ML18029A163

Responds to 840210 Request for Addl Info Re Proposed Inservice Pump & Valve Testing Program.Revised Program Encl, Including Requests for Relief from Certain ASME Requirements.Program Supersedes 820831 Program

ML18029A163
Person / Time
Site:	Browns Ferry
Issue date:	10/01/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8410110067
Download: ML18029A163 (54)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCE.S5lON NBR:8410110067 OC DATE: 84/10/01 NOTARI D: YES FACIL:50-259 Browns Ferry Nuclear Power Stationi Unit li Tennessee 50-260 Browns Ferry Nuclear Power Stations Unit 2<Tennessee 50-296 Browns Ferry Nuclear Power'Stations Unit 3<Tennessee AUTH.NAME AUTHOR AFFILIATION MILLS g L,M>>Tennessee Valley Authority RECIP~NAME RECIPIENT AFFILIATION DENTONgH~RE Office of Nuclear Reactor Regulationi Director DOCKET 05000259 05000260 05000296

SUBJECT:

Responds to 800210 request for addi info re proposed inser vice pump 8 valve testing program.Revised program encl/including requests for relief from certain ASME requirements, Program supersedes 820831 program, DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE;TITLE."OR Submittal:

Inservice Inspection/Testing NOTES:NMSS/FCAF 1cy.1cy NMSS/FCAF/PM'L:06/26/73 NMSS/FCAF 1cy, 1cy NMSS/FCAF/PM'L:06/28/7q NMSS/FCAF 1cy.1cy NMSS/FCAF/PM'Lo07/0?/76 05000?59 05000260 05000296 RECIPIENT ID CODE/NAME NRR ORB2 BC 01 COPIES LTTR ENCL 7 7 RECIPIENT ID CODE/NAME COPIES LTTR ENCL INTERNAL: ADM/LFMB NRR/DE/MEB 15 NRR/DL/TAPMG RGN2 1 0 ELD/HDSO 1 1 gg/MTEB 14 1 1 rRE'G FIL 04 1 1 EXTERNAL: ACRS NRC PDR NTIS NOTES;16 10 10 02 1 1 1 1 LPDR NSIC 03 05 TOTAL NUMBER OF COPIES REQUIRED!LTTR 30 ENCL 28 4~1 E li lp ll ll'I 4 k h il

-0~TENNESSEE VALLEY AUTHORITY cHATTANooGA.

TENNEssEE 37401 400,Chestnut

'Street"Tower II October 1, 1984 Mr.Harold R.Denton, Director Office of Nuclear Reactor Regulation U.S.Nuclear Regulatory Commission Washington, D.C.20555

Dear Denton:

In the Matter of the Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 By my letter to you dated August 31, 1982, we submitted for your staff's review the proposed Inservice Pump and Valve Testing Program for the Browns Ferry Nuclear Plant units 1, 2, and 3.In response to your staff's request;, additional information was submitted by my letter to you dated April 6, 1983.I A request for additional information was transmitted to TVA by letter from D.B.Vassallo to H.G.Parris dated February 10, 1984.In response to that request, we have revised the program provided as enclosure 1.Included are requests for relief from certain Code requirements.

None of the changes reflect a relaxation of test procedures.

Specific responses to each of the requests made in the February 10, 1984 letter is provided in enclosure 2.The revised Inservice Pump and Valve Testing Program for Browns Ferry provided as enclosure 1, supersedes the program submitted by my letter to you dated August 31, 1982.If you have any questions, please get in touch with us through the Browns Ferry Project Manager.Very truly yours, d Sworn to.ng subscribe me th s'M day of TENNESSEE VALLEY AUTHORITY c L.M.Mills, Manager Nuclear Licensing befo e 1984.Notar y Public My Commission Expires Enclosures cc: See page 284iOii0067 84100i"PDR ADOCK 05000259 P PDR An Equal Opportunity Employer l 9'I~k'y('~'I'g g'$P lt t', 1*I F F"'~~.'P C f'h I JI S y I I'ae F h 4 r-1 4~A N ll h 0 II V L-~p l Mr.Harold R.Denton October 1, 1984 cc (Enclosures):

U.S.Nuclear Regulatory Commission Region II ATTN: James P.O'Reilly, Regional Administrator 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Mr.R.J.Clark Browns Ferry Project Manager U.S.Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr.E.H.Girard U.S.Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 1

ENCLOSURE 1 ASME SECTION XI INSERVICE PUMP AND VALVE TESTING PROGRAM BROMNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (DOCKET NOS.50-259,-260,-296)Attachment 1: Inservice Testing Program for ASME Code Classes 1, 2, and 3 Pumps Attachment 2: Valves to be Cycled for ASME Section XI (IWV-3410, 3510, 3520, and 3610)Attachment 3: Category A Valves and Testing Criteria (Appendix J, Secti'on XI, or both)Attachment 4: Requests for Relief 1~AXiKP29K 1 ItJSERVICE leSTIN'i PKCP~uk FOR AS c.CODE CLASSES 1, 2, AtJD 3 PU."'PS The following table provide" a tabulation of pmps that testing requirements of Sub"ecticn IMP of Section XI of Pressur": Vessel Code, 1980 Edi'icn, and Add nda thrcugh p.ograrn will be applicable until August 31, 1992.are subjec'c t'.e the I~YZ J.'w ler and Hinter 19tC.Thi s This tabulation identifies the pcnps to be tes'ed, pup code classes, pararne'ers to be rneasur ed, and test irtervals.

HPCI.RCIC Core Spray Standby Liquid Control RFIRS(1)2 NR Q 0 Q 2 Q Q Q 0 2 Q 0 Q 0 JJR Q Q Q'2 2 lJR JR Q Q 3 tJR Q Q Q H~Ma~3 Zi Z tJA tJA 0 0<Q JJR'JA Q tJA'!JR J~n tJA 0 NR tJA~0 0 H Rotative Speed Lor P Lubricant Level or Pressur" P'ifferential Pressr:r e tJR tarot Required Pi Inlet Pres ure tJA tJo Avail able Qi Flow Rate H Mcntrg y Tb Bearir:g Temperature Q Quarterly V Vibraticrr Anrpl i tude A Annually (1)These punps are ir a systerr ccexnon to units 1, 2, and 3.Ability to start the pumps will be derncnstrated frcrn each control roan, but canparison to baseline parameters of vibraticn, flew rate, and differential pressure will be perfcrrned for instrumentation in unit 3 only, for ccnsistency of d'ata.

4~The following table provides a listing of systems, valve numbers, types, categories, test frequencies, and type of tests for those valves to be I cycled in accordance with ASME Section XI, IHV-3410, 3510, 3520, and 3610.4 Main Steam Main Steam (Rel'ief Valves)Feedwater (Check Valves)XLQD'.1-14 1-15 1-26 1-27 1-37 1-38 1-51 1-52 1-4 1-5 1-18 1-19 1-22 1-23 1-30 1-31 1-34 1-41 1-42 1-179 1-180 3-554 3-558 3-568 3-572 23-34 23-40 23-46 23-52 23-57 (U-142)A A A A A A A A C C C C C C C C C C C C C AC AC AC AC TEST HKQXH<Y Q Q Q Q Q Q Q Q 60 months 60 months 60 months 60 months 60 months 60 months 60 months 60 months 60 months 60 months 60 months 60 months 60 months Operating Cycle Operating Cycle Operating Cycle Operating Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Meets IWV-3510 Meets IWV-3510 Meets'IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets Mf-3510 Meets IWV-3510 Full Cycle, PV-8 Full Cycle, PV-8 Full Cycle, PV-8 Full Cycle, PV-8 Full Cycle-Full Cycle Full Cycle Full Cycle Full Cycle RHRSW ,(Check Valves)23-502 23-506 23-522 23-526 23-542 23-546 23-561 23-565 23-579 23-580 23-581 23-582 23-591 23-594 23-597 23-588 C C C C C C C C (510 U1)C (530 U1)C (550 U1)C (569 U1)C C C C C Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Full Cycle Full, Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle-Full Cycle Full Cycle Full Cycle

~Y~gM SLC (Check Valves)63-514 63-516 63-525 63-526 MCXKQBX C C AC AC TEST GKQUKKX Q Q Operating Cycle Operating Cycle P OF Full Cycle Full Cycle Full Cycle, Full Cycle, PV-8 PV-8 SLC (Relief Valves)SLC (Explosive Valves)EE%63-512 63-513 63-SA 63-SB 67-13 67-14 67-17 67-18 67-21 67-22 67-25 67-26 67-48 67-49 2-year 2-year Cycle Cycle Operating Cycle Operating Cycle Tech Spec 4.4.A.2 Tech Spec 4.4.A.2 IWV-3610 1WV-3610 Full Cycle Full.Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle EEL (Check Valves)67-502 67-582 67-622 67-619 67-541 67-542 67-584 67-585 67-648 67-649 67-656 67-657 67-559 67>>558 67-638 67<39 67-600 67-601 67-659 67-660 67-556 67-598 67693 (U-3)67-694 (U-3)67%95 (U-3)67-696 (U-3)67-705 (U-3)67-706 (U-3)67-703 (U-3)67-704 (U-3)C C C C C C C C C C C Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, PV-,10 PV-10 PV-10 PV-10 PV-10 PV-.10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10

EECM (Check Valves-Continued)67-528 (U-1)67-529 (U-1)67%34 (U-1)67%35 (U-1)67-521 (U-1)67-522 (U-1)67-630 (U-1)67-631 (U-1)67-624 (U>>1)67-625 (U-1)67-514 (U-1)67-515 (U-1)67-627 (U-1)67-628 (U-1)67-507 (U-1)67-508 (U-1)67-838 67-839 67-843 67-844 KQBX C C C C C C C C C C C C C C C C C C C C TEST ZEK8LKKX Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, ,Part Cycle, Part Cycle, Part Cycle, Part Cycle, PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 Part Cycle, PV-10 Part Cycle, PV-10 Part Cycle, PV-10 Part Cycle, PV-10 Part Cycle,.PV-10 Part Cycle, PV-10 67-715 (U-3)67-716 (U-3)67-713 (U-3)67-714 (U-3)67-723 (U-3)67-724 (U-3)67-725 (U-3)67-726 (U-3)67-737 (U-,3)67-738 (U-3)67-735 (U-3)67-736 (U-3)Q Q Q Q Q Q Q Q Q Q Q Q Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, Part Cycle, PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 PV-10 Recirculation Loops 68-3 68-79 TEST~CKBX HMlKhLCX Cold Shutdown Cold Shutdown Full Cycle Full Cycle Recirculation Loops (Check Valves)68-508 68-523 68-550 68-555 AC AC AC AC Operating Cycle Operating Cycle Operating Cycle Operating Cycle Full Full Full Full Cycle, Cycle, Cycle, Cycle, PV-8 PV-8 PV-8 PV-8 RWCU RWCU (Check Valves)RCIC 69-1 69-2 69-579 69-624 71-2 71-3 71-5 71-6A ,71-6B 71-34 71-8 71-9 71-10 71-17 71-18 71-25 71-37 71-39 71-40 71-22 (U-3)-AC AC A A B B B B B B B B B B B A AC B Operating Cycle Operating Cycle Cold Shutdown Cold Shutdown Q Q Q Q Q Q Q Q Q Q Cold Shutdown Cold Shutdown Cold Shutdown Q Full Full Full Full Cycle Cycle Cycle, Cycle, Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle PV-8 PV-8 RCIC (Check Valves)RCIC (Relief Valves)HPCI 71-580 71-597 71-598 71-599 71-600 71-508 71-592 71-543 71-503 73-81 73-2 73-3 73-5 AC Q C Q C Q C Q C Q C Operating Cycle AC Q 60 Months 60 months Cold Shutdown Cold Shutdown Cold Shutdown Q Full Full Full Full Full Cycle Cycle, Cycle, Cycle, Cycle, PV-11 PV-11 PV-11 PV-11 Full Cycle Full Cycle Full Cycle Full Cycle Internal Inspection, PV-9 Full Cycle, PV-11 Meets IWV-3510 Meets IWV-3510 TEST MCZKEK ZlKQL~~Y HPCI~(Continued)

HPCI (Relief Valves)HPCI (Check Valves)RHR 73-6A 73-6B 73-16 73-18 73-19 73-26 73-27 73-34 73-43 73 44'73-45 73-30 73-574 73-506 73-559 73-517 73-603 73-609 73-633 73-634 73-635 73-636 74-1 74-2 74-7 74-12 74-13 74-24 74-25 74-30 74-35 74-36 74 47 74-48 74-52 74-53 74 54 74-57 74-58 74-59 74-60 74-61 74-66 74-67 74-68 B B B B B B B B B A AC B C C AC AC C C C C B B B B B B B B B B A A B A AC A A B A A B A AC Q Q Q Q Q Q Q Cold Shutdown Q Cold Shutdown Cold Shutdown Q 60 Months 60 Months Q Operating Cycle Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Cold Shutdown Cold Shutdown Q Cold Shutdown Cold Shutdown Q Q Q Q Q.'Q Cold Shutdown Cold Shutdown Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Meets IHV-3510 Meets IHV-3510 Cycle Cycle Cycle, Cycle, Cycle, Cycle, Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full Full PV-11 PV-11 PV-11 PV-11 Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle Cycle, Cycle Cycle Cycle Cycle Cycle Cycle Full Cycle Internal Inspection, PV-9

.~GAL RHR (Relief Valves)74-.71 74-72 74-73 74 74 74-75 74-77 74-78 74-96 74-97 74-100 74-101 74-98 74-99 74-686 74-509A 74-509B 74-509C 74-509D 74-587A 74-587B 74-659 (U-28 3)(U-18 2)A A B A A A A B B B B B B TEST ZBKKFJLX Q Q Q Q Q Cold Shutdown Cold Shutdown Q Q Q Q Q Q 60 Months 60 Months 60 Months 60 Months 60 Months 60 Months 60 Months 60 Months Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 RHR (Check Valves)Core Spray 74-559A 74-559B 74-559C 74-559D 74-661 74-662 74-560A 74-5608 74<<560C 74-560D 74-792 74-804 74-802 74-803 75-2 75-9 75-11 75-22 75-23 75-25 75-26 75-30 75-37 C C C C AC AC C C C C C C C C B B B B B A AC B B Q Q Q Q Operating Cycle Operating Cycle Q Q Q Q Q Q Q Q Q Q Q Q Q Cold Shutdown Cold Shutdown Q Q Full Cycle Full Cycle Full Cycle.Full Cycle Full Cycle, PV-8 Full Cycle, PV-8 Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle, PV-12 Full Cycle, PV-12 Full Cycle, PV-12 Full Cycle, PV-12 Full Cycle Full Cycle Full Cycle Full Cycle~Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle

)LEAK TEST QKKQQBX GEQXKK Core Spray (Continued) 75-39 B 75-50 B 75-51 B 75-53 A 75-54 AC 75-57 A 75-58 A Q Q Q Cold Shutdown<<Cold Shutdown Q Q Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Core Spray (Check Valve)Core Spray (Relief Valves)Floor and Equipment Drains 75-537A 75-537B 75-537C 75-537D 75-570A 75-570B 75-570C 75-570D 75-606 75-607 75-609 75-610 75-507A 75-507B 75-507C 75-507D 75-543A 75-543B 77-2A 77-2B 77-15A 77-15B C C C C C C C C C C C C C C C C C C A A A A Q Q Q Q Q Q.Q Q Q Q 60 Months 60 Mont;hs 60 Mont;hs 60 Mont;hs 60 Months 60 Months Q Q Q Q Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle Full Cycle, PV-12 Full Cycle, PV-12 Full Cycle, PV-12 Full Cycle, PV-12 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Meets IWV-3510 Full Cycle Full Cycle, Full Cycle Full Cycle CRD Hydraulic 85-39A-(1-185)

B B 85-39B-(1-185)B B 1 10$of valves every 16 weeks, valves also cycle during any unit scram, all valves also tested each refueling outage Full Cycle Full Cycle Notes: 1.Valve position indication checks are performed per the code, 2.This program is in accordance with Subsection IWV of the 1980 edition through Winter 1980 Addenda of Section XI and is applicable through August 31, 1992.'

This table identifies the Category A valves, and the testing criteria ,'Appendix J,Section XI, or both)to be satisfied at each refueling outage.Testing criteria is based on Items 2, 3, and 4 of t'n'nts , attached to NRC Hughes)of August 8, 1978.(T.A.Ippolito)letter to TVA (N.B.1-14 1-15 1-26 1-27 1-37 1-38 1-51 1-52 1-55 1-56 3-554 3-558 3-568 3-572 43-13 43-14'3-28A 43-28B 43-29A 43-29B 63-525 63-526 68-5o8 68-523 68-55O 68-555 69-1 69-2 69-579 69-624 (Unit 3)71-2 71-3 X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X ed' 71-39 71-40 71-14 71-32 71-580 71-592 0 n C X X X X X X M c'n I Yale.~~73-2 73-3 73-81 73-44 73-45 73-23 73-24 73-603 73-609 74 47 74-48 74-53 74-54 74-57 74-58 74-60.74-61 74-67 74-68 74-71 74-72 74 74'74-75'4-77 74-78 74-661'74-662 75-25 75-26 75-53 75-54 75-57 75<<58 77-2A 77-2B 77-15A 77-15B X X X X X X X X X X X X X X X X X X X X X X X X X X'X X X X X X X X X X ASM c X X X X X X.X X X X, X X X X

C M REQUEST FOR RELIEF LI P~CM Qg~S~CA~)QUQCCggg-RHR Pumps A, B, C, D;HPCI Pump;RCIC Pump;Core Spray, Pumps A, B, C, D;SLC Pumps A, B;RHRSM Pumps A1, A2, A3).B1~B2~B3~C1~C2~C3~D1~D2~D3-Class 2, except RHRSW Pumps which are Class 3.-ECCS and Core Heat Removal (RHRSM Pumps).-Monitoring bearing temperatures during quarterly inservice testing.Bh@MRE LLZKBHKK-All of these pumps, except HPCI and RCIC, have water lubricated pump bearings.The RHR, Core Spray, SLC, and RHRSW pump bearings are lubricated by water supplied by the pump itself.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.The HPCI bearings, which are instrumented, are monitored during testing.RCIC bearings do not have temperature instrumentation.

4 Vibration measurements are taken on all of the Section XI pumps to ensure detection and correction of changes in bearing performance while the pumps are still capable of.satisfactory operation.

-Standby Liquid Control Pumps-Class 2-ECCS and alternate reactor shutdown capability'.

-Quarterly measurement of inlet pressure and differential pressure.-During testing these pumps take suction from a test tank that has 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 important.

-, Pump discharge pressure will be measured during quarterly testing.A caution note has been placed in the instruction that governs this test so that a minimum level is maintained in the test tank.This ensures discharge pressure is an adequate indication of pump performance.

~C~P~NT-Standby Liquid Control Pumps~CPS.-Class 2 f~CJQg-ECCS.and alternate reactor shutdown capability.

L~3~/XK42Z-Running pumps for five'minutes before measuring parameters.

-These pumps are tested by circulating liquid to a test tank for.2 minutes and measuring the volume change in the tank.Running for 5 minutes before measuring parameters is not compatible with the system design.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 test require-ment.This 15-minute test is of sufficient length for all parameters to stabilize and the 2-minute test is run immediately afterward.

ZRXXK Measure parameters during 2-minute test.

C 4 IJ L-All systems-Analysis of test data within 96-hours per 1WP 3220.B~~S.I~LI'F-Due to the time involved in processing surveillance instructions to the reviewer and the possibility of weekends and/or holidays falling between running tests and completely reviewing the results, 96-hours is impractical.

Pump parameters of flow rate and differential pressure will be reviewed imnediately after the test by the individual performing the test to verify that they do not fall within the"Required Action Range>>of Table IWP-3100-2.

Complete analysis of test data will be performed within 4 working days of the tests.Xf the pump parameters fall within the"Required Action Range," the individual performing the test will notify the cognizant reviewer and carry out the necessary action required.by the code.

~C pgg5XQ-Installed plant instrumentation and portable instruments used to measure pump parameters.

Q~>S QJ~CI~O-1,2,and3-Measurement of pump parameters.

-Instrunent accuracy shall be within the limits of'Table IMP-4100-1.

-The accuracy of installed plant indicators is~2'5 of full scale.However, the accuracy of installed transmitters and square-rooters is 0.5$and when these are taken into account the instrument loop accuracies are 2.5$and 3.0$for pressure loops and flow loops, respectively.

The plant installed instr+vents will continue to be used since any alternate method such as connecting test instrunents into the system or*.replacing plant instrumentation, will not provide sufficient benefit to outweigh the added'cost and manpower of the alternate methods.The portable instrument used to measure vibration amplitude has an accuracy of 11%of full scale.The instrunent has been used from the beginning of the program to collect the vibration data and develop all the vibration baselines that are used in the pump program.Since all other requirements for measuring amplitude (XWP-4520) have been met and since the instrunent used is an accepted standard method for industrial, vibration and measurements, the instrunent will continue to be used.XFAGHG An equipment diagnostic program using much more sophisticated instrunents and methods monitors rotating equipment at the plant and provides much better vibration data on the pumps than the one required data point of the pump program.This program is done in addition to the test requirement.

S LI F-All valves-A, B, and C-, Various functions-Corrective action on an inoperable valve required before startup per Mf-3417 and IWV-3523.-Limiting conditions for startup have been analyzed in Browns Ferry Technical Specifications, Technical Bases 3.4.B, 4.4, 3 O'As 3'5't 3 O'Ct 3'O'Es 3'5 F Valve'inoperability will preclude unit startup only if the.valve places the system itself in a position of preventing startup per present technical specifications.

fl L P-CRD (Scram Function)-85-39A-(1-185)85-39B-.(1-185)-Provide flow path for water for control rod scrams.-Exercised once every 3 months.-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 places an unfair burden on the licensee.b.'uel preconditioning must follow this power reduction to avoid possible fuel damage.The longer the reduction in power, the longer the pr'econditioning.

10$of the rods will be scram testd every sixteen weeks, and all rods will be scram tested during refueling, per present Technical Specifications.

Xn addition, all rods are provided with the same test during normal operation when the unit scrams.

lt LlE&5XF85L MCHRQHlBG5 (VALVES)-Feedwater-3-554, 3-558, 3-568, 3 572 Standby Liquid Control-63-525,63-526 Reactor Recircultion System-68-508,68-523, 68-550,68-555 Reactor Water Cleanup-69-579,69-624 (Unit 3 only)Residual Heat Removal-74-661, 74-662-AC ZEKTXQH-All are containment isolation, plus;prevents backflow in feedwater lines (System 3), prevents backflow in RWCU System (System 69), and thermal expansion relief (System 74).~ASS QQ jgL:gF-Exercise valves for operability quarterly.

-All of these valves are check valves whose operation cannot be verified during plant operation.

Testing requires entry into primary containment, stopping RWCU system operation (System 69)or inter rupting seal water to the recirculation pumps (System 68)which is very likely to cause seal damage.-Valves74-661, 662 are not required to change position and hence, are not required to be tested for operability.

~BHbXI'.-Valves will be tested in accordance with 10 CFR 50, Appendix J, at each refueling outage.

L~XIZQL QZEQHKHX5 (VALVES)-Reactor Core Isolation Cooling-71-508 High Pressure Coolant Injection-73-517 ZUK<UQH-Valves present backflow to the torus from the RCIC and HPCI, respectively.

-Valves cannot be cycled without introducing torus water into the vessel.This water is of such quality that it should not be introduced into the vessel unless an accident has occurred.XLZ2583X-Valve internals will be visually and manually checked each refueling outage by removal of valve access plates.Testing check valves each refueling outage is in line with the'RC's latest philosophy on testing check valves.

~Y~M MCKQKHXQ (VALVES)-67-502, 582, 622, 619 67-648, 649, 541, 542, 558, 559, 638, 639, 659, 657 656, 584, 585, 556, 598, 600, 601, 660, 659, 838, 839, 843, 844 1-67-634, 635, 528, 529, 521, 522, 630, 631, 624, 625, 514, 515, 627, 628, 507, 508 3-67-723, 724, 725, 726, 713, 714, 715, 716, 703, 704, 705, 706, 695, 696, 693, 694 3-67-735, 736, 737, 738 j~UC'Igg-All required to pass rated flow to emergency coolers, plus backseat upon loss of one of the two EEL headers (except 3-67-735, 736, 737,'738 and 67-838, 839, 843, 844)-Operability test quarterly WXQEKTK 3XGX3¹-Backflow testing these valves individually cannot be performed due to lack of test connections between valves.-These valves will be part stroke-tested quarterly (except 3-67-735, 736, 737, 738)and an internal inspection done each.refueling outage.

-High Pressure Coolant Injection-73-633, 634, 635, 636 Reactor Core Isolation Cooling-71-597, 598, 599)600-HPCI/RCIC Turbine Exhaust Vacuum Relief-Exercise each valve for operability quarterly-Each valve cannot be checked individually due to lack of isolation valves.The four valves are in a"one-out-of-two-taken twice" arrangement, so there is redundancy in case a valve fails to open.-Test each arrangement of valves quarterly.

It'I REQUEST FOR RELIEF-PV-12 MCHKHKHXQ-Core Spray-75-609, 610 75-606, 607-74-792, 804 74-802, 803 XIX,-Prevents backflow into the keep fill system (PSC Head Tank)-Exercise each valve for operability quarterly ZKU~IE L4TQ5hXK 3XSLQKi-Each individual valve cannot be tested due to lack of test connections.

-Quarterly testing of pairs of valves together plus an internal inspection each refueling outage.

'(dl ENCLOSURE 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING INSERVICE PUMP AND VALVE TESTING PROGRAM BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 (

Reference:

NRC Letter from D.B.Vassallo to H.G.Parris dated February 10, 1984)NOTE: TVA's philosophy in writing the pump and valve testing program has been to include those systems and piping that carry water, steam, or radioactive material.We see no defined regulatory basis for the NRC staff to increase the scope of testing in the inservice pump and valve testing program, as is apparently the intent of questions 1 and 2.We, therefore, plan to respond only to those water, steam, or radioactive waste-containing components in questions land 2, and request that our submittals be reviewed against currently defined regulatory requirements.

1., NRC REQUEST The pump portion of the IST program was reviewed to verify that all pumps that are important to safety are included in the program and are subjected to the testing required by the ASME Code.In the staff's judgment there are additional systems wherein the associated pumps should be in the program.These systems are: Plant Service Water PSC Head Tank Fuel Oil Transfer Please justify the omission of the pumps in, these systems or revise the IST program to include them.TVA RESPONSE Plant Service Water Pumps--The plant service water system performs no safety-related function;hence, its pumps are not considered in the scope of Section XI.Pressure Suppression Chamber (PSC)Head Tank--The pumps in the Keep Fill system do not perform an active safety function in"keeping the core spray and RHR systems charged.The head tank water volume maintains these systems charged at the required pressure.The head tank pumps maintain the proper ahead tank level with occasional makeup to the head tank.Fuel Oil Transfer-See note above.

2.NRC REQUEST Likewise, in the staff's judgement the following valves should be in the IST program: Combustible Gas Control System valves Primary Containment Atmosphere valves Fuel Oil Transfer System valves Transverse In-Core Probe valves Valves in the portions of the Instrument and Control Air System that perform a function important to safety Valves in ventilating systems that perform a function important to safety Sampl'ing System valves Torus Drain Valves Drywell-Pressure Suppression Chamber (PSC)and PSC-Reactor Building vacuum breakers SRV discharge line vacuum br eakers (Valves10-506, 507, 519, etc.)Primary Containment H2 and 02 Analyzer Valves EECM valves for the Unit 1 and 2 Diesel Generator Engine Coolers Diesel Generator Air Start Valves All relief valves important to safety except ADS valves (e.g., valves75-543 A and B).Keep-Fill valves in Core Spray System (e.g., valves75-609 and-610)Please provide technical justification for the omission of these valves or revise the IST program to include them.TVA RESPONSE Combustible Gas Control System Valves--See note above.I Primary Containment Atmosphere Valves--See note above.Fuel Oil Transfer System Valves--See note above.A Traversing In-Core Probe Valves-See note above.Valves in Instrument and Control Air System--See note above.I Valves in Ventilating Systems--See note above.Sampling System Valves-The sampling system valves (43-13, 14, 28A, 28B, 29A, and 29B), which perform a containment isolation function and are tested, in accordance with the criteria in Appendix J, are identified as Clas's A valves and included in Attachment 3 of the pump and valve program.

0 r Torus Drain Valves-The torus drain valves (75-57, 58)that perform a containment isolation function are included in the program.Drywell-PSC and PSC-Reactor Building Vacuum Breakers--See note above.SRV Discharge Line Vacuum Breakers--See note above.Primary Containment H2 and 02 Analyzer Valves--See note above.EECW Valves for units 1 and 2 Diesel Generator Engine Coolers--These valves are tested per Section XI requirements but were inadvertently left out of the program submittal.

They are included in the updated program.Diesel Generator Air Start Valves--See note above.All Relief Valves Important to Safety--We have reviewed the various safety systems and have included those relief valves determined to be needed in our program.Keep Fill Valves in Core Spray and RHR Systems-These valves have been included in the progr am as indicated in the valve listing with the conditions noted in Request for Relief PV-12.3.NRC REQUEST You requested relief for all pumps from the requirements of paragraph IWP-3220 that all pump test data be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of the test.We agree that a delay of an additional day before pump test data is completely analyzed is not significant if there is no delay in performing preliminary reviews of test data (including vibration levels)immediately after the test, and any pumps whose measured test parameters fall within the Code"Required Action Range" are immediately declared inoperable upon completion of the preliminary reviews.Confirm that this is your intent.TVA RESPONSE A preliminary analysis is performed on pump test data (including vibration) immediately after the test.Any pump whose measured test parameters fall within the Code"Required Action Range" are immediately declared inoperable.

We still need four working days for performing a complete analysis of pump data per relief request PV-4.

C n NRC REQUEST You requested relief from paragraph IWV-3411 for valves63-525 and 63-526 and propose to exercise these valves during refueling to verify that they will close.You must also verify that these valves will perform their safety-related function by passing design flow from the SLCS to the core.Please verify that this function will also be tested during refueling.

TVA RESPONSE We verify that valves63-525 and-526 will perform their safety-related function by passing design flow from the SLCS to the core during refueling.

5.NRC REQUEST You requested relief from paragraph IWV-3411 for valves74-661 and-662 and propose to exercise these valves at each refueling because such a test entails entry into containment.

We approve this request with the condition that these valves also are tested during a cold shutdown whenever the containment is de-inerted.

Please pr ovide a commitment to perform tests during cold shutdown whenever possible (not to exceed thr ee months frequency) or provide justification for not commiting to this schedule.TVA RESPONSE We do not believe the benefits of testing of valves74-661 and-662 during cold shutdown warrant the increased risks to personnel safety.These risks include working and carrying test equipment in high radiation, high temperature, and poorly accessible areas.These risks were discussed in-detail with NRC at the May 1982 meetings at Browns Ferry.6.NRC REQUEST From a review of your IST program, the staff finds that you have elected to leak test pressure-isolation valves to verify integrity.

It is the staff's position that,,when leak-rate testing is used to ve'rify the integrity of pressure isolation valves, the leakage limits selected must assure that valve sealing function has not excessively degraded.The staff does not consider relief valve capacity in setting pressure isolation valve'leakage limits.The staff recommends a leakage limit for'pressure isolation valves of 0.5 gpm per nominal inch of valve size with a maximum leakage rate of 5 gpm.State whether you comply with this postion.If you do not comply state and justify your acceptance test limits.

TVA RESPONSE We do not'comply with the staff recommended limits.Our Section XI acceptance test limits for Pressure Isolation Valves (PIV)are based on system relief valve capacities, which are higher than the NRC staff recommended leakage limits.However, these valves are also tested in accordance with Appendix J and with reference leakage rate acceptance criteria that are more stringent than the recommended limits.Rather than a basis of unnecessarily limiting values our acceptance criteria were chosen considering the design funct'ion of these valves and their integrated system responses with the closed loop safety systems.In practice we easily meet the recommended limits while on the other hand we do not limit ourselves to PIV leakage rates that would be less than those needed to protect the system integrity.

7.NRC REQUEST Your IST program did not indicate performance of position indicator verifications as required by the Code.Please verify that you meet this Code requirement or)ustify your failure to do so.TVA RESPONSE We do meet the Code requirement of position indication verifications.

This request was made previously in a letter from D.B.Vassallo to H.G..Parris dated January 17, 1983, and responded to in letter from L.M.Mills to H.R.Denton dated April 6, 1983.

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