ML20153B718
| ML20153B718 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 05/02/1988 |
| From: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20153B723 | List: |
| References | |
| B12902, NUDOCS 8805060066 | |
| Download: ML20153B718 (3) | |
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L J $(($[$.7, (203) 665-5000 May 2, 1988 Docket Nos. 50-213 50-245 B12902 Re: 10CFR50, Appendix J Hr. William T. Russell, Regional Administrator Region I U.S. Nuclear Regulatory Comission 475 Allendale Road King of Prussia, PA 19406 Gentlemen:
Haddam Neck Plant Hillstone Nuclear Power Station, Unit No. I 10CFR50. Accendix J By letter dated August 31,1987,II) Connecticut Yankee Atomic Power Company (CYAPC0) and Northeast Nuclear Energy Company (NNECO) committed to provide the Staff with the results of CYAPCO's and NNECO's review of containment isolation valve (CIV) reverse direction testing at the Haddam Neck Plant and Hillstone Unit Nos. 1, 2, and 3.
This review was undertaken to satisfy a Staff request to assure that potential containment boundaries are not inappropriat9ly omitted from 10CFR50, Appendix J local leak rate tests (LLRTs) in which reverse direction testing is utilized.
Specifically, CYAPC0 and NNEC0 developed an action plan to address the four criteria established in Reference (1).
Using this plan of action, CYAPC0 and NNECO committed to provide the Staff with the results of the review fg all four plants by February 29, 1988.
In a letter dated f 29, 1988, the NRC Staff was informed that NNECO had completed itst,ebruary assessment at Hillstone Unit No 2 and 3 and determined that no potential containment boundaries have been omitted from Appendix J leakage tests due to reverse direction testing.
In addition,
'.he NRC Staff was informed that CYAPC0 and NNECO planned to (1)
E. J. Hroczka letter to W. T. Russell, "Haddam Neck Plant, Hillstone Nuclear Power Station, Unit Nos. 1, 2, and 3, 10CFR50, Appendix J," dated August 31, 1987.
(2)
E. J. Hroczka letter to W.
T. Russell, "Haddam Neck Plant, Hillstone Nuclear Power Station, Unit Nos. 1, 2, and 3, 10CFR50, Appendix J," dated Felsruary 29, 1988.
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I 8005060066 880502 PDR ADOCK 05000213 J
P DCD 1
U.S. Nuclear Regulatory Commission B12902/Page 2 May 2, 1988 submit the results of our assessment of the reverse direction testing programs for the Haddam Neck Plant and Millstone Unit No. I by May 2, 1988.
The results of the assessments for the Haddam Neck Plant and Millstone Unit No. I are provided in Attachments 1 and 2, respectively.
Appendix J to 10CFR50 str.tes that containment isolation valves (CIVs) must be leakage tested at design basis accident (DBA) pressure.
In general, test pressure must be applied in the same direction as it would be during a DBA.
This type of LLRT is called a "direct pressure" test.
In certain circumstances, Appendix J permits test pressure to be applied to a valve in a direction opposite to that associated with a DBA.
This type of testing is called "reverse direction" testing.
CIVs that have disc / seat configurations which prevent stem
- packings, body-to-bonnet joints, or actuator shaft seals from being pressurized during reverse direction LLRTs 50-245/87-18.g of concern to the NRC as described in Inspection Report No.
This report stated that the lack of inclusion of packings and seals in LLRTs may be an unjustified omission of potential containment boundaries from a plant's Appendix J testing program.
Figure 1 provides an illustrative example of this issue.
At the start of this assessment, it was established that CIVs inside containment are not subject to the reverse direction testing concerns of Reference (3).
This is based on the premise that the inner containment boundary ends at the disc / seat interface.
Packings and seals on the containment side of this interface are only boundaries between different regions of the containment (as illustrated in Figure 2).
Leakage through these inboard packings and seals (e.g.,
reactor coolant to containment atmosphere or vice-versa) does not contribute to the of f-site dose consequences of a DBA.
Since the leak tightness of packings and seals on the inboard sides of reverse direction tested CIVs inside containment is not important to containment isolation, it is of no consequence if these packings and seals are omitted from LLK7s.
This premise permitted all CIVs located inside containment to be elin:Inated from further evaluation with regard to the concerns of Reference (3).
Using the plan of action discussed in Reference (1) and the premise discussed above, the assessment of reverse direction testing at the Haddam Neck Plant and Millstone Unit No.1 yielded the results provided in Attachments 1 and 2, respectively.
(3)
W. V. Johnston letter to E. J. Mroczka, "Inspection No. 50 245/87-18,"
dated Septenber 23, 1987.
U.S. Nuclear Regulatory Commission B12902/Page 3 May 2, 1988 If you have any questions on this matter, please feel free to contact my staff.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY h,d.NnctrIM.
E. J. Mroczka Senior Vice President L CWL By: C. F. Sears Vice President cc:
U.S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, D.C.
20555 A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant M. L. Boyle, NRC Project Manager, Millstone Unit No.1 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2 and 3
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