ML18038B796
| ML18038B796 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/06/1997 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9701130039 | |
| Download: ML18038B796 (42) | |
Text
CATEGORY i REGULAT+ ZNFORMATZON DZSTRZBUTZOISTEM (RZDS)
ACCESSIONz-'NBR:9701130039 DOC.DATE: 97/01/06 NOTARIZED:
NO DOCKET FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 0500'0260 50.'-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION ABNEYFT.E.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Provides response to NRC request for reevaluation of safety functions of certain MOVs removed from GL 89-10 program.
DISTRIBUTION CODE:
A064D COPIES RECEIVED:LTR ENCL SIZE:
A TITLE: Response to Generic Ltr 89-10, "Safety-Related MOV Testing
& Surveill >
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NOTE TO ALL MRIDSM RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
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TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
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Tennessee Valley Authority. Post Office Box 2000, Decatur, Alabama 35609 January 6,
1997 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.
50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 2 AND 3 GENERIC LETTER (GL) 89 1 0 r SAFETY RELATED MOTOR OPERATED VALVE (MOV)
TESTING AND SURVEILLANCEr NRC INSPECTOR FOLLOWUP ITEM (IFI) 50 260 r 2 96/95 1 9 0 1 r
RESPONSE
TO REQUEST FOR REEVALUATION REGARDING REDUCED SCOPE OF MOVS This letter provides TVA's response to NRC's request for reevaluation of the safety functions of certain MOVs removed from, or not included in, the BFN GL 89-10 program.
This issue was identified by NRC during the BFN Unit 2 GL 89-10 closure inspection as IFI 50-260, 296/95-19-01.
The reevaluation, performed by TVA, for the subject MOVs is consistent with the conclusions provided in NRC's assessment transmitted by letter from P.
E. Fredrickson (Region II) to 0.
D. Kingsley, dated October 7,
1996.
Based on TVA's reevaluation, 15 MOVs are being added to the BFN Units 2 and 3
GL 89-10 program.
Eighteen other MOVs that are normal'.y in their safety position are not being added to the GL 89-10 program.
However, plant procedures are being revised to require that the affected
- system, or train, for those 18 MOVs be declared inoperable when the valves are taken out of their normal (i.e., safety) position for testing.
Once declared inoperable, the applicable BFN Technical Specification Limiting Conditions for Operation will govern until testing is completed and the valve is returned to its normal position.
970i 130039 970i06 PDR ADOCK OS000260 PDR i
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U.S.. Nuclear Regul'atory Commission Page 2
January 6,,
1'997 Enclosure 1 to this letter provides. background information and specific details of TVA's reevaluation of the safety function of the:subject MOVs as requested by NRC.
Enclosure 2 provides a summary of commitments contained in this letter and a schedule for their completion.
If you have any questions regarding this.matter please contact me at (205) 729-2636.
Si cerely, T. E. Abne Manager.of Licen ing and Industry A fair Enclosures cc,:
Mr. Paul E.
- ickson, Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900
- Atlanta, Georgia 30323 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region, II 101 Marietta Street, NW, Suite 2900
- Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant 3.0833 Shaw Road
- Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager U.S. Nuclear Regu'latory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
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ENCLOSURE 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNI,TS 2 AND 3 GENERIC LETTER (GL) 89-10, SAFETY-RELATED MOTOR-OPERATED VALVE (MOV) TESTING AND SURVE ILLANCE
RESPONSE
TO REQUEST FOR REEVALUATION RE~ING MOV SCOPE REDUCTION I.
BACKGROUND During the closure inspection for the Unit 2 BFN GL 89-10
- program, NRC inspectors left open the issue of MOV scope pending further review under Inspector Follow-up Item (IFI) 50-260, 296/95-19-01.
NRC completed its assessment of the BFN program scope and its findings were issued by letter from P.
E. Fredrickson (Region II) to O.
D. Ki;ngsley, dated October 7,
1996.
In its assessment of the BFN GL, 89-10 program, NRC concluded that some of the criteria utilized by TVA. in evaluating the safety function of the BFN MOVs were unsatisfactory and may
,have resulted in the inappropriate removal or exclusion of MOVs from the BFN GL 89-10 program.
NRC requested that TVA reexamine the safety function of the BFN MOVs consistent with the information provided in their assessment and provide any appropriate corrections to the BFN GL 89-10 program.
The following sections will address the concerns identified by NRC in their assessment and provide TVA's response.
II.
GL '89-10 VERSUS SYSTEM OPERATIONAL ENHANCEMENT (SOE)
CLASSIFICATION -FOR MOVS Selected MOVs at BFN were designated in the original GL 89-10 scoping effort as SOE. valves.
SOE valves were evaluated to the same requirements as those valves in the GL 89-10 program with the exception that differential pressure (DP) testing and requirements for periodic verification. (PV) were not addressed.
The classification of these valves as SOE versus GL 89-10 was based on the valve not having an active.safety function for design basis accident mitigation.
In its review of BFN's GL 89-10 program, NRC determined that the SOE classification does not meet the intent of GL 89-10 since the design basis capability of these valves would not be periodically verified and their performance would not be trended.
NRC concluded that the omission of PV for these valves could result
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in thd MOV failing to perform its safety function at some, time in the future as a result of degradation.
The SOE classification was not considered as an acceptable alternative to the GL 89-10 program for safety-related valves.
Subsequent to NRC's review, BFN has determined that the SOE classification valves would be reevaluated to determine if these valves should be included in the GL 89-10 program.
As a result of its reevaluation, TVA has determined that the use of the SOE classification would be discontinued.
III.
CRITERIA FOR BFN GL 89-10 SCOPE REDUCTION In evaluating the safety function of its GL 89-10
Motor Operated Valves," dated November 11,,
- 1994, which was performed by S. Levy, Incorporated for BFN.
The report utilized 11 criteria to determine which MOVs could be removed from the GL 89-10 program.
NRC's review of the criteria used by BFN determined most to be unsatisfactory and may have resulted in inappropriate removal of MOVs from the BFN GL 89-10 program.
The following will list the criteria from the S. Levy report, provide NRC's comments, and give TVA's response.
Criterion 1 states that demonstration of the operability of MOVs for normal plant operation is considered satisfied by attaining a normal plant operating condition and that no specific additional testing of the valves is required.
In its review, NRC stated that fulfillingthe intent of GL 89-10 should ensure that safety-related MOVs can perform their design-basis function including normal operation.
This criterion was. used for those valves where a
design-basis review. had been performed and the result was that the conditions experienced under normal plant operation were the worst case. for the valve.
This criterion was intended-to show that for some valves, the maximum expected differential pressure for both opening and closing of,the valve during normal operations enveloped the conditions experienced under other design-basis events.
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As a result of BFN's reevaluation of the MOV program,
- this criterion was not used in determining whether an MOV was required to be included in the program.
This criterion states that the provisions of GL 89-10 are limited to valves changing position from the normal operating position to the position required to mitigate d'esign-basis events (DBE).
The criterion further states that a valve is required to change position only if the consequences
-of the DBE would exceed the event acceptance limits if it did not change position.
NRC stated that BFN should justify its bases for asserting that the consequences of a safety-related MOV being unable to reposition during any DBE are not significant.
As a result of its reevaluation, BFN has determined that it will no longer apply this criterion to determine whether a valve should be included in the GL 89-10 program.
Therefore, any valve which is required to change position when called upon by an Emergency Core Cooling Systems (ECCS) actuation will be included in the GL 89-.10 program.
For those valves which are normally in their safety position and are not included in the GL 89-10 program, the system (or train) affected will be declared inoperable and the appropriate 'Technical Specifications (TS) Limiting Conditions for Operation (L'CO) will be followed whenever the affected valve is not in its safety position.
This criterion states that valve operability, as defined by GL 89-10, is not required during periods of system or component testing or when the plant operating mode is controlled by plant TS.
NRC stated that safety-related MOVs that are placed in a position that prevents the safety-related system (or train) from,performing its safety function must be demonstrated to be capable of returning to their safety position,, or the system (or train) must be declared inoperable and the appropriate plant TS followed.
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As stated above for Criterion 2,
'TVA has determined that any safety related valve which is not in the GL 89-10 program and is not in its safety position will cause that system,(or train) to be declared inoperable and the appropriate TS will be followed.
This criterion states that design-basis events are limited to anticipated operation transients and accidents as defined by the BFN Safe Shutdown Analysis.
NRC determined that this criterion did not appear consistent with the guidance provided in GL 89-10.
The staff stated that design-basis events are defined as conditions of normal operation, including anticipated operational occurrences, design-basis accidents, external
- events, and natural phenomena for which the plant must be designed to ensure the function delineated as "safety-related" can be performed.
Specifically, NRC stated that for plants which do not consider the Reactor Core Cooling Injection (RCIC) system "safety-related" the licensee will be expected to justify that the system is, and will continue to be, capable of performing its intended function consistent with licensing commitments such as Maintenance Rule and Station Blackout (SBO) requirements.
The licensee is also expected to demonstrate that the applicable RCIC MOVs can perform their safety-related isolation functions.
NRC's acceptance of the "quality-related" classification for the RCIC syst: em was based on:
- 1) the determination that the RCIC system is not required to mitigate a design-basis accident or abnormal operational transient, 2)
BFN' commitment for other regulatory requirements such as SBO to comply with relevant standards which should assure the continuing ability of the RCIC system to function as
- required,
- 3) the lack of change in the TS requirements for RCIC operability, and
- 4) the lack of a change in inservice testing and inspection requirements.
The BFN GL 89-10 scope will be revised to include those MOVs which are required for RCIC system operation, as well as those required for containment isolation.
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This criterion states that system functional requirements for design-basis events are established by the safe shutdown analysis.
NRC responded that this did not appear consistent with the definitions of "safety-related" and "design-basis events."
The BFN Safe Shutdown Analysis is a systematic analysis of all design basis
- events, including operational transients and external events, including a determination of all system functions which are required for mitigation of those events.
This criterion which referenced the safe shutdown analysis was used to determine which system functions are defined as "safety-related" in accordance wi;th the BFN design basis.
Therefore, the active safety functions are defined by the safe shutdown analysis and determine which valves must operate to mitigate design basis accidents, operational transients, and external events.
Criterion 6 states that pipe breaks are not assumed to occur when the system is not significantly pressurized.
NRC stated that this criterion di.d not appear consistent with the staff position on the consideration of pipe breaks and that pipe break consideration should be consistent with the staff's licensing review for the individual facility.
For BFN,.the licensing basis for pipe breaks includes double ended guillotine breaks.
(DEGB), intermediate breaks, critical cracks in high energy lines, and critical cracks in low energy lines.
High energy lines are defined as system fluid conditions which are equal to or exceed 200 degrees Fahrenheit (F) and 275 pounds per square inch gage (psig).
The location of
. intermediate breaks and critical cracks are based on piping stress
- levels, and the locations of DEGB are based at termination points of the piping analyses.
Therefore, intermediate and DEGB breaks are not assumed to occur where the high energy criteria are not met.
This position is consistent with the current BFN licensing basis described in Chapter 14 and Appendix M
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7 This criterion states that consideration of valve mispositioning is not required as discussed in Supplement:
4 to GL 89-10.
NRC concurred with this criterion and had no objections that consideration of inadvertent mispositioning of MOVs was not required for Boiling Water Reactor plants.
This criterion states that long;term passive failures in piping are not considered to be part of design-basis events.
NRC stated that this criterion does not appear to be consistent with the staff position on the consideration of pipe breaks.
In addition, NRC stated that consideration of long-term passive piping failures should be consistent with the staff's licensing review for the individual faci.lity.
The single failure criterion for BFN does not consider the failure of passive mechanical components as credible.
In SECY 77-439, the staff stated that a
passive failure in a fluid system means a breach in the fluid pressure boundary.
In NRC's study of passive failures, it was determined that fluid leakage, caused by a gross failure of a pump or valve seal,,
during the long-term cooli:ng mode following a Loss of Coolant Accident (LOCA) was credible but that pipe breaks were not..
For BFN, if a pump or valve seal causes failure of a valve or pump during shutdown cooling, the system design retains sufficient redundancy to complete the shutdown cooling function.
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Criterion 9 states that analysis results for each design-basis event and each system's required capability to satisfy event acceptance limits are
.provided in the updated final safety. analysis report (UFSAR).
NRC did not object to this criterion, provided.that the information in the UFSAR is consistent with the licensing basis for the facility.
TVA did not use Criterion 9 to exclude any valve from the GL 89-10 program.
- However, TVA is in the process
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of performing a detailed review to validate the BFN UFSAR.
As discussed in TVA's letter dated October 22, 1996, transmitting Amendment 13 of the BFN UFSAR, BFN will continue to review the UFSAR, evaluate any identified discrepancies, and prepare the required changes to the UFSAR.
'This criterion states that the single failure criterion is applied to systems required to mitigate the consequences of accidents and that this criterion means that only one single failure proof path success must be provided.
NRC agreed that the requirement meets the single failure criterion of NRC regulations.
- However, NRC also stated that other criteria (e.g.,
Loss of Offsite Power) may also apply at the same time.
Xn addition, safety systems are required to meet the redundancy provisions of Appendix A to 10 CFR Part 50.
BFN concurs with NRC's review of this criterion and contends that the facility design meets the requirements for redundancy, diversity, and coincident loss of offsite power for mitigation of design basis events.
This criterion states that t:he single failure criterion is not applied to anticipated operational transients.
NRC stated that the consideration of the single failure criterion as applied to anticipated operational transients should be consistent with the staff's licensing review for the individual facility.
For BFN, anticipated operational transients result from a single equipment failure or operational error, as discussed in the BFN UFSAR Chapter 14, Section 4.2.
Therefore, consideration of additional failures is not required by the BFN licensing basis.
Based on its reevaluation of the above 11 criteria, TVA 'has revised the scope of its BFN GL 89-10 program.
TVA has determined that for any MOV which is not in its safety position during valve operability (i.e
, stroke time testing),
the affected system would be declared inoperable and the appropriate TS LCO will be followed.
Valves which
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are not in their safety position for extended periods of time (i.e.,
system flow testing),
would be included in the GL 89-10 program.
IV.
SCOPE OF GL 89-10
'PROGRAM FOR BFN UNITS 2 AND 3 NRC reviewed the safety function of MOVs in the BFN GL 89-10 program.
In its review, NRC expressed concerns regarding the assigned safety function of certain BFN MOVs based on the above guidance.
The valves listed below were identified by NRC as having potential safety functions and capabilities.
These valves were either recently deleted from the GL 89-10 program or not originally included in the BFN program.
A.
MOVs Recently Deleted from the BFN GL 89-10 Program FCV-70-47 REACTOR BUILDING CLOSED COOLING WATER (RBCCW)
PRIMARY CONTAINMENT ISOLATION VALVE NRC s'tated that thi:s MOV has a containment isolation function and must be capable of performing that function regardless of system performance requirements.
TVA concurs with that assessment and will include this valve in its GL 89-10 program.
The valve was previously designated as an SOE valve, and has been evaluated to the GL 89-10 program requirements with the exception of DP testing and periodic verification.
This valve will be evaluated against DP testing of similar valves, since it cannot be DP tested at design basis conditions, and the periodic verification will be addressed under BFN's program for GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves.
FCV-71-08'CIC TURBINE STEAM SUPPLY VALVE'CV-71-25 RCIC'UBE OIL COOLING WATER SUPPLY VALVE FCV-71--34 RCIC PUMP MINIMUM FLOW VALVE FCV-71-39 RCIC SYSTEM INJECTION VALVE NRC stated that the capability of these valves, which are required'or RCIC system operation, should be addressed.
As a result of its reevaluation, BFN will include these valves in its GL 89-10 program.
These valves were previously designated as SOE valves and have been analyzed to the BFN GL 89-10 program requirements.
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As stated.previously, DP testing of these valves will be performed, if possible, and where DP testing is not
- possible, they will be evaluated against DP testing of similar valves.
In addition, the periodic verification of MOV capability will be addressed under BFN's GL 96-05 program.
FCV-74:-07 RESIDUAL HEAT REMOVAL (RHR)
LOOP I MINIMUM FLOW VALVE FCV-74-30 RHR IOOP II MINIMUM FLOW VALVE NRC stated that it considers the RHR system to have a
safety function and that these valves are associated with,the RHR system and their capability does not appear to have been addressed by TVA.
These valves are normal'ly open and close once sufficient pump flow has been achieved to prevent pump damage.
In a BFN specific system performance analysis for the RHR system, TVA has shown that the RHR system is capable of performing its design basis function of low pressure coolant injection (LPCI) function.with the minimum flow valves failed in the open position.
Notwithstanding this analysis, BFN will include these valves in its GL 89-10 program.
These valves were previously d'esignated as SOE valves and have been analyzed to the GL 89-10 program requirements.
As stated previously, DP testing will be performed where possible.
Where DP testing is not
- possible, these valves will be evaluated using DP test results of similar valves.
The periodic verification for these valves will be addressed under the BFN GL 96-05 program.
FCV-74-47 RHR OUTBOARD SHUTDOWN COOLING SUPPLY VALVE FCV-74-48 RHR INBOARD SHUTDOWN COOLING SUPPLY VALVE NRC stated that it considers the primary containment isolation function of these valves during shutdown conditions to be required and that the capability of these MOVs were not addressed by TVA.
In BFN's reevaluation, it was determined that the primary containment isolation function of these valves is necessary and TVA will include these valves in the BFN GL 89-10 program.
These valves were previously designated as SOE valves and have been analyzed to the GL 89-10 program requirements.
The issues of DP testing and periodic verification will be addressed as stated previously.
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FCV-71-19 FCV-73-35 FCV-73-36 FCV-73-81 FCV-74-52 FCV-74-66 FCV-75-22 FCV-75-23 FCV-75-50 FCV-75-51 RCIC PUMP SUCTION VALVE FROM CST HIGH PRESSURE COOLANT INJECTION (HPCI)
TEST RETURN VALVE HPCI/RCIC TEST RETURN VALVE HPCI PRIMARY CONTAINMENT ISOLATION VALVE RHR LOOP I OUTBOARD LPCI THROTTLE VALVE RHR LOOP II OUTBOARD LPCI THROTTLE VALVE CORE SPRAY LOOP I TEST RETURN VALVE CORE SPRAY LOOP I OUTBOARD INJECTION VALVE CORE SPRAY LOOP II TEST RETURN VALVE CORE SPRAY LOOP II OUTBOARD INJECTION VALVE NRC stated, as discussed for Criterion 2 and 3, that MOVs placed in their nonsafety position during valve or system testing must be capable of returning to their safety position or the system (or train) must be declared inoperable.
TVA concurs with this position and has determined that valves FCV-71-19, FCV-74'-52, FCV-74-66, FCV-75-23, and FCV-75-51 are outside of their safety position for valve operability (stroke) testing and the system (or train) will be declared inoperable during the time these valves are outside of their safety position.
Closure of valves FCV-74-'52 and FCV-74-66 is not required by plant procedures to operate the RHR system in the suppression pool cooling mode.
Therefore, these valves have no "redundant" safety function and will not be included in the GL 89-10 program.
The affected system or loop will be declared inoperable when these valves are not in their safety position.
Valves FCV-73-35, FCV-73-36, FCV-75-22, and FCV-75-50 can be out of their safety position for longer periods of time due to system flow testing.
Valve FCV-73-81 is a primary containment isolation valve which is normally aligned in the closed (safety) position.
These valves will be included in the scope of the GL 89-10 program.
The valves were previously designated as SOE valves and have been analyzed to the GL 89-10 program requirements.
Where possible, these valves w'ill be DP tested, or a comparison to valves which have been DP tested will be
.performed.
The issue of periodic verification will be
.addressed under BFN's GL 96-05 program.
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FCV-78-68 FUEL POOL COOLING TO THE REACTOR WELL The staff did not object to this MOV being deleted from the BFN GL 89-10 program.
B.
MOVs Originally Excluded From the BFN GL, 89-10 Program FCV-71-09 RCIC TURBINE TRIP VALVE FCV-71-17 RCIC PUMP SUCTION FROM TORUS FCV-71-18 RCIC PUMP SUCTION FROM TORUS NRC's review of these valves determined that they are not required to mitigate any design-basis
- accident, but they do have a requirement to function for events such as SBO and should be evaluated.
The BFN analysis for the SBO event does not take credit for suction path realignment for the RCIC pump.
Therefore, the RCIC pump suction valves from the torus, which are normally closed, will remain closed during this event.
The RCIC turbine trip valve only operates on turbine protection trip conditions.
The motive force for this action is provided by a mechanical spring arrangement.
The motor operator on the RCIC trip valve is not required to operate during an SBO event.
Therefore, these valves are normally aligned in their safety position.
The RCIC system will be declared inoperable when these valves are outside their safety position during valve operability testing.
FCV-71-37 FCV-71-38 FCV-73-34 FCV-75-02 FCV-75-11 FCV-75-30 FCV-75-39 RCIC PUMP DISCHARGE VALVE RCIC PUMP TEST RETURN VALVE HPCI PUMP DISCHARGE VALVE CORE SPRAY PUMP A TORUS SUCTION VALVE CORE SPRAY PUMP C TORUS SUCTION VALVE CORE SPRAY PUMP B TORUS SUCTION VALVE CORE SPRAY PUMP D TORUS SUCTION VALVE NRC stated that the above MOVs appear to be, placed in their nonsafety.position during testing while assuming the system (or train) remains operable, but their capability to return to the safety position had not been addressed.
All of the, above valves, with the exception of the RCIC pump test return valve (FCV-71-38) are normally in their
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safety position and remain in their safety position except during valve operability testing.
The affected system will be declared inoperable when these valves are not in their safety position.
The RCIC test return valve (FCV-71-38) will be included in the scope of the GL 89-10 program since it is out of its safety position for longer periods of time during system flow testing.
This valve will be analyzed to the GL 89-10 program requirements and DP tested, if possible.
The periodic verification of the valve will be addressed by BFN's GL 96-05 program.
FCV-74-01 FCV-74-12 FCV-74-24 FCV-74-35 FCV-75-02 FCV-75-11 FCV-75-30 FCV-75-39 RHR PUMP SUCTION FROM TORUS RHR PUMP. SUCTION FROM TORUS RHR PUMP'UCTION FROM TORUS RHR PUMP SUCTION FROM TORUS CORE SPRAY PUMP SUCTION FROM TORUS CORE SPRAY PUMP SUCTION FROM TORUS CORE SPRAY PUMP SUCTION FROM TORUS CORE SPRAY PUMP SUCTION FROM TORUS NRC stated that these valves appear to have a safety function associated with shutdown pipe break scenarios that was not addressed.
For BFN, none of the above valves have a pipe break isolation function during shutdown conditions.
Both the RHR and Core Spray systems at BFN are considered extensions of primary containment and are seismic class I piping systems.
The design pressure and temperature for the pump suction piping is significantly below the BFN criteria for line break conditions.
Therefore, these valves are not required to close for any safety function.
These valves are in their normal safety position of "open" with the exception of valve operability stroke time testing.
Consequently, when these valves are not in their safety position, the system (or train) will be declared inoperable.
The exception to this would be when RHR is in the Shutdown Cooling Mode.
Under those conditions, the affected loop would still be available for LPCI injection as provided for in the BFN TS (section 3.5.B) with a,manual realignment of the suction valves.
During this operation there are no thrust challenges based on the interlocks between the shutdown cooling valves and the torus suction valves.
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V.
SUMMARY
As a result of TVA's reevaluation of the BFN GL 89-10 program scope, fifteen (15) valves will be included in the BFN GL 89-10 program for both Units 2 and 3.
As shown in the list below, all of the valves, with the exception of FCV-71-38 (RCIC Test Return Valve),
have received the GL 89-10 design evaluation and have been baseline (static) tested.
Valve FCV-71-38 will be evaluated consistent with the BFN GL 89-10 Program requirements and baseline tested for Units 2 and 3.prior to restart from their next scheduled refueling outage.
For Unit 2 the next refueling outage (U2C9) is scheduled for October 1997 and for Unit 3 the next refueling outage (U3C7) is scheduled for February 1997.
For BFN Unit 2, DP testing or comparison with similar DP tested valves will be completed for each of the below listed valves within three months following t:he cycle 9
refueling outage (scheduled for October 1997).
For BFN Unit 3, DP testing or comparison with similar DP tested valves will be completed for each of the below listed valves by September 30, 1997.
UNID FUNCTION ANALYZED BASELINE TESTED FCV-70-47 RBCCW Primary Containment Isolation Valve FCV-,71-08 RCIC Turbine Steam Supply Valve FCV-71-25 RCIC Lube Oil Cooling Water Supply Valve FCV-71-34 RCIC Pump Minimum Flow Valve FCV-71-38 RCIC Test Return Valve FCV-71-39 RCIC System Injection Valve FCV-74-07 RHR Loop I Minimum Flow Valve FCV-74-30 RHR Loop II Minimum Flow Valve FCV-74-47 RHR Shutdown Cooling Containment Isolation Valve FCV-74-48 RHR Shutdown Cooling Containment Isolation Valve FCV-73-35 HPCI Test Return Valve FCV-73-36 HPCI/RCIC Test Return Valve FCV-73-'81 HPCI Steam Line Containment Isolation Valve Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes
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UNID FUNCTION ANALYZED BASELINE TESTED Core Spray Loop I Test.Return FCV-75-22 Valve FCV-75-50 Core Spray Loop II Test Return Valve Yes Yes Yes Yes The following eighteen
.(18) valves are normally in their safety position.
TVA does not plan to include these valves in the scope of BFN's GL 89-10 program.
- However, during ASHE Section XI stroke time testing, the affected system, or train, will be declared inoperable and the applicable TS LCO will govern until the valve is tested and declared operable.
TVA will revise the appropriate plant procedures by February 21,
- 1997, to require that the system, or train, be declared inoperable when the subject valves are not in their normal (i.e
, safety) position.
UNID FCV-71-09 FCV-71-17 FCV-71-18 FCV-71-19 FCV-71-37 FCV-73-34 FCV-74-01 FCV-74-12 FCV-74-24 FCV-74-35 FCV-74-52 FCV-74-66 FCV-75-02 FCV-75-11 FCV-75-30 FCV-75-39 FCV-75-23 FCV-75-51 FUNCTION RCIC Turbine Trip Valve RCIC Pump Suction from Torus
'RCIC Pump Suction from Torus RCIC Pump Suction from Condensate Storage Tank RCIC Pump Discharge Valve HPCI Pump Discharge Valve RHR Pump Suction from Torus RHR Pump Suction from Torus RHR Pump Suction from Torus RHR Pump Suction from Torus RHR Loop I LPCI Throttle Valve RHR Loop II LPCI Throttle Valve Core Spray Pump Suction from Torus Core Spray Pump Suction from Torus Core Spray Pump Suction. from Torus Core Spray Pump Suction from Torus Core Spray Loop I Outboard Injection Valve Core Spray Loop II Outboard Injection Valve
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With the addition of 15 valves to the BFN Units 2 and 3
GL 89-10 program, the total number of valves in the program for each unit is now 51.
Below is a complete listing of the BFN GL 89-10 program valves and their function.
UNID FCV-01-55 FCV-01-56 FCV-23-34 FCV-23-40 FCV-23-46 FCV-23-52 FCV-68-03 FCV-68-7 9 FCV-69-01 FCV-69-02 FCV-70-47 FCV-71-02 FCV-71-03 FUNCTION Main Steam Drain Line Isolation Valve Main Steam Drain Line Isolation Valve RHRSW Throttle Valve to RHR A Heat Exchanger RHRSW Throttle Valve to RHR C Heat Exchanger-RHRSW Throttle Valve to RHR B Heat Exchanger RHRSW Throttle Valve to RHR D Heat Exchanger Recirculation Pump A Discharge Isolation Valve Recirculation Pump B Discharge Isolation Valve RWCU Primary Containment Isolation Valve RWCU Primary Containment Isolation Valve RBCCW Primary Containment Isolation Valve RCIC Steam Line Primary Containment Isolation Valve RCIC Steam Line Primary Containment Isolation Valve FCV-71-08 FCV-71-25 FCV-71-34 FCV-71-38 FCV-71-39 FCV-73-02 FCV-73-03 FCV-73-16 FCV-73-26 FCV-73-27 FCV-73-30 RCIC Turbine Steam Supply Valve RCIC Lube Oil Cooling Water Supply Valve RCIC Pump Minimum Flow Valve RCIC Test Return Valve RCIC System Injection Valve HPCI Steam Line Primary Containment Isolation Valve HPCI Steam Line Primary Containment Isolation Valve HPCI Turbine Steam Supply Valve HPCI Pump Torus Suction Valve HPCI Pump Torus Suction Valve HPCI Pump Minimum Flow Valve
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UNXD FCV-73-35 FUNCTION HPCI Test Return Valve FCV-73-36.
HPCI/RCIC Test Return Valve FCV-73-40 FCV-73-44 FCV-73-81 FCV-74-07 FCV-74-30 FCV-74-47 FCV-74-48 FCV-74-53 FCV-74-57 FCV-74-58 HPCI Pump CST Suction Valve HPCX System Xnjection Valve HPCI Steam Line Containment Isolation Valve RHR Loop I Minimum Flow Valve RHR Loop II Minimum Flow Valve RHR Shutdown Cooling Containment Isolation Valve RHR Shutdown Cooling Containment Isolation Valve RHR Loop I LPCI Injection Valve RHR Loop I Pump Discharge to Torus RHR Loop I Torus Spray Valve FCV-74-59 RHR Loop I Test Return Valve FCV-74-60 FCV-74-61 FCV-74-67 FCV-74-71 FCV-74-72 FCV-74-73 FCV-7'4-74 FCV-7'4-75 FCV-75-09 FCV-75-22 FCV-75-25 FCV-75-37 FCV-75-50 FCV-75-53 RHR Loop I Drywell Spray Valve RHR Loop I Drywell Spray Valve RHR Loop II LPCI Xnjection Valve RHR Loop II Pump Discharge to Torus RHR Loop II Torus Spray Valve RHR Loop II Test Return Valve RHR Loop XI Drywell Spray Valve RHR Loop II Drywell Spray Valve Core Spray Loop I Minimum Flow Valve Core Spray Loop I Test Return Valve Core Spray Loop I Injection Valve Core Spray Loop II Minimum Flow Valve Core Spray Loop II Test Return Valve Core Spray Loop II Injection Valve E1-16
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ENCLOSURE 2
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 2 AND 3 GENERIC LETTER (GL) 89-10, SAFETY-RELATED MOTOR-OPERATED VALVE (MOV) 'TESTING AND SURVEILLANCE
RESPONSE
TO REQUEST FOR REEVALUATION REGARDING MOV SCOPE REDUCTION COMMITMENT
SUMMARY
TVA will add the following fifteen MOVs to the GL 89-10 program for Units 2 and 3 by January 31, 1997.
FCV-70-47 FCV-71-38 FCV-74-47 FCV-73-81 FCV-71-08 FCV-71-39 FCV-74-48 FCV-75-22 FCV-71-,25 FCV-74-07 FCV-73-35 FCV-75-'50 FCV-71-34 FCV-74-30 FCV-73-36 2.
3.
TVA will perform the-design analysis and baseline (static) testing for the Unit 2 Reactor Core Injection Cooling (RCIC) Valve (FCV-71-38) prior to restart from the Cycle 9 refueling outage.
TVA will perform the design analysis and baseline (static) testing for the Unit 3 Reactor Core Injection Cooling
'(RCIC) Valve (FCV-71-38) prior to restart from the Cycle 7 refueling outage.
TVA will perform differential pressure (DP) testing, if
- possible, or perform evaluations against DP testing of similar valves for the fifteen valves added to the BFN Unit 2 GL,89-10 program within three months following the cycle 9 refueling outage (October 1997).
5.
TVA will perform differential pressure (DP) testing, if
- possible, or perform evaluations against DP testing of similar valves for the fifteen valves added to the BFN Unit 3 GL 89-10 program by September 30, 1'997.
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BFN will revise plant procedures for Units 2,and 3 by February 21,
- 1997, to require that the applicable
- system, or train, be declared inoperable when the eighteen valves, listed below, are not in their normal (i.e., safety) position.
FCV-71-09 FCV-71-37 FCV-74-24'CV-75-02 FCV-75-23 FCV-71-17 FCV-73-34 FCV-74-35 FCV-75-11 FCV-75-51 FCV-71-18 FCV-74-01 FCV-74-52 FCV-75-30 FCV-71-19 FCV-74-12 FCV-74-66 FCV-75-39 E2-2
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