ML20024H107
| ML20024H107 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/14/1991 |
| From: | Wallace E TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-11324, TAC-11325, TAC-11326, NUDOCS 9105210408 | |
| Download: ML20024H107 (6) | |
Text
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4 MAY 141991 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-259 Tennes.sco Valley Authority
)
50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - AMEH1CAN SOC!.ETY OF MECilANICAL ENGINEERS (ASME) SECTION XI -- PUMP AND VALVE TESTING (P&VT) PROGRAM, CHANCES AND CLARIFICATIONS Reference 1:
"BFN - American Society of Mechanical Engineers ( ASME)
Section 11 - Pump and Valvo Testing Program (TAC Nos.
11324, 11325, 11326)"
2: Generic Letter b!c. M-04 dated April 3, 1989, NHC's Guidance for Developing an Accept 9blo In-service Testing Program Enclosed are changen and clarifications to TVA's pump and valvo program which was submitted by Reference 1.
Based on technical discussions with URC program reviewers und TVA personnel there were three areas identified in the program submittel which needed to be changed.
The following is a list of the changes:
1.
Relief Request No. PV-23 has been revised to more clearly indicate the basis for the request and to better explain the alternate testing proposed is in accordance with Reference 2.
2.
The envised Cold Shutdown Justification No. 7 is being revised to better describo the testing of the main steam isolation valves.
Relief Roquest No. PV-35 is being submitted for the fall-cafo testing of the inboard MSIV's.
3.
Cold Shutdown Justification No. 12 is being withdrawn.
The control air drywell isolation valves will be tested quarterly as required by the ASME code.
91CG210406 910514 PDR ADOCK 05000259 pg/7 P
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E U.S. Nuclear Regulatory Commission kIAdf 141991 The above changes resolve the NRC review comments.
There are no connitments contained in this letter.
If you have any questlons, please telephone Patrick P. Carier, BFN, (205) 729-3570.
Very truly yours.
TENNESSEE VALLEY AUTHORITY 9'f
' c, v-E. C. W 11 ace, Manager Nuclear Licenning and Regulatory Affairs cc-(Enclosures):
Ms. S. C. Black, Deputy Director Project Directorato 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockvillo Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manaaer U.S. Nucicar Regulatory Commincion One White Flint, North 1159 Rockville Pike Rock /ille, Moryland 20852 Mr.. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 l
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1 I
Relief Request Number PV-35 Page 1 of 1 Systems Main Steam (1)
Drawing:
47E801-1 Valves FCV-1-14, 26, 37, 51 Class 1
Functiont Main Steam Isolation Valve Inboard of Primary Containment Impractical Test Requirement Fall-safe position testing of valves once cach quarter or on a cold shutdown basis.
Basis for Relieft The fail-safe testing of these main steam isolation valves (MSIVs) requires the isolation of control air to the valve operator and the venting of the cont *:01 air accumulator for the valve.
The MSIV the control aft isolation valve, and accumulator are located inside prin ry containment.
This test would require a primary contain.ient entry, which is precluded during operation because the containment atmosphere is inerted with nitrogen ges for oxygen control.
In addition, the inert atmosphere is maintained during short duration cold shutdown periods when entry into containment is not mandatory.
The extended downtime and the cost required to purge the containment vessel to allow entry for the test and to re-inert the vessel prior to' restart place an operational and financial hardship on the utility without a connensurate increase in safety.
Alternative Testings
-The fail-safe function of these valves will be tested at each cold shutdown during which the containment vessel.
atmosphere does not remain inerted, provided they have not been tested within the previous three months.
Should-the containment vessel atmosphere remain inerted for an entire fuel cycle, these valves will be tested at a minimum of once each refueling outage.
2
Relief _ Request Number PV-23 Page 1 of 2 Systems Control Rod Drive Hydraulic (85)
Drawingt 47E820-2, 47ES20-5 (U2), and 47E820-6 (Ul&3)
Category Valvest FCV-85-39A (1-185)
B FCV-85-39B (1-185)
B FCV-85-589 (1-185)
C FCV-85-597 (1-185)
C FCV-85-616 (1-185)
C FCV-85-617 (1-185)
C Classt Function:
Control Rod Scram Water Flow Path Impractical Test Requirement:
Exercise once every three months and measure stroke times.
Basis for Relieft _These_ valves located on the hydraulic control units for the-
-i 185 control rod drives function on a reactor signal from the teactor 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.- Scramming every rod once every three months is not practical for the following reasons:
a.
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.
b.
Fuel preconditioning'must follow this power reduction to avoid possible fuel damage.
The longer the reduction in power, the longer the preconditioning.
Th'eir proper functioning-is most practically verified by an actual scram test (except for closure of 85-589). The closure of 85-589 is demnnstrated in a special test which verifies that the CRD accumulators maintain pressure after the CRD pumps have been stopped.
Alternative Testing -
1.
Scram testing and rod insertion timing will be performed in accordance with Technical Specifications l-Section 4.3.0 (at reactor coolant pressure 800 psig) fort a.- All control rods _ prior to thermal power exceeding 40 percent after each refueling outage.
Page 2 of 2 b.
10 percent on a rotating basis at least once every 16 weeks.
2.
Scram charging water check valve (85-589) closure test - each refuelint outage.
This alternate testing is consistent with NRC staff position No. 7 in Generic Letter 89-04 " Guidance on Developing Acceptable Inservice Testing Programs."
Page 1 of 1 COLD SHUTDOWN JUSTIFICATION NUMBER 7 Systems Main Steam Drawing 47W801-1 Valves:
1-14, 1$
26, 27, 37, 38, 51, 52 Category:
A Class:
1 Function:
Main steam Isolation Justification:
Cycling of these valves during power operation requires a
. reduction in power to less than 70 percent of full power.
Per IW-3412(a), valves shall be exercised unless such.
1 operation is not practical during plant operation. Valves will be partially stroked quarterly, and full stroked on a 4
cold shutdown basis.
The valves located outside primary containment, 1-15, 27, 38, and 52, will be fail-safe tested on a cold shutdown basis.
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