IR 05000324/1981013
| ML20010H319 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/21/1981 |
| From: | Burnett P, Butcher R, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20010H306 | List: |
| References | |
| 50-324-81-13, 50-325-81-13, NUDOCS 8109240335 | |
| Download: ML20010H319 (6) | |
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UN11 ED STATES
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NUCLEAR REGULATORY COMMISSION E
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101 MARIETTA SI., N.W.. SUITE 3100
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ATLANTA. GFORGIA 30303
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Report Nos. 50-324/81-13 and 50-325/81-13 Licensee: Cerolina Power and Light Company 411 Fayetterille Street Raleigh, NC 27602 Facility Name: Brunswick Docket Hos. 50-324 and 50-325 License Nos. DPR-62 and DPR-71 Inspection at Brunswick sita near Southport, North Carolina
_[L. W[hitener[M 7//7 N Inspectors:
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Date S gned fd W2t/2/
R. C. Butcher Date signed
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/8 Approved by:
/urnetTTTctiiig'SecMon Chief
.B Udte Signed
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Engineering Inspection Branch Engirieering and Technical Inspection Division SUMMARY Inspected on June E-11,1981 Areas Inspected This routine announced inspection involved 146 inspector-hours on site in the areas of containment integrated leak rate testing for Unit 1 and follow-up on outstanding items for Units 1 and 2.
Results Of the two areas inspected one violation was found in cm area (Violation -
inadequate CILRT procedure (325/81-13-01) paragraph 6.1)).
9109240335 810916 DRADOCK05000g
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DETAILS i
1.
Persons Con + acted
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Licensee Employees C. Dietz, Plant Manager
- W. Tucker, Manager, Technical Support M. Hill, Manager, Maintenance
- S. Bohanan, Regulatory Compliance Speciali st
- G. Bishop, Project Engineer
- E. Bishop, Engineering Supervisor
- J. Boone, Project Engineer, J. Ponder, Engineer
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H. Westermark, Engineer
- G. Oliver, E&RC Manager Other Organizations EBASCO Services, Inc
- J. Bruff, Senior Engineer
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M. Tagliamonce, Principal Engineer E. Franklin, Principal Engineer United Engineers and Constructors
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J. Ashenden, Engineer JRC Resident Inspector i
- D. Johnson, Serior Resident Inspector
L. Garner, Res! dent Inspector
- Attended exit interview l
2.
Exit Interview The inspection scope and findings were summarized on June 11,1981, with those persons indicated in Paragraph I above The - licensee asked for
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further clarification of certain Appendix J requirements.
The inspectors
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reviewed the NRC posicions on venting and draining of systems, add-on leakage values for local leak rate tests and the factors considered in identifying a failed test. Following discussions with the IE Headquarters leak rate specialist, the licensee was later informed by telephone that the
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NRC positions were correct as presented by the inspectors during the exit t
interview.
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3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
One new unresolved item identified during this inspection is discussed in naragraph 6.e.
5.
Containment !.s eg-ated Leak Rate Test (CILRT)
The inspectors reviewed the test activity to determina that the CILRT was performed in accordance with the Brunswick Integrated Primary Containment Leak Rate Test procedure, Appendix J to 10 CFR % and ANSI N45.5.
The inspection was aided by the resident inspector. Selected sampling of the
licepwe's activities which were inspected included:
a.
The CILRT procedure was reviewed for conformance to NRC requirements.
b.
Test pr 'ormance was observed to determine the test was conducted in conformance to test procedure prerequisites were completed, special equipment installed, appropri ne Jata were recorded and analyzed.
c.
Calibration records were reviewed to ensure test equipment was properly calibrated prior to use.
d.
A prelinfinary re;iew of leakage rate results was performed to evaluate
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the licensee's analysis of test data.
e.
Valve lineups for selected penetrations were reviewed for correct valve
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line up per the CILRT procedure.
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General Observations and Findings The inspectors observed the licensee activitie and reviewed the test precedure and presented the following observations and findings to the licensee prior to the test or at the exit interview, as noted. It should be
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noted that the NRC positions presented to the licensee at the exit interview were confirmed by telephone review with IE/HQ following the inspectors return to Region II.
e.
The inspectors reviewed the test procedure prior to the test and notified the licensee that the valve lineups were inadequate to ensure proper venting and draining of ystems to satisfy Appendix J to 10 CFR 50. Thu inspectors reviewed valve lineups for selected penetrations in detail and for all penetrations in general with the licensee to ensure
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comprehension of Appendix J requiremcnts.
In the exit interview the licensee was notified that the test racedure still provided for incorrect valve alignments. The following examples were noted:
(1) Nitrogen supply to +,he TIP system - A manual valve was shut which prevented proper venting of the containment isolation valve.
(2) Containment atmosphere monitoring (CAM) testem - Two valves on penetration X-54E that do not automatica'ly shut on an isolation
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signal were shut.
This prmented the upstream valves, that autoisatically shut on an isolation signal, from being subjected to containment pressure as required by Appendix J.
(3) Reactor building closed cooling w:ter (RBCCW) - The RBCCW system ir not fully qualified to seismic class I for portions of the system inside containment.
The RBCCW system was not vented and drained as required by Appendix J.
As a final note of caution, the licensee was reminded that the inspec-tors accomplished a thorough review of x1y a portion of their valve
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lineup and from the findings, a complete review by the licensee, including all associated non-containment vent or block valves, would be necessary to ensure compliance to Appendix J requirements.
The licensee stated at the exit interview that these matters would be addressed in a revision of the procedure.
b.
The inspectors reviewed the calibration records for the CILRT. The inspectors found no post-test calibration requirements and requested the licensee perform a cost-test survey to adequately assure the post-test accuracy of the test equipmtnt. This is necessary since some of the equipment may not be used/ calibrated for an extended time period following the test. The licensee concurred in the need for post test verification and committed to develop a post test calibration verifica-tion program This is inspector fo?)awup item (50-325/81-13-03).
c.
The ieNectors found that the test procedure did not provide for isolating and venting a potential source of air leakage into contain-ment as requircd by Appendix J.
The instrument air line into contain-ment had a single manual isolation valve outside containment with no provisions for venting.
Prior to the test the licensee shut the isolation valve and installed a flow meter inside containment to verify no inleaiJng. The flow meter indicated no in leakage. The inspectors requestad that Brunswick address the problem of not complying with the requ',rements of Appendix J by letter to NRR. The licensee agreed to ade ress this problem.
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d.
The inspectors found no provisions in the test procedure for adding certain type 'C'
leak test results onto the final integrated leak rate.
Type 'C' leakage results should be added for those systems which are isolated or not. vented c.nd drained as required by Appendix J.
Appendix J provides that systems that are required to remain in service to provide for safe shutdown may have their containment isolation valve type 'C' test results added to the CILRT leak rate. Examples of the systems not vented or drained are:
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(1) Feedwater (2) HPCI (high pressure coolant injection)
(3) RCIC (reactor core isolation cooling)
(4) RWCl! (reactor water cleanup)
(5) Core Spray (6) RBCCW (reactor building closed cooling water)
The licensee will address this matter in a revision of the CTLRT procedure or in a letter to NRR requesting exemption from venting and draining requirements.
e.
At the time of the exit interview the CILRT leak rate was approximately 1.2 percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Brunswick allowable leak-rate limit is
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0.375 percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The source of the excessive leakage had yet to be identified. The licensee took exception to the inspectors definition of when the CILRT started.
Subsequently, it was confirmed by telephone conversation with IE/HQ that Appendix J defines the start of the test as the time the final containment inspection is completed.
After the defined start of the test no repairs or adjustments may be accomplished without quantifying the as found/as left leak rates so the containment can be tested in as close to the "as is" condition as practical.
The licensee subsequently identified the source of excessive leakage, isolated the leak path through the CAC system and then successfully measured the leakage rate. The issue of initial test failure is an unresolved item pending NRC review of the licensee's final CILRT i
report.
(50-325/81-13-02)
f.
During the preparations for and during the CILRT, the licensee was told by the inspectors that the procedure stould list all systems that should be vented and drained but are required to remain operational for safe shutdown.
In addition, any system isolation valves that cannot be vented and drained as required by Appendix J for maintenance considera-tions should also be identified in the procedure. Any systems and/or
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isolation valves not tested during the CILRT due to maintenance should
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be limited to those which are unavailable due to lack of repair parts or extended rework required.
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The inspectors note'd that the test procedure did not specify how or i
where to vent various systems. The inspectors visually observed that the co_ntainment air monitors had loosened contsections to provide a vent path.
The TIP nitrogen supply line had a loosened ' connection to provide a vent path.
In neither case did the-procedure define what connection should be loosened-nor specify the restoration of the loosened connections.
h.
The test directors maintained a test log which was in the test control room. Pr edere changes and test problems were documented in the log.
i.
Due tc the number of items that did not meet Appendix J requirements, the inspectors reiterated at the exit interview the necessity for Brunswick to identify those systems and/or components that can not be.
tested per Appendix J and either request a Technical Specification exemption or commit to a date for compliance. Such a submittal should be on a timely basis prior to the next scheduled CILRT.
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Failure to have adequate procedures which would ensure tb=' the test requirements of Appendix J are met was identified as a violation
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(50-325/81-13-01) at the exit interview.
7.
IE Bulletin 81-01 The inspector reviewed the licensee's re.ponse to IEB 81-01, Surveillance of Mechanical Snubbers.
There are no mechanical snubbers installed in Brunswick Unit 1 or Unit 2.
Therefore, no action is required of the licensee and this matter is closed for both Unit 1 and Unit 2.