IR 05000029/1980013
| ML19339C480 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 09/18/1980 |
| From: | Caphton D, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19339C479 | List: |
| References | |
| 50-029-80-13, 50-29-80-13, NUDOCS 8011180460 | |
| Download: ML19339C480 (9) | |
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U. S. NUCLEAR REGULATORY C0691ISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-29/80-13 Docket No.
50-29 License No.
DPR-3 Priority Category C
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Licensee:
Yankee Atomic Electric Company 25 Research Orive Westborough Massachusetts 01581 Facility Name:
Yankee Nuclear Power Station (Yankee-Rowe)
Inspection At:
Nowe, Massachusetts Inspection Conducted:
8/4 - 6/1980 9!/8 PO Inspectors:
W. A. Rekfto, Reactof Inspector
' dated date
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Approved by:
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D. L. Caphtdn, Chief, Nuclear Support
' date Section No. 1, RO&NS Branch Inspection Summary:
Inspection on 8/4 - 6/1980 (Report No. 50-29/80-13)
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Areas Inspected:
Routine, unannouned inspection of the containment integrated leak rate test procedure; containment leak rate test activities; inservice testing program for pumps and valves; and licensee action on previous inspection findings.
The inspection involved 22 inspector-hours on site by one region based NRC inspector.
Results:
No items of noncompliance or deviations were identified.
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Region I Form 12 l
(Rev. April 1977)
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OETAILS 1.
Persons Contacted H. Autio, Plant Superintendent
- L. French, Engineering Assistant
- T. Henderson, Reactor Engineer
- D. Long, Shift Technical Advisor
- R.
Randall, Shift Technical Advisor
- J. Staub, Technical Assistant to Plant Superintendent
- N. St. Laurent, Assistant Plant Superintendent
- B. Warner, Shift Technical Advisor NRC Personnel T. Foley, Resident Reactor Inspector
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Insoection Findings (0 pen) Unresolved Item (29/75-14-06):
Local leak rate test requirements for containment isolation check valves. The licensee's exemotion from leak rate testing these valves continues to be reviewed by NRR.
This item remains open.
(0 pen) Unresolved Item (29/77-11-03): Technical adequacy of the containment integrated leak rate test procedure.
Discussion of details is included in paragraph 3 of this report. This item remains open pending revision of procedure OP-4701, " Vapor Container Type A Leakage Test."
(Close) Unresolved Item (29/77-26-01): Technical adequacy of the local leak rate test procedure. The inspector reviewed OP-4702, rev.
7, " Vapor Container Type B and C Penetration Tests", and determined that the follcwing previously identified problems have been corrected.
(1) Valves being tested are required to be closed by their nomal means.
(2) The frequency statement for Type C Tests and airlock tests conform to the requirements of 10 CFR 50, Appendix J.
This item is resolved.
(Close) Unresolved Item (29/79-02-08): Valve testing stroke time
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requirements. The inspector reviewed procedure No. AP-7008, rev.1,
" Pumps and Valves Program" and determined that the method of evaluating the stroke time of power operated valves includes comcarison of the results to the previous test and as such conforms to the recuirements of ASME Section XI.
This item is resolve _
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(0 pen) Unresolved Item (29/79-02-04):
Pump differential pressure measurement. The licensee's relief request from this AS!1E code requirement continues to be reviewed by NRR. Paragraph 5 of this reoort contains additional infonnation on this subject.
The item remains unresolved.
3.
Containment Integrated Leak Rate Test (CILRT)
a.
Documents Reviewed Procedure OP-4701, rev. 4, " Vapor Container Type A Leakage
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Test".
Yankee-Rowe Technical Specification Section 3/4.6, Containment
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Systems.
Letter to YAEC (Mr. R. Groce) from A. Schwencer dated November
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29, 1976.
Letter to USNRC (Mr. A. Schwencer) from D. Vandenberg dated
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February 7,1977.
Dwg FM-26A, " Compressed Air System".
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Dwg M-9, " Main Coolant Orain and Samole".
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Dwg M-13, " Vapor Containment Ventilation and Pressurization".
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b.
Scone The inspector reviewed procedure 0P-4701 " Vapor Container Type A Leakage Test", for technical adequacy and compliance with 10 CFR 50, Appendix J, ANSI 45.4, and Yankee-Rowe Technical Snecifications.
The inspector also discussed various asnects of the CILRT with the licensee's representatives including current NRC cositions concerning leak rate testing.
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The licensee plans to perform a CILRT during the week of Seotember 8, 1980. The inspector found no items of noncompliance, however other findings are discussed in the following oaragraohs.
c.
Venting the Reactor Coolant System
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Section III.A.l (d) of Appendix J to 10 CFR 50 requires the Reactor Coolant system be vented to the containment atmosphere during the conduct of the CILRT but permits systems to remain in
nonnal operation if required to maintain the plant in a safe condition during the test.
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Procedure OP-4701, rev. 4, requires the Reactor Coolant system be
pressurized and the oressurizer in steam phase at 300 to 350 F.
The licensee's representative exclained this practice was carried over from previous tests due to possible damage of the main coolant pump stator housing. However, one of the cumps is fitted with a stator cavity vent plug which is removed for the test to protect it against possible damage. The licensee stated his intentions to install similar stator cavity vent pluas in the other main coolant pumps and revise the CILRT procedure to require venting the Reactor Coolant system.
This matter was previously identified as unresolved item (29/77-11-03) which will remain open pending completion of licensee
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actions described above.
d.
Acceptance Criteria The NRC requires that the CILRT Acceptance Criteria include corrections of the measured leakage for; (1) containment free volume changes (such as pressurizer level and sump water levels),
and (2) addition of local leak rate test results for CIVs of systems not vented as required by section III.A.l.(d) of Aapendix J to 10 CFR 50. The inspector noted that procedure OP-4701, rev.
4, contained instructions to add to the CILRT leakage rate; (1)
local leak rate test results for certain systems not properly vented, and (2) an equivalent leakage resulting from water accumulation in the drain tank. However, these leakage rate additions are not specified as part of the CILRT Acceptance Criteria.
The licensee's representative stated that the procedure would be revised to clarify the correct acceptance criteria.
This item is unresolved and designated item No. (29/80-13-01).
e.
Valve Line-uo Review On a samoling basis the inspector checked the CILRT orocedure valve line-no to verify that containment isolation valves (CIVs)
are closed and systems adequately vented, both inside and outside of containment to assure that CIVs will be subjected to test differential pressure.
The inspector discussed with the licensee's representative, the need to revise the procedure valve line-cp to support the decision to vent the reactor coolant system.
In addition the inspector identified several systems lacking vent paths outside the test boundary (CIVs) creating artificial leakage barriers which could mask containment leakage. Among these systems were:
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(1)
Cavity fill ifne (CS-V-601);
(2)
V.C. Service Air Supply (CA-V-688)
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(3)
V.C. Air Charge (CA-V-746)
(4) CILRT Pressurization (HC-V-602)
The licensee agreed to correct these discrepancies and conduct a complete review of all system valve line-ups to assure they are properly vented for the test.
The above items are unresolved and are collectively designated item No. (29/80-13-02)
f.
Leakace Repairs The inspector discussed with the licensee's representative the provisions of paragraph III. A.1.(a) of Appendix J regarding leakage repairs.
The inspector explained the NRC position that, if during the CILRT potentially excessive leakage paths are identified, the leak may be isolated and the CILRT restarted provided:
(1) The leak path is locally testable and is in fact tested both before and after repair; (2) The pre-repair leakage is added to the CILRT results to obtain
"as found" leakage; and (~) The post-repair leakage is added to the CILRT results to obtain the "as left" leakage.
The inspector further noted that such repairs must be carefully controlled during the test to avoid invalidating test results.
The licensee's representative acknowledged these comments.
4.
Local Leak Rate Testing (LLRT)
a.
Documents Reviewed in Addition to those in Paragraph 3.a.
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Procedure OP-4702, rev. 7, " Vapor Containment Type B&C Penetration
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Tests.".
Procedure AP-7003, rev. 4, " Vapor Containment Type B&C Penetration
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Test Guidelines", with current computer printout of LLRT pmgram summary.
Procedure OP-4702, Test Records.
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(1) Attachment W, Personnel Hatch, dated 12/21/79 and 7/18/80; (2) Attachment G, Neutron Shield Tank Sample Line Trip Valve j
(TV-207) dated 7/3/80; I
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(3) Attachment H, VC Pressure Sensing System Trip Valve (TV-211), dated 7/15/80.
(4) Attachment 2, Dfi Water Supply, dated 2/3/80.
(5) Attachment AA, LP Vent Header, dated 2/3/80.
(6) Attachment ec, Neutron Shield Tank Tell Tales, dated 6/30/80.
(7) Attachment J. MC Vent Header Trip Valve (TV-203), dated 6/30/80.
b.
Scope The inspector reviewed the LLRT procedures and records listed above for technical adequacy and compliance with 10 CFR 50 Aopendix J. ANS 45.4, and Yankee Rowe Technical Specifications.
The inspector also discussed the status of the current LLRT program with the licensee's representative. Aoproximately 60 percent of the tests had been completed. With the exception of the item below, no discrepancies were identified from the procedure and record review and the inspector had no further questions in this area.
c.
Tyoe C LLRT of Main Coolant Pressure Sensing Line CIV Attachment EE of procedure OP 4702, revision 7, orovides a leakage rate test of the Main Coolant Heise Pressure,auge r
line and valve PR-V=623, which is a manual vent valve located inside the vapor containment (V.C.) The insnector noted a discrepancy between this procedure and TS 4.6.1.2 olus Table 3.6-1 which requires tyne C testing of valve PR-V-610, which is the first manual isolation valve outside of the V.C.
Further review revealed that TS Amendment No. 58, issued April 3,1979, revised Table 3.6-1 by substituing valve PR-V-510 for valve PR-V-623 previously identified as the manual CIV.
The inspector questioned the licensee's reoresentative regarding the apparent discrepancy including plans for resolution. The licensee's representative explained that the TS requirement to Tyoe C test valve PR-V-610 was beina reviewed and may not be correct.
He further exolained that a design change to install a test connection would be necessary to conduct a valid Tyne C test of valve PR-V-61 :
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The Assistant Plar.t Superintendent stated that this divepancy would be resolved prior to conducting the Tyoe A (CILRT)
test scheduled for September 1980.
This item is unresolved pending review of licensee's actions and justifications for resolution of the discrepancy.
(29/80-13-03).
5.
Inservice Testing of Pumas and Valves a.
Documents Reviewed Yankee Rowe Inservice Inspection Program for the 40 Month
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Period March 1, 1978 through June 30, 1981, dated December 1,1977 (Program Submittal to NRC).
Revision 1, to Yankee Rowe Inservice Inspection Program,
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dated Jura 26, 1979.
Procedure AP-7008, rev.1, " Pumps and Valves Program", with
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Test Summary logs from 1979.
Procedure OP-4211, rev. 9, " Emergency Boiler Feed Water
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System Operability Test", with records from test completed 12/30/79.
Procedure OP-4204, av.18, " Monthly Test or Snecial Ooeration
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of the Safety Injection Pumps", with records from test completed 12/20/79.
Procedure OP-4610, rev. 6, " Containment Isolation System
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Containment Pressure Switch Calibrator and Trin Valve Onerability Test",
with records-from test completed 5/13/80.
Procedure OP-4707, rev. 1, " Inservice Inspection Check Valve
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Operability Check During Refueling Intervals", with records from test comoleted 10/27/79, b.
Scooe The inspector reviewed the procedures and records listed above for technical adequacy and conformance with subsections IWP and IWV of Section XI of ASME B&PV Code as described in the applicable program submittals to the NRC and Yankee Rowe Technical Soecifications.
The inspector also discussed the status of inservice testing program implementation with the licensee representative.
During this discussion the inspector explained that the inservice testing program being imnlemented must meet existing TS recuirements and Code requirements described in the most recent program su5mittal recognizing it's improvement after NRR on-site review of the original program submitta i
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Findings With the exception of the items below, no discrepancies were identified from the procedure and record review and the inspector had no further questions in this area.
i (1) Pump Of fferential Pressures During review of the IST program description the inspector recognized the licensee's request for relief from measuring pump differential pressure as required by IWP-3100 for all seven pumps within the scope of the program.
The basis for this request was identiffed to be; (1) lack of installed suction pressure indication, (2) continuation of the current testing method to satisfy TS minimum operability requi rements.
During a tour of the Primary Auxiliary Building (PAB), the inspector recognized the existance of casing drains at the suction of each of the six safety injection pumps.
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inspector stated to the licensee's representative that the NRC requires that IST operability tests meet all code requirements that are technically feasible.
It appeared to the inspector that the available pump casing drain connections could be used to monitor pump suction pressure during surveillance tests and therefore an exemption from the code requirement may not be considered valid.
The inspector stated that this information wculd be forwarded l
to NRR for use during review and determing acceptability of the licensee's IST program submittal.
The licensees representative acknowledged the inspectors comments and committed to conducting an engineering review to determine the feasibility of revising their test program to include monitoring pump suction pressures.
The effort is to be completed prior tc the next plant startup which is the next time the surveillance tests are required.
This matter was previously identified as unresolved item
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(29/79-02-04) which remains unresolved.
(2) Analysis of Results (IWP-3200)
The inspector recognized that pump differential pressure
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(AP) measurement is not presently included in the IST program but questioned why the alternate parameter, discharge pressure, in lieu of AP was not being evaluated in accordance with all of the provisions of subsection IWP. With regard to the available operating parameter, discharge pressure, l
the inspector identified that the licensee's IST pump operability procedures do not meet the following specific j
code requirements:
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9 Specific reference values for individual safety
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injection pumps are not established in accordance with IWP-3110.
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Allowable ranges of test quantities are not established
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in accordance with IWP-3210.
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Corrective actions to increase testing frequency in
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accordance with IWP-3230 is not specified.
Test results from each test are not evaluated for IWP
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acceptance criteria.
The licensee's representative acknowledged the inspectors concerns for appropriate conduct and evaluation of test results to meet the codes inservice testing requirements and committed to making appropriate revisions to the test procedures prior to the next plant startup.
This matter is unresolved pending review of revised test and evaluation procedures.
(29/80-13-04)
6.
Plant Tours The inspector conducted periodic tours of the control room and primary auxiliary building (PAB) to observe operations and activities in progress, and the general condition of safety related equipment.
During these tours no noncompliances or unacceptable conditions were identified.
7.
Unresolved Items Items about which more information is required to determine acceptability are considered unrecolved.
Paragraphs 2, 3, 4, and 5 of this report contain unresolved items.
8.
Exit Interview The inspector met with licensee representatives (see Detail 1 for Attendees)
at the conclusion of the inspection on August 13, 1980.
The inspector summarized the scope and findings of the inspection at that time.
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