ML20059C245
| ML20059C245 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/22/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058L968 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9311010066 | |
| Download: ML20059C245 (7) | |
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/~! NUCLEAR REGULATORY COMMISSION WASMNGTON, D.C. 20555-0001 ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO INSERVICE TESTING PROGRAM RE0 VESTS FOR RELIEF TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT. UNITS 1. 2. AND 3 DOCKET NUMBERS 50-259. 50-260. AND 50-296
1.0 INTRODUCTION
By letter dated August 31, 1992, the Tennessee Valley Authority (the licensee) submitted the Inservice Testing Program for pumps and valves at the Browns Ferry . Nuclear Plant (BFN), Units 1, 2, and 3 for the second inspection interval. This submittal provided information concerning the BFN IST program for the second 10-year interval, which began September 1, 1992. Additional information was submitted by the licensee in a letter dated March 19, 1993.
The Browns Ferry IST program is based on the requirements of Section XI of the ASME Code, 1986 Edition.
Title 10 of the Code of Federal Regulations, Section 50.55a, requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and l valves be performed in accordance with Section XI of the ASME Boiler and ,
Pressure Vessel Code and applicable addenda, except where alternatives are '
authorized or relief is granted by the Commission pursuant to paragraphs :
(a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In order to obtain authorization or relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for its facility. ;
l Per 10 CFR 50.55a(f)(4)(iv), inservice tests of pumps and valves may meet the I requirements set forth in subsequent editions and addenda of the ASME Boiler I and Pressure Vessel Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to Commissio.. approval. Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," provided alternatives to the Code testing requirements determined to be acceptable to the staff and provides the !
regulatory basis for authorizing those alternatives.
The Commission is authorized by 10 CFR 50.55a to approve alternatives or grant relief from ASME Code requirements upon making the necessary findings. The '
NRC staff's findings with respect to relief requested and alternatives proposed as part of the licensee's IST program are contained in this safety evaluation. A summary of the relief requests and the current status is provided in Table 1, " Summary of Rel' Requests."
9311010066 931022 PDR ADOCK 05000259 G PDR l
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2.0 EVALUATION The licensee's requests for relief from the requirements of Section XI have i been reviewed by the staff with the assistance of its contractor, EG&G-Idaho,
- Inc. (EG&G). .The Technical Evaluation Report (TER) provided as Attachment 1 is EG&G's evaluation of the licensee's IST program relief requests as contained in the licensee's IST program submittal dated August 31, 1993 and modified by the licensee's letter dated March 19, 1993. The staff has reviewed EG&G's TER and concurs with the evaluations and recommendations contained in it. The status of proposed relief requests included in the Browns Ferry IST Program is as stated in Table 1, " Summary of Relief Requests." The granting of relief or authorization of proposed alternatives is based upon' the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. The ,
implementation of the IST program is subject to inspection by the NRC. '
The licensee should refer to Appendix A of the TER for a discussion of IST program anomalies identified during the review. The licensee should respond to the concerns stated in anomalies 1 and 3 through 12 within 1 year, or by !
the end of the next refueling outage, whichever occurs later. The licensee l should consider anomaly number 2 when submitting new or revised requests for- !
relief or authorization of alternatives. These new or revised requests should not be implemented prior to approval by the NRC. The necessary actions to address the concerns stated in the anomalies should be included in a revised program for the licensee's second 10-year interval (that began on September 1, 1992). The revised program should be provided to the NRC and implemented as soon as possible.
The review performed by the staff was not intended to ensure that all of the appropriate components were included in the licensee's IST program or that all testing is appropriately applied; rather, these areas are subject to periodic NRC inspection.
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3.0 CONCLUSION
i In evaluating the licensee's requests for relief from the requirements of Section XI, the staff considered (1) the acceptability of proposed alternative testing, (2) whether the hardship of compliance is without a compensating increase in safety, and (3) the impracticality of performing the required testing considering the burden if the requirements were imposed. The last column of Table 1 identifies the regulations under which the requests are approved. The granting of relief or authorization of proposed alternatives is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the proposed alternate testing.
Principal Contributor: D. Fischer Date: October 22, 1993
BROWNS FERRY NUCLEAR PLANT, UNITS 1,2, AND 3 SAFETY EVALUATION TABLE 1 SUAISTARY OF RELIEF REQUESTS Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing ,
Nurnber Pump 2.1.1.1 IWP-3100:. All pumps in the IST Measure pump vibration Alternate approved PV-1 Measure bearing program quarterly. pursuant to temperature 10 CFR 50.55a, annually 1 (f)(4)(iv), provided all related requirements are met.
Purnp 2.1.2.1 IWP-3100: Standby liquid control Measure pump discharge Alternate approved PV-2 Measure inlet and (SLC) and diesel fuel pressure. pursuant to differential transfer (DFT) pumps 1 (f)(4)(iv), provided pressure all related requirements are met.
Pump N.A. IWP-3500(a): Diesel fuel oil transfer Measure pump parameters Non-Code Class PV-3 Pump five minute pumps during a two minute test at components, request run time least once every six months, not evaluated in SETTER.
Valve 3.1.1.1 IWV-3416 and Various valves that are Take actions according to Relief denied to PV-4 -3417(b): not specifically plant technical specifications deviate from Valves in systems identified in the IST (TS). IWV-3416.
out of service and program. Alternate authorized valves failing cold pursuant to j (a)(3)(i) shutdown stroke to deviate from time tests - IWy.3417(b) with corrective actions provisions.
Pump N.A. IWP-3210 and Diesel fuel oil transfer Evaluate the ability of each Non-Code Class PV-5 -4110: pumps pump to exceed the diesel components, request Acceptance consumption rate monthly and not evaluated in critena and take vibration measurements SErrER.
instrument quarterly.
accuracy Valve 3.2.2.1 IWV-3411, -3412, Main steam automatic Exercise during refueling Alternate authorized PV-6 and -3413: depressurization system outages and verify valve pursuant to 1 (a)(3)(i)
Test method and valves: 1(2)-PCV-1-5, operation by observing for an interim period fre4pency -19,-22 -30, -31, -34, indication of stecn flow of one year or until 3-PCV-1-5, -18, -19, through each valve. Valve the next refueling
-22. -34, and -41 stroke times will not be outage, measured.
Valve 3.2.3.1 IWV-3521: Main steam relief valve Manually full-stroke exercise Alternate approved pV-7 Test frequency discharge pipe vacuum valves during CSDs when the pursuant to breaker check valves drywell atmosphere is 1 (f)(4)(iv), provided listed in the request deinerted and during refueling all related outages. requirements are met.
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BROWNS FERRY NUCLEAR PLANT, UNITS 1,2, AND 3 j SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identincation Method of Testing Number Valve 3.3.1.1 IWV-3521: Feedwater head:r check Verify closure by performing Alternate approved PV-8 Test frequency valves: Appendix J leak rate testing at pursuant to 3-554, -558, -568, and refueling outages. 1 (f)(4)(iv), provided ,
-572 all related I requirements are met.
Valve 3.4.1.1 IWV-3521: SLC injection line Full-stroke exercise open and Alternate approved PV-9 Test frequency check valves: closed during refueling pursuant to 63-525 and -526 outages. 1 (f)(4)(iv), provided 3 all related requirements are met.
Valve 3.5.1.1 IWV-3521: Control rod drive Verify closure by performing Altemate approved l PV-10 Test frequency (CRD) supply to Appendix J leak rate testing at pursuant to recirculation pump seal refueling outages. 1 (f)(4)(iv), provided containment isolation all relatee = j valves: requirements are met. ;68-508,-523,-550, and -555 Valve 3.6.1.1 IWV-3521: Reactor water cleanup Verify closure during Attemate approved PV-11 Test frequency system retum line Appendix J leak rate testing at pursuant to I check valves: refueling outages. 1 (f)(4)(iv), pmvided 1(2)4 9-579 all related and 3-69-624 requirements are met.
Valve N.A. Request PV-12 withdrawn Valve N.A. [WV-3520: RHRSW keep fillline Verify closure capability by Approved by PV-13 Test method and check valves: performing sample . GL 89-04, Position 2, frequency 23-601, -603, -605 and disassembly and inspection not evaluated in
-607 during refueling outages. SE/TER.
Valve N.A. IWV-3520: Emergency equipment Verify closure capability by Approved by PV-14 Test method and cooling and raw cooling performing sample GL 89-04, Position 2, frequency water system check disassembly and inspection not evaluated in j valves listed in the during refueling outages. SE/TER.
relief request.
Valve 3.7.1.1 IWV-3521: Reactor building closed Verify valve closure in Altemate approved PV-15 Test frequency cooling water supply to conjunction with Appendix J pursuant to.
the recirculation pump leak rate testing during 1 (f)(4)(iv), provided bearing and seal refueling outages. all related coolers: 70-506 requirements are met.
Valve N.A. Request PV-16 withdrawn 2
BROWNS FERRY NUCLEAR PLANT, UNITS 1,2, AND 3 SAFETY EVALUATION TABLE I
SUMMARY
OF RELIEF REQUESTS i l
1 Relief TER Section XI Equipment Proposed Alternate NRC Action ,
Request Section Requirement Identification Method of Testing 1 Number Valve 3.10.2.1 IWV-3521: liPCI and RCIC Verify closure during Alternate approved PV-17 Test frequency turbine exhaust line refueling outages in with provision check valves: conjunction with the pursuant to 73-603,-609,71-580 Appendix J leak rate testmg. 1 (f)(4)(iv), provided and -592 all related I requirements are met.
Valve N.A. IWV-3520: HPCI and RCIC Sample disassemble and Approved by PV-18 Test method and turbine exhaust vacuum inspect according to GL 89-04, Position 2, frequency relief check valves: GL 89-04. Position 2, to not evaluated in 73-633,-634,-635, verify full-stroke open and SE/TER.
-636,71-597,-598, closure capability during
-599, and -600 refueling outages. ,
l Valve N.A. IWV-3520: HPCI and RCIC Disassemble and inspect each Approval by PV-19 Test method and suppression pool refueling outage. GL 89-04, Position 2, '
1 frequency suction check valves: not evaluated in 73-517 and 71-508 SEffER.
Valve 3.10.1.1 IWV-3521: HPCI and RCIC Leak rate test these valves Approved by PV-20 Test frequency suppression pool with pressure in the reverse GL 89-04, l suction, turbine steam direction. The testing is Position 10, with supply, and RCIC otherwise in accordance with provision. This is not steam bypass isolation Appendix J and IWV-3426 an exemption to valves: and -3427(a). 10 CFR 50, FCV-1-55, 73-2, and Appendix J.
71-2 Valve N.A. IWV-3411 and Ilydraulic control unit Exercise valves during Approved by PV-21 -3521: scram valves: Technical Specification scram GL 89-04, Position 7 Test frequency 85-39A, -39B, -589, testing in acirdance with not evaluated in
-597, and -616 GL 89-04, Position 7. SETTER.
Valve N.A. IWV-3521: Control air containment Verify closure during Non-Code Class PV-22 Test frequency isolation check valves: refueling outages in components, request 1-32-336,-915. -2516, conjunction with the not evaluated in
-2521, 2-32-336, Appendix J leak rate testing. SE/TER.
-2163, -2516, -2521, 3-32-336, and -2163 Valve N.A. IWV-3417(a): Power-operated valves Test rapid acting valves in Approved by PV-23 Stroke time with reference stroke accordance with GL 89-04, GL 89-04, Position 6, corrective action times s 2 seconds. Position 6. not evaluated in requirements SETTER.
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BROWNS FERRY NUCLEAR PLANT, UNITS 1,2, AND 3 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Proposed Alternate. NRC Action Request Section Requirement Identification Method of Testing Number Valve 3.11.1.1 IWV-3521: Containment inerting Verify closure during Alternate approved PV-24 Test frequency containment isolation refueling outages in pursuant to check valves: conjunction with the 1 (0(4)(iv), provided 76453 Appendix J leak rate testing, all related requirements are met.
Valve 3.8.1.1 IWV-3521: RilR injection to. Full-stroke exercise open Alternate approved PV-25 Test frequency recirculation loop using the test operator during with provision testable check valves: CSDs when a drywell entry is pursuant to 74-54 and 48 made and during refueling 1 (O(4)(iv), provided outages. all related requirements are met.
Valve 3.9.1.1 IWV-3521: Core spray injection Exercise open during CSDs Alternate approved PV-25 Test frequency testable check valves; when the drywell is de-inerted with provision 3 75-26 and -54 and during refueling outages pursuant to using the valve test operators. 1 (0(4)(iv), provided all related requirements are met.
Valve N.A. Request PV-26 withdrawn Valve N.A. IWP-3423: Inboard MSIVs: Leak test at reduced pressure Approved by PV-27 Leak rate test FCV-1-14, -26, -37, differential of 26 psig. GL 89-04, ,
differential and -51 Position 10, not pressure evaluated in SE/TER.
Valve 3.8.1.2 IWV-3521: The check valves that Full-stroke exercise open Alternate approved PV-28 Test frequency provide thermal relief during CSDs when the pursuant to protection for the line drywell is de-inerted and 1 (0(4)(iv), provided '
between the RilR during refueling outages. all related shutdown cooling Verify closure at refueling requirements are met, suction isolation valves: outages in conjunction with 74-661 and -662 the Appendix J leak testirig. -
Valve N.A. IWV-3520: HPCI and RCIC Sample disassemble and Appoved by PV-29 Test method and backflow preventer inspect according to GL 89-04, Position 2, frequency check valves: 71502, GL 89-04, Position 2, to not evaluated in
-589,73-505, and -625 verify their closure capability SETTER.
during refueling outages.
Valve N.A. IWV-3520: SLC puup discharge Full-stroke exercise open Approved by PV-30 Test method and check valves: quarterly verify closure GL 89-04, Position 2, frequency 63-514 and -516 capability by a sample not evaluated in disassembly and inspection SE/TER.
l during refueling outages.
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BROWNS FERRY NUCLEAR PLANT, UNITS 1,2, AND 3 SAFETY EVALUATION TABLE 1 .
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing Number I
Valve N.A. IWV-3413: Diesel generator air Exercise valves monthly and Non-Code Class y PV-31 Stroke time start solenoid +perated time the diesel start semi- components, request t measurement valves listed in the annually. not evaluated in request. SE/TER.
Valve 3.2.1.1 IWV-3415: Inboard main steam Fail-safe test during cold Alternate approved -
PV-32 Test frequency isolation valves shutdowns (CSDs) when the pursuant to (MSlVs): drywell atmosphere is 1 (f)(4)(iv), provided FCV-1 14, -26, -37, deinerted and refueling all related and -51 outages. requirements are met. l Valve 3.1.2.1 IWV-3417(a): All power-operated Base the " Alert" corrective Alternate approved PV-33 Stroke time valves listed in the IST action requirements on pursuant to corrective action program, deviations from reference 1 (f)(4)(iv), provided requirements stroke times. all related requirements are met.
Pump N.A. Request PV-34 withdrawn Valve N.A. IWV-3427(b): All containment Leak rate test all containment Approved by PV-35 Leak testing isolation valves with isolation valves in accordance GL 89-04, corrective action nominal pipe size of six with Appendix J and Position 10, request !
requirements inches or larger. IWV-3426 and -3427(a). not evaluated in j SE/TER. j I
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