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IE Insp Rept 50-289/81-18 on 810630-0709.No Noncompliance Noted.Major Areas Inspected:Reactor Bldg Integrated Leak Rate Testing
	ML20011A026
Person / Time
Site:	Crane
Issue date:	09/09/1981
From:	Caphton D, Chung J, Young F; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20011A011	List: IR 05000289/1981018; ML20011A010;
References
	50-289-81-18, NUDOCS 8110060371
	Download: ML20011A026 (14)
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i U.S. NUCLEAR REGULAT0r(Y -COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-289/81-18 Docket No. 50-289 License No. DPR-50 Priority

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Category C

i Licensee: Metropolitan Edison Company P.O. Box 542 Reading, Pennsylvania 19642 Facility Name:

T_hree Mile Island Nuclear Station, Unit 1

Inspection at: Middletown, Pennsylvania Insper. tion conducted: June 30 - July 4, July 7-9, 1981 Inspectors:

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6 Young ~, Reside n 'ector date signed

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' ate signed W. Chung, Reac nspector d

Approved by: J

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D. L. Caphton, Chief, Test Program date signed Section, DETI i

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Inspection Summary:

Inspection on June 30 - July 4, July 7-9,1981 (Report No. 50-289/81-18)

Areas Inspected: Routine, unannounced inspection of Reactor Building Integrated Leak Rate Testing. The inspection involved 61 inspector-hours on site by one resident and one region-based inspector.

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Results: Noncompliance: None

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Region 1 Form 12 i

(Rev. April 77)

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i 8110060371 810917 PDR ADOCK 05000289

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DETAILS 1.

Persons Contacted i

Principal Licensee Employees

R. O. Barley, Lead Mechanical Engineer i

M. J. Roso,. Manager, Plant Operations

C. W. Smyth, Supervisor, Licensing

C. Stephenson, Licensing R. L. Summers, Mechanical Engineer - ILRT Test Director

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R. J. Toole, Director, Operations and Maintenance

H. L. Wilson,- Lead I&C Foreman USNRC

A. N. Fasano, Section Chief, TMI Operations Office

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The inspectors also interviewed other licensee employees during the

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inspection, including Operations Staffs, Technical Support and performance personnel.

denotes those present at the exit interview.

2.

Pre-Test Review

a.

The inspectors reviewed the reactor building integrated leak rate

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testing procedure and procedure changes for conformance with Technical Specifications, Station Administrative Control-Procedures, l-and Appendix J of 10 CFR 50 to verify that:

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Procedures and changes were reviewed and approved.

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Procedures were technically adequate and included sufficient i

details, such as; air pressurization r3thod for each penetration on valve; venting of inters'lly isolated volumes; i

initial pressure plateau; prerequisites, limits, precautions, and acceptance criteria.

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Design Modifications were incorporated into the test procedure.

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Test instruments were calibrated and in service.

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The following documents and records were reviewed:

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TMI-1 Surveillance Procedure 1303-b.1, Reactor Building Integrated Leak Rate Test, Revision 9, June.20, 198.

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3-f.

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Temporary Change Notice (TCN) to 1303-b.1; (1) No. 1-81-64, June 27, 1981 (2) No. 1-81-65, June 27,.1981-(3) No.1-81-0558, June 8,1981

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Design Modification Packages:

(1) Task No. RM-12, H2 Recombiner Installation,. Revision 0.

(2) Task No. NM-40, DCR/CS3-069-0, Fire Standpipe Penetration and Valves, Revision 0.

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I GAI Drawings E-311-850, E-311-851, E-311-85i, and E-311-853'

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TMI-1 1430-Y-23, Instrument Calibration Data Sheet, Revision 3, October 13, 1978. The following calibration records were reviewed:

(1) TE-654A, performed June 8, 1931 i

l (2) Foxboro Temperature Recorder - 12 points, LR-TR-654,

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performed May 13, 1981

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(3) Heise Gauges, 0-100 psi; #11838R performed June 24, 1981;

11840 performed June 26, 1981 (4) Fluke, Model 8600A, performed March 3,1981

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-(5) Flowmeters, LR-FI-110 and LR-FI-111, performed June 10, 1981 Taylor Thermometer, Serial No. 64F1844 calibration performed i

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Jur.e 26, 1980.

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Certificate of Calibration and Testing, Model No.104AAN -

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40133, dated March 12, 1971.

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Texas Instrument-Pressure Transducers, P7775 and P7776.

Calibration performed June 24, 1981 by National Bureau of I

Standards.

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c.

Findings The inspector determined that the R.B. ILRT procedure 1303-b.1 was technically adeqeate to perform the test satisfactorily, and the procedure -specifitJ suf ficient details'. including; s

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Test duration (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) and Stabilization period (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ),

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Supplemental RB ILRT Instrument verification test, Initial conditions and prerequisites, and

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Calculational Methods.

(1)

Item 6.5.a of the procedure 1303-b.1, Revision 9, specified

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that the mass point data at 50.6 psig would be recorded every half hour. The inspector raised a concern on possible data fluctuation which would be expected due to the diurnal sinusoidal effects of weather conditions as well as other perturbation caused by instrument noises and uncertainties.

The licensee subsequently agreed to record data every 15 minutes to enable the monitoring of mass point variation trends in detail.

(2) Enclosure III, page 39.0 of the test procedure 1303-b.1 required that valve FS-V405 would be opened during the-ILRT.

The inspector identified by review of Fire Systems drawing SP1303-11.18E19 that the drain valve located at the Fire System

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penetration outside of the reactor building would 'oe closed.

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This finding was prcmptly incorporated and the inspector had no further questions in this area.

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(3) Enclosure III, page 41.0 of the test procedure specified that valves HR-V2A and HR-V2B would be closed for the testing.

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The inspector verified by review of drawings (Leak Rate and H2

Recombiner Systems), Design Modification Package, and subsequent discussion with the cognizant licensee engineers

that the valves, HR-V2A and HR-V28, were not installed but rather valves HR-V5 and 6 had been installed. Also,. spectacle flange LR-V3 had been placed in the line.

The inspector further determined that the above differences of the valve lineups in the test procedure were incorporated in the TCN No. 1-81-64 and placement of the spectacle flange were recognized by the test engineers. The inspector had no-further questions in this area.

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(4) The inspector determined that the test instrument had been calibrated and the accuracies were within the tolerances specified in the test procedure 1303.b.1 and ANSI /ANS 56.8-1981.

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(5) Heise gauges used during the' test, July 2-5, 1981, had been calibrated on June 24, 1981. However, the calibration data was reviewed on July 9,1981 by a QA inspector after completion of the test. The inspector raised a concern as to why the data had not been reviewed by the cognizant QA engineer prior to the test.

This item was not resolved and was incorporated,-as an ex. ample, into an Unresolved Item detailed in paragraph 3.b.2.

3.

Administrative Controls a.

The inspector interviewed selected licensee personnel and reviewed qualifications and training records for conformance with -Technical Specifications; Station Administrative Control procedures; ANSI

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N18.7 " Administrative Controls for Nuclear Power Plants"; ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel *'; and Regulatory Guide 1.33 " Quality Assurance Program Requirements". The inspector also observed conduct of testing and reviewed data / log sheets te verify that:

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R.B. ILRT was conducted in accordance with the test procedure.

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Review and documentation were in accordance with the station procedures.

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QA surveillanceswere performed.

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Personnel participating in the test were qualified and had been

given proper training.

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Findings t

(1) Prior to the Reactor Building Integrated Leak Rate Testing a formal two-hour classroom training was conducted on the subject ILRT for those who would participate in-the testing. Attendees included operations supervisors, auxiliary operators,'and

engineers.

The objectives of the training were to familiarize the attendees with the scope and requirements for the ILRT and thus to assure quality testing.

The inspector identified by an

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audit of the selected individual training records that one data taker had not attended the training class.

Discussions with the licensee representative revealed that a total of 49 persons

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had received the formal ILRT training and that four of the eighteen data takers, mostly auxiliary operators, '.ad not attended the ILRT training program. A cognizant incensee

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representative stated that those who had not received the training were' subsequently informed ~of the importance of this j

training. The inspector also identified that the data takers were qualified auxiliary operators and were directly supervised by the ILRT director or his assistants during the testing.

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Based upon these findings, this item was considered resolved and the inspector did not identify any other unacceptable conditions in this area.

(2) The following three examples of inadequacies in Quality Assurance were noted:

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During the closecut inspection of the reactor building the inspecto. noted that calibration stickers were either missing on RTD's or dated 1974, where as the RTD's'had been calibrated on June 8,1981, A cognizant licensee representative stated that the calibration stickers were attached on the Rosemont Bridges or, the data taking panel located inside the Intermediate Building.

During the subsequent re-entry into the reactor building for the 12 psig inspection tour, the calibration stickers were placed on the RTD's.

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Throughout the reactor building tours for the closeout and 12 psig visual inspections, there was no objective evidence that QA surveillance o inspections had been conducted.

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As discussed in the item 2.c.(5), the calibration data of the test gauges had been reviewed by QA inspector after completion of the testing, rather than prior to the testing.

Based on the above findings, implementation of Quality Assurance during this test appeared to be inadequate. A cognizant licensee QA representative stated that the QA implementation program would be reviewed.

This is an unresolved item pending further inspection and review of the implementation of the operational QA program (289/81-18-01).

4.

Pre-Test Inspections a.

The inspectors reviewed the inspection checkoff /signoff sheets and conducted direct observation inspections of the reactor building during the closecut and 12 psig tours to verify that:

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Test prerequisites were met,

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Proper plant systems were in service and valves were lined up in accordance with the test procedures, and Temperature elements and Dewcells were positioned as per

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drawings and test procedure.

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(1) Visual Inspection of Access Areas A visual' inspection had been conducted on June 30, 1981 by the licensee Operations Department for wall cracks and possible degradations of penetrations, floor gratings, and access hatches.

The licensee's inspection sign-off sheet,-attachment #2 to procedure 1301-8-1, was reviewed by the inspector and no adverse co..ditions were identified. The areas-inspected were:

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Auxiliary = Building

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Fuel Handling Building

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Heater Bay of Turbine Building i

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Intermediate Building

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Reactor Building and Emergency Access Hatch area (2) Closecut Inspection Prior to containment pressurization the licensee's final

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closecut inspection was conducted from 1730-2030 hours, July 1,

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1981. The NRC inspectors concurrently conducted an independent inspection tour to verify that locations of the test sensors, system / component-lineups, and other conditions were in conformance with the-requirements specified in the test

procedure. The NRC inspectors observed the following:

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Four of 24 RTD's were inoperable and "A" RTD had been replaced with "X".

The inoperable RTD's were B, Q, F, and X (moved to "A" post). -All 20 operable RTD's and 10 Dewcells were as per GAI drawings E-311-850, -851, -852, and -853.

The inspectors concurred with the licensee

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that the four inoperable.RTD's did not alter the r

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test nor calculations since there was sufficient redundancy to determine the air temperatures in the containment.

All fire extinguisher bottles were vented.

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One air cylinder near a purge valve AHV-B and oil cans were promptly removed.

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On a selective sampling basis, the inspectors verified the system / valve lineups in accordance with

the test procedure.

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Calibration stickers were either not attached or outdated on RTD's. This finding was incorporated into 3.b.(2) as an example of the unresolved item.

(3)

12 psig Inspection Immediately following the closeout inspection the reactor building pressurization was commenced at a rate of 1.9 psig/hr, and the building was pressurized to 12 psig at 0340 hours0.00394 days 0.0944 hours 5.621693e-4 weeks 1.2937e-4 months , July

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2, 1981. The inspector conducted a visual inspection inside the reactor building for any abnormal venting, leaks, or water-spills. The tour included inside and outside of "D" ring and Letdown Cooler Room.

The licensee attached the RTD calibration stickers during this

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entry, and the following valves were independently verified by j

the inspector:

IAV-59, DH-V48A, CA-V191, NI-V34, RC-V-1032, RC-V2J, NI-V29, MV-V33D, MS-V60, MV-32, MU-VIA, CA-V4A Water had been drained from the "B" Building Spray Line Drain Orifice, which had been blocked by Boron residue. The water had been drained to the sump. No adverse conditions were identified. and the inspector had no further questions.

5.

Reactor Buildirg ILRT Chronology The following is a summary of the test sequences listed chronologically, where "*" denotes the activities in which the inspectors directly witnessed or participated:

Date Time Events 7/1 1600 Planning. Meeting 1700

Closeout Inspection

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2030 Commence pressurization

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to 12 psig at a rate of 1.9 psig/hr.

7/2 0340 Attained 12 psig

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0730 Inspection 1010 Commence pressurization to 50.6 psig

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.7/3 0614 Attained 50.7 (+0.1)'psig (-0.0)

0830

4 hr stabilization period begins.

1030 Stabilization period ends.

For the last 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of stabilization period, AT = 0.125 F/2 hrs << 1* F/hr AP = 0.029 psig/2 hr AW = 132 lbs. (calculated)

1130 Repressurize from 50.238 psig to 50.792 psig (Pa + 0.2 pri)

1140 initial data readings for 15 minutes.

1220 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Leak Rate mass point measurements started 1440 Reactor Building Circulating Fan AH-EIC. tripped. A and B fans in operations.. Calculated mass points show diurnal oscillation effeu s.

7/4 0300 Air circulating fan for the data collection panel in the intermediate building-mispositioned. Rosemont Bridge temperatures increased by approximately 0.2 F.

Calculated mass points show significant d'urnal effects with a peak amplitude of more than 200 lbs. (calculated).

0430 The fan was repositioned to the original positio.

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0600 The mass point oscillation stabilized. Restarted 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ILR testing.

Heavy clouds.

1000

Initial calculations of the leak rate show approximately 0.08 %/ day, in excess of acceptance limit 0.075%/ day.

Rains, heavy at a time.

1800 Rain stopped and clearing 7/5 0615 Ended 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months testing.

Commenced 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months verification test, superimposing 200 ft'/hr leakage.

Rains.

Preliminary calculations show ILR of 0.025%/ day with a 95% confidence interval of 0.003%/ day.

1415 Makeup to Primary for pressurizer level.

1830 Ended verification test.

200 ft /hr superimposed leak rate (L ): 0.067%/ day g

24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months test (L,,): 0.025%/ day Measured total superimposed leak rate (L ): 0.077%/ day g

95% confidence interval:

0.10%/ day where, L, = 0.1%/ day 6.

Integrated Leak Rate Testing (ILRT)

a.

The inspector conducted an independent calculation of selected data points and observed the performance of the testing to verify that:

Leakage barrier differential pressure was at least Pa

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(Peak reactor building pressure during the Design Basis Accident:

50.6 psig)

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Testing was conducted in accordance with the procedure

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1303-b.1.

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Test data was recorded only after test conditions were stabilized.

Supplemental verification test was performed.

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Testing was satisfactory and met the requirements specified in Technical Specifications and Appendix J of 10

CFR 50.

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Test results were -ithin the acceptance criteria.

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Evaluation and calculations were in conformance with the requirements specified in ANSI N45.4-1972.

b.

Stabilization - 4 Hours (1) The averages of the RTD readings and pressure sensors were 87.3 F and 65.395 psia respectively at the beginning of stabilization period, and quickly stabilized to 86.2 F and 65.272 psia in two hours.

The last 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months variations during i

the 4 - hour stabilization period were; AT :

0.125 F/last 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AP :

0.029 psi /last 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AW :

132 lbs. (calculated)

The acceptance criterion for the stabilization and the initiation of 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ILRT required less than 1 F/hr temperature variation during the last two hours.

(2)

Initial ILRT The data readings were commenced at 1230, July 3,1981, at 15 minute intervals, the mass points were calculated employing an

ideal gas law and containment air volume of two million cubic

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feet.

Since the weather forecast outside the Reactor Building called for either heavy overcast or rains during the entire testing period, any diurnal effects on the mass points due to the weather conditions were expected to be minimal.

The data points during the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months did not show any meaningful diurnal effects. At 1445 p.m., July 3,1981, one of three R.B.

circulating fans (AH-E1C) tripped, causing approximately 0.2 F temperature dip. This appeared to be due to the stagnant air

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mass or less air mixing. The initial oscillation due to the

failed fan was quickly stabilized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months indicating i

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that an equilibrium air mixing was achieved. At approximately 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months (0315 hour0.00365 days 0.0875 hours 5.208333e-4 weeks 1.198575e-4 months , July 4,1981) after the test was initiated, a significant sinusoidal diurnal oscillation was observed with a peak amplitude greater than 200 lbs.

It took 90 minutes to identify the source of this fluctuation. The cause was determined to be a fan which had been blowing air

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toward the RTD bridges on the data indicator panel, had been moved and instead, the fan was blowing the air avtay from the panel and toward the ceiling. This adverse condition was corrected by 0600 hour0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months , July 4,1981.

An initial calculation of the Leak Rate was approximately 0.08%/ day, greater than acceptance limit of 0.075%/ day.

The major factors contributing to a high Leak Rate were identified as the oscillating mass points caused by the failure of the containment circulating fan and the mispositioned data panel fan. The inspector noted that the points on the diurnal curve were mostly outside of 95% confidence band on the Least-Square-Fitted straight line. At this point the licensee decided to restart the 24-hour testing, considering a favorable weather condition (i.e. rains).

(3) ILRT The inspector independently calculated three mass points and compared with the preliminary calculations obtained from the GAI computer terminal.

The differences between the inspector's and GAI calculations were 0.051%, 0.076%, and 0.095%. The following is the summary of the preliminary results:

Test Period:

0600, 7/4 - 0615, 7/5 Test Points:

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Leak Rate:

0.025%/ day 95% Confidence Interval:

0.003%/ day Acceptance:

0.075%/ day The following additional information was monitored throughout the entire test period:

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Weather conditions

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Atmospheric Temperature

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Barometric Pcessure

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Hourly Readings of R.B. Sump levels, Access Hatch, R.B.

Purge, Steam Generators, Pressurizer levels, and R.B.

Emergency Cooling Coils.

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Data Collection Panel (Rosemont Bridge) Temperatures The R.B.ILRT appeared to be successful and the inspector had no further questions.

(4)

Instrument Verification Test The licensee superimposed a known leak rate of 200 ft*/hr on the unknown leakages-for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and the 200 ft'/hr controlled leak was monitored through FI-110. The average superimposed.

leak ' temperature was 78 F (+0.5 F, -0 F) and the instrument back pressure was 5.45 psi (+0.05 psi, -0 psi).

Test Period: 0515, 7/5 - 1830, 7/5 Test Points:

Total Leak Rate (L ):

0.077%/ day g

95?; Confidence Interval: 0.010*;/ day (5)

ILRT Acceptance Criteria 24 Hour Test:

L,< 0.75 L, Superimposed:

lL

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<.25 L, am c o where:

L, = Maximum allowable Leak Rate = 0.1%/ day L,, = Measured Leak Rate = 0.025?s/ day L

Superimposed Leak Rate = 200 f t*/hr

g 0.067?;/ day L

Total Measured Superimposed Leak Rate

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= 0.077%/ day g

am Therefore:

24 Hou; ILRT:

0.025'4/ day < 0.75?s/ day Superimposed Verification Test:

l L,, - ( L - L )-l = l 0.025 - (0.077 - 0.067)l c

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= 0.015%/ day 0.015?s/ day < 0.025*;/ day

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(6) Post-Test Review The inspector noted that a temperature variation of 0.2*F on the parameter indicator panel (Intermediate Building) caused a significant diurnal effect on the mass points.

Considering the known diurnal effects by the weather conditions, the inspector reccmmended that not only the weather conditions would be monitored accurately but also the air in the data room be controlled.

The inspector determined that the ILRT appeared to be satisfactory, pending the final review of the licensee's report.

7.

Unresolved Items Unresolved items are matters about which more information is required to clarify whether they are acceptable items, items of noncompliance, or deviations. An unresolved item was identified and detailed in paragraph 3.b.(2).

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Entranca and Exit Interview Licensee Management was informed of the purpose and scope of the inspection at the cntrance interview, and the findings cf the inspection were periodically discussed with the licensee representatives as-summarized in the following:

Date Reportable Details Covered June 30, 1981 Entrance Interview July 1, 1981 3.b.(2),2.c July 2, 1981 3.b, 4.b July 3 and.4, 1981 4.b, 5, 6.b July 7, 1981 6.b July 8, 1981 2.c, 6.b, Exit The inspector conducted an exit interview with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection. The licensee acknowledged the inspection findings.

IR 05000289/1981018

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Superimposed Leak Rate = 200 f t*/hr

Total Measured Superimposed Leak Rate

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