IR 05000219/1986027
| ML20203N804 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/01/1986 |
| From: | Anderson C, Chung J, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203N799 | List: |
| References | |
| 50-219-86-27, NUDOCS 8610200036 | |
| Download: ML20203N804 (8) | |
Text
.
.
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
86-27 Docket No.
50-219 License No.
DPR-16 Priority
-
Category C
Licensee:
General Public Utilities Nuclear Corporation Post Office Box 338 Forked River, New Jersey 08731 Facility Name:
Oyster Creek Nuclear Generating Station Inspection At:
Forked River New Jersey Inspection Conducted:
September 4-9, 1986 b
/
I6 Inspectors:
-#
,
Jin W.'Chu6g, Lead Reactor Engineer da e clC
/,
lo f6 a
Jos 1, Rea o Engineer date Approved by:
/o N
,
C1.iff# V J. finderson, Chief, date
~
Plant Systems Section, EB Inspection Summary:
Inspection September 4-9, 1986 / Inspection Report No. 50-219/86-27).
Areas Inspected:
Routine unannounced inspection of test witnessing and preliminary results evaluation of local leak rate test (LLRT) and preliminary evaluation of forthcoming containment integrated leak rate test (CILRT)
procedure.
Results: No violations or deviations were identified.
8610200036 861007 PDR ADOCK 05000219 G
_
.
_ - - - - - -. -.
_ _ _
.
..
.
.
v
.
...
,
DETAILS 1.0 Persons Contacted
- George Busch, Licensing Engineer Mike Button, Group Supervisor-Operational Maintenance William Emrich, Senior Engineer
- Peter Fiedler, Vice President & Director of Operations
- S. Fuller, Operations QA Manager
.
Kenneth Hutko, Core Engineering - Engineer Donald Notigan, Engineer - Core Engineering
- Arthur Rone, Manager - Operations Engineering
- Jack Williams, Training Department USNRC
- William Bateman, Senior Resident Inspector Jacob Wechselberger, Resident Inspector
- Denotes those present at the exit meeting on September 9, 1986.
2.0 Local Leak Rate Testing (LLRT)
The purpose of this inspection was to ascertain that the LLRT was
~
conducted in compliance with the requirements and commitments referenced in the following sections, and that the test results met the acceptance criteria specified in the station procedures and Appendix J, 10 CFR 50.
The procedures.were reviewed for their technical adequacy to perform the intended activities.
2.1 References
Oyster Creek Nuclear Generating Station Technical Specifications Section 4.5.
10 CFR; Part 50, Appendix J, Primary Reactor Containment Leakage
Testing for Water Cooled Power Reactors
- '
Final Safety Analysis Report (FSAR)
ANSI /ANS 56.8-1981, Containment Systems Leakage Testing
Requirements
USNRC I&E Information Notice No. 85-71; Containment Integrated Leak Rate Tests
.
.
j
-
.
1
.
2.2 Documents Reviewed 665.5.006, Local Leak Rate Tests, Revision 15
665.5.005, Drywell Airlock Leak Rate Test, Revision 8
065.5.004, Feedwater Isolation Valve Leak Rate Test, Revision 5
$65.5.003. Main Steam Isolation Valve Leak Rate Test, Revision 8
665.5.020, Integrated Local Leak Rate Summary, Revision 2
- alibration Data For Leak Rate Monitor No. 8732
LLRT Results Running Total
~
2.3 Test Witnessing
'The inspector witnessed the performance of test activities to verify that.
- approved test procedures were available and in use.
- the procedures were adequately detailed to assure satisfactory performance.
- parts and materials were properly identified.
- qualified test equipment and tools were used.
The following test was witnessed: Mass flow retest of valve No. V-6-393 of the instrument air and nitrogen system performed on September 8, 1986.
The test was conducted with the valve in a post maintenance or "as-left" condition. The valve had previously failed the procedural acceptance criteria of 12.08 SCFH in its "as-found" condition. The valve passed the acceptance criteria in its "as-left" condition with a leak rate of 8.155 SCFH.
The inspectors noted that t
test personnel were using an approved test procedure, 665.5.006, and were qualified to conduct the test.
2.4 LLRT-Methodology The inspectors noted that the licensee utilizes two separate methods to conduct type c leak testing; they are:
1)
Mass flow method - approved per 10 CFR 50, Appendix J 2)
Pressure decay method - backup to mass flow method; approved
"where appropriate" per 10 CFR 50, Appendix J r
!
.
.
.
The licensee uses the nass flow method as the " primary" method and the pressure decay method as a backup. The inspectors determined through a test results comparison, see below, that the pressure decay method yields a more conservative leak rate.
Pressure Decay Mass Flow Method Method Valve Tested NSO4B NSO4B Test Date April 20, 1986 April 17, 1986-Test Type As-Found As-Found Test Result 4.230 SCFH 2.246 SCFH (at 20 psig)
2.5 Test Instrumentation Calibration records for the leak rate monitor (LRM) used to conduct the mass flow test described in Section 2.3 were reviewed by the inspector. Calibration records for the standards used to test the LRM were reviewed and these records indicated that the standards had
" certified accuracy" at the time the LRM was tested and that the standards were all within their calibration frequency.
These records indicated also that instruments used to calibrate the standards were traceable to the N=tional Bureau of' Standards, (NBS).
No unacceptable conditions were '
ntified.
2.6 Administrative Control The inspectors interviewed selected licensee personnel and reviewed selected administrative procedures to verify the adequacy of the maintenance activities involving containment isolation valves (CIV's)
and containment penetrations. Additionally a " Generic" licensee document pertaining to maintenance was reviewed as well as the maintenance history for the current outage of the valve discussed in Section 2.3.
Administc6tive control of maintenance appears orderly and well established.
No unacceptable conditions were identified.
-,. - -
- -,,
~
,
..,.-may,
_ -. - -..,,,
.
.
..
,
2.7 Test Results Local leak rate testing was in progress at the time of the inspection, therefore a final local leak rate total was not available.
The inspectors noted that the LLRT results were documented in an organized manner and in accordance with the established procedure.
Information concerning the LLRT of each individual CIV or penetration is contained in a package of several data sheets. An LLRT running total is recorded such that "As-Found" and "As-Left" results are easily distinguishable.
The inspectors determined that the licensee is calculating the maximum pathway leakage for test results to be applied in the determination of the total local leak rate, and that minimum pathway leakage is determined for penetration leakage that will be added on to the integrated total of the upcoming CILRT. These are the accepted methods of determining leakage through a piping network.
The inspectors discussed the provisions of IE information notice 85-71 " Containment Integrated Leak Rate Tests" with the licensee.
The licensee understood its provisions with regard to the determination of an "As-Found" Leak Rate from a.CILRT performed with containment pressure boundaries (CPB's) in an "As-Left" condition.
The licensee has stated that they will implement the provisions of the information notice for the upcoming CILRT.
No unacceptable conditions were identified.
3.0 Licensing Issues on Local Leak Rate Tests 3.1 Exemption Reauest From Type "C" Test In a letter dated December 24, 1975, supplemented by a letter dated August 12, 1976, the licensee requested an exemption from the type
"C" LLRT requirements for 28 valves.
In a subsequent response letter from the NRC dated December 3, 1976, the request for the exemption l
was denied based on insufficient justification.
The licensee subsequently submitted a supplemental letter on November 22, 1978, in which commitments were made to perform the test for certain valves and an exemption request for ten (10) valves was proposed based on further evaluation of the Appendix J, type "C" test requirements. The valves identified for the exemption request were;
V-17-19 V-14-33 V-17-54 V-14-34 V-14-30 V-14-35 V-14-31 V-14-36 V-14-32 V-14-37 l
.
I l
.
.
..
..
,
The proposed exemption was approved by a letter dated March 4, 1982, which stated neither exemption nor testing was required for V-17-19, V-17-54 or the other eight(8) valves.
3.2 Reverse Direction Test In response to a-letter dated August 12, 1976 requesting an exemption for reverse directicn testing of 13 valves, NRC letter dated December 3, 1976 stated that a specific exemption request for the valves was not required since Appendix J allows reverse direction testing, provided that the licensee documented the required justification (i.e., that the reverse direction test would provide either equivalent or conservative results), and that the documents were available at the plant site.
The inspector determinea that no such documents were available at the site. However, the inspector was informed, in writing, that seven(7)
of the proposed 13 valves were butterfly valves which by design had the same flow characteristics in both directions due to an in-line symmetrical disc. The licensee further explained that the remaining six(6) of 13 valves were globe valves, and that reverse direction
~
testing would yield more conservative leakage results since pressure acting in the reverse direction would tend to increase the leakage.
The following valves were tested in a reverse direction:
Butterfly Valve Globe Valve V-23-14 V-23-18 V-23-16 V-23-21 V-27-1 V-23-20 V-27-4 V-28-47 V-28-17 V-22-28 V-26-16 V-22-1 V-26-18 The licensee representative stated that detailed documentation of the rationale and justification for the reverse direction test would be provided in the future. This is an unresolved item pending final evaluation of the documentation (50-219/86-27-01).
4.0 Personnel Training and Qualifications The Qualification and training of selected test personnel were discussed with a licensee representative.
In addition the inspector evaluated the performance of test engineers during the test witnessing and reviewed their training and qualifications record,,
.
__
--_
- - - - - - - - - - - - - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _.. - - - - - - - - - - - - - -
.
.
l
-
-
,
..
?
The inspectors determined that the test engineers qualifications met the requirements specified in ANSI N 18.1-1971 " Selection and training of nuclear power plant personnel".
They were knowledgeable of their responsibilities and technical aspects of leak testing.
No unacceptable conditions were identified.
5.0 Containment Integrated Leak Rate Testing A draft copy of the CILRT station procedure for the upcoming (October, 1986) CILRT was obtained and is under review by the inspectors. The CILRT methodology for the upcoming test was discussed with the licensee.
The licensee stated that they plan to utilize the mass point method (MPM),
endorsed in ANSI /ANS-56.8-1981, for the CILRT as their primary method and the absolute method endorsed by ANSI N45.4-1972 as a secondary method in conjunction with the total time method (TTM) of data analysis. The inspectors informed the licensee that the TTM described in ANSI N 45.4-1972 is endorsed in 10 CFR 50, Appendix J and the MPM of ANSI /ANS-56.8-1981 is not, and that the data analysis technique of TTM was an acceptable method as per topical report, BN-TOP-1.
The problem regarding the MPM is its inability to fully report a change in leak rate with time. The method consists of determining the mass of air in the containment by application of the perfect gas law through reduced data gathered by an absolute system. The test data consists of a time series of independent values of contained air mass. The leakage rate is obtained by a straight line correlation using a least squares analysis of the mass points.
It can therefore inadequately respond.to a leak rate which is changing with time.
The licensee proposed additional acceptance criterion to be applied to the MPM results. They are; 1)
Ltm < 0.75 L at 95% upper confident limit (UCL) for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> t
reduced pressure test.
2)
The calculated leakage rate for the last 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a 24 hr.
test be less than 0.75 L.
(the 95% UCL may be disregarded for t
the final 8 hr. criteria).
The licensee stated that the addition of criteria No. 2 will show a change in the leak rate toward the end of the test.
This issue will be further discussed during a future inspection.
I
- _ _. -
.
.
.
.
6.0 QA/QC The inspectors discussed their coverage of the LLRTs with a QA/QC repre-sentative and reviewed information concerning the QA/QC organization.
It was determined from the discussion that QA " monitors" observe surveillance testing and QC " monitors" observe maintenance and repair work.
~
Based on the above review and observations, it was concluded that QA/QC coverage during the LLRT activities was adequate. No unacceptable conditions were identified.
7.0 Exit Meeting Licensee management was informed of the purpose and scope of the inspection at the entrance interview. The findings of the inspection were periodically discussed and were summarized at the exit meeting on September 9, 1986.
Attendees at the exit meeting are listed in section 1.0 of this report.
At no time during the inspection was written material provided to the licensee by the inspectors.
.