B13224, Forwards Request for Schedular Exemption from Requirements of 10CFR50,App J,Sections III.A.6.(b),III.D.2(a) & III.D.3. Exemptions Will Provide Relief from Requirements for Penalty Type a Test Intervals During 1989 Refueling Outage

Forwards Request for Schedular Exemption from Requirements of 10CFR50,App J,Sections III.A.6.(b),III.D.2(a) & III.D.3. Exemptions Will Provide Relief from Requirements for Penalty Type a Test Intervals During 1989 Refueling Outage

ML20246B341
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/26/1989
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B13224, NUDOCS 8905090018
Download: ML20246B341 (16)

Text

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NORTHEAST UTILITIES o.nor.i Ome.. . seio n sir..i. seriin. Conn.ciicui H'ARTFORD, CONNECTICUT 06141-0270 k k 1J Z $[ M S ". (203) 665-5000 April 26, 1989 {

Docket No. 50-213 B13224  ?

Re: 10CFR50.12 i

U.S. Nuclear Regulatory Commission ,

Attention: Document Control Desk l Washington, DC 20555 Gentlemen: i Haddam Neck Plant 10CFR50. Appendix J. Reauest for Exemption In September 1987 Connecticut Yankee Atomic Power Company (CYAPC0) performed a containment integrated leak rate test (CILRT) at the Haddam Neck Plant. The results of t June 1,1988.g testing were provided to the NRC Staff in a letter dated December 2,1988,(gdocumentedinNRCResidentInspection the results of this testing require that 50-213/88-19,.

a penalty Typedated A test be performed at each plant shutdown for refueling or.approximately every 18 months, whichever occurs first. The penalty Type A test is now required to be performed by April 27, 1989. Because of the extended duration of the 1987 l refueling outage, the next refueling outage is not scheduled until l September 9, 1989. A shutdown is required to perform these tests because, in most cases, the systems must be isolated and vented. Therefore, CYAPC0 hereby submits a request for a schedular exemption from the requirements of 10CFR50, Appendix J, Sections III.A.6.(b), III.D.2.(a), and III.D.3.

These exemptions will provide temporary relief from the schedular requirements for penalty Type A test intervals and Type B and C periodic retest schedules  ;

during the 1989 refueling outage. Because CYAPCO's refueling outage is scheduled to begin on September 9, 1989, in addition to the penalty Type A testing, Type B and C periodic Appendix J required retest intervals will also be exceeded. Like Type A tests, Type B and C tests also require a plant shutdown to isolate and vent the affected systems. The request for schedular exemptions for the 1989 CYAPC0 outage is included in Attachment 1. In addi-

, tion, Attachment 2 provides a summary of the corrective actions performed l

during the 1987 refueling outage.

(1) D. B. Miller letter to W. T. Russell, "Haddam Neck Plant Containment l

Operation and Testing Report," dated June 1, 1988.

l (2) L. H. Bettenhausen letter to E. J. Mroczka, " Resident Inspection 50-213/88-19,(9/28/88-11/15/88)," dated December 2, 1988.

l 8905090o18 890426 $0 gDR ADoCK05 cog 3 1

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. 1 U.S. Nuclear Regulatory Commission-B13224/Page 2 April 26, 1989 The Commission's regulations, specifically 10CFR50.12(a), provide that exemp-tions may be granted from the regulations in.10CFR50 provided that they are ,

" authorized by law, will not present an undue risk to the. public health. and safety, and are consistent with the common defense and security."

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Based on . the -information provided in Attachments 1 and 2, CYAPC0 concludes that exemptions from the requirements of 10CFR50, Appendix.J, are justified  !

pursuant to 10CFR50.12, ; entitled " Specific Exemptions," Sections'(a)(1),

(a)(2)(ii), (a)(2)(iii), and (a)(2)(v)'in that:

o These. exemptions "will not present an undue risk to the public' health and l safety."

The proposed exemptions do not change, modify, or restrict existing plant safety limits, safety settings, systems,'or operations.

The changes do not impact the design basis of containment or modify I its response during a design basis accident.

o " Application of the regulation in. the particular circumstances is not necessary to achieve the underlying purpose of the rule."

CYAPC0's commitment to improve containment integrity over the past 21 years (as demonstrated by historically very low Type B leakages and significant efforts to reduce Type C leakages) and the current Type A penalty test schedule meets the intent of Appendix J.

o " Compliance would result in costs that are significantly in excess of those contemplated when the regulation was adopted."

Current replacement energy costs associated with a midcycle shutdown were not contemplated when the regulation was adopted, o "The exemption would provide only temporary relief from the applicable.

regulation and the licensee or applicant has made good-faith efforts to comply with the regulation." ,

These exemptions apply to the next series of Type A, B, and C tests l only.

Without the unexpected core barrel and thermal shield repairs during the previous 1987-1988 refueling outage, these exemptions would not  ;

be necessary and Type A, B, and C tests would be conducted per the '

original schedule.

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U.S. Nuclear Regulatory Commission B13224/Page 3 l April 26, 1989 '

We trust you will find this information satisfactory, and we remain available .

l to answer any questions you may have, l l

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY i

44V. A/

E. JyKroczka // l Senior Vice President '

l cc: W. T. Russell, Region I Administrator 'i A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant l

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Docket No. 50-213 B13224 l

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Attachment 1 Haddam Neck Plant i 1 i 10CFR50, Appendix J, Request for Schedular '

Exemptions From Related Type A, B, and C Test Requirements 1 )

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'1 April 1989 l

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. j U.S. Nuclear Regulatory Commission B13224/ Attachment 1/Page 1 l April 26, 1989 l i

Haddam Neck Plant )

10CFR50, Appendix J, Request for Schedular Exemotions From Related Tvoe A. B.'and C Test Requirements

'l A. Exemption Reauested i Section III.A.6.(b) of 10CFR50, App'endix J, requires that:

"If ' two consecutive periodic Type A tests fail . to meet the applicable acceptance criteria in III.A.5.(b), not withstanding the periodic retest -

schedule of III.D., a Type' A test shall be performed at each plant shutdown for refueling or approximately every 18 months, whichever occurs 3 first, until two consecutive Type A tests meet the acceptance criteria in l III.A.5.(b), after which time the retest schedule specified in III.D. may i be resumed." 1 CYAPC0 requests a schedular exemption be granted because the next sched-uled Type A penalty test will exceed.the provision of this requirement by approximately 6 months.

This exemption is necessary to prevent a midcycle shutdown and to perform )

the test during the 1989 refueling outage.

1. Evaluation CYAPC0 has reviewed the regulatory requirements concerning Type A penalty testing and is not questioning the validity of. conducting the test itself, rather, the required time frame of " . . . every ,

18 months, whichever occurs first. . . . " ,

CYAPC0 conducted a Type A penalty test on September 27,.1987, and 1 passed the "as-left" acceptance criteria. According to the provi-sions of Section III.A.6.(b), the next scheduled test should occur on April 27, 1989. CYAPC0's next refueling outage is scheduled for ,

September 9,1989, and the integrated leak rate test (ILRT) itself will not start until October 1989. The start date for the outage is .

due to the extension of the 1987 refueling outage into April of 1988 'i to repair the core barrel and thermal shield. The 1989 ILRT retest. '

date would exceed Appendix J's 18-month requirement by.approximately 6 months.  ;

Review of the 1987 Type A test results indicates that the "as-left" condition of the containment satisfactorily met the requirements of -

Appendix J. However, as in 1986, the 1987 "as-found" ILRT did not meet the acceptance requirements and was deemed a failure. 'The cause for the 1986 and 1987 "as-found" ILRT failures was due to excessive Type C leakages.  ;

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U.S. Nuclear Regulatory Commission B13224/ Attachment 1/Page 2 April 26, 1989 l

As a result, CYAPC0 has increased its efforts to minimize the number of penetrations experiencing Type C leakage and that have histori- a cally been chief contributors to "as-found" ILRT failures by modify- l ing the penetrations and/or initiating repairs. Attachment 2 l summarizes the corrective actions performed during the 1987 refuel-ing outage.

In 1989 CYAPC0 plans to conduct the fifth Type A test since 1980.

CYAPCO's commitment to improve containment integrity and the current i Type A test schedule will meet the intent of Appendix J. I

2. Justification for Exemption .

1 CYAPC0's exemption request from the requirements of 10CFR50 Appen- i dix J (III.A.6.(b)), will not result in undue risk to the health or '

safety of the public:

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a. The proposed exemptions do not change, modify, or restrict  !

l existing plant safety limits, safety settings, systems, or  ;

operations. The changes do not impact the design bases of '

containment or modify its response during a design basis l accident (DBA).

b. There are no undue adverse safety effects associated with this ,

exemption. J

3. Conclusion Based on the above information, CYAPC0 concludes that the requested schedular exemption is warranted and that the underlying purpose of the regulation would still be met.

l B. Exemotion Reouested Section III.D.2.(a) of 10CFR50, Appendix J, requires that:

" Type B tests, except tests for air locks, shall be performed during l reactor shutdown for refueling or other convenient intervals but in no l case at intervals greater than 2 years."

CYAPC0 requests a schedular exemption be granted because the next sched-uled refueling outage will exceed the provision of this requirement by approximately 2 months. Currently this testing would be required by July 18, 1989.

1 The exemption is necessary to prevent a mideycle shutdown and to perform the test during the 1989 refueling outage.

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U.S. Nuclear Regulatory Commission i B13224/ Attachment 1/Page 3 April 26, 1989 l

1. Evaluation .

1 CYAPC0 has reviewed the ~ regulatory requirements concerning Type B q l periodic testing and is not questioning the validity of conducting i the test itself, rather, the required time frame of " . . . in no case at intervals greater than 2 years. . . ."

'CYAPC0's Type B local leak rate test (LLRT) leakage has historically l

not been a source of significant "as-found" leakage (less - than  ;

I 50 lbm/ day). )

i CYAPC0 contends that our improvements in containment integrity 'and historically very low Type B leakages are sufficient to allow the 2-year test interval requirement to be exceeded by approximately 2 months and still meet the intent of Appendix J.

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2. Justification of Exemotion CYAPCO's exemption request from the requirements of 10CFR50, Appen-dix J (III.D.2.(a)), will not result in undue risk to the health or safety of the public:

a. The proposed exemptions do not change, n'odi fy, or restrict existing plant safety limits, safety settings,, or- operations.

The changes do not impact the design basis of containment or modify its response during a DBA. 4

b. There are no undue adverse safety affects associated with this exemption.

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3. Conclusion Based on the above information, CYAPC0 concludes that the requested exemption is warranted and that the underlying . purpose of the regulation would still be met.

C. Exemption Reauested-l i

Section III.D.3 of 10CFR50, Appendix J, requires that:

" Type C tests shall be performed during each reactor shutdown for refuel-  :

ing but in.no case at intervals greater than 2 years."  :

CYAPC0 requests a schedular exemption be granted because the next sched- l uled refueling outage will exceed the provision of this requirement by approximately 2 months. Currently this testing would . be' required by ~;

July 18, 1989.  :

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1 U.S. Nuclear Regulatory Commission 1 813224/ Attachment 1/Page 4

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April 26, 1989 .

The exemption is necessary to prevent a midcycle shutdown and to perform the test during the 1989 refueling outage.' 4

1. Evaluatio,1 CYAPC0 has reviewed ~ the regulatory requirements concerning Type C )

periodic testing and -is not questioning the v:lidity of conducting .  !

the test' itself, rather, the required time trame of ". . . in no case at intervals greater than 2 years. . . . "

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CYAPC0's Type C LLRT test program continues to undergo significant changes and improvements. In 1987 CYAPC0 increased ' efforts to minimize Type C leakage by improving test procedures and methods, conducting supplemental LLRTS on penetrations that have been poor.

performers, making modifications to selected penetrations, and pursuing an enhanced. testing and maintenance. program to identify, test, repair, and reduce containment penetration leakage. Attach-ment 2 summarizes the corrective actions performed.

CYAPC0 contends that these efforts to reduce Type C . leakage are sufficient to allow the 2-year test interval' to be exceeded by .

approximately 2 months and still meet the intent of Appendix v. '

2. Justification of Exemption f

1 CYAPC0's exemption requttt from requirements of 10CFR50, Appendix J .i (III.D.3), will not result in undue risk to the health or safety of the public:

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a. The proposed exemptions do not change, modify, or restrict i existing plant safety limits, safety settings, systems, or i operations. The changes do not impact the design basis of  !

containment or modify its response during a DBA.

b. There are no undue adverse safety effects associated with this exemption. 1

3. Conclusion l

Based on the above information, CYAPC0 concludes that the requested.

exemption is warranted and that the underlying purpose of the regulation would still be met.

Docket No.'50-213 B13224 Attachment 2 Haddam Neck Plant l

-10CFR50, Appendix J Summary of Corrective Actions I

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U.S. Nuclear Regulatory Commission B13224/ Attachment 2/Page 1 i April 26, 1989 Haddam Neck Plant 10CFR50, Appendix J Summary of Corrective Actions A. CYAPC0 Tvoe B and C LLRT (1987-1988) i The following is a summary of corrective actions performed on the con- l tainment penetrations with significant (greater than 50 lbm/ day) "as- {

found" leak rates. The corrective actions for containment penetrations I with significant leak rates were reviewed for adequacy and potential additional actions. When required, the additional actions consisted of corrective maintenance, modification, and additional testing.

1. P-3: Hich-Pressure Safety In.iection 1

The penetration has four 3-inch, 1500-pound, 316 stainless steel l check valves. The initial "as-found" leak rate was 228.72 lbm/ day. 4 SI-CV-8628 was leaking excessively due to the valve not seating I properly. The cause of the failure was due to hinge wear. Correc- l tive maintenance included replacing the valve disc, . disc hinge, and '

disc shaft. While pressurizing for the 1987 ILRT, SI-CV-862A leaked excessively and was isolated. Subsequent to the test, an inspection i revealed foreign material wedged between the valve seat and disc.

The valve was cleaned and the "as-left" leak rate was satisfactory.

2. P-7: Reactor Coolant Pumo Seal Water Return The penetration has three containment isolation valves in parallel:

an air-operated valve (CH-TV-334) in parallel with Relief Valve CH-RV-332 and Check Valve CH-CV-262. The initial "as-found" leak rate was 45.750 lbm/ day. Penetration P-7 was modified during the 1987 outage. The modification eliminated CH-TV-334. CH-RV-332, and CH-CV-262 as containment isolation valves. The new design included the installation of two new air-operated containment isolation valves (CH-TV-240 and CH-TV-241) located outside of containment. The "as-left" leak test on CH-TV-240 and CH-TV-241 proved satisfactory.

3. P-30: Containment Space heatina Suoolv The penetration contained two 6-inch containment isolation check valves (HS-CV-295 ad HS-CV-295A) located in series. The penetration "as-found" leak test exceeded Technical Specification acceptance criteria with a measured leak rate of 20196.84 lbm/ day. Penetra-tion P-30 was modified during the 1987 outage. The modification eliminated HS-CV-295 and HS-CV-295A as containment isolation valves.

The new design included removing HS-CV-295 from the system and installing double 0-ring blank flanges in its place. The internals

U.S. Nuclear Regulatory Commission B13224/ Attachment 2/Page 2 April 26, 1989 were removed from HS-CV-295A since the valve was no longer required. l Two new air-operated ball valves (HS-TV-380 and HS-TV-381) were j installed in place of HS-CV-295 and HS-CV-295A. HS-TV-380 and HS-TV-381 are located in series and serve as the containment isola-tion valves for P-30. The "as-left" leak test was satisfactory.

4. P-38: Component Coolina Water to Reactor Coolant Pumo Thermal Barrier The penetration consisted of one containment isolation check valve (CC-CV-721) located inside containment. The valve's "as-found" leakage exceeded Technical Specification acceptance criteria with a measured leak rate of 2027.8 lbm/ day. Penetration P-30 was modified during the 1987 outage. The modification included replacing CC-CV-721, a piston check valve, with a swing check valve and eliminated it as a containment isolation valve. The new design consists of two newly installed air-operated Y-globe containment isolation valves (CC-TV-912 and CC-TV-913) in series, located outside containment. The "as-left" leak test on the modification was satisfactory.

5. P-66: Component Coolina Water to Drain Cooler The "as-found" leak rate for the penetration was 831.6 lbm/ day which exceeded Technical Specification acceptance criteria. The following preventive maintenance was performed. The containment isolation valve (CC-CV-731) was disassembled and inspected. The valve appeared in good condition with no apparent failure cause. The valve seat was ground and lapped. A retest was performed, and the penetration failed a second time. After further investigation, the boundary test valves were suspected leaking, As a result, the boundary test valves were tightened down, and a third test was performed. The retest was satisfactory.

6. P-75: Number 3 Reactor Coolant Pumo Seal Water Supply The "as-found" leak rate for the penetration exceeded Technical I Specification acceptance criteria. The penetration consists of one l check valve (CH-CV-305C) inside containment. The valve was replaced with a new check valve and the retest was satisfactory. In 1986 this check valve leaked excessively and was replaced. Additional 4 action will be reviewed to assess whether supplemental testing will i be performed.

7. P-76: Number 2 Reactor Coolant Pumo Seal Water Supply The "as-found" leak rate for the penetration was 101.58 lbm/ day.

The penetration consists of one containment isolation check valve (CH-CV-305B) inside containment. The failure was due to the disc

a U.S. Nuclear Regulatory Commission B13224/ Attachment 2/Page 3 April 26, 1989' q i

sticking slightly open. The valve was replaced with a new valve, and the retest was satisfactory. During the 1987 ILRT, the new -

valve leaked excessively and had to be isolated. The new valve was  !

disassembled, the plug was machined, the seat was ground and lapped, and the disc was lapped. The retest was satisfactory.

8. P-77: Number i Reactor Coolant Pumo Seal Water Sucoly The "as-found" leak rate for the penetration which consists of one i containment isolation valve (CH-CV-305A) was excessive. The failure  :

was due to normal wear on the seat and disc. The valve was repaired (seat and disc were lapped), and the retest was satisfactory.

B. Additional Penetration Modification?

Based on 1986 corrective and preventive action programs, the following j penetrations, that did not fail their respective leak tests, were modi- 1 fied during the 1987 outage.

1. P-10: Letdown Penetration P-10 was modified in 1987. The "as-found" leak rate test was conducted on the old containment isolation boundary which contained three containment isolation valves in parallel (LD-A0V-202, LD-A0V-203, and LD-A0V-204)'. The test was satisfac-tory. The modification included the installation of a new contain-ment isolation valve (LD-TV-230) in series with LD-A0V-202, LD-A0V-203, and LD-A0V-204. The "as-left" test was also satisfac-tory.

2. P-23B: Closed Bulb Leak Monitorina: P-23C: Dead Weicht Tester: -

P-23D: Air Monitor Purae c

These penetrations were modified in 1987. The system piping for each penetration was cut both inside and outside containment near the containment wall. A socket-welded pipe cap was welded to the pipe extending outside containment. These penetrations are now no longer required to be locally leak-tested.

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3. P-41: Looo Drain Header Penetration P-41 was modified in 1987. The "as-found" leak test was performed.on the old containment isolation boundary which consisted i of three containment isolation valves--DH-RV-1847 in parallel with Series Valves DH-TV-1841 and DH-TV-1847--all located outside cor - 2 tainment. The "as-found" test was satisfactory. The modification eliminated DH-RV-1847 as' a containment isolation valve by relocating the valve inside containment. The "as-left" test was satisfactory. ,

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U.S. Nuclear Regulatory Commission l 813224/ Attachment 2/Page 4 l April 26, 1989

4. P-60: Component Coolina Water to Neutron Shield Tank Cooler Penetration P-60 was modified in 1987. The "as-found" leak rate l test was conducted on the old containment isolation boundary which I consisted of one containment isolation check valve (CC-CV-885). The "as-found" test was satisfactory. The modification removed CC-CV-885 from the system which eliminated it as a containment isolation valve. The new design consists of two new air-operated containment isolation ball valves (CC-TV-917 and CC-TV-920) located in series outside the containment. The "as-left" test was satisfac-tory.

5. P-31. 35, 36, 37, 57, and 728: Soare Penetrations These are spare penetrations. Each penetration had new welds placed 1 on the isolation caps during the 1987 refueling outage.

C. 1987 Supplemental LLRTs The ILRT was completed on September 27, 1987, passing the "as-left" acceptance criteria.

Subsequent to the ILRT, thermal shield and core barrel repair efforts extended the outage into April 1988. Due to the length of the outage, several Type C local leak test surveillance were selected for retest (supplemental tests) to verify the integrity of penetrations that have historically been poor performers.

The supplemental test results listed below were incorporated into and l maintained in the " running totals" for the operating cycle.

Supplemental Test Results Table Penetration )

Result Valve (lb/ day)

Test (Maximum ,

Penetration Penetration Test Result Pathway l Number Description Valve ID Date (lb/dav) Leakage) Notes J Safety SI-CV-862A l

3 01/25/88 0 11.85 Injection l SI-CV-8628 0 i System SI-CV-862C 11.85 SI-CV-8020 0 64 Air Monitor VS-TV-1848 01/27/88 0.2997 0.2997 Sample From VS-S0V-12-1 0.0658 Containment

U.S. Nuclear Regulatory Commission B13224/ Attachment 2/Page 5 April 26, 1989 l

Penetration 1 Result  !

Valve (lb/ day)

Test (Maximum Penetration Penetration Test Result Pathway Number Description Valve ID Date (lb/ day) Leakaae) Notes 65 Air Monitor VS-CV-1103 01/27/88 18.97 18.97 (1) 1 Sample to VS-CV-1104 0 Containment 66 Containment CC-CV-731 01/25/88 0.29 0.29 Cooling Water to Drain Cooler 67 Containment CC-FCV-611 01/25/88 0 0 Cooling Water From Drain Cooler  ;

68 Primary PW-CV-140 02/08/88 0 0.824 (2)

Water to l Containment i 71 Primary VH-V-522 01/26/88 122.59 429.08 (3)

Vent Header VH-V-525 429.08 80 Auxiliary RH-MOV-31 02/14/88 1236.54 1236.54 (4) l Containment i Spray From Fire System Notel:

(1) Penetration P-65, Air Monitoring Supply System, has two Lunkenheimer Model No. 863,1-inch check valves (VS-CV-1103 and VS-CV-1104) in series located at a low point in the system. P-65 was originally tested on July 29,1987, with the VS-CV-1104 measured leakage of 41.28 lb/ day, and VS-CV-1103 of 0.0 lb/ day. VS-CV-1104 was disassembled and a buildup of dust and sludge was found on the valve seat causing the check valve to seat improperly. The valve was repaired and retested satisfactory, obviating further testing. The supplemental test results for VS-CV-1103 were inconsistent, and the valve was disassembled to identify root cause.

As with VC-CV-1104, dust and sludge were found on the valve seat.

VS-CV-1103 was cleaned and satisfactorily retested with a measured leak

U.S. Nuclear Regulatory Commission B13224/ Attachment 2/Page 6 April 26, 1989 rate of 0.623 lbm/ day. CYAPC0 is reviewing the design for corrective action.

(2) Penetration P-68, Primary Water to Containment, has two 2-inch check valves (PW-CV-139 and PW-CV-140) in series. PW-CV-139 was not tested due to core barrel repairs; therefore, the reported penetration running summary is listed as 0.824 lb/ day. This is the previous maximum pathway result conducted on August 6, 1987.

(3) Penetration P-71, Primary Vent Header, consists of two 2-inch manual Conval angle globe stop valves located in series. P-71 was originally tested on July 21, 1987, with a measured leak rate of 0.1644 lbm/ day. The test proved satisfactory thereby obviating further testing. The supple-mental test failed to meet the ISI Acceptance Criteria and a Plant Infor-mation Report was issued (PIR 88-17). The running total was calculated and did not exceed the Technical Specification limit of .6 La (650 lbm/ day) as evidenced in the table below:

Leakage in ibm / day Description at 40 osia Appendix J Running Total, Total "As-Left" Leakage as of 01/01/88 84.04 Supplemental Containment Air Monitor Sample (P-65) 18.97 Supplemental Primary Vent Header (P-71) 429.08 Total "As-Found" Plus Supplemental Tests 532.09 Both valvet (VH-V-522 and VH-V-523) were disassembled and inspected. Dirt and grime (sludge) were discovered on the seat and disc. The seats and discs appeared to be in good condition. It is postulated that during the venting normal operation that sediment in the vent pot and system piping entered the vent header line and became lodged in the disc / seat area.

Results from the July 2, 1987 "as-found" test indicate that at no time during the previous cycle significant leakage existed; the locked closed manual containment isolation valves are not operated during the cycle.

Corrective action to prevent recurrence was established by implementing a permanent start-up LLRT that is required after venting the primary side is complete and the system is no longer required. This action will assure penetration integrity throughout subsequent cycles.

l (4) Penetration P-80, Auxiliary Containment Spray From Fire System, has one 8-inch Chapman-Crane motor-operated gate stop valve (RH-MOV-31).

RH-MOV-31 is the containment isolation valve from the fire system which can be used in an emergency situation to supply the containment spray header. On July 29, 1987, the "as-found" LLRT was performed with

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V.S. Nuclear Regulatory Commission l B13224/ Attachment 2/Page 7 I April 26, 1989 1 1

satisfactory results, obviating 'the need for further testing. On Febru- ,

ary 14,1988, the cold shutdown in-service operability test was performed  !

with satisfactory results; however, leakage was observed from a downstream )

drain valve which was attributed to RH-MOV-31. H 1

An LLRT was performed to confirm and quantify the leakage. The leak .{

exceeded the Technical Specification limits. The valve was disassembled, . -

and silt was discovered in the pipe upstream of the valve and on the upstream side of the valve disc. The downstream pipe and disc area 'were clean. The failure is attributed to fire system (drawn from river) silt and/or sand becoming lodged between the seat and disc during operational .,

testing. It is postulated that between testing, sand and silt contained i in the upstream stagnant section of underground fire header piping 4 migrated to the valve seat / disc interface. - Results from the previous LLRT indicate that had the valve not been reopened, no leak path would have been created and containment integrity would have been maintained.. J Corrective action to prevent recurrence: flushing sand and silt contained j' in the stagnant section of the underground fire. header piping upstream of RH-MOV-31 will not provide a reliable long-term-fix. Therefore, to ensure Penetration P-80 integrity throughout subsequent cycles, an LLRT will be conducted each time the valve is opened. j i

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