ML20082S010

Review of Inservice Testing Program for TVA Nuclear Power Plants

ML20082S010
Person / Time
Site:	Browns Ferry
Issue date:	08/13/1990
From:	Murphy G MARTIN MARIETTA ENERGY SYSTEMS, INC., OAK RIDGE NATIONAL LABORATORY
To:	Jason Huang Office of Nuclear Reactor Regulation
Shared Package
ML20082R989	List: ML20082S010
References
CON-FIN-F-0001, CON-FIN-F-1 NUDOCS 9109160338
Download: ML20082S010 (13)

Text

.. ._. _ . - _ . _ - _ .. . _ - __ ._.. _ . _ __

a t. . .

b ATTACHMENT 1 OPEl,/NRC/LTR.90/21  ;

l r

. Program: Reviey of Inservice Testing Frogram for TVA Nuclear Power Plants

Subject:

- Request for Relief, Pump and Valve  ;

Inservice Testing Program, Browns Ferry  ;

Nuclear Plant, Units 1, 2, and 3, Docke-Nos. 50 259, 50 260, 50 296  ;

r Type of Document: Technical Evaluation Report  ;

Authors: G.A.' Murphy Date of Document: August 13, 1990 [

Responsible NRC Individual: J. Huang, NRC' Office of Nuclear Reactor [

Regulation >

1 Prepared for the -i U.S. Nuclear Regulatory Commission l Washindton, D.C. 20555 i under Interagency Agreement DOE.1886-Y000 1F lr NRC FIN No..F0001 Prepared by the i

(. Nuclear Operations Analysis Center [

Engineering Technology Division  ;

OAK RIDGE NATIONAL 1ABORATORY l, Oak Ridge, Tennesste 37831 l

operated by MARTIN MARIETTA ENERGY SYSTEMS, INC.

for the

• U.S. DEPARTMENT OF ENERGY .

under Contract No. DE-AC05-840R21400 9109160330 910910 i

PDR ADOCK 05000259 P PM

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I TECHNICAL EVALUATION REPORT

1. Introduction '

The purpose of this Technical Evaluation Report (TER) it to evaluate a request for changes to the pump and valve Inservice Test Program (IST)

-(Reference 1) submitted in a letter dated June 22. 1989 (Reference 2) by the Tennessee Vality Authority (TVA) for the Browns Ferry Nuclear Station

-(BFN)-Units 1, 2, and 3.

The Nuclear Operations Analysis Center (NOAC) at Oak Ridge National Laboratory .(ORNL) was contracted by the Nuclear Regulatory Commission (NRC) to review proposed revisions to the TVA.RFN Pump and Valve Inservice Test Program for conformance to the ASME Code (Reference 3). l

-The Licensee's-submittal;in Reference 2 contains two enclosures.

Enclosure 1~provides a complete explanation of the proposed program-changes -

and Enclosure'2 provides a summary _ list of all revisions. NOAC has reviewed Enclosure 1 but not Enclosure 2. The revisions were evaluated to determine if the changes to the IST Program conformed to code requirements cnd are in accordance with; applicable sections of 10CFR50.55a. The detailed evaluations are provided below.

2. Evaluations and Conclusions 2.1 PV 14 Addition of_ Valve 1 24 709 and Alternative Testing for Quarterly Exercising of Emergency Equipment Cooling Water and Raw Cooling Water

~ Check Valves Code Reauirement I

IWV 3521:-" Check-valves shall be exercised at least once every 3 months,

~

except as provided by IWV 3522."

Relief Recuest This . relief request was approved by NRC!in Reference 4 --The licensee

' resubmitted this relief request for,NRC review because-two changes were 1 proposed. One change added valve 1-24 709 to the' relief request.- The other change specified disassembly and inspection as the alternate L method ~of verifying valve closure, although in the original l relief

-request other' proven methods such as acoustic monitoring techniques were under consideration.

The Licensee has' requested relief from the IWV-3521 and .3522

_ requirements to exercise'the designated valves;to closure at-least once every three months during operation. or at cold' shutdown. The Licensee proposes to remove and visually inspect the valve internals at each l refueling outage in accordance with Ceneric Latter 89-04 L

2-1 l?

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' - - ' ' ' ' ' * ' ' ' ~ " ' " ~ " ~ " ~

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Licensee's Basis for Reauestina talief

. System design prevents _ the valves from being verified closed by reverse flow measurements or other conventional means. Therefore, closure verification by. disassembly is required. Since the valves will be verified open once every three months by flow verification, apparent disc- free movement will be indicated.

Eyaluation A review of the plant P& ids and system design indicates that check valve 1 24 709, like all others originally contained in this relief request,-

could-not be verified closed by reverse flow or other conventional means

during power operation, cold shutdown, or refueling outage. Therefore adding check valve 1 24 709 to this relief request is appropriate

~ because this valve needs the same relief consideration as the others in the relief request.

The original relief request was approved on the promise that the licensee proposed to exercise these valves and to verify proper closure by positive means once each refueling cycle. The positive means-mentioned include disassembly, acoustic monitoring, or other proven methods. In this revised relief request, the licenses has chosen disassembly _ and inspection as the 'only alternate method to verify check valve closcre.

'=

Disassembly and inspection can provide useful information on the condition and integrity of valve internals, .and in some cases verify valve opening capability. However, in _ terms of check valve - testing, the method:provides little-information on valve capability to seat promptly on. cessation or reversal of flow.' Furthermore..if the method involves extensive disassembly,_a post-reassembly test would be necessary per IWV 3200 because disassembly and inspection can lead to increased probability of human error when the valve is reassembled. Therefore, in view of-the bene"it of disassembly.andEinspection of valve internals and potential human error ~upon reassembly, the proposed method should only-

-be considered as a last resort and is acceptable as.attemporary alternate. The-licensee-should evaluate other methods of verification of valve closure such as radiographing or acoustic monitoring and

. implement them when they become effective and available.

Conclusion Compliance _with the requirements-of IWV-3521 for quarterly: testing would-result-in hardship-or unusual difficulty without a compensating increase

. in the level. of quality or safety. _ The method proposed by the-licensee to disassemble and inspect the valves in question at refueling outage

-intervals =is, at this time, the only practical means to verify valve closure._ Therefore it.is found acceptable as a temporary measure until -

more. effective methods are available and relief should be granted i pursuantEto 10 CFR 50.55a(a)(3)(ii).

Upon-iaplementation however, the licensee should observe the guidance provided in NRC Ceneric letter 89 04 regarding disassembly and inspection of-check valves. In view of the-large number of-check valves 2-2

. . . - . _. m.m.- m_, ,_ , _ , , , - - ._ ._ ..,_ _ . _ _..,_,__,.,,m-,- , . . ,

(a total of 71 valves including valve 1 14 709) to be disassembled, a sampling plan for groups of identical valves in similar application should bo employed to minimize the possibility of human error upon reassembly.

2.2 PV 23, Quarterly Exercising and Stroke Timing of CRD HCU Valves Code Reauirement

.IVV-3410: " Category A and B valves shall be exercised at least once every 3 months, except as provided by IWV 3412(a), IVV 3415 and IWV-3416.=

IWV 3521: " Check valves shall be. exercised at least once every 3 months, except as provided by IVV 3522."

Relief Recuest This relief request was approved by NRC in Reference 4. The licensee resubmitted the relief request for NRC review because a revision was proposed. The revision removes the commitment to verify closure of cooling water check valve 85-589, and scram accumulator charging check valve 85 5s7 during cold shutdown.

This revision removes the commitment to inspect by disassembly, acoustic monitoring. or other positive means during cold shutdown, the control rod drive (CRD) cooling water check valve, 85 583, and the scram accumulator charging check valve, 85 597, on each CRD hydraulic control unit (HCU). The essting of these two valves vill be verified during an actual scram test, as are the other four valves on the HCU that require testing.

Licens3e's Basis for Recuestine Relief the Licensee determined that check valve 85 597 does not perform a safety function in the open direction based on paragraph 3.4.5.3.1c of the FSAR. Valve 85 589 is tested in the open position during control rod scram and reset tests conducted under Technical Specification 4.3.c.

.Both valves are varified closed during the control rod scram time tests, the same as the other four valves listed in PV 23.

Evaluation The original relief request was approved on the basis that the scram test performed per Technical Specification 4.3.c adequately exercised and verified the functioning of the CRD HCU valves (except fot the closure of check valvas 85 589 and 85-597). These two valves would be proven closed by disassembly, acoustic monitoring techniques, or by other positive means during each refueling oucage.

A review of the scram test required by Technical Specification (TS) 4.3.c indicates that the closure of the valves 85 589 and 85 597 could not be verified by the scram test because the CRD pumps could not ba i stopped to depressurize the charging and cooling water headera during 2-3

the test. $!nce the scram test cannot verify the closure of valves85-589 and 85-597, the proposed revision is therefore not acceptable.

G2nelusion The proposed resision unwarrantedly removes the cooling water check valve and the scram accumuistor check valves from the code required closure test and is therefore found not acceptable. NRC Ceneric Letter 89 04, Position 7, discusses acceptable methods of verifying the closure capability of the affected valves. The licensee is advised to review the Generic Letter and determine if those methods are applicable to its case. If so, the relief request should be revised according to the Generic Latter. 'If not, the licensee should choose one of the methods proposed in CL 89 04, preferably a non intrusive one, to verify closure of the two affected valves.

2.3 PV 25, Stroke Timing Rapid Acting Valves.

Code Reauirement Paragraph IWV 3417(a) - Corrective Action Relief Recutti This relief request was originally submitted by the licensee. in Reference 1 and approved by NRC in Reference 4 The licensee resubmitted this relief request because a revision was proposed (Reference 5). The revision adds full stroke testing of RCIC Turbine

'Stop Valve 71-9 to relief request PV-25 and removes Turbine Control Valve 71 10 from the IST Program.

In Reference 4 the Licensee was granted relief from the stroke time trending and increased testing frequency requirements of IWV-3417(a) for the valves listed in FV-25 that have stroke times of less than two seconds. For valve 71 9, they will specify a maximum full stroke time limit-of two seconds.

Licensee's Basis for Reauestine Relig{

Valves with stroke time less than 2 seconds cannot be accurately timed.

The Licenses' does not have the special equipment and setups rer,uired to accurately. stroke time the subject valves for trending in conformance with 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.

Evaluation The original relief request was approved on the basis that stroke timing of rapid acting valves to meet Code requirements is not considered to result in sufficiently improved assurance of plant safety to warrant the burden of installing special test equipment and setups. The licensee's proposal of two second maximum stroke time for fast-acting valves 24

provides an acceptable level of quality and also is consistent with the NRC staff position documented in Generic Latter 89-04 A review of the function and design of valve 71 9 indicates it meets the criteria for fast acting valves. Therefore, adding valve 71 9 to this relief request is appropriate because this valve needs the same relief consideration as'for all others in the relief request.

In the case of valve 71 10, since it is used only for system control, it is permissible to remove it from the testing program. The ASKE Code does not. require testing of control valves.

Conclusion Based on the similarity of all the valves in the relief request, the partial relief from IWV-3417(a) that had been granted to the other valves should also be granted to valve 71-9 pursuant to 10 CFR 50.55a(a)(3)(1). The proposed testing provides an acceptable level of quality and safety and meets the intent of code section IWV 3417(a).

The removal of valve 71-10 from the testing program is also acceptable.

2.4 -PV Addition of RCIC Check Valve 71-502 and HPCI Check Valve 73-505, and Alternative Testing for the Quarterly Closure Exercising of RCIC Check Valves71-589 and -502 and HPCI check Valves73-625 and -505 Code Recuireggni-l IWV-3521: " Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522." ,

-Relief Recuest This relief request was approved by NRC in Reference 4 The licensee i

resubmitted this. relief request for NRC review because two changes were proposed. One change added RCIC check valve 71 502 and.HPCI check valve 73-505 to the relief request. The other change specified disassembly l and inspection as the alternate method of verifying valve closure, i

-although in the original relief request other proven methods such as acoustic monitoring techniques were under consideration.

l The Licensee has requested relief from the IWV-3521 and 3522 g requirements to exercise the designated valves to closure at least once L every three months during operation or at cold shutdown. The Licensee

! proposes to remove and visus 11y inrpact the valve internals at each l

refueling outage in accordance with Generic Letter 89-04.

Licensee's Basis for Recuestine Relief l System design prevents the valves from being verified clcsed by reverse

flow or other conventional means. Therefore, closure verification by

-disassembly is. required. Since the valves will be verified open once i

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every three months by flow verification, apparent disc free movement I will be indicated.'

Evaluation ,

i A review of the plant P&!Ds and system design indicates that valves j 71-502 and 73 505 like the~others originally contained in this relief  !

request, could not be verified closed by reverse flow or other '

conventional means during power operation, cold shutdown, or refueling i outage. .Therefore' adding valves71-502 and.73 505~to this relief request: is appropriate because the valves need the same- relief l

. consideration as the.others in_the relief request. i The original' relief request was approved on the premise that the  !

licensee proposed to exercise these valves and to verify proper closure ,

by positive means once each refueling cycle. The positive means.  ;

-mentioned include disassembly,_ acoustic monitoring,-or_other proven i methods. In this-revised relief request, the licensee has chosen '

disassembly. and inspection as the only alternate method to verify check valve closure.  ?

-Disassembly and inspection can provide useful information on the l condition and integrity of valve internals,. and in:some cases verify- .

[

-. valve-opening capability. However, in terms- of check valve testing, the i method provides little information on valve capability to seat promptly  ;

on cessation or-reversal of flow.- Furthermore, if the method involves- '

extensive; disassembly, a post reassembly test would be necessary per #

-IVV 3200-because disassembly and inspection can lead co increased L probability of human error when the valve is reassembled. Therefore, in ,

p view of the benefit of disassembly and inspection of _ valve internals and j L fpotential human error upon reassembly, the proposed method should only '[

l- be considered as a last resort and is acceptable as a temporaryL -

alternate; The licensee should evaluate other methods of verification i of valve' closure such asLradiographing or acoustic monitoring and

~

L i L implement 1them when they become effective and.available. l j Conclusion- l

? I Compliance with the requirements of IWV-3521 for quarterly testing would  :

result in hardshipjor unusual difficulty.without a compensating" increase  !

in the: level of quality or safety. Mme method proposed by the licensee to~ disassemble and inspect the valves in question at refueling outage-incervals is, at this time, the only practical means to verify valve' _  !

, closure. LTherefore it.is-found acceptable as at temporary measure until  !

[

L more effective methods are available and relief should be granted -

1 pursuant to 10 CFR 50.55a(a)(3)(ii).

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f Upon: implementation however, the licensee should observe _the guidance provided in NRC Ceneric-Latter 89 04 regarding disassembly and '

inspection of check valves.

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2.5 PV 32, Quarterly Exercise of Standby Liquid Control (SLC) Check Valves 63 514, and 516.

Cpde Reauirement ik"V 3521: " Check valves shall be exercised at least once every 3 months, except as provided by IWV-3522."

Relief Recuest 4

This is a new relief request added to the program that was originally.

4 submitted and approved in Reference 4. This revision adds standby 4

liquid cent ol check valves 63 514 and 516 to the Pump and Valve Inservice Test Program; and also designates disassembly and inspection i

as an alternate method for testing these valves. The Licensee has requested relief from the IWV 3521 and -3522 requirements to exercise the. designated valves to closure at least once every three months during operation or at cold shutdown. The Licensee proposes to disassemble one check = valve at each refueling outage, on a rotating basis, to verify its backsesting capability. Should the disassembled valve fail to function properly, the other valve will also be disassembled and examined. These

' valves will be full setoked to the open position during quarterly SLC pump testing.

I Licensee's Basis for Recuestine Relief

SLC system design prevents these valves from being verified closed by reverse flow measurements or other conventional means. Therefore, closure verification by disassembly is required. Since the valves will be verified open once every three months by flow verification, apparent disc free movement will be indicated, c Evaluation l A review of the SLC system design and Browns Ferry FSAR Section 3.8 indicates that testing of the backseating capability of these valves is not possible during power operation or cold shutdown. The SLC pumps are positive displacement and there is no drain or vent line between these valves and the SLC pumps consequently, testing using differential pressure is not possible.

'The Licensee specifies disassembly and inspection as the chosen method of verifying valve closure, although other proven methods such as acoustic. monitoring techniques may be available.

-. Disassembly and. inspection can provide useful information on the condition and integrity-of valve internals, and in some cases verify valve opening capability. However, in terms of check valve testing, the method provides little information on valve capability to seat promptly

on cessation or reversal of flow. Furthermore, if the method involves extensive disassembly, a post reassembly test would be necessary per IWV-3200 because-disassembly and inspection can lead to increased probability of human error when the valve is reassembled. Therefore, in view of the benefit of disassembly and inspection of valve internals and potential human error upon reassembly, the proposed method should only t

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a be considered as a last resort and is acceptable as a temporary alternate. The licensee should evaluate other methods of verification of valve closure such as' radiographing or acoustic monitoring and implement them when they become effective and available.

Conclusion Compliance with the requirements of IWV 3521 for quarterly testing would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. The method proposed by the Itcensee

.to disassemble and inspect the valves in question at refueling outage intervals is, at this time, the only practical means to verify valve closure. Therefcre it is found acceptable as a temporary measure until more effective methods are available and relief should be granted pursuant to 10 CFR 50.55a(a)(3)(ii).

Upon implementation however, the licensee should observe the guidance provided in NRC Generic Letter 89 04 regarding disassembly and inspection of check valves.

2.6 PV 33, Quarterly Exercise of Emergency Equipment Cooling Water (EECV)

Check Valves67-538, -539, -652, -653 -787, and -789 Code Recuirement 4

IVV 3521: " Check valves shall be exercised at least once every 3 months, except as provided by IVV 3522."

Relief Recuest This is a new relief request added to the program originally submitted and approved in-Reference 4. This revision adds six EECW check valves (67-538, -539, -652, 653. -787, and -789) to the Pump and Valve

-Inservice Test Program; and also designates disassembly. and inspection as an alternate method for testing these valves. The Licensee has requested relief from the IVV-3521 and -3522 requirements to exercise the dasignated valves to closure at least once every three months during operation or at cold shutdown. The Licensee proposes to disassemble two

- check valves at each refueling outage, on a rotating basis, to verify their backseating capability. Should the disassembled valves fail to function properly, the'other' valves will also be disassembled and examined. These valves will be full stroked to the open position quarterly as required.

Licensee's Basis for Recuestina Religi EECW system design prevents these valves from being verified closed by reverse flow measurements or other conventional means. Therefore, closure verification by disassembly is required. Since the valves will be verified open once every three months by flow verification, apparent disc free movement will be indicated.

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~ - ._ . . .

Evaluation A review of the EECV system design and Browns Ferry FSAR Section 10.10 indicates that testing _of the backseating capability of these vs1ves is not possible during power operation or cold shutdown. The valves can not be. individually isolated. No drain or vent lines are available for '

the piping containing these valves. Since disassembly of one of these check valves disables either the control room chillers or the emergency cooling unit, testing is limited to refueling outages. The Licenses specifies disassembly and inspection as the chosen method of verifying valve closure, although other proven methods such as acoustic monitoring techniques may be available.

Disassembly and inspection can provide useful information on the  !

condition and integrity of valve internals, and in some cases verify valve opening capability. However, in terms of check valve testing, the method provides little informatien on valve capability to seat promptly on cessation or reversal of flow. Furthermore, if the method involves extensive disassembly, a post-reassembly test would be necessary per ,

IWV-3200 because disassembly and inspection can lead to increased probability of human error when the valve is reassembled. Therefore, in view of the benefit of disassembly and inspection of valve internals and potential human error upon reassembly, the proposed method should only.

be considered as a last resort and is acceptable as a temporary alternate.. The licensee should evaluate other methods of verification of valve closure such as radiographing or acoustic monitoring and '

implement them when they become effective and available.

l Conclusion

! Compliance with the requirements of IWV 3521 for quarterly testing would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. The method proposed by the licensee to disassemble and inspect the valves in question on a rotating basis at refueling outage intervals is, at this time, the only practical means to verify valve closure. Therefora it is found acceptable as a temporary measure until more effective methods are available and relief should be granted pursuant to 10 CFR 50,55a(a)(3)(ii).

1 ,

l. Upon implementation however, the licensee should observe the guidance provided in NRC Ceneric Letter 89-04 regarding disassembly and inspection of check valves.

2.7 PV 34, Quarterly Stroke Timing of Diesel Air Start Valves.

Code Recuirement ,

IWV-3411: " Category A and B valves shall be exercised at least once ,

every 3 months, except as provided by IWV-3412(a) IWV-3415, and IWV-  ;

3416."

IWV-3413(b): "The stroke time of all power operated valves shall be measured ..."

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Relief Raouest This is a new relief request added to the program that was originally >

submitted and appreved in Reference 4. This revision adds eight diesel i

, generator air start valves to the Pump'and Valve Inservice Test Program; and also designates a fast start of the diesel generator within 10 seconds of initiation as the stroke time test for these valves.  ;

The Licensee has requested relief from the IWV 3411 and 3413 requirements to stroke time test these valves once every three months.

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Licensee's Basis for Reouestina Religi Because of the configuration of the diesel air start system, there is no '

method to individually time the stroke of each air start valve. The  ;

plant Technical Specifications require that the time period between the '

initiation of a diesel engine start signal and actual engine start not l exceed ten seconds. This specification is verified monthly by the

• Technical Specification surveillance requirements. During a diesel '

en51 ne start, the diesel air start valves must move from the-closed

• position to the open position to cause the engine to start. Failure of i the valves to operate properly will prevent the engine from starting.  ;

The successful start of a diesel engine within ten seconds of the fast start-initiation signal will demonstrate the proper operation of the air start valves. This test will be conducted monthly in accordance with ,

the plant Technical Specifications.

Evaluation A review of the Browns Ferry diesel air start system indicates that the starting air valves are solenoid typa valves which are accessible only by disassembling the engine starting system. These valves'can not be operated independently, but operate only in response to a diesel generator start signal. There exists no position indication nor visible t moving part to allow stroke timing of these valves.

Diesel generator start tests which verify that the starting time of the diesel does not exceed ten seconds are performed on a monthly basis in l accordance with plant Technical Specifications. The TSs requires that the engine start within ten seconds. Degradation in stroke time of '

these valves would prevent diesel starting within the.syacified ten  !

seconds. Since the diesel engine start time is (in part) a function of the air start valve stroke time, successful completion of the diesel start test would provide satisfactory assurance of valve operational I

readiness. *

- Conclusion The system testing provides an acceptable level of quality and safety ,

and meets the intent of IWV 3411 and .3413(b). Full compliance with i Code requirements is not possible with the present system design. The use of the system test in place of the component test appears to be the ,

only practical means of monitoring the performance of the air start f

2-10 "

i t

r valves. The partial relief requested by the Licensee f .* the Code I

recuirements should be granted pursuant to 10 CFR 50.556sa)(3)(1).

'i Cold Shutdown (CSD) Justific6 tion Number 7 Main Steam Isolation Valves 1 14 15, 26. 27, 37. 38 51, and 52.

Code Recuirement IWV 3412(a): " Valves shall be exercised to the position required to fulfil their function unless such operation is not practical during plant operation..."

IVV 3415 Fail Safe Valves: "If these valves cannot be tested once every three months, they shall be tested during each cold shutdown;...' but need not be tested more often than on'ce every three months.

Evaluation This is a revision of CSD Justification Number 7 that was originally submitted in Reference 1 and approved by NRC in Reference 4. This revision (Referenes 5) adds full etroke testing at cold shutdown, which is acceptable under the Cod requirement and fail safe testing at refueling outages.

In the c.ase of fail safe testing at each refueling outage (instead of during cold shutdown), the Licensee mui abait a request for relief to test the valves during refueling outage 6, The Licensee's revision of this Cold Shutdown Justification does not provide adequate justification to perform fail safe testing of these valves only during refueling outages, fantin12n The Licensee's justification for fail safe testing during refueling outages should be submitted as a request for relief from the Code requirement. Sincs the Licensee has not presented adequate ,

justification to perform fail-safe testing of these valves only during refueling outages, the testing should therefere be performed during each cold shutdown.

2.9 Cold Shutdown Justification Number 2 Fat) Safe Testing of Control Air Dryvell Compressor Suction Isolatir 4 Valves 32 62 and 32 63 Cnds Recuirement IVV 3415 Fail Safe Valv6s: "If these gives cannot be tested once every three months, they shall be tested dura A sach cold shutdown;...' but need not be tested more often than once s 'ery three months.

The Licensee proposes to perform the fail safe test only when the plant is in cold shutdovn and the control air system to the dryvell is not required to be in service.

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. . - _ ~ _ . . _ . - _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ . . . -

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.* l The valvas in qu3stien cro lock tested under th3 App ndix J Test Pragram and are remotely stroke timed on a quarterly basis in accordance with C(de requirements. These valves'can only be fail. safe tested when plant

' r9eTS allows inclation of the control air system for the drywell. The i L.censee's cold shutdown justification proposes to fail safe test t;ie  !

valves only when the plant is in cold shutdown and control air to the i drywell is not required to be in service . j Evaluation l,

t The Licensee has committed to test the valves at cold shutdown, but only i when the control air system for the drywell is not required to be in s e rvice . In accordance with IVV.3415, the valves must be tested at  ;

least during each cold shutdown, but not more often than once every '

three months. The Licensee has not submitted adequate justification for testing anly when the drywell air system can be isolated, presumably at more than the allowed interval of once every three months.

It is not clear why the valves cannot be fail safe tested at the same  ;

time the quarterly stroke time test is performed, or in conjunction with the Appendix J testing.  ;

It is suggested that the Licensee clarify the intent of this CSD or  !

prepare a request for relief to feil safe test only when the drywell air  !

system can be isolated.

ggnelusion 2 Addition of this proposed cold shutdown justif! cation to the program is acceptable.but the required fail safe testing must be performed during each cold shutdown. Testing to beyond CSD frequency requires a relief request.

3~ References

1. Browns Ferry Nuclear Plant . ASKE Section XI Pump and Valve Test Program, March 25, 1988.

2. Latter from TVA to U.S. NRC, dated June 22, 1969, " Browns Ferry Nuclear Plant . ASME Fection XI - Pump and Valve Testing Program" (Proposed revisions and chr.nges).

3. American Society of Mechanical Engineers (ASME) Boiler mad Pressure Vessel Code,Section II, Rules for Inservice Inspection of Nuclear Power Plant Components, Division 1, subsections IWP and IWV. The effective edition of Section XI with regard t" the TVA BFN program is the 1980 Edition through Winter 1980 Addenda for .... Units 1, 2, and 3.

4. latter ' from S. Black, U.S. NRC to TVA, dated May 19, 1989, " Safety Evaluation Report on the Inservice Testing Program for Pumps And Valves for Browns Ferry Nuclear Plant, Unita 1, 2, and 3".

5. Latter from P. Carter, TVA, to C. Murphy, ORNL.NOAC, dated September 19, 1989, (additional program change pages).

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