ML20245A933
| ML20245A933 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/18/1989 |
| From: | Fox C TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904250451 | |
| Download: ML20245A933 (5) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 l
SN 1578 Lookout Place APR 181989 1
i U.S. Nuclear Regul: tory Commission ATTN: Document Cor2rol Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260
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50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNIT 2 - AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME), SECTION XI - INSERVICE SYSTEM PRESSURE TEST PROGRAM
Reference:
TVA's letter to NRC dated January 15, 1988, " Browns Ferry Nuclear Plant (BFN) - ASME Section XI Inservice System Pressure Test Program."
A revised ASME Section XI inservice system pressure test (ISPT) program for BFN was submitted to NRC by the referenced letter.
Subsequent discussions with the NRC staff resulted in a request for TVA to provide a relief request from a requirement of the ASME Code.
Enclosed are the revised program pages containing the request for relief, and the deletion of the program statement which is now contained and clarified in the request for relief.
These changes to the ISPT Program for BFN will clarify our position and should expedite the review of the program and issuance of the subsequent program Safety Evaluation Report.
If you have any questions regarding this submittal, please telephone Patrick P. Carier, BFN, Site Licensing, at (205) 729-3570.
Very truly your TE ESSJ VA THORITY C.
. Fo,
ice President and Nuclear Tech ical Director Enclosure cc:
See page 2 gg43882k $$88@y P
An Equal opportunity Employer w_
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. U.S. Nuclear Regulatory Commission jkhj{18l@8@
cc (Enclosure):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Ms. L. J. Watson, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 l
Athens, Alabama 35609-2000 1
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Enclosure REVISION TO INSERVICE SYSTEM PRESSURE TEST PROGRAM FOR FIRST 10-YEAR INTERVAL BROWNS FERRY NUCLEAR' PLANT UNITS 1, 2, AND 3 i
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. 4.1 (cont'd)
In accordance with 10 CFR 50.55a(g)(4)(l'/) the following areas shall meet-the requirements of the 1980 Edition, Winter 1981 Addenda of ASME Section XI of the Code in lieu of the base code of record.
These areas shall consist of:
(1) Test Pressurization Boundaries (IWA-5220 and Footnote 1 for Examination Category B-P of Table IWB-2500-1)
(2) Hydrostatic Test Condition Holding Time (IWA-5213)
(3) Code Class 2 or Equivalent Test Temperature (IWC-5230)
(4) System Hydrostatic Pressure Test of Code Class 2 or equivalent exempt and nonexempt components (5) Hydrostatic Pressure Including Static Head (IWA-5265) 4.1.1 Identification of-test pressurization boundaries shall be in accordance with Subarticle IWA-5220.
In accordance with.
j Paragraph IWA-5224:
1 (a) The boundary subject to test pressurization during a system hydrostatic test [IWA-5211(d)] shall be defined by the system boundary (or each portion of the boundary) within I
which the components have the same minimum required classification and are designed to the same primary pressure rating as governed by the system function and the internal fluid operating conditions, respectively.
(b) Systems which share safety functions for different modes of plant operation, and within which the component classifications differ, shall be subject to separate system pressure tests of each portion of the system boundary having the same minimum required component classifications.
(c) Systems designed to operate at different pressures u.,'er 3
several modes of plant operation or postaccident cor.Jitions shall be subject to a SPT within the test boundary defined by the operating mode with the higher pressure.
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(d) Where the respective system primary pressure ratings on the i
suction and discharge sides of system pumps differ, the system test boundary shall be divided into two separate l
boundaries (such as suction side and discharge side test boundaries).
In the case of positive displacement pumps, the boundary interface shall be considered as the pump.
In the case of centrifugal pumps, the boundary interface shall be the first shutoff valve on the discharge side of the pump.
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r REQUEST FOR RELIEF H-13 UNITS 1,2,3 SYSTEM Various CLASS ASME Code Class 2 and 3 equivalent TEST REQUIREMENTS ASME Section XI, 1974 Edition, Summer 1975 Addenda, Article IHC-5220(a), class 2.
The system hydrostatic test pressure shall be at least 1.25 times the system design pressure (Po).
ASME Section XI, 1974 Edition, Summer 1975 Addenda, IWD-5200(a), class 3.
The system test pressure shall be at leasi 1.10 times the system design pressure.
BASIS FOR RELIEF The plant predates the inservice pressure testing requirements of ASME Section XI.
Provisions were not made in the design of all system components to accommodate pressurization-of the complete system to the pressures required by the code.
There exists non-safety-related instruments in some Code Class 2 and 3 systems whose maximum design pressure is equal to the system design pressure.
These instruments are not designed to with 'and the over-pressurization of a Section XI hydrostatic test.
The increased pressure, although not sufficient to rupture the instrument, is capable of damaging the instrument according to the manufacturers' specifications.
The cost to replace these instruments with units capable of withstanding the hydrostatic test pressure would place a financial burden on the plant with no significant increase in safety to the plant or the general public.
All instruments in Code Class 2 and 3 systems which ALTERNATE TESTING fall into the category described above, will be isolated from the system during the system hydrostatic pressure test.
These instruments will be hydrostatically tested at a pressure not to exceed the manufacturer's maximum design pressure, and no less than 94 percent of their maximum design pressure.
The remainder of the system will be hydrostatically tested
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to the pressure required by Section XI of the ASME Code.
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