L-87-005, Various CRS 08/09/2005 to 02/08/2007

Various CRS 08/09/2005 to 02/08/2007

ML070670293
Person / Time
Site:	Vermont Yankee
Issue date:	02/08/2007
From:	Lukens L Entergy Corp
To:	Office of Nuclear Reactor Regulation
References
GL-87-005
Download: ML070670293 (43)

Text

Originator: Lukens,Larry D Originator Phone: 3 131 Originator Group: Eng P&C Codes Mgmt Operability Required: Y Reportability Required: Y Supervisor Name: Corbett,Patrick B Discovered Date: 02/08/2007 09:22 Initiated Date: 02/08/2007 09:37 Condition

Description:

Unable to locate 1991 video tape of primary containment sand cushion drain inspections.

As a result of CAR 91-063, a video tape of the sand cushion drain line inspections was made. This tape has not been found, despite an exhaustive search. What is known, however, is that the inspection results were evaluated and specifically found not to have affected the VY response to GL 87-05 (memo attached).

This tape was not a Quality Record; it was not an inspection required by Code or Regulation. Its loss has no effect on any installed plant equipment and has no operability implications.

This CR simply documents an unexpected administrative condition.

No specific action is required or suggested as a result of this CR.

Immediate Action

Description:

Suggested Action

Description:

Attachments:

Condition Description February 1992 memo

Attachment Header Document Name:

Document Location Attach

Title:

MEMORANDUM This l e t t e r was reviewed and determined that no revision is necessary as a result of the "pedestal leak" event.

Items 11 through 3 1 are unaffected by thLs event. The last item (page 3, "Response" needed to be considered. It states:

"Therefore, Vermont Yankee ... will conclude that no water has leaked i n t o t h e sand gap area and if any water had it would have exited by way of the e i g h t drain lines provlded."

Later the paragraph further states:

"However, if our investigations indicate the drain lines were not operating properly or undetected water h a s penetrated the gap area, Vermont Yankee will submit a revised response for your review."

The original concern is that water (from t h e refuel cavity) has the potential to leak to t h i s lower elevation, undetected, such that tne sand cushion would become w e t , be in contact with the drywell shell, and promote unacceptable corrosion.

The following is offered to address our letter statements and the original concern of NRC (and the BWR's Owners Group position):

11 The event condition was such that VY had leakage that WAS detected.

2 ) The sand cushion was not wetted. Visual inspection verified it to be dry.

3 ) There is an existing gap between the drywell shell and t h e sand cushion as v e r i f i e d by inspection.

4 ) The drain lines were once again verified to be open and operable.

5 1 The drywell shell was visually inspected and verified to be dry and evaluated to have no corrosion concern.

It 1s concluded that:

11 No water has leaked in the sand cushion area.

2) If water had leaked into t h i s area it would have exited v i a t h e drain lines.

3 ) Undetected water also did n o t enter into the gap area between the

drywell and t h e sand cushion.

Based upon the above conclusions, the Vermont Yankee FVY 87-52 letter remains accurate and no revision is necessary.

In addition, t h e corrective actions taken are measures over and above our stated commitment. Most notable is the increased frequency of inspection of the sand drain lines and the torus floor areas.

53 L .. -.

I Entmgy 1 CONDITION REPORT I CR-VTY-2007-00445 I Originator: Lukens,Larry D Originator Phone: 3 131 Originator Group: Eng P&C Codes Mgmt Operability Required: Y Reportability Required: Y Supervisor Name: Corbett,Patrick B Discovered Date: 02/08/2007 09: 13 Initiated Date: 02/08/2007 09:2 1 Condition

Description:

Sand Cushion Drain Line Configuration The current configuration of the sand cushion drain system cannot be used to identify unambiguously water intrusion into the sand cushion area, This question was raised during the License Renewal Inspection.

This question does not affect the operability of any installed plant equipment. In the current licensing basis, it is clear that the sand cushion drain lines are not relied upon to help ensure primary containment structural integrity. This is a License Renewal question.

Immediate Action

Description:

Suggested Action

Description:

Evaluate the current design and configuration of the drain lines and determine their suitability for use as a leakage detection system.

Evaluate the installation of a collection facility to clearly identify water coming from the drains.

Revise OP 0150 to specifically direct the Operators to observe the 8 drain lines or a potential collection system. Include necessary training for Operators.

Establish and document the design basis and design function for the sand cushion drain lines.

Originator: Lukens,Larry D Originator Phone: 3 131 Originator Group: Eng P&C Codes Mgmt Operability Required: Y Reportability Required: Y Supervisor Name: Corbett,Patrick B Discovered Date: 02/08/2007 08:44 Initiated Date: 02/08/2007 0857 Condition

Description:

CAR 9 1-063 evaluation and conclusions may be potentially confusing.

CAR 91-063 (partial attached) describes a packing leak from valve MS-77. This leak became visible as water in the area of the drywell pedestal. The evaluation and conclusions are worded in such a way that it is difficult to determine precisely how the water from the packing leak found its way to the drywell pedestal.

This CR is written to evaluate whether the Apparent Cause evaluation of CAR 91-063 should be re-evaluated with the intent of making the evaluation and conclusions more clear regarding the path the water may have taken.

This CR has no effect on past or present operability of the primary containment. This issue arose as a result of helping the NRC License Renewal inspection team to understand how the 1991 packing leak of MS-77 relates to License Renewal.

Immediate Action

Description:

Suggested Action

Description:

Consider revisiting the apparent cause evaluation for CAR 9 1-063, looking for opportunities to clarify the probable path the water took before it appeared on the torus room floor.

Attachments:

Condition Description CAR 9 1-063

I Erztwgy 1 I

CONDITION REPORT I

CR-VTY-2007-00443 1

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Originator: Lukens,Larry D Originator Phone: 3 13 1 Originator Group: Eng P&C Codes Mgmt Operability Required: Y Reportability Required: Y Supervisor Name: CorbetLPatrick B Discovered Date: 02/08/2007 0858 Initiated Date: 02/08/2007 09:02 c

Condition

Description:

Results of 2007 Primary Containment Sand Cushion Drain Line Inspections The inspection results (attached) and evaluations for sand cushion drain inspections completed in January 2007 are being entered into the corrective action process as the first step toward incorporating them into an Engineering document. This CR conveys the results and evaluation of those inpsections.

This CR affects no installed plant equipment; has no operability implications; and does not identify a deviation from any requirement.

Immediate Action

Description:

Suggested Action

Description:

Evaluate screen conditions; general condition of drain lines; discontinuities in drain lines; deposits or material in drain lines; observations of departure from clean, smooth drain line internal diameter Attachments:

Condition Description 2007 Sand Cushion Drain Inspections

I Vermont Yankee Non-Code Internal Visual Examination Work Order No.: 510 f / 726 01 Report Form for Components and Piping VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-001 Page2 o f 2 Supplemental Information Comments for Sand Drain inspection at Bay #2

1. No screen was evident at the end of the drain tubing. There was no obvious obstruction at the tube inlet.

2. Air flow was noted moving in the direction of the sand cushion.

3. Small stone type particle debris was noted in 10%to 15% of the tube length.

While extensive, it does not appear that these obstructions would impede the flow of water that may come from the sand cushion area.

4. A tubing kink exists at 91 from the tubing inlet

5. A tubing joint was noted at 44 form the tubing inlet and appears to be functional.

6. Overall tube length is approximately 167

Vermont Yankee Workorder No.: s/og / 726 O/

Non-CodeInternal Visual Examination Drawing No/Rev.: G -/?f fL8/ /fed 2 Report Form for Components and Piping Page -of 2 Date: 02/01/07 Component and/or Piping Experience Hours Credit: 4.0 VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-002 Page2 o f 2 Sutmlemental Information Comments for Sand Drain inspection at Bay #4

1. Screen intact with approximately 40% of the screen area clear.

Approximately 60% of the screen area has sand or other deposit impingement.

2. Air flow noted in the direction of the sand cushion.

3, Kink noted at approximately 87 from the drain tube entry.

4. Minor debris noted including what appears to be a nail.

5. Joint at 49 from tube entry appears to be functional.

6. Overall tube length was not measured for this tube due to scaffold obstruction and radiation dose consideration.

Work Order No.: 310 f / 726 Of Vermont Yankee Non-Code Internal Visual Examination Drawing No/Rev.: G - / 9 / Yg/ 8 . d 2 Report Form for Components and Piping Page - f of 2 Date: 02/01/07 Component and/or Piping IS1 Group Evaiuation Required?

ater* ayes @NO Initials:

Experience Hours Credit: &0 VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-003 Page2 o f 2 Supdemental Information Comments for Sand Drain inspection at Bay #6

1. Screen appears to be intact with sand and other deposit impingements noted over approximately 98% of the screen surface area.

2. Kink noted at approximately 88 from the tube entry.

3. Joint noted at approximately 42 from tube entry. Joint appears to be intact and functional.

4. Overall length of drain tube is approximately 162 from tube entry.

5 . No conclusive air flow was noted in this tube.

Work Order No.: T/d)8/ 726 Of Vermont Yankee Non-Code Internal Visual Examination Drawing No/Rev.: G-/?i yg/ 2 Report Form for Components and Piping Page - 1 of 2 Date: 02/01/07 Missing Parts x Excessive Movement x Alignment x Clearances i(

Thread Damage Loose Bolting Fractured Bolting x Remarks:

Initials: 2 Experience Hours Credit: %0 VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-004 Page2 o f 2 Sumlemental Information Comments for Sand Drain inspection at Bay #8

1. Screen intact with approximately 40% of the surface area clear and approximately 60% included by sand or other deposits.

2. Kink noted at approximately 96 form tube entry.

3. Joint noted at 47 from tube entry. Joint appears to be intact and functional.

4. Overall length of tube is approximately 172 measured from tube entry.

5. No conclusive air flow was noted in this tube.

Vermont Yankee Work Order No.: J/o 8/726 01 Non-Code Internal Visual Examination Report Form for Components and Piping DrawingNoRev.: G * / 9 fyg/ /f"d 2 Page -I of 2 Date: 02/01/07 Component and/or Piping Component ID:X4n.J Jfi(fi +uIA MY 10 System ID:L J ~ JD#A M Examined MIn Place URemoved What is Being Examined: &fk%d D!-dJN TlJ& J&%f/?k41 IS1 Group Evaluation Required?

ayes HNO Initials: ,7%

~

Experience Hours Credit: 4.0 VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-005 Page2 o f 2 Sumlemental Information Comments for Sand Drain inspection at Bay #10

1. Screen appears to have a slight gap between the screen surface and the tube end. Screen is intact with approximately 98% of the screen surface area included by sand and other impinged material.

2. Kink noted at approximately 94 from tube entry.

3. Joint noted at 44 from tube entry. Joint has a significant gap in the coupling, but appears to be intact and functional.

4. Overall tube length is approximately 166.

5. No conclusive air flow was noted.

Vermont Yankee Non-Code Internal Visual Examination Report Form for Components and Piping Page -

1 of 2 Date: UZ/D.t/O?

I Component and/or Piping Experience Hours Credit: 48 VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-006 Page2 o f 2 Supplemental Information Comments for Sand Drain inspection at Bay #12

1. Slight gap noted between the screen and tube end. Screen is intact with approximately 30% of the area clear and approximately 70% of the screen area included with sand and other impinged material.

2. Kink noted at approximately 87 from tube entry.

3. Minor debris noted.

4. Joint noted at 45 from tube entry. Joint has a gap but appears to be intact and functional.

5 . Overall tube length is approximately167.

6 . Small air flow noted in direction of the sand cushion.

Vermont Yankee Work Order No,: I/o 8/726 01 Non-Code Internal Visual Examination DrawingNoiRev.: G - l f fY 8 / fled 2 Report Form for Components and Piping Page - 1 of 2 Date: 02/01/01 I

Component and/or Piping Visual Aids IS1 Group Evaluation Required?

Dyes MNo Initials: 2 Experience Hours Credit:&

VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-007 Page2 o f 2 Supplemental Information Comments for Sand Drain inspection at Bay #14

1. Screen intact and 100% clear. Minor damage to screen.

2. Minor debris noted.

3. Air flow noted in direction of sand cushion.

4. Kink noted at approximately 72 from tube entry.

5. Joint noted at approximately 47 from tube entry. Joint appears to be intact and functional.

6. Overall tube length is approximately 163.

Vermont Yankee Non-Code Internal Visual Examination Report Form for Components and Piping Component and/or Piping Component ID: 1 4ad rll*b;h MY 2 6 System ID:J ~ J JDR11N Examined: MIn Place Visual Aids ErosiodCorrosion Arc Strikes Experience Hours Credit:

VYNEF 8064.04 NE 8064 Rev. 2 Page 1 of 1

Supplemental Report Sheet Vermont Yankee Non-Code Internal Visual Examination Procedure NE 8064 Code Programs NDE Report #: 07-008 Page2 o f 2 Supplemental Information Comments for Sand Drain inspection at Bay #16

1. Screen intact approximately 80% clear and approximately 20% included by impinged material.

2. Double kink noted at approximately 93" form tube entry.

3. Air flow noted in the direction of the sand cushion.

4. Joint at approximately 48" from tube entry. Joint appears to have a slight gap but otherwise intact and functional.

5 . Overall tube length is approximately 164".

Originator: Lukens,Larry D Originator Phone: 3 131 Originator Group: Eng P&C Codes Mgmt Operability Required: N

\

Reportability Required: N Supervisor Name: Corbett,Patrick B Discovered Date: 0 1/24/2007 10:28 Initiated Date: 01/24/2007 10:3 1 Condition

Description:

NDE Procedures may not be sufficiently clear concerning the writing of CRs for identified indications.

Procedures ENN-NDE- 10.0 1;ENN-NDE- 10.02; and ENN-NDE- 10.03 do not explicitly reference EN-LI- 102, and they do not contain explicit guidance to initiate a Condition Report upon identifying a non-conforming condition.

These procedures should be reviewed and revised to be consistent with EN-LI-102 and Management expectations.

Immediate Action

Description:

/

En-w I CONDITION REPORT CR-VTY-2007-00257 Originator: Lukens,Larry D Originator Phone: 3 131 Originator Group: Eng P&C Codes Mgmt Operability Required: N Reportability Required: N Supervisor Name: Corbett,Patrick B Discovered Date: 01/24/2007 10:15 Initiated Date: 01/24/2007 10:26 Condition

Description:

Engineering Standard ENN-EP-S-001,General Visual Containment Inspection, Step 5.2.3 contains unclear direction.

Containment General Visual Inspections are conducted by qualified examiners and the results are reviewed and accepted by the W E Responsible Individual [FU](Program Owner).

Steps 5.2.1 & 5.2.2 are the following:

5.2.1: The inspection criteria (Sections 5.3,5.4,5.5 and 5.6 ditions in plants. These inspection criteria have been evaluated and acceptable by c romise the structural integrity of the primary containment pressure boundary.

5.2.2 Indications which do not exceed the inspection criteri without the RI?s review.

Step 5.2.3 states, The RI [the IWE Responsible Individua itions exceeding the inspection criteria are acceptable. A Condition Report (C It is possible to interpret this direction as being contrary non-conforming conditions are identified by CR and in criteria should initiate a CR.

Immediate Action

Description:

P This steu should be reviewed and revised to clarify that a individual identifying a condition that exceeds the acceptance Suggested Action

Description:

' Ekfergy 1 CONDITION REPORT CR-VTY- 1997-00307 Originator: Betti,Enrico J Originator Phone: 2347 Originator Group: Licensing Mgmt Operability Required: N Reportability Required: N Supervisor Name:

Discovered Date: 03/12/1997 0O:OO Initiated Date: 03/13/1997 0O:OO Condition

Description:

The Teledyne corrosion evaluation, performed in 1990, did not consider the The Teledyne corrosion evaluation, performed in 1990, did not consider the original ASME I11 design basis pressure when evaluating allowable corrosion limits. The resultant corrosion limits would ultimately compromise the ASME I11 design pressure capacity. In addition the Teledyne study neglected to address corrosion at the critical penetrations. In the process of performing work for the ECCS strainer design change and for the ITS project, it was discovered that the torus corrosion evaluation did not consider design pressure.

Immediate Action

Description:

NOTIFIED APPROPRIATE MANAGERSOEPT : Complete : Expr 1 DISCUSSED EVENT WITH EMPLOYEE : Complete : Expr 1 INVESTIGATED THE PROBLEM : Complete : Expr 1 Suggested Action

Description:

INITIATED DOCUMENT CHANGE : Complete : Expr 1 EQUIPMENT:

Tap Name Tag Suffix Name ComDonent Code Process Svstem Code PCAC NE%

REFERENCE ITEMS:

Type Code Descrhtion APPENDIX ITS EDCR EDCR96-4 15 TRENDING (For Reference Purposes Only):

Trend Tvpe Trend Code CAUSE DEPT CD-FLUID SYSTEMS ENGINEERING PERSONNEL INJURY PI-NON-INJURY CAUSAL FACTOR CODES CFC-M2A3 KEYWORDS KW-DOORS KEYWORDS KW-ITS Attachments:

Closure Description ECCS STRAINER DESIGN SPECIFICATIONPREPARATION IT WAS DISCOVI

Eitergv I ADMIN CR-VTY-1997-00307 Initiated Date: 3/13/1997 0:OO Owner Group :Eng DE Fluid Systems Mgmt Current

Contact:

Current Significance: C Closed by: CONVERSIONJT 11/20/1997 0:OO I ~~

Summary

Description:

The Teledyne corrosion evaluation, performed in 1990, did not consider the Remarks

Description:

The ER 970307 was migrated from the VY Niagara application on 10/30/2003 to generate this CR.

Closure

Description:

'En>== CORRECTIVE ACTION CR-VTY-1997-00307 Originated By: CVAX 11/18/1997 0O:OO:OC Performed By: Callaghan,James H 1 1/30/1999 0O:OO:OC Subperformed By: Callaghan,James H 11/30/1999 0O:OO:OC Approved By:

Closed By: McCullough,Richard E 11/30/1999 15:17:0C Current Due Date: 10/22/1999 Initial Due Date: 10/22/1999 CAType: ERCA Plant Constraint: NONE CA

Description:

ER-970307-0 1 ER970307-0 1 TORUS SHELL CORROSION EVALUATION/ASME I11 DESIGN BASIS PRESSURE. DETERMINE THICKNESS OF TORUS PLATE SECTIONS/GEOMETRIES OF CONCERN. REVISE CLAC VYC-1032. FORWARD RESULTS TO MECH. MAINT.

Niagara indicators set at Initiation and DH Review:

Commitment Type :: B Source Type :: Corrective Action Source Detail :: Event Report Item to be completed during outage ::

Summary of Niagara Due Date Extensions:

On 06/03/1998 revision 4 changed the due date from 06/01/1998 to 10/01/1998.

On 09/29/1998 revision 5 changed the due date from 10/01/1998 to 11/13/1998.

On 11/10/1998 revision 6 changed the due date from 11/13/1998 to 12/31/1998.

On 01/07/1999 revision 7 changed the due date from 12/31/1998 to 04/30/1999.

On 04/28/1999 revision 8 changed the due date from 04/30/1999 to 06/04/1999.

On 06/02/1999 revision 9 changed the due date from 06/04/1999 to 08/06/1999.

On 08/16/1999 revision 10 changed the due date from 08/06/1999 to 10/22/1999.

Response

Commitment ER-970307-0 1 DH Approval Comments:

complete.

Subresponse :

3/20/98 JHC. See detailed closure notes on VYAPF 0028.0 I ; attached "task" by J Fitzpatrick.

Closure Comments:

The Commitment ER-970307-01 was migrated from the VY Niagara application on 10/30/2003 to generate this CA.

Close Out Comments indicated in Niagara ::

Attachment Header Document Name:

Document Location fClosure Description Attach

Title:

fECCS STRAINER DESIGN SPECIFICATION PREPARATION IT WAS DISCOVERED THAT THE DESlGh

Entergy CORRECTIVE ACTION LO-OEN-2005-00361 CA Number: 6 Assigned By: VTY OE Coordinator Aho,Wayne Raymond Assigned To: VTY Eng DE Manager Callaghan,James H Subassigned To : VTY Eng DE Mech Civil Struct Mgmt Originated By: Aho,Wayne Raymond 08/09/2005 16:28: 1C Performed By: GoodwinScott D 09/13/2005 13:44:1C:

Subperformed By:

Approved By:

Closed By: Goodwin,Scott D 09/13/2005 I3:44: 1f

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Current Due Date: 09/ 13/2005 Initial Due Date: 09/ 1512005 CA Type: APPLICABILITY REVIEW Plant Constraint: NONE OEN CA

Description:

CR-JAF-2005-02593-RC Torus Leak Discovered Between The Support Between Bays "A"And "P" this requires a review and evaluation at VY.

Response

requested action previously completed when event first occurred. Concluded that VY is not similar in configuration or susceptible to same event as has occurred at JAF. Refer to Attachment 1 for additional information. No further actions required.

Subresponse :

Closure Comments:

Attachments:

Ca Description Torus Leak-JAF root cause Resp Description Info on JAF Torus Leak

To: Goodwin, Scott

Subject:

FW: Information on JAF Torus Leakage Attachments: VY HPCI & RClC Stm Exhaust Arrangement.pdf Is this what you are looking for?

Ahmet From: Rogers, James Sent: Thursday, June 30, 2005 2:41 PM To: Unsal, Ahmet; Goodwin, Scott; Callaghan, James; LEWIS, RAYMOND S; deburnan@nDDd.com cc: Penny, Robert; Smith, Glenroy; Mulcahy, Francis; Mileris, George; Woods, Steven; White, Thomas F (Pilgrim)

Subject:

RE: Information on IAF Torus Leakage VY has reviewed the HPCI and RClC steam exhaust lines, within the torus, in comparison to the physical arrangement provided. Unlike JAF, VYs lines extend into the torus through a 60" ELL and exit 9 ft. (HPCI) and -8 Ft. (RCIC) below the water surface. HPCl has a sparger at the exit point with none provided on RCIC Review of our torus design indicates that we are similar to JAF in that a ring girder is provided.

Additionally, during RFO 24, Visual Examination was performed on the torus external surface and on the internal surface above the water line and as far below the surface as possible. UT examination was performed in all areas where coating issues were identified. No concerns were identified within the HPCl and RClC areas.

W HPCI & RCIC Strn Exhaust Arr ...

From: Callaghan, James Sent: Thursday, June 30, 2005 12:59 PM To: Rogers, James

Subject:

FW: Information on JAF Torus Leakage From: Pace, Raymond Sent: Thursday, June 30, 2005 10:29 AM To: Unsal, Ahmet; Goodwin, Scott; Callaghan, James; LEWIS, RAYMOND S;

'deburnan@nppd.corn' Cc: Penny, Robert; Smith, Glenroy; Mulcahy, Francis; Mileris, George; Woods, Steven; White, Thomas F (Pilgrim)

Subject:

RE: Information on JAF Torus Leakage

One more item: What does the detail of the SR elbow stiffener look like? It appears to be welded directly to the torus shell. Or, is it welded to a penetration stiffening pad?

---

Original Message-----

From: Pace, Raymond Sent: Thursday, June 30, 2005 10:23 AM To: Unsal, Ahmet; Goodwin, Scott; Callaghan, James; LEWIS, RAYMOND S; 'debuman@nppd.com' cc: Penny, Robert; Smith, Glenroy; Mulcahy, Francis; Mileris, George; Woods, Steven; White, Thomas F (Pilgrim)

Subject:

RE: Information on JAF Torus Leakage All, PNPS would like to see a plan drawing so we can figure out a dimension from the column in question the HPCl steam exhaust penetration. Our penetration is at mid-bay so it is more than 10 feet to either column.

Also, have you considered that early in plant life there were numerous problems with condensation in the exhaust line? After a first run the steam would condense in the line, that would suck in water resulting in a severe water hammer situation on a restart. PNPS had to resupport the HPCl line with snubbers for this event. We also added vacuum breakers to eliminate the potential.

Next item, PNPS has a submerged sparger on the end of the HPCl line to reduce the loading in the pool. This was original equipment. Your information seems to indicate that there is no sparger. Can you verify?

Thanks

---

Original Message-----

From: Unsal, Ahmet Sent: Thursday, June 30, 2005 9:02 AM To: Pace, Raymond; Goodwin, Scott; Callaghan, James; LEWIS, RAYMOND S; 'debuman@nppd.com' Cc: Penny, Robert; Smith, Glenroy

Subject:

Information on JAF Torus Leakage To All:

On June 27, 2005, while performing RClC testing, several cracks were found in the JAF TORUS structure. Further investigation has shown that the cracks are located close to the 24" HPCl steam exhaust line in the torus. There is a ring girder inside the torus close to the location of the cracks. The cracks might be the the result of fatigue due to thermal and/or condensation oscillation loads generated by the HPCl steam exhaust. There is also a similar configuration for the RClC line, which also discharges to the torus.

Attached are sketckes, drawings showing the HPCl and RClC configurations for JAF.

Also, the UT mapping of the crack and pictures of the location of the crack are attached.

This information is sent to you so that you can investigate whether you have a similar condition at you plant.

If you need additional information, please contact me or Glen Smith at WPO.

<< File: Info Sites.TIF >> << File: MVC-581S.JPG >> << File: MVC-584S.JPG >>

Ahmet Unsal, PE Si: StaSf Engineer 440 Hamilton Avenue White Plains, hT 10601 Tel: 914 272 3529 Fax: 914 272 3537

Entefg-y CORRECTIVE ACTION LO-OEN-2005-00361 CA Number: 4 Assigned By: OEN Mgmt Coulehan,Vincent Assigned To: OEN VTY Staff Aho,Wayne Raymond Subassigned To :

Originated By: Coulehan,Vincent 0810 I /2005 07: 1 1 :47 Performed By: Aho,Wayne Raymond 09/24/2005 12:22:05 Subperformed By:

Approved By:

Closed By: Coulehan,Vincent 09/25/2005 19:30:3C

~

Current Due Date: lO/O ~ 2 0 0 5 Initial Due Date: lO/O 1 /2005 CA Type: OE IMPACT EVALUATION Plant Constraint: NONE OEN CA

Description:

CR-JAF-2005-02593-RC Torus Leak Discovered Between The Support Between Bays "A" And "P" this requires an eval at VY

Response

Design Engineering has evaluated this Root Cause in CA#6, and determined that it does not apply to Vermont Yankee.

Subresponse :

Closure Comments:

Close to the response provided Attachments:

Ca Description CR-JAF-2005-02593-RC Torus Leak Discovered Bet

Er2terg-y CONDITION REPORT CR - VTY -2005-02002 Originator: Lipinski.Frank P Originator Phone: 5408 Originator Group: Operability Required: Y Reportability Required: Y Supervisor Name: Corbett,Patrick B Discovered Date: 07/0 1 /2005 09:25 Initiated Date: 07/0 1 /2OOS 09:35 Condition

Description:

Walkdown of Torus - post Fitzpatrick shutdown Upon learning of the Fitzpatrick torus leak and after informing the shift manager, a walkdown of the torus was performed to look for moisture and weepage. Moisture was noted in bays 1 1 , IO, 3 and 15.

It is suggested that these moisture indications be characterized and documented.

Immediate Action

Description:

Walked down the area. Notified shift manager.

Suggested Action

Description:

EQUIPMENT:

Tag Name Tap Suffix Name Component Code Process System Code TORUS TORUS MR=Y NB TRENDING (For Reference Purposes Only):

Trend Type Trend Code REPORT WEIGHT 1 EU ESSE EL ESSE

Enfwgy ADMIN CR-VTY-2005-02002 Initiated Date: 7/ I12005 9:35 Owner Group :En& SYS System Eng Mgmt Current

Contact:

MMD Current Significance: C - INVEST & CORRECT Closed by: Burger,Frederick J 7/28/2005 I I :30

~ ~~ ~~

Summary

Description:

Walkdown of Torus - post Fitzpatrick shutdown Upon learning of the Fitzpatrick torus leak and after informing the shift manager, a walkdown of the torus was performed to look for moisture and weepage. Moisture was noted in bays I I , 10. 3 and 15.

It is suggested that these moisture indications be characterized and documented.

Remarks

Description:

Closure

Description:

Trend data entered.

Enfwgy 1 OPERABILITY I CR-VTY -2005-02002 OperabilityVersion: 1 Operability Code: EQUIPMENT OPERABLE Immediate Report Code: NOT REPORTABLE Performed By: Wisniewski ,Andrew T Approved By: Keith,Ronald M Operability

Description:

Qualified personnel (Operations and Engineering) walked down the Torus and identified that the leakage in bays 3 and 15 was oil coming from RHR-39Aand RHR-34R valve operators. Bays IO and I I had indications of condensation or leakage from above the Torus. These indications need to be investigated. These indications are above the Torus water line and therefore are not leakage from the Torus. There is no indication of any Torus leakage.

Approval Comments:

Entwgy I ASSIGN MENTS 1 CR-VTY-2005-02002 Version: 2 Significance Code: C - INVEST & CORRECT Classification Code: C Owner Group: Eng SYS System Eng Mgmt Performed By: Dudley,Mona M 07/06/2005 10:40 Assignment

Description:

Screening Data Significance C - INVEST & CORRECT Owner : Eng SYS System Eng Mgmt Comments:

Trending Items RW - 1 (SELF-IDENTIFIED)

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Entergy I ASSIGNMENTS 1 CR-VTY-2005-02002 Version: I Significance Code: C - INVEST & CORRECT Classification Code: C Owner Group: Eng SYS Manager Performed By: LipinskLFrank P 07/0 I /200s 0950 Assignment

Description:

characterize and document moisture on the torus.

Entctrgy REPORTABILITY CR-VTY-2005-02002 EntwgY CORRECTIVE ACTION CR-VTY-2005-02002 Originated By: Dudley.Mona M 07/06/2005 10:42:3_7 Performed By: LeFrancois.Mark P 07/26/2005 I4:3 1 :O I Subperformed By: VekasyStephen A 07/ I3/2O05 15:39: 12 Approved By:

Closed By: Burger,Frederick J 07/28/2005 I 1 2 9 : IF Current Due Date: 08/04/2005 Initial Due Date: 08/04/2005 CA Type: CA - INVEST & CORR Plant Constraint: 0 NONE CA

Description:

C - INVEST & CORRECT (Review CR for full details)

The CRG has initially classified this CR as Classification Code - C Significance Code - INVEST & CORRECT Per the CRG, Perform an Investigation of the issues identified in this CR and determine if additional actions are required within 30 days.

All Attachments are to be in PDF format Ensure all Screening Comments have been addressed in the investigation - (CR assignment tab)

Develop adequate corrective actions and issue CAS. (Due Dates per LI 102 Attachment 9.5)

LT CAS Require Approval from Site VP/ GMPO or Director prior to initiating.

Response

Approved. Per review IAW EN LI 102 Section 5.9.1 all correct actions are complete. Please close this CR.

Subresponse :

See attached description of the investigation. No further tracking is required.

Closure Comments:

Trend data entered.

Attachments:

Suhresp Description CR investigation

Attachment Header Document Name:

W e T Document Location ubresp Description Attach

Title:

P R investigation

CR-VTY-2005-2002 indicates that Upon learning of the Fitzpatrick torus leak and after informing the shift manager, a walkdown of the torus was performed to look for moisture and weepage. Moisture was noted in bays 11, 10, 3 and 15. This walkdown of the entire torus to look for leakage was performed by Frank Lipinski and B.C. Current.

System Engineering was immediately asked by OPS to evaluate the findings described in the CR.

Qualified personnel (Operations and System Engineering) performed a walkdown of the Torus to determine the source of the moisture identified on the outside of the torus. The walkdown team included:

Steve Vekasy System Engineer - qualified for System Engineering walkdowns Steve Jonasch System Engineer - qualified for System Engineering walkdowns Ted Underkoffler Code Programs Engineer - VT-2 qualified Bill Fields Code Programs Engineer Mike Flory Auxiliary Operator - VT-2 qualified The subject CR identified moisture trails down the side of the torus shell in bays 3, 10, 11 and 15. The author of the CR initiated the CR based on observations of the torus shell from the floor at elev. 213. He did not go up to the torus catwalk to identify the source of the leakage.

The inspection began on the torus floor with the initiator of the CR to accurately identify the moisture identified in the CR. The five individuals above then went to the torus catwalk to the areas immediately above the identified moisture on the torus shell below. The stain tracks leading to the moisture identified on the torus shell below were all readily identified. Each of the four stain trails initiated on the upper quadrant of the torus well above water level (which is at approx. mid point on the torus). Each of the four stain trails was caused by external moisture leaking onto the upper quadrant of the torus. The upper quadrant is in the air space of the torus. There was no evidence of through wall leakage. Through wall leaks can only begin below the midpoint of the torus.

Moisture identified in the CR in bay 3 was determined to be coming from oil leaking from the Limitorque operator of V I 0-34B.At the request of the duty Shift Manager, I submitted FRF 886 to have the oil cleaned up. I identified the leaking operator to the MOV program coordinator, and discussions are ongoing as to when to repair the gaskets in the operator. WOR 05-064986 was initiated to document the oil leak.

Moisture identified in bays 10 and 11 was identified as one of many condensation stains occurring under the general area of the heating steam discharge into the HHB condensate drain system. The fact that heating steam condenses in this area and runs down the upper quadrant of the torus is well known to OPS.

Moisture identified in bay 15 was very minor oil leakage from V I 0-34A which does not need further follow-up.

There are no safety concerns with the current condition of the torus shell. There is no evidence of any through wall leak. All of the conditions described in the CR are moisture trails which initiate above the Torus water line and therefore are not leakage from the Torus. Leakage from other sources onto the exterior of the torus is not a safety concern.