IR 05000255/1988019
| ML18054A440 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/08/1988 |
| From: | Mendez R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A439 | List: |
| References | |
| 50-255-88-19, NUDOCS 8812160075 | |
| Download: ML18054A440 (19) | |
Text
{{#Wiki_filter:* U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/88019(0RS) Docket No. 50-255
- Licensee: * Consumers Po~er Company.
1945. West Parna ll Road. Jackson, MI 49201 ~acility Name: Palisades Site Inspection At: Cove~t, Michigan Inspection Conducted: ALlgust 16 through November 18, 1988 ,...., C'- . / . ,-(. /?z.,.;,..:..ec....:*7, R. Mendez O
- Inspector:
.. 4-#
Approved By:/~~hillips, Chief Operational Programs Section Inspection Summary License No. DPR-20 /7/R*/gg Date lz..4/,,, Date Inspection on August 16 through November 18, 19~8 (Report No. 50-255/88019(DRS)) Areas Inspected: Routine, announced inspection by a Region based inspector of
- licensee actions on previous inspection findings; containment integrated leak rate test (CILRT); CILRT perfbrmance witnessing; CILRT results review; and local leak rate tests (LLRT) results revie NRC modules utilized during this inspection included 61720, 70307, 70313, 70323, and 9270 Results:
Individual~ involved with the CILRT-program appeared to be knowledgeable and conscientious in-their wor * Understanding of Appendix J local leak rate testing
- requirements appeared to be wea *
Adequate staffing was noted in the CILRT progra * Management involvement in the CILRT program was eviden Although two valves were found to be improperly positioned for the CILRT, prompt corrective action was evident. 8812160075 881209 ~DR ADOCK *05006~55 W PDC
Improvements were noted in the preventive maintenance * and rep~ir cif containment isolation valve The licensee failed the 1981 and 1986 CILRTs due to excessively leaking containment isolation valve The 1988 CILRT passed~ due to the licensee corrective actions and maintenance on containment isolation valve * Three unresolved items were identified (testing steam generator manways at -10 psi - Paragraph 6.a; failure to Type C test penetration 65 - Paragraph 6.b; and failure to corr~ct Type A test results utilizing test pressure Pt - Paragraph 7).
- Although one violation for failure to properly li~eup valves was identified, based on the licensee 1s prompt corrective -
action, no Notice of Violation is being issued.
- DETAILS
- Persons Contacted Consumers Power Comeany
- K. E. Osborne, Projects Superintendent
- *T. Buczwinski, Plant Projects Supervisor
- R. D. Orosz, Engineering and Maintenance Manager
- R. V. Van Wagner, ISI Supervisor
- D. J. Malone, Nuclear Licensing Analyst
- R. Ward, Senior Nuclear Analyst
- C. S. Kozup, Technical Engineer
- B. P. Benson, Shift Supervisor
- R. E. McCaleb, Quality Assurance Directo *Denotes persons attendin~ the exit meeting on November 18~ 198 The inspector alsQ contacted other personnel including members of the technical, operating, and regulatory assurance staf.
Licensee Actions on Pfevious Inspection Findings (Closed) Open Item (255/86005-01): An inspector concern identified a problem with mass step changes in containment which resulted in a. significant thange in the leakage rate during the 1981 and 1986 CILRT~. It was the inspector's opinion that the licensee 'had declared stabilization too e~rly. The stabilization period during the 1986 CILRT was 5.75 hour The licensee increased the stabilization period for the CILRT performed in November 19~8 to approximately 13 hour The results of the CILRT were acceptable and no appreciable changes in mass or leakage rates were note (Closed) Open Item (255/86005-04): The inspector determined that the licensee was performing repairs pripr to the performance of the Type A test without determining the.normal state of repair or the as-found conditions of containmen In the response letter to the violation, the licensee agreed that their CILRT procedure was inadequate and committed in writing to add local leakage differences resulting from repairs to the final CILRT result The licensee revised their CILRT Procedure No. RT-36, Attachment 9, to require adding leakage rate improvements to the Type A test using the minimum pathway metho. Containment Integrated Leak Rate Test Procedure Review The inspector reviewed Procedure No. RT... 36, Revision 14, 11Containment Integrated Leak Rate Test, 11 relative to the
requirements of 10 CFR 50, Appendix J, ANSI N45.4-1972 and * the Technical Specification The inspector 1s comments were discussed with the licensee during the course of the inspectio The inspector comments were satisfactorily resolve b. / Clarification of Appendix J Requirements To ensure the licensee 1s understanding of Appendix J requirements, the inspector conducted discussions with licensee personnel during the course of the inspectinn which started on Au~ust 13, 198 On August 13, 1988, the inspector and the Operational Programs Section Chief were present at the licensee 1s testing laboratory in Jackson, Michiga The purpose of the August inspection was to discuss the AppeMdix J clarifications, to observe ~n ILRT of a containment model, for the NRC and the licensee tci use the data to calculate the leakage rates and then compare the result The. licensee pressurized the containment model to approximately 28 psi Upon reaching the required pressure, the licensee discovered numerous leaks.. The licensee was u~successful in their attempts to prevent their containment model from leaking and consequently, did not have leakage data to run their CILRT progra However, the inspector used the licensee 1s CILRT data-from the Palisades 1986 test and found that there.was excellent agreement between the inspector 1s and th~ licensee*~ result * The following is a summary of the clarification discussed with the licensee whith had not*b~en previously discussed iri report --50-255/8600. . . (1) Periodic Type A, B, and C tests must include as-found results as well as as-left. 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) (b) In th~ case where individual leak rates are assigned to two valves in series (both before and after the RA), the penetration through leakage would simply be the smaller of the valve 1s leak rate In.the case where.a leak rate is obtained by pressurizing between two isolation valves and the individual valve 1s leak rate is not quant1fied, the as-found and as-left *
- penetration through-leakage for each valve would be 50%
of the measured leak rate if both valves are repaired.*
'---- -------------
-------
(c) In the case where a leak rate is obtained by pressurizing between two isolat1on valves and only one valve is repaired, the as-found penetration leak rate would conservatively pe the final measured leak rate, and the as-left penetration th~ough leak rate would be zero (this assumes the repaired valve leaks zero).
(2) *Penetrations which_ are required to Qe Type C tested, as described in the FSAR and SER, must be vented inside and outside the containment during.the CILR All vented penetrations must be draihed of water inside the containment and between the penetration valves to assure exposure of the containment isolation.valves to containment air test pressur The degree of draining of. vented penetrations outsid~ of containment is contra 11 ed by the *requirement that the va 1 ves be subjected t~ the post-accident differential pressure, or* proof that the system was built to stringent quality assurance standards comparable to those required for a seismic.syste~. (3) The start of a CILRT must be noted in the test log at the time the licensee determines that the containment stabilization has been satisfactorily complete Reinitializing a test in progress must be "forward looking, 11 that is, the new start time must be the time at which the decision to re~tart is mad This also implies that the license~ has determined th~t the test has fai1ed, and has enough data to quantify the leakage rat Any deviation from these positions should be discussed, and documented, with the NRC inspector as they occur to avoid later invalidations of the test result Examples of acceptable deviations of-reinitializing the start time of the test in the past are: time at which a leaking penetration.which has an obvious effect on the test data was secured, accidental opening and later closing of a valve which has an obvious effect on the test data, and the time at which an airlock outer door was closed and the inner door was ope (4) The supplemental or verification test shoul~ start within one hour after the completion of the CILR If problems are enc*ountered in the start of the supplemental test, data recording must continue and be considered part of the CILRT until the problems are c9rrected and the supplemental test can begi (5) The water level in the steam generators during the C°ILRT must be low enough to ensure it dose not enter th~ main steam lines unless flooding of the main steam lines is called for in the loss of coolant emergency procedur * (6) Test conne~tions must be administratively controlled to ensure their leak tightness or otherwise be subject to Type C testin One way to ensure their leak ~ightness is to cap, with a good seal, the test connection after its us Proper administrative controls should ensure Valve closure and cap reinstallation within the local leak rate testing procedure, and with a* checklist prior to unit restart.* (7) Whenever a valve is replaced, repaired, or repacked during an outage for which Type A, 8, and/or C surveillance.testing was scheduled, local leak rate testing for the as-found as well as the as-left condition must be performed on that penetration~ In the case of a replaced valve, the as-found test can be waived if no other containment isolation valve of simil~r design exists at the Sit (8) The periodic retest schedule for each subject to Type 8 or Type C testing, except for air ot s and penetration employing a continuous leakage monitoring system, shall be every refueling outage, but in no case shall the interval be greater than two year (9) If local leakage measure~ents are taken to effect repairs in order to meet the acceptance criteria for Type A tests, these measurements shall be taken at a test pressure P. tontainment Integrated Leak Rate Test Witnessing The. inspector reviewed the calibration data arid determined all the in~truments used in the CILRT had been properly calibrated and that the correct weighting factors had been placed in the computer program as require The following instrumentation was used throughout the test:
~ Quantity RTDs
Humidity
Pressure gauges
Flowmeter
Witness of Test The inspector witnessed portions of the CILRT on November 2-4, 1988, and noted that (except where noted below) test prerequisites were met and that the appropriate revision to the surveillance procedure was fo 11 owed by test personne Va 1 ve lineup for the following systems were inspected for correct position to insure that no fluid could enter the containment atmosphere and that *proper venting and draining was provided:
- System Primary System Drain Pump ReGirculatio Clean Waste Receiver Tank Pump Recirculation.
Clean Waste Receiver Tank Pump Suction Quench Tank Vapor Phase Sample Line * Primary System Drain Tank Pump.Suction Clean Waste Receiver Tank Circulation Pump Suction Purge Air Exhaust Yurge Air Exhaust Purge Air Exhaust Sef'.Vi ce.Air Containment Hydrogen Monitoring* Return Nitrogen to Quench Tank Air Supply to Air Room Comp6hent Cooling Water Out Containment Isolation and Safety Injectio Component Cooling Water Supply to Containment Containment Air Sample Penetration
67
40
49 la lb le lo* 40a
68
48
28 On November 2~ 1988, the licehsee*completed the valve lineups and was pressurizing contairimen The inspector reviewed the.valve lineups in the field to determine whether the valves were in the - correct position and tb ensure that proper venting and draining was provide During the review of the valve positions, the inspector * found that the service* air vent Valve MV-CA6.55 was cracked ope Valve MV-C655 forms part of the containment boundary and is r'equired to be open to the containment atmosphere prior to and during the test as specified in 10 CFR 50, Appendix J, Section III.A.l.(d).
In addition, the CILRT Procedure No. RT-36, Section 3.4.8.C and Attachment 3C, required Valve MV-CA655 to be in the open positio The inspector reviewed the valve lineup check sheet and found that the Performed By and Verified By sections of the checksheet had both been signed in violation of admini~trative procedure The licensee informed the inspector that the auxiliary operators who performed some of the valve lineups for the CILRT had originally cracked open Valve MV-CA655 to allow air to be vented, but the op~rators failed to return and fully open the valv In addition, the licensee informed the inspector that the same operators.were involved with mispositionfng the CILRT pres~urization isolaticin Valve MO-P The licensee had attempted to pressurize containment, but was unsuccessful since Valve MO-Pl was in the closed positio The positioning of Valve MO-Pl required that the indication was verified and that the key switch was physically in plac The valve was subsequently found in the closed position, although the valve lineup sheet for Valve MO-Pl was signed and dated as being in the open positio The licehsee initiated a reinspection of the.valves that were positioned by the two auxiliary operators and found no other problems with the valve lineu The failure by the licensee
to properly implement a surveillance test procedure is considered a violation of Technical Specification Section 6.8.1.C; however, since prompt ~orrective action was completed prior to the end, of the inspection ~nd this could be considered an isolated ca~e, no Notice of.Violation is being issued per Section V.A: of Appendix C to 10 CFR Part. . Test Results Evaluation CILRT Data Evaluation On November 3, 1988, the licensee was granted an exemption from the CILRT requirements of Appendix J which states th9t the only acceptable method for containment leakage rate calculations are the Point-to-Point a~d Total Time method The *exemption for Palisades permits the use of the Mass Point Method as an acceptable r alternative for cialculating containment leakage rate The results of the Mass Point.Method will be used throughout the data evaluatio A 24 hour Mass Point CILRT*was performed on *November 3-4, 1988, at approximately 42. 7 psi Following satisfactory completion of th required temperature stabilization period, data was collected ever minute The inspector independently monitored and evaluated the leak rate data using the Mass Point formulas to verify the licensee 1s calculations of the leak rate and instrument performanc There was excellent agreement between the inspector's and licensee's results as indicated by the summary (units are in weight percent per day): Measurement Licensee Inspector. Leakage rate measured during CILRT (Lam) 0.017 0.017 Lam at upper 95% confidence level 0.018 0.018 Appendix J acceptance criteria at 95% UCL:* < 0.75 Lt=< 0.054 weight percent per da Supplemental Test Data Evaluation After completion of the CILRT, a known leakage rate (based on the inspector 1s readings and calculations) of 2.50 SCFM, equivalent to 0.076 weight percent per day at accident pressure, was induce Data was collected and analyzed by the licensee every 15 minute The inspector independently monitored and evaluated leak rate data to verify the licensee's result At about three hours into the supplemental test, the inspector noted that the licensee was not
meeting the calculated leakage acceptance criteria with the induced flow of 2.50 SCF The licensee's results; however, indicated that the licensee was meeting the.acceptance criteria for"the suppJemental tes The tnspector determined tha_t the 1 i censee was using the average of two mass flow* meter Mass flow meter No. 1 was reading 2. 5 SCFM and mass fl ow. meter No. --2 *was reading 2.1 SCFM and the licensee was using the average* (2.3 SCFM or 0.069 wt% per day) of the two meters in their calculations.. The inspector reviewed the calibration data of the two mass flow meters and determined that the mass flow meter reading 2.5 SCFM was within closer calibratiun. . tolerances than the flow meter reading 2.1 SCF Additionally, the inspector informed the 1 i censee that the fl ow meters were *reading far enough apartto indicate that the supplemental results were questionable. *The inspector suggested that the licensee determine which one of the flow meters was ~eading more accuratel Th licensee connected their primary calibration source (a gas meter, Identification No. 3740-00055) and took severQl reading The readings were all determined to be approximately 2.03* SCF Th inspector and the licensee agreed.that flow meter No. 2 (Identification No. ME-1566) was more accurately measuring the induced fl~w and would bi used for the remainder of the t~st. The inspector asked that the licensee perform a* post calibration of flo meter No. 2 after completion of the supplemental tes The inspector reviewed the post calibration data and found the results acceptabl After 4 1/2 hours, the supplemental test was terminated with excellent results as indicated by the following summary (units are in weight percent per day):
Measurement
- Licensee InsEector Measur~d leakage rate Le, during supplemental test a.on 0. 07 Induced leakage rate, Lo 0.064 0.064 Le - (Lo + Lam)
-0.008-0.008 Appendix J acceptance criteria -0.018 < [Le - (Lo + Lam)] ~ 0.01 CILRT Valve Lineup Penalties Due to penetration configurations which deviated from the penetration requirements for the CILRT, the results of local l~ak rate tests for each penetration must be added to Lam at the 95 percent UC A review of the valve lineup penalties indicated that the total leakage rate was 0.001 wt% per da * Local Leak Rate Results Review The inspector reviewed local leak rate test results for acceptability and conformance with regulatory requirement The following problems or observations:were identifie *
i
- The inspector reviewed local leak rate test records and noted b.
that the test for the steam generator.secondary manway covers was performed at approximately -10 ps The results of the test were corrected to P The inspector asked the licensee why the test was performed at less than atmospheric pressur The licensee * indicated that the steam generator manway covers were not designed to withstand the accident pressure of 55 psig. Additionally, the licensee.stated that testing the steam generators manways a * vacuum was consistent with the Appeodix J requirement to perfor~ local leak rate tests in the direction of accident pressur CFR 50 ~ Appendix J, Sect ion II I. B. 2 requires that penetration shall be tested at a pressure not less than P The licensee's Technical Specifications require that penetrations be tested at 55 psi Additionally, Appendix J allows local leak rate testing in the opposite direction of accident pressure if the results are equiva1ent or more conservative. This item is unresolved pending review whether the local_ leak rate test performed at -10 psi is consistent with Appendix J requirements and pending review by NRR (255/88019-'01).
The inspector reviewed the results of local leak rate test~ and noted that the licensee has not performed a Type C test for the instrument air line containment isolation valves CV-1211 and CK-CA400, Penetration 6 This penetration consists of a remote manual valve in series with a check valv The litensee stated that the instrument air line is required to be riperable in the event of an accident and consequently, are not required to be Type C teste CFR 50, Appendix J, Sect ion II I. C requires the Type C testing of containment isolation valves and states that only containment isolation valves that are sealed with fluid from a seal system may be exclude Section III.C.3{b) further requires that the seal water system be sufficient to assure a water seal for at least. 30 days at a pressure of 10.10 P This item is unresolved to determine if the penetration is required to be Type C tested and pending review by NRR (255/88019-02). As-Found Condition of CILRT Results The as-found condition is the condition of the containment at the beginning of the outage prior to any repairs or adjustments (RAs) to the containment boundar If RAs are made to the containment boundary prior to the Type A test, local leak rate tests must be performed to determine* the leakage rates before and after the RA The as-found Type A test
result can then be obtained by adding the difference between the affected path leakages before and after RAS to the overall Type A. test result The following problem was identified: * * The 1 i censee *performs a reduced pressure Type A test and is required to * meet the acceptance.. criteria in Section III.A.5 bf 10 CFR 50, Ap~endix J~ * During review of the local leak rate test results, the inspector noted that when repairs or maintenance were performed on penetrations, the licensee performed the LLRTs at a test pressure of P CFR 50, Appendix J, Paragr_aph III.A.5.(b)(l) requi_res that if local leakage measurements are taken to ~ffect repairs in order to meet the acceptance criteria to the Type A test, these measurements shall be taken at ~ test pressure P The inspector determined that the licensee performed maintenance or repair on contafnment boundaries prior to the 1981, 1986, and 1988 CILRTs, but
did not perform the local leak rate tests at P The licensee stated that they were not aware of the requirements of Paragraph III. A. 5. (b)(l), but that the perfo_rmance of the. 1oca1 1 eak rate tests at Pa was more conservativ The inspector agreed that in general, performance of the local le~k rate tests at Pa was more conservative; however, this is not always the case since some valves seal better at a higher pressur The licensee committed_ to determine by testing that all of their containment isolation valves did demonstrate more conservative leakage at the pressure they were currently using (Pa), and requested that NRC. review
- these results and make an exception to the Pt test requirement in their case based on the results of their tests. This item is.unresolved to determine if the leakage corrections are always conservative and pending
- determination of whether an exemption to Paragraph III. A. 5. (b)(l) wi 11 be issued (255/88019-03).
The inspector reviewed as~found and as-left local leak rate test result Although, the licensee did not perform local leak rate
- test's at Pt, the following is a summary of the as-found containment leak rate (units are in wt % per day).
Measurement Penalties incurred due to repairs or adjustments to CILRT (not corrected to Pt) Valve lineup penalties As-left Type A test result Total as-found Leak Rate 0.015 0.001 0.018 0~034 The Appendix J acceptance criteria at the 95% UCL is 0.054 wt% per da The licensee passed the CILRT in the as~found conditio During
the previous two CILRTs, the licensee failed to meet the acceptance criteria of Appendix By letter dated August 22, 1986, the licensee requested an exemption from the requirements of 10 CFR 50, Appendix J, Section III..A.6. (b) if the results of the next Type A test met the acceptance criteria of less than 0.75 Lt or 0.054 wt% per day. . Section III.A.6. (b) required that a Type A test shall be performed during each plant shutdown until two consecutive tests meet the acceptance criteri The licensee was granted an exemption from the scheduler requirements of Section III.A.b.. (b) on September 17, 198 As the licensee performed a successful Type A test in the as-found condition on November 3-4, 1988, the licensee is exempted from the requirements of Section III.A.6.(b).
The licensee 1s next required test shall be in accordance with Appendix J, Section III.D, which specifies a frequency for test performance of three Type A tests,' at approximately equal intervals during each 10 year service perio. Unresolved Items Unreso 1 ved items are matters about which more information i_s required in order to ascertain whether they are acceptable items, violations, or deviation Unresolved items disciosed during the inspection are discussed in Paragraphs 6.a, 6.b, and ' Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on November 18, 198 The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection repor The-licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur NRCFORM766 16-831
- E...,cor.35 U.S. NUCLEAR REGULA TORY COMMISSION PRINCIPAL INSPECTOR(Name. tasl.,,;SI. andm*ddle initial)
REVIEWER . INSPECTOR'S REPORT.. /J1Euo.c2 ~ Office of Inspection and Enforcement /)rf/.LLt',,t?~j..#?.. ~.-' LICENSEENENDOR PERIOD OF INVESTIGATION/INSPECTION
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