IR 05000338/1987033
| ML20236R798 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/17/1987 |
| From: | Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236R793 | List: |
| References | |
| 50-338-87-33, 50-339-87-33, NUDOCS 8711240033 | |
| Download: ML20236R798 (7) | |
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@ Riou UNITED STATES '
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NUCLEAR REGULATORY COMMISSION g
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REGION 11 n
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- 101 MARIETTA STREET.N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.: 50-338/87-33 and 50-339/87-33
.i Licensee: Virginia Electric and Power Company
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Richmond, VA 23261
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I Docket Nos.:
50-338 and 50-339'
License Nos.:
NPF-4 and NPF-7-
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Facility Name:
North Anna 1 and 2 Inspection Conducted:
September 28 October 2, 1987-Inspector: N I //l /[o,f./
// - / d" l'7 ff. ' L. Whi te n b r Date Signed
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Approved by:
F. Jape, Chief (/
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Date Signed'
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Test Programs Section Division of Reactor Safety SUMMARY-Scope: This routine, unannounced inspection was in the areas of review of the-containment isolation system local leak rate program including review of. test procedures, valve alignments and observation of; testing.
-l Results:
No violations or deviations were identified.
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-j 8711240033 871119 i
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REPORT DETAILS ~
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Persons Contacted
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Licensee Employees
~*E. W. Harrell,LStation Manager
- G. E. Kane, Assistant Station Manager
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- M. L. Bowling, Assistant. Station Manager, Nuclear Safety and Licensing
- J. A. Stall, Superintendent, Technical Services-
- 0. A. Heacock,-Supervisor, Surveillance and Test Engineering
- P. A. Pendergast, Surveillance and Test Engineer i
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- G. Harkness, Lice'nsing Coordinator J. Leberstein, Licensing Engineer L. Lane, Controi Room Operator NRC Resident Inspectors
- J. Caldwell, Senior Resident Inspector L. King, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on October 2,1987, withL those persons indicated in paragraph.1' above. -The inspector described the areas inspected and discussed in detail.the inspection findings.
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dissenting comments were received from the licensee.
d The following new items were identified during this inspection:
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a.
Inspector Followup Item 338/87-33-01.and 339/87-33-01:
Review licensee's evaluation of the use of the. vendor rotameter calibration l
correction factor for deviation of 45'psig (Paragraph 5.b.-).
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Unresolved Item 338/87-33-02 and 339/87-33-02:
Review ' licensee's
l evaluation of reverse testing. of containment. isolation valves.
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(Paragraph 5.b.).
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c.
Unresolved Item 338/87-33-03 and 339/87-33-03:
Review licensee's evaluation of potential leakage through the bypass line on~the leak
rate test rig (Paragraph 5.c.),
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The licensee did not identify as proprietary any of the. materials provided; to or reviewed by the inspector during this inspection.
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Licensee Action 'on Previous' Enforcement' Matters This subject.was not addressed'in the inspection.
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Unresolved Items
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Unresolved items are. matters about which more.iriformation is required to ~
l determine whether. they are acceptable ~ or may ' involve : violations or-l deviations.
Two unresolved items related to ~ each unit 'and: identified-
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during this inspection are discussed in paragraphs.5.b. and 5.c.
5.
Containment Local. Leak Rate Test Program Units 1 and 2 (61720)
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-1 a.
plant Procedures-The inspector reviewed the overall local.. leakage -rate program : for.-
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North Anna to verify that procedures 1 have been - developed :and
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implemented consistent with the regulatory requirements.
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reviewed either totally, or in part, included:
(1)
2-PT-61.3.4, " Total Leak Rate Calculation" The procedure establishes the controls for tracking and summing.
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the individual Type.B and ~C local ' leak rate tests to verify that
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leakage is within the. limit.
(2)
2-PT-61.2.3, " Containment Type B Test - Equipment Hatch"'
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(3)
2-PT-61.2.1, " Containment Type B. Test - Electrical Penetrations" l
(4)
2-PT-61.2.2, " Containment Type B Test - Fuel Transfer-Tube" (5)
2-PT-61.3.2, " Containment Purge Valves Type C Test - As Found" (6)
2-PT-61.3.3, " Containment-Purge Valves Type C Test - As Lef t
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2-PT-61.1, " Containment-Airlocks - Leakage Rate" The procedure specifies the instructions for the. full press'ure test of the airlocks.
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2-PT-61.3, " Containment Type C Test"
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Based on the review of portions of the 'above procedures ona : sampling -
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basis, the inspector concluded that the licensee has developed 4 and
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implemented procedures which address the essential' elements--of-the -
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local leak rate test regulatory-requirements.
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b.
Comments'On' Test Procedures During the procedure review, some concerns L were. identified and discussed with the licensee.
These items do' not affect the above
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conclusion that the local. leak rate test program.is defined, buti relate more to test. methods.
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2-PT-61.3.2, " Containment Purge Valves Type C Testi"As found" In ' this' procedure, and. several' other. test procedures, : the.
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inspector identified anomalous statements: relating "to' the-
.j calibration of. flow meters as follows:-
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"Whenever possible, use a rotameter that was calibrated at 45:
psig when testing by the make up method. When-.possible,- usef a
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rotameter that was calibrated. at 14.7 psia whe'n testing.by the.
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leak through method-If..a. rotameter must.be used at a' pressure
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other than its calibration pressure, multiply the indicated:
y reading by the appropriate correction factor. gi'en; in
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Attachment 6.4.
Show the calculation in theLremarks section-and
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record the corrected leak rate."
j The correction. factor referenced above is.prov'ided'in the vendor
manual as follows:
l F = F IPt.x Tcl 1/2 lPc Ttj
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Where:
i F'is'the corrected flow.
Fo is the indicated flow on the rotameter calibrated scale.
P is.the test absolute pressure.
t P is the instrument calibration absolute pressure,:
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T is the ins _trument calibration temperature ( R).
c T is the test temperature ( R).
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The NRC would normally expect a test p'rocedure to; specify that l
l the instruments to be usedm are calibrated. for the appropriate-test conditions.
The concern is ' that the correction? factor,.
which is acceptable for minimal differences from'.the calibrated-conditions, may introduce. an -error when used to ' correct
differences of the order of 45-psi. If an error is introduced, l
the measure of flow could-be. outside ' of-the 2% < accuracy specified for instrument calibration.
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- i; At the exit interview, licensee management agreed to verify the.
validity of the correction factor, for the flow instruments.and; range of pressures specified in the test' procedure'with the flow meter vendor.
This matter is identified as:
Inspector Followup Item (338/87-33-01 and s 339/87-33-01):
Review the evaluation for, using the rotameter correction.
factor in the vendor's manual for,the' range of-pressure specified in the Type B and C leak rate. test 1 procedures.
(2)
2-PT-61.3, " Containment Type C. Test"
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The inspector reviewed a small sample of. the. valve alignments
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.for Type C testing'and determined that:in some_ cases,;where both.
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isolation valves were L located outside L containment,.the local.
test was performed by; presurrizing ;between 'the valves.
This-results in testing the inner valve.in~the reverse (non-accident).
direction.
Discussion with the lice'nsee indicated thatL some of:
j these' valves were globe - or_ gate = valves which arei not"normally
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considered conservative when tested -in the. reverse direction.
Sufficient detailed. information on: which - to evaluate 'the conservatism of these tests. was : not' available-.in the' test -
procedure. At the exit interview,.the licensee? agreed to review the test valve alignments to. identify the ' valves-. tested in the.
reverse direction; the type. of Evalves; and/ the in.line j
orientation of the seat, packing Land bonnet ' seals.
This-
,j evaluation along with the. justification for considerin'g the
tests conservative will tue provided to.the NRC' for review. In a subsequent telephene call between Plant Management and.
Region II, October 9, 1987,Lthe 1,1censee further agreed that any
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valves identified with untested boundaries, such asi packing,
would be properly tested prior'to startup'of either Unit 1 or 2.
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This matter was identified as:
Unresolved Item (338/87-33-02 and. 339/87-33-02):. Review-
licensee's evaluation. for reverse testing sof containment isolation valves.
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Observations-The inspector witnessed the Type C test on Penetration'No. 89, Air
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Ejector Vent. The test was conducted in~accordance with'an. approved;
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procedure which was present at the test' site..When this test failed-to meet the leaksge limit, the test? personnel processed work. requests;
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to have the penetration. repaired.
The ' maintenance procedure-d contained instructions that subsequent to maintenance aclocal leak.
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rate test must be performed.
Control of pre-and post-maintenance =
leak rate testing is discussed further;in paragraph 6.b.
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During the test, the inspector observed that ' leak - rate. test ' rig
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utilized a bypass' line. which bypasses othe flow meters for rapid pressurization of the test volume.
Isolation.of the. bypass line during.a test is provided by. an air admission valve which is not-routinely checked for leak tight isolation ~ of' the. bypass line.
If-the air admission ' valve leaks,. the, potential exists for make-up air g
flew to the test volume 'which is; not detected by the flow meters.
At the exit' interview,- licensee management agreed to ' verify that there is no bypass leakage in' the air admission valve of'the test. rig which will affect previous test results and to. establish a' positive
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method for ensuring isolation of the bypass line.
This matter was identified as:
J Unresolved ' Item '(338/87-33-03 'and' 339/87-33-03):-
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. Review-
.l licensee's verification that previous Type B and C test results
are acceptable-and action takenLto ensure that_no bypass leakage
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can occur.
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Test Results The controlling procedure for local-leak rate testing, PT-61.3.4 requires that a leak rate logbook will be maintained which confirms and updates the containment. leakage status. Only Type.B and C leak rate measurements related to the--0.6 La limit - are recorded in this-log.
Review of the log showed that Type B and C; testing. since the j
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integrated leak rate tests in 1984 had been performed'at the required j
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more than one half of the allowable-leakage.
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6.
Additional Leak Rate Areas Reviewed a.
Type A Leak Rate Test l
The Safety Evaluation Report (SER), Supplements to the ' SER, and portions of Chapter 6 of the-updated. FSAR (UFSAR) we're' reviewed. to i
identify any exemptions to Appendix'J-and the isolation l boundary requirements for the integrated leak rate- (Type A) te s t -. 'No Appendix J exemptions were identified in the SER and Supplements In
Chapter 6 of the UFSAR, - Table 6.2-72 identifies _ the penetration-
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alignment for.the Type A test. This -table. was added 'to the UFSAR subsequent to NRR review of the initial FSAR and is not addressed in-the SER and Supplements. There are 'eight explanatory notes to this
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table some of which indicate that Type C leakage corrections will not be made for certain systems which will be flooded and operating, or isolated, during the Type A test. Also', the Type'A test procedure is
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in the process'of revision and not available for' review at this time.
At the exit interview, the inspector 1 informed :the licensee that'
review of the table and Type A test'. procedure _would'be performed'at a-
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future time consistent.with the next scheduled Type A test.
b.
"As found" Leak Rate The licensee stated that determination of the "as found" integrated leak rate will be controlled by the Type A test j procedure. ' This-procedure is in the process of. revision and was. not' available for review.at this time.
However, the inspector'was able<to' determine?
that the licensee has established the control. process to ensure _that'
pre-and post-maintenance leak rate data are obtained for containment I
isolation. va l v'e s.
This control.is established 'through the maintenance procedures'and work order system. The Shift; Supervision
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1 rate testing requirements and - assuring. that these requir.ements ' are ;
identified and performed.
The inspector reviewed a general valvet maintenance procedure,- MMP-C-6V-1.
The._ shift : supervisor.i s:
s responsible for identifying
~ he required leak' rate testing.i n t
Attachment 4.0 of this procedure by periodic Ltest procedure number.
q The inspector concluded that the licensee has established controls.to i
i obtain the leak rate data required - to determine the "as found" integrated leak rate. The control and. processing-of this = data will; be reviewed in relation to the Type A test at a future time.
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