ML17342B386

Forwards Requests for Temporary Exemption from App J Testing of Reactor Bldg Closed Cooling Water Valves.Exemptions Requested to Accommodate Schedule Requirements.Approval by 860219 Requested

ML17342B386
Person / Time
Site:	Browns Ferry
Issue date:	11/20/1985
From:	Hufham J TENNESSEE VALLEY AUTHORITY
To:	Vassallo D Office of Nuclear Reactor Regulation
References
TAC-60251, NUDOCS 8511260320
Download: ML17342B386 (15)

Text

REGULATORY ORNATION DISTRIBUTION SY~ (RIBS)

ACCCKSS~,',N NBR;8511?60320, DOC DATE! 85/11/20 NOTARIZED! YES DOCKET FOCI[ SO 2'SO Tur key Point Plant'r Unit 3r Flor ida Powet and Light C 05000?50 50, 260 Br owns Ferry Auclear Power Stations Unit 2i Tennessee 05000260

. 50~296 Browns Felry Nuclear Power; Stationr. Unit 3r Tennessee 05000296 AUTHBNAME. AUTHOR Al FILIATION HOFHAMrJBW ~ Tennessee<<,Valley Authority AECIP ~ NAME~ 'ECIPIENT AFFILIATION VASSAL! OrD ~ Bs Operating, Rehctors Branch 2

SUBJECT:

For'wawr ds requests forI temporary exemption from App J test)ng of reactor bldg, closed cool-ing water valves.

Exemptions requested, to accommodate'-schedule. requirements.

Approval by 860219 rYequested',

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place November 20, 1985 Director of Nuclear Reactor Regulation Attention: Mr. Domenic B. Vassallo, Chief Operating Reactor Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Vassallo:

In the Matter of the Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 An internal review of the 10 CFR 50 Appendix J testing program for Browns Ferry Nuclear Plant (BFN), has identified several exceptions to Appendix J requirements. These exceptions were submitted to NRC in a letter to you dated May 10, 1985 and discussed in a subsequent meeting with the NRC staff on August 28, 1985. As discussed in that meeting, we are requesting the enclosed temporary exemptions to Appendix J requirements as they apply to certain of these identified exceptions for Browns Ferry unit 2. The exemptions are requested for one cycle of operation.

Our request for exemption relating to Appendix J testing of the Reactor Building Closed Cooling Water (RBCCW) valves, submitted October 10, 1975, was denied by NRC in a letter dated October 24, 1984. We are planning to perform.

the necessary testing. However, the enclosure requests a temporary exemption to Appendix J requirements for testing, the affected RBCCW valves.

The enclosed exemptions are being requested in order to accommodate schedule requirements for designing, material procurement, and installation of the modifications necessary to perform testing. The enclosed justifications demonstrate that the requested temporary exemptions of the subject valves, valve bonnets, and orifice flanges until the unit 2 cycle 6 refueling outage, do not pose any undue risk to public health and safety.

511>+0320 8511P0 PDR ADOCK 05000259' PDR

'n Equa( Opportunity Employer

II Director of Nuclear Reactor Regulation November 20, 1985 Approval of the requested exemptions is needed by February 19, 1986. Approval of the exemptions is needed before starting the integrated testing, which is scheduled for late February.

Very truly yours, TENNESSEE VALLEY AUTHORITY W. Hu h Manager i ensing an Risk Protection

,Subscribed an ~orn to before

-; me o thi ~a o - 1985.

Notary Public My Commission Expires Enclosure cc (Enclosure):

Mr. R. J. Clark U.S. Nuclear Regulatory Commission Browns Ferry Project Manager 7920 Norfolk Avenue Bethesda, Maryland 20814 U.S. Nuclear Regulatory Commission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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Enclosure Request for Temporary Exemptions from 10 CFR 50 Appendix J,gequirements for

,Browns Ferry Nuclear Plant - Unit 2 I. Valve Bonnet and d)rifice Flange Testing TVA requests exemption to 10 CFR 50, Appendix J; paragraph III.D.2 (Type B Tests) for the following valve bonnets and orifice flanges, whichI form part of the water sealed containment boundary. This exemption is requested until the unit 2 cycle 6 refueling outage.

A. Hand Control. Valve Bonnet 12-742 This is a two-inch auxiliary boiler valve located inboard of the prima y containment isolation valves in the piping which connects the auxiliary boiler system to the torus via the Reactor Core Isolation Cooling (RCIC) pump miniflow line. This valve is not a primary containment isolation valve; however, the valve bonnet forms part of.

the primary containment boundary.

B. Flow Control Valve Bonnet 71-34 This is a two-inch RCIC system inboard primary containment isolation valve located in the RCIC pump miniflow line which discharges to the suppression pool. This is the same RCIC line discussed in item I .A above.

C. RCIC Orifice Flange The RCIC orifice flange is located in the RCIC pump miniflow line inboard of the primary containment isolation valves. This orifice flange forms part of the primary containment boundary. This is the same RCIC line discussed in item I.A and I.B above.

Page 2 Enclosure (Continued)

Valve Bonnet and Orifice Flange Testing (Continued) lw D. Flow Control Valve Bonnet 73-30 This is a four-inch High Pressure Coolant Injection (HPCI) system inboard primary containment isolation valve located in the HPCX pump 4

miniflow line which discharges to the suppression pool.

Justification The above valve bonnets and orifice flanges are not currently testable (type B test). Block valves, test connections, vents, and drains must be installed to allow local leak testing in accordance with Appendix J.

Because these testing requirements were identified during the current unit 2 outage, there is insufficient time available to procure materials, prepare design changes, and implement the necessary modifications without impacting the unit 2 outage schedule.

Safety Analysis Each of the above components are primary containment boundaries associated with lines that terminate below the suppression pool water level. They are, therefore, water sealed and isolated from the containment atmosphere post accident. During the requested exemption period,-the following considerations provide a high degree of assurance that containment leakage limits will not be exceeded post accident by compensating for the exempted testing requirements. All of the exempted components are within the type A test boundary, and will be type A tested during the current refueling outage. They will not be disassembled again until type B testing can be

age 3 Enclosure (Continuyd)

Valve Bonnet and Orifice Flange Testing (Continued)

~ '8 Safety Analysis (Continued) 1~

performed. Finally, review of past test data indicates that the exempted boundaries have not exhibited leakage during type A tests. Therefore, granting the requested exemptions will not adversely affect the public health and safety.

II. Reverse Flow Testing of Spring Operated Globe Valves TVA requests'exemption to 10 CFR 50, Appendix J, paragraph III.C.1 (Type C Tests - Test Methods) for the Containment Atmospheric Dilution (CAD) system primary containment isolation valves 84-8A/8B/8C/8D (two inch). These valves are part of the primary containment boundary and are open to the drywell atmosphere. This exemption is requested until the unit 2 cycle 6 refueling outage.

Justification The current configurations allow only reverse flow testing of the above valves. Block valves and test connections must be installed in order to allow forward flow testing (direction of accident flow). Because these testing requirements were identified during the current .unit 2 outage; there is insufficient time available to procure materials, prepare design and implement the necessary modifications without impacting the 'hanges, unit 2 outage schedule.

t Enclosure (Continued) l II. Reverse Flow Testing of Spring Operated Globe Valves--(Continued) j l~ 1 Safety Analysis Appendix J requires forward flow testing of primary containment isolation valves, unless it can be shown I

that reverse flow testing will provide equal to or more conservative results. The CAD valves are spring operated (to close) globe valves. TVA does not have direct evidence supporting equivalency of reverse flow testing of these valves; however, historical data'(type A tests) have proven that these valves have never passed a reverse flow type C test and then failed a subsequent type A test.

these valves is one of a pair of valves which form the type A test boundary in the 4 CAD lines and will be type A tested during the current refueling outage Also, reverse flow type C testing will be continued which will identify any I

major deterioration of the CAD valves seating. Therefore, the public health and safety will not be adversely affected by granting a temporary exemption until the unit 2 cycle 6 refueling outage.

III. Type C Testing of RHR Vent Return Lines TVA requests exemption to 10 CFR 50, Appendix J, paragraph III.D.3 (Type C Tests) for the RHR vent return line isolation Valves FCV 74-102/103/119/120. The one and one-half inch RHR vent 'return lines are two branch lines (one and a half inch and two inch) which goin .to form a single primary containment penetration above the suppression pool water level.

Each branch line has two primary containment isolation valves (air operated globe valves). This exemption is requested until the unit 2 cycle 6 refueling outage.

Page 5 Enclosure (Continued)

III. Type C Testing of RHR Vent Return Lines (Continued)

Justification The above valves are not currently testable (type C test). Block valves, drain valves, test connections, and vent valves must be installed to allow type C testing in accordance with Appendix J. Because these testing requirements were identified during the current unit 2 outage, there is insufficient time available to procure materials, prepare design changes, and implement the necessary modifications without impacting the unit 2 outage schedule.

Safety Analysis Each of the above are primary containment boundaries which are open to the suppression pool atmosphere. Piping outboard of these valves is closed but not qualified, and has a small probability of failure post accident. Each leak path (branch line) will be included in the current unit 2 cycle 5 refueling outage type A test boundary. Historical test data (type A tests) have shown that these primary containment isolation valves have not been a significant contributor to containment leakage; therefore, the granting of a temporary exemption until the unit 2 cycle 6 refueling- outage will not.

adversely affect the public health and safety.

IV . Type C testing of RBCCW System TVA requests exemption to 10 CFR 50, Appendix J, paragraph III.D.3 (Type C Tests) for the RBCCW system isolation valves 70-47/506. RBCCW is a .closed

~ ~ e Enclosure (Contin@ed)

IV. Type C testing of RBCCW System (Continued) loop system which penetrates primary containment. It does not strictly meet the requirements of SRP 6.2.4. 'his exemption is requested until the unit 2 cycle 6 refueling outage.

Justification The above valves are not currently testable. Block valves, drains, test connections, and vents must be installed to allow type C testing in accordance with Appendix J. These modifications will require removal of the RBCCW system from service which will have a major impact on plant operation during the affected refueling outage. Preparation for this type of operation would significantly impact the current unit 2 refueling outage.

Safety Analysis The RBCCW system is a closed loop system under original Browns Ferry design criteria (non-qualified in accordance with SRP 6.2.4) which penetrates primary containment. The system does not interface with the primary containment atmosphere or the primary reactor coolant boundary. Testing the isolation valves in accordance with Appendix J provides additional safety margin for the RBCCW containment penetrations that is above and beyond the original plant requirements. Therefore, the granting of an exemption until the unit 2 cycle 6 refueling outage will not adversely affect the public health and safety.

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