B12136, Forwards Revised Pages to Attachments 2 & 3 of Re 10CFR50,App J Exemption Request Concerning Testing of Containment Isolation Valve in Reverse Direction & Addition of Penetration Requiring Schedular Exemption

Forwards Revised Pages to Attachments 2 & 3 of Re 10CFR50,App J Exemption Request Concerning Testing of Containment Isolation Valve in Reverse Direction & Addition of Penetration Requiring Schedular Exemption

ML20211Q163
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/15/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Charemagne Grimes Office of Nuclear Reactor Regulation
References
B12136, NUDOCS 8607240170
Download: ML20211Q163 (9)

Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. C O N N E C TICUT P.o pox 270 HARTFORD CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 July 15,1986 Docket No. 50-213 B12136 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

(1) 3. F. Opeka letter to C. I. Grimes, "10CFR50, Appendix 3 -

Request for Exemption," dated March 12,1986.

Gentlemen:

Haddam Neck Plant 10CFR50, Appendix 3 Revision 1 to Request for Exemption Connecticut Yankee Atomic Power Company (CYAPCO) recently completed a comprehensive review of the status of the Haddam Neck Plant's compliance with the requirements of Appendix 3. The results of this review were documented in Reference (1). Also included in that letter were requests for several exemptions from the requirements of 10CFR50, Appendix 3. Subsequently, two revisions to our submittal have been identified and are discussed below.

The first revision is the identification by CYAPCO of a containment isolation valve that is tested in the reverse direction but was not listed as such in Reference (1). That valve is CH-RV-332 in the Reactor Coolant Pump seal water return penetration, P-7. Section 2.2.1 of Attachment 2 to Reference (1) should be revised to include information with regard to valve CH-RV-332. The justification for exemption contained in Section 2.3.2 of Attachment 2 Reference (1) also applies to this valve.

The second revision is the identification by CYAPCO of an additional penetration (P-3) requiring a schedular exemption from the requirements of Section Il.H of Appendix 3. The attached exemption request and justification for exemption should be included in Section 2.1.2 of Attachment 2 to Reference (1).

Attached are revised pages which should replace the indicated pages of

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Attachments 2 and 3 to Reference (1).

The conclusions with respect to 10CFR50.12(a) discussed in our previous submittal (Reference (1)) remain unchanged.

8607240170 860715 PDR ADOCK 00000213 aJd p PDR

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2-If you have any, questions on this material, please feel free to contact my staff.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY A ICA

3. F. OpWF L Senior Vice President n

m 2.0 SCHEDULAR EXEMPTIONS REQUESTED 2.1 Exemption From the Requirements of Section II.H of Appendix 3 2.1.1 Schedular Exemption Requested Section II.H of 10 CFR 50, Appendix 3 requires that Type C tests be performed for containment isolation valves that:

"1. Provide a direct connection between the inside and outside atmospheres of the primary reactor containment under normal operation, such as purge and ventilation, vacuum relief, and instrument valves;

2. Are required to close automatically upon receipt of a containment isolation signal in response to controls intended to effect containment isolation;

3. Are required to operate intermittently under postaccident conditions; and

4. Are in main steam and feedwater piping and other systems which penetrate containment of direct-cycle boiling water power reactors."

CYAPCO requests a schedular exemption from the Type C testing requirements of Section II.H. of Appendix 3 for the reactor coolant charging (P-8),

containment sump to residual heat removal (P-73), and high pressure safety injection (P-3) penetrations.

1 2.1.2 Justification for Exemption i 2.1.2.1 Penetration P-8:

1 CYAPCO had previously requested an exemption from the Type C testing requirements of Appendix 3 for the reactor coolant charging (P-8) penetration.

This previous request was based on the seismic design of system piping inside containment and the proposed seismic qualification of system piping from the isolation valves of Penetration P-3 to its water source. Subsequent evaluations determined such qualification to be a lengthy and costly effort; therefore, CYAPCO intends to modify Penetration P-8 to permit Type C testing. In the j interim, although Penetration P-8 is not currently Type C tested, the isolation valves in this penetration are exposed to water subjected to containment pressure through the vented reactor coolant system during the CILRT.

! The valves are exposed to containment pressure in the direction of accident

pressure with the backside of the valves depressurized. Further, the portion of

(' the system outside containment is checked for liquid leakage in accordance with Administrative Technical Specification 3.14; system leakage is accounted for in offsite dose consequence calculations, per 10CFR100. Such leak testing provides additional assurance that the potential for significant containment atmosphere leakage through this penetration is minimized.

2-7 Letter No. B12136 July 15,1986

s CYAPCO believes a schedular exemption from the Type C testing requirements of Appendix 3 is justified based on the above information as well as the long lead time for equipment needed to modify this penetration, the level of design and analysis required, and the need to integrate these modifications with the ultimate resolution of the SEP review of containment isolation valve configura-tions per 10CFR50, Appendix A. This approach is consistent with the ALARA philosophy in that it avoids repetitive modifications to the same penetration.

The ultimate resolution of this issue will be accomplished within the framework of the Haddam Neck Plant ISAP.

2.1.2.2 Penetration P-73:

The contamment sump to RHR pump suction line (P-73) penetration has not previously been Type C tested. It is isolated by three normally closed valves.

The motor operated valve RH-MOV-22 and manual valve RH-V-SOSA are located outside containment and isolate the RHR system, which is operating during the CILRT; the backside of these valves is, therefore, not ventable during the CILRT. Appendix 3 does not require that these valves be tested since the RHR system will be filled with water and operating in the post-accident condition, considering a single active failure. The RHR system, however, has an Administrative Technical Specification leakage limit of 3 liters / hour (Reference LCO 3.14). This leakage limit encompasses the makeup, seal injection / return, and fill portions of the charging system as well. Any leakage through these systems is accounted for in offsite dose consequence calculations per 10CFR100.

The third isolation valve of Penetration P-73 is a check valve CC-CV-802, which has not been local leak rate tested previously. This valve isolates the component cooling water surge tank relief line. Should this valve fall to isolate, relief valve CC-RV-777 would prevent leakage. There are effectively two leakage barriers in this portion of the piping. The possibility of an unisolated leak of containment atmosphere is, therefore, not credible. During a postulated accident reactor coolant and safety injection water will fill the lower elevation of the containment and containment sump for the duration of the long-term cooling phase. Therefore, a 30-day water seal exists for this portion of the penetration.

This penetration will be water tested in the future once physical modifications have been completed to permit such testing. CYAPCO believes a schedular exemption from the Type C testing requirements of Appendix 3 is justified for valve CC-CV-802 based on the above information as well as the long lead time for equipment needed to modify this penetration, the level of design and analysis required, and the need to integrate these modifications with the ultimate i resolution of the SEP review of containment isolation valve configurations per 10CFR50, Appendix A. This approach is consistent with the ALARA philosophy in that it avoids repetitive modifications to the same penetration. The ultimate resolution of this issue will be accomplished within the framework of the Haddam Neck Plant ISAP.

2.1.2.3 Penetration P-3:

Valve SI-V-860 is a 3" locked close manual gate valve that isolates the cavity fill line. The cavity fill line branches o'ff the high pressure safety injection header i 2-8 Letter No. B12136 July 15,1986

< s inside containment. This valve is not LLRT tested but is tested during the ILRT in the accident direction with air on the containment side of the valve. The downstream side of the valve is covered with liquid but vented during the ILRT.

This is consistent with expected post-LOCA conditions because valve SI-V-860 is in a vertical run with liquid trapped above it due to testing of the high pressure safety injection system. .

The recent PRA analysis of this penetration resulted in a total risk (due to non-compliance with Appendix 3) of 0.9 man-rem over the life of the plant. Of the '

total risk, 0.3 man-rem is due to valve SI-V-860 not being tested. It is assumed -

that SI-V-860 leaks 5% of the containment air volume per day, which is greater

, than twice the worst measured containment isolation valve as-found leakage at t the plant. Clearly, the risk due to this untested valve is very small. Since the

ILRT does leak test this valve, the actual risk will be much less than 0.3 man-rem.

CYAPCO believes a schedular exemption from the Type C testing requirements of Appendix 3 is justified based on the above information as well as the long lead time for equipment needed to modify this penetration, the level of design and analysis required, and the need to integrate these modifications with the

ultimate resolution of the SEP review of containment isolation valve

! configurations per 10CFR50, Appendix A. This approach is consistent with the l ALARA philosophy in that it avoids repetitive modifications to the same penetration. The ultimate resolution of this issue will be accomplished within the framework of the Haddam Neck Plant ISAP.

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i 2-8a Letter No. Bi2136 July 15,1986

2.2 Exemption from the Requirements of Section III.C.1 of Appendix 3 2.2.1 Exemption Requested Section III.C.1 of Appendix 3 to 10 CFR 50 states:

" 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 function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative re sults."

CYAPCO requests an exemption from the above requirement so that certain valves in the following penetrations may be tested in the reverse direction:

o P-7 RCP seal water return; l o P-33 refueling cavity purification; o P-78 pressurizer relief tank drain; and A schedular exemption is requested to allow the reverse direction testing of valve PU-V-242 in Penetration P-33, DH-TV-554 in Penetration P-78, and CH-RV-332 in Penetration P-7.

In previous correspondence with the NRC staff, CYAPCO addressed the issue of reverse direction testing of certain valves. The following discussion reflects the most recent status of this issue. ' In Reference 1, the NRC Staff found CYAPCO's proposals for reverse direction testing of certain isolation valves to be acceptable, with the exception of valve VH-V-507 (Penetration P-71), which must be tested in the direction of the post-accident LOCA containment pressure. As indicated in Reference 2, Penetration P-71 for the primary vent header has been modified to allow testing in the direction of post-LOCA containment pressure. Additionally, for Penetration P-62 (Service Air), manual valve SA-V-413 is torqued closed to 133 inch-lb handwheel torque, and proce-dures were revised during the 1984 refueling outage so that valve SA-V-413 is in compliance with reverse direction testing criteria. Currently, valve CC-V-884 in Penetration P-63 (neutron shield fill) is tested in the reverse direction. Since this valve is a manual Grinnel weir-type diaphragm valve which has symmetric internals with a single seating surface, the valve would tend to unseat equally with pressure applied from either direction. Plant procedures require stem and body-to-bonnett flange leakage to be added to through-valve leakage. Hence, reverse direction testing is acceptable and in compliance with Appendix 3; no exemption is required to test this penetration in the reverse direction.

2.2.2 Justification for Exemption The refueling cavity purification (P-33) penetration is isolated by two contain-ment isolation valves. Valve PU-V-242A is Type C tested in the direction of accident pressure; valve PU-V-242 is tested in the reverse direction. The pressurizer relief tank drain (P-78) penetration is isolated by valves DT-TV-1844 and DH-TV-554. Valve DT-TV-1844 is tested in the direction of accident 2-9 Letter No. B12136 July 15,1986 .

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pressure; valve DH-TV-554 is tested in the reverse direction. CYAPCO requests l a temporary exemption to permit continued reverse direction testing of valves PU-V-242 and DH-TV-554 until modifications can be made to permit testing in the direction of accident pressure. Valves PU-V-242 and DH-TV-554 are tested at the proper direction during the CILRT. As previously concluded by the NRC Staff (Reference 3), although the CILRT is not performed as frequently as Type C leak rate tests, the CILRT does provide an indication of overall containment leaktightness, including penetrations.

Valve CH-11V-332 in Penetration P-7 has a seating force 3.5 times greater than the force due to containment accident pressure of 40 psig. This ensures that the leak geometry is dominated by the seating force instead of the test direction.

This valve is also bench tested once every five years for set pressure and leakage per Procedure PM 9.5-114. It was so tested during the 1986 outage in the accident direction and found to have no leakage.

CYAPCO believes a schedular exemption to permit reverse direction testing of valves DH-TV-554, PU-V-242, and CH-RV-332 is justified based on the above information as well as the level of design and analysis required to accomplish modifications to Penetrations P-33, P-78, and P-7 to permit testing in the l direction of accident pressure. The ultimate resolution of this issue will be accomplished within the framework of the Haddam Neck Plant ISAP.

2.2.3 References

1. D.M. Crutchfield Letter to W.G. Counsit, dated May 7,1982, " Appendix 3 Requirements (Containment Leakage Testing)."

) 2. W.G. Counsil letter to D.M. Crutchfield, dated August 16, 1983, "10 CFR 50, Appendix 3 Requirements, SEP Topic VI-4, Containment Isolation System."

3. D. G. Eisenhut letter to W. G. Counsil, dated April 5,1984, " Expanded Integrated Assessments for Haddam Neck and Millstone Unit No.1."

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2-10 Letter No. B12136 July 15,1986

Piga 1 cf 8 Letter No. B12136.

CONNECTICUT YANKEE APPEr4 DIX J TESTING STATUS July 15, 1986 .

TESTED LEACAGE BARRIER

• PENETRATION PROCEDURE NUNBER DESCRIPTION DESIGNATION LOCATION TYPE TEST EXENPTI0tt SUR P-A Personrel Hatch -

I GS OK NO-1 5.1 - 62 0 GS OK NO-1 Equalizing Valve I GL OK NO-1 Equalizing Valve O GL OK NO-1 P-B Electrical Penetrations -

I GS OK NO 5.7 - 100 0 GS OK NO P-C Equipment Hatch -

I GS OK NO 5.7 - 48 0 GS OK NO P-D Dome Vent Flange (Top) -

I GS OK No 5.7 - 50 0 GS OK NO P-E Dome Penetration Flange (Side) -

I GS OK No 5.7 - 49 0 GS OK NO P-F-A, B Equipment Hatch Penetrations -

I GS OK No 5.7 - 113 0 GS OK NO P-1 Residual Heat Removal - - -

OK NO-1 -

P-2 Residual Heat Removal - - -

OK NO-1 -

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P-3 High Pressure Safety SI-CV-862 A to D S CH LIQ YES-1, 3 5.7 - 65 Inj ection SI-V-860 S GA NT YES l P-4 Pressurizer Felief Tank WG-TV-1845 I AGA OK NO-1, 4 5.7 - 23 Vent WG-A0V-558 0 AGA OK NO SS-V-984A 0 GA OK NO

• A key for the codes follows this table

Pags 2 of 8 Lettbr No. B12136 CONNECTICUT YANKEE APPENDIX J TESTING STATUS July 15, 1986 .

TESTED LEAKAGE BARRIER

• PENETRATION PROCEDURE NUMBER DESCRIPTION DESIGNATION IDCATION TYPE TEST EXEMPTION SUR P-5 Spare - -

SW OK NO-2 -

P-6 Ilydrogen and Post Accident SS-S0V-150 A, D I SGA OK NO 5.7 - 25 Sampling SS-SOV-150 B, C 0 SGA OK NO P-7 RCP Seal Water Return CH-TV-334 S AGA LIQ YES-1, 3 5.7 - 60 CH-RV-332 S RV LIQ (ES REV YES l CH-CV-262 S CH LIQ YES P-8 RCS Charging - - -

NT YES-3 -

P-9 Hydrogen and Post Accident SS-SOV-151 A, D I SGA OK NO 5.7 - 26 Sampling SS-SOV-151 B, C 0 SGA OK NO P-10 RCS Letdown LD-FCV-202 to 204 S AGL LIQ YES-1, 3 5.7 - 28 P-11A Loop & Pressurizer Drain SS-TV-950 S AGL LIQ YES-3 5.7 - 29 Sample HP YES P-llB Pressurizer Steam Sample SS-TV-955 S AGL LIQ YES-3 5.7 - 29 HP YES P-llc Pressurizer Liquid Sample SS-TV-960 S AGL LIQ YES-3 5.7 - 29 HP YES l P-llD Loop 1 Hot Leg Sample SS-TV-965 S AGL LIQ YES-3 5.7 - 29 l llP YES l

• A key for the codes follows this table