IR 05000282/1988016

Insp Repts 50-282/88-16 & 50-306/88-16 on 880916-1026. Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Containment Integrated Leak Rate Test (Cilrt) & Cilrt Performance Witnessing & Results Review

ML20206M291
Person / Time
Site:	Prairie Island
Issue date:	11/17/1988
From:	Mendez R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206M263	List: IR 05000282/1988016 ML20206M259 ML20206M272
References
50-282-88-16, 50-306-88-16, NUDOCS 8811300517
Download: ML20206M291 (14)

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. U.S. NUCLEAR REGULATORY COMMISSION KEG 10N !!!

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Report Nos. 50-202/38016(DPS); 50-306/08016(DRS)

Docket Nos. 50-282; 50-306 License Nos. DPR-42, DPR-60 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis, MN 53401 Facility Name: Prairie Island Nuclear Generating Plants, Units 1 and 2 Inspection At: Prairie Island Site, Red Wing, MN J

Inspection Conducted: September *5 through October 26, 1988

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Inspector:

N R. Mendez d

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Approved By: M. P. Phillips, Chief Operational Programs Section Date

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Inspection Sunnary

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Inspection on September 16 through October 26, 1988 (Report Nos. 50-282/88016(DRS);

50-306/88016(DR5))

Areas Inspected: Routine, announced inspection by a Region '>ased Hspector of licensee action on previous inspection findings; containmnt int ated leak rate test (CILRT); CILRT perfomance witnessing; CILRT *esults review; and  !

) local leak rate tests (LLRT) results review. NRC rodules utilized during this >

inspection included 61720, 70307, 70313, 70323 and W70 !

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Individuals involved with the CILRT and LLRT r,agrams appeared to be '

knowledgeable and conscientious in their wor '

Inadequate staffing was noted in the CILRT program.

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The LLRT program and associated surveillances were incomplete and i inproperly innplureated. Failure to perfom an airlock surveillance, '

failure to perform the electrical penetration surveillances and failure to test values in the direction of accident pressure are examples of improper inplementation, l

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Managerent involvement for the CILRT appeared to be inaffective or inadequat This was reflected ir the failure to implereni, a Technical Specification change that required electrical penetrations to be Type B

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. tested. Additionally, management did not include a method for calculating the 95% UCL for the Total Time method. Manegement attention is needed to

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improve the performance of the CILRT Five violations were identified (failure to properly lineup valves, failure to have adequate acceptance criteria and failure to delineate as-found calibration data - paragraphs 4.b.2, 5.a and 6.d; failure to Type B test electrical penetrations - paragraph 6.a; failure to perform an airlock surveillcnce - paragraph 6.b; failure to perform local leak rate tests at Pa - paragraph 6.c; and failure to perform adjustments to the Type A te:t at Pt - paragraph 7.c).

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OETAILS Persons Contacted Northern States Power Company (NSP)

• 0. Mandele, General Superintendent, Engineering and Radiation Protection

+* Miller, Superintendent Operations Engineer

• Eckert, Licensing Engineer

+* Gruber, System Engineer

• t Hunstad, Senior Production Engineer

+ R. Frasier, System Engineer

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Nuclear Regulatory Commission (NRC)

J. E. Hard, Seninr Resident Inspector D. C. L',Ianni, Project Manager, NRR M. Moser, Resident Inspector

• Denotes persons attending the exit meeting of September 20, 198 +0enotes persons attending the exit meeting of October 25, 198 . Licensee Action on Frevious Inspection Findings (Closed) Violation (282/85011-01):

(1) This item involved failure of the licensee to perform a temperature survey required by 10 CFR 50, Appenuix J and ANSI N45.4-197 The inspector revii.wed the Integrated Leak Rate Test procedure SP 1071(2), Section 2, and no'ad that the procedure required that a temperature survey be performed prior to the start of the CILRT. In addition, the inspector reviewed the results of the temperature survey and determined that the results were acceptabl (2) This item involved failure of the licensee to establish adequate acceptance criteria in the calculation of the leakage rate at the 95% upper confideiice level (UCL) as required by 10 CFR 50, Appendix J. As a result, the licensee terminated the CILRT performed in 1985 without meeting the 0.75 Lt acceptance at the 95% UC The inspector reviewed the licensee's Integrated Leakage Rate Test Progra procedure no. dP 1071(5) and determined that the licensee had adequately addressed calculation of the 95% UCL for both the BN-TOP-1 method and the mass point leakage method. Additionally, the procedure required that the CILRT meet the 95% UCL criteri Furthermore, during the CILRT the inspector noted that the licensee established the correct methodology to calculate the 95% UCL for both BN-TOP-1 and mass poin , ,

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(3) The licensee's procedures allowed the licensee to terminate the supplemental (verification) test with the BN-TOP-1 leakage rate ,

outside of the acceptance band. Although the licensee started the CILRT with the BN-TOP-1 data reduction method, the licensee

.used the results from the mass point data reduction method during the verification phase since mass point methodology '

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yielded the acceptable results. In the licensee's response to the violation, the licensee committed to using the same supplemental verification test technique as the Type A tes The inspector reviewed the licensee's procedure no. SP 1071(5)

and noted that in Section 8.4, the licensee stated that the calculation technique used for the Type A test shall also be ;

used for the verification test. During the CILRT performed in September 1988, the licensee used the mass point method for both the Type A test and the verification tes b. (Closed) Open Itsm (282/85011-02): The licensee did not have a data rejection criteria for drifting / erroneous sensors or data outliers during performance of the CILRT. On September 20,.1988, the licensee issued Procedure Change Form no. PC 880270 which required that the CILRT procedure be changed to reflect the data rejection -

4 criteria in ANS ~e6.8-1987, Appendix ANS-56.8-1987 is an acceptable method for rejection or deletion of data outlier c. (Closed) Violation (282/85011-03): The licensee failed to perform

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a verification test that was half as long as the Type A test. The

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supplemental test duration requirement in procedure SP 1071(8),

step 3.15 required the verification test duration to be approximately equal to half the integrated leak rate test duratio ,

However, the licensee performed a 22.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> BN-TOP-1 test but [

performed a 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> verification test and signed this step in the '

procedure as being proper. In the response to the violation, the

. licensee stated they had misinterpreted the word "approximately"

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and terminated the test when the verification test results appeared acceptabl The inspector noted that in the CILRT procedure .

SP 1071(5) the licensce eliminated the word approximately. The l l procedure now states that the verification test shall be greater I

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than or equal to half the Type A test duratio d. (Closed) Unresolved Item (282/85011-05): 10 CFR 50, Appendix J, Paragraph III.C.1 and 2 required testing of individual containment ;

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isolation valves at the calculated internal pressure, Pa. The l

inspector determined that valves MV-32103 and MV-32105 were not ,

tested in the direction of the accident pressure or tested to P '

This item is being escalated to a violation (see paragraph 6.c). -

(Closed) Violation (282/82011-06)

The inspector determined that

! +'e licensee was performing repairs prior to the performance of the l

.jpe A test without determining the normal state of repair or the l as-found condition of containment. The licensee added an additional i

' requirement to the CILRT procedure SP 1071(5), revision 8. Note 6 l in Section 8.4 of the procedure now requires that in the 90 day ;

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report to the NRC, the as-found containment leakage ratetusing the l minimum pathway leakaw per penetration is to be calculated, t

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' Containment Integrated Leak Rate Test Procedure Review

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' Procedure Review The inspector reviewed the latest revisions of Procedure 9P 1071,

"Containment Integrated Leak Rate Test," and related supplements relative to the requirements of 10 CFR 50, Appendix J, ANSI N45.4-1972 and the Technical Specification Summary of Appendix J Requirements To ensure the licensee's understanding of Appendix J requirements, the inspector conducted discussions with licensee personnel during the course of the inspection. The following is a summary of the clarifications not discussed with the licensee during the previous -

CILRT as documented in Inspection Report No. 282/8501 (1) The only methods of data reduction acceptable to the NRC were total time or point-to point as described in ANSI N45.4-1972, including a statistically calculated instrument error analysi The following or'. ions were available to the licensee and are suggested in the following order:

(a) Total time (<24 hour duration test) in accordance with Bechtel Corp. Topical Report BN-TOP-1, Revision Whenever this method is used BN-TOP-1 must be followed in its entirety except for any section which conflicts with Appendix J requirement (b) Total time (>24 hour duration test) using single sided 95% UC (c) Proposed Regulatory Guide MS 021-5, RegulMory Position 13. If this method is utilized tne licensee must submit an exemption request to NRC and receive approval for its use prior to the expiration of the Type A test frequency requirements stated in the Technical Specification (2) 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 lype 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 "minimum pathway leakage" methodolog This method requires that:

(a) In the case where individual lear 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 valves' leak rate .

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(b) In the case where a leak rate is obtained by pressurizing between two isolation valves and the individual valve's leak rate is not quantified, the as-found and as-left penetration through-leakage for each valve would be 50%

of the measured leak rate if both valves are repaire (c) In the case where a leak rate is obtained by pressurizing between two isolation valves and only one valve is repaired, the as-found penetration leak rate would conservatively be the final measured leak rate, and the as-left penetration through leak rate would be zero (this assumes the repaired valve leaks zero).

(3) Penetrations which are required to be Type C tested, as described in the FSAR and SER, must be vented inside and outsida the containment during the CILRT. All vented penetrations most be drained 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 outside of containment is controlled by the requirement that the valves be subjected to 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 (4) The start of a CILRT must be noted in the test log at the time the licensee determines that the containment stabilization has beer satisfactorily completed. Reinitializing a test in progress must be "forward looking," that is, the new start time must be the time at which the decision to restart is made.

This also implies that the licensee has determined that the test has failed, and has enough data to quantify the leakage rate. Any deviation from these positions should be discussed, and documented, with the NRC inspector as they occur to avoid later invalidations of the test results. Examples of

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acceptable deviations of reinitializing the start time of the i 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 (5) The supplemental or verification test should start within one hour after the completion of the CILRT. If problems are encountered in the start of the supplemental test, data

, recording must continue and be copsidered part of the CILRT

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until the problems are corrected and the supplemental te t can begi (6) The water level in the steam generators during the CILRT must

' be low enough to ensure it does not enter the main steam lines i

unless flooding of the main steam lines is called for in the l loss cf coolant emergency procedur ,

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(7) Test connections must be administrative 1y controlled to ensure their leak tightness or otherwise be subject to Type C testing. One way to ensure their leak tightness is to cap, with a good seal, the test connection after its us Proper administrative controls should ensure valve closure and cap reinsta11ation within the local leak rate testing procedure, and with a checklist prior to unit restar (8) Whenever a valve is replaced, repaired, or repacked during an outage for which Type A, B, 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 penetratio In the case of a replaced valve, the as-found test can be waived if no other containment isolation valve of similar ,

design exists at the sit (9) The periodic retest schedule for each penetration subject to Type B or Type C testing, except for airlocks and penetration employing a continuous leakage monitoring system, shall be every refueling outage, but in nu case shall the interval be greater than two year (10) If local leakage measurements 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 . Containment Integrated Leak Rate Test Witnessing The inspector reviewed the calibration data and determined all the instruments used in the CILRT had been properly calibrated and that

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the correct. weighting factors had been placed in the computer program

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as required. The following instrumentation was used throughout the test:

Type Quantity

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RTC 30 Humidity 10 Pressure gauges 1  ;

Flowmeter 1 i Witness of Test l

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(1) The inspector witnessed portions of the CILRT on September 16-18, 1988, and noted that the test prerequisites were met and that the appropriate revision to the surveillance procedure was followed by test personnel. Valve 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: ,

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System Penetration Pressurizer Relief Tank to Gas Analyzer 1 Pressurizer Relieve Tc.ak Nitrogen Supply 2 Reactor Water Makeup to PRT 45 Reactor Coolant Drain Tank Pump Discharge 5 Sump A Discharge 26 Reactor Coolant Drain Tank to Gas Analyzer 21 Letdown Line 11 Reactor Coolant Pump Seal Water Return 14 Pressurizer Steam Sample Line 15 Pressurizer Liquid Sample Line 16 Hot Leg Loop B Sample Line 17 Service Air Supply 19 Instrument Air Supply 20 Containment Air Sample - In 22 Containment Air Sample - Out 23 Containment Air Purge Exhaust 25A Containment Air Purge Supply 25B Containment In-Service Purge Supply 428 Nitrogen to No. 11 and 12 Accumulators 31 Hydrogen Control Vent to Shield Building 42A Hydrogen Control Vent to Shield Building 50 Hydrogen Control Instrument Air to Containment 60 Reactor Containment Pressure Instrument Piping 360 No. 12 S/G Main Feed-Steam 7B Blowdown from No. 11 Steam Generator 8A Blowdown front No.12 Steam Generator 8B Auxiliary Feedwater to No. 11 S/G 46A (2) On September 19, 1988, after completion of the CILRT, the inspector entered containment to review the valve lineup During the review, the inspector observed that valve HC-1-2, which is part of penetration 42A, Hydrogen Control Vent to Shield Building System, was in the closed position. However, the inspecto" observed that the out of service tag hanging from valve required tM valve to be in the open positio Valve HC-1-2 forms part of the containment boundary and is required to be open to the containment atmosphere prior to and during the test as specified in 10 CFR 50, Appendix J, Section III.A.1 (d).

Furthermore, the CILRT procedura SP 1071 required the valve to be in the open position; and a review of the valve lineup checklist indicated that verification of the valve position was initialed and dated. The licensee informed the inspector that valve HC-1-2 had been improperly positioned and as a result desiated from the penetration lineup. This failure by the licensee to properly follow procedures is consin red a violation of 10 CFR 50, Appendix B, Criterion V (282/88016-01A).

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5. Test Results Evaluatior; CILRT Data Evalueti a On September 18, 1988, the licensee was experiencing problems meeting the BN-TOP-1 95% UCL during thc Type A test. The BN-TOP-1 95% UCL is a double sided UCL and is used for tests less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. For tests greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> an acceptable method is the Total Time single sided UCL. When the CILRT went beyond the required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the licensee was unable to meet their leakage rate of 0.116 wt %/ day using the BN-TOP-1 metho The licensee it.Ormed the inspector that they had not made provisions in their procedure or in their computer program to include the Total Time single sided UCL. The inspector offered to provide the Total Time UCL to the licensee. However, this failure by the licensee to provide adequate quantitative acceptance criteria for determining that activities be satisfactorily accomplished during the CILRT is another example of a violation to 10 CFR 50, Appendix B, Criterion V (282/88016-018).

Due to the acceptance of the licensee's exemption request on September 27, 1988, this item does not require a response. The September 27, 1988 letter permitted the licensee to use the Mass -

Point method as an alternative for calculating containment leakage rates. The licensee submitted the exemption request before performance of the Type A test. However, the licensee's request was not formally accepted until after the Type A test was complete The results of the Mass Pnint method will be used throughout the data evaluatio A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Mass Point CILRT was performed on September 17-18, 1988, at approximately 37.9 psia. Following satisfactory completion of the required temperature stabilization period, data was collected every ,

5 minutes. The inspector independently monitored and evaluated the '

leakratedatausingfirsttheBN-TOP-1andMassPointformulasto verify the licensee s 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 Leak rate measured during CILRT (Lam) 0.044 0.044 Lam at upper 95% confidence level 0.045 0.045

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Appendix J acceptance criteria at 95% UCL: <0.75 Lt = <0.116 weight percent per day, Supplemental Test Data Evaluation After the completion of the CILRT a known leakage rate (based on inspector's independent readings and calculations) of 3.50 SCFM,

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equivalent to 0.154 weight percent per day at accident pressure, was induced. Data was collected and analyzed by the licensee every 5 minutes. The inspector independently monitored and evaluated leak rate data to verify the licensee's results. After 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the supplemental test was terminated with excellent results as indicatid by the following summary (units are in weight percent per day):

Measurement Licensee Inspector Measured leakage rate, Lc, during 0.167 0.167 supplemental test Induced leakage rate, Lo 0.154 0.154 -

(Lc-(Lctam) -0.031 -0.031 Appendix J acceptance criteria: .039 1 (Lc-(Lo+ Lam)] 1 +0.03 No violations or deviations were identified, CILRT Valve Lineup Penalties

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Due to penetration configurations which deviated from the penetration requirements for the CILRT, the results of local leak rate tests for each penetration must be added to Lam at the 95 percent UCL. A review of the valve lineup penalties indicated .

that the total leakage rate was negligible or approximately .00/w'

%/ 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 identified: On September 19, 1988, the inspector requested records for the electrical penetrations Type B tests. The licensee has a total of 51 electrical penetrations for Unit 1 and 52 electrical penetrations for Unit 2. The licensee performs an electrical penetration Nitrogen pressure test yearly in accordance with procedure SP 166 The inspector reviewed the electrical penetrations tests performed on April 7, 1988. The inspector noted hat the procedure required that the penetrations be pressurized with Nitrogen gas to keep the

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penetrations free from moisture. The procedure states that a pressure of 1015 Psi is considered acceptable during the test. The

! procedure, however, does not include a eressure decay or method to quantify the volume so that the leakage rate can be calculated as required for Type B tests. Additionally, the test pressure of 1015 Psi is far below the licensee's Technical Specification i requirement to test the electrical penetrations at Pa or 46 psig.

l Technical Specification 4.4.A.2 requires that initial and periodic

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Type B tests of penetrations shall be performed at a pressure of ,

46 psig (Pa). 10 CFR 50, Appendix J, Section III.B.2 also requires

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that containment penetrations shall be Type B tested et a pressure not less than Pa. Additionally,Section III.D.2, requires that Type B tests shall be performed during reactor shutdown for refueling or other convenient intervals but in no case at intervals greater than 2 yeart. The licensee could not readily explain the reason for not ever Type B testing the ele::trical penetrations but showed the i inspector a copy of a previous Technical Specification amendment which did not require the electrical penetrations to be Type B tested prior to 1983. The licensee, however, has been required to test the 51 electrical penetrations for Unit I and the 52 electrical penetrations for Unit 2 since 1983. This failure by the licensee to test the electrical penetrations is in violation with 10 CTR 50, Appendix J, Sections III.B.2 and III.D.2 and in violation with Technical Specification Section 4.4.A.2 (282/88016-02; 306/88016-01).

The licensee subsequently Type B tested the Unit 1 and Unit 2 electrical penetrations with acceptable results, The inspector reviewed the Unit 1 containment entry records fer 1988. As a minimum, the licensee enters containment once a month to perform a containment inspection. Entry into containment is generally made through the maintenance airlock but containment entry is also made through the personnel airlock. The inspector noted that for May 1988 no apparent entries were made into the personnel airlock. However, the June 1988 personnel airlock door seal test results documented an entry into containment on May 26, 1988. The June 1988 test sheet also documented that an airlock seal test was performed. The inspector reviewed the control room log for May 25, 26, and 27, 1988, ano determined that a surveillance test was performed on May 26, 1988 but the entry in the log did not specify whether the surveillanca test was performed on the maintenance or personnel airlock. A review of the available records indicated that the licensee also entered the maintenance airlock on May 26, 198 Due to time constraints, the licensee could not fu'ly resolve this question on October 25, 1988. A licensee representative indicated that he would contact the inspector when the question of containment entry was resolved. The following day the licensee determined that an individual entered the personnel airlock at 7:45 a.ri. . n May 26, 1988, and exited at 11:00 a.m. or, the san.e day. The licensee stated that records for the personnel airlock surveillance test were not found and concluded that the required surveillance test was not performed. Technical Specification 4.4.A.2 requires that each i airlock be tested every 3 days if it is in us Contrary to the above, the licensee failed to perform the personnel airlock door

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seal surveillance within the 3 day period. This failure to perform the surveillance required by Technical Specification 4.4.A.2 is a violation (282/88016-03). During the previous CILRT, an inspector concern identified a problem with the local leak rate testing conducted on penetrations 29A and 29 Penetrations 29A and 23B are part of the containment spray system and each penetration consists of a motor-operated valve in serie3 with a check valve. The licensee p rforms the local leak rate test us%g test connections CS-30-9 for penetration 29A and CS-30-10

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,~ for per.etration 298. The test connections, however, are downstream of the check valves and as a consequence the licensee does not test motor-operated valves MV-32105 (pe.,etration 29A) and MV-32103 (penetration 298) in the direction of accident pressure. 10 CFR 50, Appendix J, Section III.C.1 requires that for Type C tests the local pressure test shall be applied in the same direction as that when the valve would be tequired to perform its safety function. In addition,Section III.C.2 of Appendix J requires that the test pressure for Type C tests shall be Pa (46 psig for Prairie Island).

A review of the test connections and the valve configuration by the inspector indicated that the licensee did not test in the direction of accident pressure nor did the licensee test valves MV-32103 and MV-23105 at the accident pressure Pa. The licensee stated that the question of containment modifica'. ions to meet Appendix J was addressed several years ago. According to the licensee, they issued a letter to the NRC stating that no changes would be made to the containment boundary to meet Appendix J. However, the licensee could not and has not produced the document. The inspector informed the licensee that only specific exemptions from Appendix J are accepted by the NRC. The licensee has not submitted a letter to the NRC to formally exempt from Type C testing valves MV-32103 and MV-3210 This failure to meet the requirements of 10 CFR 50, Appendix J, Sections III.C.1 and III.C.2 is considered a violation (282/88016-04; 306/88016-02). The inspector reviewed calibration records for the flowmeters used for testing containmc.it isolation valves and electrical penetration The flowmeters are sent to an outside calibration laboratory and are tested to an accuracy of 12% of full scale. The calibration laboratory does not make adjustments to the flowmeters but issues new calibration curves for the flowmetei. The inspector reviewed the ca'Ibration curves and compared th. .1dicated flow with the actual flows and noted that many of the lowmeter points were not within th 12% accuracy. The inspector determined that flowmeters nos. 8112H32968/4 and 8112H32968/2 had actual and indicated intersection points that diverged and were off by 8-10%.

Additionally, the inspector determined that the licensee's calibration procurement documents have not required an as-found calibration for the flowmeters. However, Prairie Island Nuclear Generating Plant, Calibration Control procedure No. SACD 3.14, paragraph 6.6 requires that procurement documents shall specify as a minimum the as-found condition end the as-left condition for instrument calibration. Contrary to the above, the procurement documents which requisition the calibration of flowmeters do not require that an as-found conditi o be determined. The failure by the licensee to follow procedures is another example of a violation to 10 CFR 50, Appendix B, Criterion V (282/88016-01C). As-Found Condition of CILRT Results The as-found condition is the condition of the containment at th? beginning of the outage prior to any repairs or adjustments (ras) to the containment

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boundar If ras are made to the containment boundary prior to the Type /

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test, local leak rate tests must be performed to determine the leakage rates before and after the ras. 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 and observation was identified: The licenste performs reduced pressure tests in accordance with Section II; . A.5 of 10 CFR 50, Appendix 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 LLRT's at a test pressure of Pa. 10 CFR 50, Appendix J, paragraph III. A.5.(b)(1) requires that if local leakage measurements are taken to effect repairs in order to meet the acceptance criteria to the Type A test, these measurements shall be taken at a test pressure P The inspector determined that the licensee performed maintenance or repairs on penetrations 12, 22, 23, 29A, 30A and 30B prior to the March 1985 Unit 1 CILRT and performed repairs on the maintenance airlock prior to the 1988 Unit 1 CILRT but did r.ot perform local leak rate tests at P Additionally, the licensee performed repairs on penetrations 11, 14, 15, 16, 17, 29A, 29B, 42A and 50 prior to the October 1985 Unit 2 CILRT but test adjustments were not made at Pt. This failure by the licensee to meet the requirements of 10 CFR 50, Appendix J, paragraph III.A.5.b.(1) is a violation (282/88016-05). The inspector reviewed several of the six month airlock test For one of the tests, the inspector determined that the licer.see performed the maintenance airlock inner volume test in March 198 Unit 1 was subsequently shutdown for refueling in August 1988. On September 15, 1988, the licensee added a ring of packing to each of the four maintenance airloc< sh&ft seals and subsequently performed the local leak rate tes Thc inspector determined that no local leak rate test had been performed prior to the addition of the packing and adjustments made to the maintenance airlo-k since the March 1988 test. 10 CFR 50, Appendix J requires that no adjustments or repairs can be made to the containment boundary prior to the Type A tests unless local leak rate tests are performed before repairs are mad This item is unresolved to determine how far in advance of the repairs a local leak rate test is acceptable prior to the addition of the packing (282/88016-06).

The inspector reviewed as-found and as-left local leak rate test results to datermine an as-found Type A test result. Although, the licensee did not perforn. local leak rate tests at Pt, the following is an uncorrected summary in the conservative direction of the as-found containment leak rate (units are in wt %/ day):

Measurement Leak Rate Penalties incurred due to repairs or 0.035 adjustments to CILRT (not corrected to Pt)

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['~ Measurement Leak Rate Valve lineup penalties 0. L'il As-left Type A tett result 0.045 Total as-found 0.081 The Appendix J acceptance criteria at the 95% UCL is 0.116 wt %/ da The licensee passed the CILRT in the as-found conditio . Unresolved Items Unresolved items are matters about which more information is required in order ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during the inspection is discussed in paragraph . Exit Interview The inspector met with licensee and contractor :epresentatives denoted in paragraph I during and at the conclusion of the inspection on October 26, 1988. 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 >