IR 05000259/1985050
| ML18030A901 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/07/1985 |
| From: | Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18030A900 | List: |
| References | |
| 50-259-85-50, 50-260-85-50, 50-296-85-50, NUDOCS 8511260690 | |
| Download: ML18030A901 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/85-50, 50-260/85-50, and 50-296/85-50 Licensee:
Tennessee Valley Authority 6Nll B Missionary Ridge Place 1101 Market Street Chattanooga, TN 37402-2801
" Docket Nos.:
50-259, 50-260 and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2, and
Inspection Conducted:
October 15-18, 1985 Inspector:
H.
L. Whit r
Approved by:
.
L2.
~ F. Jape, ection Chief Engineering Branch Division of Reactor Safety
/y'
gS'ateSigned Dat Signed SUMMARY Scope:
This special, announced inspection involved 26 inspector-hours on site in the area of local leak rate testing.
Results:
No violations or deviations were identified.
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REPORT DETAILS 1.
Persons Contacted l
Licensee Employees
- J. Swindell, Assistant Plant Manager for Operations D.
Mims, Engineering Supervisor
~K. Mulling, Mechanical Engineer (LLRT Coordinator)
K. Clark, Integrated Leak Rate Test Group, Chattanooga NRC Resident Inspectors
"G. Paulk
- C. Patterson
"C. Brooks
"Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on October 18, 1985, with-those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
IFI (259/85-50-01, 260/85-50-01, 296/85-50-Ql):
Update plant drawings to show the current status of containment penetrations and verify the accur acy of the penetration listing used in the leak rate program evaluation.
Passive Components:
This item remains unresolved pending NRC review of the licensee's proposal for testing and inspection of the RHR and CS systems.
Exemptions to Appendix J remain unresolved pending NRC review of the licensee's proposal for temporary exemption for certain valves in Unit 2.
The inspector asked the licensee to submit the above documents for NRC review as soon.- as possible to allow sufficient time for NRC review without impacting the projected startup schedule.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio t,
4.
Unresolved Items Unresolved Items were not identified during the inspection.
5.
Local Leak Rate Testing Units 1, 2, and 3 (61720, 90712, 92700)
The licensee has reported on several areas where the Browns Ferry local leak rate test program is not in strict compliance with the requirements of Appendix J to
CFR 50.
These areas concern valves tested in the wrong direction such that test results could be nonconservative, valves tested using water instead of air, and valves which are not routinely tested because they were previously identified as system isolation valves, but which also function as containment isolation valves.
Certain of the above problems were identified in March 1985 which resulted in the shutdown of Unit 1 (LER 50-259/85-008).
An engineering evaluation to review all plant isolation valves for conformance with Appendix J requirements was initiated and resulted in identification of certain additional deviations from a
strict and literal interpretation of Appendix J requirements (LER 50-259/85-008, R1; and LER 259/85-036; and LER 50-259/85-036, Rl).
Units 1, 2,
and
have remained in cold shutdown during the evaluation period.
As a result of the engineering evaluation, the licensee has developed a
program for corrective action and -isolation valve testing which was presented for NRC evaluation in a meeting with NRR and Region II representa-tives on August 28, 1985.
During this inspection, the inspector reviewed the method used to perform the evaluation, the results of the evaluation, the proposed corrective actions, and portions of the local leak rate test procedure (SI-4.7.A.2.g-3).
The inspectionfindings are discussed in the following subparagraphs.
a.
Evaluation Results In that the initial leak rate test program at Browns Ferry was based on criteria generated prior to the issuance of Appendix J, certain aspects of the test program did not conform to Appendix J requi rements.
In response to an NRC letter to all licensees in August 1975 requesting the licensees to review their leak rate programs for conformance to Appendix J, Browns Ferry identified certain areas of nonconformance and subsequently resolved these issues.
In March 1985, the licensee identifie4 additional local
'leak rate tests that do not conform to Appendix J requirements (LER 259/85-008).
The licensee initiated a
re-evaluation of the local leak rate program and identified a number of nonconformance areas based on a literal interpretation of Appendix J requirements.
The results of the evaluation were discussed with the NRC at a meeting on August 28, 1985.
At this meeting, the licensee presented a written list of the problem areas, proposed corrective action, and a schedule for implementation of the corrective action.
The problem areas and implementation schedule are listed below:
IMPLEMENTATION SCHEDULE Completed Items.
71-17/18 71-34/547 73-26/27 73-30/559 71-14 73-23 71-32 73-24 RCIC pump suction RCIC pump miniflow HPCI pump suction HPCI pump mini flow RCIC turbine exhaust (bonnet)
RCIC vacuum pump discharge (bonnet), unit 3 only HPCI turbine exhaust drain (bonnet), unit 3 only (2)
Items to be Completed Prior to Startup U-1 and U-3 U-2 U-2 U-2 U-2 U-2 U-2 U-2 U-2 All identified problems 74-58 RHR containment spray (bonnet)
74-792/804 PSC head tank tie in to RHR loop 1 74-802/803 PSC head tank tie in to RHR loop 2 75-606/607 PSC head tank tie in to CS loop
'1'5-609/610 PSC head tank tie in to CS loop
RHR and CS system walkdowns 71-32 RCIC vacuum pump discharge (bonnet)
73-24 HPCI turbine exhaust drain (bonnet)
(3)
Items to be Implemented by U2-C7 Startup 70-47/506 84-8A/8B/8C/8D 12-742 71-34 73-30 74-102/103 74-119/120 RBCCW supply and return CAD valves (arp currently type C tested, but in reverse direction)
Aux boiler tie in to RCIC (bonnet only)
RCIC pump miniflow (bonnet only and orifice)
HPCI pump miniflow (bonnet only)
RHR vent return RHR vent return All of the above will be type A tested prior to startup, except RBCCW valves 70-47/506.
During this inspection, the inspector confirmed the following condi-tions relating to the August 28, 1985 meeting:
All problems reported in LER 259/85-008; 259/85-008, Rl; and 259/85-036, R1 were included in the meeting agenda.
(2)
(3)
No new problem areas have been identified since the meeting.
Work is in progress to meet the implementation schedule and corrective actions agreed upon at the meeting.
Specifically, the licensee commitments are:
(a)
Correct all identified problems on Unit 1 and Unit 3 before startup of these units.
Based on the projected startup schedule, this commitment appears to be achievable.
(b)
Correct identified problems on Unit 2 with the exception for those identified for deferment until the fuel cycle seven startup.
This will be the second refueling outage after the current startup which is now scheduled for January 1986.
Achievement of the projected startup date is dependent upon obtaining temporary exemptions for those problems identified in item (3) of the implementation schedule.
(4)
The exemption request for the deferment of the items discussed in item 3.b above is now undergoing plant review.
The inspector reviewed a draft of the exemption request and identified one omission.
The packing on valves 73-23, 71-14, 73-24, and 71-32 is not in the leak rate testing boundary.
These are check valves and therefore cannot be reoriented in the line.
This condition should be identified along with any proposed alternative testing or inspection.
(5)
System review relative to the NRC request for additional informa-tion on testing the residual heat removal (RHR)
and core spray (CS) suction line valves is..well advanced.
The.problem concerns
.
the fact that the licensee considers the isolation valves on the RHR and CS suction lines from the torus ring header as maintenance valves and the RHR and CS piping as an extension of the contain-ment boundary.
The logical extension of this argument is that those attachments to the RHR and CS piping become containment penetrations and potential leakage paths.
In that some 80 branch lines may be involved, leak rate testing becomes a complex issue.
The licensee has previously considered the normally closed valves on piping attached to the RHR and CS piping as passive components not subject to failure analysis (this concept is discussed further in paragraph 5.c).
The licensee is reviewing the options and preparing a submittal regarding testing of the RHR and CS systems for NRC review.
b.
Penetration Identification Re-evaluation of the local leak rate program was performed by reviewing the valves associated with each containment penetration for conformance with the current Appendix J criteria.
Plant penetration listings, system drawings, and system walkdown to verify valve types and orienta-tion were used in the evaluation process.
The inspector found that a
complete, up to date listing of containment penetrations and their functions was not available in the Technical Specification, Final Safety Analysis Report (FSAR), or penetration drawings.
However, the leak rate test personnel have been maintaining a current listing of containment penetrations which reflect modifications made to the containments since completion of construction.
This listing is
t
documented in surveillance procedure SI 4.7.A.2.
Since the leak rate personnel review all containment modifications, they would be knowledgeable of any changes in the penetration listing.
The inspector accepted that all penetrations were included in the evaluation with the qualification that the plant update the penetration drawings to represent the current condition of the plant and verify that the penetration listing in SI 4.7.A.2 is accurate.
Licensee management stated that one of the tasks in progress is to update all plant drawings.
The containment penetration drawings will be updated in this program.
This matter was identified for followup inspection as Inspector Followup Item (IFI) (259/85-50-01, 260/85-50-01, 296/85-50-01):
Verify that plant penetration drawing> show an up to date, as-built condition of the plant and confirm the accuracy of the penetration listing used in evaluation of the local leak rate test program.
Passive Components In the evaluation presented for NRC consideration at the August 28, 1985 meeting, problems identified in the RHR and CS systems are based on the concept that a closed valve is a passive component and presumed not to fail.
The licensee maintains that this concept is presumed in the Browns Ferry design and is -supported by references in Section 1. 2--
and Appendix I 4.25 of the FSAR.
Review of these references indicates that the failure under consideration pertains to mechanical operability and catastrophic failure.
Appendix I. 4. 25 of the FSAR states that failure of Class I passive components such as qualified piping, valve bodies or pump casings, etc.
is not pqstulated. in the plant design.
Section 1.2, item number 67 of the FSAR states that a passive component is one in which neither a change of state nor a change of position is required for the component to perform the design function.
For example, a normally closed valve would not be postulated to fail'o close in an accident situation.
These references do not appear to address potential leakage from containment through valve seats, packing and flange seals.
At the August 28, meeting, the NRC advised the licensee that a valve is not considered a passive component relative to leakage potential.
The licensee was asked to submit additional information on the RHR and CS systems pertaining to the number, type, size, function, etc.
of potential leakage paths attached to these systems agd possible testing options.
This submittal is in prepara-tion.
Procedure Review The inspector reviewed p'ortions of SI-4.7.A.2.g-3, Containment Isola-tion Valve Leak Rate Tests, to verify that adequate valve alignments are identified in the test procedure.
Penetrations reviewed at this time included:
X-205 X-48 X-21 X-41 X-20 X-228 X-231'-16B Vacuum Breaker, Torus to Reactor Building Control Air Service Air Recirculation Pump Sample Line Demineralized Mater Cut and Capped Containment Ventilation Core Spray Injection, Loop 2 The inspector found that the block valves, test connections, vent paths and isolation valves were adequately identified and properly posi-tioned.