ML20204G849

Responds to NRC Re Violations Noted in Insp Repts 50-327/88-36 & 50-328/88-36.Corrective Actions:Exemption Request Submitted Re Type C Testing of Containment Spray & RHR Spray Inboard Containment Isolation Valves

ML20204G849
Person / Time
Site:	Sequoyah
Issue date:	10/19/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8810240249
Download: ML20204G849 (6)

Text

--

e s'

TENNESEEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place 08T 191988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEOUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327/88-36 AND 50-328/88 NOTICE OF VIOLATION Enclosed is TVA's response to F. R. McCoy's letter to S. A. White dated 5eptember 16, 1958, that trer.imitt&d ths EUbj&ct notica of violation.

Enclosure I provides TVA's response to the notice of violation. TVA admits that an exemption for type C testing of the subject valves was not sub'titted in the beginning of plant life.

TVA has and continues to believe that the design and testing of the subject systems acceptably meet the requirements of Appendix J. However, TVA did agree to submit an Appendix J exemption request to resolve this issue after NRC reevaluated the previously accepted and approved plant design and testing program and its implementation. NRC's previous reviews and acceptance of the design und the testing program, along with the acceptance of the exemption request, attest to the merits of SQN's actions and clearly indicate a safety issue was never in question. While TVA does not take issue with the NRC staff initiative to reevaluate a licensee's compliance with a regulation, TVA is concerned that such reevaluation of previously accepted programs and program implementation is cor.stituting basis for enforcement action in a number of other issues where ambiguous regulatory requirements exist. To avoid further violations, TVA will be requesting a TVA/NRC management meeting to establish consistent interpretation of Appendix J requirements in order to address whether additional corrective actions are needed. TVA has and will continue to maintain compliance with regulatory requirements consistent with the licensing basis and respectfully requests that enforcement of those requirements be consistently applied.

! If you have any questions, please telephone H. A. Cooper at (615) 670-6549.

Very truly yours, TENNESSEE VJLLEY AUTHORITY

f'j r

R. ridley, Manager Nuclear Licensing and Regulatory Affairs Enclosure gg cc: See page 2 8910240249 GS1019 An Equal opportunity Employer PDR ADOCK 0500o327

.EE

U.S. Nuclear Regulatory Comission 08719 m cc (Enclosure):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. F. R. McCoy, Assistant Director for Inspectio- Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379

o ENCLOSURE 1 Violation 50-327, 328/88-36 "10 CFR 50 Appendix J states that:

II.H.3 Type C testing is required for those valves, that 'Are required to operate intermittently under postaccident conditions . . .'

III.C.1 ' Type C tests shall be performed by local pressurization. The pressure shall be applied in the same direction as that when the valve would be required to perform its safety functh a . .. '

III.C.2 ' Valves, which are sealed with fluid from a seal system shall be pressurized with that fluid to a pressure not less than 1.10 Pa.'

Contrary to the above, the containment spray and RHR spray inboard containment "

1 isolation valves have not been type C tested for the life of the plant.

This is a Severity Level IV violation (Supplement I)"

Admission or Denial of the Alleged Violation TVA admits that an Appendix J exemption request for not performing type C tests on the subject valves was not submitted at the beginning of the plant.

Reason for the Violation .

Section III.C.3 of Appendix J provides a basis for not performing type C air leak rate tests on certain containment isolation valves where a fluid seal, meeting the requirements described therein, can be demonstrated. The technical basis for this exclusion is that, even if the particular valves leak, the fluid seal prevents any leakage of containment atmosphere to the environment. Although Appendix J provides specific criteria, which must be met to ensure an adequate seal is maintained postaccident, the nature and design of such systems are not prescribed. TVA* believed the seal system '

provided for the subject penetrations at SQN met the 10 CFR 50, Appendix J.

requirement: for a seal system and prevented the penetrations from providing potential containment atmosphere leakage paths. The NRC staff has shown agreement with TVA on the technical merits of the seal system employed at SQN based on the following statement in NRC's letter to TVA dated Septembcr 22, 1988.

Therefore, the staff concludes that testing of the'se valves i

provides no increase in safety because any leakage is precluded '

l from reaching the environment by the water sdal and in conjunction with the closed systems and HOVs outside containment, ,

the design provides an acceptable alternative in achieving the underlying purpose of the rule and the exemption is warranted.

1 SQN's containment leakage testing program was reviewed during the initial licensing of SON and was found to be acceptable as documented in NUREG-0011, SQN Safety Evaluation Report (SER), dated March 1979. NRC stateJ in l

paragraph 6.2.6 of that SER, "Hith the exception of the airlock testing, for

! 0

-2 which we may grant an exemption as discussed above, the proposed reactor .

containment leakage testing program complies with the requirements of Appendix J to 10 CFR Part 50." The SQN design features and testing of these penetrations were provided in both the text and figures of chapter 6 of the SQN Final Safety Analysis Report (FSAR). At various time.s since the operating Ilcense was issued, NRC has observed the leak rate tests at SQN.and has I reviewed the test program and results. No problems were identified by the r ins.nectors observing or reviewing the testing of the subject penetrations.

As part of the unit 2 restart inspections, NRC reviewed the SQN Local Leak

' Rate Test (LLRT) Program and specifically reviewed the testing performed for the subject penetrations. The results of that inspection are documented in Inspection Report No. 50-327, 328/87-51, which states in part, "The inspector reviewed the licensee's containment local leak rate test program to verify that procedures have been developed and implemented which insure that the requirements of 10 CFR 50, Appendix J and the Technical Specifications are met." The report further states, "Based on this review the inspector concluded that the licensee has developed and implemented the procedures necessary to conduct the local leak rate test program in conformance with the requirements of 10 CFR 50, Appendix J and the Technical Specifications."

NRC again addressed the SQN Containment Leakage Testing Program in NUREG-1232, Volume 2, dated May 1988, that documents the SER for TVA's Sequoyah Nuclear Performance Plan. This SER specifically addressed the subject penetrations as follows: "

' Containment Spray and RHR Spray Linres (Penetrations X-48A, -488,

-49A, and -498)

I The containment spray lines (penetrations X-48A and -488) are considered by the staff to be water sealed and not potential containment atmosphere leak paths.

A water leg is maintained during normal operation in each riser between a closed valve and the spray ring header. These closed valves now are leakage rate tested with water to verify that there is sufficient inventory in the risers to maintain a water seal for 30 days, even after the containment spray pumps are shut off; this testing is specifically required by Technical Specification 4.6.1.2.g. Therefore, the staff concludes that the present testing of penetrations X-48A and -488 is acceptable.

i The RHR spray lines (penetrations X-49A and -498) are very 4

similar to the containment spray lines, except that no leakage rate testing is performed. The staff would find it acceptable if TVA performed the same type testing as it does for the containment spray lines, or normal Type C testing with air or

, nitrogen. By letter dated January 2, 1987, TVA has proposed to test the RHR spray valves in the same manner as for the containment spray lines. Thus, the staff finds this is acceptable.

i 0

TVA believes the system employed at SQN has been previously considered by NRC to acceptably meet the requirements of 10 CFR 50, Appendix J, based on NRC's detailed program review at the time of initial licensing, continuing LLRT program inspections since licensing, and the more recent exhaustive reviews performed during the extended SQN shutdown. . , ,

TVA realizes that throughout plant lifetime many individuals on'the NRC staff have an opportunity to review the requirements and commitments incumbent upon a licensee. Undoubtedly, there will be occasions when 'an NRC reviewer conciudes the licensee's program on a specific area does not satisfy a regulation, license condition, or commitment, based on such thing as personal interpretation of the regulations, reference to more recent guidance, etc.

NRC has apparently adoptad a more literal and restrictive interpretation that is now being applied. Wnile TVA agreed to submit an exemption request to ensure continued operation of SQN unit 2 and expedite restart of unit I during the resolution of this issue, TVA maintained that SQN is in compliance with Appendix J as stated in our letter dated August 8, 1988.

In summary, TVA understands that the nature and design of the seal systems used to meet the specific criteria given in Appendix J, sections III.C.2 and III.C.3, are to some degree a matter of interpretation on the part of both NRC and the licensee. As discussed above, TVA's design, operation, and testing of the seal system used to protect the subject penetrations at SQN have been described clearly in the FSAR and reviewed repeatedly by NRC.

Several examples of NRC's review and acceptance of TVA's program have been provided herein. NRC has previously agreed that the existing design ana testing at SQN achieve the underlying purpose of the rule. It is for this reason that TVA did not submit an Appendix J exemption request for type C testing of the subject valves in the beginning of the plant life; an exemption request was submitted recently after NRC reevaluated their position and interpretation of the regulations in Appendix J.

Corrective Steps That Have Been Taken and Results Achieved TVA submitted an exemption request to resolve this issue. NRC accepted the request and granted the exemption for the valves listed in the violation.

Corrective Steps That Will Be Taken to Avoid Further Violations TVA has reviewed and compiled a list of other containment isolation valves that are not type C air tested under SQN's Appendix J program. It has been TVA's position that the original basis used to not type C air test these valves is valid and meets the intent of the Appendix J criteria. However, questions have resulted from NRC interpretations conveyed with regard to this violation and other restart containment isolation issues and again more recently, as a result of somewhat different interpretations conveyed to TVA by members of your staff. It has been concluded that outstanding questions are only of a regulatory nature; 1.e., containment integrity is assured, and no technical questions or safety issues are involved. Because of the apparent differences in interpretation, TVA will be requesting a TVA/NRC management

t 0 4

meeting to discuss and establish a consistent definition arti interpretation of, the requirements of 10 CFR 50, Appendix J. The results of this meeting will determine if any additional actions are necessary to ensure continued compliance with Appendix J requirements.

Date When Full Compliance Will Be Achieved ,

SQN is in full compliance.

e

_ . _ . . _ _ _ , , ,.- __