ML18033A770
| ML18033A770 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/19/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033A768 | List: |
| References | |
| NUDOCS 8905260352 | |
| Download: ML18033A770 (56) | |
Text
TABLE OF CONTENTS
- 1. 0 INTRODUCTION
~Pa e
.1 General....................................................
1 1
1.2 Inspection Interval and ASHE Edition and Addenda...........
1 1.3 Techni,cal Specification Requirements.......................
1 1.4 Past Reviews and Approvals of IST Program..................
2 1.5.
Sumnary Results............................................
2 2.0 EVALUATION
.1 Scope......................................................
11 2
2.2 Pump Testing Program.............;.........................
12 2.2.1 2.2.2 Program (Excluding Relief Requests).....
Relief Requests.........................
~ ~ ~ ~ ~
12
~ ~ ~ ~ ~
12 2.3 Valve Testing Program......................................
20 2.3.1 2.3.2 Program (Excluding Relief Requests).....
Relief. Requests.........................
~ ~ ~ ~ ~ 20
~ ~ ~ ~ ~
20 APPENDIX A Systems That Should Be Considered In Identifying Pumps and Valves To Be Inservice Tested APPENDIX B Drawing Listing
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+y*y4 UNITEDSTATES NUCLEAR REGULATORYCOMMISSION WASHINGTON,D. C. 20555 ENCLOSURE SAFETY EVALUATION REPORT BY THE UNITED STATES NUCLEAR'REGULATORY CONMISS ION REGION II RELATED TO THE INSERVICE TESTING PROGIVN TENNESSEE VALLEY AUTHORITY
,BROWNS FERRY NUCLEAR PLANT UNITS 1 2
AND 3 DOCKET NOS. 50-259, 50-260 AND 50-296
- 1. 0 INTRODUCTION
- l. 1 General This report provides the NRC staff safety evaluation of the Browns Ferry Nuclear Plant, Units 1, 2, and 3
(BFN 1, 2, 8 3) program for inservice testing (IST) of pumps and valves.
The current program was submitted to the NRC by the Tennessee Valley Authority (TVA or the licensee) in a letter dated March 25, 1988.
The program describes the IST the licensee will perform to meet the requirements of the Code of Federal Regulations (10 CFR 50.55a(g))
and.contains requests for relief from certain of the requirements.
It was submitted to the NRC pursuant to obtaining approval of the relief requests.
The 10 CFR 50.55a(g) requirements considered by the staff in performing the evaluation specify that the licensee implement an IST program for pumps and valves in accordance with Section XI of the ASIDE Boiler and Pressure Vessel Code (ASME Section XI or the Code).
Criteria are given for determining the edition and addenda of the Code that apply for a given unit.
10 CFR 50.55a(g)(5) provides that the Commission may grant the licensee relief from requirements of the Code upon making necessary findings.
In practice, the NRC staff evaluates a licensee's entire IST program along with the licensee's relief requests in determining whether relief should be granted.
The staff's evaluation and their conclusions are suIImarized in Section 1.5 below and are described in detail in Sections 2.0 and 3.0.
The c'onclusions represent the staff's determinations regarding the granting of relief.
The granting of relief is based upon the fulfillment of the commitments made, by the licensee in its basis for each relief request and the alternative proposed testing.
1.2 Ins ection Interval and ASIDE Edition and Addenda 10 CFR 50.55a(g) specifies the Code edition and addenda to apply to a facility for a specified term, normally a 120-month interval.
The dates for the term and the applicable edition and addenda of the Code are determined based on the
operating license date.
The TYA program specifies that it covers the 120-month interval from August 31.
1982 through August 31, 1992 and that it is in accordance with ASME Section XI (80W80).
This is not in accordance with the requirements of 10 CFR 50.55a(g).
In a letter to the Comnfssfon dated April 6, 1983 and supplemented in a letter dated February 17, 1988, TUA requested an exemption to permit use of the interval and Code revision stated fn their program.
That exemption has been approved by the Commission in a letter dated March 18, 1988.
The evaluation herein fs based on the code edition and addenda and the interval dates stated in the licensee's program and approved in the exemption.
1.3 Technical S ecfffcation Re uirements The BFN Technical Specifications provide no reference, direct or indirect, to inservice testing requirements of the Code.
1.4 Past Reviews and A
rovals of IST Pro ram The licensee has previously submitted programs for NRC review (e.g., submittals of August 31, 1982 and October 1, 1984 and December 23, 1986).
The previous NRC reviews were not completed.
Consequently, there was no NRC approval of these programs or relief requests.
The March 25, 1988 submittal addressed herein contains the licensee's most recent IST program and relief requests.
1.5 ~55 15 The NRC staff found that the licensee's program, exclusive of their relief
- requests, was acceptable.
One relief request, identified as PV-30 was partially denied for lack of a sufficient basis.
for relief request PV-21, the licensee was informed that the. relief would be in accordance with a separate staff determination for exemption from a similar 10 CFR 50, Appendix J requirement.
For relief requests PV-3, 4 and 5; relief was granted based on conditions identified in the staff's evaluation.
It is our understanding that the licensee is in agreement with these conditions.
The conditions have not been formally documented by the licensee,
- however, and are included fn this SER to assure that they are formally recognized.
In each instance, relief is granted only ff the conditions are met.
The remaining relief requests were granted without condftfon.
Each granting of relief is based on the fulfillment of comftments made by the licensee in its basfs for each relief request.
This is fn addftion to any conditions identified by the staff for the granting of conditionally granted requests.
The staff's findings with regard to individual relief requests are summarized in Table 1.5 and described in detail in Sectfon 2.0 of this SER.
The staff's evaluation of the licensee's program utilized previously submitted drawings.
Based on discussions with licensee personnel, it is our understanding that there have been changes to the drawings which will require further revision to the IST program.
The drawing changes were the result of modifications fn hardware, correction of drawing errors and the renumbering of some valves.
Licensee personnel have advised us that they will revise their
program to reflect these changes and that the revisions needed to assure that pumps and valves are correctly tested will be completed'by startup.
The licensee has indicated that there will be few changes to valve testing from the program revisions and that the testing, in principle, will remain the same as in the current program.
On this basis, the staff considers that a formal NRC safety evaluation of the changes associated with the drawing revisions will not be required, but that the changes will be subject to Region II inspection to assure that they are consistent with the program evaluated by the staff.
Table 1.5 Summary of Relief Requests Relief Request Number PV-1 PV-1 PV-2 SER Section 2.2.2..1 2.2.2.1 2.2.2.2 ASIDE Section XI Requirements and Subject Pum or Valve Number IWP-3100, 3300 and 3500 bearing temperature measurements for all pulllps IWP-3100, 3300 and 3500 lubricant oil level or pressure observation for
- RHR, RHRSW, CS and DFT pumps IWP-3300 inlet and differential pressure measurements for DFT and SLC pumps Alternate Test Method quarterly vibration velocity measurements on pumps quarterly vibration velocity measurements on pumps Discharge flow and pulllp vibration for DFT.
Discharge pressure for SLC Relief Action by USNRC Gr anted IAM 50.55a(g)(6)(i)
Granted IAW 50.55(a)(3)(ii)
Granted IAM 50.55(a)(3)(i)
PV-3 2.2.2.3 IMP-3500(a) five minute stabilizing run time for SLC and DFT pumps Two-minute run time for SLC pumps, immediately following 15 minute functional test.
Perform DFT pumps test with five-minute stabilization at least every six months Granted conditionally IAM 50.55(a)(3)(i)
IAW - In accordance with 10 CFR
Relief Request Number PV-4 SER Sect<on 2.3.2.1 ASME Section XI Requirements and Subject Pum or Valve Number IMY-3416 requirements for exercising a valve prior to returning a system to operable status and IWV-3417(b) requirements for cot rective action and retesting on failed valves prior to startup.
Alternate Test Method As specified by TS Relief Action by USNRC Granted conditionally IAM 50.55a(a)(3)(1)
PV-5 PV-5 PV-'5 2.2.2.4 2.2.2.4 2.2.2.4 Table IMP-4110-1 instrument accuracies for all pumps except DFT pumps Table IMP-4110-1 instrument accuracies for DFT pumps IWP-4120 full scale range requirements for all pumps Utilize installed instruments plus vibration velocity measurements Calculated flow Utilize installed instruments Granted conditionally IAM 50.55a(a)(3)(i)
Granted conditionally IAM 50.55a(a)(3)(i)
Granted conditionally IAM
- 50. 55a(a) (3) (i )
PV-5 2.2.2.4
'WP-4150 and Table IWP-3100-2 requirements for measur ement of vibration displacement on all pumps Utilize vibration velocity measurements Granted conditionally IAW 50.55a(a)(3)(i)
PV-5 PV-6 2.2.2.4 2.3.2.2 Table 3100-2 allowable ranges of flow and differential pressure for all pumps IWV-3410 quarterly exercising and stroke timing (including trending)
ADS valves Increase high value alert range of 1.02 to 1.05 and 1.03 to 1.06 Per TS 4.6.D.2 And verify stroke time not exceeding 2 seconds Granted conditionally IAW 50.55a(a)(3)(i)
Granted IAW 50.55(g)(6)(i)
IAW - In accordance with 10 CFR
Relief Request Number SER Section ASIDE Section XI Requirements and Subject Pum or Valve Number Alternate Relief Test Action by Method USNRC PV-7 PY-8 PV-9 PV-10 P V-11 2.3.2.3 2.3.2.4 2.3.2.5 2.3.2.6 2.3.2.7 IMV-3521 quarterly exercising of HSRV discharge pipe vacuum breakers IWV-3521 and 3522 quarterly closure testing of FM valves 3-554, 558, 568 and 572 IWV-3521 and 3522 quar terly exercising to open and closed positions for SLC check valves63-525 and 526 Same as PV-8 but for Recirculation System valves68-508,
- 523, 550 and 555 Same as PV-8 but for RMCU valves69-579 and 624 Test only at cold shutdowns when drywell is deinerted Leak test at refueling outages Verify opening per TS 4.4.A.2.C closure by leak testing each refueling outage Leak test at refueling outages Leak test at refueling outages Granted IAW 50.55a(3)(ii)
Granted IAW 50.55a(a)(3)(fl)
Granted IAM 50.55a(a)(3)(ii)
Granted IAW 50.55a(a)(3)(ii)
Granted IAW 50.55a(a)(3)(ii)
PV-12 2.3.2.8 IWY-3417 full stroke time testing for RHRSW valves 23-34, 40, 46 and 52 (throttle valves)
Stroke time from a reference position Granted IAM 50.55a(a)(3)(i)
PV-13 2.3.2.9 Same as PV-8 but for RHRSM valves23-601,
- 603, 605 and 607 Verify closure every 24 months by a method such as disassembly or acoustic testing Granted IAM 50.55a(a)(3)(ii)
IAW - In accordance with 10 CFR
Rel ief Request Number PV-14 PV-15 SER Section 2.3.2.10 2.3.2.11 ASHE Section XI Requirements and Subject Pum or Valve Number Same as PY-8 but for EECW (67-) and RCW (24-) valves as follows:
67-541, 542, 584, 585, 648) 649, 657, 659, 660, 528, 529, 634, 635, 521, 522, 627, 628, 507, 508, 502, 622>> 619, 656, 558, 559, 638>> 639) 600) 601) 630) 631, 624, 625, 514, 515, 671, 679, 638 3-24-831, 833, 796, 798 3-67-639, 694) 695) 696, 703, 704, 705, 724, 725, 726, 771, 772) 774) 775) 761, 706; 715, 716, 713, 714, 723, 762, 764, 765, 737, 738, 735, 736 Same as PV-8 but for RBCCW valve 70-506 Leak test at refueling outages Granted IAW 50.55a(a)(3)(ii)
Alternate Relief Test Action by Method
'SNRC Verify Granted closure IAW every 50.55(a)(3)(ii) refueling outage by a method such as disassembly or acoustic testing PV-16 2.3.2.12 Same as PV-8 but for HPCI valve 73-559 and RCIC valve 71-547 Leak test at refueling outages Granted IAW 50.55a(a)(3)(ii)
PV-17 2.3.2.13 IWY-3513 requirements for testing an additional quantity of valves following failures in set point tests.
For all NSRVs Test valves Granted per TS 4.6.D.1 IAW Determine both 50.55a(a)(3)(i) as found and as left set pressures before startup or within 120 days of removal, and assess failures to determine
. need for additional testing PV-18 2.3.2.14 Same as PV-8 but for.HPCI valves73-603 and 609 and RCIC valves71-580 and 592 Leak test at Granted refueling IAW outages 50.55a(a)(3)(ii)
IAW - In accordance with 10 CFR
Relief Request Number SER Section ASME Sectfon XI Requirements and Subject Pum or Valve Number Alternate Rel ief Test Action by Method USNRC PV-19 2.3.2.15 IWV-3521 and 3522 quarterly exercising to open and closed positions for HPCI check valves73-633,
- 634, 635 and 636 and RCIC check valves71-597,
- 598, 599 and 600 Verify opening and closing functions each refueling outage by disassembly acoustics or other positive means Granted IAM 50.55a(a)(3)(lf)
PV-20 2.3.2.16 IWV-3521 and 3522 quarterly exercising to the open position for HPCI valve 73-517 and,RCIC valve 71-508 Verify opening function each refueling outage by disassembly, acoustics or other positive means Granted IAM 50.55a(a)(3)(li)
PV-21 2.3.2.17 Performance of IWY-3413 seat leakage tests on single disk gate valves with pressurization in the direction which they perform their function for the following valves:
MS valve 1-55 RHR valves 74-61, 75 HPCI valves 73-2, 26 RCIC valves 71-21, 17 RW valves 77-2A, 15A Test with pressure in direction opposite that for valve to perform function Licensee referred to NRC evaluation perform Appendix J exemption request PV-22 2.3.2.18 Same as PV-8 but for FPC check valves78-526 and 527 Verify closure Granted each refueling IAM outage by 50.55a(a)(3)(i) dfsassembly, accoustics or other positive means IAW - In accordance with 10 CFR
Relief Request Number PV-23 SER Section 2.3.2.19 ASIDE Section XI Requirements and Subject Pum or Valve Number IWV-3410 quarterly stroke timing for CRD valves85-39A and 39B and IWV-3521 quarterly exercising for CRD valves85-589, 597, 616 and 617 Alternate Test Method Stroke time and exercise test per TS 4.3.C.
Closure test 85-589 and 597 each cold shutdown by disassembly, acoustics or other positive means Relief Action by USNRC Granted IAM 50.55a(a)(3)(i)
PV-24 PV-25 2.3.2.21 IWY-3417(a) trending and test frequency increases for all rapid acting valves (stroke times of 2 seconds or less) in the SAW(, CI, HPCI, CAD, DGAS, SW, RHRSW and TIP systems 2.3.2.20 Same as PY-8, but for CA check valves32-336,
- 2521, 2163 and 2516 Leak test at refueling outages Rapid acting valve stroke times will not be trended but their maximum specified stroke times will be 2
seconds Granted IAW 50.55a(a)(3)('ii)
Granted IAW 50.55a(a)(3)(i)
PV-26 2.3.2.22 Same as PV-8 but for CI valve X-35f Leak test at refueling outages Granted IAM 50.55a(a)(3)(ii)
PY-27 2.3.2.23 IMV-3521 and 3522 quarterly exercising RHR testable check valves 74-54 and 68 and CS testable check valves 75-26 and 54.
Exercise at cold shutdowns in which the containment is deinerted, time permitting Granted IAM 50.55a(a)(3)(ii)
PV-28 2.3.2.24 Same as PY-8 but for CRD check valve 85-576 Leak test at refueling outages Granted IAM 50.55a(a)(3)(ii)
IAW - In accordance with 10 CFR
10 Relief Request Number ASIDE Section XI SER Requirements and Subject Section Pum or Valve Number Alternate Test Method Relief Action by USNRC PV-29 2.3.2.25 IWV-3423 leak testing at maximum function differential pressure or adjustment of measured leak rates to maximum function differential pressure.
MS valves 1-14, 26, 37 and 51.
Leak test per Granted TS IAW 50.55(a)(3)ii)
PV-30 2.3.2.26 Same as PV-9 but for RHR valves74-661 and 662 and for CAD valves84-600, 601, 602. 603, and 617 Leak test at refueling outages to Verify closur e.
Verify opening at cold shutdowns provided the containment
's entered Granted for RHR valves and closure testing CAD valves.
Denied for open testing CAD val ves
'AW 50.55a(a)3)(ii)
PV-31 2.3.2.2. 7 Same as PV-8 but for RCIC check valve 71-589 and HPCI check valve 73-625 Closure test at refueling outages Granted IAW 50.55a(a)(3)(ii)
IAW - In accordance with 10 CFR
11 2.0 EVALUATION 2.1
~Sco e
The Browns Ferry IST program submitted by TVA was reviewed and evaluated by the NRC staff to verify that all pumps and valves required to be tested by the Code are included in the program and that the periodic testing required by the Code is specified for each, except where relief from the Code requirements is requested.
Each of the relief requests described in the program was evaluated to determine if the licensee's bases and proposed alternative testing adequately support a
finding to grant the relief.
The review and evaluation of the program and its included relief requests was performed as follows:
(I)
Systems containing ASHE class pumps and/or valves apparently needed for safe shutdown or to mitigate the consequences of an accident were determined from a review of the Final Safety Analysis Report (FSAR).
An informal guidance list developed by the NRC was used as an aid in the review.
The list is given in Appendix A.
(2)
Utilizing design and functional information from piping drawings and the FSAR and criteria given in ASHE Section XI, the pumps and valves apparently required to be inservice tested was established.
A list of drawings utilized is provided in Appendix B.
(3)
Coincident with (2) above, the IST program was reviewed to determine if it
~ contained the pumps and valves being identified.
(4)
Utilizing ASHE Section XI criteria and system functional information described in the FSAR, the IST program was reviewed to determine if appropriate testing is specified for each pump and valve.
(5)
The relief requests were reviewed to determine if they accounted for any deficiencies identified in the IST program and if the bases and alternate testing proposed were adequate to justify granting relief.
(6)
The licensee's justifications for testing certain valves at cold shutdown, rather than quarterly, were reviewed to verify that they were adequately based.
(7)
Comunications between TVA and the staff were held throughout the evaluation to aid in understanding the functioning of the systems and hardware involved and information presented in the program itself.
Throughout this safety evaluation report, abbreviations are utilized in place of plant system names.
A list of the abbreviations and corresponding system names is included in the Drawing Listing in Appendix B.
12 2.2 Pum Testin Pro ram 2.2.1 'ro ram, Excludin Relief Re uests The NRC staff review determined that the program specifies the periodic testing required by the Code, except where relief from the Code requirements has been requested.
2.2.2 Relief Re uests A
licable to Re uirements in Code Subsection IWP 2.2.2.1 PV-1 Measurin Bearin Tem eratures and Observin Lube Oil Level Pressure Relief Re uest The licensee has requested relief from Code (IWP-3100, 3300 and 3500) requirements for annual measurement of stabilized bearing temperature for all of the following pumps:
Licensee's Basis for Re uestin Relief The RHR, CS, and RHRSW pump bearings are lubricated by water supplied by the pump itself and satisfactory pump operation is indicative of sufficient bearing lubrication.
HPCI and RCIC have oil cooled bearings, but these pumps cannot be
'perated long enough to reach stable bearing temperatures without overheating the torus and causing plant shutdown.
SLC and OFT bearings are not instrumented.
The HPCI bearings, which are instrumented, are monitored during testing.
RCIC bearings do not have temperature instrumentation.
Vibration tests performed on the pumps ensure detection and correction of changes in bearing performance while the pumps are still capable of satis-factory operation.
Evaluation The NRC staff finds that the Code required bearing temperature measurements referred to in the licensee's request are impractical for the following reasons:
(1)
The annual bearing temperature measurements required by the Code are considered unreliable in detecting bearing failure.
(2)
Vibration testing which the licensee will be required to perform on the pumps is considered to provide adequate assurance of detection of bearing or bearing cooling degradation.
(3)
The pumps and systems described in the licensee's request were not designed to have the Code bearing temperature measurements performed and the required measurements could not be accomplished by conventional or standard means.
13 Relief Re uest The licensee requested relief from Code (IWP-3100, 3300 and 3500) requirements for observation of lubricant level or pressure for pump bearings for the following pumps:
All RHR,
Licensee's Basis for Re uestin Relief The RHR, CS, and RHRSW pump bearings are lubricated by water supplied by the pump itself and satisfactory pump operation is indicative of sufficient bearing lubrication.
HPCI and RCIC have oil cooled bearings, but these pumps cannot be operated long enough to reach stable bearing temperatures without overheating the torus and causing plant shutdown.
SLC and DFT bearings are not instrumented.
The HPCI bearings, which are instrumented, are monitored during testing.
RCIC bearings do not have temperature instrumentation.
Vibration tests performed on the pumps ensure detection and correction of changes in bearing performance while the pumps are still capable of satisfactory operation.
Evaluation The licensee's written request for relief from observation of lubricant level/pressure was unclear or insufficient with regard to the following:
(I)
The pumps for which relief was requested was unclear.
(2)
There was not sufficient information to ascertain whether the designs of all the pumps precluded any 'simple observations or measurements to aid in assuring proper distribution of the required lubricating fluid or fluids; In view of the above, responsible personnel (H. Hodges and P. Gilbert) were contacted by telephone on June 8, 1988, and they informed us that:
(1)
Relief from observation of lubricant level/pressure was required only for the
The subject pumps were not designed such that adequate lubrication could be determined through observation of lubricant level or pressure (3)
Lube oil level/pressure is observed on the pumps that are not water or diesel fuel lubricated,.those being the HPCI, RCIC and SLC.
Based on the information provided in the licensee's IST program document and via the telephone calls with responsible licensee personnel, the staff is satisfied that the designs of the
Design changes (or pump replacements) to permit the Code specified observation would not in themselves provide significantly increased assurance of operability for the subject pumps.
14 Conclusions The NRC staff finds the Code requirements for annual measurement of stabilized bearing temperature referred to in the licensee's request are impractical.
The vibration testing, as the NRC staff determines is authorized by law, which the licensee will be required to perform on the pumps is considered to provide adequate assurance of detection of bearing or bearing cooling degradation.
The annual bearing temperature measurements required by the Code are considered unreliable in detecting bearing failure.
The pumps and systems described in the licensee's request were not designed to have the Code bearing temperature measurements performed and the required measurements could not be accomplished by conventional or standard means.
The proposed vibration testing provides reasonable assurance of operational readiness, and based on the impracticability of complying with the Code requirements and the burden on the licensee if the Code requirements were imposed and considering the proposed testing, relief is granted on the annual measurement of stabilizing bearing temperature for all the RHR, HPCI, RCIC, CS,
The NRC staff finds that compliance with the Code requirement for observation of lubricant level or pressure for pump bearings would result. in hardships without a compensating increase in the level or quality or safety.
The Code requirement is for observation of lubricant level or pressure.
Vibration testing which the licensee will be required to perform on the pumps; is considered to provide adequate assurance of detection of bearing or bearing cooling degradation.
The
lubrication could be determined through observation of lubricant level or pressure.
The proposed vibration testing provides reasonable assurance of operational readiness and compliance with the Code would result in safety, therefore relief is granted on the observation of lubricant level or pressure for all the
2.2.2.2 PV-2 measurement of Inlet Pressure and Differential Pressure in tan u
ontro an ese ue rans er um ests Relief Re uest The licensee has requested relief from quarterly measurement of inlet pressure and differential pressure in accordance with Code requirement IWP-3300 for the SLC and DFT pumps.
15 Licensee's Basis for Re uestin Relief During testing, these pumps take suction from tanks that have a relatively small range of level variation during pump operation.
In addition, these are positive displacement pumps whose inlet pressure does not affect pump operating characteristics.
Therefore, differential pressure measurement is not meaningful in monitoring pump performance.
Also, the DFT pumps are not instrumented or constructed to allow measurement of discharge pressure.
Pump discharge pressure can and will be 'used in place of the differential pressure test parameter for the SLC pumps.
Although there will be no pump pressure parameter measured for the DFT pumps, flow will be determined and used in assessing pump operability.
Evaluation The staff agrees with the licensee that inlet pressure measurements are not important for positive displacement pump tests.
The significant pressure parameter for such pumps is discharge
- pressure, and the licensee indicates it will be used in place of differential pressure for the SLC pumps.
The staff finds that it is correct and appropriate to substitute discharge pressure measurement for differential pressure measurement on the SLC pumps.
The testing proposed by the licensee is equivalent to that specified by the Code and provides an acceptable level of quality and safety.
The licensee does not have instrumentation installed for the DFT pumps that
- would permit them to measure discharge pressure.
Taking into account the fact that the functioning of the DFT pumps is not as immediate or safety-significant as other safety-related
- pumps, and that they are readily accessible if maintenance proves necessary during plant opet ation; the staff finds that the:
installation and use of instrumentation for DFT pump discharge pressure measurements is unnecessary.
The flow and vibration testing that is specified for these pumps is considered to provide an acceptable level of quality and safety.
Conclusions The Code (IMP-3300) requires quarterly measurement of inlet and differential pressure for all pumps.
For the DFT pumps, discharge flow and pump vibration testing, and for the SLC pumps, discharge pressure, will be used to monitor pump performance.
Due to the type of pump (positive displacement) the NRC staff finds the proposed alternatives would provide an acceptable level of quality and safety, therefore relief is granted on the quarterly measurement of inlet and differential pressure for the DFT and SLC pumps.
16 2.2.2.3 PV-3 Five Minute Minimum Run Time for SLC and DFT Pum Tests Relief Re uest The licensee has requested relief from running the SLC pumps for five minutes under stable conditions prior to measurement or observation of the specified test parameters as required by INP-3500(a) of the Code.
They propose to limit the time of the Code test to two minutes and to perform the Code test iomediately following a 15-minute functional test of the pumps.
The five minute run time of IWP-3500(a) also poses a problem to the licensee in their DFT pump testing as, depending on diesel oil usage, day tanks may be too full to permit the pumps to be run long enough for completion of testing.
Because of anticipated difficulties in scheduling pump testing to coincide with day tank levels low enough to permit stable runs of five minutes or more, the licensee requested relief from IWP-3400 ~equirements for quarterly testing.
Based on clarification provided in a telephone conversation between responsible TVA (H. Hodges and P. Gilbert) and NRC (E. Girard) personnel on August 11,
- 1988, TVA considers that day tank levels will be low enough to permit pump runs of the required time and test measurements to be completed at least once every six months.
They propose to perform the tests at that frequency instead of the three month frequency specified by IWP-3400.
Licensee's Basis for Re uestin Relief The SLC pumps are tested by circulating liquid to a test tank for two minutes and measuring the volume change. in the tank.
Running for five minutes before measuring parameters is not compatible with the system design.
The volume of the test tank (210 gallon capacity) prohibits running the pumps (flow rate of approximately 55 gpm) for five minutes.
- However, a 15-minute functional test.
which involves recirculating water back to the test tank is run before the system is lined up for the Section XI'est requirement.
This 15-minute test is of sufficient length for all parameters to stabilize and the two-minute test is run immediately afterward.
Depending upon diesel oil usage, day tank level may be so high that high level switches will stop DFT-pumps before the scheduled periodic testing required by the Code can be completed.
The licensee proposes that the test will be performed when day tank level permits the pumps to be run for as long as
- possible, but not less often than once per six months (as compared to quarterly testing required by the Code).
In the July ll, 1988 telephone call referred to above, the licensee indicated that "for as long as possible" meant that the IWP-3500(a) requirement would be met.
Evaluati on The staff agrees, based on the system description provided by the licensee, that it is impractical to run the Code required SLC pump tests for five minutes.
The proposed alternative of running the Code pump test for two minutes immediately following a 15-minute functional pump test is considered to
.provide an equivalent test.
17 As already noted in 2.2.2.2 above, the functioning of the DFT pumps is not as immediate or safety-significant as other safety-related pumps.
Therefore, the staff finds that the steps the licensee would have to take to assure quarterly
- testing, versus the testing they propose, are unwarranted from a safety standpoint.
The other testing to be performed by the licensee, including improved vibration testing, provides an acceptable level of quality and safety.
Conclusion-The Code (IWP-3500(a)) requires a minimum of a five minute run time under stable conditions prior to measurements or observations of specified test parameters.
I The SLC pumps would only be for two minutes immediately following 15-minute functional test.
The DFT pumps would not be tested once per six months vice quarterly.
The proposed running of the SLC pumps for two minutes immediately following the 15-minute functional test is considered to be equivalent to the required testing and the running of the DFT pumps for five minutes at least every six months, along with improved vibration testing provides an acceptable level of quality, therefore relief is granted, provided the DFT pumps IMP-3500(a) requirements are met in tests performed at least every six months.
2.2.2.4 PV-5 Pum Test Instrumentation Accurac and Full-Scale Re uirements owa e
an es o
n-serv ce est uant t es an rat on u e e
u remen s
~R1t f R The licensee has requested the foll'owing relief for all Code IST of pumps:
(I)
Relief is requested from the
+2% pressure and flow instrument accuracies-specified by Code Table IWP-4110-1.
The licensee proposes to use the originally installed plant instrumentation which provide accuracies of
+2.5X and l:3.0% for pressure and flow respectively on all pumps except the DFT pumps.
The DFT pumps are not instrumented for flow and the licensee proposes to use level change in the diesel fuel day tank to assess flow.
(2)
Relief is requested from the IWP-4120 requirement that the full-scale range of each instrument shall be three times the reference value or less.
(3)
Relief is requested from the requirements to measure displacement vibration amplitude in accordance with IMP-4510 and to use the vibration amplitude allowable ranges in Code Table IWP-3100-2.
The licensee proposes to instead measure velocity vibration amplitude replacing the Table IWP-3100-2 vibration ranges with the following:
Test Acceptable Alert Required uantit Ran e
Ran e
Action Ran e
NOTE:
G V
1 ~ 5Vr Io5 V
3 ~ OVr V
3eOVr V is defined as vibration amplitude in in/sec and Vr is the baseline value.
18 One point (i.e., the value from one measurement location) will be trended, utilizing broad band unfiltered measurements with an instrument with a calibrated frequency response range of 10-1000 HZ.
Relief is requested to change the allowable ranges of inservice test flow and differential pressure quantities stated in Code Table 3100-2.
The licensee proposes to use a multiplier of 1.05 fn place of 1.02 and 1.06 fn place of 1.03, for all pumps except the DFT pumps.
For the DFT pumps they simply propose that the pumps will be proven to pump within lOX of their baseline flow rates.
Licensee's Basis for Re uestin Relief The proposed instrument accuracies are those of the currently installed instrumentation.
Use of alternate instrumentation conforming to the r equirements of the Code would not sfgnificantly incr ease the repeatabi1ity of the instrument data for use in trending.
(2)
(3)
Same as (1).
The licensee did not state a basis for the change from use of vibration displacement to vibratfon velocity.
The increases in upper flow and differential pressure limits are necessary because of inaccuracies-in the installed instrumentation.
Evaluation The staff's evaluation of the relief requested fs as follows:
The staff finds that the reduced measurement accuracies that result from the licensee's instrumentatfon accuracies are minor and are more than offset by the benefits of licensee's proposal for using velocity measurements fn performing vibration testing.
This finding does not take into account the affects of deviatfons from code range requirements described fn (2) below.
(2)
Code requirements for instrument accuracy are specified as a percent of full scale (range).
Therefore, the instrument range lfmft stated in the Code affects permitted measurement in accuracies.
The licensee's relief request did not indicate the extent to which the instruments exceeded the Code requirement for range, such that the effects on measurement accuracy could be determined.
On June 10, 1988, we contacted responsible licensee personnel (H. Hodges and P. Gflbert) regarding this matter and were informed that the Code range limit was exceeded as follows:
L9 Code re uirement:
Full scale range not to exceed three times reference va ues.
Browns Ferr Instruments:
Pumps Core Spray RHR EECM HPCI RCIC Instrument Suction Pressure
- Flow Suction Pressure Flow Flow Suction Pressure Discharge Pressure Suction Pressure Discharge Pressure Range (As a Multiple of Minimum Exce t Reference 15 3.1 38 4,4 5
3.3 5
3.7 6.7 (3)
(4)
Based on our evaluation of the above, we find that the inaccuracies that may result from the ranges of the installed instrumentation and their
=
affect on the capability to detect significant pump degradation are minor as compared to the benefits of the improved vibration testing being proposed in this relief request.
- However, we encourage the licensee to upgrade their instrumentation, and note that approval of this relief request expires at the end of the program interval.
The staff finds that the vibration testing proposed by the licensee is.
superior to that specified by the Code and, therefore, we consider their proposal acceptable.
In stating this evaluation we note that, where the licensee has not specifically stated alternative vibration testing requirements, we consider Code requirements to still be applicable.
For example.
Code test frequency and measurement location (and quantity) requirements still apply.
Considering the improved pump testing that will result from the vibration testing referred to in (3) above, the staff finds that the small increase in allowable and acceptable range limits proposed is acceptable.
Conclusions The overall effect of the four parts of the licensee's proposed alternative would provide an acceptable level of quality and safety that is equivalent to or exceeds the intent of the Code requirements.
Therefore, the NRC staff granted the requested relief provided:
r (1)
The licensee's performance of vibration testing complies with the test criteria specified in their request and with any Code vibration test criteria they did not propose an alternative to (e.g.
number and location of measurements).
20 (2)
The licensee recognizes
- that, unless they can demonstrate significant-hardship or burden, instrumentation not meeting Code requirements will not be acceptable in the next interval.
2.3 Valve Testin Pro ram 2.3.1 Pro ram Excludin Relief R
uests The NRC staff review found that the specified periodic testing conforms with Code requirements except where relief has been requested.
2.3.2 Relief Re uests A
licable to Re ufrements in Code Subsection IWV 2.3.2.1 PV-4 Re uirements for Valve 0 erabilit Before Startu
~Rii f R
The lfcenske has requested relief from IIV-3416 requfrements that valves be exercised within 30 days prior to the return of a system to operable status.;
Also, they have requested relief from IWV-3417(b) requirements that valves which fail cold shutdown testing must have necessary corrective actions and",
retestfng per Code performed before startup.
Licensee's Basis for Re uestin Relief The plant Technical Specifications (TS) limiting conditions of operation clearly state the minimum requirements for safe operation of the plant.
The failure of a particular valve may not require plant shutdown or prevent startup.
System requirements for operation will be per technical specification requirements.
Evaluation The TS provide conditions for system operability which may permit individual components or trains of systems to be out of service with the systems still considered operable.
The controls provided by the TS 'in such cases are considered to provide satisfactory assurance of plant safety.
The staff finds that the TS provides an acceptable alternative to the Code requirement.
Correctfve actions and Code required tests must be performed within 30 days prior to consfderfng the valve operable.
Conclusion The proposed alternative would provide an acceptable level of quality and safety.
Therefore, the HRC staff granted the requested relief provided:
(I)
The corrective action and testing required by the Code are performed prior to declaring a valve operable
- and, (2)
The testing must be done within 30 days prior to return, of the valve to operable status.
21 2.3.2.2 PY-6 uarterl Exercisin Automatfc De ressurizatfon S stem ADS a vas
~ll 11 1
R 1
The 1icensee has requested relief from Code, IWV-3410, requirements for exercising ADS safety/relief valves (SRVs).
As these valves may be power
- actuated, IWV-3410 requires them to be exercised (to the position required to fulfi11 their function) and stroke time. tested.
The Code requires the testing to be performed at least once every three months, except that if full-stroke testing cannot be performed during operation, the valves must be full-stroke
,tested at cold shutdowns and part-stroke exercised during operation.
The Code also requires comparisons of stroke times with previously obtained values (trending).
The licensee proposes as an alternative to IWV-3410, to test these valves in accordance with TS 4.6.D.2.
This TS does not require stroke timing and only requires exercising once each operating cycle.
The licensee also proposes that, during the TS testing, they will verify that the valves stroke in two seconds or less.
Licensee's Basis for Re uestin Relief The six SRYs assigned to the ADS system perform an essential safety function when operated by the pneumatic actuator with gas supplied through the ADS "
Operation of these valves fs not practical during power operation because this action will vent main steam to the suppression
- pool, inducing a transient condition and increasing the potential for an open failure of SRVs valve.
- Also, no stroke time trending fs practical, as these are pneumatic assisted SRVs.
Since "position indication" of the SRVs is provided by acoustic monitors attached to the valve discharge piping, exercising during cold shutdown cannot be accomplished because of lack of steam flow (and -:.
attendant noise).
The ADS valves will be exercised once each operating cycle in accordance with Technical Specification 4.6.D.2, which provides manual opening of each ADS valve (with reactor dome pressure greater than or equal to 100 psig) and observing either control valve or bypass valve response or corresponding change in measured steam flow.
No stroke time trending will be done but the valves will be verified to stroke in two seconds or less.
Evaluatf on The staff finds that it is impractical to operate the ADS valves during power operation - because of the safety hazard that would result if a valve failed open.
This open failure could create a loss of coolant accident.
From. safety and design considerations the most appropriate time to test these valves is during startup and, even then, there fs some hazard from an open valve failure.
It fs the staff's position that testing of these valves should not be required at a frequency greater than refueling outages and that the TS provides satisfactory exercising of the valves.
The staff also finds that it fs desirable to stroke time these valves with a maximum stroke time of two seconds specified for acceptance.
Trending of stroke times fs considered unnecessary
22 as the valves are not designed or instrumented for measurements of sufficient-accuracy to make stroke time trending useful or practical.
The staff has determined that Code exercising and trending of stroke times for the ADS valves, as opposed to testing per TS 4.6.D.2, is both impractical and undesirable.
The safety hazard and burden of the additional testing outweigh the possible increased assurance of valve operability that it would provide.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Code, IWV-3410, would be an undesirable hardship and safety hazard without a
compensating increase in
- safety, therefore, the partial relief requested by the licensee from Code, IMV-3410, requirements for exercising ADS safety/relief valves (SRVs) is granted.
2.3.2.3 PY-7 uarterl Exercisin of Hain Steam Relief Valve MSRV sc ar e s
e acuum rea ers Relief R
uest The licensee has requested relief from Code, IWV-3521, requirements for quarterly testing NSRV discharge pipe vacuum breakers.
They propose to perform the required tests only during cold shutdowns in which drywell entry is made (time permitting).
As a minimum the valves would be tested each refueling outage.
Testing frequency will be consistent with requirements applied to other cold shutdown tested valves.
Licensee's Basis for Re uestin Relief These valves are located in the drywell and access to perform the testing during operation is not practical.
The drywell is inerted with nitrogen, and entry would involve personnel safety hazards or deinerting.
Evaluation The staff finds that deinerting a drywell or entering an inerted drywell solely for MSRV vacuum breaker testing represents an expenditure of effort and/or personnel safety hazards without a compensating increase in safety.
Having taken this into consideration, we are satisfied that 'the alternative proposed by the licensee provides reasonable assurance that the HSRV vacuum breakers are operational.
'Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Code, IWY-3521, would be an undesirable hardship and safety hazard without a compensating increase in
- safety, therefore the partial relief request by the-licensee from Code, IMV-3521, requirements for quarterly testing NSRV discharge pipe vacuum breakers is granted.
23 2.3.2.4 PV-8 uarterl Exerci sin Reactor Feedwater Valves 3-554 558 568 an Relief Re uest The licensee has requested relief from the
- Code, IWV-3521 and
- 3522, requirements to stroke these valves to the closed position every three months during operation or at cold shutdowns.
The licensee proposes to use the 10 CFR 50. Appendix J testing performed each refueling outage to verify that these valves stroke to the closed position.
Licensee's Basis for Re uestin Relief All four check valves remain open, maintaining the flow path to the reactor vessel whenever the feedwater/condensate systems are supplying feedwater to the reactor vessel.
When RCIC or RWCU are returning flow to the reactor vessel, check valve 3-572 remains open.
When HPCI is injecting to the vessel, check valve 3-558 remains open.
Due to the necessity of maintaining this flow path in virtually all modes of operation, closure testing is only practical during extended
- outages, such as refueling, during which.these systems are shut down..
Also, plant design does not provide a practical means of demonstrating closure other than by upstream pressurization during the leak rate testing performed in accordance with Appendix J of 10 CFR 50.
This testing involves significant effort for installation of temporary equipment, and requires entry into the-reactor containment.
Such entry into containment poses a hazard to personnel safety or necessitates deinerting.
Evaluation The staff finds, for the reasons stated in the licensee's basis, that there is no practical means of both causing the closure of these values and verifying that closure (or even partial closure) has occurred during power operation or at cold shutdowns.
The closure function of these valves will be adequately.
verified by 10 CFR 50, Appendix J, Type C tests that are performed at refueling outages.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore the partial relief requested by the licensee from Code IWV-3521 and
- 3522, requirement for stroking RFW valves 3-554, 3-558, 3-568, and 3-572 to the closed position every three months is granted.
2.3.2.5 PV-9 uarterl Exercisin of SLC Check Valves63-525 and 526 Relief Re uest The licensee has requested relief from IWV-3521 and 3522 requirements to stroke these check valves to the positions required to fulfilltheir, functions every three months during operation or at cold shutdowns.
The licensee proposes
24 instead to verify the opening and closing functions of these check valves at.
each refueling outage.
Opening will be demonstrated by a
Technical Specification injection test and closure will be demonstrated through 10 CFR 50, Appendix J, local leak testing.
Licensee's Basis for Re uestin Relief To verify proper opening of these check valves, it is necessary to pass fluid through each valve.
This action would result in an injection into the vessel and would require actuation of an explosive valve, both undesirable during power operation.
Closure testing is only practical by pressurizing downstream of the valve (the upstream side being vented) and verifying absence of flow on the upstream side.
This requires installation of temporary equipment and access to the containment which is inerted during power operation.
Evaluation The staff agrees that it is not practical to exercise test these valves to the positions required to fulfilltheir functions either at three month intervals.
during operation or at cold shutdowns.
Performing exercise tests at the frequency specified by IWV-3521 and 3522 is not considered to provide sufficient additional assurance of the proper functioning of the valves, as compared to the licensee's proposal, to justify the burden of the methods that would have to be used to accomplish the testing.
The alternative testing proposed by the licensee provides reasonable assurance the valves will be operational.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522, would be an undesirable hardship without a compensating increase in safety, therefore, the partial relief requested by the licensee from Codes, IWV-3521 and 3522, requirements to verify proper opening of SLC check valves,63-525 and 63-526, every three months is granted.
2.3.2.6 PV-10 uartei 1 Closure Exercisin of Reactor Recirculation S stem onta nment so at on ec a ves an Relief Re uest The licensee has requested relief from the requirements of IWV-3521 and 3522 to exercise these valves to closure at least once every three months during operation or at cold shutdowns.
They propose to perform the testing only at each refueling outage and to verify proper closure through 10 CFR 50, Appendix 8 local leak rate tests.
Licensee's Basis for Re uestin Relief These check valves serve as inboard and outboard containment isolation valves.
The valves are not equipped with remote indication, and there is no pressure
~
'Lv ls ae 4W,A,,
~
25 indication downstream of the valves.
For these valves, closure'esting is only practical through pressurization downstream of the valve, with the upstream piping vented and the absence of flow upstream verified.
Interruption of the CRO flow (seal injection) is required to perform this testing, and during reactor recirculation pump operation, could result in seal damage.
The practical method for verifying closure is the local leak rate test performed at refueling outages.
This test would be impractical on a cold shutdown basis due to the burden of installing the associated temporary test equipment.
Evaluation The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to'rovide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance
'f operational readiness and full compliance with Codes, IWV-3521 and 3522,;.
would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore, the partial relief requested by the licensee.
from
- Codes, IMV-3521 and
- 3522, requirements for exercising Reactor Recirculation System Containment Isolation Valves68-508, 68-523,68-550 and-68-558 every three months is granted.
2.3.2.7 PV-ll uarterl Closure Exercisin of Reactor Mater Cleanu RWCU ec a ves an nit Relief R
uest The licensee has requested relief from the requirements of IWY-3521 and 3522 to exercise-these valves to closure at least once every three months during operation or at cold shutdowns.
The licensee proposes to perform the closure test at each refueling outage.
They propose to verify closure through 10 CFR 50, Appendix J, Type C tests.
Licensee's Basis for Re uestin Relief These check valves remain open to return water to the reactor vessel whenever the reactor water cleanup (RMCU) system is operating.
The valves are not testable whenever the RWGU, feedwater/condensate, or RCIC system is returning flow to the reactor vessel.
Testing requires entry into primary containment and the disruption of system flow (RWCU, feedwater/condensate or RCIC).
For these
- reasons, closure testing is only practical during extended outages such as refueling when no return flow fs required through the valves.
Also, plant
26 design does not provide a practical means of demonstrating closure other than by upstream pressurization performed during leak rate testing conducted in accordance with 10 CFR 50, Appendix J.
This testing involves significant effort for installation of temporary equipment.
This would require valve lineups to abnormal positions, installation of pressurizing equipment and associated test lines, as well as deinerting the drywell for safe entry..
Evaluation The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore the partial relief requested by the licensee from
- Codes, IWV-3521 and 3522, requirements for exercising RWCU check, valves69-579 and 69-624 every three months is granted.
2.3.2.8 PV-12 uarterl Stroke Timin Residual Heat Removal Service Water a ves an Relief Re uest The licensee has requested relief from IWV-3413 requirements to measure the full stroke time of these power operated valves.
The licensee proposes to set an intermediate stroke "reference" position to which the valves will be stroked and timed.
This test will be performed quarterly and the reference position will be 4500 gpm.
Licensee's Basis for R uestin Relief In order to obtain good stroke times for baseline
- values, these valves would have to be stroked from the same position.
Since the valves are throttle valves, the position to obtain the desired flow of 4500 gpm would change due to system variables such as corrosion, tube
- blockage, plugged
- tubes, etc.
Additionally, full opening the valve would overflow the heat exchanger and possible damage it.
Evaluation Considering that full stroking these valves might result in heat exchanger
- damage, the staff agrees that the such testing is a safety hazard.
The alternative proposed by the licensee, stroke timing to a reference flow, is a
27 satisfactory alternative test.
The staff finds that this alternative meets the intent of the Code.
Conclusion The NRC staff concludes that the proposed alternate testing would provide an acceptable level of quality and meets the intent of the
- Code, IMV-3413, therefore the partial relief requested by the licensee from Code, IMV-3413, requirements to measure the full stroke of RHRSW valves 23-34, 23-40. 23-46 and 23-52 is granted.
2.3.2.9 PV-13 uarterl Closure Exercisin RHRSM Check Valves23-601 603 an Relief R
uest The licensee has requested relief from the IWV-3521 and 3522 requirement for exercising these valves to closure at least once every three months during operation or at cold shutdowns.
The licensee proposes to exercise these valves and to verify proper closure once every 24 months.
The valves will be proven to close by disassembly, acoustic monitoring techniques or other proven methods.
Licensee's Basis for Re uestin Relief These check valves, located in keep fill lines for the RHR service water
- system, permit raw service water flow into the respective headers while preventing process flow in the reverse direction during RHRSW system operation.
There are two check valves in each line located in parallel.
There are no-
- vent, drain, or test connections located upstream of the check valves.
Therefore, no practical method exists to directly verify closure of either-valve upon cessation or reversal of flow.
Evaluation The lines upstream of the subject valves do not contain vent, drain or test connections needed to facilitate valve exercising to closure.
In the absence of such connections, the staff considers that the proven exercising methods which could be used would be unnecessarily burdensome, as compared to the increased confidence in valve operability obtained by performing the exercising at the Code specified frequency.
The 24 month frequency proposed by the licensee provides reasonable assurance of operational readiness and is judged satisfactory by the staff.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IMY-3521 and 3522, would be an undesirable hardship without a compensating increase in safety, therefore the partial relief requested by the licensee from Codes, IMY-3521 and
~
28
- 3522, requirement for exercising RHRSM check valves23-601, 23-603,23-605, and 23-607 every three months is granted.
2.3.2.10 PY-14 uarterl Closure Exercisin of the Followin Emer enc u
ment oo n
ater an aw oo n
ater CW 24-hec a ves67-541, 542, 584, 585, 648,
- 649, 657, 558, 559, 638, 639, 600, 601, 659, 660, 528, 529, 634, 635, 521, 522, 630, 631, 624, 625, 514, 515, 627, 628, 507, 508, 502, 622, 619, 656, 671, 679, 638 3-24-831, 833, 796, 798 3 67 639'94s 695) 696s 703) 704) 705) 706) 715) 716'13 i 714) 723 ~
724, 725, 726, 771, 772, 774, 775, 761, 762, 764, 765, 737, 738, 735, 736
~R1f fR R
The licensee has requested relief from the IWV-3521 and 3522 requirements
- for, exercising these valves to closure at least once every three months during
'peration or at cold shutdowns.
The licensee proposes to exercise these valves and to verify proper closure by positive means once per refueling cycle.
Licensee's Basis for Re uestin Relief The EECM valves pass rated flow for the emergency coolers and prevent backflow from opposite header.
The RCM valves prevent backflow of EECM into RCM.
System design prevents the valves from being verified closed by reverse flow measurements or other conventional means.
Therefore, an alternate test such as acoustic monitoring or disassembly will be required.
Since the valves can be
~
verified open quarterly by flow verification, apparent disc free movement will be indicated.
Evaluation For the given design, the staff considers the IMY-3521 and 3522 quarterly closure test frequency to be unnecessarily burdensome.
The additional efforts required to perform the tests at the IWV-3522 frequency (versus the proposed refueling outage frequency) are not.compensated by significantly increased confidence in operation safety to warrant the hardship involved.
The staff finds that the refueling outage test frequency proposed by the licensee provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWY-3521 and 3522, would be an undesirable hardship without a compensating increase in safety,
29 therefore, the partial relief requested by the licensee from Codes, IMV-3521 and
- 3522, requirement for exercising EECW and RCM check valves, as listed
- above, once every three months is granted.
2.3.2.11 PV-15 uarterl Closure Exercisin of Reactor Buildin Closed oo n
ater ec a ve Relief Re uest The licensee has requested relief from the IMV-3521 and 3522 requirements for exercising this check valve to closure at least once every three months during operation or at cold shutdowns.
The licensee'proposes to verify closure of this valve through the 10 CFR 50, Appendix J, Type C leak testing.
Licensee's Basis for Re uestin Relief This containment isolation valve is in the cooling water supply for the reactor recirculation pump bearing and seal coolers.
Testing this valve closed during power operation would interrupt this cooling water flow, possibly causing pump bearing damage or seal failure.
Due to the necessity of maintaining this flow path in virtually all modes of operation, closure testing is only practical "
during extended
- outages, such as refueling, during which this system is shutdown.
Plant design does not provide a practical means of demonstrating closure other than by downstream pressurization, as is performed during leak rate testing.
This testing involves significant effort for installation of.
temporary equipment, abnormal valve lineups for test boundaries, and complete purging of the inerted reactor containment.
Evaluation I
The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IMV-3521 and 3522, would be an undesirable hardship without a compensating increase in safety, therefore, the partial relief requested by the licensee from Codes, IWY-3521
'nd
- 3522, requirement for exercising RBCCM check valve 70-506 to closure at least once every three months is granted.
30 2.3.2.12 PV-16 uarterl Closure Exercisin of Hi h Pressure Coolant n ect on an eactor ore so at on oo n
IC a ves an Relief Re uest The licensee has requested relief from the IWV-3521 and 3522 requirements that these valves be exercised to closure at least once every three months during operation or at cold shutdowns.
The licensee proposes to exercise and verify closure of these valves through the 10 CFR 50, Appendix J, Type C tests performed each refueling outage.
Licensee's Basis for Re uestin Relief These valves are not equipped with position indication.
Their configuration with an open discharge into the suppression pool prevents usage of reverse flow to demonstrate closure.
No practical method exists to perform closure testing other than the downstream pressurization in leak rate testing.
Such testing conducted per Appendix J, requires installation of temporary equipment
- and, closure of valves which'render the system inoperable.
Evaluation The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IMU-352) and 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore, the partial relief requested by the licensee from Codes, IMV-3521 and 3522, requirements for exercising to closure of HPCI valve 73-559 and RCIC valve 71-547 every three months is granted.
2.3.2.13 PV-17 Additional Testfn for Hain Steam Relief Valves HSRVs 1-4 I>>
1~
1-an Relief Re uest The licensee has requested relief from the IMV-3513 requirements for testing an additional quantity of valves (based on a Code formula) following the failure of a valve in the set point testing of IMV-3511.
They propose that their testing will be conducted in accordance with Technical Specification (TS) 4.6.D.l, which provides for either bench checking one-half..the valves each operating cycle or replacing one-half the valves with bench checked valves.
31 IWV-35l3 requires that, if any additional valves fail'n the additional testing. all valves in the system in this category shall be tested.
There is no simi1ar requirement in the TS and it would not even assure that all valves are tested for as found conditions.
The licensee proposes to supplement the TS with requirements that:
(1)
Both as-found and as-left set pressures will be determined (2)
As-found pressures (for valves replaced) will be determined either prior to the respective unit's startup or within 120 days of removal from the system, whichever is longer (3)
Failures wi11 be evaluated to determine ff additional testing is warranted 1
Licensee's Basis for Re uestin Relief The current Technical Specification 4.6.D.1 requires one-half of all relief valves to be bench checked or replaced with bench checked valves.
All 13 valves will have been checked or replaced upon completion of every second cycle.
Although this does not require additional sampling based on results,"
all the valves are tested at a minimum of every other refueling, which is more stringent than the potential of every five years per code.
Also, in shor t outages, it may not be practical to remove the valves, ship them offsite for testing, and have the tests completed in time to determine additional testing without delaying unit startup.
To assure that deficiencies that have developed in installation and subsequent operation of HSRVs are identified and that the causes are corrected, the TS.
requirements have been supplemented as indicated above (see description under "Relief Request" ).
Evaluation The NRC staff finds that while the testing proposed by the licensee differs from the Code requirements, it does satisfactorily address the important aspects of the Code requirements including:
Original testing (as-found and as-left)
Additional testing (per TS and evaluation of any failures).
Corrective action (evaluations and replacements)
The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
32 The staff considers that the TS and supplemented requirements proposed by the licensee provide a level of assurance of valve operability that is equivalent to or exceeds the IWV-3413 requirements.
Conclusion The NRC staff concludes that the proposed alternate testing would provide an acceptable level of quality and meets the intent of the
- Code, IWV-3513.
therefore the relief requested by the licensee from
- Code, 1MV-3513, requirements for testing an additional quantity of valves (based on Code formula) following the failure of a valve in the set point testing of Code, IWV-3511 is granted.-
2.3.2.14 PV-18 uarterl Closure Exercisin of HPCI and RCIC Valves73-603 an an 1-5 an 59 Relief Re uest The licensee has requested relief from the IWV-3521 and 3522 requirements that these valves be exercised to closure at least once every three months during.-.
operation or at cold shutdowns.
The licensee proposes to verify exercising of these valves to closure through 10 CFR 50, Appendix J, Type C tests each refueling outage.
Licensee's Basis for Re uestin Relief These check valves are not equipped with position indication, and system design does not provide any practical method of verifying closure other than pressurization similar to leak rate testing.
Such testing requires installation of temporary equipment which is impractical on a quarterly basis, and it would render the system inoperable during the testing period.
Additionally, the valve location (top of torus) could present a personnel safety hazard during operation.
Normally, testing of this type is accomplished by required containment local leak rate testing in accordance with Appendix J.
Evaluation The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Hodifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522, would be an undesirable hardship and safety hazard without a compensating
33 increase fn safety, therefore the partial relief requested by the licensee from
- Codes, IWV-3521'nd 3522, requirements for exercising to closure HPCI valves73-603 and 73-609 and RCIC valves71-580 and 71-592 every three months is granted.
2.3.2.15 PV-19 uarterl Exercisin of HPCI and RCIC Valves73-633 throu h
an rou Relief Re uest The licensee has requested relief from the IWV-3521 and 3522 requirements that these valves be exercised to the position required to fulfilltheir functions at least once every three months or at cold shutdowns.
The licensee proposes to exercise test these valves each refueling outage by disassembly,'coustic monitoring, or other positive means.
Licensee's Basis for Re uestin Relief Valve configuration prevents the valves from being individually proven open or closed.
No test connections or isolation valves exist to allow reverse testing.
Additionally, the valves are located in the torus room adjacent to-'he top of the torus.
Access requires scaffold erection which would present a
safety hazard dur ing operation.
Evaluation Having reviewed the system configuration, the staff agrees that exercising tests may not be easily accomplished on these valves.
Methods such as disassembly would be required and we do not consider that the burden of such.
tests should be imposed at a frequency greater than refueling outages.
Performing the tests at a greater frequency than refueling outages does not result in a sufficiently improved assurance of plant safety to warrant the additional burden on the licensee.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IMV-3521 and 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore the partial relief requested by the licensee from
- Codes, IMY-3521 and
- 3522, requirements for exercising HPCI valves73-633 through 73-636 and RCIC valves71-597 through 71-600 to the position required to fulfilltheir functions every three months is granted.
2.3.2.16 PV-20 uarterl Exercisin of HPCI and RCIC Check Valves73-517 and Relief Re uest The licensee has requested relief from the IMV-3521 and 3522 requirements that these valves be exercised to the positions required to fulfilltheir functions
34 at least once every three months during operation or at cold shutdowns.
The licensee proposes to exercise test these valves each refueling outage by disassembly, acoustic monitoring or other positive means.
Licensee's Basis for Re uestin Relief To verify proper opening of these check valves, it is necessary to initiate system flow while taking suction from the suppression pool.
Since the water quality in the suppression pool is not maintained at reactor coolant standards, it is not advisable to initiate this flow at any time during normal operations.
The resulting contamination of the HPGI or RCIC system from such flow testing would affect the condensate storage tank purity and ultimately affect the chemistry control of the reactor coolant system.
There exists no other practical method of verifying proper valve operation.
Evaluation Taking into consideration the system configurations and types of valves, the.
staff finds that the only practical method for exercising these valves during operation or cold shutdown would be through initiation of system flow through.
these valves from the torus.
We agree with the licensee that this is undesirable, in that it would result in degradation of reactor coolant water quality through introduction of lower quality water from the torus.
Other methods which might be used during operation or cold shutdown, such as manual exercising after disassembly, are considered impractical by the staff on the basis that they result in the system being inoperable when required for safety and/or that the additional assurance of safe operation gained through the tests is insufficient to warrant the burden on the licensee.
Although the staff considers the exercising tests impractical during operation or cold shutdown, we find that testing is warranted at refueling outages to assure the continued operability of these valves.
The refueling outage testing proposed by the licensee provides reasonable assurance of the operational readiness of the valves.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and meets the intent of Code, IWV-3521 and 3522, would be an undesirablc hardship and safety hazard without a compensating increase in safety, therefore, the partial relief requested by the licensee from Codes, IWV-3521 and 3522, requirements that HPCI check valve 73-517 and RCIC check valve 71-508 be exercised to the position required to fulfill.their function every three months is granted.
35 2.3.2.17 PV Leak Testin the Followin Gate T e Containment Isolation a ves w
ncorrec ressure eren a
rect on
~Ss tern Hain Steam (1)
RHR (74)
HPCI (73)
RCIC (71)
Floor 8 Dirty Radwaste Drainage (77)
Clean Radwaste 5
Decontamination Drainage (77)
Relief.Re uest Val ve FCV 1-55 FCV 74-61, 75 FCV 73-2 FCV 73-26 FCV 71-2 FCV 71-17 FCV 77-2A FCV 77-15A
~
Code subsection IWV-3423 requires that seat leakage tests on single disk gate valves be made in the same direction as when the valve is performing its function.
The licensee has requested relief from this requirement for the
~
subject gate valves.
The licensee proposed to test the valves in the opposite direction.
These valves are containment isolation valves.
Licensee's Basis for Re uestin Relief These containment isolation valves are configured such that there is no practical means of pressurizing and testing them in the direction of safety function (lack of proper isolation
- valves, test connections, etc.).
Pressurization in the direction of safety function would require actions such as pressurizing the containment (equivalent to an ILRT) or precisely controlling the entire Reactor Coolant System (RCS) at the valve test pressure.
Evaluation The staff considers that the requirements of IWV-3421 through 3425 are adequately addressed by 10 CFR 50, Appendix J, Type C.test requirements.
Test direction requirements. similar to those of, IWV-3423 apply to Appendix J testing and the licensee must meet those requirements or request NRC approval of an exemption.
Conclusion The staff concludes that the evaluation and granting of relief relative to the subject valves should be accomplished in accordance with NRC'evaluations of requests for exemptions from 10 CFR 50, Appendix J.
36 2.3.2.18 PV-22'arterl Exercisin of Fuel Pool Coolin and Cleanu Check a ves an Relief Re vest The licensee has requested relief from the IWV-3521 and 3522 requirements that these valves be exercised to the position required to fulfilltheir function at least once every three months during operation or at cold shutdowns.
The licensee proposes to verify closure for these valves each refueling outage by disassembly, acoustic monitoring. or other positive means.
The valves will be verified to open quarterly.
Licensee's Basis for Re uestin Relief These valves are located directly over the fuel pool.
Valve configuration (open ended to fuel pool) prevents reverse flow testing to prove closure.
Evaluation The valves were not designed to be closure tested.
Modifications or special.
test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of the valves closure operation to justify the efforts involved.
The licensee proposed use of disassembly or other positive methods to verify closure on a'efueling outage frequency is considered to provide a reasonable alternative to the code requirements.
Conclusions The NRC staff concludes that the proposed alternate testing would provide an:
acceptable level of quality and meets the intent of the Codes, IWV-3521 and
- 3522, therefore the partial relief requested by the licensee from Codes, IWV-3521 and 3522, requirements to exercise FPC check valves78-526 and 527 to the position required to fulfilltheir function every three months is granted.
2.3.2.19 PV-23 uarterl Exercisin and Stroke Timin of the Followin ontro o
r ve rau c
a ves Valve Number Code Cate or 85-39A 85-39B 85-589 85-597 85-616 85-617 Relief Re uest (1-185) 1-185 1-185 1-185 (I-I85)
(1-185)
The licensee has requested relief from the exercising and stroke timing requirements of IWV-3410 for the above Category B valves; and from the
37 exercising requirements of IWY-3521 for the above Category C valves.
The licensee proposes that the testing of the above valves will be accomplished as follows:
Scram testing and rod insertion timing wi11 be performed in accordance with Technical Specifications Section 4.3.C (at reactor coolant pressure 800 psig) for:
(1)
All control rods prior to THERMAL POWER exceeding 40-percent after each refueling outage.
(2) 10-percent on a rotating basis at least once every 16 weeks.
(3)
Yalves85-589 (1-185) and 85-597 (1-185) will be proven closed by disassembly, acoustic monitoring techniques, or by other positive means each refueling outage.
Licensee's Basis for Re uestin Relief These
- valves, located on the hydraulic control units for the 185 control rod=
drives, function on a reactor scram signal from the reactor protection system:
to insert the control rods rapidly into the reactor core.
Cycling these valves requires scramming a control rod.
There are 185 control rods in the reactor.
Scraoeing every rod once every three months is not practical for the following reasons:
(1)
A power reduction is required to test the scram function.
Reducing power for the length of time required to scram 185 rods is not practical.
(2)
Fuel preconditioning must follow this power reduction to avoid possible fuel aamage.
The longer the reduction in power, the longer the preconditioning.
Their proper functioning is most practically verified by an actual scram test (except for closure of 85-589 and 85-597).
Evaluation For the design of this system the subject valves cannot be exercised during operation except by scraaefng the associated control rods.
Scram tests which exercise and verify the functioning of these valves (except for closure of check valves85-589 and 85-597) are performed on a frequency in accordance with TS 4.3.C.
This frequency has been previously approved by the staff and any increase is undesirable because of increased wear to the control rod drive mechanisms, as well as the reasons stated by the licensee.
With the licensee's
- design, closure of valves85-589 and 85-597 cannot be verified during operation.
The staff is satisfied that closure testing valves88-589 and 85-597 at greater than cold shutdown frequencies is 'impractical for the licensee's design and that the cold shutdown testing frequency proposed by the licensee provides reasonable assurance of operational readiness.
Redesign to permit CRD valve exercising at the Code specified frequency is impractical and the TS and cold shutdown frequencies proposed provide reasonable assurance of operational readiness.
38 The licensee did not describe a basis for not measuring the stroke times of.the Category B valves.
- However, TS 4.3.C is referenced in their proposal and it specifies limits on,.rod insertion times.
The insertion times are a function (in part) of the -valve stroke times and we are satisfied that their measurement and assessment per TS 4.3.C will provide a satisfactory assurance of valve operational readiness.
Conclusion The NRC staff concludes that the proposed alternate testing would provide an acceptable level of quality and meets the intent of the Codes, IWV-3410 and
- 3521, therefore the partial relief requested by the licensee from Codes IWC-3410 and 3521, exercising and stroke timing of valves85-39A and 85-39B and exercising of 85-589,
- 597, 616 and 617 is granted.
2.3.2.20 PV-24 uarterl Closure Exercisin of Control Air Check Valves 1
an Relief Re uest The licensee has requested relief from the Code requirements that these containment isolation valves be closure exercised at least once every three months during operation or at cold shutdowns.
The licensee proposes to closure exercise test these valves only at refueling outages.
Licensee's Basis for Re uestin Relief The inboard valves are inside containment and, therefore, could not be proven closed without entry into the drywell.
The drywell is inerted, and entry would
'be a hazard to personnel safety.
Evaluation Valves 2163 and 2516 are the inboard CIVs on penetrations X-22 and X-50, 336 and 2521 are the respective outboard CIVs on the same penetrations.
All four are check valves.
The licensee's design does not provide for closure testing these valves during operation or cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide sufficiently increased assurance of the closure to justify the hazards (e.g.,
personnel hazards for containment entry during operation) and/or efforts involved.
The Appendix J, Type C testing which will be performed these valves at refueling outage frequency provides reasonable assurance of their operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore, the partial relief requested by the licensee
~
)
39 from Codes, IMY-3521 and 3522, requirements the CA check valves32-336,
- 2521, 2163 and 2516 be closure exercised every three months fs granted.
/
2.3.2.21 PV-25, Stroke Tfmfn Ra id-Actin Valves in the Followin S stems Sampling and Mater gualfty (43),
HPCI (73), Contafnment Inertfng (76),
Containment Atmosphere Diluting (84), Control Rod Drive (85), Diesel Generator Air Start (86), Service Mater (23), Residual Heat Removal Service Mater (23) and Traversing Income Probe.
Relief Re uest The licensee has requested relief from the power operated valve stroke time trending and increased frequency of testing of IMV-3417(a) for the subject valves, which have stroke times of less than two seconds.
for these valves they will specify a lfmiting.full stroke time maximum of two seconds.
Licensee's Basis for Re uestfn Relief Valves with stroke times 2 seconds cannot be accurately timed.
Evaluation The staff recognizes that the licensee does not have such special equipment and setups as would be required to accurately stroke time the subject valves for trending in conformance IWV-3417(a) requirements.
Stroke timing rapid-acting valves to the Code requirements is not considered to result in sufficiently improved assurance of plant safety to warrant the burden of such special test equipment and setups.
The staff finds that the licensee's proposal of two second maximum stroke times for the valves provides an acceptable level of quality.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and meets the intent of Code, IMY-34I7(a),
therefore.
the partial relief requested by the licensee from Code IMY-3417(a),
power operated valve stroke tfme trending and increased frequency of testing for the above subject valves is granted.
2.3.2.22 PV-26 Closure Exercfsin Containment Inertin S stem Check Valve X-35 Relief Re uest The licensee has requested relief from the IN-3521 and 3522 requirement to stroke this containment isolation valve to the closed position every three months or at cold shutdowns.
They propose to use 10 CFR 50, Appendix J, Type C testing performed each refueling outage to verify the stroking of this valve to the closed position.
40 Licensee's Basis for Re uestin Relief
'This purge check valve serves a's an outboard containment isolation valve.
Testing of this valve requires entry into primary containment and disconnection of the purge line for installation of test equipment.
Because of the plant
- design, demonstrating closure can only practically be accomplished by pressurizing downstream, as is performed during leak rate testing in accordance with 10 CFR 50 Appendix J.
Conducting such a test would therefore pose a
hazard to personnel safety or require the deinerting of containment for safe entry and would also require the depressurization of the purge line which could result in the introduction of moisture in these lines.
Evaluation The staff 'finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed -with refueling outage frequency pro'vides-'easonable assurance of operational readiness.
Conclusion
'he NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes, INV-3521 and
- 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore the partial relief requested by the licensee from
- Codes, IWV-3521 and
- 3522, requirements to stroke valve X-35f to the closed
position every three months is'granted.
2.3.2.23 PV-27 uarterl Exercisin of the followfn RHR and Core S ra esta e
ec a ves S stem RHR Core Spray Core Spray Relief R
uest Valvel~
74-68 75-26 75-54 The licensee has requested relief from IWV-3521 and 3522 requirements that these valves be exercised to the positions required to fulfilltheir functions once each three months during operation or at cold shutdowns.
They propose to conduct the exercising at cold shutdowns, but only when the containment is deinerted and there is sufficient time to perform the testing.
Additionally, the testing will be performed during refueling outages.
41 Licensee's Basis for Re uestin Relief
, Due to potentially inadvertent valve operation caused by nonclass lE circuitry to the valve operator, the air supply is normally disconnected.
Since these valves are located in containment.
entry to connect the air supply is not practical during operation and may not be practical during cold shutdown.
Eva1uation The NRC reviewed documentation relevant to the licensee's basis during NRC Inspection
- 259, 260, 296/87-22.
As described in the report for that inspection, the documentation supported the licensee's contention that the valves should not have to be tested quarterly during operation because of concerns for inadvertent actuation and that, with the present designs the valves could not practically be tested during any shutdown of short duration or when the containment was not deinerted.
Testing with the containment inerted would be both a hardship and a personnel safety hazard.
Deinerting solely for the testing would be an undue hardship.
Redesign to permit Code testing is also an undue hardship.
The licensee defines "short duration" cold shutdowns in I.C.I1 of their program and the-staff finds that definition acceptable.
The testing frequency proposed by the licensee provides adequate assurance of operational safety.
Conclusion
~ The NRC staff concludes that the pr'oposed testing provides reasonable assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522,>>
would be an undesirable hardship and safety hazard without a
compensating increase in safety, therefore the partial relief requested by the licensee from
- Codes, IWY-3521 and
- 3522, requirements that testable check valves, 74-54, "
74-68, 75-26 and 75-54, be exercised to the positions required to fulfilltheir functions every three months is granted.
2.3.2.24 PV-28 uarterl Closure Exercisin of CRD Check Yalve 85-576 Relief Re uest The licensee has requested relief from the IWV-3521 and 3522 requirements that this valve be closure exercised at least once each three months or at cold shutdowns.
They propose to perform the closure exercising through 10 CFR 50, Appendix J. Type C testing conducted each refueling outage.
Licensee's Basis for R uestin Relief This check valve may be open or closed during system operation.
Plant design does not provide a practical means of demonstrating closure other than upstream pressurization, disassembly, or acoustical monitor techniques.
Upstream pressurization or disassembly would require entry into primary containment to isolate Feedwater from the vessel.
42 Evaluation The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns.
Modifications or special test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved.
The Appendix J, Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Codes IWV-3521 and 3522, would be an undesirable hardship and saftey hazard without a compensating increase in safety, therefore the partial relief requested by the licensee from
- Codes, IWY-3521 and 3522, requirement that CRD check valves85-576 be exercised to closure every three months is granted.
2.3.2.25 PV-29 Leak Testin Inboard Main Steam Isolation Valves at Full ax mum unc on ressure eren a
Relief Re uest The licensee has requested relief from the IWV-3423 requirement that leak testing of the subject valves be performed at maximum function differential pressure or that leakage be adjusted to function maximum pressure differential.
The licensee proposes to test the valves at a reduced differential pressure of 26 psig.
In informal discussions the licensee noted that this is the pressure specified by TS 4.7.A.2.i.
Licensee's Basis for Re uestin Relief Due to testing techniques, valve manifold design does not allow testing at'full function pressure differential.
Such a test would subject the valve manifold to potentially damaging loads.
Evaluation Leak testing requirements for these valves are specified by TS.4.7.A.2.i.
These requirements are acceptable to the staff for the subject valves.
Additional testing or adjustment of leak rate values to conform fu'lly with Code requirements would not result in sufficiently increased assurance of plant safety to warrant the burden of the 'testing or adjustment.
The TS-test requirement provides an acceptable level of quality and safety.
Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compliance with Code IWV-3423 would be an
43 undesirable hardship and safety hazard without a
compensating increase in IWV-3423, requirement that leak testing of inboard MSIV's at maxfmum functional
- safety, therefore the partial relief requested by the licensee from Core differentfal pressure or that leakage be adjusted to perform at maximum differential fs granted.
2,3.2.26 PV-30 uarterl Exercfsin of the Followfn RHR 74 and CAD 84 stem erma e ie onta nment so at on ec a ves Valve Number R~RR I 74-661 74-662 84-600 84-601 84-602 84-603 84-617 C
C C
C C
C C
~RII IR I
The licensee has requested relief from the IWV-3521 and 3522 requirements for exercising these valves to the positions required to fulfilltheir functions (open and close) at least once each three months or at cold shutdowns.
The licensee proposes to exercise these valves to verify adequate opening during cold shutdowns in which the drywell fs entered if there fs sufficient time.
They propose to verify proper closure through 10 CFR. 50, Appendix J, Type C testing performed at refueling outages.
Licensee's Basis for Re uestfn Relief RHR:
These valves provide thermal relief between the inboard and outboard shutdown cooling suction valves.
Since these valves are fn series, with no isolatfon valve or test connection between them, they individually cannot be proven to close.
As they are located inside containment, access to perform testing during operation fs impractical due to the drywell -being fnerted.
Cycling by system manipulation fs not possible during reactor operation due to pressure fnterlocks which prevent the suction valves from operating.
CAD:
These valves provide an injection path when open and containment isolation when closed.
Cycling the valves open would require establishing flow through the valve or disassembly.
Cycling the valve closed would require setup of temporary test equipment and abnormal valve lineups.
Evaluation The licensee 'did not provide a sufffcient basis to demonstrate that exercfsfng the CAD valves to the open position fn accordance with Code requirements would be a hardship.
44 Taking into account the system and valve designs involved, the staff agrees that closure exercising the CAD and RHR valves is impractical except at refueling outages.
Similarly, we agree that open exercising the RHR valves is impractical except at cold shutdowns in which there is containment entry.
Performing this exercising at the Code frequency is not considered to be of sufficient value in assuring operational safety to warrant the burden and/or hazards of the methods that would be necessary.
The RHR valv'e open exercising and the CAD and RHR closure exercising frequencies provide adequate assurance of the capabilities of the valves to perform the associated opening (RHR only) and closing functions.
Conclusion The NRC staff concludes that the proposed testing provides assurance of operational readiness and full compliance with Codes, IMV-3521 and 3522, would be an undesirable hardship and safety hazard, except for the open exercising frequency requirements for the CAD valves, without a compensating increase in
- safety, therefore the partial relief requested by the licensee from Codes,,
IMV-3521 and
containment isolation valves be exercised open and closed every three months is
- granted, except for the CAD valves open exercising frequency requirements which is denied.
2.3.2.26 PV-31 uarterl C1osure Exercisin of RCIC Check Valve 71-589 and C
ec a ve 73-Relief Re uest The licensee has requested relief from the closure exercising frequency requirement of IRY-3521 and 3522 for the subject check valves.
They propose to perform the closure testing of the valves once each refueling cycle by 'positive means such as disassembly, acoustic monitoring or other proven methods.
Licensee's Basis for Re uestin Relief System design prevents the valves from being verified closed by reverse flow or other conventional means.
Therefore, an alternate test such as acoustic monitor verification or disassembly will be required.
Since the valves can be ver'ified open quarterly by flow verification, apparent disc free movement will be indicated.
Evaluation The staff finds that for the given designs these valves cannot be verified closed by conventional means.
Redesign would be an'xcessive burden.
Alternate test methods, such as acoustic monitoring or disassembly must be used to demonstrate closure.
These tests are burdensome and we consider that limiting the test frequency to refueling outages is appropriate.
This frequency of testing. will provide adequate assurance of operability.
l
~
e a
v
~
y 45 Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and full compl iance with Codes, IWV-3521 and 3522, would be an undesirable hardship without a compensating increase in safety, therefore, the partial relief requested by the licensee from Codes,,IWY-3521 and 3522, requirements for closure exercising of HPCI check valve 73-625 and RCIC check valve 71-589 every three months is granted.
3.0 CONCLUSION
I The Browns Ferry IST program establishes that inservice testing will be performed in accordance with 10 CFR 50.55a(g).
Of the 31 relief requests submitted, three were granted conditionally, one will be evaluated against 10 CFR 50, Appendix J requirements in order to determine whether an exemption is needed, one was partially denied, and the remainder were granted in their entirety.
With respect to the relief granted, the staff has determined that:
(I) pursuant to 10 CFR 50.55a(3), that (a) the alternative testing proposed will provide an acceptable level of quality and safety or (b) compliance with the code would result in hardship or unusual difficultywithout a compensating increase in the level of quality and safety; and/or (2) pursuant to 10 CFR 50,55a(g)(6)(i), that the requirements of the code are impractical and relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facilty.
PrincipaL Contributor:
E. Girard
APPENDIX A SYSTEMS 'THAT SHOULD BE CONSIDERED IN IDENTIFYING PUMPS AND VALVES TO BE INSERVICE TESTED The pumps and valves in the following systems should be considered for inclusion in a
comprehensive inservice testing program.
The list is not intended to be all inclusive.
Key components in instrumentation and auxiliary sytems that are required to directly support plant shutdown or safety system function should also be considered.
Reactor Coolant Recirculation System (RCS)
Portions of Main Steam Supply High Pressure Injection System (HPIC)
Low Pressure Injection System (LPCI)
Residual Heat Removal System (Steam Condensing, Shutdown Cooling, Suppression Pool Cooling)
Low Pressure Core Spray System Safety, Relief, and Safety/Relief Valves of RCS and secondary systems Reactor Core Isolation Cooling System Containment Cooling System (Spray)
Containment Isolation Valves Required to Change Position on a Containment Isolation Signal Standby Liquid Control System Automatic Depressurization System Control Rod Drive Hydraulic System Active Valves In Service and Backup Water, Closed Cooling Water, Firewater, or Well Water Systems Emergency Diesel Engine Fuel Oil Storage and Transfer System Portions of Main Feedwater System Instrument Air Systems That Are Required to Support Safety System Functions NOTE:
The terminology for various systems may vary depending on the preference of the individual nuclear steam system supplier, architech-engineer or licensee.
APPENDIX B DRAWING LISTING The drawings listed below were used fn this review:
~Ss tom Mafn Steam Demineralized Water Feedwater Main Steam (Vac Brkr)
Auxf1iary Boiler Diesel Fuel Transfer Residual Heat Removal Service Mater Abbreviation DW FW MS AB DFT RHRSW System No.
10 18
, 23 Drawing No.
47M801-1 47W856-2 47M803>>1 47W801-2 47M815-1 47M840 47W858-1 Revision 13 14 G
(Units 2
8 3)
(Unit 1)
Raw Cooling Water Control Air RCW
, CA 32 47W844-2 47W1847-6,9,10 47M2847-5,8,9 47W3847-5,9 A
(Unit 1)
A (Unit 2)
A (Unit 3)
Service Air Samplfng and Water Quality Standby Liquid Control Reactor Building Heating and Ventilation SA SAWQ 33 43 SLC 63 RB HVAC 64 47W845-2 47M610-43-1 C
47W854<<1 47W865-12 8.
(Units 2 8L 3) 6 (Unit 1)
Appendix B
~Sstem Abbreviation System No.
Drawing No.
Revision Emergency Equipment Cooling Water Reactor Mater Recirculation Reactor Water Cleanup Reactor Building Closed Cooling Mater Reactor Core Isolation Cooling High Pressure Coolant Injection Residual Heat Removal Core Spray Containment Inerting EECM RECIRC RWCU RBCCW RCIC HPIC RHR CS CI 67 68 69 70 71 73 74 75 76 47M859-2 47W866-7 47W859-1 47M859-1 47W817-1 47M810<<1
. 47W810-1 47W822-1 47W813-1 48W812-1 47W811-1 47W814-1 47M860-1 F
(Unit 3) 3 (Unit 3)
(Unit 3) 0 (Units 2 8 3) 15 (Unit 2) 13 (Unit 3 14 (Unit 1) 15 (Unit 1) 14 (Units 2 5 3) 12 (Units 2 8 3) 14 (Unit 1) 18 Units 1 5 3) 16 (Unit 2)
A
Appendix B
~Ss ten Radwaste Fuel Pool Cooling and Demineralizing Containment Atmosphere Dilution Control Rod Drive Radiation Monitoring.
Diesel Generator Starting Air Abbreviation FPC CAD CRD DGAS System No.
77 78 85 90 Drawing No.
-2 47W855-1
. I-47E862-1 2-47E862-1 3-47E862-1 47W820-5 47W820-2 47W820-6 47W610-90>>1 3-47E861-1 4-47E861-1 3-47E861-1A Revision 12 (Unit 1) 10 (Units 2 5 3)
D (Unit 3)
E (Units 2 8 3) 2(Unit 1) 2(Unit 2) 1(Unit.3) 0 K
(Unit 1)
E (Unit 2 5 3)
A (Unit 1)
B (Unit 3)
E (Units 2 8 3)
B 4(Unit 3) 4 (Units 2 8 3) 0(Unit 3)
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-8:w %el << tto Docket Nos.: 50-259/260/296 ENCLOSURE 2
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALP REPORT LICENSEE: Tennessee Valley Authority PLANT:
Browns Ferry Nuclear Plant, Units 1, 2 and 3
REVIEWER: E. Girard FUNCTIONAL ACTIVITY:
Review of Licensee's IST Program (TAC NOS.
- 11324, 11325 and 11326)
(1)
Mana ement Involvement in Assurin ualit Licensee management involvement appeared to be adequate.
Rating Category:
2 (2)
A roach to Resolution of Technical Issues from a Safet Stand oint Licensee personnel appeared to have an adequate understanding of the technical issues.
Rating Category:
2 (3)
Res onsiveness to NRC Initiatives Licensee provided timely informal responses but was somewhat slow in responding formally.
Rating Category:
2 (4)
~staffin Meetings and other contacts with the licensee were staffed with competent personnel.
Rating Category:
2 (5)
Re ortin and Anal sis of Re ortable Events N/A (6)
Trainin and ualifications N/A (7)
Enforcement Histor
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v r>f, Appendix B
N/A
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