IR 05000244/1982008
| ML20053A784 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/10/1982 |
| From: | Bettenhausen L, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053A765 | List: |
| References | |
| 50-244-82-08, 50-244-82-8, NUDOCS 8205270273 | |
| Download: ML20053A784 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244/82-08
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Docket No.
50-244 License No. DPR-I8 Priority
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Category C
Licensee:
Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649 Facility Name:
R.E. Ginna Nuclear Power Plant Inspection at: Ontario, New York Inspection conducted: Apri
3, 982 W
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87M Inspector:
~ A.'Rekito, Reactor Inspector date' signed
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date signed date signed Approved by:
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S/d/O A~
L. H. Bette'nhausen, Chief, Test Programs date signed Section, Engineering Programs Branch Inspection Summary:
Inspection on April 20-25, 1982 (Report No. 50-244/82-08)
Areas Inspected:
Routine, unannounced inspection of licensee action on previous inspection findings; containment penetration leakage testing program; and prepara-tions for the containment integrated leakage rate test.
The inspection involved 35 inspector-hours on site by one region based NRC inspector.
Results:
No violations were identified.
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DETAILS 1.
Persons Contacted The technical and supervisory personnel listed below were contacted.
J. Bodine, QC Engineer
D. Gent, Results & Test Supervisor
G. Joss, Results & Test Technician G. Larizza, Technical Engineer
F. Scwind, Results & Test Technician R. Shirk, ILRT Engineer - Gilbert Associates
B. Snow, Plant Superintendent
P. Wilkens, Licensing Engineer NRC Personnel R. Zimmerman, Senior Resident Inspector The inspector also talked with and interviewed other licensee personnel during the inspection. They included members of the operating and technical staffs.
- denotes those present at the exit interview on April 23, 1982.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (244/76-15-07):
The licensee has completed piping system modifications which provide for venting and draining of containment penetrations to assure that containment isolation valves are leakage rate tested without a water seal on the valve seats.
These modifications were completed in accordance with Design Change No. 2507. On a sampling basis, the inspector reviewed the venting and draining instructions provided in the local leak rate test (LLRT)
Procedure PT-23 series and identified no problems. This item is considered resolve.
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R. E. Ginna Nuclear Power Plant
(Closed) Unresolved Item (244/76-15-08): The licensee has determined that type C testing the inboard Containment Purge Isolation valves in the reverse direction is equivalent to testing them in the containment leakage direction.
The inspector considered testing the Containment Purge Penetrations as prescribed in Procedure PT-23.35 and 36 to be an acceptable method.
This it,em is closed.
(Closed) Unresolved Item (244/78-08-02): The licensee has provided justification for not testing the RHR system CIV's which was found acceptable by the NRC as documented in Technical Specification Amend-ment 42.
This item is closed.
(Closed) Unresolved Item (244/78-16-01): The licensee performed an evaluation and ra-calculated the maximum allowable leakage, using the containment free volume specified in the FSAR, to confirm the limits used in his procedures and CILRT Report. The inspector reviewed these documents, performed independent calculations, and found the licensee's prescribed leakage limits to be accurate. This item is closed.
(Closed) Unresolved Item (244/78-16-02): The licensee revised the PT-22 series test procedures to specify an initial test pressure of 60 to 62 psig.
In addition, all test records from the 1978 outage were reviewed to ensure that the minimum test pressure of 60 psig was satisfied.
This item is closed.
(Closed) Unresolved Item (244/78-16-03): The licensee revised Procedure PT-22 data sheets to specify using the smallest calculated air density instead of the average density for pressure decay test leakage rate calculations.
This practice removes a possibility of non-conservative test results.
This item is closed.
(Closed) Unresolved Item (244/78-16-04): The licensee revised Procedure PT-23 to provide improved guidance to test personnel for investigating apparent leaks and determining if indicated leakage was through the CIV being tested or a test boundary isolation valve. The need to document these additional actions on the test data sheet was also enforced. The inspector reviewed special comments on several completed test data sheets and questioned test personnel on this matter.
He concluced that the practice was being carried out in an apparent controlled acceptable manner. This item is considered closed.
3.
Containment Local Leakage Rate Testing (LLRT)
3.1 Documents Reviewed
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Procedure PT-22, Revision 4, Containment Penetration Leak Rate Testing PT-22 series procedures for conducting Type 8 tests, numbers
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PT-22.1 through PT-22.2.
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R. E. Ginna Nuclear Power Plant
Procedure PT-23, Revision 14, Containment Isolation Valve
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Leak Rate Testing.
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PT-23 series procedures for conducting Type C tests, numbers PT-23.1 through PT-23.52.
Records of Local Leakage Rate Testing (LLRT) activities
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conducted during the recent outage including test results, related repair and retest documentation.
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Selected system drawings, Piping and Instrumentation Diagrams (P& IDS).
3.2 Scope of Review The inspector reviewed the above documents to ascertain compliance with regulatory requirements of 10 CFR 50, Appendix J, Technical Specifications, commitments to the NRC and applicable Industry Guides and Standards.
The inspector also examined special test instrumentation, reviewed qualifications of test personnel and held discussions regarding the relationship between LLRT failure results and the Containment Integrated Leakage Rate Test (CILRT)
evaluation of "AS FOUND" condition.
Further details and inspec-tion findings are described below.
3.3 Piping System Modifications In a letter to the NRC dated September 21, 1978, the licensee committed to modifying certain piping penetrations to provide the capability for draining fluid away from containment isolation valves (CIVs) during leakage rate testing of these containment boundaries.
The modifications have all been completed in accord-ance with Design Change No. 2507. The inspector reviewed these modificati ans to ascertain that required containment leakage rate tests were being performed, related procedures and drawings were updated and adequate controls were in place to assure maintenance of containment integrity.
No unacceptable conditions were identified.
3.4 Test Results The inspector reviewed the LLRT results summary and discussed analysis of test failures and status of repairs and retests with the licensee.
All LLRTs were completed except for CIVs for seven (7) penetrations. The inspector noted that several problems were encountered. The initial tests of containment isolation check valves (Check-304A, Check-1599. Check-8628) resulted in excessive unacceptable leakage; the valves had to be repaired and retested.
These problems did not represent d total containment system degradation because, in each situation, the leakage past the redundant leakage limiting barrier was not excessive. The inspector explained that the overall containment system leakage improvements
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resulting from these repairs and others prior to the CILRT are expected to be added to the results of the CILRT for determination of the "AS IS" test results in accordance with 10 CFR 50, Appendix J.
This requirement was acknowledged by the licensee and prelimi-nary evaluations of LLRT results for this purpose appeared to be
adequate.
3.5 Reportatility.
The inspector inquired about licensee intentions to report the noted LLRT results which exceeded their TS allowable limit of
l 0.60 La.
In accordance with Procedure A-25.1, Ginna Station
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Event Report, the Results and Test Supervisor submitted an event report on this subject. After PORC review on April 22, 1982, the t
j Plant Superintendent discussed the applicable reporting requirements with the inspector. At this time and during the exit meeting he st:ted his plans to submit an appropriate Licensee Event Report (LER).
This statement satisfied the inspector's concern.
I 3.6 Test Personnel Qualifications The inspector interviewed several persons involved with containment LLRT activities to ascertain degree of knowledge for procedural and regulatory requirements, level of experience and adequacy of training. The inspector also reviewed Procedure A-1102, Qualifi-cation of Test Personnel, and a sample of Personnel Qualification Certificates.
From these reviews the inspector determined that the Qualifications of LLRT personnel appeared to be satisfactory.
4.
Containment Integrated Leakage Rate Test (CILRT)
i 4.1 Occuments Reviewed
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Procedure RSSP-6.0, Revision 8, Containment Integrated i
Leakage Rate Test.
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Draft Procedure RSSP-6.1, Revision 7, Integrated Leakage Rate Test Valving Alignment.
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Procedure RSSP-6.2, Revision 3, Pressurization Monitoring of
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Penetration Free Volumes During Containment Integrated Leak
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Rate Test (CILR Test).
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Procedure RSSP-6.3, Revision 4, Air Supply for Integrated Leak Rate Test.
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Procedure CP-52, Revision 0, Containment Temperature Monitoring
a System.
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Procedure CP-50.0, Revision 1, Containment Atmosphere Dewpoint Instrument Calibration.
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R. E. Ginna Nuclear Power Plant
4.2 Scope of Review
The inspector reviewed the CILRT prccedures listed above along with
the documents listed in paragraph 3.1 for technical adequacy and to
ascertain compliance with Technical Specification 4.4 and commitments q
for compliance with 10 CFR 50, Appendix J.
The inspector discussed
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various aspects of the CILRT with the licensee's representatives, i
ir.cluding personnel training, plans and preparations in progress.
Also discussed was the NRC position regarding the need to account for containment system overall leakage improvements preceding the CILRT when evaluating and reporting the "AS FOUND" condition.
During this review the inspector noted that the CILRT procedures were in general conformance with the guidance of ANSI /ANS 56.8-1981, Containment System Leakage Testing Requirements.
Further details and inspector findings are described below.
4.3 Leakage Rate Calculational Method The inspector noted that the CILRT procedures did not identify use
of the Mass Point Analysis Technique which is the one currently accepted by the NRC. The licensee explained that their computer
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leakage rate calculation program provides analysis using Total Time, Point to Point, and Mass Point Analysis Techniques and that the later would be used for reporting the official test results.
The licensee further satisfied the inspector's concern by initiating
a procedure revision which specified use of the Mass Point Analysis Technique in Test Requirements Section 2.2.
4.4 Acceptance Criteria The inspector questioned the adequacy of guidance in Procedure RSSP-6.0 for making necessary corrections to the measured leakage rate.
The licensee satisfied the inspector's concern by initiating the following changes to the procedure:
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Section 2.4 was added requiring leakage rate corrections for containment boundaries not in their expected post accident configuration, such as the CILRT instrument sensing line.
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Section 4.15 was revised to include more detail about various liquid level data required during the CILRT.
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Section 6.29 was added requiring an evaluation of liquid level changes; their effect on Containment free volume and appropriate corrections to the measured leakage rate.
4.5 Test Boundaries On a random samplino basis, the inspector reviewed the valve lineups of Draft Pr;eaare RSSP-6.1 for approximately 25*4 of the piping penetrations.
This review was to ensure that systems were
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properly vented and drained to expose the CIVs to containment
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atmosphere and test differential pressure with no artificial leakage barriers.
This Draft procedure was scheduled for PORC review on April 23, 1982.
No problems or unacceptable conditions were identi-fied from the inspector's review.
- 4.6 Instrumentation The inspector verified that the instrumentation system specified in the test procedures satisfied the instrument selection guide of ANSI /ANS 56.8-1981.
The inspector also reviewed calibration records of the six dewpoint instruments, observed calibration checks of resistance temperature detectors (RTDs) and examined the condition of several RTDs inside the containment.
No unacceptable conditions were identified with the instrumentation review.
4.7 Weld Channels The containment liner has channels attached over each seam weld.
j These channels were used during construction for acceptance testing i
of the liner welds.
The inspector identified an NRC position that
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all containment liner weld channels be vented to the containment i
atmosphere during the CILRT unless the licensee has demonstrated l
that the weld channels maintain their integrity when subjected to j
the loading conditions of a DBA.
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The licensee explained that no subject weld channels were accessible
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due to insulation covering the containment walls and lack of access l
to the dome area. Additionally, the licensee assumed that all l
channels are sealed with a threaded plug as shown on the liner plate and test channel fabrication detail drawings. The inspector conducted an inspection of the containment inside wall and verified that the existing stainless steel reflective and fiber insulation prohibits easy access to the weld channels.
The inspector informed the licensee that the validity of CILRTs with these channels not vented is in question and specific justifications would have to be reviewed further by both the licensee and NRC.
The plant superintendent acknowledged this need and committed to initiate
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an engineering evaluation to prepare such justifications. This
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matter is considered unresolved pending further licensee evaluations and NRC technical review.
(244/82-08-01)
5.
Facility Tours The inspector made several tours of the facility including the control room, auxiliary building, intermediate buildings and containment building.
During these tours the inspector observed operations and activities in progress, implementation of radiological controls, and general condition of safety related equipment.
In addition the inspector examined
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containment system boundaries, component tagging and instrumentation to
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support CILRT.
No unacceptable conditions were identified.
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Unresolved Item s
items about which more info,rmation is required to determine acceptability are considered unresolved.
Paragraph 4.7 contains an unresolved item.
7.
Exit Interview The inspector met with licensee representatives (see detail 1 for attendees) on April 23, 1982.
The inspector summarized the scope and findings of the inspection at that time.
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