IR 05000317/1985010

Insp Rept 50-317/85-10 on 850429-0502 & 0517-21.No Violations Noted.Major Areas Inspected:Containment Leakage Testing Program,Including Review of Containment Integrated Leak Rate Test & Local Rate Test Procedures

ML20127P571
Person / Time
Site:	Calvert Cliffs
Issue date:	06/23/1985
From:	Bettenhausen L, Kucharski S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127P533	List: IR 05000317/1985010 ML20127P529
References
50-317-85-10, NUDOCS 8507020457
Download: ML20127P571 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-10 Docket N License No. DPR-53 Priority --

Category C Licensee: Baltimore Gas and Electric Company P.O. Box 1475 Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Plant, Unit 1 Inspection At: Lusby, Maryland i Inspection Conducted: April 29 - May 2, 1985, May 17-21, 1985 Inspectors: d .

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S. D. Kucha'rski, Reactor Engineer

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' date Approved by: d Mu -

L. H. Bettenhausen, Chief

[Mdate Operations Branch, DRS Inspection Summary: Inspection on April 29-May 2 and May 17-21, 1985 (Inspection Report No. 50-317/85-10)

Areas Inspected: Routine, announced inspection of the containment leakage testing program including procedure review of Containment Integrated Leak Rate Test (CILRT) and Local Leak Rate Test (LLRT) procedures, CILRT and LLRT witnessing, CILRT and LLRT test review, on-line primary containment leakage monitoring, and general tours of the facilit The inspection involved 67 j hours onsite by one region based inspecto Results: No violations were identified.

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8507020457 850625 PDR ADOCK 05000317 G PDR i

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DETAILS Persons Contacted Baltimore Gas and Electric Company

• • R. Androsik, Engineer, LLRT Coordinator

• • 0. Bulich, Engineer, ILRT Coordinator

• • R. Denton, General Supervisor

• Miernicki, Principal Engineer

• • C. Quimby, Jr., Operations Quality Assurance Specialist

• • L. Russell, Station Superintendent

• • T. Sydnor, Supervisor, Technical Support

• • R. Wenderlich, Supervisor, QA Auditing Bechtel Corporation

• • L. Young, Engineer U.S.. Nuclear Regulatory Commission

• Ferlic, Project Engineer

• Denotes those present at exit meeting on May 2, 1985

• • Denotes those present at exit meeting on May 21, 1985 Containment Local Leakage Rate Testing 2.1 Documents Reviewed

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STP M-571-1, Local Leak Rate Test, Revision 6, 3/29/85

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STP M-671-1, Containment Purge Isolation Valves Leak Rate Test, Revision 1, 4/26/85

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STP M-171-1, Personnel Air Lock Seal Test, Revision 6, 8/8/84

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Records of local leakage rate testing (LLRT) activities conduct-ed during the recent outage including test results, related repair and retest documentatio Selected System Drawings, Piping and Instrumentation Diagram .2 Scope of Review The inspector reviewed the above documents to ascertain compliance with regulatory requirements of Appendix J to 10 CFR 50, Calvert ,

Cliffs Technical Specifications, applicable industry standards and station administrative guideline The inspector also witnessed a local leakage rate test, held discussions with the licensee regarding

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the documentation of tests results, the repair and retesting folfow-

~ ing failed tests, and the relationship of these items to the "As-Found" and "As-Left" conditions of containment as applied to CILRT results. Further details are discussed belo .3 Procedure Review The procedures reviewed were technically accurate and in conformance with the regulatory requirements of Appendix J to 10 CFR 50 and applicable industry standard The LLRT coordinator and associated licensee personnel have made a concerted effort via plant system walkdowns to assure that the valve lineups used for local leak rate testing are accurate and in accordance with leakage testing requirement No unacceptable conditions were identifie .4 Test Witnessing On May 18, 1985, the inspector witnessed a Type B LLRT of the Personnel Air Lock Door seals. The test was conducted with procedure STP-M-171-1 using a Volumetric Leak Rate Test Monitor. The result of the inner door test was considered acceptable with a measured leak-age of 5.9 Standard Cubic Centimeters per minute (SCCM) which is below the administrative limi The result of the outer door test was 31.2 SCCM which is above the administrative limit of 25 SCCM but below the Technical Specification limit of 69.2 SCCM. The decision of the licensee was to repair the door seal after the ILR The inspector verified that the test was being conducted in accor-dance with the approved procedure and that the test instrument were properly calibrated. Additionally, the inspector interviewed a test technician to ascertain that he was knowledgeable of test procedure requirements and use of the special test instrument No unaccept-able conditions were identifie .5 LLRT Instrument Calibration .

The inspector reviewed the calibration records for the flow trans-mitters, and pressure gages used on the LLRT test rigs. The instru-ments were appropriately calibrated and were marked with current calibration sticker No unacceptable conditions were identifie .6 Test Results The inspector reviewed the LLRT results summary and discussed analysis of test failures, repairs and retests with the license The "As-Found" and "As-Left" leak rate for every test done on each penetration isolation valve are documented by the licensee in the LLRT summary and will be in the CILRT test repor Based on a preliminary review of the data the LLRT was within the allowable leakage total of 0.6La or 207600 SCC The "As-Found" leakage was 45393.56 SCCM and the "As-Left" leakage was 83052.21 SCCM. No unacceptable conditions were identifie .

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3. Containment Integrated Leak Rate Test 3.1 Document Reviewed

-. STP M-662-1, ILRT Unit 1 Containment, Revision 4/10/85

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CILRT Log Book

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CILRT Computer Program

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CILRT Instrumentation Documentation (Calibration Records and Volume Fraction Calculations)

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Test Results

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Selected Piping and Instrument Drawings 3.2 Scope of Review The inspector reviewed the above listed documents for technical ade-quacy and to ascertain compliance with the regulatory requirements of Appendix J to 10 CFR 50, Technical Specifications and applicable in-dustry standards. The inspector noted that the procedure required a minimum test duration of eight hours. This reduced duration test is acceptable to the NRC based on the procedure meeting the requirements of Bechtel Power Corporation's Topical Report BN-TOP-1, " Testing Criteria of ILRT of Primary Containment Structures for Nuclear Power Plants". The procedure referenced and was in general conformance with industry standard ANS/ ANSI 56.8-1981, Containment System Leakage Testing Requirements. The Inspector witnessed a large portion of the activities related to the CILRT and the subsequent verification tes The inspector also performed an independent calculation of the test result .3 Procedure Review The inspector reviewed the above documentation for technical adequacy and for consistency with regulatory requirements, guidance and li-censee commitments. Review of the procedure's acceptance criteria, test methods, and references indicated adequate conformance with Appendix J to 10 CFR 5 On a random sampling basis, the inspector reviewed the procedure valve lineups for many of the piping penetrations. This review was to ensure that systems were properly vented and drained to expose the containment isolation valves to containment atmosphere and test differential pressure with no artificial boundaries. No unacceptable conditions were identifie .4 CILRT Instrumentation i The inspector reviewed the calibration records for the resistance temperature detectors (RTD's), dew point instruments, precision pres-sure detectors, and verification test flowmeters. Their calibrations prior to the. CILRT were found to meet applicable accuracy requirements and were traceable to the National Bureau of Standards. No unaccept-able conditions were identifie ...

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3.5 CILRT Chronology

5/18/85 0600 Commenced containment inspection 0730 Completed containment inspection 1230 Completed local leakage testing on drywell air lock 1530 Stopped pressurization problem with pres-surizer level (dropped from 138" to 58")

1655 Level stayed constant - filled to 155" in the pressurizer 1725 Restarted pressurization 5/19/85 0245 Reached test pressure of 50.5 psig 0645 Secured last containment cooler 0800 Received permission to allow pressure to go to 52.0 psig 0830 Completed temperature stabilization perio Acceptance criteria met. (According to ILRT log of events)

1200 Resistance temperature detector (RTD) TE14

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indicates lower reading than the other temperature elements. It was deleted and the volume fraction was assigned to TE 1 Data analysis indicates a negative leak rate. Investigating the possibilities of in-leakag Inspection shows no probable path for in leakage to the containment 1745 TE-13 is giving bad data, its volume will be assigned to another T RTD TE-13 is assigned to RTD TE-6 2343 Test start time was changed to 1330 -due to temperature transients still occurring at 0830 (B.G.& E. also terminated the ILRT at

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5/20/85 0030 Started superimposed leak verification tes Imposed leak 10.75 SCFM, 0.173%/ Day 0630 Completed data collection for verification test 0725 Started Depressurization, rate is approximately 5 psig/hr 3.6 Test Performance / Control The majority of the test was performed strictly within the guidelines

- of the procedure. Slight problems and confusion did occur once the proper pressure was reache The licensee in an attempt to maintain pressure below the upper limit continued to cycle the containment i cooling units. At 0645 the last containment cooler fan was secured !

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and pressure was allowed to increase and level of Because of the pressure increase at 0800 the station superintendent gave permission to allow the pressure to go as high as 52.0 psi Based on BN-TOP-1, the licensee decided at the time to select 0830 as the official start of the tes The licensee after reviewing the data several times during the test decided to pick 1330 as the time for the start and the duration of the test to be 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. This decision as shown in the log was made at 234 The licensee based it's decision on the fact that the mass point calculation would show a maximum leakage rate. The inspector informed the licensee that the test should be from the the time stabilization has occurred and run for a minimum of eight hour After reviewing the data it was concurred by both parties that stabilization period started when the last fan was turned off at 0645. Based on this the start of the test should have been 1100 and the duration be 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Although the licensee and the inspector did not agree on the time block used, independent calculations by the inspector indicated that similar test results were obtained (See Paragraph below). The inspector had not further questions at this tim .7 Test Result Review The licensee evaluated the test results for the ten hour period between 1330 and 2330 on May 19, 1985. The calculated leakage rate at the upper 95?s confidence limit was 0.035 wt %/ Day for the mass point calculation and 0.069 wt is/ Day for the total time method. The test acceptance criterion is 0.150 wt is/ Da The inspector performed an independent calculation of the test results using the raw data from the test to estimate the accuracy of the licensee's leak rate calculations. The independent - calculation was performed first using the data from 1330 to 2330 which was reported as the official test by the license Secondly, the inspector performed the calculation using the data from 1100 to 2330 which is taking all the data into consideration. Thirdly, the inspector performed the calculation using first the air mass data and then the average temperature, total pressure and vapor pressure. The results are as follows: Licensee Mass point 0.032 wt is/ Day UCL-0.035 wt is/ Day Total time 0.025 wt is/ Day UCL-0.069 wt is/ Day NRC (1330-2330) Air mass calculation Mass point - 0.03202 wt is/ Day UCL-0.03518 wt is/ Day Total time - 0.02426 wt is/ Day UCL-0.06928 wt is/ Day

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7 Average Temperature, Total Pressure, Vapor Pressure Mass point - 0.03214 wt %/ Day UCL-0.03530 wt %/ Day Total time - 0.02517 wt %/ Day UCL-0.06804 wt %/ Day 3. NRC(1100-2330) Air mass calculation Mass point - 0.02770 wt %/ Day UCL-0.03058 wt %/ Day Total time - 0.02398 wt %/ Day UCL-0.10054 wt %/ Day Average temperature, total pressure, vapor pressure Mass point - 0.02771 wt %/ Day UCL-0.03058 wt %/ Day Total time - 0.02343 wt %/ Day UCL-0.09861 wt %/ Day The above values do not include the results of the LLRT's that were performed prior to the ILRT. A preliminary review of that data incorporated into the inspector calculations shows the following result . "As-Found" leakage = 45,393.56 SCCM Mass point - 0.05808 wt %/ Day UCL-0.06108 wt %/ Day Total time - 0.05108 wt %/ Day UCL-0.09508 wt %/ Day As-left leakage = 83,052.21 SCCM Mass point - 0.07972 wt %/ Day UCL-0.08272 wt %/ Day Total time - 0.07272 wt %/ Day UCL-0.11672 wt %/ Day 2. NRC(1100-2330) Air mass calculation "As-Found" data Mass point - 0.05379 wt %/ Day UCL-0.05662 wt %/ Day Total time - 0.050062 wt %/ Day UCL-0.12469 wt %/ Day "As-Left" data Mass point - 0.075429 wt %/ Day UCL-0.078299 wt %/ Day Total time - 0.0717 wt %/ Day UCL-0.14633 wt %/0ay .

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The inspector concluded that the licensee's calculations were ap-propriately- performed and accurate and if the licensee had picked

_1100 as the official start of the test, the results would still be acceptabl The CILRT was followed by a successful superimposed leak verification test. The licensee imposed a leak of 10.75 SCFM or 0.173 wt %/ Day on the existing leak. The measure verification test leak was 0.201 wt

%/ Day for mass point calculation and 0.166 wt %/ Day for total tim The test result was within the acceptance criteria band. The inspec-tor also verified this result by independent calculation. The results were as follows: Licensee Mass point band (0.155 < 0.201 < 0.255) Total time band (0.148_< 0.166 < 0.248) NRC Mass point band (0.155 < 0.20113 < 0.255) Total time band (0.148 < 0.16539 < 0.255)

No unacceptable conditions were identifie . Facility Tours The inspector made several tours of the facility including _ the control room, auxiliary building, and containment buildin During these tours the inspector observed operations and activities in progress, implementation of radiological controls, and the general condition of safety related equipment. In addition the inspector examined the containment system boundaries, component tagging, and instrumentation used to support the CILRT. During these tours the inspector also observed licensee personnel checking for evidence of leakage and verifying selected valves to be in the correct position according to procedural requirement No unacceptable conditions were identifie . Independent Calculations The inspector performed independent calculations of the test results of the CILRT and the subsequent verification test. Details are included in Section 3.7 of this repor .

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6. QA/QC Involvement During the performance of the final LLRT and the ILRT the inspector verified QA involvement in test monitoring. When questioned the QA personnel were knowledgeable of their responsibilities, how to perform their ' duties and reporting of their findings. No unacceptable conditions were identifie . Exit Meeting A meeting was held on May 2, 1985 and on May 21, 1985 to discuss the scope and findings of the inspection as delineated in this report (see Paragraph I for attendees). At no time during this inspection was written information provided to the license .