IR 05000324/1985031

Insp Repts 50-324/85-31 & 50-325/85-31 on 850909-13 & 23-26. No Violation or Deviation Noted.Major Areas Inspected: 10CFR50,App J,Type A,B & C Leak Rate Testing & Followup on Licensee Action on Previous Insp Findings

ML20133P997
Person / Time
Site:	Brunswick
Issue date:	10/11/1985
From:	Jape F, Macdonald J, Mellen L, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133P991	List: IR 05000324/1985031 ML20133P989
References
50-324-85-31, 50-325-85-31, NUDOCS 8511010297
Download: ML20133P997 (14)

Text

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NUCLEAft HEGULATORY COMMISSION

'O\- p/ '   REGION li h f  101 MARIETTA STREET,N *'-

t A1LANTA GEORGI A 30323

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Report Nos.: 50-325/85-31 and 50-324/85-31 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: September 9-13 and 23-26, 1985 Inspectors: ( /3 W /a , A d /0/II[FI . Macdonald Date Signed h . M 10l84 l85 LV. 5. M Uate Signed

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 . L. WhTtener  /  Dare Si'gned Accompanying Personnel: M. Allen Approved by: ,/M deo   //[[J Date bigned FranVJape, Section Chief f Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection involved 175 inspector-hours on site in the areas witnessing of 10 CFR 50 Appendix J Type A, B, and C leak rate testing; followup on licensee action on previous inspection findings, and previously identified inspector follow-up item Results: No violations or deviations were identifie e511010297gSdo 324 PDft ADOCK ppg G

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l REPORT DETAILS i Persons Contacted Licensee Employees

*P. W. Howe, Vice President, BNP
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'C. R. Dietz, General Manager, BNP
**B. E. Hinkley, Manager, Technical Support
** S. Blinson, Inservice Inspection Specialist
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#J. J. Blessing, U. E. S. C., ILRT Engineer
#R. E. Shirk, U. E. S. C. ILRT Engineer M. J. Pastva, Jr. , Regulatory Technician

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*#R. M. Poulk, Jr. , Senior Specialist, Regulatory Compliance Other licensee employees contacted includea construction craftsmen,
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engineers, t-chnicians, operators, mechanics, security force members, and

; office personne !

NRC Resident Inspector

#T,. Ruland
*L. Garner
" Attended exit interview on September 13, 1985 1 # Attended exit interview on September 26, 1985 1 Exit Interview The inspection scope and findings were summarized on September 13, 1985, and September 26, 1985, with those persons indicated in paragraph 1 above. The

! inspector described the areas inspected and discussed in detail the

inspection findings. No dissenting comments were received from the

licensee. The following new inspector followup item was identified during

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this inspection, inspector Followup Item (IFI) 325, 324/85-31-01, Isolation Valves Local Leak Rate Tested in the Reverse Direction, paragraph 5. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio I Licensee Action on Previous Enforcement Matters I (Closed) Violation Item 325/81-13-01, Inadequate (CILRT) Procedur In

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a CP&L letter to NRC Region !!, Serial Number NO-81-1362, dated

August 24, 1981, the licensee committed to revise the Brunswick (ILRT)

! procedure to provide for venting and draining of systems prior to ! performance of the ILRT to correct the problems cited in this violation. The inspectors reviewed the revised procedure Periodic Test

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PT-20.5 Integrated Primary Containment Leak Rate Test (IPCLRT). Of particular concern was meeting the test requirements of 10 CFR Part 50 Appendix J for proper venting and draining of systems and meeting the acceptance criteria of Appendix J BN-TOP-1, and ANS-4 , Periodic Test PT-20.5 meets these requirements and acceptance criteri Violation Item 325/81-13-01 a close ' (Closed) Unresolved Item 325/81-13-02, Review of the June 1981 Unit 1 t Type A Test Results. The Type A test is considered a failed test  : because it did not meet the acceptance criteria in Appendix J Paragraph III. A.1(a), which states that during the performance of the l test no repairs or adjustments shall be made so that the containment l can be tested in as close to the "as is" condition as possibl The licensee identified and isolated a leakage path through the CAC system  ; after the test was starte Since this constituted an adjustment to  : the containment, subsequent to the inspection, the Itcensee determined i this was a fatted test. Unresolved Item 325/81-13-01 is close , (Closed) Unresolved item 325, 324/85-21-01, Complete Review of LLRT Valve Alignments to Determine if Procedure is Adequate. The inspectors I reviewed Engineering Procedure: ENP-16.4 Use of Local Leak Rate Test i Equipment and 121 periodic tests: (PT-20.3.54-PT-20.3.175) local Leak  ; Rate Test for Containment Isolation. The valve alignments in all the procedures reviewed were in the proper test position and a vent path r for each penetration was estabit sbed. The valves tested in the reverse i (Non-LOCA) direction were identified in CP&L letter, serial i number: BSEP/84-161 This letter is addressed in paragraph 5. I Unresolved Item 325, 324/82-21-01 is close ! i (Closed) Unresolved Item 32S, 324/82-38-01, Verify Testing of Isolation I Valves in the Reverse Direction is Conservative. The licensee has i committed to preparing a report to NRR including an evaluation and i justification for testing isolation valves in the reverse (Non-LOCA) l direction. This item is addressed in paragraph 7.c. Unresolved Item ' 325, 324/82-38-01 is closed, r Unresolved Items i Unresolved items were not identified during this inspectio . Surveillance Containment Leak Rate Testing (CILRT) Units 1 and 2 (61720)

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The inspectors examined Type C local leak rate testing procedures and the local leak rate test apparatus. During review of the procedure t, the  ! inspectors determined which valves were tested in the reverse direction, and verified that the identification of these valves was documented. Acceptance criteria utilized by the inspectors appear in 10 CFR 50 Appendix . i

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, i a. Local Leak Rate Test Apparatus i l The inspectors reviewed the construction of the licensee's local leak i j rate test apparatus with the following observations-

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 (1) The flow meters on the test rig were within the range for normally  ;

expected valve leakag ' l l (2) A potential leakage path (via valve V-8) exists such that high j pressure make-up could bypass the flow meters during the t performance of local leak rate testin This would result in a j nonconservative leak rate calculatio The licensee will review j the construction of the test apparatus and make adjustments if

appropriat I j (3) The test apparatus employs the upstream test method which will i detect seat, stem and packing leakage (except as noted in section j on valves tested in the non-LOCA direction).

j b. Local Leak Rate Test Procedures

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I The inspectors reviewed the following local leak rate performance test i

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procedures: l PT N E_quipment Tested Penetration

r i 20.3.54 821-F010A X-9A 7

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20.3.55 B21-F010B X-98 ! 20.3.56 B21-F032A E41-F006 X-9A ! 20.3.57 B21-F032B,E51-F013, X-98 . ! G31-F039 i ! 20.3.58 B21-F016,F019 X-8 i ! 20.3.59 B32-V22,V30 X-62A,78A j ! 20.3.60 B32-F019,F020 X-56E ' i 20.3.61 B32-V24 X-62A

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i 20.3.62 B32-V32 X-78A i 20.3.63 C41-F006 X-42 1 20.3.64 C41-F007 X-42 l 20.3.65 CAC-V47 X-205  ! 20.3.66 CAC-V48 X-25 20.3.67 CAC-V4,V5,V6,V15, X-25,X-205 V55,V56 20.3.68 CAC-V7,V8,V22 X-220

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20.3.69 CAC-V9,V10,V23 X-26 l 20.3.70 CAC-X20A,V16 X-205 l 20.3.71 CAC-X208,V17 X-205 l 20.3.72 CAC-V29,V50 X-3B ! 20.3,73 CAC-PV12000 X-49B l 20.3.74 CAC-PV1261 X-498 l 20.3.75 CAC-PV1227A X-73A ,

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)  PT N Equipment Tested  Penetration l  20.3.76  CAC-PV1227B  X-73B
!  20.3.77  CAC-PV1227C (U-1)  X-73C l   CAC-PV1227E (U-2)  X-73E  :
:  20.3.78  CAC-PV1227E (U-1)  X-73E

CAC-PV1227C (U-2) X-73C

!  20.3.79  CAC-PV1260  X-73E (U-1) i
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j X-73C (U-2) 20.3.80

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!   CAC-PV1231B  X-244B i  20.3.81  CAC-PV3440  X-76B i  20.3.82  CAC-PV1225B  X-76B I  20.3.83  CAC-PV1211F  X-54F
{  20.3.84  CAC-PV1262  X-54F  ;

20.3.85 CAC-PV1209A X-57A i

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i 20.3.86 CAC-PV12098 X-57B j 20.3.87 CAC-PV1205E X-60E I

20.3.88 CAC-PV1215E X-245E  ;

)  20.C.39  CAC-PV1211E  X-54E i  20.3.90  CAC-PV3439  X-54E j  20.3.91  CAC-PV4541  X-244B  '

1 20.3.92 CAC-SV4540 X-245E j 20.3.93 CAC-SV4409-4 X-57A l 20.3.94 CAC-SV4409-3 X-57B

{  20.3.95  CAC-SV4409-2  X-60E 20.3.96  CAC-SV4409-1  X-209B(A)
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20.3.97 CAC-SV4410-4 X-73A 20.3.98 CAC-SV4410-3 x-/JB j 20.3.99 CAC-SV4410-2 X-73C (V-1)

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2 X-73E (U-2) 90.3.100 CAC-SV4410-1 X-206A(A) i i 20.3.101 CAC-PV1218C X-206A(C) , l 20.3.102 CAC-PV1219B X-206B(B) l

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20.3.103 CAC-PV1225C X-76C  ! i 20.3.104 CAC-PV12090 X-570

!  20.3.105  CAC-PV1219C  X-206B(C) I i  20.3.106  CAC-PV1213A  X-209B(A) l j  20.3.107  CAC-SV1218A
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X-206A(A) 20.3.108 E11-F008,F009 X-12 20.3.109 E11-F011A X-210A i i 20.3.110 E11-F0118 X-210B j 20.3.111 E11-F015A,F017A X-13A

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20.3.112 E11-F0158,F0178 X-138 {

l 20.3.113 E11-F016A,F021A X-39A l 1 20.3.114 E11-F0168,F021B X-39B i l 20.3.115 E11-F020A X-225A i i 20.3.116 E11-F0208 X-2250  ! . 20.3.117 E11-F022,F023 X-17 ' l 20.3.118 E11-F024A,F027A,F028A X-210A,X-211A ,

20.3.119 E11-F0240,F0278,F028B X-2100,X-211B l I

20.3.120 E11-F025A X-210A j 20.3.121 E11-F025B X-2100

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PT N Equipment Tested Penetration 20.3.122 E11-F037D X-68A (U-1) X-68C (U-2) 20.3.123 E11-F037B X-68D 20.3.124 E11-F0430 X-63C (U-1) X-68A (U-2) 20.3.125 E11-F0438 X-68B 20.3.126 E11-F037C X-51C 20.3.127 E11-F043C X-51A 20.3.128 E11-F043A X-51B 20.3.129 E11-F037A X-51D 20.3.130 E11-F097 X-210D 20.3.131 E11-F007A X-210A 20.3.132 E11-F0078 X-210B 20.3.133 E11-F103A X-214 20.3.134 E11-F103B X-214 20.3.135 E11-F055A X-214 20.3.136 E11-F055B X-214 20.3.137 E11-V20 X-214 20.3.138 E11-V21 X-214 20.3.139 E11-F029 X-210B

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20.3.140 E21-F001A X-227A 20.3.141 E21-F0018 X-2278 20.3.142 E21-F005A,F004A X-16A 20.3.143 E21-F005B,F0040 X-16B 20.3.144 E21-F015A X-223A 20.3.145 E21-F0158 X-2238 20.3.146 E21-F031A X-223A 20.3.147 E21-F0318 X-2238 20.3.148 E41-r002,F003 X-11 20.3.149 E41-F012 X-2108 20.3.150 E41-F042 X-226 20.3.151 E41-F022,F040 X-222 20.3.152 E41-F021 F049 X-214 20.3.153 E41-F075,F079 X-214.X-218 20.3.154 E41-PV1218C.PV12200 X-206A(D) X-206C(0) 20.3.155 E41-PV12190,PV12210 X-206B(0) X-2060(D) 20.3.156 E51-F007,F008 X-10 20.3.157 E51-F019 X-210 20.3.158 E51-F031 X-224 20.3.159 E51-F002,F028 X-221 20.3.160 E51-F001.F040 X-212 20.3.161 E51-F062,F066 X-212,X-216 20.3.162 G16-F003,F004 X-18 20.3.163 G16-F019,F020 X-19 20.3.164 G31-F001,F004 X-14 20.3.165 G31-F042 X-9B 20.3.166 RCC-V28,V52 X-23.X-24 20.3.167 RXS-PV12228,PV1222C X-778,X-77C

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_enetration 4 i i 20.3.168 RNA-V101 X-55 l 20.3.169 RNA-V103 X-71  !

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20.3.170 LA-pV12048 X-628 i I 20.3.171 LA-PV1204C X-62C

20.3.172 RXS-SV4186 X-209A(B) (U-1) l

! X-209B(0) (U-2) l 20.3.173 RXS-SV4187 X-209A(B) (U-1) J X-209B(D) (U-2) j 20.3.174 RXS-SV4188 X-209A(D) (U-1)

X-209B(B) (U-2) 1 i

20.3.175 RXS-SV4189 X-209A(D) (U-1) ! X-209B(D) (U-2)

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l These are all of the Type C rate test procedures, as identified by the

[ license The procedures meet the applicable requirements of 1 10 CFR 50, Appendix J, Section 11 !      ,

I Valves Tested in Non-LOCA Direction 10 CFR 50, Appendix J requires containment isolation valves to be i , tested in the direction that the valve would be required to perform its

safety function unless it can be determined that the results from the ! tests for a pressure applied in a different direction will provide i equivalent or more conservative result The inspectors reviewed the i Type C test procedures to determine which valves were tested in the ' . reverse direction. The number and type valves tested in the reverse j direction is summarized in the table below. Final determination of J conservation of the reverse direction testing of these valves will be ] made by the NRC Of fice of Nuclear Reactor Regulation.

. l TABLE i l VALVES TESTED IN OPPOSITE DIRECTION OF LOCA !

VALVE TYPE NUMBER TESTED IN REVERSE _ DIRECTION

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t Unit 1 Unit 2 Atlas RIP valves 0 17

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Gate Valves 23 23 i i Globe Valves 18 19

{ Plug Valves 0 11 j Solenoid Valves 2 2 { Butterfly Valves 0 7

l The specific valves tested in the reverse direction are listed in the l i following paragraphs, l l 1 (1) Atlas RIP Valve These valves have bellows and diaphram ! j arrangement which eliminates any possible leakage path around the ! stem. As a result, pressure applied om LLRT direction reflects a h

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all possible leakage paths from containmen These valves on l Unit 2 are as follows

i  ! I CAC-PV-1218C E11-F037A

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CAC-PV-12198 E11-F0378 , I CAC-PV-1225C E11-F037C l CAC-PV-1209D E11-F0370 1 CAC-PV-1219C E11-F0433 ' E41-PV-1218D E11-F0(1U E41-PV-12200 E11-F043C E41-PV-12190 E11-F0430

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: The valves on Unit I have been replaced by excess flow check j valves. Similar modifications are planned for Unit 2 during the i next refueling outag i I (2) Gate Valve These valves incorporate a wedge-shaped disc which j seats on both seating surfaces simultaneousl This seating !

j creates a disk-to-seat seal, and the packing is not exposed to [ i LOCA pressur Therefore, a failure of the seating surface : 1 nearest prima ry containment and a packing failure would be recuired before leakage to the atmosphere would occu l j $1x gate valves are located inside the drywell. As a result, any j leakage from the packing would still be inside primary t containmen These valves are as follows: i

E21-F016 E41-F002  ! i E11-FC09 E51-F002  ! E11-F022 G31-F001 i i $even gate valves are in lines which penetrate primary containment i and extent below the minimum water level, which would exist in the j torus during a LOCA. As a result, the only leakage possible from i primary containment would be water leakage. These valves are as , j follows: '

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I E11-F011A E41-F042 } E11-F011B E41-F075  ! ! E11-F007A E51-F031

;  E11-F0078 i Gate valve numbers 832-V22 and 832-V30 are in 3/4-inch lines. The 4 size of the stem on these valves is 3/8 inch. Even a severe r packing leak for a ster' this size would present a very small

- j j leakage path. The packing of these valves is cormally subjected - j to pressure in excess of 1000 psi, and routine visual inspection l

; by the Auxiliary Operator should detect any packing leakage.

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l , j 8 i t i ! j Gate valve numbers G16-F003 and G16-F019 are the isolation for the ! Orywell Drains System. Both lines are drains from submerged sump i

. pump These pumps remain underwater even when the sumps are  ,

i pumped to the minimum level. Therefore, a water seal is main- ' j tained and any packing leakage would be water leakage.

i ! Gate valve numbers E11-F021A and E11-F021B rely entirely on

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disc-to-seat leakage and packing integrity to ensure against gaseous leakage from primary containment. The valves are on lines ,

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connected directly to the ECCS ring header and would require j extensive modification to test in the LOCA directio l

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 (3) Globe Valves. These globe valves are pressurized from beneath the  i disc during the local leak rate test. This is a more conservative  l j  direction because test pressure would try to lif t the disc from its seat. However, testing from this direction leaves the packing  >

isolated from test pressure, i Five globe valves are located inside the drywell. As a result, i any leakage from the packing would still be inside primary containmen These valves are as follows: 4 B32-F019 B21-F022C B21-F022A B21-F0220 j B21-F0228 I I Eleven globe valves extend below minimum torus water level and, as j such, have water seal These valves are as follow:

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E11-F024A E41-F012 E51-F002 ;

. E11-F024B  E41-F022  E51-F001 '

i E11-F015A E41-F021 E51-F062 ! E11-F015B E51-F019 One Unit 2 globe valve, number G31-F042 ties into the feed water , line which should remain flooded post-LOCA and, as such, also has a water seal. Additionally, leakage must escape past two check ' ) valves prior to this packing receiving LOCA pressure, i

Two globe valves, numbers E11-F027A and E11-F0278 are installed in l

{ lines open to primary containment atmosphere and would require i J extensive modification to test in the LOCA direction. Since the  ! packing on these valves is normally exposed to drywell pressure , only and the valve is cycled only for testing, total packing , l failure is unlikely. An additional conservatism is that LLRTs are  ; j conducted by pressurizing between the two isolation valve ;

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Therefore, recorded leakage may be greater than would actually i occur during a LOCA. Additionally, Technical $pecifications allow l for 40 percent degradation prior to exceeding containment l

allowable leakage limits, i l

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i (4) Plug Valves. The design of these valves is such that there is not f' j leakage path around the stem. As a result, the LLRT reflects all possible leakage paths from containmen These valves on Unit 2

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are as follows: i l CAC-PV-12008 CAC-PV-1211F i CAC-PV-1261 CAC-PV-1262 ! CAC-PV-1260 CAC-PV-1215E  : CAC-PV-1231B CAC-PV-1211E . j CAC-PV-3440 CAC-PV-3439

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CAC-PV-1225B  : i l These valves have been replaced on Unit Similar modifications are planned for Unit 2 during the next refueling outag l l (5) Target Rock Solenoid "alves. These electric solenoid valves have l seal welded bonnets and no leakage path around the st*: LLRT !

;  leakage reflects all possible leakage paths from containmen .
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Valves affected are valve numbers CAC-SV4541 and CAC-SV-435 i (6) Butterfly Valve These valves have an offset disc stem arrange- , j y nt which places the packing on one side of the seating surfac , 1 Only those with packing facing the containment side of the disc  ; i are of potential concer Based on previous ILRT testing, these j j valve packings have not presented a significant leakage concer ; j These valves on Unit 2 are as follows: ,

i CAC-V5 CAC-V7 CAC-V16 CAC-V49 i CAC-V6 CAC-V9 CAC-V17 ! The Unit 1 valves have been reoriented and the packing is outboard i of the dis Similar reorientation is planned for Unit 2 during j the next refueling outage.

j (7) Summary l The licensee failed to identify E11-F015A (24 inch gate), j E11-F0158 (24 inch gate), E21-F005A (10 inch gate) and E21-F005B j (10 inch gate) in their study of valves tested in non-LOCA .

directions as identified in PT Nos. 20.3.111, 20.3.112, 20.2.142, l l and 20.3.143, respectively,  !

The licensee has committed to submit a report to NRR including . justification and evaluation for testing isolation valves in the L l reverse direction. The above valves will be listed in their i i repor This item will be identified as IFI 325, 324/85-31-01 l Isolation Valves Local Leak Rate Tested in the Reverse (Non-LOCA) l Directio . s t l Within the areas inspected, no violations or deviations were identifie .

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. 10 Type A Test Sequence and Description (61719) (90713) Pressurization of containment commenced at 2049 hours on September 23, 198 At 2230 hours the Personnel Airlock outer door seal was found to be leakin The seal was repaired at 0305 hours on September 24 and pressurization continue Containment test pressure was attained at 0511 hours on September 24, 1985, at which time the stabilization period bega During pressurization, stabilization and the next several hours an extensive leakage investigation revealed only minor seat or packing leakage on the following valves: E41 - F012 Ell - F027A At 1130 hours on September 24, 1985, the licensee met the containment stabilization criteria as established in BN-TOP-1 1972 Revision 1, Section 2.3.A.1, which states: "The 4 rate of change of average temperature is less than 1.0 F/ hour averaged ohr the last two hours".

At 1200 hours on September 24, 1985 the licensee began the ILRT. The reactor vessel level had been dropping at approximately 0.6 inches per hour, at 1435 hours the Control Rud Drive cooling water pumps were isolated in an attempt to stop the leakage. The leak continued and the licensee sub-sequently determined that the leakage path was into containment and would not effect the test results. At 1610 hours on September 24, 1985, the licensee halted the test and increased the reactor vessel leves to 211 inche The test was restarted at 1645 hours on September 24, 198 At 0600 hours on September 25, 1985, the ILRT met all the acceptance criteria established in BN-TOP-1 Section 2.3.8, for test termination as noted below: Criteria The trend report based on total time calculations was less than miximum leakage rate allowable (Note: BN-TOP-1 Section 2.3.B.1, indicated the maximum allowable leakage is L However, 10 CFR 50 Appendix J, which was issued subsequent to BN-TOP-1, reduces this to 0.75La. In cases where there is conflict between test methods and the regulations, the regulations govern).

Seventy-five percent of the maximum allowable leakage rate (0.75 La) for Unit 1 is 0.375 % weight / day. The preliminary test results indicated the leakage rate calculated to be 0.3635% weight / day which was obtained by adding the Type C penalty of 0.008*. weight / day to the mea >ured leak rate of 0.3555*. weight / da Criteria The end of the test upper confidence limit for the calculated leak rate based on total time was less than 0.75La (note discussion in Criteria B.1) including the as-found leakage and the type B and C leakage penaltie . - . -. - . . . _ _ - _ - . .- - .- . _ . - . _ ._. _ _ - _ _ - _ - - . _ l i

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l The upper confidence limit for the calculated leak rate based i on total time was 0.3635?. weight / day. (Note discussion in 2 f criteria B.1). j i

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Criteria The mean of the measured leak rates based on total time  ! calculations over the last points was below 0.75La (note discussions in Criteria B.1). , j Criteria Data was recorded at equal 15 minute intervals.

i i criteria The 13.25 hour test provided more than the minimum (20) data l j sets require by BN-TOP- l

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Criteria The test duration of 13.25 hours exceeded the minimum i

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requirements of BN-TOP- I i j At 0600 hours on September 25, 1985, the one hour stabilization period prior i to the supplemental test was started. At 0700 hrs the supplemental test i began. At 1345 hrs on September 25, 1985, the supplemental test acceptance i j criteria of BN-TOP-1 Section 2.3.C was me , I I Criteria At 0700 hrs on Septen.ber 25, stabilization for the I superimposed verification test was complete The i stabilization period of one hour met requirement of BN-TOP- i

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Criteria The verification test duration was 6.75 hours, was concluded l } ' at 1345 hours on September 25 and exceeded the minimum , required duration of 6.63 hour ! Criteria The resulting measured verification leakage agreed within 25*. of the calculated leakag ( ) i <  ; i Synopsis _of Unit 1 Type A Test _ _

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September 23, 1985 _

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r 2049 Commenced Pressurization I

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2230 Personnel Airlock nuter seal was leakin Pressurization l continued during repai ; ' i September 24, 1985 _ l t 0305 Personnel Airlock outer seal declared operable I l 0511 Attained test pressure

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1200 Commenced test 1435 Control rod drive cooling water pumps isolated 1610 Began reactor vessel level increase 1638 Reactor vessel level at 210 inches 1645 Test restarted September 25, 1985 0600 ILRT portion of PT 20.5 is completed satisfactorily. Verification test stabilization commenced + 0700 Verification test commenced 1345 Verification test complete 1405 Depressurization begsn Previously Identified Inspector Followup Items (IFI) (Closed) IFI 325/81-13-03, Post Test Calibration Verification Progra Periodic Test PT-20.5 Integrated Primary Containment Leak Rate Rest (IPCLRT) states that all test measurin) equipment must be calibrated within six months of performance of the test. The verification test also indicates if the test equipment remained in calibration for the duration of the tes IFl 125, 324/81-13-01 is closed, (Closed) IFI 325, 324/82-21-02, Identify and Correct Miscellaneous Leakages Not Quantified by Type C Testing. Miscellaneous leakages, not identified or quantified during Type C testing, were identified while performing the Type A testing. The most significant leakage paths being (1) the missing gagging bolt for relief valve E11-F055A and (2) the flow orifice for CAC-FT-2686. In a letter to NRC Region II, serial number: 85EP/82-1988, the licensee performed a review and has taken or committed to corrective actions to quantify or eliminate these leakage path IFI 325, 324/82-21-02 is close (Closed) IFI 325, 324/82-38-02, Changes to Pipe Supports and Restraints. The licensee has deleted Table 3.7.5-1 from Units 1 and 2 Technical Specification Deletion of the Table, which lists safety-related snubbers, eliminates the need for TS amendments to incorporate changes in the snubber listin This change is in accordance with guidance issued to the licensees in NRC Generic letter 84-13, dated May 3, 1984, subject: Technical Specification for Snubbers (Generic Letter 84-13). Any changes in snubber quantities, types or locations would be a change to the facility, such changes would be subject to the provisions of 10 CFR 50.59. The inspectors reviewed the licensee's Regulation Change Instruction RCI-03.1, which

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meets the provisions of 10 CFR 50.59 for reporting changes to the facilit IFI 325, 324/82-38-02 is close d. (Closed) IFI 324, 325/84-28-01 Review of the September 1984 Unit 2 Type A Test Results and the Licensee's Proposed Test Schedule. The Type A test is considered a failed test becuase it did not meet the acceptance criteria in Appendix J paragraph III. A.1.(a), which states that during the performance of the test no repairs or adjustments shall be made so that the containment can be tested in as close to the "as is" condition as possible. The licensee identified and isolated a water leak path from the RHR pump suction and discharge lires to the RH4 sump through 4-inch drain valves. This failure was the third consecutive Unit 2 Type A failure. The licensee acknowledged that the subsequent test dates must be in accordance with Appendix J paragraph III.A.6.(b) which states that if two consecutive Type A tests fail to meet the applicable test criteria, a Type A test shall be performed at each plant shutdown for refueling or approximately every 18 months, whichever occurs first, until two consecutive Type A tests meet the acceptance criteria. The licensee has committed to this test schedul IFI 324, 325/84-28-01 is close . }}