IR 05000219/1980010

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IE Insp Rept 50-219/80-10 on 800317-20.Noncompliance Noted: Failure to Implement Inservice Testing Program & Procedures Per Tech Spec 6.8
ML19320D675
Person / Time
Site: Oyster Creek
Issue date: 05/06/1980
From: Caphton D, Rekito W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19320D665 List:
References
50-219-80-10, NUDOCS 8007220060
Download: ML19320D675 (9)


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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-219/80-10 Docket No. 50-219 License No. DPR-16 Priority

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Category C

Licensee:

Jersey Central Power and Light Company

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Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 Facility Name:

Ovster Creek Nuclear Generating Station Inspection at:

Forked River, New Jersey Inspection conducted: March 17-20, 1980 Inspectors:

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W. A. Rekito, Reactor Inspector date signed

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date signed 1.

date signed hpproved by; i.

A OfA/lf>)

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D.L.Caphton(Chief,NuclearSupport

/ dat'e signed Section No. 1, RO&NS Branch Inspection Summary:

Inspection on March 17-2G, 1980 (Report No. 50-219/80-10)

Areas Inspected:

Routine, unannounced inspection by a regional based inspector of the containment integrated leak rate test procedure; containment penetration leak rate test activities; inservice testing of safety related pumps and valves; and licensee action on previous inspection findings. The Inspection involved 32 inspector hours on site by one regional based inspector.

Results: Of the four areas inspected, no items of noncompliance were found in two areas, one item of noncompliance was found in one area (Infraction-Failure to implement an inservice testing program, para. 3) and one item of noncompliance was found in the fourth area (Deficiency-Failure to implement procedures per TS 6.8, para. 2).

Region I Form 12 (Rev. April 77)

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DETAILS

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1.

Persons Contacted

  • J. Carroll, Station Superintendent
  • K. Fickiessen, Technical Superintendent
  • A. Rone, Technical Supervisor
  • W. Stewart, Management Control Supervisor

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  • J. Sullivan, Chief Engineer R. Thompson, Technical Engineer The inspector also talked with and interviewed other licensee personnel during this inspection.

They included members of the technical and operating staffs.

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  • Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings a.

Items Closed (Closed) Unresolved Item (219/79-08-01):

(1)

Local Leak Rate Test Procedure 665.5.006, Rev. 1, dated 1/3/80 included valve lineups and sketches for individual valve and containment penetration tests. This action provides assurance that piping is properly vented and drained for conducting each test.

(2) The inspector reviewed data sheets and test records for local leak rate testing from January 6, 1980 to March 15.

1980. The method of documentation appeared to be in order and in accordance with the approved procedure.

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(3)

Procedure 665.5.006, Rev. 1, dated 1/3/80, includes instructions on each data sheet to add the correction factor of 0.01SLM (standard liters per minute) when using the leak rate test monitor.

(4)

In a letter dated November 22, 1978, the licensee identified that the Reactor Water Sample System valves V24-29 and V24-30 were not testable and requested an exemption from requirements of 10CFR50, Appendix J, until a system modification could be completed.

The procedure revision deleted the test requirement for these two valves.

However, the omission of these tests during 1977 and 1978 did not conform to the procedural implementation requirements of TS 6.8.1 and 6.8.2.

In addition, the method of documentation for this apparent change did not conform to temporary procedure change requirements of TS 6.8.3 and Administrative Procedure 107, Procedure Control.

Nonconformance to these requirements constitutes an item of noncompliance.

(219/80-10-01)

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(5) Th inspector reviewed Data Sheet 28 and others from t.sts conducted in 1978 and verified that the Technical Supervisor had reviewed and signed each as required by the procedure.

(Closed) Unresolved Item (219/79-08-03):

Procedure 665.5.003, Rev. 3 dated 2/22/80 revised the method used to test the in-board main steam isolation valves (MSIVs) to yield conserva-tive results. This change includes adding the leakage rate

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measured for the outboard MSIV to the results of the inboard MSIV test.

b.

Items Open (0 pen) Unresolved Item (219/78-34-01):

The inspector reviewed a " Draft" copy of the containment integrated leak rate test pro;edure 666.5.007 and noted that it included provisions for instrument weighting factors and administrative controls of the computer program. This item will remain open until the procedure is approved and implemented with the noted changes.

(0' pen) Unresolved Item (219/79-08-02):

The licensee has not yet revised the procedure for "Drywell Airlock Leak Rate Test" but discussed with the inspector his intentions to do so during the current refueling outage.

The inspector noted that the following proposed procedure changes appeared to be acceptable.

(1) Use a temperature recorder or transmitter located inside the airlock to verify that temperature has stabilized after pressurizing.

(2) When using the pressure decay method of test, include the effect of temperature changes in the leak rate calculation.

(3)

Permit the option of using the Volumetrics Leak Rate Monitor in lieu of the pressure decay method.

This item will remain open until appropriate revisions are made to the procedure and implemented.

3.

Inservice Testing of Pumps and Valves a.

Documents Reviewed ASME Boiler and Pressure Vessel Code,Section XI, Subsections

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IWP and IWV, " Inservice Testing of Pumps and Valves in l

Nuclear Power Plants",1974 edition with Summer 1975 i

Addenda.

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" Inservice Inspection Program Manual" for Oyster Creek

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Nuclear Generating Station, dated August 3, 1979.

j Letter from the NRC to Jersey Central Power and Light

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Company, dated January 14, 1980, granting interim approval of Oyster _ Creek Nuclear Generating Station's Inservice Inspection and Testing Program Submittal.

Procedure 610.4.002, Rev. 3, dated April 25, 1979, Core

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_ Spray Pump Operability Test.

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Procedure 607.4.001, Rev. 9, dated October 1, 1979,

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Containment Spray and Emergency Service Water Pump Operability

Test.

Procedure 607.3.002, Rev. 6, dated September 10, 1979,

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Containment Spray System Automatic Actuation Test.

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b.

Scope The inspector reviewed the licensee's inservice testing program of ASME Code Class 1, 2, and 3 pumps and valves for conformance

to Section XI of the ASME Code and the program submittal approved by NRR. The date for implementation for this program

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was December 8, 1979.

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Findings The inspector was informed by the licensee that not all the required test plans (procedures) have been completed and

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approved and that they were late in implementing the overall

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program requirements. The inspector reviewed several ~ existing i

test procedures and identified to the licensee that they did not include the requirements of ASME Section XI.

It was further noted that the program description identified procedures for testing pumps and valves in systems for which no sur-veillance procedures currently exist. These systems include Service Water, Closed Cooling Water, Fuel Pool Cooling, Condensate Transfer, Isolation Condenser, Reactor Recirculation, Reactor Head Cooling, and Demineralized Water Transfer.

The licensee has not met the requirements of ASME Section XI

for testing' pumps and valves included in the systems mentioned above since the required data was not taken nor were the required test plans-(procedures) completed. This failure to-noncompliance with 10CFR50.55 a(g) gram constitutes an item of-implement an inservice testing pro (219/80-10-2)

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4.

ContainmentIntegratedLeakRateTest(CILRT)_

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Documents Reviewed

" Primary Containment Leak Rate Test", Procedure 666.5.007

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DRAFT.

Oyster Creek Technical Specifications Section 4.5, Containment

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System.

Oyster Creek Containment Leakage Testing Program and

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Exemption Requests from the requirements of 10CFR50, Appendix J, dated November 22, 1978.

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Modification No. 259-78-26, Rev. O. dated October 22, 1979, Containment Leak Rate Testing Modification for Instrument Air and Nitrogen System.

Dwg No. GE 237 E 726, Rev.11, Drywell and Suppression

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System.

Dwg No. GE 148 F 262, Rev. 6, Emergency Condenser System.

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Dwg No. GE 148 F 740, Rev. 14, Containment Spray System.

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Dwg No. GE 886 D 403, Rev. 2, Reactor Head Cooling.

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Dwg No. B&R 2163, Rev. 3, Reactor Building N2 Purge &

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Makeup Piping Plan and Section.

Dwg No. B&R 2011, Rev. 8, HVAC Reactor Building.

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Dwg No. B&R 2013, Rev. O, " Instrument, Service, Breather,

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and Bleeder Check Trip Air System.

Dwg No. B&R 2003. Rev. 11, Condensate and Feedwater

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System.

Dwg No. GE 706 E 206, Rev.1, Drywell Equipment Arrange-

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ment.

b.

Scope The inspector reviewed a "pRAFT" copy (of procedurePCLRT), for technical 666.5.007,

" Primary Containment Leak Rate Test" adequacy and compliance with 10 CFR 50, Appendix J, ANSI 45.5 and Oyster Creek Technical Specifications.

The inspector also discussed various aspects of the CILRT with the licensee's representatives including, current NRC positions and the licensee's plans for the 1980 CILRT.

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With the exception of the items noted below and in paragraph 2, the inspector found no items of noncompliance and had no further questions in this area.

c.

Valve Lineup Review On a sampling basis, the inspector checked the PCLRT procedure valve lineup sheets to verify that:

Each penetration was provided with a valve lineup;

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Containment Isolation Valves (CIVs) were in the correct

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positions; Proper vent paths were provided; and

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Artificial leakage barriers were not created which could

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mask containment leakage.

Appendix J requires that systems which are part of the reactor containment boundary and which may be open to the containment or outside atmosphere under post accident conditions shall be opened or vented to the appropriate atmosphere during the test.

The current valve lineup does not properly vent the follow systems / penetrations outside of the containment:

(1)

Reactor Head Cooling (Pene X-62), CIV 31-2;

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(2) Nitrogen Purge and Makeup to Torus (Pene X-65), CIVs 23-15 and 23-19; (3)

Drywell Nitrogen Purge (Pene X-18), CIVs 23-17 and 23-13; (4)

Drywell Purge from Reactor Building (Pene X-18), CIV 27-3.

The licensee agreed to correct these discrepancies and conduct a complete review of all system valve lineups to assure they are properly vented for the test.

The above items are unresolved and are collectively designated item No. (219/80-10-3).

d.

10 CFR 50, Appendix J, Exemption Requests

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Following a meeting with NRR on February 24, 1977 concerning Oyster Creek conformance to Appendix J, the licensee submitted a revision to his exemption request.

In this revision dated November 22, 1978 the licensee has committed to performing hardware modifications to ten piping systems which would facilitate local leak rate testing of CIVs and accommodate venting requirements during the CILRT. These modifications will achieve greater conformance to Appendix J.

The inspector reviewed one modification i

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in progress for the Instrument Air and Nitrogen System and was informed that one other proposed modification had been completed on the Demineralized Water System.

The licensee's representative did not know the status of the remaining proposed modifications.

However, tae letter to NRR dated November 22, 1978 Stated, " Schedules for these modifications are being developed and will be submitted to the Commission". The inspector requested that a schedule for the remaining modifications be developed and provided to the NRC and the licensee agreed to do this.

This matter 'is considered unresolved.

(219/80-10-4)

5.

Local Leak Rate Testing (LLRT)

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Documents Reviewed Ir Addition To Those In Para. 4.a.

Procedure 665.5.006, Rev. 1, dated January 3, 1980, " Local

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Leak Rate Tests";

Procedure 665.5.003, Rev. 3, dated February 22, 1980, " Main

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Steam Isolation Valve Leak Rate Test".

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Scope The inspector reviewed the LLRT procedures listed above for technical adequacy and compliance with 10 CFR 50, Appendix J, ANSI 45.4, and Oyster Creek Technical Specification.

The inspector also discussed the status of the current LLRT program with the licensee's representative. Approximately 60% of the tests had been completed and the inspector reviewed the records from these tests.

With the exception of tne items noted below and in paragraph 2 the inspector found no items of noncompliance and had no further questions in this area.

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c.

Ac,r.eptance Criteria Th.. acceptance criteria of procedure 665.5.006 establishes a maximum allowed leakage rate for any one penetration or isolation valve. This corresponds to one of the four acceptance criteria in TS 4.5.F.

The other three establish leakage limits for; (1)

Total of all double gasketed seals, (2) Total of all penetrations and isolation valves, (3) Total primary containment air purge penetrations and reactor building to torus vacuum relief valves.

All of these correspond to a test pressure of 20 psig.

The tests are performed at an accident pressure (Pa) equal to 35 psig and the procedure conservatively adjusts the measured leakage to 20 psig.

10 CFR 50, Appendix J, has a different acceptance criteria for the cothined leakage rate for all penetrations and valves.

(less than.6 La at 35 psig)

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The inspector verified that each and all of the described acceptance criteria have been satisfied for the LLRTs conducted for the last two years. The inspector stated that the subject procedure should include all applicable acceptance criteria and the licensee's representative agreed to revise the procedure.

This item is unresolved and designated item (219/80-10-5).

d.

Leak Rate Test Modifications The inspector inquired about anticipated changes to the LLRT program due to system modifications currently being done. The licensee's representative identified the Modification No. 259-78-26 would permit testing of the Instrument Air and Nitrogen System CIVs V6-393, and V6-395. He further explained that appropriate test. procedures would be developed and implemented during the current refueling outage. This item will be reviewed by the inspector during a subsequent inspaction.

(219/80-10-07)

e.

Feedwater Isc lation Valves The inspector reviewed procedure 665.5.004 and questioned the licensee's representative about the feasibility of testing the Feedwater CIVs No. V-2-71 and V-2-72.

These valves are currently not being tested because of an existing Appendix J exemption and intended system modification which would facilitate testing all four feedwater CIVs.

The inspector explained the Region I position that all CIVs that are able to be tested should be tested. The licensee agreed that it was technically feasible to test the two outboard CIVs mentioned above and committed to develop e procedure and test these valves during the current refueling outage. This item is unresolved and designated item (219/80-10-6).

f.

MSIV Leak Rate Tests As stated in paragraph 2. procedure 665.5.003 was revised to yield conservative results by adding the measured leakage rate from the corresponding outboard MSIV to the results of the inboard MSIV test.

The licensee's representative proposed doing a reduced pressure test of the outboard MSIV and using this leakage rate as the adjustment to the inboard MSIV test resul ts.

This method appears to be more representative of the actual leakage possible past the outboard MSIV while testing the inboard MSIV and is considered acceptable.

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6.

Plant Tour The inspe: tor conducted periodic tours of various protected areas and the Control Root. Observations relative to security were made, including access controls, search, escort, and badging requirements.

The. inspector reviewed the Control Room Daily Logs, verified Control Room Manning Requirements and Technical Specifications for Refueling Mode were being met.

During these tours no items of noncompliance were identified.

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Unresolved Items Items about which more information is required to determine acceptability are considered unresolved.

Paragraphs 2, 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 March 20, 1980. The inspector summarized the scope and findings of the inspection at that time.

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