IR 05000261/1982022

IE Insp Rept 50-261/82-22 on 820525-28.No Noncompliance Noted.Major Areas Inspected:Integrated Leak Rate Testing, Local Leak Rate Testing & Hydraulic Shock Suppressor Insp & Testing

ML20054M999
Person / Time
Site:	Robinson
Issue date:	06/18/1982
From:	Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054M997	List: IR 05000261/1982022 ML20054M996
References
50-261-82-22, NUDOCS 8207150251
Download: ML20054M999 (6)

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t UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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%, .M....f Report No. 50-261/82-22 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: H. B. Robinson Docket No. 50-261 License No. DPR-23 Inspection at H. B. Robinson site near Hartsville, South Carolina

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Inspector:_H. L. Whitener gg /-/f-f/2 Date Signed Approved by: Af h 4>c i _ , [L F. Jape, ~Section Chieff f Date Signed Engineering Inspection Brarfch Division of Engineering and Technical Programs SUMMARY Inspection on May 25-28, 1982 Areas Inspected This routine, safety inspection involved 42 inspector-hours on site in the areas of integrated leak rate testing, local leak rate testing and hydraulic shock sup--

p essor inspection and testin Results Of the three areas inspected, no violations or deviations were identifie PDR ADOCK 05000261 G PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• S. Zimmerman, Director, Planning and Scheduling

• J. Curley, Manager, Technical Support

• W. Farmer, Engineer R. Daton, Engineer

• F. Gilman, Regulatory Compliance M. Watford, Engineering Technician Other Organizations Gilbert Associates R. Shirk, Lead Engineer, Leak Rate Testing NRC Resident Inspector S. Weise

• Attended exit interview Exit Interview The inspection scope and findings were summarized on May 28, 1982, with those persons indicated in paragraph 1 above. The licensee agreed with the inspection findings and will implement the commitments discussed in this repor . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item 261/82-09-01 concerned the apparent failure to meet the acceptance criteria of Appendix J to 10 CFR 50 during the integrated leak rate supplemental tes The inspector reviewed the instrument recali-bration and corrected data and concluded that the supplemental test results are acceptable. See paragraph 5 for detail . Unresolved Items Unresolved items were not identified during this inspectio . Review of Integrated Leak Rate Test Results During the integrated leak rate (ILRT) supplemental test on March 6-7, 1982, the test result for the supplemental test composite leak rate did not meet the acceptance criteria specified in Appendix J to 10 CFR 50. The criteria can be stated as:

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L + L - 0.25L s L s L + L + 0.25L where L o tm t c o tm t o is the imposed leak rate, L y is the measured 24-hour leak rate at one half accident pressure. 0.25Lt is 25% of the allowable leak rate at one half accident pressure and Lc is the measured composite leak rate with the imposed leakage include The supplemental test was terminated on March 7 with unacceptable results after nine hours of testing. At this time the licensee suspected a problem with the flowmeter calibration since it differed significantly from previous calibrations of the same instrumen Consequently, after the ILRT the licensee hand carried the flowmeter to the vendor for recalibration of the instrument under test conditions recreated in the lab. It was determined that the setting of 3 scfm used during the supplemental test was actually 4.09 .01% scfm which yields an error range of 4.05 to 4.13 scf Calculating the limit using the lower value of 4.05 scfm is conservative f since the measured Lc was near the upper limi For test conditions, the calculation is as follows:

L imposed leakage 0.123 wt. %

o, L measured 24-hour leak rate 0.02 wt ?e tm, L measured composite leak rate 0.157 wt ?J c,

0.25L 0.014 wt ?e t

Substitution of these values in the acceptance criteria yield acceptable results as follows:

0.123 + 0.02 - 0.014 s .157 s 0.123 + 0.02 + 0.014 /or/

0.129% s 0.157% s 0.157%.

At the exit interview, the inspector informed the licensee that this matter was considered resolve . Review of Local Leak Rate Test Program The region specialist in conjunction with the resident inspector, reviewed the licensee's type B and C local leak rate test (LLRT) program for conformance with the requirements of the technical specifications and ,

Appendix J to 10 CFR 50. The plant design incorporates an isolation valve I seal water (IV5W) system and a penetration pressurization (PPS) syste These special design features were considered in the inspector's finding The procedures reviewed during this inspection included the following:

CPL-PT-16.3, Revision 1; Pressure Test of Containment Isolation Valve, CPL-PT-16.4, Revision 3; Containment Airlock Leakage Rate Test

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CPL-PT-51, Revision 0; Local Leak Rate Test of Post Accident Sampling Valves 1- Conclusions from the review of the procedures and program were discussed with licensee personnel and identified at the exit interview for management as follows: ,

l Procedures I (1) Include specific steps in PT 16.3 and PT 16.4 to ensure the isolation and venting of the pressurization source during a l pressure decay leak rate measuremen '

(2) Incorporate in present procedures or develop a new procedure to ensure that all type B and type C leak rate data are collected, summed and compared to the acceptance limits set forth in Appendix (3) In Section 2 of PT 16.3, certain system valves are listed as excluded from type C testing. It appeared that some of these valves, such as nitrogen supply valves, meet the requirements for type C testing specified in paragraph II.H of Appendix J. The inspector stated that :f a valve meets the requirements of paragraph II.H, the valve must be included in the type C test program. If there are valid reasons for excluding a valve which meets the specifications of paragraph II.H f rom the type C test program, the licensee must submit a request for exemption which describes the valve function and the basis for the reques In regard to items 1 and 2 above, the licensee agreed to address these matters in a revision to PT 16.3 and PT 16.4. These revisions will be complete prior to reusing PT 16.3 and PT 1 This matter is identified for followup inspection as Inspector Followup Item 261/82-22-0 In regard to item 3 above, the inspector stated that the evaluation and revision of the type C test program including any requests for exemption should be completed within six months and the programs imolemented at the following refueling outage. The basis for this time frame is that valves such as the nitrogen supply and instrument air valves were tested during the integrated leak rate test this refueling outag The licensee agreed to this schedul This matter is identified for followup inspection as Inspector Followup Item 261/82-22-0 Containment Personnel Air Lock The inspectors found that, to perform the airlock leak rate test, the air lock is pressurized by removing a bolted flange f rom an air lock penetration and installing a flange with a test connection. When the

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4 I air lock test is completed, the test fixture is removed and the original flange is installed on the penetration. The 7-1/2" flange contains a single 0-ring seal. Testing in this manner results in a potential leak path which is never tested. The inspectors stated that a method of leak testing the entire air lock boundary must be developed and a leak test performed prior to entering a mode requiring contain-ment integrity. At the exit interview, licensee management stated that an appropriate leak test will be performed during the current outag This matter is identified for inspector followup as inspector Followup Item 261/82-22-0 c. Manometer Line The manometer line opens directly to the containment atmosphere and has only one isolation valve which is outside containment. General Design Criteria 56, Appendix A to 10 CFR 50 requires double isolation for this type of penetration and paragraph II.H of Appendix J to 10 CFR 50 requires these isolation valves be type C teste The licensee installed a thread d pipe cap on the open end of the pipe inside containment to provide a second barrier. The inspectors found that the type C test performed on this system did not test the leak tightness of the pipe ca Since a threaded connection is considered a potential leak path, the inspectors stated that a method of leak testing all barriers of this line must be developed and a leak test performed prior to entering a mode requiring containment integrit At the exit interview the licensee stated that an appropriate leak test would be performed during the outage. This matter is identified for followup inspection as Inspector Followup Item 261/82-22-0 d. Penetration Pressurization System (PPS)

The PPS provides continuous monitoring of air leakage at greater than accident pressure for a number of containment penetrations. Appendix J permits the use of a continuous monitoring system that maintains a pressure not less than accident pressure as the method of determining the type B and/or type C leak rate for those components serviced by the system. The leakage measured by the PPS is in lieu of individual local tests and must be included in the summation of type B and type C leak rates to compare against the acceptance limit of Appendix J of 0.6L The inspectors reviewed the reportability of leakage detected by the PPS against the system operating requirement The PPS detects component leakage immediatel If the leakage exceeds 0.3La immediate repair is require Based on these requirements the inspectors concluded that leakage detected by the PPS is not reportable unless an actual breach of containment integrity is identifie The licensee has translated the 0.3La requirement to a flow of 1.39 scf Neither the licensee nor the inspectors could determine the basis of 1.39 scfm at the time. The licensee agreed to verify the flow rate currently used for the PPS limit.

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7. Hydraulic Shock Suppressors The inspector reviewed the snubber program for conformance to Technical Specification 4.1 This specification was recently "evi sed by license Amendment No. 63 to reflect current NRC requirements for inspection and testing cf snubber Procedures reviewed during this inspection included revised procedures for snubber inspection and testing as follows: CPL-PT-31.1, Visual Inspection of Hydraulic Shock Suppressors, Revision 0, 4/6/82 CPL-PT-31.2, Functional Testing of Hydraa' . Shock Suppressors, Revision 0, 4/6/82 These procedures concern only hydraulic shock suppressors since no mechanical snubbers are installed on safety related systems. The inspector found that the procedures adequately address the revised Technical Specification, contain the essential elements for proper inspection and testing and require the recording of essential dat The inspector also reviewed the visur.1 inspection data and independently inspected a sample of the snubbers. No problems were identified.

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