IR 05000155/1989015

Insp Rept 50-155/89-15 on 890725-0905.No Violations Noted. Major Areas Inspected:Mgt Meetings,Surveillance Activities, Maint Activities on Various Components,Containment Integrated Leak Rate Test & Operational Safety Verification

ML20248A544
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/18/1989
From:	Jackiw I, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248A537	List: IR 05000155/1989015 ML20248A535
References
50-155-89-15, NUDOCS 8910020245
Download: ML20248A544 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

,' REGION'III Report No. . 50-155/89015(DRP)- ,

Docket ~No.'50-155 License No. DPR-6 Licensee: Consumers Power. Company -

212 West Michigan Avenue Jackson,'MI 49201-Facility. Name: . Big Rock Point Nuclear Plant Inspection'At: . Charlevoix, Minnesota Inspection Conducted: July 25 through September 5,1989 Inspectors: E. Plettner N. Williamsen F. Maura P. Lougheed Approved By: ack r ~, ts e, Y Rea cti n 2B Date '

M. P'. Phi ips, Chie Operational Programs Section 7[9[8/'

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Inspection Summary Inspection on July 25 through September 5, 1989 (Report No. 50-155/89015(DRP))

Areas Inspected: The inspection was routine, unannounced, and conducted by the senior resident inspector, the resident inspector, and two reactor inspector : The functional. areas inspected consisted of the following: management meetings; surveillance activities; maintenance activities on various components; Containment Integrated Leak Rate Test (CILRT) - Inspection Modules 70307,

'70313, and 70323; operational safety verification; including, the liquid poison system; and plant startup from refuelin Results:- The. licensee has responded in a. timely manner to issues and concerns presented to them by the NRC. The surveillance, maintenance, operational

. safety, and refueling and startup programs appeared to be performed in a manner to ensure public health and safety. The inspection on the CILRT resulted in an open item and two unresolved items. Status of the test is potentially invalid, pending further information from the licensee. Further concerns l'

center on the weakness exhibited by the licensee as shown by their failure to quantifiable justify the assumptions made regarding expansion and contraction of the containment sphere during the tes Ne significant safety items' were identified in this repor )

8910020240 990919 PDR ADOCK 05000156_ )

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DETAILS Persons Contacted

• T. Elward, Plant Manager R. Abel, Production ~and Performance Superintendent

• L. Monshor, Quality Assurance Superintendent

• H. Hoffman. Maintenance Superintendent W. Trubilowicz, Operations Supervisor

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• Withrow,. Plant Engineering Supervisor

• J. Beer, Chemistry / Health Physics Superintendent R. Alexander, Technical Engineer E. Zienert>, Director Human Resources

~* McIntosh, Senior Engineer,-Nuclear Assurance

• Bielinski, Acting Production and Performance Superintendent

• T. Dugan, Acting Human Resources Director

• D.,Lacroix, Training Administrator R. Nicholson, Vice-President, Energy Supply Services W. Richie, Manager, Field Maintenance Service ' J. Fremeau, Director, Nuclear- Safety Services Department B. Rabideau, Assistant Supervisor, Property Protection M. VanAlst, Supervisor, Property Protection J. Toskey, Senior Engineer T. Marshall, Associate Engineer The inspectors also contacted other licensee personnel in the Operations, Maintenance, Engineering, Radiation Protection, and Technical Department * Denotes those present at the exit interview on September 5, 198 Regional inspectors Messrs. F. Maura and Ms. P. Lougheed conducted a portion of the exit per teleco . Action on Previous Inspection Items (Closed) Open Item (155/85020-01(DRS)): Incomplete and/or vague procedural instructions in regard to corrections to Type A test results. The licensee revised their Containment Integrated Leak Rate Test (CILRT) procedure to address Type A corrections. This item is considered close (Closed) Open Item (155/85020-02 (DRS): Lack of censor data rejection criteria. The licensee addressed sensor rejection evaluai, ion in their revised CILRT procedure. This item is considered close .(Closed) Open Item (155/85020-03 (DRS): Use of all data points from start of tes The licensee revised the precautions and limitations section of their CILRT procedure to address this item. It is considered close _ _ - _ _ - _ - _

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a (Closed) Open Item (155/85020-04(DRS): Incorrect' superimposed leak.-

-rate siz The licensee revised the CILRT procedure to correctly address the~ Appendix J requirements for the superimposed leak rat , The' inspectors reviewed.the revised procedure and the superimposed

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. leak rate that was used during the test and found them.to be acceptable. ~This item is: considered close (Closed) Open' Item (155/85020-05(DRS): As-found condition of CILRT results. .The licensee addressed the use of the " minimum pathway methodology" in their revised CILRT procedure. 'This item is

. considered close . Management (30703) ,

The. Senior Resident Inspector met with R. Nicholson, Vice-President, Energy Supply Services, and W. Ritchie, Manager, Field Maintenance

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Services, to discuss the performance of field maintenance services during the outage. The discussion included the lessons learned from the outage and.how the field maintenance services could improve their work in the futur The Senior Resident Inspector met with J. Fremeau, Director Nuclear Safety Services Department, to discuss items dealing with reviews conducted by the Offsite Revien , mmittee, called the Nuclear Safety Boar Amendment 100, whit.n was issued during this inspection period and discussed in Paragraph 7, changed the way the Offsite Review Committee functioned.

i How those changes impact upon plant operations were discucsed along with L ' issues concerning quality control, quality assurance, and licensing activities.-

l- . 4 .- Refueling Activiti,es (60710)

Preparations for refueling and refueling activities were observed / reviewed to ascertain that the activities were in conformance with approved procedures and with the Technical Specifications (TS). Inspection Reports 155/89006, 155/89009, and 155/89013 document previous inspection findings on' refueling activities. This report concludes the inspection module requirements. The NRC inspectors reviewed three Specification Change (SC)

packages: SC-88-035, "C-24 Core Reload: Fuel Design," dated December 20, 1988, SC-036, " Cycle 24 Core Data - Control Blade Shuffle, Shut Down Margin Verification - Low Power Physics Testing," dated June 28, 1989, and 5C-0037, " Cycle 24 Core Reload: Core Data," dated December 20, 1988. The Specification Change packages documented that the licensee had conducted a L 10 CFR 50.59 safety evaluation. The results of the evaluation confirmed that present core parameters (Cycle 24) were within the bounds of previous core parameters (Cycle 17). Approval by the NRC for Cycle 17 was

' documented'in NUREG-0828, " Integrated Plant Safety Assessment, Systematic Evaluation Program, Big Rock Point Plant," dated May,1984. Therefore, Cycle 24 parameters meet regulatory requirement No violations or deviations were identified in this are L

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. Monthly Surveillance Observation-(61726)

Station surveillance act.vities listed below were observed to verify that-the activities were conducted in accordance with the Technical Specifications and surveillance procedures. The applicable procedures were reviewed for adequacy, test and process instrumentation was verified to be in their current cycle of calibration, personnel performing the tests appeared to be qualified, and test data was reviewed for accuracy and completenes The NRC inspectors ascertained that any deficiencies identified were reviewed and resolved. The NRC inspectors observed the licensee's performance of the following surveillance tests on the indicated dates:

July 31: TR-99, " Surveillance Check of ASD System Equipment," Revision 4, June 29, 198 August 1: T7-28, " Emergency Diesel Generator Auto Test Start," Revision 8, October 24, 1988. Vibration measuring and recording equipment was used to establish new base-line data for the Emergency Diesel Generator, following the realignment and other maintenance activities performed during the refueling outag August 3: TR-35, " Reactor Recirculation Pump Interloc.k Test," Revision 10, April 21,198 August 3: TR-33, " Reactor Protection System Response Time," Revision 9, February 17, 1989, with Procedure Change Form, dated August 3, 198 August 5: TV-10, " Pressure Test of Nuclear Steam Supply System,"

Revision 38, May 24, 1989. Reactor pressure met the hydrostatic test requirements. The resident inspector accompanied the Shift Supervisor and a Maintenance. Supervisor on the visual inspection of the Nuclear Steam Supply System. A few minor packing leaks were found and repaired in a timely manne August 30: T30-29, "RDS Cabinet Test (Sensor Cabinet B/ Actuation Cabinet No. 2)," Revision 25, dated August 29, 1989. The procedure was performed in a professional manner. Problems occurred while performing the procedure that resulted in a plant Limiting Condition of Operation (LCO). Licensee personnel exercised sound judgement by returning plant equipment to normal and investigating the prcblem. Results of the licensee's investigation revealed that a new revision of the procedure issued on August 29, 1989, contained an incorrect page. The correct page of the procedure was obtained and verified by appropriate personnel. Testing was satisfactorily performed and the equipment declared operable, subsequently exiting the LC August 30: RM-53, " Radioactive Material Shipment," Revision 22, dated February 15, 1989, Attachment 5, Form RM53-5."

September 4: T7-30, " Plant Water Inventory," Revision 3, June 16, 198 _ . _ _ _ _ _ _ _ _ _ _________

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September 4:. CP-42,'" Cleanup Demineralized Effluent Analysis Procedure,"-

Ttevision 0, February'7, 198 . No violations or deviations were identified in this are i ' Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components:

-listed below were observed / reviewed to ascertain that they were conducted

--in accordance with approved procedures, regulatory guides and industry codes'or standards and in conformance with Technical Specification The following-items were considered during this review: the limiting conditions'for~ operation were met while components or systems were; removed from service; approvals were obtained prior to initiating the work;

. activities were accomplished using approved procedures and were inspected as applicable; functional testing-and/or calibrations were performed prior to returning components or systems to service; quality contro records were maintained; activities were accomplished by qualified personnel; parts and materials used were certified; radiological and fire prevention controls-were implemente Work requests.were reviewed to' determine the' status of outstanding jobs and to assure that priority was assigned to safety related equipment maintenance which may' affect system performanc The NRC inspectors observed the licensee's performance of the following maintenance work orders on the indicated dates:

July 29: No. 89-ASD-0027, dated May 12, 1989, for installing heavier cable in the Alternate Shutdown System's electrical supply to the Service Water Pum August 1: No. 89-RDS-0076, dated June 12, 1989, for stroke-testing RDS Valve."D" in conjunction with Surveillance Procedure TR-101, "RDS Depressurizing Valve Test," Revision 2,. July 11,198 August 8: No. 89-RDS-0141, dated August 6, 1989, for RDS valve "A" post-maintenance testing using Surveillance Procedure TR-101, "RDS Depressurizing Valve Test," Revision 2, July 11, 198 August 31: No. 89-ASD-0042, dated August 31, 1989, for replacing one-battery cell in the Alternate Shutdown System battery bank, using procedure MEPS-11 " Single Cell Replacement of Stationary Batteries," Revision 0, September 29, 198 No violations or deviations were identified in this are ' Containment Integrated Leak Rate Test Procedure Review (70307)

' Procedure Review The. regional-based inspectors reviewed procedure TV-02 Revision 19, dated July 19, 1989, " Containment Integrated Leak Rate Test" relative

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u to'the requirements of 10 CFR 50, Appendix J, ANSI N45.4-1972, and-the Technical-Specifications. The inspectors noted several areas where further clarification should be provided by the licensee: 1 (1): Steps 5.7k and 5.10b should' include a statement to address the methodology for uniformly-applied sensor. data rejection h data based on pre-established criteri (2).-Steps 5.9a and 5.9b should indicate that termination of the test is in accordance with the acceptance criteria of Appendix J rather than state."After greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of successive data."

The current wording may be misinterpreted to read that tests could be terminated after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and that only 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> worth _of a leak rate data need be use (3) ' Step' 5.10e should clearly incorporate .the BN-TOP-1 requirement that the duration-of the verification test be approximately one-half of the length of the CILR The regional-based inspectors also reviewed the licensee's Technical Specifications against the requirements of Appendi_x J. Discrepancies were noted in that (1) no tests were performed to determine the relationship between Ltm at 11.5 psig and Lam at 27 psig. Appendix J requires a CILRT to be run both at the full and reduced pressure during one outage in order to establish the maximum allowable leakage rate, Lt for future tests. Additionally, no exemption, or-request for an exemption, from the requirements of-Appendix J for the correlating tests was foun The licensee was requested to determine if such an exemption had been granted, or otherwise justify how they met the Appendix J requiremen Additionally the inspectors noted that this test, as well as.the majority of the previous tests, was performed at a reduced pressure that was below one-half of Pa. Appendix J requires that reduced pressure testing be performed at a minimum of one-half'of Pa. The Technical Specifications, Section 3.7 defines the La (the maximum allowable leakage) as 0.5 wt%/ day at the design pressure of 27 psi Appendix J states that La is to be the maximum leakage at the peak accident pressure, Pa, and that this value is to be documented in the Technical Specifications. Verbal discussions with the licensee indicates that they consider the peak accident pressure to be 23 psi The licensee was requested to determine the correct Pa. If Pa is not 27 psig, then the definition of La in the current Technical Specification value is incorrect, and the licensee must determine the correct La as required by Appendix J. If the value of Pa is 27 psig, then the licensee must determine whether an exemption to allow performance of a reduced pressure test at less then one-half Pa has been grante !

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'The above questions:regarding_ compliance with Appendix J are being

% tracked as-an Unresolved Item. (155/89015-01(DRS))

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t bl -Clarifications of Appendix J Requirements To ensure the licensee's understanding of Appendix J requirements, the regional inspectors transmitted to the licensee,'and discussed-with them, the following clarifications:

n (1) ;The Type A test length must be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or-longer to use the mass point method;of data rejection.- If tests of less than

.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are planned,.the Bechtel Topical Report, BN-TOP-1, .

must be' followed in its ' entirety,. except for any section_ which conflicts with Appendix J or Technical Specification requirement For either methodology, the acceptance criteria is that the

L" measured leakage at the 95 upper confidence limit must be less-than 75% of the maximum allowable leak rate for the pressure at which theitest was performe (2) Periodic Type A, B, and C tests must include as-found results as.well as as-left. If Type B and C tests.are conducted prior to a Type A, the as-found condition of.the containment must be calculated by adding any improvements in. leakage rates, which are the result of repairs and adjustments _(R/A), to the Type A test results using the " minimum pathway leakage" methodolog This method requires that:

(a) In the case where individual leak rates are assigned to two valves in series (both before and after R/A), the penetration through-leakages would simply be the smaller of the two valves' leakage rate (b) In the case where a leak rate is obtained by pressurizing between two isolation valves, and the individual valve's leak rates are not quantified, the as-found and the as-left  !

penetration through-leakage for each valve would be 50% of the measured leak rate, if both valves are repaire (c) In the case where a leak rate is obtained by pressurizing between two isolation valves, and only one valve is repaired, the as-found penetration leak rate would conservatively be the final measured _ leak rate, and the as-left penetration through-leak rate would be zer (This assumes the

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repaired valve leaks zero.)

(3) ' Penetrations which are required to be Type C tested, as described in the FSAR, SER, or Technical Specifications must be vented inside and outside the containment during the CILRT. All vented penetrations must be drained of water inside the containment and between the penetration valves to ensure exposure of the contain-ment isolation valves to containment air test pressure. The degree of draining of vented penetrations outside of containment

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L is controlled by.the requirement that the valves be. subjected to the post-accident differential pressure, or proof that the system was built to stringent quality assurance standards ,

comparable.to.those required.for a seismic syste ~

(4)' Whenever penetration configurations during a CILRT deviate from the ideal, the.results of the LLRT for penetrations must be added as a penalty to the CILRT results at the 95% upper

. confidence level. This penetration leakage penalty.is determined

'using the " minimum pathway leakage" methodology. This methodology is defined as the minimum leakage value that can be quantified through a penetration leakage path (e.g. the' smallest

leakage.through two valves in series). This assumes no single active failure of; redundant leakage. . Additionally, any increase

'in containment sump, fuel pool, reactor' water, or suppression  !

. pool level during the course of the CILRT,'must be taken as a

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penalty.to'the CILRT results. If penalties exist they must be- i added;(SUBTRACTION IS NEVER PERMITTED)-to the upper confidence ,

level of the CILRT result (5) The start of the CILRT must be noted in the test log at the time l the licensee determines that-the containment stabilization has

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been satisfactorily completed. Reinitializing a test in progress i must be " forward looking," that is, the new start time must be that time at which the decision to restart is made. This also implies that the licensee has determined that the test has failed, and has enough data to quantify the leakage rate. Any deviation from these positions should be discussed, and documented, '

with the NRC inspector as they occur to avoid later invalidation c 'of the test result Examples of acceptable deviations of reinitializing the start time of the test in the past are: time ,

at which a leaking penetration (which has an obvious effect on  !

the test data) was secured, accidental opening and later closing '

of a valve which has an obvious effect on the test data, or the  ;

time at which an airlock outer door was closed and the inner door was opene (6) The supplemental, or verification, test should start within one  ;

hour after the completion of the CILRT (Note: BN-TOP-1 requires a one-hour stabilization period). If problems are encountered in t.he start of the supplemental test, data recording must continue and be considered part of the CILRT until the problems are corrected and the supplemental test can begi R (7) For the supplemental test, the size of the superimposed leak rate l must be between 0.75 and 1.25 times the maximum allowable leak )

rate (La). The higher the value, the better. The supplemental j test must be of sufficient duration to demonstrate the accuracy of the tes The NRC looks for the results to stabilize within the acceptance criteria rather than the results being within the acceptance criteria. Whenever the BN-TOP-1 methodology is being used, the length of the supplemental test cannot be 'ess than approximately one-half of the length of the CILR ____-__ _ _ __ _ -

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(8) .During a CILRT, it may become necessary to reject or delete specific sensors or data points due to drifting of erroneous sensors, or data outlier Data rejection criteria should be developed and used so that there is consistent, technical basis for data rejection. One example of an acceptable method for data outliers is described in an Appendix to ANSI /ANS 56.8-198 Sensor data rejection criteria should be plant specific and based upon a sensor's trend relative to the average scatter, slope, and/or absolute output of the senso (9) An acceptable method for determining if the sum of Type B and C tests exceeds the 0.60 La Appendix J limits is to utilize the

" maximum pathway-leakage" methodolog This methodology is defined as the maximum leakage value that can be quantified through a penetration leakage path (e.g. the larger, not total, leakage of two valves in series). This assumes a single active failure to the better of two leakage barriers in series when performing Type B or C test (10) Test connections between containment isolation valves must be administratively controlled to ensure their leak tightness or otherwise be subject to Type C testing. One way to ensure their leak tightness is to cap, with a good seal, the test connection after its use. (Note: test connection lines which penetrate containment must have two valves and a cap.) Proper administra-tive controls should ensure valve closure and cap reinstallation within the local leak rate testing procedure, and with a checklist prior to unit restar (11) Whenever a valve is replaced, repaired, or repacked during an outage for which Type A, B, and/or C surveillance testing was scheduled, local leak rate testing for the as-found as well as i

the as-left condition must be performed on that penetration. In i the cases of a replaced valve, the as-found test can be waived, except during outages when a Type A test is scheduled, provided

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that no other containment isolation valve of similar design exists at any nuclear site owned by the same utility.

l l (12) The periodic-retest schedule for each penetration subject to Type B or C testing, except for airlocks and penetrations employing a continuous leakage monitoring system, shall be tested every refueling outage, but in no case shall the interval be greater than two year (13) If local leakage measurements are taken to effect repairs in order to meet the acceptance criteria for Type A tests performed at reduced pressure, these measurements shall be taken at the test pressure Pt used for the Type A test, i

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Containmen't Integrated Leak Rate Test Witnessing (70313)

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u E Instrument' Calibration Data and Weighting Factors The regional inspectors reviewed the calibration data and determined all the' instruments used in the CILRT had been properly calibrated-and that the correct weighting factors had been placed-in the computer program as required. The following instrumentation was used throughout the test, according to information supplied by the' licensee:

t-TYPE -QUALITY-RTDs 20

' Humidity sensors 10 Pressure gauge Flowmeters 2 Temperature Calibration Survey

.The resident inspector witnessed the temperature calibration survey performed on July 24, 1989. Sensor readings were taken, by a calibrated thermometer, in the subvolume measured by'each RT .These readings were then compared to the data acquisition reading, with reasonable result Witness of Test The resident inspector witnessed portions of the containment pressurization, stabilization, and CILRT on July 24-27, 1989 and noted that test prerequisites were met and that the appropriate revision to-the surveillance procedure was followed by test personnel. During this time an increase in containment mass was noted during the first half of the test, followed by a decrease in containment mass. The-resident inspector maintained close contact with the regional CILRT specialists in order to monitor the CILRT result . Test,Results Evaluation (70323) Increase in Containment Mass, or Expansion and Contraction of the Sphere

During the performance of the CILRT, the resident inspector noted that the' containment mass was rising. The mass increase continued for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. The mass then started to decreas When the resident inspector questioned the licensee about this increase in mass, the licensee stated that it was due to expansion and contraction of the spher During the evaluation, the regional inspectors attempted to determine the mass change due to this " diurnal effect." The inspectors noted that'during the first half of the test the mass increase was approxi-mately 100 pounds, while during the second half, the mass decrease was 4

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approximately 80 pounds. .Four pounds of the mass increase could be L

' explained by the decrease in the CRD accumulator pressure At th'e. inspectors' request, the licensee submitted a calculation estimating the amount that the sphere would expand due to heat fro .the~ sun. This calculation had two serious deficiencies: (1) the

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, . licensee ~used a steel temperature 20 higher than ambient. They based this on a single measurement taken two weeks after the conclusion of

'he test at 10 a.m. on a sunny day; (2) the licensee reduced the final mass decrease by an arbitrary factor of 25% to account for " shading .

of the sphere due to the turbine building." This calculation concluded that the mass change would be 96 pounds, or the approximate amount actually seen during the tes The regional inspectors independently calculated the expansion of an ideal sphere assuming that the steel temperature was the same as the outside temperature. This amounted to a mass change of approximately-The inspectors agreed with

th53 pounds, that e licensee or about half what was the expansion see of the sphere should be decreased since part of the sphere was underground, as well as part being

" shaded"; however from the information available to the inspectors (as contained in the SER and Technical Specifications) it was not possible to quantify the amount of this decreas In a'ddition to the above factors, the regional inspectors obtained the official National Weather Bureau data for the local area (data taken at a location less than 5 miles from the plant). According to this data, the weather during the stabilization period was sunny to partly cloudy, and during the test it was cloudy with periods of rain. From this data, the inspectors concluded that contraction of the sphere during the first.part of the test was possible, but expansion during the second talf was improbable. This then points to a leakage much higher' than actually calculated, as the mass increase would mask leakage out of containmen In order to determine.the effect that weather conditions have had on previous CILRTs, the inspectors reviewed the the licensee's reports for the previous three CILRTs (1977, 1982 and 1985). According to the limited data provided (basically, a brief sentence giving weather conditions, temperatures and wind information), cloud cover appears to be the main criteria as to whether diurnal effects will be experience Since the calculations and information obtained by the regional inspectors did not support the licensee's conclusions that the mass changes were due strictly to diurnal effects, the test results are being treated as an Unresolved Item, pending further information regarding sphere expansion / contraction (Unresolved Item 155/89015-02(DRS)). If the 1989 CILRT is declared invalid, the licensee will have to perform a new CILRT within the requirements of their Technical Specifications and 10 CFR 50 Appendix _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _

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, The specific information necessary to determine the validity of the

. test is:

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(1)~: Detailed information to show why a 20 degrees delta between

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steel temperature and ambient temperature is. expected. This-E information should provide enough data points in regards to

.(a) time of day,~(b) location on sphere, and (c) local weather-conditions (such as cloud cover) so that reasonable extrapola-l'

tion back to the time of the test is vali (2). Justification for the 75% " turbine building factor."

(3) If,'as was indicated during.the exit, the weather data as supplied by the National Weather Bureau for the area on the day of the test is not applicable, then a log (or other documentation)

indicating the weather conditions at the plant during the test shall be provide b. CILRT Data Evaluation A 28 hour3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> CILRT was performed during July 26 - July 27,1989 at 28 psia following completion of the required temperature stabilization perio Data'was collected every 15 minutes. Independent monitoring of the leak rate data was performed by the resident inspector. Following completion of the test, the licensee'r results were transmitted to the region, where an independent evaluation of the leak rate data using mass point time formulae was performed to verify the licensee's calculations of the leak rate and instrument performance. The inspectors' and the licensee's results were as indicated by the following summary (units are in weight percent (wt%) per day):

Measurement Licensee Inspectors Leak rate measured -0.0096 -0.0079*

during CILRT (Ltm)

Ltm at upper 95% 0.0014 0.0027*

confidence sevel Appendix J acceptance criteria at 95% UCL: <0.75Lt = <0.266 wt%/ da *These numbers reflect calculations performed using licensee -

supplied data taken during the test and do not reflect any corrections for changes in the mass due to expansion or contraction of the sphere. The formulae used by the licensee and the inspectors, in accordance with the requirements of Appendix J, assumes that the volume of the containment is constant. Therefore, a variation in volume would be perceived as a change in the mass and the leakage correspondingly compute In this case, it implies that there was leakage into containment, hence the negative numbe .--___-_______--__- _ _ _ __ _

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.was" required to make' corrections'to the; calculated Ltm at.the 95% UCL due to changes in water levels in the sumps and steam drum,-as well as. corrections!for control rod drive'(CRD): nitrogen accumulators pressure decrease According to data submitted by the licensee,.there was an increase in water level of approximately 3 feet in the enclosure dirty sump. The licensee did not provide the volume of this sump, and did not_ include

it in their. correction to the calculated Lt Additionally, the pressure in 7 of the 32 CRD accumulator bottles

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increased, it decreased in 9 and remained constant in 16 bottle After numerous discussions with the licensee, it was agreed that.the increase in accumulator pressure was due to temperature effects, and-the other 25 bottles should have shown a similar increase, so that they actually decreased more than first appeared. The licensee also

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agreed that readability and sensitivity of the gauges needed to be factored into the calculatio In the calculation submitted by the licensee,'the readability and sensitivity (R/S) was added to both the before and after reading,

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and the two' readings were then subtracted from each other. This methodology resulted in cancelling the R/S corrections, and is not acceptabl The correct methodology (taking the pressure drop due to R/S, multiplying it by the number of bottles, and calculating the increase in leakage in wt%/ day) was discussed with the license Finally, there was an inconsistency in the CILRT procedure in that Step 5.9b did not address corrections to the calculated leak rate due to the changes addressed abov The procedure mentioned correcting the calculated leak rate in Step 5.11, but did not require correction of Step 5.9 results. The licensee hand-added the information to the final calculations in Step 5.9 The above problems indicated that further work is necessary to ensure that corrections to the calculated Ltm due to water level increases or pressurized bottles pressure decreases are performed properl The licensee was to submit revisions to the calculated leak rate due to the (1) changes in sump level, or justification why these changes are negligible, and (2) corrections to the CRD accumulator penalty, based on correct application of R/S data. The licensee also needed to revise their CILRT procedure in order' to ensure that the inconsis-tencies mentioned above were eliminated. These will be tracked as 0 pen Item (155/89015-03 (DRS)). Supplemental Test Data Evaluation After completion of the CILRT, a known leakage rate (as based on licensee supplied information) of 4.21 scfm, equivalent to 0.355 wt%/ day was induce The containment was allowed to restabilize

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and data was'. collected and analyzed by the' licensee every 15 minute Following completion of the' test, the regional 1 inspectors independently ~

evaluated the leak rate calculations, using data submitted.by th licensee to. verify the licensee's results. After 14 and 1/4 hours,-

.the test was terminated with satisfactory results as indicated by'the following summary. The.results were stable within the acceptance criteri Measurement- Licensee Inspectors Measured leakage rate, 0.273 0.277*

Lc, during supple-mental-test

Induced _ lea'kage rate, Lo 0.355- 0.354*.

Lc - (Lo + Ltm) -0.072 -0.077*

• These-numbers reflect calculations performed using

--licensee ~- supplied data'taken during the test and

.do not reflect any corrections for changes-in the mass due~to expansion or contraction of the spher Appendix J acceptance criteria: -0.088 < [Lc - (Lo + Ltm)] < 0.088

' CILRT Valve Lineup Penalties Due to. valve configurations which deviated from the ideal penetration valve lineup requirements for the CILRT, the results of local leak-rate' tests.for such penetrations must be added as a penalty to Lam at the 95% UCL The licensee deiermined that the penalty for such lineups was 0.0002 wt%/ day. This addition to the overall containment leakage rate _is negligibl As-Found Condition of CILRT The as-found condition is the condition of the containment at the beginning of the outage prior to any repairs or adjustments

to'the containment boundary. The licensee determined that the

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penalty for as-found conditions was 0.0001 wt%/ day. This addition to the overall containment leakage rate is negligible.

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- 10. Operational Safety Verification (71707) (93702)

The NRC inspectors observed control room operations, reviewed applicable logs, and' conducted discussions with control room operators during the inspection period. Instrumentation and recorder traces were examined for abnormalities and discussed with the control room operators, as were the

. status of control room annunciatc 's. Reviews were conducted to confirm

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, that the required leak rate calculations were performed and were within l: the Technical Specification limits. System Walkdowns were performed to verify the operability of the liquid poison system and the Reactor

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l Depressurization system. : Tours'of the containment sphere and ttirbine -

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building were conducted to observe plant equipment conditions; including, ,

potential' fire hazards, fluid leaks, and excessive vibrations, and to !

verify that maintenance requests had been initiated.for equipment in need l-of maintenance. Radiation protection controls were inspected, including'

Radiation Work Permits, calibration.of' radiation detectors, and proper i posting and observance of-radiation and/or contaminated areas. The-

, ' inspectors observed site security measures including access control of personne1 'and vehicles, proper display of. identification badges fo personnel within'the protected' area,- and compensatory measures when security equipment-had a failure or impairmen ,

On' August 2 and 3, the resident inspector observed classroom training on i the following Off-Normal Procedures (0NPs): 0NP-2.2, " Loss of Instrument Air System," Revision 138, dated October 6, 1987, and DNP-2.34, " Loss of Shutdown Cooling System," Revision 62, dated April. 19, 1989. The class consi.sted of two Senior Reactor Operators, one licensed and one. certified by the licensee, and two licensed Reactor Operators. The material

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presented'followed-the instructor's guide and prompted good student participation. A written examination was administered which adequately tested the lesson objectives. 'All four students passed the examinatio .'On August 16, the resident inspector observed an unannounced fire dril Plant management, corporate management, and an outside evaluator were present to observe and critique the dril The outside consultant, a member of the Society of Fire Protection Engineers, was present to perform the evaluation required every three years by the Technical Specification The plant fire brigade and the Charlevoix. Volunteer Fire Department responded to the drill in a timely manner. During the critique of the drill, the evaluators determined that the actions taken would have been sufficient to control and extinguish an actual fir On August 18, the licensee submitted Licensee Event Report 89-00 Titled " Discovered Defects =in Fire Penetration Seals Resulting in Technical Specifications Violation." The Licensee Event Report will l be closed and documented in a future report when corrective actions are complete On August 22 at 6:45 a.m. (EDT), a reactor scram occurred when all three neutron wide-range monitors tripped on high flux indication. The flux L increase was the result of equipment failure in the turbine control syste Following the scram, all safety systems responded as required, with no l noted abnormalities. The licensee completed all notifications in a timely manner. The following detailed procedures were used to establish hot H shutdown conditions: ONP-2.31, " Reactor Scrams," Revision 103, dated l- October 7,1987; 0-TGS-1, " Master Check-Off Sheet," Revision 64, dated April 12,1989, with a Procedure Change Form dated August 10, 1989, concerning turbine operations; and General Operating Procedure (GOP) 6,

" Plant Shutdown to Hot Shutdown," Revision 115, dated October 23, 198 The turbine control system was investigated and the fault was determined to be a small steam leak. The Plant Review Committee approved reactor startup following replacement and testing of the control assembly. The

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dactor was critical at 11:15 p.m. the same da The NRC inspector observed _the startu The startup was performed in a professional manner with the-detailed procedures. listed in Paragraph 8, " Plant. Start-Up from-Refueling," Substituting G0P-2, " Plant Start-Up from Hot Shutdown,"

Revision 118,. dated May 11, 1989, for GOP-1. During the pre-synchronization turbine testing, a turbine trip. occurred on high

' vibration. The . reactor was subsequently shut down using procedures 0-TGS-l'and.also Technical Data Book 15.5.I~2, " Control Rod Withdrawal

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and Insertion Sequence Cycle 24," Revision 88, dated July 25, 198 Arrangements-were made to obtain and install additional vibration monitoring equipment to assist in trouble-shooting the turbine vibration problem. The reactor.was critical at 1:27 p.m. on August 23. .The start-up was performed in a professional manner'using the detailed procedures noted.above. Additional time was given to heating.up th turbine before pre-synchronization testing. The additional heat up time resulted in no high vibrations. The generator was synchronized to.the grid'at 7:06 p.m.-

OnA'hast u 30, 1989, the' senior. resident inspector observed the performance

. of. a. Security Drill conducted by the Security Plant Management. Security--

Plant Personnel responded in a timely and professional manner using the appropriate procedures to control the drill. scenario. Plant Management-conducted a drill critique to identify and discuss any weaknesses that may have occurre No weaknesses were identifie On August 31 at 10:30 a.m. (EDT), a Limiting Condition of Operation (LCO) was entered when the requirements of Technical Specifications (TS) 11.3.5.3.5. " Station Battery System and Alternate Shutdown Battery

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System" could not be met. The LCO has a one hour time frame in which to-correct the problem or commence a reactor shutdown. ,At 11:23 a.m., a

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reactor shutdown was commenced as required by T At 11:50 p.m., the Shift Supervisor declared a Notification of Unusual Event as required by the Site Emergency Plan EPIP-1 under " Limiting Conditions of Operation" and "LCO resulting in a Plant shutdown." The Plant Manager immediately assumed the duties of the Site Emergency

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Director (SED). There was a partial activation of the Technical Support Center (TSC) and Operation Support Center (OSC) with a Maintenance Supervisor and two repairmen. The Maintenance Superintendent was also availabl Calls were made to the Charlevoix County Sheriff, the State Police, and the NRC, by 12:14 p.m.; meeting the required reporting tim The Notification of Unusual Event was terminated at 2:55 p.m. when the  !

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. defective battery cell was replaced, testing completed, and the maintenance order close Calls were made to the Charlevoix County Sheriff, the State Police, and the NRC by 3:07 p.m. of event terminatio The resident inspector observed the replacement of the battery cell and the return to operability of the Syste ;

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On August 31, a reactor plant tour was conducted by the senior resident inspector'with the Plant Manager, and with the Maintenance Superintendent on September 1, 1989. Discrepancies were noted and given to the

. appropriate people for corrective action. The material condition of the plant was acceptable with only a few areas requiring additional work to return the area to pre-outage conditions. It was noted during the tour that plant personnel were diligently trying to resolve the problems in the areas requiring additional wor During this inspection period three amendments, Numbers 98, 99, and 100 were_ issue Amendment No. 98 modified paragraph 2.C.(5) of the license to require compliance with the amended Physical Security Plan. This Plan was amended to conform to the requirements of 10 CFR 73.55. Consistent with the provisions of 10 CFR 73.55, search requirements must be implemented within 60 days and miscellaneous amendments within 180 days from the effective date of Amendment No. 98. Amendment No. 99 changed Sections 3.7(d), (e) and (f)'to depict the requirements of 10 CFR Part 50 of Appendix J and NUREG-0123, " Standard Technical Specifications for General Electric Boiling Water Reactors," and to remove the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration requirement to reduce the impact of diurnal effects by using an NRC approved " Total Time" or point-to point method described in ANSI N45.4-1972 and Bechtel Topical Report BN-TOP-1. At this time only the Bechtel Topical Report, BN-TOP-1, Revision 1, has been approved with a methodology that allows a test duration less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Amendment 100 revised the Technical Specifications by providing for a new organizational unit--the Nuclear Safety Services Department (NSSD)--to discharge off-site safety review functions instead of the (former) Nuclear Safety Board (NSB).

1 Plant Start-up from Refueling (71711)

This inspection was performed to ascertain that systems disturbed or tested during the refueling outage were returned to an operable status before plant start-u In addition, plant start-up, heat-up, approach to criticality and appropriate core physics tests were conducted in accordance with approved procedure On August 13 at 3:04 a.m. (EDT), the reactor at Big Rock Point achieved criticality following the 65 day refueling and maintenance outage. This was the first time in several years that the outage was completed on schedule. The NRC Inspectors observed the start-up. Besides the normal on shift crew an extra Reactor Operator and Auxiliary Operator were present. Two Reactor Operator trainees were also present to conduct control rod manipulations as part of the training evolutions to become Reactor Operators. The start-up was performed in a professional manner with detailed procedures. Procedures used during the start-up were:

General Operating Procedure (GOP) 1, " Plant Start-up from Cold Shutdown,"

Revision 117, dated May 12,1989; 0-TGS-1 " Master Check-off Sheet,"

Revision 64, dated April 12, 1989, with Procedure Change Form dated August 10, 1989, for turbine operation; Technical Data Book 15.5. " Control Rod Withdrawal and Insertion Sequence Cycle 24," Revision 88, l

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e (sted July 25, 1989; and System Operating Procedure (S0P) 31 " Nuclear Instrumentation System," Revision 142, dated July 10, 1989. No problems were noted during the reactor start-u The-resident inspector accompanied the Shift Supervisor and a Maintenance Supervisor on an inspection tcur during the heat-up later iii the da The tour included the steam drum area, the recirculation pump room, the control rod drive room, and the lower accumulator room. No discrepancies were noted during the tou The plant continued to heat-up within the required limits with extensive main turbine testing being conducted because of the major turbine overhaul that was performed during the maintenance outage. No major problems were identified during the testing of the turbine. The generator was synchronized to the grid at 5:32 p.m., August 13. The generator was removed from the grid.for overspeed trip tests at 11:05 p.m. and resynchronized with the grid at 11:33 p.m. No problems were noted in the overspeed trip tes Power ascension was continued as necessary to meet plant conditions and electrical generation needs as requested by the load dispatche No violations or deviations were identified in this are . Open Item Open items are matters which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC~or the licensee or bot An open item disclosed during the inspection is discussed in Paragraph . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 6.a and . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection period and summarized the scope and findings of the inspection activities. The licensee acknowledged these findings. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio Tha licensee did not identify any such documents or processes as proprietar .

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