IR 05000250/1990013
| ML17348A344 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/13/1990 |
| From: | Belisle G, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348A343 | List: |
| References | |
| TASK-2.E.4.1, TASK-TM 50-250-90-13, 50-251-90-13, NUDOCS 9006280270 | |
| Download: ML17348A344 (16) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Hos.:
50-250/90-13 and 50-251/90-13 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-250 and 50-251 License Nos.:
DPR-31 and DPR-41 Facility Name:
Turkey Point 3 and
Inspection Conducted:
April.30 - May 4, May 14-18, 1990 Inspector:
.
. J '>>
H. L. Whitener v
Approved by:
C-v t ~~i IC>>.
G. A. Be is e, tIief Test Programs Section Engineering Branch Division of Reactor Safety (~W v
ate Signed
~ICi>
Date igned SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of containment leak rate testing, containment integrity and licensee action on previous inspection findings.
Results:
In the areas inspected, violations or deviations were not identified.
One unresolved item was identified concerning capability to install and operate a hydrogen recombiner (paragraph 3).
The licensee stated that they would send to the NRC a corrective action plan concerning non-conservative testing of containment isolation valves and failure to test potential leakage paths through manual valves between containment and the isolation valves (paragraph 4.a).
The licensee was responsive to the NRC concerns regarding the leak rate testing and will prepare a corI ective action program on this matter.
A strength was identified in the leak rate prooram concerning trending of valve leakage dat REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. Bladow, guality Manager A. Cifuentes, System Engineer
- J. Cross, Plant Manager V. Edwards, Senior System Performance Engineer D. Feingold, System Engineer
- K. Harris, Senior Vice'President, Nuclear Operations M. Herfurth, System Engineer
- P. Higgins, Project Engineer, JPN
- J. Knorr, Acting Supervisor, Regulatory Compliance, Licensing C. Melchor, System Engineer
- K. Remington, Supervisor, System Performance Group, Technical Department
- G. Salamon, Acting Superintendent, Licensing
- D. Sisk, Regulatory Compliance Engineer, Licensing Other Organizations P. Dillion, Consultant, Ebasco Services
2.
NRC Resident Inspectors
- T. McElhinney, Resident Inspector
- G. Schnebli, Resident Inspector
- Attended exit interview Containment Leak Rate Testing and Integrity (61720 and 61715)
Inspection in this area was performed to verify the
'development and implementation of programs, controls, procedures, and test activities which ensure that containment integrity is established, monitored and maintained consistent with the requirements of the Technical Specifi-cations (TS)
and Code of Federal Regulations.
a.
Local Leak Rate Testing (61720)
An important part of monitoring-and maintaining containment integrity is performing periodic local leak rate testing (LLRT) to verify the leak tightness of containment leakage barriers.
The purpose of the inspection activities in this area was to ascertain that the LLRT program was being conducted in compliance with NRC requirements.
The inspector reviewed LLRT procedures.
and evaluated test result (1)
Procedure Review The controlling procedure for Type B and Type C local leak rate tests is OP 13404. 1, Local Leak Rate Tests.
The general procedure was reviewed for technical content.
The inspector verified that the following attributes were included.in the procedure to ensure adequate leak rate testing of containment isolation boundaries:
(a)
LLRTs were performed at the calculated peak accident pressure, Pa.
(b)
The LLRT procedures utilized approved methods for testing containment penetration boundaries and containment isolation valves (CIVs);
(c)
Penetration leakage rates were determined using the maximum pathway leakage.
(d)
The criteria and response for LLRT and combined leakage rate failure were 'incorporated in the test program procedures.
(e)
Repairs or modifications to containment isolation boundaries and CIVs were preceded and followed by LLRTs.
(f)
The correct test frequency was specified.
(g)
As found leak rates are determined and recorded in Appendix B of the procedure.
(h)
The summation of local leak rates are performed and recorded in Appendix C of the procedure.
In addition to the overall review, Type C local leak rate testing of the containment leakage barriers for ten penetrations were reviewed.
These tests included the following:
Penetration Descri tion
Instrument Air Bleed Line
19A 19B
Post Accident Containment Vent System Containment Spray "A" Containment Spray
"B" Containment Sump
Penetration cont Descri tion Seal Return
33
(2)
Records Review Breathing Air Containment Air Sample Service Air Personnel Hatch (OSP-051.3)
Implementation of the LLRT program to establish and maintain containment leak tight barriers was reviewed including records of performance, identification of problems, corrective actions, retests, and test'cceptance.
A detailed review of Type B and Type C
leak rate testing was performed for the previous refueling outage on Unit 4 (1988-1989)
and on Unit 3 (February-flay, 1990).
Test status and data sheets for the current Unit 3 refueling outage were also reviewed.
Records reviewed included test results for the following:
Airlock full pressure tests Airlock seal tests Purge valve tests Electrical penetrations Isolation valves Total local leak rate calculation (running summation of Type B and Type C leak rates)
In the review, the inspector determined that:
Data sheets were complete and test results were within the specified acceptance limits.
Data was tabulated for verification that the total local leakage did not exceed the 0.6 La limit.
Identified problems were corrected and retesting performed.
Tests were performed at the frequency required by NRC regulations.
For the Unit 4 1988-1989 refueling outage, the penetration maximum pathway as left leakage was 34'A of the allowable 0.6 La leak rate:
for the Unit 3 current outage, the maximum pathway penetration as left leakage was 374 of the allowable 0.6 La.leak rate.
These numbers represent a conservative approach to maintaining the containment integrity within TS requirement (3)
Test Control The inspector reviewed certain administrative control procedures designed to implement the TS requirements.
These procedures included:
(a)
OSP-200. 1, Schedule of Plant Checks and Surveillances (b)
OSP-200.2, Plant Startup Surveillances (c)
GOP-503, Cold Shutdown to Hot Standby OSP-200.
1 identifies the schedule for all plant periodic surveillance tests and contains log sheets for tracking any tests not performed on schedule.
Surveillance tests which fall into the 254 grace period are reviewed daily and brought to management attention at the plan of the day meeting.
OSP-200.2 specifies those surveillance tests required to be verified complete prior to each mode change from cold shutdown to hot standby.
GOP-503 identifies the steps required to take the plant from cold
.shutdown to hot standby including verification that OSP-200.
1 and 200.2 are complete.
The inspector verified that TS requirements for leak rate testing, containment boundary conditions and operability of containment systems designed to mitigate
%he consequences of an accident were identified in these procedures.
From the above review,.the inspector concluded that the licensee developed and implemented the programs, controls, procedures, and surveillance tests necessary to ensure that containment leakage barriers are established and maintained consistent with the TS and code of Federal Regulations.
b.
Containment Integrity (61715)
The purpose of inspection activities in this area was to verify that the licensee developed and implemented procedures and controls to meet the TS requirements that are intended to ensure the operability of those containment related systems designed to prevent or mitigate the rel,ease of radioactivity from the containment post accident.
For this purpose, portions of the following containment related systems designed to mitigate the consequence of a Loss of Coolant Accident (LOCA) were inspected for compliance with the plant TS:
Containment isolation valve alignment checks, Containment personnel and emergency airlocks,
Containment combustible gas monitoring system, Containment depressurization system - containment spray, Containment depressurization system - containment cooling, and, Containment ventilation system.
For selected TS requirements on these systems, the inspector reviewed administrative controls, surveillance test procedures and test performance records on Unit 3 from the current refueling outage and the previous operating cycle to verify the following:
Surveillance test procedures were established which address the TS requirements.
The surveillance tests were performed at the frequency required by the TS.
The test procedures contained instructions, acceptance criteria, and limits appropriate to the TS requirements.
Corrective action and retest were performed when problems were identified; The sample of administrative and surveillance records reviewed by the inspector for Unit 3 included the following:
GOP-503 OSP-200.
OSP-200.2 OSP-203 OSP-51. 2 Cold Shutdown to Hot Standby Schedule of Plant Checks and Surveillances Plant Startup Surveillances Engineered Safeguards Integrated Test (Contain-ment Spray System Test, Train A 203. 1 and Train B
203.2)
Containment Personnel and Emergency Airlock Seal Vacuum Test OSP-51. 3 Containment Personnel and Emergency Airlock Pressure Test OSP-51.7 OSP-53.4 OSP-56.1 PACV System Filter Performance Test Containment Boundary Valve Position Verification Emergency Containment Filter Fans Operating Test
OSP-56.2 Emergency Containment Filter System Performance Test OSP-56.3 Charcoal Sample OSP-68.2 OSP-68.3 Containment Spray Pump Inservice Test Containment Spray System Monthly Flowpath Verification OSP-68.4 SMI-94.1 OSP-94.2 OP-13404.
OP-588 Containment Spray System Nozzle Function Test PAHM Monthly Analog Test Hydrogen Monitoring System Flowpath Verification Local Leak Rate Tests Temporary Operating Procedure
.(Draining Instrument Air Bleed to Plant Stack)
Based on this sample review, the inspector concluded that the licensee establ.ished and implemented periodic test procedures to ensure that the operability requirements specified in the TS for containment systems designed to mitigate the consequences of an accident are maintained.
Within areas inspected, no violations or deviations were identified.
3.
Additional Area Reviewed (61701)
NUREG 0737, Item II.E.4. 1, requires licensees to provide for the installation of an external hydrogen recombiner if a permanent recombiner is not installed as a
means of post accident hydrogen control.
The Regulation,
CFR 50.44 was amended December 2,
1981.
Paragraph c.(3)(ii)
requires the capability to install an external recombiner.
However, Paragraph (g)
appears to exempt some plants from this requirement based on the date of Notice of Hearing for the construction permit and an
,acceptable Post Accident Ventilation System.
The licensee complied with the Regulation by installing piping and electrical service for the installation of an external hydrogen recombiner based on their conclusion that the amended regulation required this capability.
In an audit gAO-PTN-90-16, March 1 - April 6, 1990, gA identified as a concern that no detailed plans or instructions exist to obtain, install, test, or operate a hydrogen recombiner.
In response to the audit an off normal, procedure was being developed, ONOP-094.3, and engineering personnel are reevaluating the need for a hydrogen recombiner at Turkey Poin e From documentation available, the inspector could not precisely discern the extent of the licensee's commitment.
The inspector indicated to the licensee that capability to install a recombiner also means the ability to operate the recombiner.
'tems such as sufficient power, mechanical fit, and flow rate need to be verified.
At the exit interview, the licensee agreed to expeditiously define their commitment with NRR and take further action as necessary.
This matter is identified as Unresolved Item (UNR) 250, 251/90-13-01:
Review licensee's
'ommitment and actions with regard to the installation and opera'tion of a hydrogen recombiner.
4.
Licensee Action on Previous Inspection Findings (92701)
(Closed)
URI (50-250, 251/89-11-01):
Review The Licensee's Evaluation For Reverse Testing Of Containment Isolation Valves.
CFR 50, Appendix J,Section III.C.1 states in part that type C
tests shall be performed by local pressurization.
The pressure shall be applied in the same direction as that when the'alve would be required to perform its safety function, unless it can be determined that the results from tests for a pressure applied in a different direction will provide equivalent or more conservative results.
During a previous inspection in February 1989 and documented in NRC Report Nos. 50-250/89-11 and 50-251/89-11, the inspector determ'ined that the licensee was testing certain valves by pressurizing the valve in a di rection reverse to the direction of pressurization when the valve would be required to perform its safety function.
The inspector pursued this matter with the licensee and determined that in some cases these were gate valves and reverse testing may not be conservative.
While the licensee believed that these tests had been evaluated at the initial plant startup, no documentation could be located.
The licensee subsequently agreed to reevaluate
'and document the equivalent conservatism of these tests for NRC review.
A second problem which the i'nspector discussed with the licensee in the 1989 inspection involved the use of manual valves located outside containment between the containment wall and the first containment isolation valve.
Normally a penetration is qualified, safety class, seismic category I piping up to and including the second isolation valve.
When a
normally open manual valve is installed between containment and the isolation valve, a potential leakage path to the atmosphere through the valve packing and bonnet seals is introduced in that penetration.
Depending on the type of manual valve and orientation of the valve in the line, this potential leak path may not be tested by LLR During this inspection, the inspector reviewed the licensee's evaluation of the above problems contained in FPL letters JPN-PTP-89-1575 and JPN-PTP-89-1769.
As a result of this NRC review of the licensee's documented evaluation, Unresolved Items 50-250/89-11-01 and 50-251/89-11-01 are closed.
With regard to reverse testing the licensee identified ll penetrations in each unit where the first isolation valve is tested in a reverse direction.
Penetrations with diaphragm or butterfly valves were considered acceptable leaving only penetrations 11, 16 (Unit 3), 47, 53 (Unit 3),
54A, and 548 involving gate valves.
For the gate valves the licensee evaluation concluded that the valves involved are high quality valves which have exhibited minimal maintenance requirements and plant design does not permit testing in the accident direction.
In discussions with FPL engineers, the inspector concurred with their position that a
high quality leakage barrier may increase the reliability of the barrier; however, a potential for leakage through back seats, bonnet seals and packing is always present.
The requirement is to verify that these barriers are leak tight within the limits of
CFR 50, Appendix J.
The current local leak test method leaves this potential leakage undetermined.
At the exit interview the inspector stated that for those penetrations involving reverse testing of gate valves, the valves must be tested in an accident direction or an exemption from Appendix J requirements obtained.
Licensee management stated that a
study of their options would be initiated immediately and a
corrective action plan submitted in writing to the NRC within 60 days.
Regarding the condition of manual valves between the containment and outside isolation valve, the evaluation was not adequate.
It appears that the extent of the NRC concern was not fully realized by the licensee.
In discussions with the inspector on June 1,
1990, corporate engineering indicated that due to the similarity of the problem with that of reverse testing, this issue would also be included in the 60 day corrective action plan submitted to the NRC.
The inspector found that containment integ'rated leak rate (Type A) tests were performed on Unit 4 in March 1989 and on Unit 3 in May 1989.
Since both the manual valves and reverse tested isolation valves are correctly tested in a Type A test, the leak tightness of these valves was demonstrated at that time.
Appendix J allows up to two years or March 1991 for the next required test.
Consequently, the incor rect local test methods discussed above have no impact on near term plant operation.
An extended outage is planned for both units at the end of 199 b.
(Closed)
IFI (250, 251/89-11-02):
Verify That Adequate Draining Instructions Are Included In The Local Leak Rate Test Procedure.
The inspector reviewed local leak rate test procedure, OP 13404. 1, and found that the licensee has identified the valves to be used for draining and provided instructions to drain the appropriate piping before pressurizing the penetration.
5.
Exit Interview The inspection scope and results were summarized on May 18, 1990, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below.
.Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Item Number 250, 251/90-13-01 Descri tion Unresolved item concerning the capability to obtain, install and operate an external hydrogen recombiner.
The licensee stated they will provide a corrective action plan for reverse testing gate valves for penetrations 11, 16 (Unit 3), 47, 53 (Unit 3),
54A, and 548.
This corrective action plan is to also include an evaluation for manual valves between the containment and the first isolation valve.