IR 05000213/1986008

Insp Rept 50-213/86-08 on 860310-14.Violation Noted:Numerous Isolation Valves on Lines Penetrating Containment Tested Using Water as Test Medium When Purpose of Test Was Not to Demonstrate Water Seal at Penetration

ML20198P209
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/23/1986
From:	Bettenhausen K, Kucharski S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198P166	List: IR 05000213/1986008 ML20198P161 ML20198P192
References
50-213-86-08, 50-213-86-8, NUDOCS 8606060260
Download: ML20198P209 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N Docket N License N DPR-61 Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck Atomic Power Plant Inspection At: Haddam, Connecticut Inspection Conducted: March 10-14, 1986

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Inspectors: . / g3 S. Kucha'rski, Resident Inspector 'I d te Limerick, DRP Approved by: j Ib 8[

. H. Bettenhausen, Chief, date Operations Branch, DRS Inspection Summary: Inspection on March 10-1411986

.. (Inspection No. 50-21/86-08)

Areas Inspected: Routine, announced inspection of the containment. leakage testing program including procedure review of the Containment Integrated Leak Rate Test (CILRT) and Local Leak Rate Test (LLRT) procedure and followup of previous inspection finding Results: Three violations were identified which involved the followin Technical Specification 4.4; Technical Specification 1.8 and 10 CFR 50.5 l 8606060260 860522 PDR I

G ATOCK 05000213 PDR

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DETAILS 1.0 Persons Contacted 1.1 Connecticut Yankee Atomic Power Company

"J. Ferguson, Unit Superintendent

• R. Graves, Station Superintendent

• P. L'Heureux, Assistant Engineer Supervisor

• M. Turner, Engineer 1.2 NUSCO

• R. Kacick, Licensing Supervisor

"W. Koste, Senior Engineer

• M. Lederman, Licensing Engineer

• E. Mroczka, Vice President-Nuclear Operations

• Schmidt, Supervisor - Special Test 1.3 TERA -

! *N. Montgomery, Licensing Engineer l

> 1.4 USNRC i *E. McCabe, Section Chief - RPS-3B

• S. Pindale, Resident Inspector

• P. Swetland, Senior Resident Inspector 2.0 Licensee Action on Previous NRC Findings 2.1 (Closed) Unresolved Item (50-213/76-09-06) Minimum Indication of Leakage Rates for Local Leak Rate Tes The inspector reviewed the licensee's process for recording leak rates for penetrations when leakage rates are below the minimum sensitivity of the test instru-ment. The licensee now records h of the scale division when the test result indicates a zero leakage, which is conservative. This item is close .2 { Closed) Unresolved Item (50-213/76-09-10) Evaluation of LLRT and ILRT program for Artificial Boundaries. The inspector reviewed a sampling of the penetrations and their related Piping and Instrumen- .

tation Diagrams (P&ID's) for proper alignment for both the LLRT and the ILRT. This item is closed.

l 2.3 (0 pen) Unresolved item (50-213/84-25-01) Failure to verify containment integrity _by integrated leakage rate test. This item has to remain open until the ILRT is performed and evaluated by the NRC inspecto ._ , , .. . _ . . _ . . , _ . . _ - . . .. - _ - - - _-

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2.4 Exemption Request to 10 CFR 50 App. J. The licensee has submitted to NRR an exemption request dated March 12, 1986. The request includes the following issues:

• Reduced Pressure Test, Pt=15 psig;

LLRT by the water collection method (see Section 5.3);

LLRT by reverse direction testing for certain penetrations;

• LLRT by high pressure test for certain penetrations; and

• Modification of the charging and seal water injection line; 3.0 Containment Integrated Leak Rate (CILRT) Procedure Review The inspector reviewed the CILRT Procedure for technical adequacy and for consistency with regulatory requirements, guidance, and license commitment Review of the procedure acceptance criteria and references indicated con-formance with Appendix J to 10 CFR 50, except that the inspector also noted the licensee maintains a reduced test pressure of 15 psig which is less than 0.5 Pa (Pa=40 psig) as prescribed in Appendix J. This item has been identified by previous NRC inspection and submitted to NRR for an exemption request (paragraph 2.4).

The inspector also noted several minor issues which the licensee agreed to addres They are as follows:

Precaution statement for personnel safety when checking for " oil free" air;

Official start of the ILRT logged in to eliminate selection of a test

" window" after data is take *

Stabilization period for the verification test (one hour);

Throughout the CILRT procedure, various leak checks are performed during the test by valve manipulation. A precaution statement should be added stating that, if a leak is detected by these manipulations, the ILRT has to be restarte The licensee has agreed to incorporate these changes into the test proce-dure. This will remain open as an inspector followup item to be reviewed prior to the start of the ILRT (50-213/86-08-01).

4.0 CILRT Calibration Records The inspector reviewed the calibration records for the precision pressure detectors and the mass flow mete The calibrations met applicable accu-racy requirements and were traceable to the National Bureau of Standard The inspector did note that the mass flow meter was calibrated at a con-stant pressure of 14.39 to 14.42 psia, which is the low pressure end of the test rang The inspector requested the licensee to check the calibra-tion at the 30 psia range where the instrument is to be use This is an unresolved item (50-213/86-08-02).

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The licensee had not performed the calibrations for the Dew Cells or the resistance temperature detector This will be an inspector followup item to be reviewed prior to the test (50-213/86-08-03).

5.0 Local Leak Rate Testing 5.1 Documents Reviewed

• Technical Specifications 3.11 and 4.4;

• Amendment No. 49 to Haddam Neck Facility Operating License, May 13, 1982;

Selected piping and instrumentation drawings; and a

Surveillance procedure SUR 5.7-53, Revision 1, Auxiliary Containment Spray from Fire System, P-80; 5.2 Scope of the Review The inspector reviewed the documents listed above to determine compliance with the regulatory requirements of Appendix J to 10 CFR 50, Technical Specifications and conformance to applicable industry standards and station administrative guidelines. The inspector held discussions with the licensee regarding test methods, quantification methods, and valve line ups use .3 Findings During the review process the inspector noted the licensee continued to perform local leak rate testing with methods and under test con-ditions not approved through NRC regulations and/or technical posi-tion (water collection method testing, testing at high pressure, reverse direction testing). These items have been identified during previous NRC inspections of Local Leak Rate Testing activities and are the subject of continuing correspondence and a recent (March 12, 1986) licensee exemption reques The NRC Safety Evaluation report dated May 7, 1982 accompanying a Technical Specification change stated, " Type C testing with water as a test medium... is acceptable only where the hydraulic test is used to demonstrate a water seal at the penetration throughout the post-accident period."

A Technical Evaluation Report submitted to the NRC by Franklin Re-search Center was attached in which an evaluation was performed on Type C testing with water as a test medium in lieu of air or nitroge The result of this evaluation indicates this method was not acceptabl To the date of this inspection, the licensee is still performing LLRT by the water collection method which is not an approved metho . _ _ _ - -

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Technical Specification 4.4.II.A states the following, " Leak detec-tion tests of the following components shall be performed locally at j a pressure of not less than 40 psig, using halogen gas detection,

soap bubbles, pressure decay, or other methods of equivalent sensi-J tivity... Isolation valves on lines penetrating containment."

l Contrary to this, the licensee performs Local Leak Rate Testing via the water collection method for numerous penetrations. This water collection method is not a method of equivalent sensitivit Failure to comply with Technical Specifications is a violation (50-213/

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86-08-04).

During the review of the P&ID's for valve line-ups, the inspector noted that two valves were reclassified as containment isolation valves. The containment spray line, Penetration P-80, has a single check valve in a line open to containment. The only method available to the licensee to perform a LLRT on this valve is to do an ILR The licensee therefore designated FM-MOV-31 as the isolation valve for the penetratio CFR 50.59(b) requires the licensee to per-

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form a written safety evaluation report (SER) which provides the

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basis for the determination that the change does not involve an unreviewed safety questio I A second example is the licensee's designation of SA-U-413 as a manual containment 1 solation valve for penetration P-62 (Service Air). The reason the licensee designated this valve as an isolation valve was because of the excessive leakages through the two check valves, SA-CV-415 and SA-CV-41 The licensee again failed to perform the required safety evaluation to show no unreviewed safety question exists as a result of the chang <

Contrary tc 10 CFR 50.59, the licensee failed to provide a SER show-ing that an unreviewed safety question does not exist as a result of changes to containment boundaries. Failure to perform a 50.59 safety evaluation is a violation (50-213/86-08-05).

l During the inspector's review for SA-V-413 it was discovered that '

Operations Surveillance procedure No. SUR 5. 1-6, Reactor Containment

- Leak Monitoring, which monitors containment leakage is performed on a daily basis to ensure that the leakage from the ccntainment is main-tained within the limits and also provides a method of periodically charging air into the containment. Because of the leakage problem with the check valves, SA-V-413 which is a manual locked closed valve has to be unlocked and operied. Section 3.11 of the Technical Speci-fications requires maintaining containment integrity when the reactor coolant system is above 300 psig and 200 F and Section 1.8 of the Technical Specifications that manual containment isolation valves be closed to maintain containment integrit l

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Contrary to the above, the licensee unlocked and opened this valve on three different occasions, January 7, 1985, March 7, 1985 and November 15, 1985 when containment integrity was required. This is in violation of the Technical Specifications (50-213/86-08-06).

6.0 Exit Meeting A meeting was held on March 14, 1986 to discuss the scope and findings of the inspection as delineated in this report (see section 1 for attendees).

At no time during this inspection was written information provided to the license