ML20235L415

Summary of 870721 & 22 Site Meetings W/Licensee & Eg&G Idaho,Inc Re Inservice Testing Program Submittals.Attendance List & Questions & Comments Re Pump & Valve Inservice Testing Program Encl

ML20235L415
Person / Time
Site:	Brunswick
Issue date:	09/28/1987
From:	Sylvester E Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8710050458
Download: ML20235L415 (31)

Text

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', - SEP 2 81987 Docket Nos. 50-325/324 DISTRIBUTION See attached list LICENSEE: Carolina Power & Light Company (CP&L)

FACILITY: Brunswick Steam Electric Plant, Units 1 and 2

SUMMARY

OF MEETING HELD ON JULY 21 AND 22, 1987: INSERVICE TESTING PROGRAM

Background

A meeting was held at the Brunswick facility on July 21 and 22,1987, to discuss the proposed program for the inservice testing of pumps and valves at the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. Participants in the meeting included representatives of CP&L, the NRC and the NRC contractor, EG&G Idaho, Inc. The list of attendees is provided as Enclosure 1.

By letter dated October 23, 1986, CP&L submitted the proposed inservice test (IST) program for BSEP for the second ten-year cycle of operation which began on July 10, 1986. EG&G Idaho,'Inc. was contracted by the NRC for review of the program. During the course of the review, EG&G developed a list of comments and questions to be addressed by the licensee to support completion of the review.

These comments and questions were transmitted to the licensee as an attachment to the meeting notice dated July 15, 1987.

Meeting Summary The agenda for the July 21 and 22, 1987 meeting followed from the comments and questions issued with the July 15, 1987 meeting notice. In response to the coments and questions, CP&L provided a written response to supplement the October 23, 1986 submittal. The comments and questions, the CP&L response, and the EG&G evaluation of the CP&L response are provided as Enclosure 2. The licensee comitted to provide a further supplement to the IST program submittal of October 23, 1986 as a result of this meeting. The supplemental submittal will include a response to the open items remaining after the discussion, as well as the corrections and modifications made to the program as a result of the discussion. The subm'ttal will also confirm all comitments for additional testing made in the meeting and ' discussed in Enclosure 2. The licensee comitted to provide the supplemental submittal within 60 days of receipt of this meeting sumary.

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Ernest Sylvester, Project Manager Project Directorate 11-1 Division of Reactor Projects I/II

Enclosures:

As stated cc: See next page ,j PM:PD21:DRPR b D:PD21,1RR{(

ESylvester/dsf EAdensam 9/2 o/87 9/g/87 8710050458 870928 PDR ADOCK 05000324 P PDR

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dr.'E.E.Utley Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 cc:

Mr. P. W. Howe Mr. C. R. Dietz -

Vice President -

Plant General Manager Brunswick Nuclear Project Brunswick Nuclear Proje'ct Box 10429 Box 10429 Southport, North Carolina 28461 Southport, North Carolina 28461 Thomas A. Baxter, Esquire Mr. H. A. Cole Shaw, Pittman, Potts & Trowbridge Special Deputy Attorney General 2300 N Street, N. W. State of North Carolina Washington, D. C. 20037 Post Office Box 629 Raleigh, North Carolina 27602 Mr. Mark S. Calvert Associate General Counsel Mr. Robert P. Gruber -

- Carolina Power & Light Company Executive Director -

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Public Staff - NCUC-

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Post Office Box 1551 i Raleigh,, North Carolina 27602 Post Office Box 29520 Raleigh, North Carolina 27626-0520 l -

Mr. Christopher Chappell, Chairman Board of Commissioners Post Office Box 249 Bolivia, North Carolina 28422 Mrs. Chrys Baggett State Clearinghouse Budget and Management

, 116 West Jones Street Raleigh, North Carolina 27603

! Resident Inspector i U. S. Nuclear Regulatory Commission Star Route 1

> Post Office Box 208 i Southport, North Carolina 28461 Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 Mr. Dayne H. Brown, Chief Radiation Protection Branch Division of Facility Services ,

N. C. Department of Human Resources 701 Barbour Drive -

Raleigh, North Carolina 27603-2008 ,

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n ENCLOSURE 1

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ATTENDANCE LIST INSERVICE TESTING PROGRAM. WORKING MEETING Plant - Brunswick Steam Electric Plant, Units 1 and 2 Date - July 21 and 22, 1987  :-

Name Representing Ernest Sylvester NRC/Div. of Reactor Projects Mark Blinson CP&L (July 21 only)

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John Brobson CP&L (July 21'only)

Barbara Teletzke CP&L Patrick Godsey CP&L (July 21 only)

Larry Wheatley CP&L

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lo' Leunis P. van Eeden CP&L Action Tech.

Horace K. Shaw NRC/NRR/EMEB Terry Cook EG&G, Idaho Scott Hartley EG&G, Idaho i

f e-e enum#

ENCLOSURE 2

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I BRUNSWICK STEAM ELECTRIC PLANT, UtilT 1 AND 2 PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COPMENTS 1

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1. VALVE TESTING PROGRAM A. General Questions and Comments i

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1. Are all valves that are Appendix J, type C, leak tested included in the q IST program and categorized A or A/C7 J I

'l CP&L: Yes. They are identified in the submittal as valves with "L" .

test requirements. -

EG&G:' The written response is satisfactory.

2. Prov'ide a listing of the limiting values of full-stroke time for all 3 l power operated valves in the Brunswick IST program for our review. l CP&L: See Valve Table attached.

EG&G: The written response is satisfactory because the limiting stroke time values were provided and reviewed. A general discussion of .

l' the methodology utilized to develop valve stroke time acceptance

l. criteria followed.

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3. Does the control room ventilation system perform any safety-related function? If so,'the appropriate support system valves should be included in the IST program.

CP&L: Our review of this system indicates that it does perform a safety-related function. Based on a thorough review, the appropriate valves will be added to the program in the- next submittal. -

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EG&G: This system is equipped with two air supply and two air exhaust check valves that shut-to prevent'a low pressure condition in the control building during tornado conditions. This is an OPEN ITEM for both the licensee and the hRC staff to determine if these, check valves perform a safety-related function.

B. Service Water System

' 1. Has the~ service water lubricating water system deactivation been completed or is it still scheduled to be completed in late 1987. (See l

valve relief request VR-15)? Does this relief request also apply to Unit 2? ,

r CP&L: Deactivation of the service water lubricating water system has ,

l not been completed. The plant is currently evaluating an additional option regarding this system. This would entail utilizing the current system as a means for normal bearing lubrication but reclassifying the system as non-Q. A back-up loop utilizing pump discharge being recirculated to the bearings would be available should the lube water system fail.

i A plant decision will be made by December 15, 1987, as to which option, with the modification to be implemented in 1988. This

! relief applies to both Brunswick units. l

& EG&G: This is an OPEN ITEM for the licensee to resolve this issue. )

Additionally, the NRC staff position concerning valve sample disassembly / inspection was explained to the licensee.

1 C. Diesel Generator Service Water System 1

1. How are valves SW-272., 273, 274, and 275 verified shut quarterly? I CP&L: SW-V272, 273, 274, and 275 presently cannot be tested. A relief request will be included in the next submittal. .__.

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a* .c EG&G: This is an OpEN ITEM for the licensee to determine a method:to utilize to verify closure of these valves. A valve sample disassembly / inspection program will be considered.

D. Containment Atmospheric Control System =

1. Are. valves CAC-X18A through J equipped with position indication? If not, how is the closed position.' verified during quarterly exercising?

CP&L: CAC-X18A through.J do have-position indication (lights on the

.RTGB).

EG&G: . The written response is satisfactory. Addit,ionally, the position indication will be verified at a refueling outage frequency.

2. -Does valve relief request VR-03 apply to valves 1-CAC-V160 and 1627 CP&L: Yes. This was a typographical error which has been corrected in the plant IST program and will be corrected in the next submittal.

EG&G: The written response is satisfactory. .

10 3. What is'the P&ID location of valves 2-CAC-PV4344 and -PV3457 Should j these valves be identified as SV-4344 and SV-43457 '

CP&L: Located on P&ID D-2515/25015, SH-1A. CAC-SV-4344 is located at A-3 and CAC-SV-4345 is located at A-6. These valves are solenoid valves. They are identified in the plant IST program and will be corrected in the next submittal.

EG&G: The written response is satisfactory.

4. Valve 2-CAC-V170 is listed in the Valve Tables on the wronrP&ID. Is this valve equipped with a solenoid operator instead of an sir operator? _

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CP&L: This is a solenoid valve and is listed on P&ID D-2515, SH-1B.

This' condition has been corrected in the plant IST program and will be included in the next submittal.

EG&G: The written response is satisfactory.

5. Is valve 2-CAC-V171 equipped with a solenoid operator instead of an air operator?

g Cp&L: This is a solenoid valve. This condition has been corrected in the plant IST program and will be corrected in the next submittal.

EG&G: The written response is satisfactory. -

-E. Control Rod Drive Hydraulic System

1. How'are valves C11-115 and 138 verified to close during control rod scram testing?

CP&L: PT-14.2.1 (Single Rod Scram Insertion Time Test) measures rod insertion times. This rod insertion timing detects any problem i,n D the CRD-HCU. During normal operation, the CRD drive water is kept approximately 250 psi above reactor pressure. Cooling water is kept approximately 20 psi above reactor pressure, therefore, during rod insertion, there is approximately 230 psid to close valvo 138. As stated previously, if the valve (138) does not close or there is significant leakage, it will brcome apparent in rod insertion time.

The charging water header is at CRD pump dischtrge pressure, approximately 1400 psig, therefore, valve 115 is not verified to the closed position during rod insertion. The present relief request will need to be revised and another relief request will be written for 115. e mes 4

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'a b , + y-p/li,. ?l EG&G: The w"itten r response is satisfactory concerning the C11-138 _

val'm. .Also, another indication of valve closure is observation f ,f/( -

t ofnopressurespikeinthecoolingwaterheaderduqngnormal(no 3

.-)'q .

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, scram) control rod movement. However, it is an OPEN ITEM for the k*

licensee to determine how valve C11-115 is verified to sTiut.

2. How are valves C11-126 and 127 stroke timed during exercising? )

CP&L: As stated in VR-04, these valves are functionally verified during j rod insertion timing. They are not individually'r.troke timed.

Any stroking problem with these valves will bi detected by an increase in rod instrtion time.

l EG&O The written response is satisfactory. Additionally, the relief request will be expanded to include a discussion of the method utilizedtoveriffsatisfactoryvalvestroketimes. )

l F. Reactor Coolant Recirculation Systv3 ' l

1. Provide a more detailed technical justification for not full-stroke exercising all excess flow check vr1ves quarterly and during cold ,

EO shutdown.

CP&L: Four excess flow check val'ves feed instrumentation that can only be isolated when the plant is in Condition 5 (refueling),

therefore, these valves can only be tested during a refueling outage. Of the remaining excess flow check valves, the larq$

majority feed instrumentation that, if isolated, would place.the i 1

plant in an LCO. The remainder of excess flow check vth es feed instrumentation tha, tre used by Operations to monitor plar,t parameters, therefore, the excess flow check valves cannot be tested quarterly. There are approximately 90 excess flow check valves per unit. Thesevalveshavevari,ingoggreesof >

accessibility and generally require two to three hours per test.  !

Therefore, the number of valves whjch could be tested _during a 1

cold shutdown is small compared with the total population. Our 5

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, experience to date has shown these to be reliable valves. As the testi'ng frequency of 18 months is already specified by Technical Specifications, an increased testing frequency is not warranted.

EG&G: The written response is satisfactory. Additionally, relief ,

request VR-05 will be expanded to provide more techni6a1 information to justify not testing the excess flow check valves quarterly and during cold shutdowns.

2. What is normal position of valves B32-F032A and 03287 (See valve cold shutdown justification VC-01). ,

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CP&L: The normal position of valves B32-F032A and B is open. This i

typographical error will be corrected and included in the next submittal. '

t EG&G: The written response is satisfactory.

G. Nuclear Steam Supply System

1. What is the exercising frequency for the ADS valves? The IST program.

4 Valve Tables, p-19, do not agree with valve relief request VR-07.

CP&L: The current exercising frequency for the ADS valves is at least once per 18 months when at sufficient power. The IST program valve tables will be revised to reflect this change.

EG&G: The written response is satisfactory.

2. Provide a more detailed technical justification for not full-stroke exercising valves B21-F037A through H, J, K, and L during cold shutdowns. ,

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.. l P&L: Full-stroke exercising frequency of valves B21-F037A through H, J, K, and L will be changed to be performed when the plant is in cold shutdown and the drywell is de-inerted.

EG&G: The written response is satisfactory in that the rel.ief request VR-08 will be expanded to provide more detailed technical justification for not full-stroke exercising these valves during those cold shutdowns when the containment is not de-inerted.

H. Hilt pressure Coolant Injection System i

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1.- Provide a detailed technical justification for not full-stroke

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exercising valve 1-E41-F002 quarterly.

I' CP&L: This typographical error will be corrected in the next submittal.

EG&G: The licensee will provide a cold shutdown justification to test valve E41-F002 during cold shutdowns because this valve is located l

insid2 the drywell, is inaccessible during power operation, and failure in the closed position while testing would render an

'{p entire safety system inoperable. *

2. Does valve E41-F019 perform a safety-related function in the closed

position?

i CP&L: No. The only function for this valve in the closed position is to stop water downstream from flow / draining into the CST. i E41-F005 stops the pump discharge from draining back to the CST.

All other lines that tap into this line between the E41-F005 and E41-F019 valves are below the CST water level, therefore, will not drain back to the CST. Thus, this valve has no safety-related function in the closed position.

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1 EG&G: .The written response is incomplete because this valve may be required to close to prevent diversion of HPCI pump suction flow during the automatic system suction switch to the torus supply.

This is an OPEN ITEM for the licensee to determine if this valve must close and, if it must close, a method to verify closure.

3. How is the valve E41-F046 verified to full-stroke open quarterly?

CP&L: Minimum flow valve E41-F012 is stroked during pump operation and a change in pump noise (flow through minimum flow line) is heard indicating flow through the minimum flow line which indicates E41-F046-opens.

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EG&G: This test method does not verify a full-stroke exercise of the

- check valve, therefore, this is an OPEN ITEM for the licensee to investigate an alternate method of testing that will verify the

' full-stroke capability of E41-F046.

4. How are valves E41-V93 and 94 individually verified to close quarterly?

CP&L: As stated in V-05, E41-V93 and 94 cannot be verified closed 50 individually. It is only verified that at least one valve closes. (The boundary was extended to the second valve for this

' I reason.)

b EG&G: The proposed alternate testing is unacceptable, therefore, this is an OPEN ITEM for the licensee to develop an alternate method to utilize to verify valve closure individually. (An option discussed was removal of the valve internals from one of these series check valves.)

5. Review the safety-related function of valve E41-F011 fP& ids D-25023 and f D-2523, SH-1, coordinates F-3) to determine if it should be. included in the IST program and tested to the Code requirements. . i l

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CP&L: The valve receives a close signal upon HPCI initiation along with the E41-F008 to ensure injection into the vessel if HPCI is in the test mode. E41-F011 is redundant because E41-F008 and E51-F022 receive a close signal, therefore, does not need to be added to the IST program. -

EG&G: The NRC staff has determined that safety system full flow test valves should be included in the IST program, therefore, this is an OpEN ITEM for the licensee to investigate including this valve in the IST program and testing it in accordance with Section XI.

6. Provide a detailed technical justification for not full-stroke exercising valves E41-F021 and 022 quarterly.

CP&L:. Valves E41-F021 (HPCI turbine exhaust line isolation valve) and E41-F022 (exhaust drain pot drain line to suppression pool isolation valve) are presently closed by handwheel and verified closed by LLRT. When closing these valves the turbine exhaust line is isolated, therefore, the HPCI system is inoperable. When the HPCI system is inoperable, an LCO is required. A relief request will be written to address compliance to IWV-3522. '

o EG&G: The written response is satisfactory. Additionally, the closure j capability of these stop check valves will be demonstrated using f the manual handwheel during cold shutdowns. )

7. How is valve E41-F045 verified to full-stroke quarterly?

CP&L: Valve E41-F045 (suppression pool suction) is verified open by aligning and running the HPCI system taking suction from the i suppression pool. I EG&G: This test flow path is from the suppression pool, through the pump, and back to the suppression pool through the purpp minimum

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flow line and results in a partial-stroke exercise of this valve, therefore,thisisanOpENITEMforthelicenseetoinIestigatea 9

i method and frequency to full-stroke exercise this valve. (A disas'sembly/ inspection program was' discussed as an acceptable alternate method of exercising.)

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8. How is stroke time measured while exercising valves E41-V8 an'd V9 quarterly? I CP&L: Valves E41-V8 and V9 are stroke timed from when the auxiliary oil "

pump switch is placed in the start position until the indicating  !

lights indicate open. ~

t EG&G: These valves are the HPCI turbine trip / throttle and governor ,

valves and are considered part of the skid mounted assembly, - l therefore, they need not be included as separate items in the IST

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program. The' licensee will delete E41-V8 and -V9 from the  !

program.

9. Review the safety-related function of the following valves to determine if they should be included in the IST program and tested to the Code requirements.

Valve p&ID & coordinates E41-F026 D-25023 SH-2 (A-4)

D-2523 SH-2 (A-4)

E41-F028 D-25023 SH-2 (E-2)

D-2523 SH-2 (E-2)

E41-F076 D-25023 SH-2 (B-8) ]

l D-2523 SH-2 (B-8)

E41-F077 D-25023 SH-2 (B-8)

D-2523 SH-2 (B-8)

CP&L: E41-F026 (condensate pump discharge inboard drain' valve) closes upon HPCI initiation to direct HPCI condenser water from radwaste l to HPCI suction line, therefore, the valve has no safety related I function. - .

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, j E41-F028-(supply drain pot inboard drain valve) closes upon HPCI initiation to isolate the steam line. This is only a 3/4" line, therefore, the steam that would be diverted to the main condenser, if E41-F028 failed open, is minimal and would not impede HPCI operation. l

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E41-F076 and F077-(turbine exhaust vacuum breakers) will open when f there is a vacuum in the HPCI steam exhaust line due to steam condensing. If they were not to open, the differential pressure would cause the exhaust line to fill with torus water and eventually trip the turbine. Therefore, these valves are safety-related and will be added to the IST program.

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EG8G: The written response is satisfactory. Valves E41-F026 and -F028 '

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do not perform a safety-related function and need not be included I in the IST program. Additionally, a cold shutdown justification

'will be provided that addresses the technical concerns associated with exercising valves E41-F076 and F077 during power operation.

I. Core Spray System

! A eo 1. What are the consequences of injecting condensate water into the reactor vessel during cold shutdown? (See valve relief request VR-09.)

CP&L: Prior to injecting condensate water into the reactor vessel, vessel shell temperature must be less than 200 degrees F (Ref. pT-7.1.1A). This condition does not usually occur except for refueling outages.

EG&G: Relief request VR-09 will be expanded to provide more technical information to support the refueling outage exercising frequency, f

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2. Is valve E21-F007B locked open as indicated on P&ID D-25020 SH-17 l- CP&L: Yes (per OP-18). This valve is also indicated locked open in I plant IST program. This typographical error will be corrected in the next submittal.  !

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EG&G: The written response is satisfactory.

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- 3. How are valves E21-F029B and 30B individually verified to close quarterly?

CP&L: As stated in V-05, E21-F029B and 30B cannot be verified closed individually. It is only verified that at least one valve closes (thb boundary was extended to the second valve for this reason).

L EG&G: The proposed alternate testing is unacceptable, therefore, this is an OpEN ITEM for the licensee to develop an alternate method to utilize to verify valve closure individually. (An option discussed was removal of the valve internals from one of these ~

series check valves.)

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J. Residual Heat Removal System

1. Provide a more detailed technical justification for not full-stroke exercising valves E11-F004A, B, C, and D and E11-F006A, B, C, and D quarterly. Why is the exercising frequency for the Unit i valves different than that for the Unit 2 valves? ,

o CP&L: E11-F004 A, B, C, and D and E11-F020 A and B do not receive an  !

I automatic open signal upon LPCI initiation. Tech Specs require both LPCI loops, each having two pumps, to be operable. To close E11-F004 A, B, C, and D and valve E11-F006A, B, C, and D (of the applicable loop) or E11-F008 or E11-F009 the applicable pump receives an automatic stop signal (i.e., E11-F004A and E11-F006A or E11-F008 or E11-F009 closed, 'A' pump will receive a stop signal). Therefore, when one of the valves (E11-F004A, B, C, and D, E11-F020A or B) is closed the applicable pump and/or loop is rendered inop and an LCO must be initiated. -

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a------------__._____ _ - _ _ _ . . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

c.

In order to open E11-F006.A,'B, C, and D; valves E11-F020 A and B and E11-F028 A and B (of the appli. cable loop) must be closed,

! therefore an LCO must be initiated. The next submittal will reflect frequency as cold shutdown.

p .

, EG&G: This'is an OpEN ITEM for the licensee to further investigate exercising these valves during power operation. As indicated in the licensee's response, a cold shutdown justification may be l included in the resubmittal.

2. Why is the exercising direction of valve 1-E11-F016A different than that of valve 2-E11-F016A7 CP&L: The valve is presantly stroked in both directions in both units. "

. This is a typographical error which will be corrected b che next-L submittal.

l EG&G: The written response is satisfactory.

l l 3. Valves 2-E11-F031B and -F031D are listed twice in the Valve Tables, This will be corrected in the next submittal.  !

a CP&L:-

i EG&G: The written response is satisfactory.

4. How are valves E11-F046A, B, C, and D verified to full-stroke exercise quarterly?

CP&L: While the pumps (A, B, C, and D) are running, the applicable minimum flow valve is cycled. A change in flow (verified by j sound) verifies F046A, B, C, or D opens. )

EG&G: This test method does not verify a full-stroke exercise of the check valve, therefore, this is an OpEN ITEM for the , licensee to investigate an alternate method of testing that will verify the full-stroke capability of valves E11-F046A, B, C, and D. f i

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5. How are valves E11-V192'and 193 and valves E11-F089 and 090 individually verified to close quarterly?

1 CP&L: As stated in V-05, E11-V192 and 193 and E11-F089 and F090 cannot l t

be' verified closed individually. It can'only be verified that at i least one valve closes (the boundary was extended to the second valve for this reason).

-EG&G: The proposed alternate testing is unacceptable, therefore, this is an OpEN ITEM for the licensee to develop an alternate method to utilize to verify valve closure individually. (An option discussed was removal of the valve internals from one of these

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series check valves.) -

6. Provide a detailed technical justification-for not exercising valves E11-F022;and 023 quarterly in accordance with the Code requirements.

CP&L: The head spray mode of RHR is no longer used and the valves have been.deenergized.

p EG&G: The written response is satisfactory.

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- 7. Review the safety-related function of the following valves to determine if they should be included in the IST program and tested to the Code fl

[. requirements

Valve P&ID & coordinates E11-F010 D-25025 SH-1B (D-8)

D-2525 SH-1B (D-8)

E41-F052A D-25025 SH-1A (E-8)

D-2525 SH-1A (E-8)

E41-F052B D-25026 SH-2A (D-1)

D-2526 SH-2A (D-1) -

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Valve P&ID & coordinates E11-F078 D-25026 SH-2A (C-7)

D-2526 SH-2A (C-7)

E11-F079 D-25026 SH-2A (C-7) _ i D-2526 SH-2A (C-7)'

CP&L: E11-F010 (RHR system divisional cross-tie isolation valve) is

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locked closed and racked out during normal operation, therefore, is not safety-related.

E11-F052A and B (steam pressure reducer isolation valve). The steam condensing mode of RHR has been removed from the RHR ,

system. These valves were only used during steam condensing. ,

They are now locked closed, therefore, they are not safety-related.

' E11-F078 (RHRSW inboard injection valve), E11-F075 (RHRSW check valve) - The RHRSW injection is considered the ultimate heat sink and is safety-related. A relief request will be written for testing these valves because of salt water contamination into the RHR system. .

':n EG&G: The written response is satisfactory for valves E11-F010,

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E11-F052A, and -F052B and they need not be included in the IST program. It is an OPEN ITEM for the licensee to determine an alternate test method and frequency for valves E11-F075 and E11-F078.

Additional Comment: Residual heat removal system valves E11-LVF053A and -LVF053B do not perform a safety-related function and will be deleted from the IST program.

K. Reactor Water Cleanup System -

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1. How is valve G31-F039 verified to close quarterly? .___

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CP&L: G31-F039 is not verified to close quarterly. RWCU is normally in operation and would require shutdown to test quarterly.

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Additionally, the.only means to test is by injecting water into the downstream volume which would.give test personnel only a one

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check valve isolation from feedwater at power. It-is tested at cold shutdown per PT-14.6.1. A relief request will-bs included in the next submittal. j EG&G: A cold shutdown justification will be provided that explains why this valve will be verified to close during cold shutdowns.

L. Reactor Core Isolation Cooling System ,

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Credit is not taken for the RCIC system in the Additional Information:

t ' Brunswick FSAR.

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1. Would failure of valve E51-F007 in the closed position during quarterly testing render an entire safety system inoperable?

CP&L: Yes.

'? EG&G: The written response has been revised due to the additional ,

information. The answer to the question is - No.

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2. How are valves E51-V72 and 73 individually verified to close quarterly?

I CP&L: As stated in V-05, E51-V72 and 73 cannot be verified closed individually. It is only verified that one valve closes. (The boundary was extended to the second valve for this reason.)

EG&G: The written response has been revised due to the additional information. These valves are not safety-related and need not be 1 included in the IST program.

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3. How is valve E51-V88 verified to full-stroke open quarterly?

CP&L: E51-V'88 is verified to full-stroke open by operation of RWCU which is normally in service.

EG&G: The written response has been revised due to the additional  !

information. This valve performs a containment isolation valve function only and will be tested accordingly.- )

4. How is the stroke time measured while exercising valves E51-V8 and -V9 quarterly?

CP&L: The E51-V8 (RCIC trip and throttle valve) is motor operated and ,

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e is timed in PT-10.1.1, Rev. 35, step 7.3.40 in accordance with

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f IWV-3413a by normal means'. The E51-V9 (RCIC governor valve) is a f hydraulically operated valve and its design does not allow full-stroke timing. A relief request will be submitted.

EG&G: The written response has been revised due to the additional information. These valves are not safety-related and need not be included in the IST program. . j

• y eo

5. Provide a more detailed technical justification for not full-stroke exercising valves E51-F001 and 002 to the closed position quarterly.

CP&L: Valves E51-F001 (turbine steam exhaust to suppression pool valve) and E51-F002 (vacuum pump discharge to suppression pool valve) are presently closed by handwheel and verified closed by LLRT. When closing these valves, the turbine exhaust line is isolated, therefore, the RCIC system is inoperable. When the RCIC system is inoperable, an LCO is initiated. A relief request will be written to address compliance to IWV-3522.

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• ' ' EG&G: A cold shutdown justification will be provided explaining that the c.losure capability of these stop check valves will be demonstrated using the manual handwheel during cold shutdowns.

'6. How is valve E51-021 verified to full-stroke open. quarterly? ..

CP&L: E51-F021 is verified. full-stroked quarterly during performance of PT-10.1.1, Rev. 35, note and steps 7.3.34 through 7.3.35.2.

Verification is by flow changes heard upon stroking of minimum flow bypass valve E51-F019. q l

EG&G: The written response has been revised due to the additional information. This valve is not safety-related and need not be -

included in the IST program. -

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7. How is valve E51-030 verified to full-stroke open quarterly?

CP&L: E51-F030 is verified full-stroked quarterly during performance of j PT-10.1.1, Rev. 35, note and steps 7.3.34 through 7.3.35.2. )

Verification is by flow changes heard upon stroking of minimum flow bypass valve E51-F019.

.{o EG&G: The written response has been revised due to the additional information. This valve is not safety-related and need not be included in the IST program. 4

8. Review the safety-related function of the following valves to determine if they should be included in the IST program and tested to the Code requirements:

Valve p&ID & coordinates E51-F011 D-25029 SH-1 (F-4)

D-2529 SH-1 (F-4) _

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- _ - - - - _. ____m.__ ___ _ _ . - _ _ _ _ _ _ _ _ _ _ __

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• ' ' Valve P&ID & coordinates E31-F046 D-25029 SH-1 (B-4) i D-2529 SH-1 (B-4)  !

E51-F047 D-25029 SH-2 (E-6)

D-2529 SH-2 (E-6) -

L E51-F063 D-25029 SH-2 (B-8) ,

D-2529 SH-2 (B-8) l E51-F064 D-25029 SH-2 (B-8) 0-2529 SH-2 (B-8)

CP&L: E51-F011 has been included in the IST program and is currently tested quarterly during performance of PT-10.1.1, Rev. 35. ]

$51-F046(coolingwatersupplyvalve)epensuponRCICinitiation a-to supply cooling water to the lube oil cooler and introduces water into the condenser for steam condensing. If this valve was l to fail in the closed position lube oil would overheat and the )

condenser would not be able to draw vacuum eventually RCIC I turbine, therefore, valve is safety-related and will be added to the IST program.

i

o E51-F047 is the condensate pump discharge check valve. If this i j valve was to fail in the closed position during RCIC initiation, j the condenser would fill and eventually trip the turbine, therefore, this valve is safety-related and will be added to the ]

• IST program.

E51-F063 and F064 (turbine exhaust vacuum breakers) will open when there is a vacuum in the HPCI steam exhaust line due to steam condensing. If they were not to open, the differential pressure would cause the exhaust line to fill with torus water and eventually trip the turbine. Therefore, these valves are safety-related and will be added to the IST program. _ )

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--_ --_m_.--____.-_______m._

EG&G: -The written response has been revised due to the additional information. These valves are not' safety-related and need not be includ'ed in the IST program.

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M. Service Water System ,

1. Are valves SW-V136,137,138, and 139 fail-safe tested in accordance with the Code requirements 7 CP&L: SW-V136, 137, 138, and 139 are fail-safe tested in accordance with Code requirements.

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EG&G: 'The written response is satisfactory. - -

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l' l} 2. Review the safety-related function of the following valves to determine if they should be _ included in the IST program and tested to the Code.

requirements:

l' Valve P&ID & coordinates l

E11-F068A D-25037 SH-1 (D-1)  !

• D-2537 SH-1 (D-1) -

9 D-25037 SH-2 (D-8)

E11-F068B

D-2537 SH-2 (D-8) f E11-F073 D-25037 SH-2 (C-2)

D-2537 SH-2 (C-2) l 1-E11-V124 D-25037 SH-2 (B-6) 3 i

CP&L: Valves E11-F068A and B are used to control service water flow / pressure through the RHR heat exchangers, therefore, these valves are exempt per IWV-1200a.  ;

e Valves E11-F073 (RHRSW outboard injection valve) - reference J. 7, valves E11-F078 and F075. '

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1-E11-V124 should be SW-V124 and is tested.

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EG&G: Valves E11-F068A and -F068B are not exempt from testing because they dre directly in the flow path' utilized for long term reactor cooldown. Modifications to the control circuits that. allow full-stroke exercising these valves have been completed in Unit 1, therefore, E11-F068A and -F068B will be included in the Unit 1 IST program and tested in accordance with Section XI. 'ArIlief request will be provided explaining that the control modifications should be completed in January, 1988, in Unit 2 and that the valves will be tested in accordance with Section XI after that time.

It is an OpEN ITEM for the licensee to determine an alternate test method and frequency for valve E11-F073. Also see Question J.7 of, this trip report.

The written response for valve 1-E11-V124 is satisfactory.

N. Standby Liquid Control System

1. How are valves C41-F033A and B verified to full-stroke open during quarterly testing? '

.o t CP&L: C41-F033A and B (SLC discharge check valves) are verified to full-stroke open on a monthly frequency (PT-6.1-1 and PT-6.1-2) by proper flow indication for each pump (Unit 1) and by proper discharge pressure for each pump (Unit 2).

EG&G: The written response is satisfactory concerning Unit 1.

Concerning Unit 2 - a relief request will be provided that explains that system modifications to allow flow measurements will be performed approximately January, 1988.

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e emme--

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O. Fuel Pool Cooling and Filtering System

1. How are valves G41-V8 and V24 verified to close during quarterly exercising?

l CP&L: When the fuel pool cooling pumps are shut-off, these-valves can be heard going to the closed position.

EG&G: The written response is satisfactory.

P. Instrument Air Supply System

1. Provide a more detailed technical justification for not verifying ~

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closureofthecheckvalvesidentifiedinvalvereiiefrequestVR-11 during cold shutdowns.

CPL: B21 check valves are now being verified closed each cold shutdown per PT-31.1. The PT will be revised to verify the remaining RNA valves in the closed position and both B21 and RNA valves in the open position.

The written response is satisfactory. Additionally, it is an EG&G:

OPEN ITEM for the licensee to evaluate the adequacy of relief request VR-11 and revise as necessary.

2. The P&ID sheet identification is incorrect for valves 2-RNA-5261 and -5262 in the Valve Tables.

CP&L: These are correct in the plant IST program and will be included in the next submittal.

RNA-SV-5261 D-7077, SH-3B '

RNA-SV-5262 D-7077, SH-3A -

EG&G: The written response is satisfactory. __,

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3. Provide a more detailed technical justification for not verifying closure of. the check valves identified in valve cold shutdown justification VC-09 quarterly?

CP&L:- The only way to verify the valves are closed is by_ isolation of one division of instrument air and opening a vent j.nside the drywell. The drywell is inerted during operation. (Ref. PT-31.1)

EG&G: The written response is incomplete in that the requirement to maintain the nitrogen concentration in the drywell is not addressed nor is the fact that the valves are inaccessible. VC-09 will be revised to contain this type of technical information. {

Q. Containment Atmosphere Monitoring' System -

1. Provide a more detailed technical justification for not exercising valves CAC-SV1225B and 3440 quarterly during power operation. (See valve cold shutdown justification VC-10.)

i j

CP&L: These valves are located in the common return line to the drywell for CAC-AT-1260 and 1261. Stroking these valves will inop both

{o monitors leaving only the CAC-AT-1262. Tech Spec Table 3.3.5.3-i

,[ requires a minimum of two monitors operating in conditions 1, 2, and 3.  ;

. l t EG&G: The written response is satisfactory. VC-10 will be revised to contain this information.

i R. Standby Gas Treatment System

1. Is remote position indication verified for valves SGT-V8 and 9 as required by the Code? ,

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_au..--,-- _ - -

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• ' ' CP&L: Yes, per PT-15.7. This is corrected in the plant IST program and 1 will be included in the next submittal.

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EG&G: The written response is satisfactory.

S. Diesel Generator Start _ing Air System .

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1. Should relief request VR-13 be referenced on page 5 of the Unit 2 Valve i

Tables?

CP&L: Yes. The F and V tests are deleted.

EG&G: The written response is satisfactory.

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2. How are the diesel generator starting air solenoid valves individually verified to full-stroke exercise quarterly?

CP&L: During diesel start, the pressure is verified to drop in each bank and while the diesel is running, jet assist is activated and the pressure drop is verified.

, EG&G

The written response is satisfactory. Additionally, VR-13 will i be expanded to explain that each starting air header is equipped with pressure instrumentation with which the pressure drop can be readily seen. ,

3. How are the following valves verified to shut quarterly?

2-DSA-V141 2-DSA-V145 2-DSA-V149 2-DSA-V153 2-DSA-V142 2-DSA-V146 2-DSA-V150 2-DSA-V154 CP&L: These valves cannot be tested quarterly. A relipf request will be written accordingly. .-

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_I:_ _XY

-EG&G: The written response is incomplete because it is possible that these' valves are being verified to shut during performance of an exist'ing diesel surveillance procedure, therefore, it is an OPEN ITEM for the licensee to determine a method and frequen y for verifying closure of these valves. -

4. Review the safety-related function of the following valves to determine if they should be included in the IST program and tested in accordance with Section XI.

Valve P&ID & coordinates PRV-1689 D-2265 SH-1A (E-5)

PRV-1691 D-2265 SH-1A (E-5)

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PRV-1675 D-2265 SH-1B (E-5)

PRV-1676 D-2265 SH-1B (E-5)

PRV-1664 D-2266 SH-2A (E-5)

+ PRV-1665 D-2266 SH-2A (E-5)

PRV-786_ D-2266 SH-2B (E-5)

PRV-789 D-2266 SH-2B (E-5)

CP&L: These are pressure regulating valves, therefore, exempt per IWV-1200(a).

• EG&G: The written response may be incorrect because these may be valves of a testable design, therefore, it is an OpEN ITEM for the licensee to determine if these valves are testable and if they have a required fail safe position since they are installed in the starting air supply lines to the diesels.

2. PUMP TESTING PROGRAM

1. How are the standby liquid control pumps tested quarterly if they are required to remain aligned to the control tank during plant operation (See pump relief request PR-03)?

l CP&L: This statement has no bearing on the request for relief and will l

be removed. This relief request will be deleted for.1[ nit 1 as 25 l

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flow instrumentation has been installed. Unit 2 flow instr.umentation will be installed.in the next refueling outage.

The next submittal will reflect these changes to the plant IST program.

EG&G: The written response is satisfactory. -

2. How is individual pump flow rate measured during quarterly testing of the service water pumps?

CP&L: Individual pump flow rates for the service water pumps are measured quarterly by alignment of one pump on the nuclear header with no other service water pumps aligned to it at this time.

• Reference flow rates are set by positioning'of the RBCCW-SW heat ~

exchanger outlet valves.

EG&G: The written response is satisfactory.

3. Has the service water lubricating system deactivation been completed or is it still scheduled to be completed in late 1987? Does pump relief request PR-05 apply to these pumps or does Code Exception Number 47

.7, e CP&L: Reference B.1 about the service water lubricating system.

! EG&G: Reference B.1 of this trip report. This is an OpEN ITEM for the licensee to resolve this issue. (The service water lubricating system may not be required to operate the support service water pump operation.)

4. In reference to the diesel fuel oil transfer pumps, the NRC staff position is that lack of installed instrumentation is not an acceptable long term justification for not measuring the Code required parameters on pumps that perform a safety-related function. The _

26 h - - - - . _ _ . _ _ . _ . . _ _ _ _ .

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Unit 2 Code Exception Number 3 implies that modifications are in progress to permit testing to comply with this position. Is this true and, if so; when will the modification be completed?

CP&L: . Plant modifications'will be initiated by the end of 1987~and implementation completed by the end of 1988. - -

]

I EG&G: The written response is satisfactory. 'A relief request will be provided to explain that when modifications are completed, all applicable parameters will be measured. l

5. Are lubricant pressures or levels observed during pump testing for all pumps in the Brunswick IST program? If not, provide the specific (

~

f technical justification for not doing so.

r Cp&L: The lubricant pressures or levels in the pumps in the IST program i 'are observed during pump testing with the exception of the diesel generator fuel oil transfer pumps which do not have an external means of lubrication.

EG&G: The written response is satisfactory. The IST program will be

io revised to indicate that this is being done.

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M i 27 El r 1---- ------ - ~ ~ ~ ~

MEETING

SUMMARY

DISTRIBUTION

Docket' No(s):250-325/3241 NRC PDR Local PDR PD 11-1 r/f E. Adensam Attorney, 0GC P. Anderson E. Jordan J. Partlow ACRS (10)

Project Manager Ernest Sylvester NRC PARTICIPANTS Horace K. Shaw Terry Cook (EG&G, Idaho)

ScottHartley(EG&G, Idaho) cc: Applicant & Service List

_ _ _ _ .