ML20248B598

Advises That 890721 Revs to ASME Section XI Pump & Valve Testing Program SER Acceptable

ML20248B598
Person / Time
Site:	Browns Ferry
Issue date:	08/01/1989
From:	Black S Office of Nuclear Reactor Regulation
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
TAC-11324, TAC-11325, TAC-11326, NUDOCS 8908090271
Download: ML20248B598 (8)

Text

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August le 1989 we .

Docket Nos. 50-259/50-260 Distribution

,- and 50-296 Docket File GGears NRC PDR DMoran Local PDR TDaniels ADSP Reading NMarkisohn Mr. Oliver. D. Kingsley, Jr. DCrutchfield 0GC Senior Vice President, Nuclear Power BDLiaw JZwolinski Tennessee Valley Authority SBlack EJordan 6N 38A Lookout Place RPierson ACRS(10)-

1101 Market Street BWilson GPA/CA Chattanooga, Tennessee 37402-2801 WSlittle BFN Rdg. File MSimms

SUBJECT:

BROWNS FERRY NUCLEAR PLANT (BFN) . CORRECTIONS TO ASME SECTION XI _

PUMP AND VALVE TESTING PROGRAM SAFETY EVALUATION REPORT (SER) -

(TAC N05. 11324, 11325, AND 11326)

In TVA's letter cated July 21, 1989, a list of discrepancies and their pro.

posed revisions, in the above. subject safety evaluation report, was transmitted to the NRC staff for review.

These revisions provide clarification and do not change any conclusions that resulted from the original review of the proposed BFN ASME Secticn XI - Pump and Valve Testing Program.

The staff has completed its review and find acceptable all revisions proposed by TVA.

The revised pages to the SER are contained in the enclosure. Please replace the original pages with these revised pages.

Sincerely.

Original signed by G. Gears for Suzanne C. Black, Assistant Director for Projects TVA Projects Division Office of Nuclear Reactor Regulation

Enclosure:

Revised Pages cc w/ enclosure: OFol See next page i g  !

8908090271 890801 PDR ADOCK 0500 {9 P

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DATE :7/3 /89 :7/N/89 . /t 89. J  :  :  :  :

i 0FFICIAL RECORD COPY i

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O Mr. Oliver D. Kingsley, Jr. l l

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General Counsel Chairman, Limestone County Comission Tennessee Valley Authority P. O. Box 188  !

400 West Summit Hill Drive Athens, Alabama 35611 l ET llB 33H l Knoxville, Tennessee 37902 Claude Earl Fox, M.D. '

State Health Officer l Mr. F. L. Moreadith State Department of Public Health )

Vice President, Nuclear Engineering State Office Building 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 Comission j 101 Marietta Street, N.W. .

Dr. Marx 0. Vedford 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 Comission Route 12, Box 637 Manager, Nuclear Licensing Athens, Alabama 35611 and Regulatory Affairs Tennessee Valley Authority Dr. Henry Myers, Science Advisor SN 157B Looko:ut Place Comittee 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 Mr. P. Carter Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority l P. O. Box 2000 Decatur, Alabama 35602 Mr. G. Campbell Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority l P. O. Box 2000 Decatur, Alabama 35602 c

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ENCLOSURE-The following revised' pages should replace the previously transmitted pages in

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- the SER for;the BFN - Pump and Yalve Program.

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2.2.2.3 PV-3, Five Minute Minimum Run Time for SLC and DFT Pump Tests Relief Request l The licensee has requested relief from running the SLC pumps for five minutes j under stable conditions prior to measurement or observation of the specified i test parameters as required by IWP-3500(a) of the Code. They proposed to limit the time of the Code test to two minutes and to perform the Code test immedi-ately following a 15-minute functional test of the pumps.

The five minute run time of IWP-3500(a) also poses a problem to the licensee in  !

their DFT pump testing as, depending on diesel oil usage, day tanks may be too l full to permit the pumps to be run long enough for completion of testing. )

Because of anticipated difficulties in scheduling pump testing to coincide with day tank levels low enough tc permit stable runs of five minutes or more, the licensee requested relief from IWP-3400 requirements for quarterly testing.

Based on clarification provided in a telephone conversation between responsible TVA (H. Hodges and P. Gilbert) and NRC (E. Girard) personnel on August 11, 1988, TVA considers that day tank levels will be low enough to pemit pump runs of the required time and test measurements to be completed at least once every  ;

six months. They proposed to perform the tests at that frequency instead of the l three month frequency specified by IWP-3400.

Licensee's Basis for Reques_ ting Relief f The SLC pumps are tested by circulating liquid to a test tank for two minutes and measuring the volume change in the ta n . Running for five minutes before  ;

measuring parameters is not compatible with the system design. The volume of l the test tank (210 gallon capacity) prohibits running the pumps (flow rate of '

approximately 55 gpm) for five minutes. However, a 5-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 requirement. This 5-minute test is i

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of sufficient length for all parameters to stabilize and the two-minute test is i run immediately afterward.

Depending upon diesel oil usage, day tank level may be so high that high level switches will stop DFT pumps before the scheduled periodic testing required by '

the Code can be completed. The licensee proposed that the test will be 1 performed when day tank level permit the pumps to be run for as long as i possible, but not less often than once per six months (as compared to quarterly testing required by the Code). In the July 11, 1988 telephone call referred to above, the licensee indicated that "for as long as possible meant that the ,

IWP-3 BOO (a) requirement would be met. 1 Evaluation The staff agrees, based on the system description provided by the licensee, that it is impractical to run the Code required SLC pump tests for five minutes. The proposed alternative of running the Code pump test for two j minutes imediately following a 5-minute functional pump test is considered to provide an equivalent test..

REVISED 7/28/89

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17 As already noted in 2.2.2.2 above, the functioning of the DFT pumps is not as imediate or safety-significant as other safety-related pumps. Therefore, the staff finds that the steps the licensee would have to take to assure cuarterly testing, versus the tasting they propose, are unwarranted from a safaty standpoint. The other testing to be performed by the licensee, including improved vibration testing, provides an acceptable level of quality and safety.  !

l Conclusion The Code (IWP-3500(a)) requires a minimum of a five minute run time under stable conditions prior to measurements or observations of specified test parameters.

i The SLC pumps would only be for two minutes immediately following 15-minute functional test. The DFT pumps would not be tested once per six months vice quarterly. The proposed running of the SLC pumps for two minutes immediately following the 15-minute functional test is considered to be equivalent to the required testing and the running of the DFT pumps for five minutes at least every six months, along with improved vibration testing provides an acceptable.

2.2.2.4 PV-5, Pump Test Instrumentation Accuracy. and Full-Scale Requirements Allowable Ranges of In-service Test Quantities, and Vibration Fnplitude Requirements Relief Request The licensee has requested the following relief for all Code IST of pumps:

(1) Relief is requested from the 22% pressure and flow instrument accuracies specified by Code Table IWP-4110-1. The licensee proposes to use the originally installed plant instrumentation which provide accuracies of 2.5% and 3.0% for pressure and flow respectively on all pumps except the DFT pumps. The DFT pumps are not instrumented for ficw and the licensee proposes to use level change in the diesel fuel day tank to assess flow.

(2) Relief is requested from the IWP-4120 requirement that the full-scale range of each instrument shall be three times the refer'.:nce value or less.

(3) Relief is requested from the requirements to measure displacement vibration amplitude in accordance with IWP-4150 and to use the vibration amplitude allowable ranges in Code Table IWP-3100-2. The licensee proposes to instead measure velocity vibration amplitude replacing the Table IWP-3100-2 vibration ranges with the following:

Test Acceptable Alert Required Quanti ty Range Range Action Range V 0 < V < 1. 5V r 1.5 r< V < 3.0V r V > 3.0V r NOTE: V is defined as vibration amplitude in in/sec and Vr is the basline value.

REVISED 7/28/89

26 design does not provide a practical means of demonstrating closure other than by upstream pressurization performed during leak rate testing conducted in accordance with 10 CFR 50, Appendix J. This testing involves significant effort for installation of temporary equipment. This would require valve lineups to abnormal positions, installation of pressurizing equipment and associated test lines, as well as deinerting the drywell for safety entry.

Evaluation The staff finds that the licensee's design did not provide for testing these valves during plant operation or at cold shutdowns. Modifications of special test installations needed to demonstrate closure at the Code specified fre-quency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or efforts involved. The Appen-dix J, Type C testing proposed with refueling outage frequency provides reason-able assurance of operational readiness.

Conclusion The NRC staff concludes that the proposed testing provides reasoble assurance of operational readiness and full compliance with Codes, IWV-3521 and 3522 would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore, the partial relief requested by the licensee from Codes IWV-3521 and 3522, requirements for exercising RWCU check valves69-579 and 69-624 every three months is granted.

2.3.2.8 pV-12, Quarterly Stroke Timing Residual Heat Removal Service Water (RHR5W) Valves 23-34, 40, 46 and 52 Relief Request The licensee has requested relief from IWV-3413 requirements to measure the full stroke time of thesc power operated valves. The licensee proposes to set an intermediate stroke " reference" position to which the valves will be stroked and timed. This test will be performed quarterly anli the reference position will be less than or equal to 4500 gpm.

Licensee's Basis for Requesting Relief In order to obtain good stroke times for basline values, these valves would have to be stroked from the same position. Since the valves are throttle valves, the position to obtain the desired flow of 4500 gpm would change due to system variables such as corrosion, tube blockage, plugged tubes, etc.

Additionally, full opening the valve would overflow the heat exchanger and possible damage it.

Evaluation Considering the full stroking these valves might result in heat exchanger damage, the staff agrees that the such testing is a safety hazard. The alternative proposed by the licensee, stroke timing to a reference position, is a REVISED 7/28/89 1

, , s-39 from Codes, IWV-3521 and 3522, requirements the QA check valves32-336, 2521, 2163 and 2516 be closure exercised every three months is granted.

2.3.2.21 PV-25, Stroke Timing Rapid-Acting Valves in the Followin Systems Sampling and Water Quality (43), HPCI (73), Containment Inerting (76),

Containment Atmosphere Dilutin (84), Control Rod Drive (85), Diesel Generator Air Start (86), Service Water (23), Residual Heat Removal Service Water (23) aad Traversing Incore Probe.

Relief Request The licensee has requested relief from the power operated valve stroke time trending and increased frequency of testing of IWV-3417(a) for the subject valves, which have stroke times of less than two seconds. For these valves they will specify a limiting full stroke time maximum of two seconds.

Licensee *s Basis for Requesting Relief Yalves with stroke time less than 2 seconds cannot be accurately timed.

Evaluation The staff recognizes that the licensee does not have such special equipment and setups as would be required to accurately stroke time the subject valves for trending in conformance 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.

The staff finds that the licensee's proposal of two second maximum stroke times for the valves provides an acceptable level of quality.

Conclusion The NRC staff concludes that the proposed testing provides reasonable assurance of operational readiness and meets the intent of Code. IWV-3417(a),

therefore, tha partial relief requested by the licensee from Code IWV-3417(a),

power operated valve stroke time trending and increased frequency of testing for the above subject valves is granted.

2.3.2.22 PV-26 Closure Exercising Containment Inerting System Check Valve

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Relief Request i i

The licensee has requested relief from the IWV-3521 and 3522 requirement to i stroke this containment isolation valve to the closed position every three i months or at cold shutdowns. They propose to us 10 CFR 50, Appendix J.

Type C testing performed each refueling outage to verify the stroking of this valve to the closed position.

. REVISED 7/28/89

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42 Evaluction l The staff finds that the licensee's design did not provide for testing these I valves during plant operation or at cold shutdowns. Modifications or special ,

test installations needed to demonstrate closure at the Code specified frequency do not appear to provide a sufficiently increased assurance of their closure operation to justify the hazards and/or. efforts involved. The Appendix J. Type C testing proposed with refueling outage frequency provides reasonable assurance of operational readiness.

Conclusion The NRC staff concludes that the propoeed testing provides reasonable t.ssurance of operational readiness and full compliance with Codes IWV-3521 and 3522, would be an undesirable hardship and safety hazard without a compensating increase in safety, therefore the partial relief requested by the licensee from y

Codes IWV-3521 and 3522, requirement; that CRD check valves85-576 be exercised '

to closure every three months is granted.

2.3.2.25 PV-29 Leak Testing Inboard Main Steam Isolation Valves at Full Maximum Function Pressure Differential The licensee has requested relief from the IWV-3423 requirement that leak testing of the subject valves be performed at maximum function differential pressure or that leakage be adjusted to function maximum pressure differential.

The licensee proposes to test the' valves at a reduced differential pressure of 25 psig. In infomal discussions the licensee noted that this is- the pressure specified by TS 4.7.A.2.1.

Licensee's Basis for Requesting Relief Due to testing techniques, valve manifold design does not allow testing at full function pressure differential. Such a test would subject the valve manifold to potentially damading loads.

Evaluation

' Leak testing requirements for these valves are specified by TS 4.7.A.2.1.

These requirements are acceptable to the staff for the subject valves.

Additional testing or adjustment of leak rate values to conform fully with Code requirements would not result in sufficiently increased assurance of plant safety to warrant the burden of the testing or adjustment. The TS test requirement provides an acceptable level of quality and safety, j Conclusion The MC staff concludes that the proposed testing provides reasonable assurance I of operational readiness and full compliance with Code IWV-3423 would be an REVISED 7/28/89

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