ML17263A986

Requests one-time Exemption from 10CFR50,App J,Re Performance of Type C Testing During 1995 Refueling Outage. Licensee Feels That Containment Isolation Valves Do Not Need to Be Tested for Leakage Based Upon Past Testing

ML17263A986
Person / Time
Site:	Ginna
Issue date:	03/15/1995
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9503210175
Download: ML17263A986 (23)

Text

P R.IC3R.I"EY' (ACCELERATED RIDS PROCESSIN REGULATORY INFORMATION DXSTRXBUTXON SYSTEM (RIDS)

ACCESSION NBR:9503210175 DOC.DATE: 95/03/15 NOTARXZED: YES DOCKET N

FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

05000244 AUTH.NAME AUTHOR AFFXLXATION MECREDY,R.C.

Rochester Gas

& Electric Corp.

RECIP.NAME RECXPXENT AFFXLIATION JOHNSON,A.R.

Project Directorate I-1 (PD1-1)

(Post 941001)

SUBJECT:

Requests one-time exemption from 10CFR50,App J,re performance of Type C testing during 1995 refueling outage.

Licensee feels that containment isolation valves do not need to be tested for leakage based upon past testing.

DISTRIBUTION CODE:

A017D COPIES RECEIVED:LTR ENCL SXZE:

TITLE: OR Submittal:

Append J Containment Leak Rate Testing P

0 R

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

05000244 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A INTERNA : FILE CENTER Ol

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TOTAL NUMBER OF COPIES REQUIRED:

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4ND ROCHESTER GASANDElECTRIC CORPORATION

~ 89 FASTAYENUF, ROCHESTER, N. Y 1/649-NOI ARFA CODE716 546-2700 ROBERT C. MECREDY Vice President Nuclear Operations Harch 15, 1995 U.S. Nuclear Regulatory Commission'ocument Control Desk Attn: Allen R. Johnson Project Directorate I-1 Washington, D.C.

20555

Subject:

Application for Exemption from 10 CFR 50, Appendix J Rochester Gas

& Electric Corporation R.E.

Ginna Nuclear Power Plant Docket No. 50-244

References:

(a)

Letter from R.C. Hecredy, RG&E; to A.R. Johnson, NRC,

Subject:

"Application for Amendment to Facility Operating

License, Containment Isolation Valve Testing Frequency,"

dated Harch 13, 1995.

(b)

Federal

Register, Volume 60, page

9634, February 21, 1995.

Dear Hr. Johnson,

In accordance with 10 CFR 50. 12, section (a)(2)(ii),

RG&E hereby applies for a one-time exemption from 10 CFR 50, Appendix J.

This exemption request addresses two parts of 10 CFR 50, Appendix J, section III.D.3.

First, RG&E requests an exemption from performing Type C testing during the 1995 refueling outage except for containment isolation valves which have maintenance performed on them or valves which have not demonstrated acceptable leakage during their previous two leakage tests.

Second, RG&E requests an exemption from performing Type C tests for 129 containment isolation valves to allow an interval greater than 2 years between leakage tests.

The technical specification changes which necessary are to support this exemption request are provided separately in Reference a.

Background information, the basis for the request, technical justification, and a safety evaluation of this application for exemption from 10 CFR 50, Appendix J, are provided in Attachment A.

This attachment demonstrates that. the requested exemption does not represent an undue risk, avoids performance of leakage tests on valves which have previously demonstrated acceptable leak tightness, and is otherwise in the public interest.

The exemption request is also consistent with the recently proposed new Appendix J rule (Ref. b).

The estimated savings from not having to perform these Type C tests during the 1995 refueling outage is approximately

$80,000 which includes a

1 person-rem reduction in personnel exposure.

'st507210175

'st50315" PDR

~ADOCK 05000244 P

PDR

'I Since R&GE expects to exit Cold Shutdown conditions following the 1995 refueling outage on April 27,

1995, we request NRC approval two weeks prior to this date, April 13, 1995 in order to allow RG&E to plan adequate resources to perform the required Type C testing if this exemption request will not be granted.

Very uly yours, Robert C. Hecredy Subscribed and sworn to before me on this 15 day of Harch 1995.

HDF~731 Notary Public DEBORAH A.PIPERNI Notary Public m the State of New York ONTARIO COUNTY Commission Expires Nov. 23, 19...'g~

XC:

U.S. Nuclear Regulatory Commission Hr. Allen R. Johnson (Hail Stop 14B2)

PWR Project Directorate I-1 Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Region I

475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

~

11 j

1

Attachment A

R.E.

Ginna Nuclear Power Plant Application for Exemption from 10 CFR 50, Appendix J This attachment provides a description of the requested exemption and the necessary justification.

The attachment is divided into six sections.

Section A describes the requested exemption from 10 CFR 50, Appendix J while Section B

provides background information associated with the exemption request.

Sections C and D

present the bases for the request with respect to 10 CFR 50. 12 and the technical justification, respectively.

A safety evaluation of the exemption request is provided in Section E with a summary presented in Section F.

Section G lists all references used in this attachment.

A.

DESCRIPTION OF EXEMPTION REQUEST RG&E requests a one-time exemption from,10 CFR 50, Appendix J.

Section III.D.3 of 10 CFR 50, Appendix J 'states as follows:

Type C tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years.

RG&E requests an exemption from performing Type C testing during the 1995 refueling outage except for containment isolation valves which have maintenance performed on them or valves which have not demonstrated acceptable leakage during their previous two leakage tests.

RG&E also requests an exemption from performing Type C tests for 129 containment isolation valves to allow an interval greater than 2 years between leakage tests (see Note 4 to attached table).

The interval between tests for these 129 valves would exceed 2 years by no more than 1 month (i.e.,

a maximum testing interval from 3/10/94 to 4/10/96).

B.

BACKGROUND On February 21, 1995, the NRC published a proposed revision to 10 CFR 50, Appendix J for public comment (Ref. 1).

The proposed revised rule would provide an option for containment leakage testing which is predicated on using performance based acceptance criteria.

As such, containment leakage testing frequencies would be developed based on the results of previous tests instead of the current prescriptive frequencies which are now provided in 10 CFR 50, Appendix J.

This change is being proposed as a

result of extensive industry and NRC evaluations of the actual containment leakage testing results in the nuclear power industry which demonstrates that the current prescriptive testing frequencies are marginal to safety and that a performance based leakage test program is acceptable, and in many

ways, preferable.

The proposed rule is supported by a draft regulatory guide (Ref.

2) and various industry guidance documents (Refs.

3 and 4).

The rule is anticipated to be issued in the fall of 1995.

The current (and proposed) 10 CFR 50, Appendix J is organized based on three types of tests:

Type A, Type B, and Type C.

Type A tests refer to the overall containment integrated leakage rate.

Type B tests refer to those containment penetrations which use isolation barriers that incorporate resilient

seals, gaskets, sealant compounds,

bellows, or flexible metal seal assemblies.

Type C tests refer to containment isolation valves.

The last Type A test performed at Ginna Station was in April 1993 during the 1993 refueling outage.

In general, the last Type B

and C tests performed at Ginna Station were during the 1994 refueling outage between the dates of Harch 6th and April 8th (i.e., the last Type B and C tests for all penetrations were done on or after Harch 10, 1994).

This exemption request proposes to defer Type C

testing for most containment isolation valves that would normally be required to be tested during the 1995 refueling outage.

These containment isolation valves would be tested during the 1996 refueling outage at which time Type A, B, and C tests will all be performed.

These three tests cannot be postponed beyond the 1996 refueling outage since RGRE will be replacing steam generators during this outage which requires breaching the containment structure and liner in order to remove and install the steam generators.

The 1996 refueling outage is currently scheduled to begin on Harch 31, 1996 with Cold Shutdown reached on April 1, 1996.

For the 1995 refueling outage, RGEE anticipates that Ginna Station will leave Cold Shutdown on April 27, 1995 at which time containment integrity is required by technical specification LCO 3.6. 1.

Since Type C testing is required to ensure containment integrity is available, this exemption request must be in place prior to going above Cold Shutdown conditions.

To provide for the potential of some required Type C tests, RG&E requests approval two weeks prior to this date, April 13, 1995.

BASIS FOR EXEHPTION The proposed exemption request meets the criteria for special circumstances as described in 10 CFR 50. 12 (a)(2)(ii) since application of Section III.D.3 of 10 CFR 50, Appendix J for the existing circumstances at Ginna Station is not necessary to achieve the underlying purpose of the rule.

The purpose of 10 CFR 50 Appendix J is presented in Section I of the rule as follows:

These test requirements provide for preoperational and periodic verification by tests of the leak-tight integrity of the primary reactor containment, and systems and components which penetrate containment of water-cooled power

reactors, and establish the acceptance criteria for such tests.

The purposes of these tests are to assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment.

As discussed above in Section A,Section III.D.3 of 10 CFR 50, Appendix J requires that all containment isolation valves be tested every refueling outage but with an interval between tests not to exceed 2 years.

Ginna Station is currently on 12 month refueling cycles such that all containment isolation valves are nominally tested every 12 months.

Other nuclear power plants with longer operating cycles (e.g.,

18 to 24 months) are allowed longer time intervals between tests as long as the time interval is less than 2 years.

As such, approximately 22 Type C tests have been performed at Ginna Station since 10 CFR 50, Appendix J was first, published in 1973.

This is twice as many as would have been required by 10 CFR 50, Appendix J if Ginna Station were on 24 month cycles during this time frame.

Deferring leakage testing of containment isolation valves from the 1995 refueling outage to the 1996 refueling

outage, and extending the time interval between tests to 2 years, 1 month for certain valves does not invalidate the overall purpose of 10 CFR 50, Appendix J.

The Ginna Station technical specifications (and 10 CFR 50, Appendix J) restrict the total containment isolation valve leakage rate to ( 0.6 L. which is not affected by this exemption request.

As such, the acceptance criteria for the leakage tests as used in the accident analyses remain unaffected.

The testing history and structural capability of the containment establish that Ginna Station has previously had acceptable containment leakage rates and that there has typically been little change between tests.

All containment isolation valves have been assigned administrative leakage limits which are based on a ratio of the nominal valve diameter with respect to the sum total of all valve diameters.

This prevents any one valve from dominating the overall leakage rate.

The current as-left Type B and C leakage is 13,858.9 cc/min when measured on a maximum path leakage rate basis and 2,559.3 cc/min when measured on a minimum path leakage rate basis.

These correspond to 61% and 11%, respectively of the allowed 0.60 L, leakage rate of 22,700 cc/min.

The as-left Type A leakage rate is 0.05387 wt%/day or 35% of L, (i.e.,

0. 1528 wt%/day).

Therefore, the ability of containment to mitigate the consequences is still maintained with a large available margin.

Requiring leakage testing during the 1995 refueling outage will result in approximately a

1 person-rem exposure, and require the removal of systems which normally would be available for any accident mitigation function (e.g., charging).

The estimated savings from not performing these Type C tests is approximately

$80,000 based on manpower savings which can then be used to support other required testing.

This estimate does not include any cost savings incurred as a result of reducing the outage length which can be expected to occur due to a

reduction in potential critical path activities.

In addition, several containment isolation valves will not exceed the maximum time between tests of 2 years as currently allowed by 10 CFR 50, Appendix J.

For the remaining valves, a one-time extension of 1 month is of negligible risk impact since it represents approximately 4% of the total interval.

Requiring a shutdown strictly to perform Type C leakage t'ests prior to exceeding 2 years between tests is not in the public best interest since Ginna Station represents approximately 40% of the base load for RG&E.

Also, performing this test would result in unnecessary personnel exposures and a thermal transient to the plant.

This exemption request does not affect the periodic schedule for Type A

and B 'tests which will continue to be performed in accordance with technical specifications, Appendix J and approved exemptions.

TECHNICAL JUST IF ICATION The proposed new 10 CFR 50, Appendix J rule (Ref.

1) was developed based on a detailed review of previous industry experience with performing Type A, B, and C testing.

This review concluded that it was acceptable to base testing intervals on the performance of the containment systems and structures instead of prescribing specific testing intervals.

Draft Regulatory Guide DG-1037 (Ref.

2) endorses an industry standard (Ref. 3) as being an acceptable performance based leak testing program approach which may be used to implement the proposed new rule.

This industry standard states that the interval between Type C tests may be extended from 24 to 60 months provided the successful completion of two consecutive leakage tests.

The exemption request documented in this attachment is to extend the time between Type C tests from 12 months to at most 25 months provided the successful completion of two consecutive leakage tests.

As

such, the proposed exemption request is conservative and well within the guidelines of the proposed new Appendix J rule and supporting guidance documents.

A similar exemption has also been granted for a plant on a

12 month refueling cycle (Ref. 5).

Attachment B provides a listing of the containment isolation valves (and barriers) subject to the Type C testing at Ginna Station.

The table lists the administrative leakage limit of each

valve, the date of its last leakage test, and the leakage test results since 1991.

As can be seen, only 12 of 151 valves do not meet the criteria of two consecutive successful leakage tests to administrative limits such that they would require testing during the 1995 refueling outage.

Therefore, it can be concluded that there is a negligible risk increase with the proposed exemption request based on our previous testing experience.

SAFETY EVALUATION The proposed exemption request as discussed above has been evaluated with respect to the accident analyses as follows:

There is no increase in the probability or consequences of an accident or malfunction of equipment important to safety previously evaluated in the UFSAR related to this request.

There is no impact to initiators of analyzed events since the containment isolation system provides a

mitigation function.

The containment remains capable of performing its intended safety function since previous leakage testing has confirmed the acceptability of the Type C tested containment penetrations.

The proposed extension of the time between leakage tests is also well within the industry guidance proposed to support the new 10 CFR 50 Appendix J rule.

The possibility of a new or different kind of accident or a malfunction of a different type than previously evaluated in the UFSAR is not created by the proposed change.

The containment isolation valves are still required to be tested to ensure containment integrity can be met above Cold Shutdown; only the testing frequency is being revised.

There is also no physical modification to the plant or a

change to normal operational procedures required to support the extension request.

There is no reduction in the margin of safety as defined in the basis for any Technical Specification.

The necessary changes to the Ginna Station Technical Specifications have been submitted separately (Ref. 6).

SUMMARY

In summary, the proposed exemption request meets the special circumstances of 10 CFR 50.12 since:

a ~

b.

Application of Section III.D.3 of 10 CFR 50, Appendix J in this particular circumstance would not serve the underlying purpose of the rule.

The rule provides for the assurance of a leak tight containment system to mitigate the consequences of an accident.

The past leak rate test data and available margin to that allowed by technical specifications provide the necessary assurance that the purpose of the rule is being fulfilled.

Compliance with the rule would cause undue hardship in that requiring testing on an annual basis as a result of 12 month refueling cycles subjects personnel to unnecessary personnel exposures and requires the removal of systems which normally would be available for an accident mitigation function during an outage.

Also, a forced outage for the purpose of testing those valves which would have an interval between testing of greater than 2 years would result in subjecting the plant to an unnecessary thermal transient.

Based. on the above, the requested exemption to 10 CFR 50, Appendix J has been justified, does not involve an unreviewed safety question, and will not adversely affect or endanger the health and safety of the general public.

REFERENCES 2.

3.

5.

6.

Federal

Register, Volume 60, page

9634, February 21, 1995.

Regulatory Guide DG-1037, "Performance-Based Containment Leak Test Program," Draft.

NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Draft, Revision D.

ANSI/ANS-56.8-1994, "American National Standard for Containment System Leakage Testing Requirements."

Letter from D.M. Crutchfield,

NRC, to G.C.

Sorensen, Washington Public Power Supply

System,

Subject:

" Issuance of Exemption to a

Provision of App'endix J and Amendment No.

41 to Facility Operating License No. NPF-21, WPPSS Nuclear Project No.

2 (TAC No. 60740),"

dated April 29, 1987.

Letter from R.C.

Mecredy, RGSE, to A.R.

Johnson, NRC,

Subject:

"Application for Amendment to Facility Operating

License, Containment Isolation Valve Testing Frequency,"

dated March 13, 1995.

ATTACHMENT B Table of Containment Isolation Barriers Subject to Type C Testing Page 1

TYPE C CONTAINMENT BARRIERS VALVE PEN f ADHIN LEKAGE (CCs/HIM)

RETEST IN 1995?

LAST TEST BATE 1995 RESULTS 1994' RESULTS 1993M RESULTS 1992"'ESULTS 1992" RESULTS AOV-200A AOV-2008 AOV-202 CV-304A CV-3048 MOV-313 CV-3708 AOV-371 CV-3838 AOV-508 CV-528 CV-529 AOV-539 V-546 V-547 CV-743 AOV-745 HOV-749A HOV-7498 HOV-759A HOV-7598 112 112 112 106 110A 108 100 112 102 121A 1218 121A 1208 1208 1218 124A 124C 127 128 126 125 111.0 111.0 111.0 166.5 166.5 166.5 166.5 111.0 166.5 111.0 166.5 166.5 20.8 20.8 41.6 166. 5 111.0 166.5 166.5 166.5 166. 5 4/3/94 4/3/94 4/3/94 3/20/94 3/20/94 3/27/94 3/20/94 4/3/94 3/12/94 3/10/94 3/10/94 3/10/94 3/10/94 3/10/94 3/10/94 3/20/94 3/20/94 3/30/94 4/1/94 3/30/94 3/30/94 50 100 20 660 10 10 20 2.4 20 15 20 20 21.6 40 81.4 13 75 49 2.6 2.6 352 20 90 13.3 13.3 13.3 4.2 9.1 32.5 12.8 110 71 95 50 20 Page 2

TYPE C CONTAINMENT BARRIERS VALVE HOV-813 HOV-814 AOV-846 CV-862A CV-8628 V-869A V-869B CV-870A CV-870B V-879 V-885A V-8858 CV-889A CV-8898 SOV-921 SOV-922 PI-922A PT-922 PT-922 END CAP SOV-923 PT-923 PI-923A SOV-924 PEN f 131 130 120A 105 109 105 109 113 101 110B 113 101 113 101 332D 332A 113 113 113 3328 101 101 332A ADHIN LEKAGE (CCs/HIN) 333.0 333.0 55.5 499.5 499.5 41.6 41.6 249.8 249.8 41.6 41.6 41.6 249.8 249.8 20.8 20.8 20.8 20.8 20.8 20.8 20.8 20.8 20.8 RETEST IK 1995?

LAST TEST DATE 3/31/94 3/31/94 3/29/94 3/18/94 4/8/94 3/18/94 4/8/94 3/27/94 3/27/94 3/27/94 3/27/94 3/27/94 3/27/94 3/27/94 4/1/94 4/1/94 3/27/94 3/27/94 3/27/94 4/1/94 3/27/94 3/27/94 4/1/94 1995 RESULTS ISS4cn RESULTS 30 1.0 1.7 3.0 7.5 1993' RESULTS 90 90 27.5 20 35 20 1.9 1992en RESULTS 3.8 54 30 4.3 3.5 iSed" RESULTS 20 6.8 61 15 90

Attachment B. Page 3

TYPE C CONTAINMENT BARRIERS VALVE PT-944 PT-945 PT-946 PT-947 PT-948 PT-949 PT-950 V-956D V-956E V-956F AOV-966A AOV-9668 AOV-966C AOV-1003A AOV-10038 V-1076A V-10768 V-1080A V-1084A V-10848 V-1554 V-1555 V-1556 V-1557 PEN f 332C 121C 121C 203A 203A 332C 332C 205 206A 207A 207A 206A 205 143 143 304A 202A 210 3048 2028 305A 305A 305A 305C ADMIN LEKAGE (CCs/MIN) 20.8 20.8 20.8 20.8

20. 8 20.8 20.8 20.8 20.8 20.8 20.8 20.8 20.8 166.5 166.5 55.5 55.5 55.5 55.5 55.5 41.6 20.8 41.6 41.6 RETEST IN 1995?

y(1)

LAST TEST DATE 8/11/94 3/18/94 3/18/94 3/17/94 3/17/94 8/11/94 8/ll/94 4/5/94 3/2/95 3/2/95 3/2/95 11/9/94 4/5/94 3/24/94 3/24/94 3/21/94 3/15/94 4/2/94 3/21/94 3/15/94 4/1/94 4/I/94 4/1/94 4/1/94 1995 RESULTS 610 1994"'ESULTS 0

10 10 15 12 1993"'ESULTS 4.6 4.1 29 20 1992 RESULTS 4.3 25.9 160 9.5 18 10 230 1991"'ESULTS 0-3.9 9.1 4.5

0 I'

Page 4

TYPE C CONTAINHENT BARRIERS VALVE V-1558 "

V>>1559 V-1560 V-1561 V-1562 V-1563 V-1564 V-1565 V-1566 V-1567 V-1568 V-1569 V-1570 V-1571 V-1572 V-1573 V-1574 V-1596 AOV-1597 AOV-1598 AOV-1599 V-1655 V-1709G CV-1713 PEN f 305C 305C 305D 305D 305D 2038 2038 2038 203C 203C 203C 124D 124D 124D 1248 1248 124B 305E 305E 3058 3058 123A

)43 129 ADHIN LEKAGE (CCs/HIN) 20.8 41.6 41.6 20.8 41.6 41.6 20.8 41.6 41.6

20. 8 41.6 41.6 20.8 41.6 41.6 20.8 41.6 55.5 55.5 55.5 55.5 20.8 41.6 83.3 RETEST IN 19957 LAST TEST DATE 4/1/94 4/1/94 4/1/94 4/1/94 4/1/94 3/15/94 3/15/94 3/15/94 3/15/94 3/15/94 3/15/94 3/31/94 3/31/94 3/31/94 3/31/94 3/31/94 3/31/94 4/3/94 4/3/94 4/3/94 4/3/94 3/30/94 3/24/94 3/30/94 1995 RESULTS 19940 RESULTS 35 71 1993 RESULTS 0

248 20 16 27 199 2en RESULTS 5.5 400 20 20 1991 RESULTS 0

23 32.5

Attaclment B. Page 5

TYPE C CONTAINHENT BARRIERS VALVE PEN f ADHIN LEKAGE (CCs/HIN)

RETEST IN 1995?

LAST TEST DATE 1995 RESULTS 1994"'ESULTS 1993' RESULTS 1992' RESULTS 1992" RESULTS AOV-1721 V-1722 AOV-1723 AOV-1728 AOV-1786 AOV-1787 AOV-1789 V-1793 HOV-1813A HOV-18138 V-1819A V-18198 V-1819C V-1819D V-1819 E V-1819 F V-1819G V-2825 V-2825A V-2826 V-2826A V-2856 V-2858 143 143 107 107 129 129 123A 129 141 142 121C 121C 203A 203A 332C 332C 332C 105 105 109 109 105 109 166.5 166.5 166.5 166.5 55.5 55.5 41.6 55.5 333.0 333.0 20.8 20.8 20.8 20.8 20.8 20.8 20.8 41.6 41.6 41.6 41.6 20.8 20.8 Y(0 y(O 3/24/94 3/24/94 3/24/94 3/24/94 3/30/94 3/30/94 3/30/94 3/30/94 3/24/94 3/27/94 3/18/94 3/18/94 3/17/94 3/17/94 8/11/94 8/11/94 8/11/94 3/18/94 3/18/94 4/8/94 4/8/94 3/18/94 4/8/94 6.5 5.5 0

1.5 17 970 15 72 75 68 2.9 0

64 61 11.2 11.6

Attachment 8,

Page 6

TYPE C COHTAIHHEHT BARRIERS VALVE PEH f ADHIN LEKAGE (CCs/NIH)

RETEST IN 1995?

LAST TEST DATE 1995 RESULTS 1994'ESULTS 19S3"'ESULTS ISS2"'ESULTS ISSI"'ESULTS V"5129 AOV-5392 CV-5393 V-6151 V-6152 V-6165 V-6175 V-7141 CV-7226 AOV-7445 V-7448 V-7448 CAP V-7452 V-7452 CAP V-7456 V-7456 CAP AOV-7478 AOV-7970 AOV-7971 AOV-8418 CV-8419 CV08623 AOV-9227 CV-9229 103 310A 310A 301 303 301 303 310B 3108 309 3320 332D 332A 332A 3328 3328 309 132 132 324 324 120A 307 307 111.0 111.0 166.5 111.0 111.0 111.0 111.0 111.0 166.5 333.0 20.8 27.8 20.8 27.8 20.8 27.8 333.0 333.0 333.0 111.0 166.5 83.3 222.0 333.0 Y(2)

(2)

(2)

(2) 3/11/94 3/13/94 3/13/94 3/15/94 3/15/94 3/15/94 3/15/94 4/1/94 4/1/94 3/30/94 4/1/94 4/1/94 4/I/94 4/1/94 4/1/94 4/I/94 3/30/94 3/14/94 3/14/94 4/3/94 4/3/94 3/29/94 4/1/94 4/I/94 8350 10 290 49 59 500 15 20 18 233 3.4 50 16 130 25 50 10.8 1900 12 18 25 74 15 15 20 163 340 630 20 22 8.2 5.1 1014 400

P Page 7

TYPE C CONTAINMENT BARRIERS VALVE 1020551 1020951 1021151 1021351 1021451 1021551 V-12406 V-12407 FIRE SH PIPE CAP MINI-PURGE EXHAUST CAP A M2 MONITOR CABINET 8 M2 MONITOR CABINET PEH f 304A 3048 202A 2028 210 210 113 101 103 132 3320 3328 ADMIN LEKAGE (CCs/MIH) 55.5 55.5 55.5 55.5 55.5 55.5 20.8 20.8 111.0 11.8 100 100 RETEST IH 1995?

LAST TEST DATE 3/21/94 3/21/94 3/15/94 3/15/94 4/2/94 4/2/94 3/27/94 3/27/94 3/11/94 3/14/94 4/1/94 4/I/94 1995 RESULTS 1994@

RESULTS 45 130 25 25 7.5 0

60.3 20 1993en RESULTS 31.4 735 400 400 13 1992m RESULTS 168 33 10 1120 300 0

73.3 1991P)

RESULTS 10.9 4.8 35 22 22 2.3

9.5 NOTES

nn cn (4)

VALVE FAILED FIRST LEAKAGE TEST IH 1994 (LEAKAGE IH COLUMN FOR 1994 RESULTS IS FOR SECOND TEST).

THE PENETRATION IS TO BE DECOMMISSIONED DURING 1995 REFUELING OUTAGE.

RESULTS ARE IN CCs/MIN TOTALS FROM TABLE:

CONTAINMENT BARRIERS (VALVES, EHD CAPS, AND CLOSED SYSTEMS)

SUBJECTED TO TYPE C TESTS:

151 MINUS FOUR VALVES FOR PENETRATIONS 301 AND 303 (V-6151, V-6152, V-6165, and V-6175) OICM ARE TO BE DECOMMISSIOHED: 147 TYPE C CONTAINMENT BARRIERS LAST TESTED BETWEEN 3/10/94 AND 4/10/94 (DOES NOT INCLUDE PENETRATIONS 301

& 303):

139 MINUS 10 VALVES TO BE TESTED IN 1995 DUE TO PREVIOUS UNACCEPTABLE LEAKAGE (DOES NOT INCLUDE AOV-966A SINCE IT WAS LAST TESTED ON 3/2/95 AND V-6151 SINCE PENETRATION IS BEING DECOMMISSIONED): 129