ML20154A084

Forwards Request for Addl Info Re 840626 Submittal of Proposed App J Tech Specs Concerning Leak Test Program. Response Requested within 90 Days of Ltr Receipt

ML20154A084
Person / Time
Site:	Vermont Yankee
Issue date:	02/14/1986
From:	Rooney V Office of Nuclear Reactor Regulation
To:	Capstick R VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8603030287
Download: ML20154A084 (6)

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4 Docket No.: 50-271 l

l Mr. R. W. Capstick FEB 14 1980 Licensing Engineer Vemont Yankee Nuclear Power Corporation 1671 Worcester Road Framingham, Massachusetts 01701

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATI0'i - APPENDIX J TECHNICAL SPECIFICATIONS .-

Re: Vermont Yankee Nuclear Power Station We are reviewing your proposed Appendix J Technical Specifications dated June 26, 1984, and find that we need additional infomation to complete our review. We request that you provide responses to the enclosed request within 90 days of receipt of this letter.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Original cignolby; Vernon L Rooney, Project!bnager BWR Proj ect Directorate f2 Division c,' CHR Licensing

Enclosure:

DISTRIBUTION:

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Mr. R. W. Capstick Vemont Yankee Nuclear Power Corporation Vermont Yankee Nuclear Power Station CC:

Pr. W. F. Conway W. P. Murphy, Vice President &

President & Chief Executive Officer Manager of Operations Vermont Yankee Nuclear Power Corp. Verront Yankee Nuclear Power Corp.

R. D. 5 Box 169 R. D. 5, Box 169 Ferry Road Ferry Road Brattleboro, Vermont 05301 Brattleboro, Vemont 05301 Mr. Donald Hunter, Vice President Mr. Gerald Tarran~t Comissioner Vermont Yankee Nuclear Power Corp. Vermont'Oepartment of Public Service i

1671 Worcester Road 120 State Street Framingham, Massachusetts 01701 Montpelier, Yemont 05602 1

! New England Coalition en l

' Nuclear Pollution Hill and Dale Fam Public Service Board R. D. 2 Box 223 State of Vemont Putney, Vemont 05346 120 State Street Montpelier, Vermont 05602 Mr. Walter Zaluzny Chairman, Board of Selectman Vemont Yankee Decommissionirg Post Office Box 116 Alliance Vernon, Vemont 05345 Box 53 Montpelier, Verment 05602-0053 J. P. Pelletier, Plant Manager Vermont Yankee Nuclear Power Corp.

Post Office Box 157 Resident Inspector Vernon, Vement 05354 U. S. Nuclear Regulatory Comission i Post Office Box 176 Raymond N. McCandless Vernon,.Verrent 05354 Vemont Division of Occupational

& Radiological Health Yemont Public Interest Administration Building Research Group, Inc.

10 Baldwin Street 43 State Street Montpelier, Vemont 05602 Montpelier, Vermont 05E02 Honorable John J. Easton Thomas A. Murley Attorney General Regional Administrator State of Vermont Region 1 Office 109 State Street U. S. Muclear Regulatory Comission - l Montpelier, Vermont 05602 631 Park Avenue King of Prussia, Pennsylvania 19406 1 John A. P.itscher, Esquire Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110

REQUEST FOR ADDITIONAL INFORMATION APPENDIX J LEAK TEST PROGRAF 1 VERM0flT YANKEE NUCLEAR P0HER CORPORATIO!!

DOCKET NO. 50-271 ~

General Disctission Appendix J to 10 CFR 50 contains the regulatory requirements regarding individual containment isolation valve leakage test requirements. It also provides the conditions which must exist to preclude the Type C air leak tests.

In addition, Appendix A, GDC54 provides more general requirements regarding piping systems penetrating containment. This regulation requires that piping systems penetrating containment "shall be designed with a capability to test periodically the operability of the isolation valves...to determine that valve leakage is within acceptable limits."

Appendix J, Section Ill.C.3 states that " leakage from containment isolation valves that are sealed with fluid from a seal system may be excluded.,..provided that (a) such valves have been demonstrated to have fluid leakage rates that do not exceed those specified in the technical specifications or associated bases, and (b)the installed isolation valve seal-water system fluid inventory is sufficient to assure the sealing function for at least 30 days at a pressure of 1.1 Pa.

In examining a seal system it must be ascertained that the system will maintain the water seal under post accident design basis conditions including a LOCA coincident with loss of offsite power and the worst single active failure.

This usually means that the isolation valves in question must be feed by pumps that are powered by diverse diesels so that if the single active failure is )

postulated to be a diesel failure then the seal system will remain functional l

by virtue of the redundant diesel. In the evaluation of the seal system no l

credit is given for water in the reactor vessel to act as a source of water l l

inventory acting against the isolation valves. On the other hand, an inward l acting (toward containment) passive water leg would be acceptable if it l provided a pressure of 1.1 Pa against the valve for 30 days given the specified l valve leakage rate. The valves which meet the seal system provision mentioned above should, as indicated in Appendix J, be water tested with an acceptance l criteria provided in the Technical Specifications, i l

4 L

GDC 54 of Appendix A to 10 CFR 50 is the regulatory basis which the staff looks to in requiring a water test on valves which terminate below the minimum suppression pool level. These valves are not covered by the Appendix J test program. However, a water leak test will provide confidence that the containment boundary will be maintained in an accident condition requiring the valve to be isolated.

Questions

1. The following penetrations have been listed in the Vermont Yankee Local Testprogramashavind"mettherequirementsofthewater-sealasdiscussed

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above and in Appendix J and consequently no air-leakage testing is proposed.

For each of these syrtems state how a water seal is provided under the post accident DBA condition which include loss of offsite power and worst case single active failure. Include or reference drawings or sketches showing system piping and the pumps involved. Note that no credit may be given to water 1egs provided by water in the reactor vessel. A crossover between redundant trains of an ECCS system may be taken into account if a procedures erists to provide the water leg to the isolation valves in the event it would not otherwise be available:

Penetration No. System P

X-12 RHR Shutdown Cooling Supply X-13A/B LPCI Injection X-14 RWCU Suction X-16A/B Core Spray X-17 RHR Head Spray X-42 Standby Liquid Control i

2. The following piping lines appear to terminate below the minimum drawdown level of the suppression pool. As mentioned above, staff interpretation of GDC 54 requires a water test on these valves. ~

Indicate whether the valves will be water tested and if not justify why a water test should be not performed. Note that an exemption from the regulations must be requested and justified to eliminate leakage testing cf these valves.

Penetration No. System X-210A/B RHR Return X-212 RCIC Turbine Exhaust X-221 HPCI X-222 HPCI Drain Pot X-223 RCIC Drain Pot '

X-224 RHR Suction X-225 HPCI Suction X-226A/B Core Spray Suction X-227 RCIC Suction

3. Discuss the test provisions for the TIP explosive shear valve and the ball valves, penetration X-35C, D, E. Also indicate the proposed testing provisions on the check and solenoid valve of the TIP A'ir Purge System, penetration X-35A.

4. For the CAD system indicate'the valves that will be Type C air tested in penetrations X-50A, B, C-205.

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5. The following system isolation valves appear to meet the definition in 1 Section II.A of Appendix J requiring Type C leak testing. Indicate the extent of testing proposed for the isolation valves in these lines and provide your basis for any valves for which test Type C testing is not proposed.

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- Penetration System '

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X-23, 24 Inlet RBCCW X-39A/B Drywell Spray O

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