IR 05000336/1986028
| ML20207P932 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/22/1986 |
| From: | Anderson C, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207P925 | List: |
| References | |
| 50-336-86-28, NUDOCS 8701200425 | |
| Download: ML20207P932 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-336/86-28 Docket No. 50-336 License No.
DPR-65 Licensee: Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06141-0270 Facility Name: Millstone Nuclear Power Station, Unit 2 Inspection At: Waterford, Connecticut Inspection Conducted: December 2 - 5, 1986 Inspector:
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/2 - 2.2 - Bd fv Clifford J. p rson, Chief date Plant ystems Section, EB Inspection Summary:
Inspection December 2 - 5, 1986 (Inspection Report No. 50-336/86-28).
Areas Inspected:
Routine unannounced inspection of test witnessing and preliminary results evaluation of local leak rate test (LLRT), follow-up of previous inspection findings and licensee commitments concerning preventive maintenance of containment isolation valves (CIV's).
Results: No violations or deviations were identified.
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DETAILS 1.0 Persons Contacted A. Andre, NNECO, QC
- R. Bates, Assistant Engineering Supervisor, MSP2 J. Heg, Unit 2 OPS Assist.
- S. Scace, Millstone Station Superintendent S. Stadnick, OPS Engineer U.S. NRC
- T. Rebelowski
- Denotes those present at exit meeting held on December 5, 1986.
2.
Licensee Action on Previous Inspection Findings (Closed) violation (50-336/85-22-01) performance of LLRT with non-cali-brated instrumentation. The inspector reviewed calibration records for the flow meters in the LLRT boxes being used this outage, (boxes 2 and 3).
The flow meters were found to be in current calibration. Also, the due date for recalibration was indicated on the calibration records. Addi-tionally, the inspector reviewed the following documentation with appro-priate revisions to avoid further violations:
(1) procedure IC 2436B
" Local Leak Rate Test (LLRT) Box Calibration" has been revised to include the calibration of the temperature gages.
(2) LLRT data sheets 2605D-3 (type C) and 2605C-2 (Type B) have been revised to include the recording of the instrument identification number and calibration due date. The inspector found the results of the licensee's action taken to be accept-able.
3.0 Local Leak Rate Testing The purpose of this inspection was to ascertain that the LLRT was conducted in compliance with the requirements and commitments referenced in the following sections, and that the test results met the acceptance criteria specified in the station procedures and Appendix J,10 CFR 50.
The procedures were reviewed for their technical adequacy to perform the intended activitie.
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3.1 References
Millstone-Unit 2 technical specifications section 4.6.
10 CFR; Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors
Final Safety Analysis Report (FSAR)
ANSI /ANS 56.8-1981, Containment Systems Leakage Testing Requirements 3.2 Documents Reviewed
2701J-73, Maintenance Form, "ILRT Valve Program", Revision 3.
- Letter to Ralph Bates from Rick Bonner dated September 5, 1986
"ILRT Valve Preventive Maintenance on Fisher T-Ring valves."
- Work orders M2-86-11974 on valve 2-AC-5 and M2-86-11975 on valve 2-AC-6 indicating the replacement of T-Ring seats.
- Work Order M2-86-11698 on valve 2-RB-28,18 and all maintenance history this outage for the valve.
- ACP-QA-2.02C " Work Orders" Administrative Control Procedure.
- ACP-QA-3.10 " Plant Design Change Request" to install screens in containment sump trough.
- SP2605C procedure " Containment Leak Test-Type B", Revision 7
SP2605D procedure " Containment Leak Test - Type C",
Revision 7.
J 3.3 Test Witnessing The inspector witnessed the performance of test activities to verify that:
approved test procedures were available and in use.
- the procedures were adequately detailed to assure satisfactory performance.
- parts and materials were properly identified.
- qualified test equipment and tools were used.
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The following tests were witnessed:
(1) Type C "As-Found" LLRT of instrument air valve No. 2-1A-27-1 outboard of penetration 37 on December 3, 1986.
(2) Type B "As-Left" LLRT of personnel air lock on December 4,1986.
Both penetrations met their test acceptance criteria.
Test personnel followed approved test procedures SP 2605D Type "C" and SP 2605E Type "B" and were competent to perform the tests. The inspector noted that an operations engineer, who was assigned to supervise LLRT activities, was present at both tests. The inspector also noted that the LLRT prerequisites do not include a check of the LLRT Box flow meter, such as by induced leak method, prior to each test. The calibration frequency of the flow meters is three (3) years.
Since the LLRT boxes may be used for numerous tests within the cali-bration frequency of the flow meter this practice provides additional assurance that the flow meter is reading properly for each test performed. This is an accepted industry practice. The inspector brought this to the attention of the licensee.
The inspector noted that LLRT Type C prerequisites include stroking the valves prior to testing.
10 CFR 50 Appendix J prohibits preli-minary exercising of valves being "As-Found" leak tested.
The licensee has identified his reasons for stroking valves as follows:
Piping systems must be drained to perform LLRT.
- To ensure normal closure, stroking by means of MOV control ensures no manual torquing has been performed.
The licensee's formal justification has been reviewed by the Region I staff and found acceptable.
3.4 Test Instrumentation Calibration records for the instruments which comprise the leak rate monitors (LRM's) were reviewed by the inspector. Calibration records for the standards used to test the LRM's were also reviewed. These records indicated that the standards were calibrated with instruments i
which are traceable to the National Bureau of Standards (NBS) and that the standards were within their calibration frequency.
The inspector noted upon reviewing the calibration records that the serial numbers of individual instruments contained in the LLRT boxes were not entered on the data sheets but identified only by LLRT box i
number. The inspector brought this to the attention of the licensee.
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The licensee then stated that the instruments could be identified by inspection of the boxes but committed to include instrument serial numbers on calibration sheets in the future.
3.5 Administrative Control The inspector interviewed selected licensee personnel and reviewed selected administrative procedures to verify the adequacy of the maintenance activities involving containment isolation valves (CIV's) and containment penetrations. Additionally, a control document pertaining to maintenance was reviewed as well as the maintenance history for the current outage of selected CIV's.
Administrative control of maintenance appears orderly and well established.
No unacceptable conditions were identified.
3.6 Test Results Local leak rate testing was in progress at the time of the inspec-tion, therefore a final "As-Left" local leak rate total was not available.
The total "As-Found" local leak rate was unquantifiable due to several penetration leakages which failed "off scale" of the LRM. Any one unquantifiable high penetration leakage constitutes a failure to meet LLRT acceptance criteria per 10 CFR 50, Appendix J and MS-2 techni-cal specifications. This describes a potential loss of minimally acceptable containment integrity for the previous operating cycle.
The issue will be addressed by NNECO as the subject of an LER pursuant to 10 CFR 50.73, " Licensee Event Report System".
It is being rectified by actions being taken on previous licensee commit-ments to improve preventive maintenance (PM), see Section 4.0.
The inspector noted that the LLRT results were documented in an organized manner and in accordance with the established procedure.
Information concerning the LLRT of each individual CIV or penetration is contained in a package of several data sheets. An LLRT running total is recorded such that "As-Found" and "As-Left" results are easily distinguishable.
The inspector determined that the licensee is calculating the maxi-mum pathway leakage for test results to be applied in the determi-nation of the total local leak rate. This is the accepted method per 10 CFR 50, Appendix J.
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4.
Licensee Action on Previous Commitments The licensee attended a meeting with the Division of Reactor Safety and NRR at Region I on June 4,1986 to discuss the proposed schedule for Type
"A" containment leak rate testing.
It was determfined by the NRR Division
- of PWR Licensing - B that the proposed schedule for Type A testing was acceptable if the following four conditions were met.
That a preventive maintenance program for Fisher valves be initiated to include replacement of the T-ring gaskets;
That traps or screens be provided to prevent debris from entering the sump valve's seat area; That local Leak Rate Tests (LLRT) for identified " problem" valves be conducted;
That NRC Region I be notified of any Type B and/or Type C test results which indicate excessive leakage.
The inspector reviewed maintenance form 2701J-73 Revision 3, dated October 1, 1986 "ILRT Valve Program" which addresses preventive maintenance of (20) Fisher valves. As committed to, the maintenance form indicates the subject valves (Identified by the licensee as problem leakers) will have their gaskets replaced every other refueling outage.
The PM program places the valves on an even - odd schedule such that one half of the valves will receive replacement gaskets on even numbered refuel-ing outages and the ether half on odd numbered refueling outages. The maintenance form reads in part, " Replace seats even if they appear satis-factory". Also as committed to, the valves are scheduled for maintenance such that penetrations which have two valves in series will have one of the two valves overhauled each outage. This will ensure that each pene-tration has at least one valve with a new seat at the beginning of each cycle. This meets the licensee's commitment to PM for the valves in the future.
The inspector reviewed documentation addressing the licensee's commitment to replace all T-rings during the 1986 refueling outage. This work was almost complete as of the time of the inspection. The inspector verified that LLRT's were being conducted for the identified " problem" valves and that Region I has been informed this outage, through the office of the resident inspector, of valves which have indicated excessive leakage. The inspector verified, through a review of the appropriate documentation (plant design change request, purchase order, safety evaluation, etc.. ),
that screens will be installed in the containment sump troughs. This meets the licensee's commitment to provide means to prevent debris from entering the sump valves seat are _
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The above program meets the licensee's commitments.
No unacceptable conditions were identified.
5.0 QA/QC The inspector discussed coverage of LLRT with representatives from both the QA and QC organizations.
It was determined that QA has a good audit-ing_ technique in place for monitoring maintenance activities and that some audits involved valve work.
The inspector questioned the adequacy of QA and QC direct involvement in monitoring the overall LLRT program. The inspector brought this to the attention of the licensee. They agreed to provide the NRC additional information at a future date, to support the adequacy of QA and QC involvement in the LLRT program. This issue is an unresolved item (50-336/86-28-1) pending NRC review of QA/QC activities in this program.
6.0 Exit Meeting Licensee management was informed of the purpose and scope of the inspection at the entrance interview. The findings of the inspection were periodically discussed and were summarized at the exit meeting on December 5, 1986.
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 licensee by the inspectors.
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