ML20053C326

Requests Addl Containment Purge & Vent Info within 45 Days, in Support of Review of Licensee Response to NRC . Info Needed Includes Schedule for Installing Debris Screens, Valve Operability & Safety Actuation Override

ML20053C326
Person / Time
Site:	Maine Yankee
Issue date:	05/21/1982
From:	Clark R Office of Nuclear Reactor Regulation
To:	Garrity J Maine Yankee
References
NUDOCS 8206010667
Download: ML20053C326 (13)

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MAY 211982 DISTRIBUTION:

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/Afocket File WButler NRC PDR MHaughey L PDR Gray File Docket No. 50-309 NSIC I

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JHeltemes Mr. John H. Garrity, Senior Director OELD EDED Nuclear Engineering and Licensin9 I&E tr MAY g 7ggb Q Maine Yankee Atomic Powe:r Company ACRS-10 C

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83 Edison Drive RAClark Q%ax [*

Augusta, Maine 04336 PMKreutzer

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Dear Mr. Garrity:

In our letter of November 29, 1978, we identified the generic concerns of purging and venting of containments to all operating reactor licensees and requested your response to these concerns. Our review of your response Con-was interrupted by the TMI accident and its demands on staff resources.

sequently, as you know, an Interim Position on containment purging and venting was transmitted to you on October 23, 1979. You were requested to implement short-term corrective actions to remain in effect pending completion of our longer-term review of your response to our November 29, 1978 letter.

Over the past several months we and our contractors have been reviewing the responses to our November 1978 letter to close out long-term review of this rather complex issue. The components of this review are as follows:

1.

Conformance to Standard Review Plan Section 6.2.4 Revision 1 and Branch Technical Position CSB 6-4 Revision 1.

These documents were provided as enclosures to our November

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1978 letter.

2.

Valve Operability Although the Interim Position allowed blocking of the valves at partial-open positions, this is indeed an interim position. Ear-lier we requested a program demonstrating operability of the valves in accordance with our " Guidelines for Demonstrative Operability of Purge and Vent Valves." These Guidelines were sent to you in our letter of September 27, 1979. There is an acceptable alternative

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which you may wish to comider in lieu of completing the valve qualifi-cation program for the large butterfly-type valves. This would be the installation of a fully-qualified mini-purge system with valves 8 -inches or smaller to bypass the larger valves. Such a system change might prove more timely and more cost-effective. The system would meet BTP CSB 6-4 item B.I.c.

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OFFICE )

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uncvonusss neosuncuc2n OFFICIAL RECORD COPY usam m,_,,,,

Mr. John H. Garrity, Senior Director 3.

Safety Actuation Signal Override This involves the review of safety actuation signal circuits to ensure that overriding of one safety actuation signal does not also cause the bypass of any other safety actuation signal.

4.

Containment Leakage Due To Seal Deterioration i

Position B.4 of the BTP CSB 6-4 requires that provisions be made to test the availability of the 4 solation function and the leakage rate of the isolation valves in the vent and purge lines, individually during reactor operations.

But CSB 6-4 does not explain when or how these tests are to be perfomed.

, is an implification of Position B.4 concerning these tests.

The status of our long-term review of the above items for MainbYankeef t 1 is as follows:

l.

Conformance lo Standard Review Plan Section 6.2.4 Revision 1 and Branch Technical Position CSB 6-4 Revision 1 A.

The issuance of the enclosed partial Safety Evaluation Report (Enclosure 2) resolves this item subject to the three conditions discussed therein and repeated here:

l a.

Install debris screens in the purge supply and exhaust lines.

(Staff guidelines for evaluating t

these screens are presented in Enclosure 3.)

b.

Commit to limit the use of the purge system to a specified annual time that 1: commensurate with identified safety needs.

c.

Propose a Technical Specification which requires that you perf6rm-leakage integrity tests of the isolation valves in the containment purge lines at least once every three months.

i You are requested to respondato the above items a and b within 45 days of the date of this letter.

For item a please provide your si:hedule for installing the debris screens. The technical specifications requested in item c shoulti be proposed within 60 days of receipt of this letter. These technicil specifi-

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cations are discussed below in paragraph 4 of thislietter and a model for this technical specification is included as part of Enclosure ?.

2.

Valve Operability Brookhaven flational Laboratories, in conjunction with the flRC staff, omee >

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OFFIClAL RECORD COPY uso %.- m eco hRC FORM 318 (10@) NRCM 02c

ss Mr. John H. Garrity, Senior Director

• i has reviewed your submittal of May 1,1981 regcrding this subject.

We have detemined that the additional infomat!on identified in is necessary to complete our review < Please provide j

this infomation within 45 days of the date of this letter.

3.

Safety Actuation Override This item is still under reHew.

It is noted that a somewhat parallel review of engineered safety features reset is being carried out in conjunction with I&E Bulletin 80-06. That review will be handled separately outside the framework of the purge and vent review.

4.

Containment Leakage Due to Seal Deterioration We request that you propose a Technical Specification chanJe incorporating the test requirements together with the cita11s 1

of your proposed test program within 60 days of receipt of this letter.

In closing, you may have noted the similarity of this long-term genric issue with Item II.E.4.2 of NUREG-0737, TMI Action Plan. Except fot-Positions 5, 6, and 7 of Item II.E.4.2, the review of the remaining eut-standing positions of Item II.E.4.2 will be completed by this purge aod vent review. Our schedule of the purge and vcut review agrees with tia 4

schedule for Item II.E.4.2 Our acceptance of Maine Yankee with respec+.

to Item II.E.4.2 (5) has been documee.ted in our letter dated January 18, 1982. Thus, your assistance in completing the outstanding purge and vent items, noted above, is necenary to complete Item II.E.4.2.

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'Please contact your hRC Project !?anager should you have any questions.

Sincerely, Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing

Enclosures:

As stated cc: See next page t

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. NRC FORM 318 00-80) NACM oao OFFIClAL RECORD COPY usam mi-meeo

TJaVne Vandee AtomUc Vower Company cc[ E4 W. T'hurlow, President Judith M. Barrows, President Maine Yankee Atomic Power Company SAFE POWER FOR MAINE Edison Drive Post Office Box 2204.

Augusta, Maine 04336 Augusta, Maine 04330 Mr. Donald E. Vandenburgh First Selectman of Wiscasset Vice President - Engineering Municipcl Building Yankee Atomic Electric Company U. S. Route 1 20 Turnpike Road Wiscasset, Maine 04578 Westboro, Massachusetts 01581 John A. Ritsher, Esquire Atomic Safety and Licensing Board Ropes & Gray U.S. Nuclear Regulatory Commission i

225 Franklin Street Washington, D. C.

20555 Boston, Massachusetts 02110 David Santee Miller, Esq.

Mr. Rufus E. Brown 213 Morgan Street, N. W.

Deputy Attorney General Washington, D. C.

20001 State of Maine Augusta, Maine 04330 Mr. Paul Swetland Resident Inspector / Maine Yankee Mr. Nicholas Barth c/o U.S.N.R.C.

Executive Director P. O. Box E Sheepscot Valley Conservation Wiscasset, Maine 04578 Association, Inc.

P. O. Box 125 Mr. Charles B. Brinkman Alan, Maine 04535 Manager - Washington Nuclear Operations Combustion Engineering Inc.

Wiscasset Public Library Association 4853 Cordell Avenue, Suite A-1 High Street Bethesda, Maryland 20014 Wiscasset, Maine 04578 Mr. Robert H. Groce Mr. Torbet H. Macdonald, Jr.

Senior Engineer - Licensing Office of Energy Resources Maine Yankee Atomic Power Company State House Station #53 1671 Worcester Road Augusta, Maine 04333 Framingham, Massachusetts 01701 l

Robert M. Lazo, Esq., Chairman l

Atomic Safety and Licensing Board U.S. Environmental Protection Agency U.S. Nuclear Regulatory Co?. mission Region I Office Washington, D. C.

20555 ATTN:

Regional Radiation Representative JFK Federal Building Dr. Cadet H. Hand, Jr., Director Boston, Massachusetts 02203 Bodega Marine Laboratory University of California Bodega Bay, California 94923 i

l Mr. E. C. Wood, Plant Manager l

Maine Yankee Atomic Power Company State Planning Officer P. O. Box 3270 Executive Department Wiscasset, Maine 04578 189 State Street l

Augusta, Maine 04330 i

Regional Administrator Nuclear Regulatory Commission, Region I l

Office of Executive Director for Operations 631 Park Avenue King of Prussia, Pennsylvania 19406 I

PURGE / VENT VAQE_ LEAKAGE TESTS

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l The long tenn resolution of Generic Issue B-24, " Containment Purging During Normal Plant Operation," includes, in part, the implementation of~

Item Bs4 s cifies Item B.4 of Branch Technical Position (BTP) CSB 6-4.that provision purge / vent i

system) isolation valves, individually, during reactor operation. Although i

Item B.4 does not address the testing frequency, Appendix J to 10 CFR Part 50 specifies a maximum test interval of 2 years.

As a result of the numerous reports on unsatisfactory perfonnance of the resilient seats for the isolation valves in containment purge and vent fines (addressed in OIE Circular 77-11, dated September 6,1977), Generic Issue -

B-20, " Containment Leakage Due to Seal Deterioration," was established to evaluate the matter and establish an appropriate testing frequency for the isolation valves. Excessive leakage past the resilient seats of isolation valves in purge / vent lines is typically caused by4evere environmental con-Consequently, the leakage test ditions and/or wear due to frequent use.

frequency for these valves should be keyed to the occurrence of severe environ.

mental conditions and the use of the valves, rather than the current require-ments of 10 CFR 50, Appendix J.

It is re' commended that the fbilowing provision be added to the Techntcal-Specifications for the leak testing of purge / vent line isolation valves:

" Leakage integrity tests shall be performed on the containment isolation valves with resilient ma.terial seals in (a) active purge / vent systems (i.e., those which may be operated during

. plant operating Modes 1.through 4) at le~ast once every. three months and (b) passive purge systems (i.e., those which must be administrative 1y controlled closed during reactor operating Modes 1 through 4) at least once every six months."

By way of clarification, the above proposed surveillance specification is predicated on our expectation that a plant would have a need to go to cold To cover the possibility that this may shutdown several times a year.

However, it not occur, a maximum test interval of 6 months is specified.

is not our intent to require a plant to shutdown just to conduct the valve If if censees anticipate long duration power oper-s leakage integrity tests.

ations with infrequent shutdown, then installation of a leak test connection This that is accessible from outside containment may be appropriate.

It will not be will permit simultaneous testing of the redundant valves.

possible to satisfy, explicitly the guidance of Item B.4 of BTP CSB 6-4 _

(which states that valves should be tested individually), but at least some testing of the valves during react 3r operation will be possible.

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is intended that the above proposed surveillance specification be applied 1.e., the

+he active purge / vent lines, as well as passive purge lines:

..e lines that are administrative 1y controlled closed during reactor oper-The reason for including the passive purge lines is that

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20 is concerned wtih the potential adverse effect of seasonal weather con-Consequently, passive

., -ditions on the integrity of the isolation valves.

purge lines must also be included in the surveillance program.

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The purpose of the leakage integrity tests of, the isolation valves in the containment purge and vent lines is to identify excessive degradation of the resilient seats for these valves. Therefore, they need not be conducted with the precision required for the Type C isolation valve tests in 10 CFR These tests would be performed in addition to the Part 50, Appendix J.

quantitative Type C tests required by Appendix J and would n In view of the wide variety of valve types and seating materials, the acceptance criteria for such tests should be developed on a plant-specific basis.

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Request for Additional Information Maine Yankee Atomic Power Plant Containment Purge and Vent Valve Operability 42 Inch Valves 1.

Where operators are equipped with a manual mode of operation (e.g. handwheels)

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does their design provide for automatic re-engagement of the automatic mode of operation following the manual mode of operation? If not, describe the procedures used to assure the valve is not left in the manual mode of operation following maintenance or test operations.

2.

Describe the periodic maintenance and inspection programs for these valves.

'8 Inch Valve 1.

The purge system contains an eight inch globe valve. This valve is in a bypass line around the 42 inch valve VP-A-3.

Describe the method used to show this valve is capable of closing under accident loads (e.g.

seismic,LOCA,etc.)

_ GUIDELINES FOR USE IN EVALUATION OF PURGE AND VENT SYSTEM DEBRIS SCREEN DESIGN The debHs screen should satisfy the following criteria:

The ' debris screen should be seismic Category I design and installed abou 1.

U one pipe diameter away from the inner sid'e of the inboard isolation valve.

2.

The piping between the dbbris screen and the isolation va'lve should also be seist.ic Category I design.

3.

The debris screen should be designed to withstand the LOCA differential pressure.

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The debris s'creen should be designed similar.to that shown in the attached

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Enclosura 2 PARTIAL SAFETY EVALUATION REPORT FOR CONTAINMENT PURGING AND VENTING DURING NORMAL OPERATION OF THE MAINE YANKEE !')MIC POWER PLANT (Docket No. 50-309)

I.

INTRODUCTION A number of events have occurred over the past several years which directly relate to the practice of containment purging and venting during normal plant operation. These events have raised concerns relative to potential failures affecting the purge penetrations which could lead to degradation in containment integrity, and, for PWRs, a degradation in ECCS performance.

By letter, dated November 9,1978, the Commission (NRC) requested aLL Licensees of operating reactors to respond to' certain generic concerns about containment purging or venting during normal plant operation.

The generic concerns were twofold:

(1)

Events had occurred wi.ere ' Licensees overrode or bypassed the safety actuation isolation signals to the containment isolation valves. These events were determined to be abnormal occurrences and were so characterized in our report to Congress in January 1979.

l (2)

Recent Licensing reviews have required tests or analyses to show that containment purge or vent valves would shut without degrading containment integrity during the dynamic loads of a design basis loss of coolant accident (DBA-LOCA).

The NRC position of the November 1978 letter requested licensees to cease purging (or venting) of containment or limit purging (or venting) to an absolute minimum. Licensees who elected to purge (or vent) the containment were requested to demonstrate that the containment purge (or vent) system design met the criteria outlined in the NRC Standard Review Plan (SRP) 6.2.4, Revision 1, and the associated Branch Technical Position (BTP) CSB 6-4, Revision 1.

II.

DISCUSSION AND EVALUATION The Purge / Vent System at Maine Yankee consists of two 42-inch penetrations (supply and exhaust lines) for purging the containment atmosphere to f acilitate personnel access. Two 42-inch butterfly valves are arranged in series to provide isolation redundancy in each penetration. The inboard isolation valve of the exhaust line is bypassed by one 8-inch globe valve used for containment depressurization prior to purge initiation.

The licensee responded to the NRC position letter of November 1978, by indicating that they planned to justify unlimited purging, but that they would minimize the number of purges performed dusing power operations.

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The licensee reported that their analysis indicated that the ECCS backpressure (containment pressure) has negligible effect on ECCS performance.

Further, the licensee calculated the quantity of steam and air mixture which will be expelled f rom the containment under DBA-LOCA conditions before the purge valves are closed to be 16001bM of air and 10401bM of steam.

The Licensee has not provided sufficient information concerning the provisions made to ensure that isolatiion valve closure wiLL not be prevented by debris which could potentially become entrained in the escaping ai~r and steam.

We recommend that debris screens shoulo be provided for the purge j

supply and exhaust ductwork. Also, the debris screens shogld be seismic 1

Category 1 design and installed about one pipe diameter away from the inner side of the inboard isolation valve.

The piping between the debris screen and the isolation valve should also be seismic Category I design.

The Licensee indicates that there is no safety related equipment located downstream of the containment isolation purge / vent valves.

III.

CONCLUSION he have re vi ew ed t h e Maine Yankee Purge System against the guidelines of BTP CSB 6-4, Revision 1, " Containment Purging During Normal Operations."

Although the li certs ee provided information to justif.y unlimite'd purgi.ng during power operations, our v ew'is that system use should be limited.

The plant is inherently safer with closed purge valves than with open Lines which require valve action to provide.

containment integrity.

We, therefore, recommend that the Licensee commit to limit the use of the purge system to a specified annual time that is commensurate with identif.is.i.

. safety needs.

. l

We recommend that debris screens.be provided for the purge supply and exhaust Lines.

The debris screens should be seismic Category I design and installed about 'one pipe diameter away from the inner side of each, inboard isolation valve.

The piping between the debris screen and the isolation

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e valve should aLso meet seismic Category I design standards.

In addition, as a result of numerous reports on the unsatisfactory performance of resilient seats in butterfly-type isolation valves due to seal deterioration, periodic Leakage integrity tests of the 42-inch butterfly-isolation valves in the purge system are necessary. Therefore, the licensee,s should also propose a Technical Specification for testing the valves in accordance with the following testing frequency:

"The Leakage integrity tests of the isolation valves in the containment purge / vent Lines shaLL be conducted at least once T

every three months."

The purpose of the leakage integrity tests of the isolation valves in the containment purge lines is to identify excessive degradation of the resilient seats for these valves. Therefore, they need not be conducted with the precision required for the Type C isolation valve tests in 10 CFR Part 50, Appendix J.

These tests would be performed in addition to the quantitative Type C tests required by Appendix J and would not relieve the Licensee of the isibility to conform to the requirements of Appendix J. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _.

4 ENCLOSURE 4

CONTAINMENT SYSTEMS

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LIMITING CONDITION FOR OPERATION The containment purge supply and exhaust iso'lation valves may 3.6.1.7 The '

be open for safety-related reasons [or shall be locked closed).

containment vent line isolation valves may be open for saf'ety-related reasons (or shall be locked closed).

'APPLICA3ILITY:

MODES 1, 2, 3, and 4.

ACTION:

(For plants with valves closed by technical spe,cification)

With one containment purge supply and/or one exhaust isolation valve open, close the open valve (s) within one hour or be in at least HOT STAMDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(For plants with valves that may be opened by technical specifications)

With' one containment purge supply and/or o.ne exhaust isolation or vent.

1.

valve inoperable, close the associated OPERABLE valve and either restore, the inoperable valve to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or lock the' OPERABLE valve closed.

Operation may then continue until perfomance of the next required 2.~' valve test provided that the OPERABL4 valve is verified to be locked

-losed at least once pe'r 31 days.

4 Otherwise, be in at 1 east HOT STANDSY within the next six hours and

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3.

in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The provisions of Specification 3.0.4 are not applicable.

4.

S'URVEILLANCE REOUIREMENTS

-inch containment purge supply and exhaust isolation valves The 4.6.1.7.1

-incTvent line isolation valves shall be determined locked closed" and the at least once per 31 days.

The valve seals of the purge supply and exhaust isolation valves 4.6.1.7.2 and the vent line isolation valves shall be replaced at least one per1 years.

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CONTAINMENT SYSTEMS 3/4 4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3 The containment isolation valves specified in Table 3.6-1 shall be OPERABLE with isolation times as shown in Table 3.6-1.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

With one or more of the isolation valves (s) specified in Table 3.6-1 inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and either:

Restore the inoperable valve (s) to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> a.

or Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at leas't b.

one deactivated automatic valve secured in the isolation position, or Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use 'of at least-c.

one closed manual valve or blind flange; or

:a_

Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD

'. d.

SHUTDOWN within the following 30 tours.

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SURVEkLLANCEREQUIREMENTS The iso.lation valves specified in Table 3.6-1 shall.be demonstated 4.6.3.1 OPERABLE prior to returning the valve to service af ter main'tenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test, and verification of isola-tion time.

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CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.6.3.2 Each isolation valve specified in Table 3.6-1 shall be demonstrated OPERABLE during the COLD SHUTDOWN or REFUELING MODE at least.once per 18 months by:

Verifying that on a Phase A containment isolation test signal, each a.

Phase A isolation valve actuates to its isolation position.

b.

Verifying that on a Phase B containment is.olation test signal, each-Phase B isolation valve actuates to its isolation position.

4.6.3.3 The isolation time of each power operated or automatic valve of Table 3.6-1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

4.6.3.4 The containment purge.and vent isolation valves shall be demonstated OPERABLE at intervals not to exceed months.

Yalve OPERABILITY.shall be determined by verifying that when th'e measuued leakage rate is added to the leakage rates determined pursuant to Specification 4.6.1.2.d for all other Type B and C penetration, the combined leakage rate is less than or equal to 0.60La.

However, the leakage rate for the contiinment purge and vent isolation valves.

shall be compared to the previcusly measured leakage rate to detect excessive 1

valve degradation.

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