IR 05000237/1990006
| ML17202L200 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/28/1990 |
| From: | Lougheed V, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202L199 | List: |
| References | |
| 50-237-90-06, 50-237-90-6, 50-249-90-05, 50-249-90-5, NUDOCS 9004200358 | |
| Download: ML17202L200 (14) | |
Text
- ;.*
U.5,. NUCLEAR REGULATORY COMM.ISSION
.. :REGlON I II
. -.. '
Report Nos:
Docket Numbe~s:. 50-237; 50-249.'.
Li£ensee:
Commonweatth Ediso~
Li:censes Number:
DPR~l9* DPR-25
'
Facility Name:.
Dresden Nuclear Power Station~ Uni ts.2&3 Inspection At:
Morris, Illinois Inspection Conducted:
February 5,_ Marcti 8, 1~90 Inspector:
//(,t;j-µ11t.Rd_
- . V.. P. Lo.t1gheed Approved By:.
. *' r-l~f'J;~ ~..
Monte.If Phillips, C.hief
- Operational Programs Section Inspection Summary
..
...
,3/.;.:_a /C?n Date :
Date Inspection on Februar0 5 through March 8, 1990 (Reports No. 50-237/90006(DRS);
50-249/90005 (DRS)).
Areas lrispected:
Routine announced inspection by a regional based inspector *
in order to review the containment integrated.leak rate test (CILRT) and
local leak rate test (LLRT) procedures, review of the CILRT and LLRT test results, limited review of the engineering and technical support programs and closure of opeh item Inspection modules used during this inspection were 37700, 41400, 61720, 703Q7, 70323, 91701 and 91702~
Results:
The inspector found that the licensee had upgiaded th~ir tratning program' to adequately resolve the concerns expressed by the Diagnostic Evaluatio~ Tea The licensee had also resolved concerns with regard to modifying test acceptance criteria and attention to detai The licensee 1 s temporary modification program was a strength in that only a limited number of tempora~y ~lterations were open on both units, and less than five pe~cent of
'those open were over six months o 1 In tegard to their leak rate testing program, the licensee identified several penetrations which required LLRTs* but which had not been previously i.ncluded
- "in the progra These wer tested during thi.s.. outag The licensee committed to complete a study to d*o'cument the containment isolation valves (CIVS) and
- to define the testing required for.these valves in order.to s_how compliance with requirement The lfcensee -also committed to submitting this completed*
. study to NRR for approva Fa il.ure to perform LLRTs on these 1 i nes was a
- violation; however, because the licensee identified the. violation_, took prompt immediate corrective.action,. as well as long-term action-s to prevent
.
recurrence, th~ requirement~ of *10 CFR Part 2 Appendix C,Section V.G were met, and no violation was issue *
The inspector had several concerns *; n regard to the testing methodology used
- for the LLRT~.
These were discussed with the.licensee, including discussions held in the regio The li£en~ee committed to revise the methodology used to perform the LLRTs, and to make changes to their CILRT procedure in regard to documentation of valve lineups and proper venting and draining of lines prior to their next CILRT, scheduled for October 1990 on the other unit at the sit A violation was identified for fai1~re io include in a procedure the requirement to isolate the valves for *the service air 0 sy~tem prior to the CILR The licensee stated that they had verified that th~ line was closed but did not document thi An unresolved item was identified in regard to some quarter inch pneumatic lines which penetrate containmen The licensee did:not perform LLRTs on these lines and stated that they wer~ instrument lines, and, as such, exempt from the requirement to perform LLRT How.ever these lines were pneumatic lines to dampers inside containment; and were not co.nnected to any instrument~tio The licensee agreed to inc1ude these line~ in the submittal to NRR and that the need to perform LLRTs would be based on NRRs review and
. acceptance of the licensee's submitta Appendix J imposes a limit of.75La for the CILRT, and.6La for the total LLRT The as-found (beginning of outage) _leak rates for both tests _exceeded the allowable Since the as-fo!Jnd CILRT was above the acceptance criteria, the licensee must obtain approval of their next CILRT schedule from the
- C6mmission (per Appendix J).
- DETAIL'S *. ¥ersons -contacted. :commonwea 1th Edi so *G.. Bergan, On-site Nuclear Safety L. Decarlo, Training:
- E. Eenigenburg, Station Manager
- R. Falbo, Regulatory Assurance
+*J. Geiger, Tech Staff, (CILRT Test Lead Enginee~)
- L:\\Gerner, Technical 'Superintendent
+*J. Glover, Nu.clear Engineering Division
- *J. Harrington, Qual i 1;.y Assurance
+*M. Horbaczewski, Tech Staff (CILRT Test Director).
~J. Ketowski, Production Superi~tendent
- K. Peterman, Regulatory Assurance Supervisor
- M. Strait, TeCh Staff. Supervisor
U. S. NRC S. DuPont, Senior Resident Inspect6r
- D. Hill, Resid~nt,In~pector
-
- Attended exit interview held Feb~uary 23, 1990
+Attended in-region meeting held February 27, 1990 The inspector also interviewed other licensee employees during the course of the inspection, including ~e~6ers of the operations and technical staf * *
Licen$ee Action.on Previ~~sly -Identified Findings (Closed) Open It.em (237/88017-30):.
11 DET Items 2.2.4.1, 2.2.4.2, 2.2.4.3, 2.2.4.5. and 3.4.2.on Inadequ~te Training Program.
11 The inspector reviewed the licensee's training program interview~d training personnel, and atte~ded. a session of the continuing non-licensed operator training ~rogra The inspector determined that the training program for non-licensed p~rsonnel was adequat This item is considered close (Closed) Violations (237/88025-01) and (249/88027-01): "Failure to
.Carry Out Design Assumptions on a Safety Relat*ed Modification (250 VOC Batteries"._ The licensee revised p~ocedure OAP 5-1, Rev 19 to ensure that desig~ issumptions are properly translated to the fiel These items are considered close * (Closed) Violations (237/88025-02) and (249/88027-02:
11 0AD
.~ailure to Obtain Approval from BWRED Prior to Changing the Acceptance Criteria of 250 VD.C & 125.voe Battery Construction Tests
- The licensee revised procedure_DAP 5-1 to caution that any
- changes to BWRED acceptance criteria must be.coordinated with BWRED prior to making the change~ This was verified during the* inspection,.
as discussed in section These *items are considered closed*. (Closed) Open Item (237/88025-03):
"Obvious Errors on th Modification Packages Issued by the Staff Reviewers.
Based on the modifications reviewed, the licensee had increased their level of at;tention to detail, as no errors were discovere This item is considered Close (Closed) Open Items (237/88025-04) and (249/88027-03):
Document Control Should Always Inform Personnel Requesting a Controlled Drawing of All Outstanding ECNs, FCRs, etc.
When the inspector
- requested drawings on the modifications review~d, the.licensee informed the insp~~tor that there were outstanding r~visions on some of the drawings, and identified the outstandin~ wor These items are consi*dered close (Closed)'Open Items (237/88025-05) and (249/88027-04):
11 Procurement Inspection and Dedication of Commercial Grade Components to Regulatory Grade or Safety Related Grade Must be Improved to Meet G~neric Letter 89-02.
The licensee had made a corporate commitment to improve th~ir p~ocurement process for comme~cial
_grade items by January 1, 199 The licensee had revised their procedures for handling of commercial grade item Due to the increased effo~ts made on a corporate* basis in this area, these items are consi~e~ed close **
- (Closed) Open Item (249/86009-04):
11 Deficiency 2.1-4 from SSOMI:
Fail-ure to*Assure for Reattor Water Cleanup Leak Detection System that the Dot~~ented. Basis for the Temperature Trip Setpoint Reflected Actual Conditions.
This item is being tracked by NRR as TAC item 63971~ It is closed for Region III tracking pu~pose (Closed) Open Item (249/88027'."'05):
11 Failure to Follow Procedure:
Re~ctor Building Material Interlock 1nner Door Opened and Left Unattended.
The -licensee took the following immediate steps:
(1) Closure of the door, and (2) Permanent posting of a sign ihstructing that -the door was not to be left ope Other corrective actions included revising the pertinent procedures (Dresden Administrative Procedures (OAP) 13-3, Rev: 1, 11 Unit 2 Reactor Bui 1 ding Trackway r'nter lock Door Access Contra 1 (At the Reactor Building Railroad Door)
11 and OAP 13-14, Rev. 2, 11 Unit 3* Reactor 3ui lding Material Interlock* Access Control (Unit 3 *Reactor Building Material Interlock Inner Door) to elimi~ate any ambiguity about the door's status~
The inspector toured the reactor buildi~g and reviewed the procedurei. ~he licensee 1 s actions were considered to be adeauat This 'item is considered close * *
Review of Modification *Pa~kages (92702, 37700) *. Procedures The inspect-0r reviewed the following licensee procedures, in ~egard to the modification and commercial grade procurement program, and determined that they were acceptable:
OAP 5:-1, Rev. 19, 11 Plant Modification P.rogra'm
OAP 7-4, Rev. 11, 11 Control of Temporary System Al.terations
.
'
OAP 10-2, Rev. 2, 11Title 10 of the Code of Federal Regulations Part 50. 59, Review Screening and Safety Evaluations
.
OAP 11-5, Rev. 8, 11 Classification of Non-Safety-Related Subcomponents/Parts Used ON/IN Safety-Related Systems, Structures, and Component OAP 11-6, Rev. 7, 11 Request for Pu_rchase Preparat i on
OAP ll-7, Rev. 3, 11Technical Evaluation of Parts Used in Safety~
Related or Environmentally Qualified (EQ) Components
. OAP ll-15, Rev. 0, 11 Acceptance Testing of Electrical Commercial Grade Items for Use in Safety-Related Applications
.
\\
OAP ll-19, Rev. 1, 11 0edication of Commercial Grade Items for Safety-Related Applications"*
OAP ll-24, Rev. 1, 11 Receiving Instructions" Modifications (1) Modification Ml2-3-87-43:
11 Install Signal Isolators on the Reactor Protection System (RPS)."
This modification added Cl~ss 1E isolators to the RPS in order to isolate the non-saf~ty related _recorders from the safety related Neutron Monitoring Syste ;.
The inspector reviewed the modification packag As part of the package, the inspector noted that the licensee, in accordance with OAP 5-1, had notified BWREO that the acceotance criteria to the construction tests needed revision prior to performing the tes The inspector concluded, based on this review, that the licensee had resolved the concerns listed in Open Items 237/88025-02 and 249/88027-02.
- (2) Modification Ml2-3-87-39:
11 Automati.c Slowdown System (ABS) Time Delay Relay Replacement."
This modification replaced the *time delay relays which were used to initiate the AB Th~.old relays, GE Type CR120K, were susceptible ~o ~riftin Th~*new relays; Agastat'ETR1403G, had a*better accuracy and response t.i.. * *
The inspector re.viewed the modification package,. i *nc 1 udi ng the 50.. 59 safety evaluation, and installati.or:i and testing documents, and determined that_they were acceptabl *
((3)' *Mod1fication Ml2-3-86-24H:
11 Detailed Control Room Design Review (DCRDR) Human Engineering Deficiencies (HED)
11 Resolution Core Spray System Panel Rearrangemen This wa~ one of a number of partial mo~ifications which redesigned the Main Control Room Boards in order to resolve human factor concerns over the layout of th~ control room board This particular partial modification moved indicators and controls for the core spray syitem:
The inspector reviewed the modification package, including the installation and.testing package The inspector determined that the packages were acceptabl Temoorarv Alterations:* The inspector reviewed the licensee 1 s temporary alteration The inspector noted that the licensee had made a toncerted effort to limit the number of outstanding temporary alterations, ;~*that there were less than 40 temporary alter~tions for both unit The inspector also ~oted that the
majority of the temporary* al.terations were less than six months ol Safety evaluations were prop~rly completed on all the
~emporary ~lterations reviewed.*
Thi~ area appeared to be a strength for the license * Review of Containment Integrated Leak Rate Test Procedure (70307) Procedure Review The inspector *reviewed surveillance instruction DTS 1600-7 "Unit 2/3 I~tegrated Primary Containment leak Rate Test, Revision 9, dated February 1990, relative to the require~ents of 10 CFR 50, Appendix J; ANSI N45.4-1972; and the licensee 1 s Technical Specification This review was. done following the CILR The* inspector identified several valve lineup problems within the procedur The licensee committed to revise the procedure prior to the next CILRT, in October 199 Review of Valve Lineups The inspector reviewed and discussed the.valve lineups for the CILRT with the license The main concerns were the clean demineralized water system and the service air system, as the valve lineups for these systems were.not included in the CILRT procedur The licensee
stated.t.hat the systems were i so 1 ated, however this was not *
documented in a specific checklis The licensee also stated that the servke air system was in service (air compressor on) during the CURT *and that thE\\! line was not yented downstream of the CIV. (The licensee properly added a penalty to the CILRT results for failure to vent this llne. *However the inspectors considered,requiring
'imposition of a double penalty sinte the compresso~s not only wbuld have prevented air from leaking out but may have added air to the containmen Review of the ClLRT results with.this* additional.
penalty did not change the overall conclusions.)
The failure to have the valve lineup~ prestribed by procedures cohstitutes a violation of 10 CFR Part 50 Appendix B, Criterion V *
which requires that activities affecting quality be prescribed by instructions, procedµres, or drawihgs and be accomplished in accordance with these procedures. (500249/96005-0l(DRS)).
The inspector spot verified that the remainder of ihe penetrations were, by the procedure, in the proper post-accident lineu The inspector had questions on ~ome small diameter pneumatic lines which penetrated containment but were not type C teste The licensee originilJy stated that these lines were instrument lines; however; it was igreed that further review of these lines was necessary since they were not connected to any instrument These lines were to be included in the* licensee 1s study on the requirements for CIV Upon completion, the licensee agreed to submit this study to NRR for approva The status of these_lines (as to whether an LLRT is required) has been left as an unresolved item, pending submission of the.study and acceptance by NRR.. (50249/90005-02(DRS)). Clarification of Appendix J Requirements T6 ensure the *licensees'~ ~nderstanding of Appendix J requirements, and other applicable requirements, the inspector conducted numerous discussion with licensee personnel during the course of the inspectio The following clarifications were provided in order to ensure the licen~ee's understanding of Appendix J: Item (1) was revised in order to remove some conservatism; Item (2) was repeated because of problems enco~ntered in this area; Item (3) was previously discussed with the licensee, and is formally documented here; *and Items (4) and (5) were discussed with the licensee during the._exit meetin (1)
Periodic Type A, B, and C tests must includ~ as-found results as well as as-lef 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 results of repairs and adjustments (RA), to the Type A test results using the 11minimum pathway leakage 11 *methodolog This method requires that:
(a) *1n the case ~here i~dividual leak-rates.a~~ assigned.to two*
valves in series (both before and.after RA), the penetration through leakage woul~ simply be the smaller of the two valves
.* leak rates".*
(b)
In.the case where a leak rate is obtained by pressurizing between two isolati6n valves, and the individual valve 1s leak fate is not quantified, the as-found and as-left penetration through-1 eakage for each valve* would be 50% of the measured leak r~te if both valves are repa~re (c)
In the case whefe ~ leak rate**is obtained by pressurizing between two isolation valves and ~nly one valve is repaired, the as-found penetration leak rate shall be taken as either the final measured leak.rate or the difference between the measured as-found and as-left leak rate, whichever is
- smaller:
In either case, the as-left Leak rate would be zero.
. (2)
Penetrations*.whi~h are requir~d to be Type C tested as described in the FSAR, the SER, or the Technical Specifications, must be vented inside and.outside the containment during the CILRT. *
(3)
(4)
(5)
All vented penetrations must b~ draihed bf water iniide the containment and between the penetration valves to ensure exposure of the containment isolation valves to containment air test pressur The degree of draining of vented pehetrations outside of containment is controlled by the requirement that the valves be subjected to the post~accident differential pressure, -or.proof that the system was bujlt to st~ingent quality standards comparable to those required for a* seismic syste *
Th~ periodic retest schedule for each penetration ~ubject to Type B or C testing, except for airlocks and penetrations employing a cqntinuous leakage monitoring system, shall be every refueling outage, but in no case shall the interval be greater than.two year All air sources left.inside containment during a CILRT shall be vented to* atmosphere dur~ng the tes If *they are not vented, th~n they shall be monitore The CILRT penalty taken shall take into account the readability and sensitivity of the monitoring:instr.umentation. *rf the air sources are*neither vented or monitored, the penalty added to the CILRT results shall assume th~t the air source went from its design pressure to the test press~re during* the course of the tes When determining the results of the Type B and C tests, the minimum readability accuracy and sensitivity of the a*
instrumentation used shall be accounted fo ~o leakage rates shall be reported as zero, b~t shall rattier be reported as the minimum discernible valu.
Test Results Evaluati6n (70323) * CILRT Data Evaluation I
.
. A 7 1/2 hour CILRT~as performed during February 4, 1990, at*:6 psia following sattsf~ctory completiori ~f the required temperature stabilization perio Data* was collected every 10 minute The.
inspector independently ev~luated leak rate data using total time (BN-TOP-1)
formul~s to verify the licensee 1 s calculations of the leak rate and. instrument performance~ There was good agreement
.between t~e inspector 1 s a~d licensee 1 s results as indicated by the following summary*(unfts are in weight percent per -day).
- Measurement Licensee Inspector Leak rate measured
- o. 104 0.704
. during CILRT (Lam)
Lam at upper 95%.
'0.769 0. 770
- confidence-level
Appendix J acceptance criteria at 95~6 UCL:' <0. 75 La = < l. 2 wt%/ da At the completion of the CILRT ~nd the supplemental test, the licensee was required to* make Corrections to the calculated La_m at the 95% UCL due t& changes in volume of various water soufces inside*
containment, as well as changes due to non-vented air sources *
inside containmen The following correction to Lam w~re recorded and calculated by the license Water Source Equipment Drain Sump Floor Drain Sump Total:.
Change in Volume 39 cuft;
-4.5.cuft; 43.5 cuft Leakage, due to increase in sump levels, _was 0.048 wt%/da Air Source Change in Pressure
.
.
MSIV Accumulators (4)
52 psi Leakage,.due to air sources, was 0. 008 wt%/ da *'
J"*
'
.~
Totai increase in leakage at the 95% UCL,was 0.056 wt%/day for a total of 0. 826 wt%/ da This is* be 1 ow the_ acceptance criteria of l. 2 wt%/ da,, *
b. * Suoplemental Test Data Evaluatio *
l, After.the satisfactory complet'ion~of the *crLRT, a known leakage rate o.f 783 scfh, equivalent to.1. 54 wt%/ day was induce Data was collected and analyzed by the licensee every 10 minute The inspector indepentjently evaluated leak rate caltulatioMs using the data submitted by *the licensee, including the post test calibration of the flowmeter, to verify the licensee 1s result After 4.167 hours0.00193 days <br />0.0464 hours <br />2.761243e-4 weeks <br />6.35435e-5 months <br />, the s~pplemental teit was terminated with satisfactory results as indicated by the following summary (units are in wt%/day).
The results.were stable within th~ acceptance criteri Measurement Licensee InsQector Measured leakage rate, Le, 2. 263,.
2.263 during suppl~mental test Induced leakage rate, Lo 1.520 1. 539 I ~ -
-'-
(Lo + Lain) : '
0.039 0.020 Appendix J acceptance criteria -0.400 < [le -(Lo ~Lam)l~ 0.400 CILRT Valve Lineup Penalties *
Due to ~alve configurations which deviated from the ideal penetration valve lineup requirements for,the CILRT, the results of* LLRTs for such penetrations must be added ~s a penalty to Lam at the 95% UCL. *
The following penaltfes were added using the 11 minimum pathway leakage
method:
Penetration (System)
X-101 (Personnel Airlock)
X-107A&B (Feedwater)
Lo~al leak Rate Test Value (Units are in SCFH)
- o. 30 15.18 0.53 53.77 0.83 X-109A (Isolation Conden.ser)
- x-lllA&B (Shutdown.Reactoi Cooling)
X-113 (Reactor Water Cleanup)
X-116A&B (Low Pressure Coolant Injection to Containment}
( LPCI)).
.
X-145, 150A (LPCI to Core)
X-310A&B (LPCI Test Line)
. }
16. 42
X-311A&s' (LPCI.to,Suppression :Pool Spray).
X-119 (Clean Oemineralized Water)
X-120 (Service Air)
- X-122 (Reactor Water Sample)
..
X-138 CStandby..Liquid.Control).
2.49 3.49*
5.24 X-149A&B (Core Spray)
1.13 X-317 (High Pressure Coolant Injection
Turbine.Exhaust line)
- Total Type C Leakage *Penalty:
99. 38 (or.. 0.1.95 wt%/day)
After taking *thes~ local penalties into account, the final upper 95%.
confidence value for containment leakage was equal to 1.021 wt%/day, which is within the acceptable value of< 1.2 wt%/da Addition'of a "double penalty" for the service air system raises the leakage rate to 1.027 wt%/day, which is still acceptabl As-Found Condition of Containment The as-found condiiion is the condition of the containment at the beginning of the outage p~ior to any repaits or adjustments to the contail'lffient. boundar The inspector reviewed the licensee 1 s summary of the** containment penetration LLRTs (Type B and C) performed prior to the CILRT in order to determine the amount of leakage rate improvement due to repairs or adjustment Based on the results revie~ed, th~ inspector determined that the amount tif the leakage improvement prior*to the CILRT equalled 123.91 scfh, or the
equivalent of 0.244 wt%/da Based on this, the as found containment leakage rate, at the 95% UCL, was 1.265 wt%/da The containment was considered to have failed the as-found periodic CILR.
Review of Local Leak Rate Testing (Type B and C) Program (61720)
- Procedures The inspector reviewed.the following procedures in regard to the licensee 1 s LLRJs:
(1)
OAP 14-5 "Leak Rate Testing Program, 11 Revision 2, including Temporary Change Number 90-103; (2)
DTS 250-1 11 Main Steam'Isolation Valve Local leak Rate (Dry) Test, 11 Revisi.on 8;
(3)
DJS 1600-1 11 Local *Leak Rate Testing of Primary *containment lsol at ion Valves,.... Revision 13;
- (4)
.
.
DTS 1600-2 -"Local Leak Rate Test Procedure Penetrations, 11 Revision.6; Be J1 ows Sea 1 ( 5)
DTS.1600:-4 11 Local Leak Rate Testing for El ectri cal Penetrations,
Revision 8; (6)
DTS 1600..,4 11 Loca*1 Leak Rate Testing for Electrical Penetrations, 11 Revision 8; (7)
DTS 1600-9 11 Augmented ASMESection XI Leakage Rate Testing,'
11 Revision O; (8)
DTS 1600~14 11 Local Leak Rate Testing of Personnel Access Loc_k, 11 Revision 8;.:
(9)
DTS 1600-15 11 Local Leak Rate Testing of Double Gasketed *
Seals, 11.*Revision 7
- *
The inspector had several comments on these procedures, mainly in regard to a correction factor used by the licensee to co~rect the leakag~ rates back to design pressure, This is discussed further in Section 6.c belo Newly Identified Penetrations*
As a result of *a study performed at another site of the licens~e 1 s, the licensee identified three penetrations which should have been local leak rate tested, but which had not previously been teste During this outage, the licensee tested at least one valve in each line (testing was limited by lack of test connections), and the leak rates were acceptabl The licensee committed to perform a study to ensure that all other penetrations have received requir~d testing and that the valves would be properly tested in future outage CFR Part 50, Appendix J,.Section III.C requires testing of conta~nment isolation valve Failure to test these valves during previpus outages was a violation of the above requirement~ However,
- since the license~ identified the item, *reported it, took appropriate corrective action as well as long-term acti6ns to prevent recurrence, this violation ~eets the criteria of 10 CFR Part 2, Appendix C Section V.G fo~ non-cited.violation Therefore, no notice of violation wi.11 be.issue Correction Factor D_uri ng this outage, the.Ji cens.ee used the pressure decay method* for determining the local. l~ak.rates.* This method interprets a change in ~ressure as being indicative of the leak rat Use of this method resulted in average.test pre~sures which were higher or lower
- than-the accident pressure-(Pa=48*ps.ig). **Since 10 CFR 50 Appendix*J*
requires that CIV testing be performed *at Pa, the.1 i cen*see corrected the l~ak rates from -.test :pressure to Pa through a correction factor de.scr.ibed in thei_.r. test procedur *
While :use *of this. correction is conservative for test pressures 1 ess *
than *pa, in that it raises the leak rate.from what was measured, Appendix J does not allow for extrapolation to Pa for local leak rate.:test AdditiDnally., use of a correction factor *in the downward direction (from a test pressure higher than Pa) is noii-conservative* since a CIV which was leaking through the.seat might tiav~ a lower leak rate at.the higher pressure than it would at P Use of a correction factor in lieu of testing at Pa was a violation of the requirements-of Appendix J Section IIIC.2.a..
During a meeting in the regional offices held February 27, 1990, the licensee provided.information on the derivation of the correction facto The licensee also stated that they had incorrectly applied the coriection factor in certain tase Some lines had required pressurizi~g to an extremely high pressure (100 psig) in order to overcome back.pre~sure in the lin The licensee originally correctly these lines down to test pressure, when in reality, the te~ts were conducted at test pressur The* revised numbers.were given to* the inspector, and were used 1n this repor The inspector performed a c~lculation factor on the CILRT and LLRT results.
did not increase the r~sults past the therefore, deem~d inconsequential for of the effects of the correction Using non-corrected results third decimal place and were, this tes The licensee verbally committed to revising their pr6cedures to use the flow makeup testing method.* The licensee stated that if the pressure decay method was used in*the future (such as for very large volumes), then a *Jimit of 4% of Pa would be placed on the pressure',
and the correcti~n factor ~o~ld not be used. The use of the pressure decay method in this manner was acceptab l_e to the inspector.*
Ba~ed on the info~maticin provided, the. revised numberi, and the licensee's commit~ent to switch to the flow makeup method, the requirements of,10 CFR 2 Appendix C Section V.A have been met and no violation will be' issue Local Leak Rate Test Results The licensee's Technical Specifications require that the total of the LLRTs, when c~lculated by the maximum pathway meth6d and
'.c**
- .
- ~
,.
e*xclusive of the MainStea*m Iso.lation Valves, be. less than 0.6La, v1hich is equivalent to 608.84 scf The as-found LLRT total was 3411.09 scfh or~4La. The final as-left LLRT total.was 470.56 scfh,-or 0.58L This *high value for the as-left LLRTs was
- ~iscussed with the license The licensee stated that this was a management deci. s i 9n in -order not to extend the outage. The
~!inspector reminded the licensee that leaving this small a margin to their administrative limit for LLRTs may impose operability
constraints du~ing the next cycle if future tests during the outage
.
- raised the to~al above* 0.6 L The licensee acknowledged this warnin~. Unresolved Items Unresolved items are matters which have been discussed with the licensee and which r.equire further action on the part of either the licensee or the-NR An unresolved item~ requiring ~ction on the licensee's part, was discussed in Paragraph 4.b of this repor.
Exit Interview The inspector met wi_th licensee representatives (denoted in Paragraph 1)
throughout the insp~c~jon~ An exit meeting was held prior to* leaving the sit Following review of all d~ta submitted by th~ licensee an additional exit meeting conducted by telephone on March 8, 1990..The ihspector summarized the scope and findings of the inspectio The licensee acknowledged these finding The inspector also discussed the likely informational conteni of the inspection report with regards to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents or processes as proprietar :~ ~,....