IR 05000249/1982008

IE Insp Rept 50-249/82-08 on 820420-0521.Noncompliance Noted:Failure to Perform Calculations Per 10CFR App J During Initial Phase of Containment Integrated Leak Test & Failure to Have Record for Latest Flowmeter Calibr

ML20062E696
Person / Time
Site:	Dresden
Issue date:	06/28/1982
From:	Jackiw I, Maura F, Robinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20062E691	List: IR 05000249/1982008 ML20062E689 ML20062E694
References
50-249-82-08, 50-249-82-8, NUDOCS 8208100265
Download: ML20062E696 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-249/82-08 Docket No. 50-249 License No. DPR-25 Licensee: Commonwealth Edison Compan P. O. Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Unit 3-Inspection At: Morris, Illinois Inspection Conduc ed: pril 20, 22-25 and May 10 and 21, 1982 Inspectors: 1.' Ja (4/22, 23, 25) -N If-r 0, 22-25, 5/21) [ U ~8 L

.w f.. Ro inson (4/24 and 5/10) N "IE Approved by: J Chief 8'

Tes) Program Section Inspection Summary Inspection on April 20, 22-25, and May 10 and 21,1982 (Report No. 50-249/82-08)

Areas Inspected: Routine, announced inspection of the containment inte-grated leakage rata _ tests. The inspection involved 70 inspector-hours onsite by three NRC inspectors including 33 inspector-hours during offshift Results: Three apparent items of noncompliance were identified (failure to perform calculations in accordance with 10 CFR 50 Appendix J during the initial phase of the test - Paragraph 2.c; failure to have records for latest calibration of flowmeter - Paragraph 2.b; and failure to follow valve check- *

list procedure - Paragraph 2.d).

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8208100265 820729 PDR ADOCK 05000249 G PDR __

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DETAILS 1. Persons Contacted

• • D. Scott, Station Superintendent R. Regan, Assistant Station Superintendent

• • D. Farrer, Assistant Station Superintendent M. Wright, Operating Engineer, Unit 3

• • J. Brunner, Technical Staff Supervisor

• • R. Ryback, Systems Group Leader, Technical Staff

• • S. Rhee, Technical Staff Engineer

• • E. Wilner, QA Supervisor

• F. Anousch, Engineer, CECO HQ The inspectors also interviewed other licensee employees including members of the technical and operating staf * Denotes those attending the exit interviews of April 23, 198 ** Denotes those attending the exit interviews of April 23 and May 21, 198 . Dresden Unit 3 Containment Integrated Leak Rate Test Procedure Review The inspectors reviewed procedure DTS 1600-7, Revision 4, " Unit 2/3 Integrated Primary Containment Leak Rate Test" against 10 CFR 50, Appendix J, ANSI N45.4-1972, and ANSI N18.7-1976 and it was deter-mined that the procedure required the conduct of a 24 'aour test using the mass plot analysis method of ANSI /ANS 56.8-1981 although it was the licensee's intent to perform a short duration tes The inspectors informed the licensee that in order to perform a test of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration, they would have to comply with Bechtel Topical Report BN-TOP-1 which in turn requires that the data analysis be based on " total time" calculations instead

of mass calculation Another problem noted was the magnitude of the planned induced l 1eakage flow rate. The procedure called for a leak of the same

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magnitude as the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> calculated leak rat Appendix J thru ( ANSI N45.4-1972 requires that the induced leak rate be approxi-mately equivalent to Lt. The new ANSI /ANS 56.8 calls for the induced leak rate to be between 0.75 and 1.25 La. Following discussions between NRR, the licensee, and the inspector, it was agreed to require an induced leak rate of at least 0.66 La for this test since the licensee was limited by_the size of the flow-meter available. Hewever, the licensee has been informed that he must obtain a higher range flowmeter for future CILRT's. This is considered an open item (249/82-08-01) pending the inspectors' review of the next ILRT at the Dresden sit _.-_. .,

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b. Instrumentation The inspectors reviewed the calibration data associated with performing the CILRT. All the instruments to be used in the test had been calibrated as required. There were 30 RTD's, 10 dewcells, 2 pressure gauges and 1 flowmeter. On April 24, 1982, during the performance of the test, the inspectors noted that the voltage vs. flow relationship for the flowmeter calibration which he had previously reviewed (calibration data supplied by the licensee) was different than the numbers being used by the licensee. For example, the available calibration records indi-cated that 9sefm = 4.69V, and 10 scfm = 4.90V. The "new" calibration figures were 9scfm = 4.63 V and 10 scfm = 4.74 Upon questioning, the licensee stated that a more recent'

calibration had been performed, but that he had not received the calibration documentation from Volumetrics and that was why the inspectors were not given the data. However, the licensee had copied the results of the latest calibration for his use. Failure to have calibration records for the flowmeter used during the verification phase of the CILRT is considered to be a violation of 10 CFR 50, Appendix B, Criterion XII and XVII and is an item of noncompliance (249/82-08-02).

c. Witness of Test The inspectors witnessed portions of the CILRT on April 24-25, 1982 and verified that the licensee had met the stabilization criteria prior to commencement of the CILRT. At approximatel five hours into the test, the inspector questioned the licensee regarding the calculations being done by the process computer in that the results, at the 95% confidence level, appeared to be based on the mass equations instead of the required " total time" method of BN-TOP-1, Revision In addition, the results of two data sets from the printout column titled, " Measured Leak Rate, %/ day, Total" did not agrae with independent calculations donc using the equations of BN-TOP-1. During the procedure review on April 20, 1982, the licensee had been made aware of the require-ment to calculate the leakage rate based on the total time method of BN-TOP-1, Rev. 1. The licensee initially insisted the total time method was being utilized, but once it was verified that the computers had not been programmed to do a total time calcu-lation per BN-TOP-1, plans to start the verification phase were terminated and the licensee decided to proceed with hand calcu-lations. At approximately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> into the test, the licensee decided to complete a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ILRT. The decision freed the licensee from the requirements of BN-TOP- The licensee's attempt to perform a short term duration test while ignoring the require-ments established for short test data reduction are considered to be a violation of 10 CFR 50 Appendix J, and is an item of noncompliance (249/82-08-03).

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d. Valve Lineups During containment pressurization, the inspectors verified that the valve lineups were conducted and documented in accordance with the approved test procedure except as noted below:

(1) Core Spray valve, MO-3-1402-25A, was sed during the test to main-tain reactor water level within prescribed limits on April 23-24, 1982. The procedure specified that this valve be closed during the CILRT. No change was made to the procedure to permit the operation of this valve during the tes (2) Isolation valves, S0-3-2301-29 and S0-3-2301-30, were found closed contrary to procedure requirements. Th< valves htd apparently closed on a containment high pressure signa After the inspectors identified the error, a change to the procedure was made to allow the valves to remain close Technical Specification 6.2.A states that detailed written procedures addressing surveillance and testing requirements shall be prepared, approved, and adhered t Contrary to the above, core spray valve, M0-3-1402-25A and isolation valves, S0-3-2351-29 and S0-3-2301-30, were found in positions other than those specified by the procedure. This is considered an item of noncompliance (249/82-08-04).

e. CILRT Valve Lineup Penalties Valve configurations noted below deviated from the normal CILRT valve lineup requirement. As a result, the local leak rate test results are added as a penalty to have at the 95% UC Penetration Leakage (Scf/hr.)

X113, RWCU 2.73 X138, SBLC 0.96 X11A/X11B Shutdown Cooling 1.30 X311A/X3aaB LPCI Torus Spray 0.75 X310A/X310B LPCI Test Lines 5.16 X116B LPCI Injection Line 2.79 Total Type C Leakage Penalty 13.69 Expressed in % La, 0.0167 La where La = 821.86 scf/hr. = 1.6 weight %/ day

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f. CILRT Data Evaluations-The 24 hr. CILRT was performed on April 24-25,L1982. The inspectors independently monitored leak rate data to ensure the licensee's calculations were in accordance with the approved method for the chosen test duration. Following completion of the test, independent calculations were performed by the-inspectors and acceptable agreement between the inspectors' and licensee's results was.obtained as noted below. ..(Units are in weight %/ day.)

Measurement, Licensee Inspector Leakage rate measured, 0.539 0.534 Lam Lam at upper 95% confidence 0.547 0.557 level Lam at upper 95% confidence 0.574 0.584 level adjusted to reflect penalties (see Paragraph 2.e.)

Appendix J acceptance criterion.at the upper 95% confidence level = 0.75 La = 0.75 (1.6 weight-%/ day) = 1.2 weight %/ da ~

g. Supplemental Test Evaluation After the satisfactory completion of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ILRT on April 25, 1982, a known leakage rate of 9.5 scfm = 1.110 weight- %/ day wa induced. The inspectors monitored and evaluated the leak rate data generated by the licensee. .Following completion of the supplemental phase of the CILRT independent calculations were performed by the inspectors and acceptable agreement with the licensee results were obtained as noted belo (Units are in weight %/ day.)

Measurement Licensee Inspector !

Measured leakage (Lc) 1.61110.024 1.66010.047 rate during supplemental phase Induced leakage rate, Lo 1.110 1.110- i 0.016i0.052

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Lc-(Lam +Lo) -0.038i0.025 Appendix J Acceptance Criteria: .400 5 [Lc - (Lam +Lo)]s + 0.400 h. Containment "As Found" Condition i The inspectors reviewed the licensee's summary report of the containment penetrations local leak rate tests performed prior 5 ,

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to the ILRT. Based on the licensee's results of~the "as found"

'minus "as left" penetration thru leakage, the containment "as found" leakage rate was 0.848 weight %/ day. The Appendix J acceptance criteria is s 1.2 weight %/ da . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) on April 23 and May 21, 1982. The inspectors summarized the scope and findings of the inspection. The calculational method to be used during short duration testing (BN-TOP-1) and the magnitude of the super- -

inposed leak rate (<.66La) were discussed during the April 23 meeting to ensure licensee's understanding prior to the test performance. The-licensee acknowledged the statements by the inspectors with respect to the items of noncompliance (Paragraphs 2.b., 2.c., and 2.d.)

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