IR 05000269/1980006
| ML19309G977 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/18/1980 |
| From: | Brooks E, Upright C, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19309G974 | List: |
| References | |
| 50-269-80-06, 50-269-80-6, NUDOCS 8005080080 | |
| Download: ML19309G977 (9) | |
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- pn argg'o UNITED STATES g
NUCLEAR REGULATORY COMMISSION o
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REGION 11
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101 MARIETTA ST., N.W., SUITE 3100 g
ATLANTA. GEORGIA 30303
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Report No. 50-269/80-06 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Facility Name: Oconee 1 Docket No. 50-269 License No. DPR-38 Inspection at Oconee site near Seneca, SC Inspectors:
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/ Tkd H. L. Whiten r
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[ Da(e Signed A0.@ df?m 3l/8lfo B. T. Moorf Ilate Signed Approved by:
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O C. M. Upright ti ection Chief, RONS Branch
/Date/ Signed
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SUMMARY Inspection conducted on Janua.y 23-30, 1980 Areas Inspected
This routine, announced inspection involved 196 inspector-ho ars onsite in the
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area of containment integrated leak rate testing which included inspection of test procedures, instrument calibrations, data processing, valve alignment and problems encountered during the test.
Results Of the area inspected, no items of noncompliance or deviations were identified.
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DETAILS
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Persons Contacted Licensee Employees Oconee
- J. E. Smith, Plant Manager
- J. N. Pope, Operations Superintendent G. A. Ridgeway, Operations Engineer
- T. S. Barr, Performance Supervisor
- G. Davenport, Performance Engineer W. Neuman, Test Engineer, Performance
- R. T. Bond, Project License Engineer J. Bracket, Senior QA Representative M. Alexander, Assistant Engineer Mechanical
- J. Snyder, Engineer, Corporate Office Corporate Office (contact by telephone)
- K. S. Canady
- R. L. Gill
- N. A. Rutherford
- K. Wilson Other licensee employees contacted included ILRT personnel, shift foreman, Unit I shift supervisor and Unit 1 operators.
NRC Resident Inspectors
- F. Jape, Senior Resident Inspector
- W. Orders, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on January 30, 1980, with those persons indicated in Paragraph I above. The inspectors advised the licensee that although the measured integrated leak rate was well within the acceptance limit the test result was not acceptable to IE in that certain systems were not properly vented and drained. At this time the licensee would not commit to resolving the question of leakage rate through 11 penetrations identified as not properly tested before returning Unit I to power.
A four-way conference call was set up on January 31 between Duke Corporate Office, Oconee, IE Headquarters and Region II.
The licensee agreed to account for potential leakage through the 11 questionable pene-trations and correct the ILRT leakage as necessary. See paragraph 5 for further details.
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3.
Licensee Action on Previous Inspection Findings
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Not inspected.
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Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
New unresolved items identified during this inspection are discussed in paragraph 5.
5.
Primary Containment Integrated Leak Rate Test The inspector reviewed surveillance activity to determine that the primary containment integrated leak rate test (CILRT) was performed in accordance with appropriate sections of Technical Specification 4.4; the " Reactor Building Integrated Leak Rate Test Procedure", PT/0/A/150/3; Appendix J to 10 CFR 50; and ANSI N45.4.
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Selected sampling of the licensee's activities which were inspected included:
(1) review of PT/0/A/150/3 to verify that the procedure was approved and conformed to Technical Specifications; (2) observation of test performance to determine that test prerequisites were completed, special equipment
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installed and calibrated, appropriate data were recorded and analyzed; and (3) preliminary evaluation of leakage rate test results to verify that leak
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rate limits were met.
Pertinent aspects of the test are discussed in the following paragraphs:
a.
General Observations
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The inspector witnessed and/or reviewed portions of the test preparation, containment pressurization, temperature stabilization and data processing in the period of Jaauary 23-30, 1980. The following items were noted:
(1) The test was conducted in accordance with an approved procedure maintained at the test control center. Changes to the procedure were made with proper concurrence and administrative controls.
(2) A sampling of test prerequisites was reviewed and found to be completed.
(3) A sampling of plant systems required to maintain test control was reviewed and found to be completed.
(4) Special instrumentation was reviewed and found to be installed and calibrated.
(5) Venting and draining of specific systems were reviewed and found to be incomplete. See paragraph 5.c for further details.
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(6) Data required for the performance of the containment leak rate calculations were recorded at 15 minute intervals.
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(7) Problems encountered during the test were described in the test event log.
(8) Pressurized gas sources were reviewed for proper isolation and venting to preclude in-leakage or interference of out-leakage through containment isolation valves.
Certain pressure sources had not been depressurized or vented to the atmosphere.
See paragraph 5.c for further details.
(9) Final analysis of the leak rate data will be performed by the licensee and will be reported in the test report to the Office of Nuclear Reactor Regulation (NRR).
The inspector's preliminary review indicated that the calculated leakage rate was less than 0.75 L. During the exit interview and a subsequent telephone call, banuary 31, 1980, certain penetrations were identified for which type-C leakage rates will be determined and added to the calculated leak rate to determine the final ILRT results.
The licensee was advised that the calculated containment leakage 95%
Upper Confidence Limit plus the Type-C add-on leakage must be less than the 0.75 L acceptance limit.
b.
Procedures The inspectors reviewed the following procedures:
PT/0/A/150/3 Reactor Building Integrated Leak Rate Test
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(approved 10-23-78)
PT/0/A/150/08A -
Reactor Building Personnel Lock Leak Rate Test (approved 2-17-77)
PT/0/A/150/09 Reactor Building Personnel Hatch Outer Door
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"0" Ring Seal Leak Rate Test (approved 3-5-76)
The valve alignment check list in TP/0/A/150/3 was not adequate to assure proper system venting and draining. At the exit interview the licensee committed to revising TP/0/A/150/3 prior to the integrated leak rate test for Unit 2 scheduled for May 1980. This matter is identified for later inspection as Inspector Follow Up Item (269/270/
287/80-06-03).
c.
Indentified Problems (1) Venting and Draining From a review of valve alignments listed in the integrated leak rate test procedure, TP/0/A/150/3, the inspectors were unable to verify that system venting and draining had been performed in accordance with the requirements of Section III.A.I.(d) of
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Appendix J to 10 CFR 50.
This matter was discussed with test personnel who confirmed that systems had not been vented and drained for the integrated leak rate test. The inspectors met with plant management on January 25 to express their concern that the requirements of Section III. A. I. (d) of Appendix J were not being met. Plant management could not verify that these require-ment-a being met, and agreed to conduct a detailed review of penetration valve alignments. The inspectors reviewed the align-ments with licensee personnel, and found that certain penetration alignments did not meet Appendix J requirements for venting, and draining systems and depressurizing pressure sources. Of the 60 penetrations all but 14 were correctly aligned, or would be accounted for by adding Type-C leakage measurements, which had already been performed, to the ILRT results. Three of the 14 penetrations (1, 60 and 61) were also type-C tested, and would be added to the ILRT results leaving 11 penetration alignments unresolved. Local leak rate tests could not be readily performed on these 11 penetrations due to system design. The inspectors also noted that high pressure nitrogen, low pressure nitrogen, instrument air and breathing air had been blocked but had not been vented to preclude back pressure on penetration
isolation valves or potential leakage into containment. The licenser offered no adequate resolution to these issues during the inspection.
At the exit interview, January 30, 1980, the inspectors stated that the ILRT result was not acceptable to IE in that certain systems were not drained and vented and pressure sources vented or depressurized as required by Section III.A.I. (1) of Appendix J.
The inspector asked plant management and corport.tn representatives, tied into the inter-view by telephone, for a cos. itment to resolve the question of leakage through those penetrations not properly tested before returning Unit I to power.
Licensee management stated their position as follows:
(a) The measured integrated leak rate of 0.0222% per day was well below the acceptance limit of 0.0581% per day.
(b) Type C leakage measurements, where available for penetrations not properly aligned, would be added to the ILRT result.
(c) Measurement of potential leakage through penetrations which were not properly vented and drained and which are not designed for Type C testing would be resolved by May 25, 1980 (technical specification time limit for completing the ILRT).
(d) Unit I would be returned to power (heat up to comumence about February 5) prior to resolving item (c).
i The inspectors stated that items (c) and (d) were unacceptable to IE.
This issue was identified as unresolved pending further
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discussion between the licensee and Region II.
A four way con-ference call was set up on January 31, between Duke Power Corporate
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representatives, Oconee plant personnel, IE Headquarters and Region II.
The questionable penetrations were reviewed and the licensee committed to leak test each of these penetrations prior to making Unit I critical. Type-C measurements would be added to the ILRT results.
An immediate action letter was issued by Region II to confirm the licensee's commitment. This commitment resolves the issue raised on the ILRT and will be inspected at a later time as Inspector Follow Up Item (269/270/287/80-06-04).
The penetrations in question, test status and proposed corrective action are summarized below.
OCONEE ILRT-PROBLEM AREAS TYPE C LINE CORRECTIVE *
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PENETRATION SYSTEM TEST CONDITIONS TEST SIZE ACTION
Pzr. liquid Not drained; covered by Yes
\\"
I sample line water in pressurizer.
Instr. Air Pressure not vented; back No 1"
2, 3 pressured during test.
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SuPP y to Pressure (100 psi) isolated No 1"
2, 3 2RCS by 2 valves but not vented or depressurized.
39 & 53 N, Supply to Pressure (600 psi) isolated No 1"
2, 3 CM but not vented; back pressure uncertain: gage on the line
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(not calibrated) indicated possible 25 psi back pressure.
Fill line to Water full; not vented CFT to atmosphere.
Chem. Addition Water full; not vented
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to atmosphere.
60 & 61 Containment Not vented to atmosphere.
Yes
Rad. monitor
Rx Headwash Not vented to containment.
No 6"
47 RCP Vents Not vented on demineralized No
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water header side; water-
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filled; not a seismic designed
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system.
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TYPE C LIllE CORRECTIVE PENETRATION SYSTEM TEST CONDITIONS TEST SIZE-ACTION (*)
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Breathing Air Not vented to containment; No 2"
2, 3 dry line; 54 psi back pressure.
SF Canal fill Not vented to containment No 8"
and drain or atmosphere and full of water.
CFT Sample Vented to containment but No 1"
hydro test not vented outside.
to show 0 leakage.
Leak Rate Test Vented to containment but No k"
line not vented outside.
Demin. water High pressure outside.
No Not
Supply Known
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Add Type C leakage measurement to the ILRT leakage result.
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Perform a Type C test and add leakage to the ILRT leakage result.
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Determine effect of back pre.ssure and potential in-leakage for pressure sources which were not vented and correct ILRT results appropriately.
I (2) Personnel Airlock Testing The inspectors determined that the licensee does not test the air-lock door seals after each opening as required by Section III.D.2 of Appendix J to 10 CFR 50.
Correspondence relating to airlock testing is summarized below,
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i Letter Dated From/To Summary 8/4/75 NRR/DPC Generic letter requested licensees to identify those areas of Appendix J where they cannot or do not comply.
9/5/75 DPC/NRR A request for exemption to airlock
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testing as required by Section III.D.2 of Appendix J to 10 CFR 50.
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Letter Dated From/To Summary
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11/23/76 NRR/DPC Licensee's request for exemption dated 9/5/75 was denied. Guidelines for an acceptable alternate test method were provided to the licensee.
- 12/28/76 DPC/NRR Receipt of NRR guidelines for airlock testing was acknowledged. The licensee committed to submitting a proposed change to Technical Specifications which would incorporate these guidelines by 2/15/77.
2/15/77 DPC/hP,E The licensee reversed his decision of 12/28/76, and again requested an exemp-tion from Section III.D.2, stating that airlock modification would be necessary to meet this requirement.
8/15/77 NRR/DPC The licensee was asked to provide additional information to support a request for exemption to Type C testing certain isolation valves. The request for exemption to airlock testing in accordance with the staff guidelines provided 11/23/76 was denied. NRR requested the the licensee respond within 30 days and state his intent to adopt airlock testing in accordance with the staff position provided 11/23/76.
9/14/77 DPC/NRR The licensee restated his position that meeting the. staff position would require extensive modification, provided addi-j tional information on the nature of seal failure at Oconee, and continued to request exemption from airlock testing as specified in Section III.D.2 and the staff position.
The licensee's letter of Sentember 14, 1977 has not been evaluated.
In that this letter provideu some additional information relative to seal failure at Oconee and further arguments for exemption the inspector did not identify this matter as an item of noncompliance at this time. Unresolved Item (269/270/287/80-06-01): The method and frequency of conducting airlock tests at Oconee was identified l
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as unresolved pending NRR review and evaluation of the licensee's
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September 14, 1977 request for exemptions to Appendix J.
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(3) Closed Systems Which Penetrate Containment The inspectors asked for identification of closed systems inside containment which penetrate containment and are postulated to rupture (i.e., not designed for post accident functioning). The licensee stated that all closed systems inside containment were built to USAS B31.7 requirements and seismic design. The inspector stated that the licensee should identify those systems which may fail during the design basis accident and vent and drain these systems to the containment atmosphere during the ILRT or perform Type C tests and add the local leakage to the ILRT result.
Unresolved Item (269/270/287/80-06-02):
Review Duke system design, identify those systems which may rupture during the design basis accident and include these systems in determining the overall integrated leakage rate.
The licensee stated that this matter had been referred to the corporate engineers, and estimated about one month to verify these systems.
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