IR 05000327/1987051

Insp Repts 50-327/87-51 & 50-328/87-51 on 870720-24.No Violations or Deviations Noted.Major Areas Inspected:Review of Containment Isolation Sys Local Leak Rate Program Including Review of Test Procedures & Valve Alignments

ML20235T526
Person / Time
Site:	Sequoyah
Issue date:	09/17/1987
From:	Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235T507	List: IR 05000327/1987051 ML20235T505
References
50-327-87-51, 50-328-87-51, NUDOCS 8710130118
Download: ML20235T526 (7)

Text

{{#Wiki_filter:en Mo ~UNITED STATES f oq'o ~ NUCLEAR REGULATORY COMMISSIDs0-f f-g' -j)h ' j REGloN Il-101 MARIETTA STREET, * I ATLANTA, GEOnGt A 30323 e

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Report Nos.: 50-327/87-51 and 50-328/87-51

' Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street-Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50 328  License.Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah I and 2 Inspection Conducted: July 20-24, 1987    '
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Inspector: 'Yy M N [~~~~7[[w ' 7 - / 7 - R#7 H. L. Whiten r .Date Signecf Approved by: 9//// I F. Jape, Chief V / Dite Signed Test Programs Section Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was in the areas of review of the containment isolation system local leak rate program including review of test procedures, valve alignments, and observation of testin Results: No violations or deviations were identified,

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i i i 8710130118 870929 . PDR ADDCK 05000327 G PDR

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. REPORT DETAILS Persons Contacted Licensee Employees

*M. Chattin, Mechanical Test Supervisor
*M. Cooper, Compliance Licensing Engineer
*M. Cutlip, Mechanical Services Branch, Containment Test G. Gault, Acting Mechanical Test Supervisor
*L. Nobles, Plant Manager F. Walker, Mechanical Test Group NRC Resident Inspectors
* Branch, Restart Resident Inspector    i K. Jenison, Senior Resident Inspector    l
* Attended exit interview Exit Interview The inspection scope and findings were summarized on July 24, 1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio I Unresolved Items Unresolved items were not identified during this inspectio . Containment Local Leak Rate Test Program, Units 1 an 2 (61720)   ,

The inspector reviewed the licensee's containment local leak rate test program to verify that procedures have been developed and implemented which insure that the requirements of 10 CFR 50, Appendix J and the Technical Specifications are met. Selected procedures were reviewed for adequate technical content including: clear instructions, test , alignments, system restoration, procedural sign off, acceptable test 1 criteria, and review of test results Procedures which were reviewed totally, or in part, included the following:

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2 SI-157: " Testable Penetrations, Units 1 & 2, Revision 18" The procedure specifies the - Type B test program for electrical penetrations, mechanical bellows and resilent seal .1: " Containment Isolation Valve Leak Rate Test, Units 1 and 2, Revision 26" The procedure specifies the Type C test program for containment isolation valves, S1-159.1: " Personnel Airlock Operability and Overall Leakage Test, Units I and 2, Revision 10" The procedure specifies the actions to perform the full pressure air test on the personnel airlock .2: " Airlock Resilient Seal-Leak Rate Test, Units 1 and 2, Revision 12" The procedure specifies the test to be performed to demonstrate operability of . airlock door seals after airlock openin SI-159.3: " Containment Hydrogen Analyzer System Leakage Test, l Units 1 and 2, Revision 5" The procedure specifies the test to be performed on the system to verify its integrity as an extension to the containment boundar SI-159.4: " Personnel Airlock Operability, Units 1 and 2, Revision 2" l

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The procedure specifies the functional test of airlock doors as required by Technical Specification SI-159.5: " Leak Rate Test on Containment Pressure Instrumentation, Unit 1 and 2, Revision 2" The procedure specifies the required test if the containment pressure boundary is broken for instrument maintenanc Instrument boundary test is normally included in the Type A tes SI-658: " Electrical Penetration Nitrogen Supply Header Pressure Integrity Test, Revision 2" The procedure specifies the test to be performed to verify integrity of the Nitrogen supply to electrical penetration i. 51-160: " Primary Containment Local Leak Rate Summary, Units 1 and 2, Revision 4" _____ _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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3 The procedure specifies the summation of leakages from Types A,' B and C tests to verify that leakage limits meet the limiting condition for-operation for total leakage and bypass leakag SI-14.2: " Verification of Containment Integrity, Unit 2, Revision 14" The procedure specifies the requirements to insure that any isolation valves not capable of automatic closure are closed and, if appropriate, deactivated in order to establish containment integrit The procedure establishes the administrative control of manual vent and drain valves which are a part of the containment boundar TI-69: (Technical Instruction): " Summary of Pre-and Post-mintenance Tests For ASME Section XI and 10 CFR 50 Appendix J Valves Requiring Position Verification, Units 1 and 2, Revision 11" The procedure specifies the requirements for pre-and post-maintenance leak rate tests on containment isolation valves to insure that the i

"as found " integrated leak rate can be determine In addition to the above procedure review, the inspector verified that the licensee has established a control to insure that Technical
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Specification surveillance requirements are incorporated into surveillance instruction This control was established in SI. 1, Appendices A, B and C which provide a cross reference index of surveillance requirements and surveillance instruction The inspector verified that the procedures reviewed fulfilled the surveillance requirements of Technical Speci fications' 4.6.1.1.a-c , l 4.6.1.2.a-j, 4.6.1.3.a-c, and 4.6.3.4 and were properly identified in the Appendices of SI- Based on this review the inspector concluded that the licensee has developed and implemented the procedures necessary to conduct the local leak rate test program in conformance with the requirements of 10 CFR 50, Appendix J and the Technical Specification ) Comments On Test Procedures During the procedure review some concerns were identified and resolved l with the licensee. These items do not af fect the above conclusion that j the local leak rate test program is adequately defined.

j .1 (Type C Valve Testing)

(1) Non-Essential Air System The non-essential air system supplies control air to certain  s components which need to be operable during plant shutdow Depressurization of the entire system for the Type C test would
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4 I require a number of temporary connections . from another air sourc The licensee normally depressurizes only the penetration test volume leaving the system beyond. the block valves pressurize The concern is the , potential' for ! unmonitored air. flow during the test from the pressurized portion of the system into the test volume through the block valves. This would result in a non-conservative leak rate. The licensee will revise the test procedure to require that the test volume be depressurized and then isolated. After an established waiting period, the vent valve on the test volume will be opened ' and bubble tested to detect any air leakage into the test - volume. If no leakage through the block valves is detected, the Type C test can be performed with a portion of the system pressurized. The inspector had no further questions on this matter, j (2) Containment and RHR Spray Systems I The licensee has an exemption from Appendix J to permit testing the containment spray system, Penetrations 48 A and 48 B, using water as a test medium. The licensee has also submitted a request for an exemption to Appendix J which will allow a water test medium to be used for a similar system: the RHR containment spray system. Water leakage is currently added to Type C air

, leakage for the total local leak rat The inspector determined, that with exemption to use water as a test medium, there is no requirement to add the water leakage to the Type C air leakag b. TI-69 (Pre-and Post-Maintenance Leak Rate Tests)

This procedure addresses the type of valve maintenance which could i affect the leakage through a valve and, therefore, would require a l pre-and post maintenance leak rate test to obtain the information ; necessary to determine the "as found" integrated leak rat The

inspector observed that a change in the torque setting and valve packing was not adequately adressed. The licensee agreed to revise the procedure to address these areas of maintenance. The Containment l Systems Branch in conjunction with the Plant Systems Branch of the

Office of Nuclear Reactor Regulation (NRR) issued a staff position relat?ve to leak rate testing subsequent to valve maintenance in May 1 197 l The staff concluded that during operations the systems should be maintained as leak tight as possible. Since the addition of packing rings and tightening of the packing . is expected to reduce the I leakage, these activities require no post-maintenance leak rate test.

l However, repacking or replacement of the packing does require a post , maintenance leak rate test.

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5 ) ! l In an outage where a plant is conducting a valve test program prior ) to a Type A test, Appendix J specifies the requirement Specifically, no adjustment or repair to,the containment boundary may be made prior to the Type A test unless the change,s in leakage rate are quantifie t

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      ' (Control of Containment Integrity)

In this procedure the licensee identified several ways to achieve the condition of " locked" or " secured" closed. The inspector pointed out l that the intent of this requirement is as follows: ]

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Provide a physical restraint to movement of the_ valve which would discourage any inadvertent movement of the valve and, 2) provide a means for visual detection' of valve movement. The words " locked" or " secured" are generally accepted to mean ' physical restrain The licensee will review his controls in this contex The inspector had no further questions at this tim . As-Found Integrated Leak Rate The licensee has implemented a procedure, Technical Instruction (TI)-69, for the purpose of identifying the valves in the Appendix J and ASME

,Section XI programs. These valves are listed or referenced in the procedure and the pre-and post-maintenance leak rate test requirements are specified. The procedure refers to SI-158.1 for details in testing Appendix J valves. This procedure is used by the work request planning group to insure that a work request for maintenance on containment isolation valves has the pre-and post-maintenance leak rate testing specifie Before maintenance can be performed on 'the valve, the Mechanical lest group must sign off on the work request certifying that the specified pre-maintenance leak rate test is completed. The inspector concluded that the licensee has established a system of controls which should insure that the required leak rate testing is performed on containment isolation valve . Review of Open Items Two outstanding items were reviewed during this inspection. The status of these items is summarized below: (Closed): IFI (50-327/85-44-01) concerned a discrepancy between the output of two precision pressure gauges monitoring the same pressure source which resulted in using a previous and consistent instrument calibration for these gauges during the Unit 1,1985 integrated leak i rate test. The licensee committed to recalibration of the gauges after the test and to recalculation of the leak rate based on the corrected data. The inspector reviewed the corrected calibration i data and a memorandum dated February 5,1986 to the Site Director l from the Director of Nuclear Services certifying that all pressure

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1 gauges were recalibrates and the leak rate recalculated using the corrected pressure instrument calibration The corrected calculation changed the leak (LAM) from 0.073 wt.is per day to wt.?? per da The corrected 95?s Upper Confidence Limit was 0.123 I wt.fs per day which is well below the allowable leakage of 0.1875 wt.?s l per day. The cause of the problem was not an error in calibrating , the gauges but rather the assignment of the calibration data to the ] wrong instrument number due to a computer error. This error has been i corrected to prevent a recurrence of this proble This item is ] l considered close b. (Closed): IFI (50-327/85-44-02) concerned an inadvertent change to i the integrated leak rate test procedure (SI-156) during ;he procedure I revision proces Investigation indicated that revisicns to this f procedure had been made at locations onsite and in the Chattanooga l offices. Further, it was determined that some changes to SI-156 had been on a word processing system other than the IBM 05/6. When the IBM 05/6 disks were used to generate a complete revision of SI-156, the change in step 6.4.2 stored on a jacquard disk was omitted. The { licensee now has the corrected procedure on the IBM 05/6 disk and all future changes will be made on this system and controlled by the Site Procedures Staf This item is considered close l

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