IR 05000334/1982011

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IE Insp Rept 50-334/82-11 on 820504-06 & 10-13.No Noncompliance Noted.Major Areas Inspected:Lers,Plant Mod, Containment Penetration Leakage Testing Program & Containment Integrated Leakae Rate Test
ML20054G753
Person / Time
Site: Beaver Valley
Issue date: 06/03/1982
From: Bettenhausen, Rekito W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20054G748 List:
References
50-334-82-11, NUDOCS 8206220266
Download: ML20054G753 (10)


Text

t U. S. NUCLEAR REGULATORY COMMISSION 50334-800409 50334-820206

REGION I

50334-820416 Report No. 50-334/82-11 Docket No. 50-334 License No. DPR-66 Priority Category C

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Licensee: Duquesne Lighting Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power. Station, Unit No. 1 Inspection At: Shippingport, Pennsylvania Inspection Conducted:

May 4 - 6, 10 - 13, 1982 Inspector:

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. A. Rek'ito, Reactor Inspector date Approved by:

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L. H. B ttenhausen, Chief, Test Programs date Section, Engineering Programs Branch Inspection Summary:

Inspection on May 4 - 6, 10 - 13, 1982 (Report No. 50-334/82-11)

Areas Inspected: Routine, unannounced inspection of licensee event reports, plant modification, containment penetration leakage testing program, and the containment integregated leakage rate test.

The inspection involved 51 inspector-hours on site by one region based NRC inspector.

Results: No violations were identified.

8206220266 82d6U4 PDR ADOCK 05000334 O

PDR

Details 1.

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

R. Burgundy, Supervising Engineer

K. Grada, Superintendent, Licensing

L. Hendrickson, Test Engineer B. Kuechler, Consultant - Stone and Webster Corporation

W. Lacey, Chief Engineer

F. Lipchick, Senior Compliance Engineer

R. Mafrice, Supervisor, Onsite Engineering Group

J. Maraffi, Senior Test Engineer R. Parry, Consultant - Stone and Webster Corporation

G. Ritz, Senior Project Engineer

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J. Sieber, Manager, Nuclear Safety and Licensing P. Slifkin, Station Engineering Group J. Sockaci, On-Site Engineer

J. Wade, Test Engineer H. Williams, Station Superintendent

R. Zabowski, Technical Supervisor

NRC Personnel W. Troskoski, 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 May 13, 1982.

2.

Containment Local Leakage Rate Testing (LLRT)

l 2.1 Documents Reviewed

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OST 1.47.1, Revision 48, Containment Air Lock Door (s) Type B Leak Test

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OST 1.47.4, Revision 48, Containment Isolation Valve Leakage Test, Type C

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OST 1.47.28, Revision 41, Containment Penetration #37 Valve No. 1

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CH-183, MOV-1CH-308C Type C Leak Test

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OST 1.47.58, Revision 45, Penetration #68, 69, Valve No, MOV-1SI-860 A, MOV 1S1-860B Type C Leak Test i

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i OST 1.47.90, Revision 48, Personnel Air Lock Isolation Valve

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(IVS-153) Type C Leak Test OST 1.47.92, Revision 45, Penetration 31, Valve No. 1 FP-804, TV-

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FP-105 Type C Leak Test

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OST 1.47.99, Revision 45, Penetration #109.52, Valve S0V-HY-

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014A1, SOV-HY-104A2 Type C Leak Test OST 1.47.89, Revision 48, Emergency Hatch (es), Type B Leak Test

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for Personnel Air Lock i

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OST 1.47.101, Revision 48, Equipment Hatch Air Lock Type B Test

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Station Log, Sheet C2, Types B and C Containment Leak Rate Tests

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Records of Local Leak Rate Test Activities including test results,

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l related repair and retest documentation.

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Selected system drawings, piping, and Instrumentation Diagrams i

2.2 Scope of Review I

The inspector reviewed the above documents to ascertain compliance with regulatory requirements of 10 CFR 50, Appendix J and BVPS Technical Specification (TS) 4.6.

The inspector also examined special test instrumentation, reviewed qualifications and training records of test personnel, and held discussions regarding the relationship between LLRT failure results and the Containment Integrated Leakage Rate Test (CILRT) evaluation of "AS FOUND" J

condition.

Further details and inspection findings are described below.

2.3 Test Results

The inspector reviewed the LLRT results summary and discussed analysis of test failures and status of repairs and retests with the licensee. All repairs and retests were completed prior to the start of the CILRT. The licensee submitted LER 82-06/03L describing the LLRT results which showed containment isolation valve TV-CC-105D1 exceeding the TS limit for the types B and C combined total leakage.

Subsequent to that report, the initial tests of several other CIV's resulted in excessive unacceptable leakage necessitating repairs and retest which the licensee will report in a supplement to LER 82-06.

The inspector explained that the overall containment system leakage improvements resulting from these repairs and others prior to the CILRT are expected to be added to the results of the CILRT for determination of the "AS IS" test results in accordance with 10 CFR 50, Appendix J.

The requirement was acknowledged by the licensee, and preliminary i

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evaluations of the LLRT results for this purpose appeared to be-

adequate.

2.4 Technical Specification Changes The inspector reviewed a sample of plant modifications that

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affect the primary containment boundaries to ascertain that required leakage rate tests were being done. The sample included

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the Post-Accident Sampling System, Fire Protection System, Modification of Existing Personnel Airlock and Installation of a Second Personnel i

airlock.

The review consisted of an audit of newly issued and revised test procedures, design change documentation, discusstels with licensee personnel and direct observations.

Based on this sample review, the inspector determined that the licensee is taking appropriate action to maintain containment integrity and to meet the containment testing requirements of 10 CFR 50, Appendix J.

The inspector noted that several of the modifications necessitated a change to TS Table 3.6-1.

The licensee had prepared and was in

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the process of reviewing an updated TS Table 3.6-1, and planned to submit it as a TS change request following the next scheduled ORC Meeting. The inspector stated that this matter would be

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l unresolved, pending licensee submittal and NRC approval of the TS change.

(334/82-11-01).

3.

Containment Integrated Leakage Rate Test (CILRT)

3.1 General On May 9 - 13, 1982, BVPS Unit 1 performed a CILRT as required by TS 4.6.

The test was performed in accordance with Procedure BVT 1.1-1.47.2, Revision 0.

The inspector reviewed the test procedure, witnessed preparations and various portions of the test, and

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performed independent calculations of test results.

Further details and inspection findings are described below.

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3.2 Procedure Review

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The inspector reviewed the CILRT Procedure along with documents listed in paragraph 2.1 for technical adequacy and to ascertain compliance with requirements of Technical Specifications and 10 CFR 50, Appendix J.

During this review, the inspector noted that the LTLRT procedure referenced the standard and was in general conformance with the guidance of industry standard ANSI /ANS 56.8-1981, Containment System Leakage Testing Requirements. However, the three concerns following were identified by tra inspector:

The test procedure specified the test duration to be a minimum of eight (8) hours. The inspector stated the NRC general position that CILRT durations be a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless specifically

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approved otherwise. The licensee acknowledged this position and stated that it would be complied with.

Later, during performance of the test, the~

l inspector verified that official test data was taken for a full 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This action satisfied the inspector's concern.

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Procedure Section VIII contains the test acceptance criteria.

The inspector questioned the adequacy of procedural guidance for making necessary corrections to the measured leakage rate. Using a procedure field revision, the licensee revised the test acceptance criteria to require adding type C penalties to the measured leakage rate. These type C penalties are recorded in Table 9 of the test procedure and include LLRT results for penetrations isolated and systems not properly vented and drained during the CILRT.

In addition, the licensee improved the procedure guidance for monitoring and evaluating all vessel water levels inside con-tainment for a possible change in free volume and corresponding appropriate correction to the test measured leakage rate.

Based on the above actions and the licensee's awareness of the need for these corrections, the inspector's concern was satisfied.

Attachment #4 of the test procedure describes the Mass Step Change Verification Test method. The inspector questioned the specified need to limit the amount of air injection to 120 pounds mass per hour and stated that for this type of verification test, the metered air should be added as quickly as possible.

The licensee satisfied the inspector's concern by revising the test procedure to specify injecting the metered air at the approximate rate of 240 pounds mass per hour.

3.3 Test Boundaries On a random sampling basis, the inspector reviewed the procedure valve lineups for approximately 25% of the piping penetrations.

This review was to ensure that systems were properly vented and drained to expose the CIV's to containment atmosphere and test differential pressure with no artificial leakage barriers.

No problems or unacceptable conditions were identified.

3.4 Instrumentation The inspector reviewed the calibration records for the resistance temperature detectors (RTD's), dewpoint instruments, precision pressure detectors, and verification test flowmeter. Their calibrations prior to the CILRT were found to meet applicable accuracy requirements and were traceable to the National Bureau of Standards. During a tour of the containment building, the condition of several instrument sensors was examined. The inspector also verified that the instrumentation system specified in the test procedure satisfied the instrument selection guide of ANS/ ANSI 56.8-1981.

No unacceptable conditions were identified with the instrumentation review.

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3.5 Inspection Tours The inspector conducted inspection tours independently and with licensee personnel both before and during the CILRT. During these tours, test boundaries were surveyed for evidence of leakage and, on a sampling basis, selected valves were verified to be in the correct positions according to procedure requirements. Two significant problems were discovered.

During a leakage survey, the licensee discovered a significant leak path through the IB Recirculatory Spray Heat Exchanger and out the River Water Cooling piping which was then drained of water. The River Water lines were isolated to reduce the amount of leakage.

This action was considered justified because the post-accident condition of the River Water System is filled and operating at a pressure greater than Pa which would prevent any containment atmospheric leakage through this path. The licensee explained that this system had recently been hydrostatically tested and subsequently drained. They suspected the leak path to be a vent or drain valve not fully closed and would investigate the matter as part of the test results evaluation.

One additional problem was discovered while initially pressurizing the containment. The personnel airlock became pressurized.

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cause was later determined to be inadvertant actuation of the newly installed inner door emergency access hatch equalizing valve. The outer door seal was locally tested and an entry was made into the airlock to secure the equalizing valve in the closed position.

Engineering evaluatior of this problem is

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described further in paragraph 4 of this report.

3.6 CILRT Chronology May 9

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Completed test preparations and the containment inspection 2100 Commenced pressurizing the containment Conducted leak surveys May 10

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1430 Discovered personnel airlock pressurized 1500 Completed pressurization 0 38.8 psig and started the temperature stabilization period May 11

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Continued leak surveys

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Data trend indicates excessive leakage at approxim-ately 20 pound mass loss per hou r

1600 Vented personnel airlock.

Secured the inner door equalizing valve in closed position.

No pressure buildup recognized in the personnel

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airlock May 12 0100 Data trend still indicates excessive leakage at approximately 25 pounds mass loss per hour.

0345 Discovered leak path and isolated River Water piping return lines from Recirculating Spray Heat Exchangers.

0550 Data trend indicates significant leakage rate reduction.

0905 Leakage Rate calculation computer inoperable due to loss of power supply

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1300 LR computer back in service 1620 Re-Initialized computer data acquisition and started 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test period.

2300 Data trend indicates acceptable leakage rate at approximately 0.04 per cent per day.

(Seven pounds mass loss per hour).

May 13

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Continued leak surveys.

0800 Data trend indicates acceptable leakage rate at approximately 0.034 percent per day.

1620 Completed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test period data collection.

3.7 Test Results The licensee evaluated the test results for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period starting at 16:20 hours on May 12 and ending 16:20 hours on May-13, 1982. The calculated leakage rate at the 95% upper confidence

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level was 0.0375 weight percent per day.

The test acceptance

criterion is 0.075 weight percent per day.

The inspector noted that the above calculated leakage rate included corrections for systems not properly vented and drained to simulate post-accident conditions. Additionally, this value represents I

the Containment System "AS LEFT" overall leakage. An evaluation

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of leakage improvements resulting from repairs performed prior to the CILRT is needed to determine the Containment System "AS

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FOUND" overall leakage.

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Both values are expected to be reported in the Technical Summary Report.

The inspector independently calculated several mass values and leakage rate, using raw data from the test. The results were in

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agreement with and verified the accuracy of the licensee's leak rate calculations.

4.

Personnel Airlock Modifications One of several changes made in accordance with DCP 322, Miscellaneous Airlock Modifications, was to replace the 18 inch emergency access

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doors with ones having an improved operating mechanism and adding an

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additional differential pressure equalizing line and valve. This normally closed equalizing valve represents a containment leakage boundary and is actuated by movement of the door locking pin. During the ILRT, a problem was identified with the design of the newly installed equalizing valve on the airlock inner door.

It was discovered that a containment pressure less than 38.3 psig (Pa) was sufficient to force the lock pin to slide and to open the equalizing valve between the containment and airlock space. The inspector reviewed the Design

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Change Package (DCP) and Safety Evaluation Report which erroneously concluded that these changes would not reduce the ability of the airlock to maintain containment integrity.

The licensee recognized this design inadequacy. Their engineering department was in the process of evaluating the situation to improve the design and assure containment integrity would be maintained. The Station Superintendent stated that all corrective actions would be completed prior to the next plant startup. This matter is unresolved pending licensee completion of corrective actions and NRC review.

(334/82-11-02).

5.

Review of Licensee Event Reports (LER's)

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LER 80-029/83L-1, dated January 4, 1982 (TS 4.6.3.1.2.e, Containment Isolation Valves)

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LER 82-06/03L, dated March 4, 1982 (TS 3.6.3.1, Containment Isolation Valves)

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LER 82-13/99.T, dated April 26, 1982 (TS 3.6.1.6, Containment Structural Integrity)

The inspector reviewed the LER's listed above to verify that the details of the event were clearly reported, including the accuracy of the description of the cause and the adequacy of corrective actions.

The inspector determined whether further information was required from the licensee and whether the event should be classified as an abnormal occurrence. The inspector also verified that the reporting requirements

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of Technical Specifications had been met and the appropriate corrective actions had been or are being taken.

Inspector findings are described below.

5.1 Containment Isolation Valve (CIV) Testing LER 82-06/03L identified the Type C leakage test failure of containment isolation trip valve TV-CC-105D1.

The cause was being investigated, and a follow-up report is to be submitted.

Subsequent to this test failure, Type C leakage tests of several other CIV's resulted in unacceptably high leakage necessitating corrective maintenance.

The licensee described his intentions to submit one follow-up report, including descriptions of all CIV Type C leakage test failures.

The inspector acknowledged that this approach would satisfy the TS reporting requirements. Discussions with responsible personnel and preparations for this report appeared to be adequate.

However, this LER will remain open, pending licensee submittal and NRC review of the subject report.

5.2 Containment Structural Integrity LER 82-013/99T identified the discovery of five bulges in the containment liner.

These bulges were in addition to ones previously discovered during the 1978 structural integrity inspection. The cause and significance of the bulges is being investigated by the licensee. A follow-up report, including final resolution of the problem, will be submitted. The licensee reported a probability

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l that these bulges existed but were not identified during the previous 1978 inspection. The licensee also reported that the condition of bulges previously discovered had not changed from 1978 till 1982.

The inspector reviewed inspection procedure BVT 1.1-1.47.1, Verfication of Structural Integrity of the Containment Liner and Concrete Structure, and records of the inspections conducted in 1978 and 1982. The inspector also examined a portion of the containment liner and noted the appearance of bulges in several locations other than the ones discovered by the licensee inspections.

During a meeting with licensee management and engineering personnel, the licensee explained his plan for further investigation and evaluation of this situation to be assured that no safety problem exists with the containment structural or leak tight integrity. Major points of the plan include:

(1) Revising the inspection procedure BVT 1.1-1.47.1 to include more specific acceptance criteria such as those used during construction (e.g., radial deflection of the liner shall not exceed three

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inches, and deviation from true curvature will not exceed one quarter inch in any fourteen inch arch).

(2) Upon completion of the CILRT, the liner inspection would be repeated, and all significant bulges adequately marked and accurat-ely measured so that monitoring for any change of condition could be done during future inspections.

(3) For bulges previously measured, compare new measurements to detect and analyze for acceptability any changed condition.

(4) Submit a supplement report to LER 82-13/99T describing the results of the inspection and investigation status.

(5) Conduct re-inspection of the liner during the next shutdown for refueling to track the condition and monitor any changes of liner bulges.

l The investigation plan appeared to be adequate and satisfied the inspector's concern for this LER.

However, the inspector stated that the acceptability of the liner plate bulges would receive further NRC review.

This matter is considered unresolved, pending further investigative actions by the licensee and review by the NRC.

(334/82-11-03).

6.

Facility Tours The inspector made several tours of the facility, including the control room, auxiliary building, and containment building.

During these tours, the inspector observed operations and activities in progress, implementation of radiological controls, and the general condition of safety-related equipment.

In addition, the inspector examined the containment system boundaries, component tagging, and instrumentation to support the CILRT. With the exception of the liner bulges described as an unresolved item in paragraph 5.2, no unacceptable conditions were identified.

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

Paragraphs 2.4, 4, and 5.2 contain unresolved items.

8.

Exit Interview The inspector met with licensee representatives (see detail 1 for attendees) on May 13, 1982.

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

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