ML20052C101

Forwards Draft Evaluation of SEP Topic VI-4 Re Containment Isolation Sys.Lists Outstanding Items Identified in Rept. Missing Incomplete Info & Comments Should Be Provided within 30 Days of Receipt of Ltr

ML20052C101
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/26/1982
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Counsil W CONNECTICUT YANKEE ATOMIC POWER CO.
References
TASK-06-04, TASK-6-4, TASK-RR LSO5-82-04-080, LSO5-82-4-80, NUDOCS 8205040365
Download: ML20052C101 (34)

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April 26,1982 Docket No. 50-213 LS05-82 080

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Mr. W. G. Counsil, Vice President Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company D..

Post Office Box 270 Hartford, Connecticut 06101 D

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SUBJECT:

FORWARDING DRAFT EVALUATION REPORT OF SEP TOPIC VI-4, CONTAIfEENT ISOLATION SYSTEM FOR THE HADDAM NECK PLANT Enclosed is a copy of our draft evaluation of SEP Topic VI-4, Containment Isolation System. This assessment compares your facility, as described in Docket No. 50-213, with the criteria currently used by the regulatory staff for licensing new facilities.

Please inform us if your as-built facility differs from the licensing basis assumed in our assessment.

The following sumarizes the outstanding items identified in the enclosed Evaluation Report.

1.

The use of simple check valves outside containment as an automatic isolation valve; 2.

Isolation provisions for certain closed systems; e.g., single manual isolation valves are identified in the containment cooling water lines to and from the fan coolers rather than remote manual valves; 3.

Inadequate isolation provisions with respect to. redundancy, i.e., only one isolation valve is provided for certain open systems; and 4.

The use of local manual valves for containment isolation with no indication that these valves are sealed closed or othemise under administrative control.

As noted in our evaluation there is insufficient information about contain-ment isolation provisions for useto complete our review. Therefore, you are requested to provide the information identified as missing or incomplete.

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$ In addition, we will need the defined basis upon which the specific isolation configurations at the Haddam Neck Plant were judged to be acceptable to you. Please provide this information as a part of your comments on this report.

Comments are required within 30 days of receipt of this letter so that they may be included in our final report. This evaluation will be a basic input to the integrated safety assessment for your facility unless you identify chanaes needed to reflect the as-built conditions at your facility. This assessment may be revised in the future if your facility design is changed of if NRC criteria relating to this subject are modified before the integrated assessmeat is completed.

Sincerely, Dennis H. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing

Enclosure:

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Mr. W. G. Counsil t

CC Day, Berry & Howard Counselors at Law One Constitution Plaza Hartford, Connecticut 06103 Superintendent

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Haddam Neck Plant RFD #1-Post Office Box 127E East Hampton, Connecticut 06424

. Mr. Richard R. Laudenat Manager, Generation Facilities Licensing Northeast Utilities Service Company P. O. Box 270 Hartford, Connecticut 06101 Board of Selectmen

-1 Town Hall Haddam, Connecticut 06103 State of Connecticut 0Ffice of Policy and Management ATTN:

Under Secretary Energy Division 80 Washington Street Hartford, Cenndcticut 06115

'U. S. Environmental Protection Agency Region I Office ATTN:

Regional Radiation Representative

.JFK Federal Building Boston, Massachusetts 02203

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Resident Inspector Haddam Neck Nuclear Power Station c/o'U. S..NRC East Haddam Post Office East Haddam, Connecticut 06423 Ronald C. Haynes, Regional Administrator Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 I

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Containment Systems Branch Evaluation Report on SEP Topic VI-4 Containment Isolation System for the i

Haddam Neck Nuclear Power Plant, Unit 1 Docket No. 50-213 I

Introduction The Haddam Neck Plant was licensed for emnmercial operation.in 1967.

Since then safety review criteria have changed. As part of the Systematic Evaluation Program (SEP), the containment isolation sys-tem,for the Haddam Neck Plant has been re-evaluated. The purpose of this evaluation is to document the deviations from current safety criteria as they relate to the containment isolation system. The 1

significance of the ' identified deviations, and recommended corrective j

measures to improve safety, will be the subject of a subsequent, inte-grated assessment of the Haddam Neck Plant.

II Review Criteria The safety criteria used in the current evaluation of the containment isolation system for the Haddam Neck plant are contained in the follow-ing references:

1) 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants (GDC 54', 55, 56 and 57).

2) NUREG-75/087, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP 6.2.4, Containment Isolation System).

3) Regulatory Guide 1.11, Instrument Lines Penetrating Primary Reactor Containment. and

4) Regulatory Guide 1.141, Containment Isolation Provisions for Fluid Systems.

ENCLOSURE

s 2-III Related Safety Topics The review areas identified below are not covered in this report, but are related and essential to the completion of the re-evaluation of the con-tainment isolation system for the Haddam Neck plant. These review areas are included in other SEP topics or ongoing Generic Reviews, as indicated below:

(1),III-1, Cla~ssification of Structures, Components and Systems (Seismic and Quality)

(2) III-4C, Internally Generated Missiles (3) III-5. A.

Effects of Pipe Break on Structures, Systems and Compo-e nents Inside Containment

( t) III-5.B.

Pipe Break Outside Containment (5) III-6, Seismic Design Considerations (6) III-12 Environmental Qualification of Safety-Related Equipment (7) VI-6, Containment Leak Testing (8) VII-2, Engineered Safety Feature System Control Logic and Design (9) VIII-2, Onsite Emergency Power Systems - Diesel Generator (10) VIII t,

Electrical Penetrations of Reactor Containment (11) NUREG-0737, Clarification of TMI Action Plan Requirements, Item II.E.4.2, Containment Isolation Dependability (12) NUREG-0660, NRC Action Plan Developed as a Result of the TMI-2 Accident, Item II.E.4.4, Containment Purging and Venting Requirements i

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s IV Review Guidelines The containment isolation system of a nuclear power plant is an en-gineered safety feature that functions to allow the normal or emer-gency passage of fluids through the containment boundary while pre-serving the ability of the boundary to prevent or limit the escape of fission products to the environs that may result from postulated accidents. General Design Criteria (GDC) 54, 55, 5~6 and 57 of Ap-pendix A to 10 CFR Part 50 pertain to the containment isolation sys-tem of a nuclear power plant.

General Design Criterion 54 establishes design and test requirements for the leak detection provisions, the isolation function and the con-tainment capability of the isolation barriers in lines penetrating the primary reactor containment. From the standpoint of containment iso-lation, leak detection provisions should be capable of quickly detect-ing and responding to a spectrum of postulated pipe break accident con-di tions. To accomplish this, diverse parameters should be monitored to initiate the containment isolation function. The parameters selected should assure a positive, rapid response to the developing accident condi tion. This aspect of the containment isolation system review will be addressed during the review of the post-TMI requirements ap-proved for implementation, as stated in NUREG-0737 at Item II.E.4.2.

Leak detection capability should also be provided at the system level to alert the operator of the need to isolate a system train equipped with remote manual isolation valves. SRP 6.2.4, at Item 11.11, pro-vides guidance in this regard.

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a-With respect to the design requirements for the isolation function, all non-essential systems should be automatically isolated (with manual valves sealed closed), and valve closure times should be selected to as-sure rapid isolation of the containment in the event of an accident. The review of the classification of systems as essential or non-essential, and the automatic isolation provisions for non-essential systems by appro-priate signals, will be addressed in conjuncti.on with the review of the post,TMI requirements as stated in NUREG-0737 at Item II.E.4.2.

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i sure time of the containment ventilation system isolation valves will be evaluated in conjunction with the ongoing generic review of purging prac-tices at operating plants {see NUREG-0660 at Item II.E.4.4).

The electrical pcwer supply, instrumentation and controls systems should i

be designed to engineered safety features criteria to assure accomplish-ment of the containment isolation function. This aspect of the review is covered under SEP Topics VII-2 and VIII-2. Also, resetting the isolation signal should not result in the automatic re-opening of containment isola-tion valves. This will be addressed in conjunction with the review of the post-TMI requirements approved for implementation, as stated in NUREG-0737, at Item II.E.4.2.

With respect to the capabilities of containnment isolation' barriers in lines penetrating primary containment, the isolation barriers should be designed to engineered safety feature criteria, and protected against missiles, pipe whip and jet impingement. Typical isolation barriers include valves, closed systems and blind flanges. Furthermore, provi.

1 sions should be made to permit periodic leak testing of the isolation barriers.

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-5, The adequacy of the mi-ssile, pipe whip and jet impingement protection will be covered under SEP Topics III 4.C, III-5.A and III-5.B. The acceptability of the design criteria originally used in the design of the containment isolation system components will be covered in SEP Topics III-1, III-6 and III-12.

4 The adequacy of the leak testing program will be covered under SEP Topic VI-6.

The acceptability of electrical penetrations will be covered in SEP Topic VIII 4 GDC 55, 56 and 57 establish explicit requirements for isolation valv-ing in lines penetrating the containment. Specifically, they address the number and location of isolation valves (e.g., redundant valving with one located inside containment and the other located outside con-tainment), valve actuation provisions (e.g., automatic or reinote manual isolation valves), valve position (e.g., locked closed, or the position of greater safety in the event of an accident or power failure), and valve type (e.g., a simple check valve is not a permissable automatic isolation valve outside containment).

Figures 1 and 2 depict the ex-plicit valve arrangements specified in GDC 55 and 56, and GDC 57, re-spectively.

GDC 55 and 56 also permit containment isolation provisions' for lines penetrating the primary containment boundary that differ from the ex-plicit requirements, provided the basis for acceptability is defined.

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l isolation requirements for essential (i.e., safety related) systems, or there is a clear improvement.in safety.

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GENERAL DESIGN CRITERIA 55 AN) 56 SOLATION VALVE CRITERIA MISSILE PROTECTION CONTAINMENT INSIDE OUTSIDE INSIDE OUTSIDE

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Standard Review Plan (SRP) 6.2.4 at Item II.3 presents guidelines for i

acceptable alternate containment isolation provisions for certain clas-ses of lines. Containment isolation provisions that are found acceptable on the "other defined basis" represent conformance with the GDC and do not constitute exceptions.

The following evaluation addresses deviations in the containment isola-tion provisions from the explicit requirements of the GDC.

V Eval'uation The Haddam Neck plant Facility Description and Safety Analysis (FDSA),

Volumes 1 and 2 (Reference 1) did not address the containment isolation system; however, some con'tainment isolation provisions were addressed in FDSA Section 3.4.

The evaluation of the containment isolation provi-sions, then, was based on other documented information referenced in Section VII, most notably Reference 2.

Reference 2 contains a listing of the containment isolation provisions for the primary reac' tor contain-ment penetrations, as well as system drawings. There was insufficient in:ormation to complete the review; therefore, the licensee should pro-vide the information identified as missing or incomplete.

The containment isolation provisions were evaluated against current safety criteria as set forth in GDC 54, 55, 56 and 57 (Appendix A to 10 CFR Part 50), and the supplementary guidance of SRP 6.2.4, Containment Isola-tion System, where applicable. Deviations from the explicit requirements of GDC 54, 55, 56 and 57 and the acceptance criteria of SRP 6.2.4 are l

tabulated in Table 1.

The Haddam Neck FDSA, Section 3.4 identifies 1

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. 4 five classes for categorizing the lines penetrating the containment.

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For ease of reference, we have categorized all lines penetrating the containment into these five classes for evaluation. The following discussion addresses each penetration class and identifies the piping lines we have selected to be included in each class. The licensee should verify the acceptability of our classification for each line penetrating the primary containment.

1.

Class I penetrations "This piping normally carries radioactive fluids and/or is connected to the reactor coolant system. Outgoing lines are provided with at least one automatically operated trip valve or one remotely motor operated valve located outside of the re-actor containment structure. The motor operated valves are capable of being remotely operated from a location accessible under accident con-ditions.

Incoming lines connected to open systems outside the reactor containment are provided with two check valves in series, one located inside and one outside the containment.

Incoming lines connected to closed systems outside the containment are provided with at least one check valve located directly inside the containment."

GDC 55 applies to Class I lines. GDC 55 specifies that one valve should be located inside containment and one valve should be located outside containment, with the valves being either locked closed or automatic isolation valves. Furthermore, a simple check valve out-side containment may not be used as an automatic isolation valva. The.

l following lines are included in this class:

P-1, P-2, P-3, P-7, P-8, P-10, P-23C, P-24A, P-248, P-24C, P-240, P-74, P-75, P-76, and P-77.

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, The containment isolation provisions for lines P-1 and P-2 differ from the explicit requirements of GDC 55 from the' standpoint of valve.actua-tion (line P-1) and location (line P-2).

For line P-1, remote manual, power operated isolation valves are provided outside containment and in the containment spray lines inside containment. Since the piping system outside containment is a closed, safety-grade system having a post-accident safety function (low pressure safety injection and con-tainment spray), automatic isolation of line P-1 is not appropriate; remdte manual isolation capability is acceptable. Furthermore, the system constitutes an appropriate isolation barrier outside cont'ain-ment for line P-2 (residual heat removal letdown line) which has two normally closed (interlocked) valves inside containment. Therefore, lines P-1 and P-2 satisfy ~ GDC 55 on the other defined basis.

The containmnent isolation provisions for line P-3 (high pressure safety injection) include, for the five branch lines outside, contain-ment, a simple check valve in two lines, a normally closed globe valve in one line, a relief valve in one line, and a simple check valve and i

normally closed gate valve in series in one line, and, for the six branch lines inside. containment, a simple check valve and remote manual valve in series in four of the lines and a locked ~ closed manual valve in two lines. These provisions differ from the explicit requirements of GDC 55 from the standpoint of valve type and actuation. A simple check valve outside containment is not an appropriate automatic iso-lation valve. However, the safety injection system (SIS) is a closed safety-grade system outside containment and double barrier isolation l

- 11 isolation capability is provided without taking credit.for the sim-ple check valves. Also, since the SIS has a post-accident safety function, it is acceptable for the motor operated valves inside containment to have remote manual closure capability. Consequently, GDC 55 is met on some other defined basis.

Line P-8 (charging line) contains two parallel air operated valves outside containment and a check valve inside containment. The actu-atien provisions for the air operated valves do not conform to GDC 55 in that remote manual, instead of automatic, isolation valves are provided. Since the charging line has a post-accident safety func-tion, and the chemical and volume control system outside containment is a losed safety-grade system, remote manual isolation valves sat'-

isfy GDC 55 on the other defined basis.

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The containment isolation provisions for lines P-23C, P-24A, P-248, P-24C, P-240, P-74, P-75, P-76 and P-77 differ from the explicit re-quirements of GDC 55 from the standpoint of valve number. Lines P-23C, P-24A, P-24B, P.-24C, and P-24D are each provided with one i

locked closed isolation valve outside containment; there is no iso-lation valve inside containment. The licensee should provide re-l dundant isolation valves in these lines, and justify the. valve type, location and actuation provisions.

Lines P-74, P-75, P-76 and P-77 each have a check valve inside con-tainment, no isolation valves are identified outside containment.

However, these lines (RCP seal water supply) are connected to a D

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. closed safety-grade system outside containment which constitutes an appropriate isolation barrier in lieu of a valve outside contain-ment. Therefore, the containment isolation pr.ovisions satisfy GDC 55 on some other defined basis.

The containment isolation provisions for lines P-7 and P-10 satisfy the explicit requirements of GDC 55 and are therefore acceptable.

2.

Class II penetrations "This piping is n' rmally open to the re-o acto'r containment atmosphere. At least two check valves in series, one inside and one outside the containment, are provided in these lines."

GDC 56 applies to Class II lines. GDC 56 specifies that one valve should be located inside containment and one valve should be located outside containment, with the valves being either locked closed or automatic isolation valves.

Furthermore, a simple check val.ve outside containment may not be used as an automatic isolation valve. The fol-lowing lines are included in this class:

P-4, P-12A, P-23A, P-238, P-28, P-29, P-34, P-38, P-60, P-61, P-64, P-65, P-66, P-67, P-69, P-70 and P-72.

The containment isolation provisions for lines P-4, P-12A,, P-23A and P-64 differ from the explicit requirements of GDC 56 from the stand-point of valve location; these lines have two automatic isolation valves in series outside containment. Locating both containment iso-lation valves outside containment may be acceptable if the criteria used in the design of the piping between the containment and the i

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first valves are sufficiently conservative to provide adequate as-surance of integrity. This matter should be addressed in the inte-grated assessment of the plant.

The containment isolation provisions for line P-23B consist of an automatic isolation valve outside containment and sealed pressure taps inside containment. GDC 57 may apply and, therefore, the sin-gle automatic isolation valve may be acceptable, if the licensee can jus'tify that the sealed pressure taps constitute an appropriately designed closed system inside containment.

If this can not be shown, the explicit requirements of GDC 56 must be met.

Lines P-28 and P-38 are equipped with a check valve inside containment, and lines P-29 and P-34 are equipped with an air-operated, automatic isolation valve outside containment. These lines provide for the sup-ply and discharge of reactor coolant pump bearing and thermal barrier cooling water. The isolation provisions differ from the explicit re-quirements of GDC 56 from the standpoint of valve number. Since the lines are non-essential, the isolation provisions should be upgraded to meet the explicit requirements of GDC 56. An automatic isolation valve should be added to lines P-28 and P-38 outside containment, and an automatic isolation valve should be added to lines P-19 and P-34 i

inside containment.

The containment isolation provisions for lines P-61 and P-67 consi;t '

of a single automatic isolation valve located outside containment.

A redundant automatic isolation valve should be provided in each line inside containment, to meet the explicit requirements of GDC 56.

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Line P-72A is the high containment pressure sensing line for actuation of engineered safeguards in the event of a high energy line break acci-dent. Because of its important safety functiQn, isolation valves are not provided in the line, which is acceptable.

The containment isolation provisions for lines P-60, P-66 and P-69 dif-fer from the explicit requirements of GDC 56 from the standpoint of valve number. Each of these lines has a simp,le check valve inside containment, with no valve outside containment being identified as a containment isolation valve. Since these lines are non-essential, the isolation provisions should be upgraded to meet the explicit re-quirements of GDC 56.

For lines P-65 and P-70, two check. tlvas in series, one inside and one outside containment, are identified as the containment isolation valves. This does not satisfy the explicit requirements of GDC 56 with respect to valve type. Asimplecheckvalveoutsidec5ntainment is not an appropriate automatic isolation valve; either a power oper-ated automatic isolation valve or a sealed closed valve should be pro-vided to satisfy GDC 56.

3.

Class III penetrations "These lines are in normal operation but are separated from the reactor coolant system and the containment at-mosphere by a single wall or other merbrane.

Steam and feedwater pip-ing to the steam generators are included in this class. The outgoing lines are provided with at least one automatically cperated trip valve located outside the containment. The incoming lines require at least one check valve located directly inside the containmant."

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- 15 The following lines a're included in Class III:

P-15, P-16, P-17, P-18, P-42, P-43. P-44, P-45, P-46, P-47, P-48, P-49 and P-81. They are the blowdown, main steam and feed water piping serving the steam generators which constitute a closed system inside containment.

Therefore, GDC 57 applies to this class of lines. GDC 57 specifies that a single automatic, remote manual or. locked closed isolation valve should be provided outside containment; furthermore, a simple check valve may not be used as the automatic isolation valve.

The isolation provisions for lines P-15, P-16, P-17, P-18, P-42, P-43, P-44, P-45 and P-81 are acceptable.

Lines P-46, P-47, P-48 and P-49 are the main feedwater lines. Each line has a check valve inside containment, and a flow control valve, in series outside containment, and a remote manual valve in a bypass

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line around the flow control valve. There is insufficient information regarding the isolation capability of the main feedwater flow control valves and the administrative control exercised over the bypass valves, to make a judgment on their acceptability as containment isolation valves. The licensee should provide this information.

4.

Class IV penetrations "This piping is connected to the containmer.:

atmosphere, but is normally closed during reactor operation. These lines are provided with isolation valves or flanged closures located outside the containment. Locks, interlocks or administrative proce-dures insure that these lines are closed whenever containment integrity is required."

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, GDC 56 applies to Cla'ss IV lines. The following penetrations are in-cluded in Class IV: P-11A, P-118, P-11C, P-11D, P-12B, P-13, P-14, P-20, P-22, P-23D, P-30, P-33, P-39, P 40, P-41, P-50, P-62, P-63, P-68, P-71, P-78 and P-80.

Containment isolation provisions for lines P-11A, P-11B, P-IIC, P-11D and P-230 differ from the explicit reqirements of GDC 56 from the standpoint of valve number. Each of these lines has an air oper-ated automatic isolation valve (for lines P-11A, P-118, P-11C, P-110) or a locked closed valve (for lines P-22 and P-23D) located outside containment, and no isolation valve identified inside containment.

The isolation provisions for these non-essential lines should be up-graded to meet GDC 56.

Containment isolation provisions for lines P-128, P-13, P-14, P-33, P-41, P-71 and P-78 differ from the explicit requirements of GDC 56 from the standpoint of valve location. Redundant isolation valves are provided for these lines outside containment. The acceptability of this is contingent on the criteria used in the deign of the pip-ing between the containment and first valve; i.e., the piping design should provide adequate assurance of integrity. This matter should be addressed in the integrated assessment of the plant. -

Containment isolation provisions for lines P-30 P-6? and.P-68 dif-fer from the explicit requirements of GDC 56 from the standpoint of valve type. These lines are equipped with two check valves in e * -

- 17 series, one inside and one outside the containment. A simple check valve outside containment is not an appropriate automatic isolation valve; a power operated automatic valve should be provided outside -

containment.

Line P-50, the fuel transfer tube, is equipped with a closed gate valve and a blank flange outside containment. The blank flange does not satisfy the explicit requirements of GDC -56 with respect to the type of isolation barrier. However, a blank flange is an acceptable isolation barrier in lieu of an isolation valve if it is leak test-able. The licensee should address the leak testing provisions for the blank flange.

The isolation provisions for line P-63 satisfy the explicit require-ments of GDC 56.

The containment isolation provision for line P-20, the nitrogen sup-ply to the Pressurizer Relief Tank (PRT), differ from the explicit re-quirements of GDC 56 from the standpoint of valve type. A check valve inside containment and a pressure control valve (PCV 407) outside con-tainment is provided for containment isolation..For the PCV to be an acceptable isolation valve, it must satisfy the requirements for an automatic isolation valve. PCV 407 maintains the downstream pressure at a prescribed pressure.

If the downstream pressure is elevated, e.g., in the event of an accident, PCV 407 will automatically close.

If the downstream pressure drops below the prescribed value, PCV 407 will open in an attempt to raise the downstream piping pressure.

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, light of this, the performance characteristics of the valve controls do not satisfy the requirements for an automatic isolation valve.

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Consequently, line P-20 should be provided with an automatic isolation valve.

The isolation provisions for the containment purge system exhaust (P-39) and supply lines 'o-40) differ from the explicit requirements of GDC 56 from the standpoint of isolation barrier type. Locked closed isolation valves are provided inside containment, which is acceptable, but blind flanges are provided outside containment. Blind flanges are acceptable alternate isolation barriers provided they are leak testable; the licensee should address this aspect.

The isolation provisions for the containment fire water supply line (P-80) differ from the explicit requirements of GDC 56 from the stand-point of the number of valves. The licensee only identifies a single check valve inside containment for isolation of the line. However, a motor operated valve (MOV 31) is shown outside containment, which may also be a suitable containment isolation valve. Since the isolation provisions for line P-80 should be upgraded to meet GDC 56, the licen-see should describe the design and operating characteristics of MOV 31, and the written procedures in effect to control its use, to justify the acceptability of the valve for containment isolation.

5.

Class V penetrations "These lines penetrate the containment, but are part of systems which are closed both inside and outside the Reactor Containment. Manual shutoff valves, located outside the containment, are provided in these lines."

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. GDC 57 applies to this class. The following lines are included in Class V:

P-51, P-52, D-53, P-54, P-55, P-56, P-57 and P-58.

Containment isolation provisions for the containment fan cooler sup-ply and discharge lines (P-51, P-52, P-53, P-54, P-55, P-56, P-57 and P-58) differ from th'e explicit requirements of GDC 57 from the stand-point of valve number. There is no valve identified as a containment isolation valve on either the supply or discharge lines.

Each line should be equipped with a power operated remote manual isolation valve outside containment, to satisfy GDC 57. Since these lines have a post-accident safety function (containment heat removal), automatic isola-tion is not appropriate.

6.

Special Cases:

The equipment hatch is closed by a single double-gasketed bolted door.

The door gaskets are leak testable.

The personnel hatch is mounted in the equipment hatch, and consists of a hydraulically latched double door.

An equalizing valve connects the personnel hatch with the interior of the containment to equalize any pressure differential between the, containment and the personnel hatch.

The personnel hatch and the door gaskets are lea'k testable.

7.

Leak Detection Provisions:

l Where remote manual isolation valves are used, the capability to de-tect system leakage to alert the operator of the need to isolate a line should be provided. The licenseee should address this issue.

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i 1 VI Conclusions The following summarizes the evaluation of the containment isolation provisions, including deviations from the review guidelines that have been identified and described in Section V of this report:

1.

The penetrations listed below have two isolation valves in series outside containment:

P-4, P-12A, P-123, P-13, P-14, P-23A, P-33, P-41, P-71 and P-78.

The acceptability of locating both valves outside containment is contingent on the acceptability of the piping design criteria. Also, the licensee should discuss the unique characteristics of the valve closest to the containment to terminate valve shaft or bonnet seal ieakage, or the provisions in the plant for conttol of leakage.

2.

The penetrations listed below have simple check valves outside containment in series with other valve types or check valves:

P-3, P-30, P-65, P-68 and P-70.

A simple check valve located outside containment is not an appropriate automatic isolation valve. The judgment regarding its acceptability should be made in conjunction with the integrated assessment of the plant.

3.

The following penetrations have remote manual valves in lieu of automatic isolation valves:

P-1, P-2 and P-8.

Since these lines are essential; i.e., have post-accident functions, automatic iso-lation of these lines is not desirable, and the remote manual valves are acceptable. Also, certain lines should have remote manual isolation valves, such as line P-81, but do not. For lines having remote manual valves, provisions should be made I

l i

- 21 tc allow the operator in the control room to know when to isolate fluid systems equipped with remote manual isolation valves (SRP 6.2.4, Item II.11).

4 The following penetration has manual valves serving-as containment isolation valves:

P-20. A local manual valve is not an accept-able containment isolation valve. The licensee should implement administrative controls on all manual valves used for containment isolation.

5. 'The following penetrations have no isolation valves-identified:

P-51, P-52, P-53, P-5 4, P-55, P-56, P-57 and P-58.

The licensee should justify t,he applicability of GDC 57 and provide isolation capability which meets GDC 57 requirements.

6.

The following penetrations have only one isolation valve identi-fied: P-11A, P-11B, P-11C, P-11D, P-22, P-23C, P-23D, P-24A, P-248, P-24C, P-240, P-28, P-29, 'P-34, P-38, P-60, P-61, P-66, P-67, P-69 and P-80.

Since they are non-essential lines, the isolation provisions should be upgraded to meet GDC 55 and 56.

7.

The following penetrations have lines equipped with blind (blank) flanges:

P-39, P-:40, P-50 and P-70.

4 A blind flange, either inside or outside containment, is an accept-able isolation barrier in lieu of an isolation valve.' However, a l

l blind flange without leak testing provisions is not a suitable l

l isolation barrier.

8.

GDC 55 and 56 specify that automatic isolation valves should, upon loss of actuating power, take the position that provides greater 9

' ' '~~

m 9

.. safety. The position of an isolation valve for normal and shutdown operating conditions, and post-accident ' conditions, depends on the fluid system function.

In the event of power failure to a valve operator, the valve position should be consistent with the line function.

In this regard, separate power supplies for isolation valves in series may be required to assure the isolation of non-essential lines. Since there is no information available which discusses whether and how power operated valves change position on

-loss of actuating power, the licensee should provide this informa-tion.

9.

It is noted that many lines have branch lines, serving as vent, drain, test or sample lines, containing local manual valves. These valves are typically not accounted for (but should be) in the compi-lation of containment isolation valves. Nevertheless, for these valves to be effective containment isolation valves, they must be administratively controlled closed, and, as the case may' be, there must be written procedures in effect governing their use during normal plant operation. The licensee should address this matter.

10. In order to assure that the containment isolation system review is accurate and complete..the licensee should provide the following t

information for all containnent penetrations in tabular form:

a.

Containment penetration number; b.

System affiliation /line function; c.

Fluid contained; d.

Line size (inches);

o <

m,

. s uw

- 23 e.

Essential or non-essential; Reference to P&ID showing arrangement,of containment isola-f.

tion barriers (include updated P& ids, if available);

1 g.

Isolation valve number; a

n h.

Location of valve (inside or outside containment);

1.

Valve type and operator;

j. Primary mode of valve actuation;

'k.

Secondary mode of valve actuation; s

1.

Normal valve position; m.

Shutdown valye position; l

n.

Post-accident valve position; a.

Power failure valve position; p.

Containment isolation signals (including parameters. sensed);

q.

Valve closure time; and r.

Power source.

VII Reference 1.

Facility Description & Safety Analysis, Vols.1 & 2, Connecticut Yankee Atonic Power.Co. Topical Report No. 3250-5, Haddam Neck Plant.

2.

CYAPC0 (W. G. Counsil) letter to NRC (B. Grier), dated April 24, 1979, regarding responses to IE Bulletin 79-06A, Rev.1.

3.

CYAPC0 (D. W. Switzer) letter to NRC (B. Grier) dated May 18, 1979, regarding responses to IE Bulletin 79-06A, Rev.1.

t O

I e

l e-w. m a h ame 4 = e m e.-

e

4.

CYAPC0 (W. G. Cou'nsil) letter to NRC (D. L. Ziemann), dated June 29, 1979, regarding Inservice Inspection and Testing Program.

5.

CYAPC0 (W. F. Fee) to NRC (H. R. Denton), dated December 14, 1979, regarding Modifications of Containment Isolation.

6.

CYAPC0 (W. G. Counsil) letters to NRC (D. M. Crutchfield), dated April 8 and November 20, 1981, regarding SEP Tepic VI-7.B ESF Switenover.

i 7.

CYAPC0 (R. H. Graves) letters to NRC (R. C. Haynes), dated Novem-ber 20, 1981 and January 26, 1982, regarding Licensee Event Report LER 81-18/3L.

8.

CYAPC0 (W. G. Counsil) letter to NRC (D. M. Crutchfield), dated December 14, 1981, regarding Safety Assessment Report, SEP Topic IX-5, Ventilation Systems.

9.

FRC (S. P Carfagnc) letter to NRC (E. J. Butcher, Jr.), dated August 24, 1981, regarding Technical Evaluation Report on Systems Need for Safety Shutdown.

10. The Haddam Neck plant design drawings:

10899-RM-5A; 10899-RM-6A; 10899-RM-7A; 10599-FM-9A; -

E. D. Sk. 3127 46-F; E. D. Sk. 3127 47-F; E. D. Sk. 298042-F; E. D. Sk. 298044-F; E. D. Sk. 298041-F.

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CONTAINMENT ISOLATION SYSTEM PLANT: NADDm ^ket P/Avr SEP REVIEW FINDfNGS

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PAGE 4 OF '7

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TABLE 1

CONTAINMENT ISOLATION SYSTEM Pl.A N T: HAmdu Akck' Plaar SEP REVIEW FINDYNGS

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CONTAINMENT ISOLATION SYSTEM PLANT:hhmiO Aleck' pinar SEP REVIEW FINDfNGS

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PAGE 5 OF '7 lk = M D//

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CONTAINMENT ISOLATION SYSTEM PLANT:NADoan WreK Pinnr SEP REVIEW FINDINGS

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EXCEP770NS

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