ML18029A245

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Safety Evaluation Re 840920 Request for Exemptions from 10CFR50 App J Requirements.Exemption Requests Acceptable W/Exception of Item Re Reactor Bldg Closed Cooling Water Valves 70-47 & 70-506
ML18029A245
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 10/24/1984
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML18029A246 List:
References
NUDOCS 8411080526
Download: ML18029A245 (5)


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'NITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION APPENDIX J REVIEW TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 DOCKET NOS. 50-259, 50-260 AND 50-296 1.0 Introduction Appendix J to 10 CFR Part 50 was published on February 14, 1973.

Since, by this date there were already many operating nuclear plants and a number more in advanced stages of design or construction, the NRC decided to have these plants reevaluated against the requirements of this new regulation.

Therefore, requests for review of the extent of compliance with the requirements of Appendix t were made of the licensee.

On August 4, 1975, the NRC requested the Tennessee Valley. Authority (licensee) to review its containment testing program for the Browns Ferry Nuclear Plant (Browns Ferry),

and the associated Technical Specifi'cations, for compliance with the requirements of Appendix J to 10 CFR Part 50.

Our consultant, the Franklin Research Center (FRC), has reviewed'he licensee's submittals regarding the containment leak rate testing program and prepared the attached technical evaluation report (TER).

We have reviewed the TER and have prepared the following staff safety evaluation.

2.0 Evaluation and Conclusions Based on our review of the attached TER prepared by the FRC, the following conclusions are made regarding the Appendix J review for the Browns Ferry Nuclear Plant, Units 1, 2 and 3.

1)=

The licensee's request for not venting and draining certain instrument lines is acceptable as these lines are Type C tested and the measured leakage r'ates used to back-correct the Type A test results.

No exemption is required.

2)

The licensee requested a temporary exemption to exclude venting and draining of the seal water supply to the reactor recirculation pumps during Type A testing while a modification was being installed to permit future draining and venting.

The modification has been completed on all three units; therefore.an exemption is not required.

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3) 4)

5) 6)

7)

The licensee requested an.exemption to test containment airlocks once each operating cycle at 2.5 psig instead of at six month intervals at full Pa pressure as. required by Appendix J.

FRC stated that this is unacceptable.

However, during recent refueling outages for each unit, TYA has installed strongbacks on the inner airlock doors to permit testing the airlocks at Pa.

TVA also submitted appropriate changes to the Technical Specifications (TS) to reflect compliance with Appendix J test requirements.

Thus, the exemption requested by the licensee is no longer necessary.

The licensee requested an exemption to permit Type C testing of three containment isolation valves (that are not water sealed) with pressure in the opposite direction than that which the valves would experience when performing their safety function.

The TER concludes that an exemption is unacceptable because single-wedge gate valves are not capable of meeting the "equivalent or more conservative" test criterion Appendix J,

,Section III.C.l.

The subject valves (FCV 1-55, FCV 71-2, and FCV 73-2) are leak tested by pressurizing between paired valves.

The test pressure acts in the reverse direction on the inboard valve tendimg to reduce seating force on the seating surface.

Since a reduction in seating force increases

leakage, the measurement will be conservative.

Therefore no exemption 'is required.

The TER concludes that the licensee's request for exemption regarding HSIY testing is acceptable because the method provides a conservative leak rate determination.

Because the "equivalent or more conservative" criteria of Section III.C.l of Appendix J is satisfied, an exemption is unnecessary.

The licensee withdrew a request for exemption from Type C testing for 59 valves to be tested with water in lieu of air or nitrogen.

Therefore, as stated in the TER, an exemption is not required.

As stated in the TER,'he request to exempt valves 70-47 and 70-506 from Type C testing is unacceptable.

These valves should be Type C tested or the RBCCW system shown to meet the closed-loop acceptance criteria stated in Standard Review Plan Section 6.2.4.

8)

The licensee requested a permanent exemption to exclude the traversing in-core probe (TIP) ball valves from Type C testing as well as a temporary exemption for the nitrogen supply to the TIP indexers.

The TER states that the permanent exemption is unacceptable.

However, in a letter from L. H. Hills to H.

R.

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~ Denton dated September 20, 1984, the licensee withdrew these exemption requests and agreed to perform testing in accordance with Appendix J. Therefore no exemption is required.

9)

We agree with FRC that the licensee's interpretation of the requirements of summing the leakage from Type C tests to determine acceptability satisfies the requirements of Appendix J.

The licensee's proposed method of summing the path leakage from Type C tests is acceptable provided that the path leakage will be rechecked after repairs.

Attachment:

TER dated'ecember 23, 1981 prepared by Franklin Research

. Center.

Principal Contributor:

Y. Huang, R. Clark, F. Eltawila, H. Lang E

Dated:

October 24,,

1984