RHR system water (closed loop) and provide 66 l

. . .i.< . .. ,..i...P ,. w.<  : .,i . .,y . i. .

9 a backup water supply to the reactor vessel in an emergency. Cycling these valves during operation or cold shutdown is impractical since it would introduce untreated saltwater into the RHR system and feasably into the reactor vessel and possibly result in contamination above Technical Specification levels. These contaminants could cause severe corrosion problems . Testing of these valves would require system draining and flushing which is time consuming and could result in an extension of cold shutdown and would be burdensome to the licensee.

The licensee's proposal to full-stroke and time valves Ell-F073 and F075 during refueling outages provides a reasonable alternative to the Code requirements.

Based on the determination that the Code requirements are impractical and that the licensee's proposed testing provides a reasonable alternative to the Code requirements, relief should be granted as requested.

4.10.2 Cateaory C Valves 4.10.2.1 Relief Recuest. The licensee has requested relief from the exercising frequency requirements of Section XI, Paragraph IWV-3522, for the residual heat removal service water injection isolation check valve, Ell-F078, and proposed to full-stroke exercise this valve during refueling outages.

4.10.2.1.1 Licensee's Basis for Reauestina Relief--In the event of a loss of cooling accident and the failure of the Emergency Core Cooling Systems to maintain adequate vessel level, the RHR Service Water System (saltwater) pumps B & D can be used to provide a last resort backup supply of water to flood the reactor vessel via crossconnect valves Ell-F073, F075, and F078. These valves link the discharge side of one loop of the RHRSW System with the B loop Low Pressure Coolant Injection line of the RHR System. Exercising these valves quarterly may introduce untreated saltwater directly into the RHR System. This activity would 67

4 constitute la degradation p the reactor coolant which is monitored for .

- conductivity and chloride. concentration in accordance with plant Technical Specification. To facilitate testing of these valves; it.will be ,

necessary.to isolate and drain a substantial portion of the Service Water System.~ _ In addition,- the RHR Keepfill System maintains the E11-F078 check valve in the closed direction making manual cycling of the 16" valves by mechanical lever improbable.

-Alternate Testina: Full stroke exercise valves to the open position at refueling.

4.10.2.1.2 - Evaluation--Valves E11-F073, F075, and F078 isolate the RHR service water from the RHR system water (closed loop) and provide a backup water supply to the reactor vessel in an emergency. Cycling valve E11-F078 during operations or cold shutdowns is impractical since it would introduce untreated saltwater .nto the RHR system and possibly result in contamination of the RHR water above Technical Specification levels. These contaminants could cause severe corrosion problems.

Testing of this valve would require system draining and flush'ing which is time' consuming- and would be burdensome to the licensee. Further, the manual operation lever on check valve E11-F078 cannot overcome system pressure to operate the valve.

' The licensee's proposal to' verify the full-stroke capability of valve E11-F078 during refueling outages provides a reasonable alternative to the Code requirements.

Based on the determination that the Code requirements are impractical and that the licensee's proposed testing provides a reasonable alternative to the Code requirements, relief should be granted as requested.

68

p . , ,

r , ,

'4.li Various Emeroency Core Coolina Systems m.

4.11.1 Catecoty A Valves

-4.11.1.1 Relief Reaugal. The licensee has requested relief from performing seat leakage tests in the forward direction for containment isolation valves, E11-F011A and B, F007A and B, E41-F075, and E51-F031, in accordance with the requirements of Section XI, Paragraph IWV-3423, and proposed to leak test these valves from the reverse direction.

4.11.1.1.1 Licensee's Basis for Reauestina Relief--The referenced valves are gate valves and are the.first valve on the pipe from the torus. No~ isolation valves or flanges exist to facilitate testing in .;

the proper direction. 'The ends of the pipe are submerged below the j minimum torus water level. No means are available to test these in the function pressure direction. .,

1 l  !

Alternate Testina: The valves will be tested from the reverse

~

l j

direction, j 4.11.1.1.2 Evaluation--These valves perform a containment

.]

L isolation function. There are no isolation valves, flanges, pressure

- taps, etc., to- facilitate leak testing these valves in the forward or  ;

l function direction as specified in the Code, therefore, it is impractical to leak test these valves in-accordance with the Code requirements. The ,

licensee's proposal to leak test these valves in the reverse direction  !

presents an acceptable level of quality and safety and provides a reasonable alternative to the Code requirements.

I Based on the determination that the Code requirements are impractical

. and that the licensee's proposal provides a reasonable alternative to the Code requirements, relief should be granted as requested.

69

Wit?$V# ~9%?!? W1 P7:W ,

WT'" " JWlq J

. T '- . 7

.l

?,

5 l

f

}

.. .4 f

. t 1

,'?'

. , a

'i 1

- ,l i

e f

h i

e h V

1; i

-(

4-c

. t 13 t 4 l

/-

h

.IE t

s

' Ai I

2 '.,

t.

)

,f

.i o-,

f

- Ir 1-w

)

e i, h

ca

+...f, f

-t W

s F,

?

f r

' 4E

? -

f

-m t

e. .

h c.

(i .

h s '

6 Yk 1 C'.

y

u. 4 s

4A

[Y-p 5

e g t.I g- 1 2

Y-1-

t F",)

h.

,ki i

f.

s.

y .

r ,

"h' k'

t';

i l

h. .

S-e b

4-

&# e- , .

1. ' IN4FO 3 h./I,, .'2M _A%' P r.W~M" sew o na c., e ,,. + , , ,,_

p .i.

' '-4' . ..

t .

3 4J i

sc.,

i > .:' >_ ,- .

1 4

9 4

e j.~.

i?

- APPENDIX A 6

4 4

k1.

A-1

+ ..

APPENDIX A ,

VALVES TESTED DURING COLD SHUTDOWN The following are' Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke exercised E every three months'during plant operation. These valves are specifically identified by the owner in accordance with Paragraphs IWV-3412 and 3522 and i- are full-stroke exercised during cold shutdowns and refueling outages. All valves:in this Appendix have been evaluated and the reviewer agrees with the licensee that testing these valves during power operation is not practicable due to the valve type, location, or system design. These valves should not be full-stroke exercised during power operations. These valves are listed below and grouped according to the system in which they are located.

1. REACTOR RECIRCULATION SYSTEM P

1.1 Cateoory A Valvel L

The reactor recirculation pump seal and cooling water containment L

isolation valves, B32-V22 and V30, cannot be exercised quarterly during power operation. Exercising these valves during normal operation would j require isolating the seal water flow to the reactor recirculation pumps.

Isolating the seal water flow to these pumps could potentially cause pump damage. These valves will be full-stroke exercised and stroke timed during l cold shutdowns and refueling outages.

1.2 Cateoory B Valves The reactor recirculation loop isolation valves, B32-F031A and F0318

.and their bypass valves, B32-F032A, and F032B, cannot be exercised during power operation. Shutting B32-F031A or F031B more than 107,will trip the associated recirculation pump. Valves and B32-F032A have a normal open position. If either valve B32-F032A or F0328-(both normally open) failed shut during cycling and the associated recirculation pump was to trip, the only mechanism for restoring that recirculation loop would be a drywell A-3

7  ;.  ;

entry and manualf operation' of B32-F032A or F0328. This requires accessing

• the primary containment which is iner'ted with nitrogen (oxygen content <4%

by volume) during reactor operation. Further, one loop-operation is ,

restricted by Technical Specifications. These valves will be exercised and stroke timed during cold shutdowns and refueling outages.

2. NUCLEAR STEAM SUPPLY SYSTEM.

a 2.1 Cateaory A Valves

- The main steam line isolation valves, B21-F022A, F022B, F0220, F022D, F028A, F0288, F0?.80, and F0280, cannot be full-stroke exercised quarterly during power operation. Full.-stroke testing the,se valves during normal reactor operation requires isolating one of the four main steam lines .

_This could result in primary system pressure spikes, reactor power fluctuations, and increased flow in the unisolated steam lines'. 'This unstable operation can lead to_a reactor scram, and as discussed in NUREG-0626, pressure transients resulting from full-stroke testing MSIVs increase the chances of actuating primary safety / relief valves. - These valves are designed for partial-stroke exercising during normal operation. j These valves will be part-stroke exercised quarterly and full-stroke l

l exercised and stroke timed during, cold shutdowns and refueling outages.

l 2.2 Cateaory C Valves L

The fol, lowing valves open to allow manipulation of air-operated valves and close to isolate instrument air divisions:

h L

L Valve Valve l B21-F024A, B, C, and D B21-V29A, B, C, and D B21-F029A, B, C, and D B21-V28A, B, C, and D RNA-IV-519 thru 526 RNA-IV-531 thru 542 RNA-V313 thru 316 <

B21-V27A, B*, C, D, E*, F*, G*, H, J, K, and L B21-F036A, B*, C, D, E*, F*, G*, H, J, K, and L l

• Unit 1 only Verification of these valves' operation requires isolation of the e

non-interruptible instrument air system which supplies air to the main A-4 l/, .

,4

steam isolation valves (MSIV) and automatic depressurization and safety / relief system (ADS /SRV). Therefore, the MSIVs would close and SRV/ ADS would be inoperative causing a reactor SCRAM. In addition, testing of_these valves requires accessing the primary containment wh;ch

. is inerted_with nitrogen (oxygen content 14% by volume) during reactor operation. These valves willibe full-stroke exercised during cold-shutdowns and refueling outages.

Valves B21-F037A thru H, J, K, and L, nuclear steam supply / automatic depressurization system vacuum breakers to suppression pool, cannot be exercised quarterly during power operation. Following a safety valve / relief valve operation, the steam in the line will condense as it cools creating a vacuum in the downcomer tube. The vacuum bresakers open to prevent water from the suppression pool from being drawn up into the downcomer tube. Adequate testing of these check valves will require operating the SRVs, at power, and observing the check valve operation or manually cycling the check valves. The SRVs cannot'be operated at power and the check valves cannot be observed or cycled at power because they are located in the containment which is inerted with nitrogen <4% o.xygen content by volume) and subject to high radiation levels and temperature.

These valves will be full-stroke exercised during cold shutdowns and refueling outages.

3. FEEDWATER SYSTEM 3.1 Cateaory A/C Valves .

Feedwater inlet motor-operated stop check isolation valves, B21-F032A and F032B, cannot be exercised quarterly during power operation.

Full-stroke exercising during plant operation would require stopping one loop of feedwater flow and would result in a reactor scram. Valve control logic and valves design precludes part-stroke exercising. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

l A-5

1 V. .

4. RESIDUAL HEAT. REMOVAL SYSTEM 4.1 Cateoory A Valves

The residual heat removal (RHR) system, reactor coolant system (RCS) shutdown suction isolation valves, E11-F008 and F009, cannot be exercised.

quarterly during power operation. These valves are interlocked.with RCS pressure to prevent opening during normal operation. Exercising during

' power operation could lead to. extensive damage to the low pressure residual heat removal system. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

4.2 Cateoory A/C Valves The RHR system low pressure coolant injection (LPCI) check valves, E11-F050A and F0508, cannot be exercised quarterly during power operations. The only way to verify forward flow through the check valve is to inject water from the RHR system through the valve into the RCS, Flow cannot be established through these valves during normal operation when the RCS pressure is much greater than the RHR system operating pressure.' These valves will be full-stroke exercised open with flow during cold shutdowns and refueling outages.

4.3 Cateoory B Valves Valves F020A, and B, RHR system LPCI suction from the suppress' ion pool, cannot be exercised quarterly during power operation. These valves supply RHR pumps A and C (E11-F020A) and B and D (E11-F020B).. Technical Specifications require two LPCI subsystems to be operable' during reactor operation with each subsystem comprised of two pumps with an operable flow path taking suction from the suppression pool. These valves do not receive an automatic open signal upon LPCI initiation. When these valves are closed the suction flow path for both pumps of the subsystem is lost.

If the plant was to receive a LPCI initiation signal, it would require operator intervention to get injection through the affected subsystem of LPCI. LPCI is an Emergency Core Cooling System (E,CCS) and is required to l

A-6

4

[- - <

?c;

~

perform its function without operator intervention. Valves E11-F020A, and B will be full-stroke exercised and stroke timed during cold shutdowns and .

refueling outages.

- Valves E11-F006A, B,. C, and D, RHR system suction from RCS isolations, ,

cannot be exercised quarterly during operation. They are . interlocked with

valves E11-F020A and B (E11-F006A and C.with E11-F020A and E11-F006B and D with E11-F0208) such that E11-F006A, B, C, or D cannot be opened unless the associated valve, E11-F020A or B, is closed. -If valves E11-F020A or B are closed, the suction flow path for both pumps of the subsystem is l lost. These valv'es do not receive an automatic open signal 'upon LPCI initiation. If the. plant was to receive a LPCI initiation signal, it would require operator intervention.to get injection through-the affected subsystem of LPCI. LPCI is an Emergency Core Cooling System (ECCS) and is

-required to perform its function without operator intervention. Valves E11-F006A, B, C, D, will be full-stroke exercised and stroke timed during o cold shutdowns and refueling outages.

5. REACTOR BUILDING CLOSED COOLING WATER SYSTEM 5.1 Cateoory A Valves Valves RCC-V28 and V52, containment isolation valves for the reactor building closed cooling water system supply and return, cannot be full-stroke exercised during power operations. Stroking of these valves

.during operation interrupts the flow of cooling water to the recirculation pumps and drywell coolers which are required during operation. Closing these' valves during operation may lead to overheating and potential damage to the recirculation pump motors in a short period of time. Valve design -

precludes partial stroke exercising. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling outages.

l' A-7

f .

g ,

~

6., NON-INTERRUPTIBLE INSTRUMENT AIR SYSTEM 6.1 cat.tgory A Valves Valves RNA-SV5261 and SV5262, non-interruptible instrument air to the primary containment isolation valves,;cannot be exercised quarterly during power operations. Instrument air supplies various components in the-primary containment which are essential for normal operation. Loss of instrument air during normal operation could result in a reactor scram.

Valve design precludes partial stroke exercising. These valves will be full-stroke exercised and stroke timed during cold shutdowns and refueling-outages.

t 7.. CONTAINMENT ATMOSPHERE MONITORING SYSTEM l

7.1 Cateaory A Valves l

Containment atmospheric monitoring containment isolation valves, .

i CAC-SV1225B and SV3440, cannot~ be full-stroke exercised quarterly during operation. These valves are the inboard and outboard containment d isolation valves for the common return line for two containment radiation monitors. There are a total of three containment radiation monitors.

Technical Specifications require two containment radiation monitors to be operable during reactor operation and when these valves are cycled, two containment radiation monitors are inoperative. These valves will be I . full-stroke exercised and stroke timed during cold shutdowns and refueling i outages. -,

8. HIGH PRESSURE COOLANT INJECTION SYSTEM u

! 8.1 Cateaory A Valve

! Valve E41-F002 opens for HPCI steam supply and closes for primary containment isolation. This valve is in the steam supply line for the high pressure coolant injection turbine and is normally open during plant operation. The valve cannot be manually cycled during plant operation A-8 l

y, .

V s. .

\;'  :.-

' J '- because it is located in the primary containment which is inerted with ,

nitrogen (oxygen content less than 4% by volume) during operation. If  ;

this valve fails in the closed position during quarterly testing duri.ng plant operation it will render the entire HPCI system inoperable. This valve will be full-stroke exercised and stroke timed _during cold shutdowns. I and refueling outages.

8.2' Cateoory A/C Valves Valves E41-F021 and F022, steam turbine exhaust and drain pot line return, respectively, close to perform a primary containment isolation function. There is.no external / remote means to verify the valves' position during system operation. These valves are stop check valves and ,

the handwheel can be ' cranked' down to verify check valve closure'.  ;

L However, when the handwheel is placed in the ' closed' position the applicable system is considered inoperable and could result in a violation of Technical Specifications. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

8.3 Cateoorv C Valves Valves E41-F076 and F077, turbine exhaust vacuum breaker check valves, open.to relieve the vacuum in the HPCI steam exhaust line to prevent.the.

line from filling up with suppression pool water which would eventually trip the HPCI turbine. There is no external / remote means to verify valve position during system operation or an external means to cycle these valves. Testing these valves encompasses c~1osure of the automatic isolation valves (E41-F075 and E41-F079) in conjunction with opening the test /ventvalveslocatedbetweenthem. This activity would limit these penetrations with only one containment isolation valve wMch is a breach of primary containment and during reactor operation would require the applicable unit to be shutdown. These valves will be full-stroke exercised to the open position during cold shutdowns and refueling outages.

A-9

9.- REACTOR CORE ISOLATION COOLING SYSTEM 9.1 Cateaory A Valve

- Valve E51-F007 closes to perform a primary containment isolation function. This valve is in the steam supply line for the reactor core isolation cooling turbine-and is normally open during plant operation. .

The valve cannot be manually cycled during plant operation because it is located in the primary containment which is inerted with nitrogen (oxygen content <4% by volume). If this valve fails in the closed position during quarterly testing during plant operation it will render the entire reactor

- core isolation cooling system inoperable. This valve will be full-stroke 4 exercised and stroke timed during cold shutdowns and refueling outages.

9.2 Cateaory A/C Valves Valves E51-F001 and F002, steam turbine exhaust and drain pot line i return, respectively, close to perform a primary containment isolation function. There is no external / remote means.to verify the valves' position during system operation. These valves are stop check valves and the handwheel can be ' crank'ed' down to verify check valve closure.

However, when the handwheel is placed in the ' closed' position the applicable system is considered inoperable and could result in a violation of Technical Specifications. These valves will be full-stroke exercised during cold shutdowns and refueling outages.

p-l

=

t l

A-10

13

. 7,;

. ..y

._y_

.., m'< , , , .,

y,> _,,y

.,4 3 ,

9

('

w d

f

=e

... m

'a)

.n.-

1 4

4 -' q

, , - .{

+

. 1 FP r

o t

+

)

. - g.4 1, -

4

.,F F

c 4

i APPENDIX B i A

.f d x

.r, -'

O e- .. ;a

.f

?: .

. ,.s

.% 1 .L

.s - 't

i

4. [ <

4-  :[

a 9

%l t w s

[ b y

• . i;

~

kh e-

.?

• 'i*

?.

?

.tg t

r( # .js v

F.,g 8.

[r  !

e . '9 a., <

{ 4,]'

'l .

v.

u

+v.

s: ,- '

b.'/: 6

g. - l[ . ,(

.I:'; ~h p

h, ' h b

I

{

?' ,

?

e- - t

l. 'f t r t- - c.

bc. ;

b' v:

n k

{' .

B-1 r

t y.

e L

I-

{t >-. s

,' ,'6MEy w g. m -A 4.y% c- ' ' " ' ' " " ' ' ' .. s y

[c .

L .. i

. APPENDIX'B ,

A

. The ISI Boundary Drawings listed below were used during the course of this review.

System Drawino No. Revision ;

Service Water System Sheet 1. Unit 1 D 20041 33 Service Water System Sheet 2, Unit 1 D 20041 29.

Service Water System Sheet 3, Unit 1 0 20041 26 Diesel Generator Service Water & Demineralized Water Systems Sheet 1. Units 1 & 2 0-2274 9 Diesel Generator Service Water & Demineral~ized Water Systems Sheet 2. Units 1 & 2 0-2274 9 Containment Atmospheric Control System Sheet 1A, Unit No. 1 D 25015 43 '

Containment Atmospheric Control System Sheet IB, Unit No. 1 D-25015 39 Control Rod Drive Hydraulic System Sheet 2A, Unit No. 1 0 25017 12 -

Control Rod Drive Hydraulic System Sheet 28, Unit No. 1 0-25017 13 Reactor Water Clean-Up System Sheet 18, Un.it No. 1 0-25027 20 '

. Nuclear Steam Supply System Sheet 3A Unit No. I D-25020 18 Nuclear Steam Supply System Sheet 3B, Unit No. 1 0-25020 20 Nuclear Sterm Supply System Sheet IA, Unit No. 1 0 25021 30 Nuclear Steam Supply System Sheet 18, Unit No. 1 D 25021 34 Nuclear Steam Supply System Sheet IC, Unit No. 1 0 25021 29 Nuclear Steam Supply System Sheet 2A, Unit No. 1 0-25022 21 Nuclear Steam Supply System Sheet 28, Unit No. 1 D 25022 22 High Pressure Coolant Injection System Sheet 1, Unit No. 1 D 25023 27

. High Pressure Coolant Injection System Sheet 2. Unit No. 1 D-25023 22 Core Spray System Sheet 1 Unit No. 1 0-25024 19 Core Spray System Sheet 2, Unit No. 1 0-25024 17 Residual Heat Removal System Sheet IB, Unit No. 1 D 25025 27 Residual Heat Removal System Sheet lA, Unit No. 1 0-25025 29 Residual Heat Removal System Sheet 2A, Unit No. 1 0-25026 32 B3 ,

System Drawina No. Revision Residual Heat Removal System Sheet 2B, Unit No. I D 25026 31 Reactor Core Isolation Cooling System i Sheet 1 Unit No. 1 0 25029 30  ;

Reactor Core Isolation Cooling System Sheet 2. Unit No. 1 0-25029 25 Service Water System Sheet 1. Unit No. 1 D-25037 40 Service Water System Sheet 2, Unit No. 1 D 25037 41 Closed Cooling Water System Sheet 1. Unit No.1 D-25038 13 l Drywell Drains Sheet 3A, Unit No. 1 D-25045 17 Drywell Drains Sheet 3B, Unit No. 1 D 25045 18 Standby Liquid Control System, Unit No. 1 D-25047 17 Reactor Coolant Recirculation System Sheet IA, Unit No. 1 D 25018 18 Reactor Coolant Recirculation System Sheet IB, Unit No. 1 0 25018 18 Reactor Coolant Recirculation System Sheet 2B, Unit No. 1 D 25048 19 Reactor Coolant Recirculation System Sheet 2A, Unit No. 1 0 25048 19 fuel Pool Cooling & Filtering System ',

Sheet IB, Unit No. 1 D-25049 13 Torus. Drain and Keep Fill Charging System Unit No. 1 D 26098 7 Instrument Air Supply System Sheet 1. Unit No. 1 D-70007 11 Instrument Air Supply System Sheet 3A, Unit No. 1 D-70077 17 Instrument Air Supply System -

Sheet 38, Unit No. 1 D 70077 18 Instrument Air Supply System Sheet 4. Unit No. 1 0-72006 18 Reactor Building Containment Atmosphere Monitoring Systam, Unit No. 1 0-72018 21 Primary Containment Hydrogen Monitoring System Sheet 1. Unit No. 1 0 73026 7 Primary Containment Hydrogen Monitoring System Sheet 2. Unit No. 1 0 73026 8 Post Accident Sampling System Sheet 1. Unit No. 1 0-73027 6 Instrument Air Supply Nitrogen Backup Reactor Building Sheet 1. Unit No. 1 D-73068 1 Standby Gas Treatment Sheet 3, Unit No. 1 F 40073 0 Starting Air For Diesel Generators Sheet IB, Units No. 1 & 2 D 2265 14 Traversing incore Probe (TIP) Equipment

& Piping Arrangement Sheet 1. Unit No. 1 F-70081 5 B4

4 System Drawino No. Revision P

Service Water System Sheet 1. Unit No. 2 D 2041 36  ;

Service Water System Sheet 2 Unit No. 2 D 2041 36 Service Water System Sheet 1, Unit No. 2 0 2537 42  ;

Service Water System Sheet 2, Unit No. 2 0 2537 40  ;

Closed Cooling Water System i Sheet 1. Unit No. 2 D-2538 15 Drywell Drains Sheet 3A, Unit No. 2 D 2545 15 t Drywell Drains Sheet 3B, Unit No. 2 0 2545 16  !

Standby Liquid Control System, Unit No.2 D 2547 15 fuel Oil to Diesel Generators Sheet IB, Unit 1 & 2 0-2268 17

• Fuel Oil to Diesel Generators Sheet IA, Unit 1 & 2 0 2268 17 .

Fuel 011 to Diesel Generators Sheet 2A, Unit 1 & 2 0 2269 17 fuel 011 to Diesel Generators  :

Sheet 2B, Unit 1 & 2 D 2269 17 Containment Atmospheric Control System Sheet IA, Unit No. 2 D-2515 39 Containment Atmospheric Control System Sheet 18, Unit No. 2 D-2515 35 Control Rod Drive Hydraulic System -

Sheet 1A, Unit No. 2 0-2516 16  :

Control Rod Drive Hydraulic System Sheet 2A, Unit No. 2 D 2517 16 Control Rod Drive Hydraulic System Sheet 2B, Unit No. 2 0 2517 17 Reactor Coolant Recirculation System Sheet IA, Unit No. 2 D-2518 26 Reactor Coolant Recirculation System .

Sheet IB, Unit No. 2 -

D 2518 27 Reactor Coolant Recirculation System Sheet 2B, Unit No. 2 D-2548 25 ,

Reactor Coolant Recirculation System Sheet 2A, Unit No. 2 0-2548 27 fuel Pool Cooling & Filtering System Sheet IB, Unit No. 2 D-2549 13 Containment Atmospheric Control System Sheet 2A, Units No. 1 & 2 D-2560 17 Containment Atmosphere Monitoring System Unit No. 2 D-7218 22 Primary Containment Hydrogen Monitoring System Sheet 1. Unit No. 2 0-7326 7 Primary Containment Hydrogen Monitoring System Sheet 2. Unit No. 2 D-7326 5 Post Accident Sampling System Sheet 1. Unit No. 2 D-7327 4 Torus Drain and Keep Fill Charging System Unit No. 2 0-2698 8 Instrument Air Supply System Sheet 1. Unit No. 2 0-7007 20

. B-5

l

. i System Drawina No. Revision Instrument Air Supply System  !

Sheet 2A, Unit No. 2 D-7029 26 -

Instrument Air Supply System  ;

Sheet 28, Unit No. 2 D-7029 26  !

Instrument Air Supply System t Sheet 3A, Unit No. 2 D-7077 20 Instrument Air Supply System Sheet 3B, Unit No. 2 D 7077 18 Instrument Air Supply System Sheet 4 Unit No. 2 D-7206 21 i instrument Air Supply Nitrogen Backup i Reactor Building Sheet 1. Unit No. 2 D-7368 1 Standby Gas Treatment Sheet 3, Unit No. 2 F-4073 0 .

Fuel Pool Cooling & Filtering System  ;

Sheet IA, Unit No. 2 D-2549 12 i Nuclear Stoam Supply System Sheet 3A, Unit No. 2 0-2520 23 Nuclear Steam Supply System Sheet 38, Unit No. 2 0 2520 22 i Nuclear Stear Supply System .

Sheet 1A, Unit No. 2 D-2521 30 i Nuclear Steam Supply System .

Sheet IB, Unit No. 2 D-2521 30 .

Nuclear Steam Supply System  !

Sheet IC, Unit No. 2 D 2521 31 1 Nuclear Steam Supply System >

Sheet 2A, Unit No. 2 0-2522 27 Nuclear Steam Supply System  :

Sheet 2B, Unit No. 2 D 2522 28 High Pressure Coolant Injection Syst,em Sheet 1, Unit No.2 0-2523 27 High Pressure Coolant Injection System Sheet 2. Unit No.2 D-2523 22 ,

Core Spray System Sheet 1, Unit No. 2 0 2524 20 Core Spray System Sheet 2 Unit No. 2 D-2524 19 Residual Heat Removal System '

Sheet IB, Unit No. 2 D 2525 29 Residual Heat Removal System Sheet lA, Unit No. 2 0-2525 31  !

Residual Heat Removal System Sheet 2A, Unit No. 2 0-2526 31 Residual Heat Removal System Sheet 2B, Unit No. 2 0-2526 32 Reactor dater Clean-Up System Sheet IB, Unit No. 2 D-2527 29 Reactor Core Isolation Cooling System Sheet 1 Unit No. 2 D-2529 30 Reactor Core Isolation Cooling System Sheet 2, Unit No. 2 D 2529 28 B-6

p - - .

1 System Drawino No. Revision Starting Air For Diesel Generators  !

Sheet IA, Units No. 1 & 2 D-2265 13  ;

Starting Air For Diesel Generators >

. . Sheet 2A, Units No. 1 & 2 D-2266 12 .

i Starting Air For Diesel Generators i Sheet 2B, Units No. 1 & 2 D-2266 12 i Traversing Incore Probe-(TIP) Equipment ,

& Piping Arrangement Sheet 1, Unit No. 2 F-7081 6 .

s h

f I

{.

h l

l n

k o

B7

1 gj%4 sT-%

i ..k A

B 4'

4 APPENDIX C e

S C-1

.. l i

APPENDIX C ,

IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW Inconsistencies and omissions in the licensee's program noted during  ;

the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines l presented in this report.

1. The licensee has proposed to perform pump bearing vibration monitoring in accordance with ASME/ ANSI OM 6, in lieu of annual pump bearing temperature measurement as required by Section XI (see section 3.1.1 of this report). The NRC recognizes the vibration testing program of OM 6 to be more comprehensive than the program outlined in Section XI and frequently grants relief from the Section XI vibration testing requirements when this is proposed as an alternative testing method. A request for relief from the Section XI requirements that proposes to perform pump vibration testing per OM 6 would likely be approved and would relieve the licensee from performing unnecessary additional testing. The licensee should consider submitting a relief request to NRC to use this pump vibration testing program.

2. The licensee has requested relief from fail-safe testing valves equipped with fail safe operators and stated that normal operation verifies the fail-safe capability of these valves. Since the licensee's proposed testing is in accordance with the Code ,

requirements, relief is not necessary. This relief request (Relief Request No. VR 01) should be deleted from the IST program.

3. The licensee has requested relief from complying with the requirements of IWV-3420 for all containment isolation valves and proposed to utilize the leak testing requirements of 10 CFR 50, Appendix J. The licensee should be granted relief from the requirements of IWV-3421 through 3425, to leak test as described C-3

I 1

. in Appendix J, however, the licensee should comp)y with the requirements of IWV-3426 and 3427(a) (see section 4.1.4 of this report).

l

4. The licensee has requested relief from stroke timing the residual  ;

heat removal pump service water booster pump motor cooler inlet  !

isolation valves, SW-V136, V137, V138, and V139. However, the  ;

licensee has not proposed any acceptance criteria for determining  ;

if these valves are capable of performing their safety function, j Relief should be granted, provided the licensee develops some I acceptance criteria for making an objective determination of valve j operational readiness (see section 4.8.1.1.2 of this report). l

5. The licensee has requested relief from quarterly verification of the full-stroke capability of the service water lubricating water pump suction check valves, SW V201, V204, and V205, and proposed l to perform sample disassembly / inspection on these valves (grouped )

with 3 others) every two years. However, the licensee's proposed testing frequency and sampling and grouping methods are unacceptable. Relief should be granted provided the licensee J performs sample disassembly / inspection in accordance with the NRC ]

staff position (see section 4.1.6.1.2 of this report) and groups the valves into three groups as identified (see section 4.8.2.1.2 of this report).

L 6. The licensee has requested relief from quarterly verification of the full-stroke capability of the service water system nuclear i header to conventional header isolation check valve, SW-V200, and proposed to perform sample disassembly / inspection on this valve (grouped with 5 others) every two years. However, the licensee's

! proposed testing frequency and sampling and grouping methods are i unacceptable. Relief should be granted, provided the licensee performs sample disassembly / inspection in accordance with the NRC l staff position (see section 4.1.6.1.2 of this report) and groups '

th'e valves as identified (see section 4.8.2.2.2 of this report).

I .

I C-4

w y:.

q. ,

ju o +

n 7. The licensee has requested relief from quarterly verification of the full-stroke capability of the service water lubricating water l

, system check valves, SW V202 and 203, and proposed to perform  ;

sample disassembly / inspection on these valves (grouped with 4 '

others) every two years. However, the licensee's proposed testing frequency and sampling and grouping methods are unacceptable.

Relief should be granted, provided the licensee performs sample ,

disassembly / inspection in accordance with the NRC staff position  ;

(see section 4.1.6.1.2 of this report) and groups the valves as [

identified (see section 4.8.2.3.2 of this report).

8. The licensee has requested relief from quarterly verification of the full-stroke capability of the service water nuclear header cross-connect / isolation check valves, SW-V272, 273, 274, and 275, and proposed to perform sample disassembly / inspection on these valves every two years. However, the licensee's proposed testing frequency and sampling and grouping methods are unacceptable.

Relief should be granted, pnovided the licensee performs sample disassembly / inspection in accordance with the NRC staff position (see sections 4.1.6.1.2 and 4.8.2.4 of this report).

j 9. The licensee has requested relief from quarterly verification of '

the full-stroke capability of the residual heat removal and high pressure coolant injection check valves, E11-F046A, F0468, F046C, F0460, and Ell-F046A, and proposed to perform sample disassembly /iupection on these valves every two years, however, the licensee's proposed testing frequency and sampling and grouping methods are unacceptable. Relief should be granted provided the licensee performs sample disassembly / inspection in accordance with the NRC staff position (see section 4.1.6.1.2 of I this report) cnd groups the valves as identified (see section 4.9.1.1.2 of this report).

i

10. The licensee has provided a relief request (VR-20) for valve E41-F019, high pressure coolant injection suction from the L

l C-5

y L- -

condensate storage tank, proposing to verify its closure position -

by sample disassembly and inspection every two years. Howe'er, v in  ;

L reviewing the system prints the reviewer feels that it is i practical to verify this valve's closed position quarterly (see discussion in section 4.9.1.2.2 of this report). This valve ,

should be verified closed quarterly as required by the Code. l

11. The licensee has requested relief from quarterly verification of the full-stroke capability of the high pressure coolant injection from suppression pool check valve, E41-F045, and proposed to l include it in a group with E41-F019 and perform sample i disassembly / inspection on these valves every two years. However, the licensee's proposed grouping method is unacceptable. Relief should be granted provided the licensee performs  ;

disassembly / inspection of this valve at each refueling outage in accordance with the NRC staff position (see sections 4.1.6.1.2 and '

4.9.1.3.2 of this report). ,

12. The licensee was informed at the working meeting that all reactor f i

core isolation cooling system pumps and valves, other than those that perform a containment isolation function, could be deleted from the IST program if credit was not taken for the operability of the system in the station accident analysis. The licensee's i revised IST program reflected this information in that only those .

RCIC valves that perfom a containment isolation function remain in the program. However, the NRC staff position is that all appropriate RCIC system pumps and valves (i.e., those required to l function to support system operation) should be included in the i IST program and tested in accordance with the Code requirements to

( the extent practicable.

This position is based on the fact that the RCIC is designated a " safe shutdown system" and is addressed in the station Technical Specifications, which specify operability and testing requirements in addition to placing Limiting Conditions for Operation in effect in the event the system becomes unavailable. Therefore, the licensee should include all -

C-6

m

• l j ,

l . J i

f appropriate RCIC system pumps and valves (and reactor water ,

j i cleanup return valve G31 F039) in the IS'T program and test them in accordance with the requirements of Section XI.  !

l

13. The licensee has added valves Ell-F080A, B, and F040 to the IST program valve listing tables since they are in the Brunswick Station Technical' Specifications as containment isolation valves.  ;

However, these valves ha've been categorized B and are not identified to receive leak rate testing. These valves should be  ;

identified as Category A and be leak rate tested at least once ,

every two years, i

14. Valve 1 Ell-F0040 is identified as Category A in the IST program, however, no leak testing is identified. This is likely a ,

typographical error and should be corrected. i

15. The licensee has provided a cold shutdown justification for testing the Cll/C12-115, charging water header to accumulator i check valves (137 per Unit, I for each of 137 hydraulic control

• rod drive units), during cold shutdowns. However, the licensee

. has not provided a technical justification that demonstrates that it is impractical to perform this testing quarterly during power operations. The licensee has stated that testing these valves requires isolating the charging water header and that this places ,

the plant in a Limiting Condition for Operation, however, this alone does not justify the increased testing interval. The licensee should test these valves at the frequency specified in the Code. If the licensee can demonstrate the impracticality of exercising these valves at the Code specified frequency he should provide this information in the form of a revised cold shutdown justification or a relief request.

16. The licensee has provided a cold shutdown justification (VC-ll) for testing the Ell-F004A, B, C, and D, low pressure cpolant injection suction from the supression pool, during cold C-7

e L .,

shutdowns. These valves supply redundant pumps in redundant systems and would affect only'one pump (out of the four) during each test. Further, the licensee's assertion that testing these valves places the plant in a Limiting Condition for Operation does not in itself justify an extension of the interval from that -

required by the Code. These valves should be exercised and stroke l timed quarterly as required by the Code.

4 9

4 C-8

)