ML20246F084

Advises That 890601 Clarification to Granting Relief Request H-3 Re Changing Pressure Boundary for HPCI Sys from Valve 73-646 to Valve 73-645 Does Not Affect Request Acceptability

ML20246F084
Person / Time
Site:	Browns Ferry
Issue date:	07/06/1989
From:	Black S Office of Nuclear Reactor Regulation
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
TAC-00234, TAC-00235, TAC-00236, TAC-234, TAC-235, TAC-236, NUDOCS 8907130116
Download: ML20246F084 (5)

Text

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July 6, 1989 Docket Nos. 50-259, 50-260 Distribution dnd 50-296 e Docket Jiles MSimms BFN Rdg.

NRC PDR GGears Local PDR DMoran ADSP Reading TDaniels l

Mr. Oliver D. Kingsley, Jr.

DCrutchfield NMarkisohn j

Senior Vice President, Nuclear Power BDLiaw OGC Tennessee Valley Authority RPierson BGrimes 6N 38A Lookout Place SBlack EJordan 1101 Market Street BWilson ACRS(10)

Chattanooga, Tennessee 37402-2801 WSlittle GPA/CA

SUBJECT:

CLARIFICATION CONCERNING HYDROSTATIC PRESSURE TEST RELIEF H-3 GRANTED BY LETTER DATED FEBRUARY 14,1989(TAC 00234,00235,00236)

By letter dated February 14, 1989, the NRC staff provided its analysis of your requested relief from certain American Society for Mechanical Engineers (ASME)

Boiler and Pressure Code,Section XI inservice system pressure test require-ments.

Your relief requests, identified as H-3 and H-12, were found to be acceptable.

By telephone conference call on June 1,1989, your staff provided clarification to our February 14, 1989 letter concerning granted relief request H-3.

This clarification involved changing the pressure boundary for the High Pressure Coolant Injection (HPCI) System from valve 73-646 to valve 73-645, which is the next valve in line and which is a pressure relief valve. The designation of this relief valve permits the performance of a pressure test on the piping between valves73-646 and 73-645. This clarification does not affect the staff's previous evaluation of relief request H-3.

In addition, the staff has determined that there is a need to correct an administrative error made by the staff in its February 14, 1989 letter concerning relief request H-3.

We are i

enclosing an amended Page 3 of the staff's Safety Evaluation (Enclosure 1 of the staff's February 14, 1989 letter).

This correction of a staff error does not affect our previous conclusion on the acceptability of relief request H-3.

If you have any questions concerning these clarifications, please contact Gerald E. Gears at 301-492-0767.

Sincerely, Original signed by 890713o116OggI59 Suzanne Black, Assistant Director PDR ADOCK O PNV for Projects P

TVA Projects Division Office of Nuclear Reactor Regulation

Enclosure:

Corrected Page 3 to staff's Safety Evaluation gj cc w/ enclosure:

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l D:c'ket Hos. 50-259, 50 260 Distribution and 50-296 Docket File MSimms BFN Rdg.

NRC PDR GGears Local PDR DMoran ADSP Reading TDaniels Mr. Oliver D. Kingsley, Jr.

DCrutchfield NMarkisohn Senior Vice President, Nuclear Power BDLiaw OGC Tennessee Valley Authority RPierson BGrimes 6N 38A Lookout Place SBlack EJordan 1101 Market Street BWilson ACRS(10)

Chattanooga, Tennessee 37402-2801 WSlittle GPA/CA

SUBJECT:

CLARIFICATION CONCERNING HYDROSTATIC PRESSURE TEST RELIEF H-3 GRANTED BY LETTER DATED FEBRUARY 14,1989(TAC 00234,00235,00236)

By letter dated February 14, 1989, the NRC staff provided its analysis of your requested relief from certain American Society for Mechanical Engineers (ASME)

Boiler and Pressure Code,Section XI inservice system pressure test require.

ments. Your relief requests, identified as H-3 and H-12, were found to be acceptable.

By telephone conference call on June 1, 1989, your staff provided clarification to our February 14, 1989 letter concerning granted relief request H-3.

This clarification involved changing the pressure boundary for the High Pressure Coolant Injection (HPCI) System from valve 73-646 to valve 73-645, which is the next valve in line and which is a pressure relief valve. The designation of this relief valve permits the performance of a pressure test on the piping between valves73-646 and 73-645. This clarification does not affect the staff's previous evaluation of relief request H-3.

In addition, the staff has determined that there is a need to correct an inconsistency in its February 14, 1989 letter concerning relief request H-3.

We are enclosing an amended Page 3 of the Staff's Safety Evaluation (Enclosure 1 of the staff's February 14, 1989 letter). This correction does not affect the staff's previous conclusion on the acceptability of relief request H-3.

If you have any questions concerning these clarifications, please contact Gerald E. Gears at 301-492-0767.

Sincerely, 1

Suzanne Black, Assistant Director l

for Projects l

TVA Projects Division

(

Office of Nuclear Reactor Regulation

Enclosure:

Corrected Page 3 to Staff SE cc w/ enclosure:

See next page

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Mr. Oliver D. Kingsley, Jr.-.,

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General Counsel Chairman, Limestone County Commission Tennessee Valley Authority P. O. Box 188 400 West Summit Hill Drive-Athens, Alabama 35611 ET 11B 33H Knoxville, Tennessee 37902 Claude Earl Fox, M.D.

State Health Officer Mr. F. L. Moreadith State Department of Public Health Vice President, Nuclear Engineering State Office Buildir.g Tennessee Valley Authority Montgomery, Alabama 36130 400 West Summit Hill Drive WT 12A 12A Regional Administrator, Region II Knoxville, Tennessee 37902 U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W.

Dr. Mark 0. Medford

- Atlanta, Georgia 30323 Vice President and Nuclear Technical Director Mr. Danny Carpenter Tennessee Valley Authority Senior Resident Inspector 6N 38A Lookout Place Browns Ferry Nuclear Plant Chattanooga, Tennessee 37402-2801 U.S. Nuclear Regulatory Commission Route 12 Box 637 Manager, Nuclear Licensing Athens, Alabama 35611 and Regulatory Affairs Tetassee Valley Authority Dr. Henry Myers, Science Advisor SN 1578 Lookout Place Committee on Interior Chattanooga, Tennessee 37402-2801 and Insular Affairs U.S. House of Representatives Mr. O. J. Zeringue Washington, D.C.

20515 Site Director Browns Ferry Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority Rockville Office P. O. Box 2000 11921 Rockville Pike Decatur, Alabama 35602 Suite 402 Rockville, Maryland 20852 3

Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Decatur, Alabama 35602 Mr. G. Campbell Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Decatur, Alabama 35602 1

7 ENCLOSURE CORRECTED PAGE TO NRC SAFETY EVALUATION DATED FEBRUARY 14, 1989 (PAGE 3 0F ENCLOSURE 1) 1 1

i

_____E_._______________

l

. i In the reactor core isolation cooling (RCIC) system, check valve FCV-71-40 is

• design'ed to prevent flow from Class 1 to Class 2 piping and is the bounoary between Class 1 and Class 2 piping.

This valve cannot hold pressure from the Class 2 direction.

1.4 Alternative Testing All r. lass 2 MS system piping will be tested at the appropriate Class 1 a.

pressure in conjunction with the Class I reactor vessel system hydrostatic I

pressure test.

b.

That portion of ths Class 2 HPCI system piping between FCV-73-44, f

FCV-73-45, and FCY-73-646 will be tested at the appropriate Class 1 pressure in coCun: tion with the Class I reactor feedwater system.

That portion of the Class 2 RCIC system piping between FCV-71-39 and c.

FCV-71-40 will be tested at the appropriate Class 1 pressure in conjunction with the Class 1 reactor feedwater system.

2.0 STAFF EVALUATION The NRC staff has reviewed the licensee's relief request H-3 for the SPT of certain~ Class 2 piping (the N system and portions of the HPCI and RCIC systems) at 1.25 times the system design pressure.

Requiring these operational valves, some of which are very large (26 inches inside diameter), to be replaced so that the pressure tests can be conducted on both sides of the valve is a significant undertaking.

Extensive dcwntime, radiation exposure of workers and generation of large amounts of radioactive material waste will Redesign of the systems and replacement of the valves would be occur.

necessary be:ause of (D pressurizing the main steam isolation valve in the Class 2 direction wil; :ause the valve to unseat and leak.

The valve manufacturer has str.ced that mechanically'y restraining the valve could damage the valve stem, (2) in the HPCI system, check valve FCV-73-45 is designed to prevent flow from Class 1 to Class 2, and is the boundary between Class 1 ar.d Class 2.

This valve cannot hold pressure from the Class 2 direction, (3) in the RCIC system, check valve FCV-71-40 is designed to prevent flow from Class 1 to Class 2 and is the boundery between Class 1 and Class 2.

This valve cannot hold pressure from the Class 2 direction.

During operation, these valves will not be subjected to higher pressures from the downstream side (Class 2) and therefore, the pressure tests do not represent ar operational condition.

The replacement of these valves is a significant burden to the licensee, in that it would also require extensive redesign of the system and possibly require other system changes.

The fact that check valves FCV-73-45 and FCV-71-40 are in the j

line to be tested makes it impossible to set up operational flow in ene

)

direction and test flow (and pressure) in the opposite direction.

Therefore, the testing must be perforried from the same direction as operational flow cnd presfyr.sc The-proposed alternative Class I hydrostatic pressure test at 1.1 times d'esign-pressure versus the required Class 2 hydrostatic pressure test at 1.25 times design pressure will usually detect the type of defects and operating characteristics of concern.

CORRECTED: July 6, 1 89

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