IR 05000327/1990010
| ML20034A573 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/27/1990 |
| From: | Belisle G, John Zeiler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20034A572 | List: |
| References | |
| 50-327-90-10, 50-328-90-10, NUDOCS 9004230500 | |
| Download: ML20034A573 (9) | |
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pmat:0 UNITE] STATES
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- o NUCLEAR RECULAT;RY COMMISSION
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CE! ION ll
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101 MARIETTA STREET N.W.
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ATLANTA, G EORGI A 30323
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Report Nos.: 50-327/90-10 and 50-328/90-10 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
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i moection Conducted: March 5 - 9, 1990 lupector:
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3 26 !90 J. Zeile p'
/Date Signed J!z7 fd Approved by:
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G. A. Belisle, Chie'f
/ Date/ Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:
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This routine unannounced inspection was conducted in the areas of containment local leak rate testing, verification of containment integrity, and review of previous inspection findings.
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Results:
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The licensee's local leak rate test program was found to meet all NRC requirements.
Detailed test procedures and controls have been developed and l
implemented accordingly.
Ongoing leak rate tests for the containment purge.
valves and airlock door seals were witnessed.
Conservative leak rate test-i practices were being followed and test personnel appeared knowledgeable of test requirements and the use of test instrumentation.
Two minor
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. discrepancies were. identified from a review of test data from the most recent Unit 1 outage testing, but this was not indicative of programmatic weaknesses.
A limited review was conducted in the area of. containment integrity. Startup procedures contained adequate measures and controls to ensure that containment integrity ~ is established snd maintained.
Technical specification required surveillance procedures e.id records for the containment airlock, spray system, and vent coolers were reviewed.
These systems appeared to be reliable in that operability. problems wer.. not identified in the tests reviewed.
l A.non-cited violation was identified concerning the March.1988 inadvertent issuance of boric acid from Power Stores, paragraph 4.b.
The boric acid was issued prior to Quality Control receipt inspection.
9004230500 900410 PDR ADOCK 05000327
Q PDC s
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REPORT DETAILS
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Persons Contacted i
Licensee Employees
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- F. Bodine, Engineering Support
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- J. Bynum, Vice President, Nuclear Power Production
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- C. Vondra, Plant Manager.
- M. Burzynski, Site Licensing Manager
- M. Cooper, Compliance Licensing Manager
- J. Gates, Technical Support Manager
- W. Lagergren, Jr., Operations Superintendent
- S. Spencer, Licensing Engineer J. Wheeler, Materials and Procurement Manager Other licensee employees contacted during this inspection included
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engineers, operators, technicians, and administrative personnel.
NRC Resident Inspectors l
- P. Harmon, Senior Resident Inspector K. Jenison, Senior Resident Inspector
- D. Loveless, Resident Inspector
- Attended exit interview
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Acronyms and initialisms used in this report are listed in the last
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paragraph.
2.
ContainmentLocalLeakRateTesting(61720)
The purpose of the inspection activities in'this area was to determine if the licensee's LLRT program was_ being conducted in compliance with NRC
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requirements and applicable industry standards.
P The following surveillance instructions which control and implement the licensee's LLRT program were examined:
SI-158.1 Containment Isolation Valve Leak Rate Test, Rev. 29 SI-159.1.1 Personnel Airlock Pen-X2A Operability and Overall Leakage Test, Rev. 1 SI-159.1.2 Personnel Airlock Pen-X2B Operability and Overall Leakage Test, Rev. 1 SI-159.2.1 Airlock Resilient Seal Leak Rate Test, Rev.-0
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SI-159.4.1 Personnel Airlock 0parability, Rev. 0 SI-160 Primary Containment Local Leak Rate Summary, Rev. 4
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The inspector verified that the following attributes were included'in these procedures to ensure that adequate leak rate tests were conducted:
(1) All required containment penetration. boundaries and CIVs were
included in the LLRT program.
(2) LLRTs were performed at CILRT peak design pressure.
(3) The LLRT program utilized approved methods for testing containment penetration boundaries and CIVs.
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(4) Penetration leakage rates were determined using the maximum pathway leakage.
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(5) The criteria and response for LLRTs and combined leakage rate failure were incorporated in the test program procedures.
Using procedure SI-159.1, a detailed review was performed for Type C classified CIVs in the following penetrations:
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Penetration X-15 Chemical and Volume Control System Penetration X-30 Safety Injection System Penetration X-44 Chemical and Volume Control System
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Penetration X-51 Fire Protection Penetration X-64 ERCW Penetration X-76 Compressed Air System Penetration X-77 Demineralized Water System
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l Penetration X-110 Upper Head Injection The inspector verified that adequate alignments for venting and draining existed, and that adequate valve boundary alignments were provided for i
I each valve tested.
The inspector verified that the penetration valve
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l configurations described in the procedure agreed with that of current plant drawings.
In addition, the inspector - verified. that these penetrations conformed to 10 CFR 50, Appendix A, GDC 55, 56, and 57.
The inspector reviewed a sample of completed "As-Found" and "As-Lef t" Type
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B and C LLRT results since the beginning of the last outage for Unit 1.
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l Particular attention was devoted to verify that corrective maintenance I
work was performed for valve test failures _and that retests were performed
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as required. The following two minor discrepancies were identified:
A July 29,1988, "As-Found" leak rate test for isolation valve 61-193
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located in penetration X-47B was tested at approximately double the required test pressure.
The test performer was unable to pressurize
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the test volume at the required 12.0 psig.
The test pressure was increased to 25 psig in order to get a flow rate reading within the range of the one-inch tube rotometer used for the test.
The measured
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leak rate was 754.4 SCFH-which exceeded the leak rate acceptance
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value of 0.24 SCFH for the valve.
The test was declared a failure, maintenance w6s performed to repair the valve, and a retest was conducted as required.
The inspector concluded.that the licensee
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would have performed the same corrective action regardless, had the correct test pressure been used since the measurea leakage was so grossly over both the individual valve limit and the overall 0.6La limit of 135.1 SCFH.
However, the test performer.should have
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recorded that the valve would not pressurize as opposed to testing at the higher pressure. This appeared to be an isolated event and not a common practice among test personnel.
All test personnel were counseled by the licensee to reinforce testing at the correct.
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pressure at all times.
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After maintenance was conducted on Unit i valves 30-47 and 30-572, an-
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"As-Left" leak rate test was performed on September 17, 1988.
However, the licensee failed to record the leakage result of 0.595
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SCFH in procedure SI-158.1, Appendix A, Data Summary Sheet.
Consequently, this leakage was not included in the summation of Type B and C leakage as recorded in procedure $1-160.
The inspector considered this an isolated event and was not indicative of
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programmatic weaknesses in the licensee's LLRT program.
The inspector witnessed various aspects of ongoing licensee leak rate testing for the containment purge valves and the personnel airlock door seals.
The purge valves are required to be tested by TS every three months and the airlock door seals are tested by the licensee every three i
days, regardless of whether a containment entry has been made or not. The
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inspector verified that test personnel followed approved test procedures and that qualified test equipment were used.
Personnel conducting the tests demonstrated a good understanding of the test equipment and were
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knowledgeable of test requirements.
The results-for all tests conducted met the acceptance criteria specified in the test procedures.
I Within the areas inspected, violations or deviations were not identified.
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Verification of Containment Integrity (61715)
The purpose of the inspection activities in this area was to verify the adequacy and implementation of procedures and controls designed to maintain containment integrity and to mitigate contamination releases in the event containment integrity is lost following a LOCA, a.
Primary Containment Integrity Controls The inspector reviewed procedures G01-1, Plant Startup from Cold
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Instructions Required for Modes 4 or 3.
Together, these procedures ensure that all necessary plant conditions are established for plant
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startup.
The inspector verified that the procedures included the minimum provisions as specified in TS Section 1.7 for ensuring
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primary containment integrity ecists before the - plant enters operational modes which require containment integrity.
The inspector also reviewed Unit 1 procedure SI-14.1, Verification of Containment Integrity which provides assurance of primary containment isolation by visual verification that all manual CIVs and inside and outside vent / drain valves located between CIVs are closed.
The inspector verified that the procedure ~ included all applicable containment isolation barriers.
Completed surveillance records for.
procedure SI-14.1 were reviewed. for. the past four months of Unit 1 operation.
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Containment Systems Designed to Mitigate the Consequences of a LOCA
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The following containment related systems or mechanisms designed to mitigate the consequences of contamination releases following a LOCA were reviewed for compliance with TS requirements:
Containment airlocks Containment temperature and pressure limits Containment spray Containment vent coolers The inspector reviewed the following surveillance procedures which-demonstrate the operability of the above systems:
SI-159.1.1 Personnel Airlock Pen-X2A Operability and Overall Leakage Test, Rev. 1 SI-159.1.2 Personnel Airlock Pen-X2B Operability and Overall Leakage Test, Rev. 1 SI-159.2.1 Airlock Resilient Seal Leak Rate Test, Rev. O SI-3 Daily, Weekly, and Monthly Logs, Rev. 70 SI-34 Containment Spray System Valve Position Verification, Rev. 8 SI-37.1 Containment Spray Pump 1A-A Quarterly Operability Test, Rev. 1 SI-37.2 Containment 9 > ray Pump IB-B Quarterly Operability
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Test, Rev. *
SI-68 Functional Test of Containment Spray Pumps and Associated Valves, Rev. 5 SI-738 Lower Containment Ventilation Coolers Operability, Rev. 1 SI-739 Lower Containment Ventilation Coolers Flow Verification Test, Rev. 3 The inspector verified that the procedures complied with applicable TS requirements, that adequate information and instructions were provided, and that adequate acceptance criteria and limits were specified.
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l The inspector reviewed the completed surveillance records listed in.
t Table 1 and verified that the surveillances were performed at the req' aired frequencies, test results met acceptance criteria or limits, and appropriate sign-offs, test reviews, and test concurrences were performed.
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Table 1
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Containment Procedure System No.
-Records Reviewed
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Airlocks SI-159.1.1 07/19/89 to 12/14/89 4.6.1.3.b
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SI-159.1.2 07/20/89 to 12/19/89 4.6.1.3.b
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SI-159.2.1 12/05/89 to 02/21/90 4.6.1.3.a Temperature SI-3 Month of February 1990 4.6.1.4 and Pressure 4.6.1.5.1/2 Containment SI-34 12/14/89 to 02/07/90 4.6,2.1.1.a Spray SI-37.1 02/22/89 to 08/09/89 4.6.2.1.1.b SI-37.2 02/17/89 and 05/08/89 4.6.2.1.1.b SI-68 09/05/88 4.6.2.1.1.c Vent Coolers SI-738 12/06/89 to 03/02/90 4.6.2.2.a SI-739 05/04/88 4.6.2.2.b Based on this sample review, the inspector concluded that, for these
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systems, the licensee has established and implemented surveillante tests to ensure their operability as required by TS.
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Within the areas inspected. violations or deviations were not identified.
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4.
Followup on Previous Inspection Findings (92701, 92702)
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(Closed) URI (50-327, 328/88-60-02):
QC. Acceptance of Boric Acid Which did not Conform to Receipt Specifications The licensee's performance of startup physics test RTI-4, Boron Endpoint Determination and Isothermal Temperature Coefficient, completed November 8,1988, for Unit 1, resulted in an ARO critical
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boron concentration which was outside the acceptance criteria.
Upon-evaluation by the licensee, it was discovered that boric ' acid
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purchased earlier in the year had been incorrectly accepted by QC receipt inspectors.
The boron-10 content of the boric acid slightly exceeded the 19.6 0.3 atom percent specified in the receipt specification requirements.
Subsequently, the licensee initiated an evaluation of. the acceptance and use of boric acid not meeting the boron-10 content requirements specified above.
Westinghouse determined the range of boron-10 content that can be accepted in boric acid at Sequoyah for the current fuel cycle without i
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impacting safety' limits to 'be 19.75 to 20.3 atom percent.- Samples of the boric acid from Contract No. 88NDA-47787A,were analyzed and the content of boron-10 was found to be between 20.02 and 20.09 atom E
percent._ This was within the safety margin-for boron-10 content-as specified-by Westinghouse.
The actual safety - significance of. the boron concentration discrepancy was'therefore minimal.
This matter was addressed in the licensee's response to Example No. '3 '
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of NRC Violation 50-327, 328/88-60-01._ The violation addressed the-
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licensee's. failure' to :promptly initiate _ corrective action upon.
identifying that on April 7,1988, a licensee - QC inspector. had -
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approved-the receipt of. boric acid which did not conform to the--
receipt specifications of %A-159.. Standards and Guides 4r Quality:
Assurance Level III Items.
As discussed in the.-licensee's response g
dated April 10, 1989, the incident was an isolated case of QC
inspector's failing to follow procedures.
The licensee conducted i
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training sessions with their QC inspectors to discuss the inadequate j
receipt in3pections, explain the importance of verifying-each
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specification before acceptance, and, provide direction in obtaining!
l assistance from quality engineering personnel _ to. resolve problems.
i The inspector determined that this matter was adequately _ addressed in
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the licensee's corrective action for NRC Violation: 50-327,
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328/88-60-01.
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(Closed) URI (50-327, 328/88-60-03):
Release of Boric Acid from
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Power Stores Prior to QC Receipt Inspection i
er NRC Inspection Report No. 50-327, 328/88-60 reported that the j
licensee had indicated that boric acid purchased under Contract No.
l 88HDA-47787A was released from Power Stores prior to QC inspection.
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This matter was not addressed by the licensee.ii their response to NRC Violation 50-327, 328/88-60-01.
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Boric acid purchased under Contract No.: 88NDA-47"87A was received by j
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the licensee on March 22, 1988. 'As described in paragraph 4.a, the i
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boric acid contained a slightly higher boron-10 content than specified
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in the receipt specifications of SQA-159. The boric acid was tagged -
with Power Stores labels which identify each item ~and provides -
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traceability to the contract and was segregated pending QC receipt
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inspection.
On March 31, 1988,. Power Stores ' personnel issued 16
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drums of the boric acid not knowing it had not been inspected _ by QC.
The licensee reported that this occurred due to the practice of i
tagging incoming material before QC inspection.
Power Stores has discontinued the practice of tagging material prior to QC receipt inspection. The inspector reviewed Administrative. Instruction AI-11,
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Receipt Inspection and Nonconforming Items, which was revised by the
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licensee on May 11, 1989, to-restrict the tagging of material-until
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after the mater tal has been found acceptable through receipt
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inspection.
The licensee stated that their review did not identify
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any other material that was not receipt - inspected due to-l g
segregation durf ag thn time frame, so the boric acid release
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appeared to be an isalated case.
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Because the licensee identified the issue and-because the corrective 4 action had already been taken by the licensee, this violation is not being cited.. The criterf a =specified' in Section V.G.1 of the
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NRC Enforcement Policy were satisfied.
This matter will be tracked as HCV 50-327, 328/90-10-01..
No. response to this item is required and the item is considered. closed, c.
(Closed) IFI (50-'327, 328/89-16-01):
Commitment to-. Add the Acceptance. Criterion of 1 PCM/*F. Span' for Agreement : Among the.
-Measurements Used-in Determining the Average ITC
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During' an NRC inspection of Unit 2, Cycle 4 -initial criticality,Ta weakness was. noted in-startup ' procedureiRTI-4, Boron EEndpoint-Determination and Isothermal Temperature: Coeificient Neasurement.:
The pro:edure did not have acceptance criterionifor agreedent between.
the ITC measurements at ARO during heatup and cooldown. - At most.
Westinghouse plants, the -acceptance criterion is 1 pcm/ F agreement "
between the two values.
At the exit interview, the licensee.
committed to add the acceptance critorionito~the proceduree The inspector reviewed procedure RTI-4, Rev. 5,- which added: the.
requirement for the heatup and cocidown ITC measurements to agree '
with less than or equalf1 pcm/ F difference between them.
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(Closed) Violation (50-327, 328/89-16-02):
Inadequate Surveillance Procedure to Determine RCS Leakage.
During a previous'NRC inspection of the licensee'Is measurement.of RCS leakage, an inadequacy was identified in the" licensee's performance-of SI-137.2, Reactor Coolant System Inventory.L. For the test.
conducted on May 8,1989,-the total unidentified leakage resulted in a negative value.
This was accepted by the. censee withoutJ erther f
review or documented justification regarding the negative result.
Negative unidentified leakage is a physical impossibility and could be indicative of non-RCS inleakage that could obe masking the: true'
value.
The licensee response dated Junea20, 1989, was considered acceptabl.e by the NRC.
The insouctor reviewed procedure 137.2 which'was revised to include appropriate licensec. action if the caiculated unidentified leakage is determined to be negative.
The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct current conditions, and developed corrective actions needed to preclude, recurrence of similar problems. Corrective actions stated in the licensee. response have been implemented.
A Violation 50-327, 328/89-25-01,. for.
failure to follow SI-137.2 was closed by the-Resident Inspectors in NRC' Inspection Report No. 50-327, 328/90-06.
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5.
ExitInterview(30703)
The inspection scope and findings were summarized on March 9,'1990, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed ~the inspection findings listed below.
Proprietary-information is-not contained in this report:
No dissenting comments were;
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received by the licensee.
Item Number Description and Reference S0-327, 328/90-10-01 NCV --Release of Boric Acid from Power'
Stores Prior to QC Receipt Inspection, paragraph 4.b.
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Acronyms Ond Initialisms-
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d ARO - all rods out
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'CFR' - Code of Federal Regulations Li CILRT-containment integrated leak rate test CIV - containment. isolation valve
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ERCW - essential raw cooling water
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GDC - General Design Criteria l
GOI - general operating procedure IFI - inspector followup item ITC - isothermal temperature coefficient
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- maximum allowable containment leakage rate
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LLRT - local leak rate test
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LOCA - loss-of-coolant accident
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NCV - non-cited violation NRC - Nuclee-Regulatory Commission pcm - percent intilirho a
psig - pounds per square inch gauge
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- Quality Control j
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Rev. - revision RTI - refueling test instruction SCFH - standard cubic feet per hour SI
- surveillance instruction TS
- technical specifications URI - unresolved item
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