A05804, Responds to NRC Re Violations Noted in Insp Rept 50-213/86-08.Corrective Actions:Util Submitted Request for Schedular Exemption from Requirements of 10CFR50,App J, Pending Resolution of Integrated Safety Assessment 1.03

Responds to NRC Re Violations Noted in Insp Rept 50-213/86-08.Corrective Actions:Util Submitted Request for Schedular Exemption from Requirements of 10CFR50,App J, Pending Resolution of Integrated Safety Assessment 1.03

ML20206S480
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/25/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A05804, NUDOCS 8607070364
Download: ML20206S480 (5)

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CONNECTICUT YANKEE ATOMIC POWER COMPANY )

l B E R L I N, CONNECTICUT P o BOX 270 HARTFORD, CONNECTICUT 06141-0270 TELEPHONE 203 4 65-5000 June 25, 1986 Docket No. 50-213 A05804 Mr. Stewart D. Ebneter, Director Division of Reactor Safety United States Nuclear Regulatory Commission Region 1 631 Park Avenu2 King of Prussia, Pennsylvania 19406 Re f erences : (1) S. D. Ebneter letter to J. F. Opeka, dated May 22, 1986, transmitting Inspection No. 50-213/86-08.

(2) J. F. Opeka letter to C. I. Grimes dated March 12, 1986.

(3) W. G. Counsil letter to D. M. Crutchfield, dated January 5, 1983.

(4) D. G. Eisenhut letter to W. G. Counsil, dated April 5, 1984.

(5) W. G. Counsil letter to D. M. Crutchfield, dated August 18, 1982.

(6) D. M. Crutchfield letter to W. G. Counsil, dated December 13, 1982.

Gentlemen:

Haddam Neck Plant Response to I&E Inspection No. 50-213/86-08 Pursuant to the provisions of Section 2.201 (" Notice of Violation")

and Appendix C (Enforcement Policy) of the NRC's Rules of Practice (10 CFR 2), this report is submitted in reply to Reference (1), which informed Connecticut Yankee Atomic Power Company (CYAPCO) of vio-lations which were identified during a routine inspection at the Haddam Neck Plant from March 10-14, 1986. An extension of the response time from June 21, 1986 to June 25, 1986 was granted by Region I via telephone conversation on June 20, 1986.

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II DOC O TE O1

r-Alleged Violation:

Technical Specification 4.4.II. A states, " leak detection tests of the following components shall be performed locally at a pressure of not less than 40 psig, using halogen gas detection, soap bubbles, pressure decay or other methods of equivalent sensitivity... isolation valves on lines penetrating containment."

NRC Safety Evaluation report dated May 7,1982, supporting Amendment No. 49 to the Facility Operating License states , " Type C testing with water as a test medium...is acceptable only where the hydraulic test is used to demonstate a water seal at the penetration throughout the post accident period."

Contrary to the above, as of March 14, 1986, numerous isolation valves on lines penetrating containment were being tested using water as the test medium when the purpose of the test was not to demonstrate a water seal at the penetration. Further, this testing has not been shown to have sensitivity equivalent to the approved test methods.

This is a Severity Level IV Violation.

Response :

CYAPC0 currently tests certain penetrations using the water collection method. This method complies with that portion of Technical Specifi-cation 4.4 which permits the use of test methods other the those specifically enumerated in the Technical Specification. The intent of the Technical Specification is to assure that local leakage can be detected. The water collection method, in f act, permits not only the detection but the quantification of leakage. In contrast, the soap bubble method of leak detection does not permit the quantification of le akage. CYAPCO maintains that the method used does indeed accomplish the intent of the Technical Specification. Since the Technical Speci-fication permits the use of alternative leakage testing methods, no approval of such usage is required by the NRC Staf f prior to imple-mentation of an alternative test method. On this basis, CYAPCO maintains that local leak rate testing at the Haddam Neck Plant is conducted in accordance with the Technical Specifications.

Inspection Report No. 50-213/86-08 references an NRC Safety Evaluation Report (SER) dated May 7, 1982 to support the Notice of Violation.

That SER, supporting Amendment No. 49 to the Facility Operating License states, " Type C testing with water as a test medium...is acceptable only where the hydraulic test is used to demonstrate a water seal at the penetration throughout the test accident period."

In response to that SER, in a letter f rom W. G. Counsil to D. M.

Crutchfield dated January 5, 1983 (Reference 3), CYPACO concluded that a re-evaluation to determine the presence of a water seal would be required prior to implementation of any required modifications.

CYAPCO also concluded that there was a need to integrate any modifi-cations with the ultimate outcome of the SEP review.

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• In a letter from D. G. Eisenhut to W. G. Counsil dated April 5,1984 (Reference 4), the Staff approved deferral of the implementation of the modifications identified in Amendment No. 49- because of the

"... interrelationship of the Appendix J, Appendix A and seismic ev aluations , and the existing penetration leak testing...". This deferral was approved pending resolution of policy and programmatic issues related to the implementation of the Integrated Safety Assessment Program (ISAP). The NRC subsequently determined that this issue would te reviewed as part of ISAP Topic 1.03, " Containment Pene trations" . That review is ongoing.

, This position is further supported by the results of an inspection conducted in July 1984 (reference Inspection Report No. 84-13).

^

During the inspection, NRC Region I personnel reviewed documents related to local leak rate testing at the Haddam Neck Plant. These documents included Technical Specification 4.4. The documents were reviewed to determine compliance with the regulatory requirements of Appendix J to 10 CFR 50, Technical Specifications, applicable industry standards and station administrative guidelines. The documents were also reviewed against a number of previously identified NRC unresolved items to determine progress made and/or compliance achieved. The inspector held discussions with the CYAPC0 personnel regarding test methods, the documentation of test results, and repair and retesting following f ailed tests.

The Region I personnel determined that documents reviewed were in general conformance with the regulatory requirements of Appendix J to 10 CFR 50 and applicable industry standards. The inspectors noted ,

that CYAPCO was performing local leak rate testing with methods and l under test conditions not approved through NRC regulations and/or technical positions , e.g. , water collection testing. The inspectors indicated they were aware this item had been identified during previous NRC inspections of local leak rate testing activities and was in the process of licensee evaluation and NRR SEP/ISAP review. The inspection report concluded that no unacceptable conditions were identified.

Pending final resolution of ISAP Topic 1.03, " Containment Pene-trations", Connecticut Yankee submitted an exemption request for schedular exemption from the requirements of 10 CFR 50, Appendix J to allow liquid collection testing (Reference 2) .

Based on the above, CYAPCO maintains that this item does not constitute a violation.

Alleged Violation:

Technical Specification 1.8 states, " Containment integrity shall exist when: ... All penetrations required to be closed during accident conditions are.. . closed by manual valves.. ."

r Technical Specification 3.11.B states, " containment integrity shall be maintained whenever the reactor coolant system is above 300 psig and 200 F..."

Contrary to the above, on January 7, March 7 and November 15, 1985, valve SA-V-413, a designated locked closed manual containment isolation valve, was opened to perform a surveillance test when containment integrity was required.

This is a Severity Level IV Violation.

Response

CYAPC0 agrees that the opening of SA-V-413, when containment integrity was required, is a violation. A Technical Specification change will be submitted by August 29, 1986 proposing to open SA-V-413 under administrative controls. SA-V-413 has been red tagged to prevent it from being opened until NRC approval is obtained.

The containment building is equipped with a continuous monitoring system (CMS). The purpose of the CMS is to provide an indication of any leaks that develop in the containment boundary during plant operation. The use of the CMS is described in the Facility Description and Safety Analysis (FDSA), Section 3.5.3 "Continous Leak Te s t " . The containment is kept at a positive pressure during plant operation. The containment weight of air is then monitored for any trends that indicate excessive leakage.

As stated in the FDSA, when the containment air pressure decreases to a prescribed limit , air is charged into containment. This practice serves two purposes: 1. A positive pressure is maintained for leakage monitoring; 2. The addition of air verifies that the instruments respond to a change. SA-V-413 must be opened to charge air into containment. The Technical Specifications do not contain a provision to open SA-V-413.

Alleged Violation:

10 CFR 50.59(b) states, in part, ".. . records shall include a written safety evaluation which provides the bases for the determination that the change, test or equipment does not involve an unreviewed safety question."

Contrary to the above, valves Ei-MOV-31 and SA-V-413 were designated as containment isolation valves for penetrations P-80 and P-62 without -

the required safety evaluation being performed to determine that no unreviewed safety questions exists as a result of the change.

This is a Severity Level IV Violation.

A

Response :

CYAPCO did not violate the 10 CFR 50.59(b) safety evaluation requirement. The basis for this position is that the containment boundaries were not changed.

The use of SA-V-413 as a containment isolation valve for P-62 dates back to preoperation design and testing. The design requirement does not specifically state that two check valves in series are required for containment isolation. SA-V-413 has always been the containment isolation valve for P-62 by design. Therefore, there was no design change .

The plant design change to add an auxiliary containment spray line f rom the fire system was approved in December 1967. The line utilizes containment penetration P-80. The line has a check valve located inside containment and a motor-operated valve (MOV-31) located outside containment. The use of MOV-31 as a containment isolation valve meets design requirements. A review of procedures showed that MOV-31 has always been tested as the conts.inment isolation valve for P-80.

Our position on this matter is further supported by correspondence on SEP Topic VI-4, " Containment Isolation System". By letter dated August 18, 1982 f rom W. G. Counsil to D. M. Crutchfield (Reference 5),

in response to an NRC request, CYAPCO provided a list of all con-tainment penetrations along with the isolation provisions for each penetration. Both SA-V-413 and MOV-31 were designated as containment isolation valves in that submittal. Furthermore, in Reference (6),

the Staff explicitly approved the isolation provisions for penetration P-80 noting that those provisions included "...a normally closed, remote manual motor operated valve (MOV 31) . ..". That safety evalu-ation also noted that the isolation provisions for penetration P-62 included two locked, closed valves outside containment, one of those being SA-V-413.

Based on the above information, CYAPC0 contends that this is not a violation.

We trust that this information satisfies your concerns. in this matter.

However, if you have any further questions or concerns, we remain available to discues them with you.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY

%.F h

(__,) J. F. dgbka Senior Vice President

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