IR 05000333/1982004

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IE Insp Rept 50-333/82-04 on 820208-12.No Noncompliance Noted.Major Areas Inspected:Primary Containment Leak Rate Testing & Licensee Action on Previous Insp Findings
ML20042B658
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 03/04/1982
From: Bettenhausen L, Rekito W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20042B655 List:
References
50-333-82-04, 50-333-82-4, NUDOCS 8203250493
Download: ML20042B658 (6)


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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

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Region I Report No. 50-333/82-04 Docket No. 50-333

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License No. DPR-59 Priority

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Category C

Licensee: Power Authority of the State of New York P. O. Box 41 Lycoming, New York 19093 Facility Name: James A. FitzPatrick Nuclear Power Plant Inspection at: Scriba, New York Inspection conducted:

February 8-12/s19S2 Inspector:

d - Y-M W. A. Rekito, Rea'ctor Inspector date signed Approved by:

N M M <r 3/8h L. H. Bettenhausen, Chief, Test Program date signed Section, Engineering Inspection Branch Inspection Summary:

Inspection on February 8-12, 1982 (Report No. 50-333/82-04)

Areas Inspected:

Routine, unannounced inspection of primary containment-leak rate testing and licensee action on previous inspection findings. The inspection involved 34 inspector-hours onsite by one region based inspector.

Results:

No violations or deviations were identified.

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8203250493 820309 PDR ADOCK 05000333-G PDR

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DETAILS 1.

Persons Contacted The below listed technical and supervisory personnel were contacted.

  • J. Busa, Consultant, Stone & Webster Corporation
  • V. Childs, Assistant to Resident Manager
  • R. Converse, Operating Superintendent M. Curling, Plant Performance & Reliability Supervisor
  • T. Dougherty, Operations Engineer
  • W. Fernandez, Technical Services Superintendent
  • H. Keith, I & C Superintendent
  • C. McNeill, Resident Manager
  • R. Parry, Consultant, Stone & Webster Corporation
  • P. Swinburne, Shift Technical Advisor NRC Personnel L. Doerflein, Resident Inspector J. Linville, Resident Inspector The inspector also talked with and interviewed other licensee personnel during the inspection.

They included members of the operating and technical staffs.

  • denotes those present at the exit interview on February 12, 1982.

2.

Licensee Action on Previous Inspection Findings (OPEN) Unresolved Items 333/79-03-01 thru 05.

Inadequacies of the Inservice Inspection Program (ISI) for testing pumps and valves.

The inspector reviewed the licensee's current inservice inspection program description for testing pumps and valves and held discussions with personnel responsible for developing and implementing this program.

Discussions included various methods of meeting test requirements and certain technical justifications for not meeting specific test requirements which are acceptable to the NRC.

The inspector also reviewed PASNY QA Audit No. 380 which revealed that many of the ISI pump and valve testing requirements were not being implemented.

The audit finding response committed to correcting the identified problems and being in full compliance with the ISI program by March 1, 1982.

The inspector reviewed proposed changes to five ISI surveillance test procedures which appeared to satisfy the audit findings and test requirements.

These items will remain open pending full implementation of the licensees corrective action plan and more through review by the NRC during a subsequent inspection.

(OPEN) Unresolved Item 333/77-32-04:

Procedure F-ST-39B still does not require the MSIV leakage test results to be converted to a test pressure of

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P before including it in the Type B & C combined total. The inspector v$rified that, with this converted leakage value, the Type B & C combined total was well within the allowable limit. The inspector also explained that this practice was an industry wide standard and required by 10 CFR 50 Appendix J.

The Resident Manager stated that the matter would be reviewed and resolved by April 1, 1982.

This item will remain open pending licensee's

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actions and NRC review.

3.

Containment Local Leak Rate Testing a.

Documents Reviewed Procedure F-ST-398, Revision 9, Type B & C, LLRT of Containment

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Boundaries.

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Records of local leak rate testing activities including test results and related repair documentation.

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LER 81-078-03L-0. dated November 24, 1981 - LLRT failures of valve 27-A0V-114.

Selected system operating procedures and drawings (P& ids)

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b.

Scope of Review The inspector reviewed the above documents to ascertain compliance with regulatory requirements of 10 CFR 50 Appendix J and Technical Specifications.

The inspector also witnessed selected LLRT activities and held discussions regarding the relationship between LLRT failure results and the Primary Containment Integrated Leak Rate Test (PCILRT)

evaluation of "AS FOUND" condition.

Further details and inspection

findings are described below.

c.

Test Witnessing On February 9, 1982, the inspector witnessed a type B test of the Torus Access Hatch (Penetration X-200 A). The test was conducted in accordance with the approved procedure and the results were acceptable.

Additionally, the inspector observed that the test instruments were properly calibrated and the test personnel appeared to be knowledgeable of the procedure and suitable qualified.

No unacceptable conditions were identified.

d.

Test Results The inspector reviewed the LLRT Results Summary and discussed analysis of test failures and status of repairs and retests with the licensee.

Several significant problems were encountered.

The initial tests of five penetrations (Drywell Purge Supply and Exhaust X-25, 26A, 26B, 71, and Drywell Service Air Supply X-21) resulted in excessive unaccept-

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able leakage past both redundant boundaries. The inspector noted that this problem was of particular importance because it represented the

"AS FOUND" state of the primary containment system to be in excess of the Technical Specification allowable leak rate limit.,The inspector also explained that the overall primary containment system leakage improvements resulting from repairs of these penetrations and others prior to the PCILRT are expected to be added to the results of the PCILRT for determination of the "AS IS" test results in accordance with 10 CFR 50 Appendix J.

This requirement was acknowledged by the licensee and preliminary evaluations of LLRT results for this purpose appeared to be adequate.

e.

Reportability In reviewing LER 81-078 the inspector noted that the LER incorrectly stated that only one isolation valve of the drywell purge exhaust line was found with leakage that exceeded the TS limit of.60 L *

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addition the LER stated that details concerning any future LLRT failures would be provided with the PCILRT Report. The inspector stated that this additional information should also be included in an LER update upon completion of the LLRT program and noted that this subject was previously addressed during NRC Inspection 78-22.

The licensee acknowledged the need and comitted to correct the error noted and to provide an LER update with more complete information.

The inspector stated that the licensee's commitment appeared acceptable and that this matter would receive further review after receipt of the LER update.

(333/82-04-01)

4.

Plant Modifications Affecting Primary Containment Integrity Modification F1-80-16, H.R. Containment Rad Monitors.

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Modification F1-80-20, H Monitoring Systems.

Modification F1-80-28, Drywell Purge and Vent line.

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The inspector reviewed the above modifications to ascertain that required containment leak rate tests were being performed, related procedures and drawings were updated and that adequate controls were in place to assure maintenance of primary containment integrity. The licensee explained that the Hydrogen Monitoring System modification would not be completed during the current outage and that the ten newly installed containment boundary valves would be lock-wired shut for administrative control. This was accomplished by temporary change to procedure F-0P-37.

The licensee also reoorted that appropriate TS change requests were being prepared for the other completed modifications.

During this review the inspector identified no unacceptable conditions and had no further questions in this area.

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5.

Primary Containment Integrated Leak Rate Test (PCILRT)

a.

Documents Reviewed Procedure F-ST-39F, Revision 2, Type "A" Test (60 PSIA) Primary

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Containment Integrated Leak Rate Test.

Selected Drawings (System P& ids)

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JAFNPP Technical Specification 4.7 and associated Bases.

JAFNNP FSAR 5.2.4, Primary Containment System.

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Safety Evaluation Report, dated November 20, 1972

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ANSI /ANS-56.8 - 1981, Containment System Leakage Testing Require-

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ments.

b.

Scope of Review

The inspector reviewed the PCILRT procedure to ascertain compliance with regulatory requirements and held discussions with the licensee concerning plans and preparations in progress for the PCILRT. During this review the inspector noted that the PCILRT procedure referenced and was in general conformance with the-guidance of ANSI /ANS 56.8.

Further details and inspection findings are described below.

c.

Acceptance Criteria

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The inspector questioned the adequacy of the procedural guidance 1)

for making all necessary corrections to the measured leak rate.

The license satisfied the inspectors' concern by initiating a temporary procedure change which specifically included corrections for:

1) systems not properly vented and drained and 2) penetrations isolated during the_ test.

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The inspector noted that the test acceptance criteria of 0.5

%/ day was greater thaa the value of 0.375 %/ day used during the preoperational and 1978 PCILRT.

It was determined that the current acceptance criteria satisfies 10 CFR 50 Appendix J and the Technical Specifications. The smaller value previously used was based on a conservative assumption that the maximum overall allowable leakage (L ) was 0.5 %/ day, as opposed to 1.5 %/ day as specifiedintheTS$asesandFSAR.

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Further examination of the FSAR and NRC independent accident analysis performed in 1972 revealed discrepancies in assumed t

values for L and results of the LOCA analysis dose calculations.

Theinspectofverifiedthatbothcalculationresultssatisfied the limits specified in 10 CFR 100. However the inspector informed

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the licensee that this matter would receive further NRC review.

Based on the above discrepancies and the fact that the PCILRT acceptance criteria and value for L specified in the JAFNPP TS, differsfromthecurrentBWRStandafdTS,thisissueisconsidered unresolved pending the outcome of the further NRC review.

(333/82-04-02)

d.

Instrumentation The inspector verified that the instrumentation system specified in the test procedure satisfied the instrument selection guide of ANSI /ANS 56.8.

The inspector also reviewed the calibration records for the test resistance temperature detectors (RTDs), dewcells, and pressure instruments to verify required accuracies and traceability to nationally recognized standards.

6.

Facility Tours The inspector made several tours of the facility to observe activities in progress and the general condition of primary containment boundaries.

Specific observations included implementation of equipment tagging and radiological controls during testing, maintenance and selected modification work. No unacceptable conditions were identified.

7.

Unresolved Items Items about which more information is required to determine acceptability are considered unresolved.

Paragraphs 2 and 5.c of this report contain unresolved items.

8.

Exit Interivew The inspector met with licensee representatives (see Detail 1 for attendees)

at the conclusion of the inspection on February 12, 1982.

The inspector summarized the scope and findings of the inspection e.t that time.