IR 05000333/1987008
| ML20206D842 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/28/1987 |
| From: | Anderson C, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206D818 | List: |
| References | |
| 50-333-87-08, 50-333-87-8, NUDOCS 8704130440 | |
| Download: ML20206D842 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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. REGION I Report No. 87-08
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Docket No.
50-333 License No. DPR-59 Licensee: Power Authority of the State of New York P. O. Box 41 Lycoming, New York 13093 Facility Name: James A. FitzPatrick Nuclear Power Plant Inspection At: Scriba, New York
Inspection Conducted:
February 24-27, 1987 Inspectors:
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J cJ / <f7 pph VGolla, Reac Engineer date
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Approved by:
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CliffoMjJ.A4derson, Chief date Plant Systems Section, EB Inspection Summary:
Inspection February 24-27, 1987 (Inspection Report No.
50-333/87-08).
Areas Inspected: Routine announced inspection of local leak rate test program and licensee preventive maintenance activities with resot:t to containment integrated leak rate testing.
Results: No violations or deviations were identified.
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DETAILS 1.0 Persons Contacted
- R. Baker, Maintenance Superintendent l
- R. Converse, Resident Manager l
- W. Fernandez, Superintendent of Power W. Hendrick, Nuclear Control Room Operator
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. L. Johnston, QA Supervisor
- D. Lindsey, Operations Superintendent
- R. Patch, QA Superintendent l
T. Pelton, Assistant Shift Supervisor j
- P. Swinburne, Performance Engineer l
D. Torbitt, Assistant Shift Supervisor
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V. Walz, Technical Services Superintendent R. Wiese, Assistant Maintenance Superintendent
- Indicates those present at the exit meeting held February 27, 1987.
2.0 Local Leak Rate Testing (LLRT)
2.1 General The purpose of the inspection in this area was to ascertain that the LLRT is being administered adequately and conducted in compliance with the requirements and commitments referenced in the following sections. The LLRT procedure was reviewed for its technical adequacy to perform the intended activities. Other record keeping and LLRT related documentation was reviewed to determine the adequacy of overall administrative control of the local leak rate test program.
2.2 References 1.
James A. FitzPatrick Nuclear Power Plant Technical Specifica-tions Section 4.7.
2.
10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors.
3.
Letter from R. J. Converse to the Of rector of Nuclear Reactor Regulation dated January 21, 1987 concerning Containment Integrated Leak Rate Test Schedule.
2.3 Documents Reviewed
Operations Surveillance Test Procedure No. F-ST-39B, " Type B and C, LLRT of Containment Penetrations" Revision No. 16.
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Procedure No. PS0 31, "IST Program for Pumps and Valves" Revision No. 4.
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Procedure No. MP-59.5, "Atkomatic Solenoid Valve Maintenance"
Revision No. 2.
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Work Tracking Documentation for Containment Isolation Valve
Nos. 27 S0V 135A, 135B.
Instrument calibration records for LLRT panels.
- Memorandum from P. Swinburne to W. Fernandez dated February 19, 1987 concerning containment isolation valves proposed for replacement due to "as-found" ILRT failure.
Memorandum from R. Wiese to W. Fernandez dated February 25,
1987 concerning valves proposed for replacement.
2.4 Administrative Control of LLRT The inspector interviewed selected licensee personnel and reviewed administrative documents. The adequacy of administrative control over local leak rate testing was evaluated by an audit in the following areas:
1.
Local Leak Rate Test Procedure This procedure was-found to be technically correct to perform LLRT utilizing the mass flow in method.
Test data sheets provide for the inclusion of pertinent data such as test pressure and flow rate. Also included is pertinent information of an administrative nature such as test panel used, leakage conversion information and test date.
The inspector noted that the procedure provided for a LLRT panel-operational test prior to usage. The operational test provides assurance that the test pane.1 is reading correctly.
This is an accepted industry practice.
It was determined by the inspector that for test leakage flow rates smaller than the lowest reading on scale the licensee records the leakage as the first on scale reading. This administrative practice is conservative and therefore acceptable.
2.
Recording of Penetration Leakage The LLRT procedure contains data sheets with which penetration leakages are properly determined and recorded.
The data sheets provide instructions for calculating penetration leakage based on the specific configuration of the piping / valve network for each penetration. The data sheets also contain instructions for computing additive local leakage from all penetrations
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resulting in "as-found" and "as-left" totals.
The inspector
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determined that LLRT Supervisors are responsible for data evaluation.
3.
Assignment of Individual Acceptance Criteria The inspector reviewed a document (Procedure No. PS0 31)
concerning IST for pumps and valves. The document establishes administrative guidelines for data gathering and evaluation of readiness of pumps and valves. The documents include individual leakage limits for each valve and the action required for valves with demonstrated leakage above their limit. The inspector determined that the document is a good administrative tool for-maintaining a minimum level of leak tight integrity for individual valves. The rule contained in 10 CFR 50, Appendix J pertains only to a minimum acceptability for total leakage through all containment isolation valves (CIV's). The Administrative Guidelines provided represent an initiative by the licensee above the requirements.
e 4.
Valve Maintenance The inspector reviewed several work tracking documents for CIV's receiving maintenance. All documentation reviewed was orderly.
The various work request forms, work tracking forms, and main-tenance procedures provided for thorough administrative control of valve maintenance. No unacceptable conditions were' identified.
2.5 Test Witnessing The inspector witnessed the performance of test activities to verify that:
Test technicians followed the procedure.
The procedure was adequately detailed to assure satisfactory performance.
- Qualified test equipment and tools were used.
The following test was witnessed:
Type B "as-found" LLRT of CRD removal hatch seal on February 26, 1987.
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The hatch seal leakage, measured less than the lowest on scale f'
reading.
It was recorded by the test technician as less than 2 sccm.
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The test technician followed approved Test Procedure No. F-ST-398.
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No unacceptable conditions were identified.
2.6 Test Instrumentetton Calibration records for the instruments which comprise the leak rate.
tr.st panels were reviewed by the inspector. Calibration records for the standards used were also reviewed.
These records indicated that v
the standards were calibrated with instruments which are traceable to the National Bureau of Standards (NBS) and that the standards were i
within their rpquired calibration frequency.
It was determined by
the inspector,that panel No. IC-210 was in calibration as of the test date.
It was also determined, through a discussion with I&C personnel t and a documentation review, that the I&C Department alerts LLRT persontel (Operations Department) of icpending recalibration due dates.' This information is supplied to I&C through a computer listing approximately every two weeks which projects instrument calibration dates ils months ahead.
The I&C Department then impounds the equipment until recalibration is performed. No unacceptable conditions were identified.
2.7 Test Results The local leak rate testing of all valves and penetrations was not
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ccmplete at the time of the inspection, therefore a final "as-left" local leak rate was not available.
However, it was determined that
' Me total "as-found" local leakage has not met the acceptance criteria of less than.6L,.
This was due mainly to excessive leakage through the drywell inerting and purge system penetration X31AD. The
leakage, for this penetration alone measured 11,757.9 scfd. This is i
greater than the.6L, criteria for total leakage through all contain-ment penetrations. The licensee has acknowledged the failure and has written an LER on the subject.
In Series Containment Isolation Valve
Nos. 27 SOV 135A, and 135B contributed to the penetration le dage.
They have been repaired. The NRC evaluation of the final LLRT
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results will be performed in a followup inspection.
3.0 Personnel Training and Qualificatiqn The Qualification and training of selected test personnel were discussed
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with a licensee representative.
In addition the inspector evaluated the
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performance of test technicians during witnessing of the LLRT. The
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inspector determined that the test technicians qualifications met the i
requirements specified in ANSI N18.1-1971 " Selection and training of nuclear power plant personnel".
No unacceptable conditions were identified.
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4.0 QA/QC
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The inspector discussed coverage of local leak rate testing with QA repre-sentatives and reviewed QA surveillance reports.
It was determined tha't.
QA provides coverage of a small sample of LLRT's and that QA findings andeo evaluations are well documented. However, it was determined that Q14does not evaluate overall LLRT program adequacy.
The inspector discussed with-the licensee the safety significance of the containment isolation boundary and the need for increased QA attention to the overall effectiveness of
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the LLRT program. The licensee agreed with the inspectors observation and committed to performed an "LLRT Program Effectiveness Audit." The inspector had no further questions.
5.0 Containment Integrated Leak Rate Testing (CILRT)
5.1 Background
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Based on apparent uncertainty concerning the pass / fail status of the licensee's last two CILRTs, and therefore the possible requirement for the licensee to perform a CILRT this outage, a teleconference was held with NRC Region I staff and licensee management on December 9, 1986. As a result of this telecon the staff expressed their view that that the JAFNPP containment had failed the "as-found" portion of the May 1985 CILRT but that the status of the February 1982 CILRT remained questionable. The licensee agreed to provide a proposed schedule for subsequent Type A tests for review by the Commission.
The licensee also agreed to provide information concerning the licensee's program to improve containment valves and penetration
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leakage for NRC review tr support the proposed test schedule.
In a letter to the NRC dated January 21, 1987 the licensee provided the information discussed above. Their proposed schedule of subsequent testing did not include a CILRT this outage.
This portion of the inspection was therefera dedicated to evaluating the adequacy of their containment e 5 e and penetration program to determine if the proposed schedule was. :Sptable.
5.2 Evaluation of Programmatic Improvements The letter describing containment boundary improvements cited several initiatives taken since 1980.
These included the purchase of a special Rockwell MSIV seat machining tool and plant and valve maintenance training for maintenance personnel. Additionally, an upgraded valve maintenance and repair program was initiated. These efforts while positive in nature were insufficient to assure that CIV leakage through the next operating cycle would be low enough to pass the "as-found" CILRT acceptance criteria. More recent efforts cited in the letter
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include modifications for several penetrations which have had problems I
with "as-found" leakage.
For example, several penetrations have been cut and capped thereby removing the problem leakers. Other modifications include adding solenoid operated valves (SOVs) for-the recirculation
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pump seal " mini purge" penetrations X-31AC and X-31BC (this was verified by the inspector), and plans for replacement of containment atmosphere sampling system valves next outage.
The inspector questioned the licensee as to whether efforts to identify historically problematic high leakage valves have been undertaken. The licensee has made efforts in this area. The results
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indicate approximately 51 valves which have failed local leak rate testing repeatedly over the last 3 to 5 operating cycles. The
inspector questioned the licensee concerning their plans regarding the identified problematic valves.
The licensee indicated that efforts might be taken the next outage to assign a systems engineer
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with the responsibility of developing a program for Local Leak Rate Test Failure Analysis. The inspector had no further questions.
5.3 Evaluation of Previous CILRTs The inspector reviewed the Summary Technical Reports for the February 1982 and May 1985 Type A tests. The inspector also reviewed NRC Region I Inspection Report Nos. 82-04 and 85-15 covering the 1982 and 1985 Type A tests, respectively. Both inspection reports indicate that the licensee was informed of the need to determine an "as-found" containment integrated leak rate.
In both cases the calculated minimum pathway add on leakage from containment penetration brings the "as-found" Type A total above the acceptance criteria. Based on
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the above, the inspector concluded that the JAFNPP containment has
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failed two consecutive Type A tests. The inspector brought this to the attention of the licensee.
5.4 Conclusion The inspector informed the licensee of the following conclusion:
Based on the position that the containment has failed the last 2 consecutive Type A tests, and the result of the inspectors evaluation of programmatic improvements, it is concluded that a Type A test of the JAFNPP containment is required this outage.
This requirement is based on 10 CFR 50, Appendix J, Section III.A.6(b)
which states in part, "If two consecutive periodic Type A tests fail to meet the applicable acceptance criteria, a Type A test shall be performed at each plant shutdown for refueling, until two consecutive Type A tests meet the acceptance criteria." Based on this rule a Type A test will also be required after the next operating cycle.
The inspector informed the licensee that a formal exemption request may, be filed with the NRC requesting an exception to Type A testing next outage.
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- 6.0 Exit Meeting Licensee management was informed of the purpose and scope of the
' inspection at the entra.nce interview. The findings of the inspection were periodically discussed and were summarized at the exit meeting on February 27, 1987.
Attendees at the exit meeting are listed in Section 1.0 of this report.
At no time during the inspection was written material provided to the
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licensee by the inspector, i
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