IR 05000348/1986025

Insp Repts 50-348/86-25 & 50-364/86-25 on 861107-14 & 1201-05.Violation Noted:Failure to Obtain Local Leakage Measurements Before & After Repairs or Adjustments Made to Containment Boundary

ML20210A589
Person / Time
Site:	Farley
Issue date:	01/16/1987
From:	Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210A526	List: IR 05000348/1986025 ML20210A523 ML20210A563 ML20210A589
References
50-348-86-25, 50-364-86-25, TAC-65399, NUDOCS 8702060501
Preceding documents:	ML20238A072 (31 August 1987)
Download: ML20210A589 (11)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION l

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Report Nos.: 50-348/86-25 and 50-364/86-25 Licensee: Alabama Power Company 600 North 18th Street-Birmingham, AL 35291 Docket Nos.: 50-348 and 50-364 License No.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 ,

Inspection Conducted: November 7-14, 1966 - Onsite December 1-5, 1986 - Region II Office Inspector: M. [ // '

/-/f- 7 HJ L. Whi ener Date Signed Approved by: AM F. Jape, Chief hN '

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Test Programs Section Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of contain-ment leak rate testing, including Type A, B and C leak rate testing, and followup inspection of outstanding item Results: One violation was identified - Failure to obtain local leakage measure-ments before and after repairs or adjustments, which were made to the containment boundary prior to the Type A test, in order to quantify the leakage correction to be used to adjust the Type A test result to the "as is" (sometimes called the "as found") containment leak rate. paragraph S PDR ADOCK 05000348 o PDR ,

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REPORT DETAILS Persons Contacted Licensee Employees

• D. N. Morey, Assistant General Manager, Operations

• B. Shipman, Assistant General Manager, Support R. D. Hill, Operations Manager

• R. M. Coleman, System Performance Supervisor

• D. B. Hartline, Test Supervisor

• L. D. Huey, System Engineer Other licensee employees contacted included leak rate test personne Other Organizations Bechtel - Leak Rate Test Consultants H. Hill R. Blum L. Young K. Pimentel Volumetrics ,

T. Scott, Project Engineer, Field Representative NRC Resident Inspectors

• Bradford, Senior Resident Inspector

• B. Bonser, Resident Inspector l

• Attended exit interview Exit Interview i The inspection scope and findings were summarized on November 14, 1986, with I those persons indicated in paragraph 1 above and in subsequent conference calls on December 23 and 30,198 The inspector described the areas l

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inspected and discussed in detail the inspection findings. The following j new items were identified during this inspection.

1 Violation 50-348/86-25-01: Contrary to the requirements of Appendix J to 10 CFR 50, the change in local leak rates resulting from repairs or adjustments made to the containment boundary prior to the Type A test I was not measured; therefore, the leakage correction to be used in

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determination of the "as found" ccntainment leak rate could not be determined (Paragraph 5.c.).

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2 Inspector Followup Item (IFI) 50-348/86-25-02: Evaluate the licensee's analysis and justification of the " pass" or " failure" status of the "as found" containment leak rate as presented in the containment leak rate report to the NRC (Paragraph 5.c.). IFI 50-348/86-25-03: Veri fy that the analysis of the "as left" containment leak rate includes the local leak rates for penetrations 56, 57 and 46 which were isolated or not vented during the Type A test (Paragraph 5.b.1). IFI 50-348/86-25-04: Verify that the required testing for isolation valves Q1E21V116A, B and C is resolved and, if required, appropriate tests are performed (Paragraph 5.b.(2)(a)). IFI 50-348/86-25-05: Verify that the correct method for testing 16 penetrations identified in FSAR Table 6.2-38 as Type C tests with water filled piping is resolved and, if necessary, appropriate testing is performed (Paragraph 5.b.(2)(b)).

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items

Unresolved items were not identified during the inspection.

Containment Integrated Leak Rate Test (CILRT) - Unit 1 (70313)

The inspector reviewed and witnessed test activities to determine that the primary CILRT was performed in accordance with the requirements of Appendix J to 10 CFR 50; ANSI-N 45.4-1972; Technical Specification (TS) 3/4.6.1.2; and, the Unit 1 test procedure, FNP-1-STP-117.0, Revision 6, " Containment Inte-grated Leak Rate Test". ANSI /ANS 56.8-1981, "American National Standard Containment System Leakage Testing Requirements," and Bechtel's BN-TOP-1,

" Testing Criteria for Integrated Leakage Testing of Primary Containment Structures for Nuclear Power Plants," were used for guidance during the course of the inspectio Selected sampling of the licensee's activities which were inspected included:

! (1) review of the test procedures to verify that the procedures were properly

! approved and conformed with the regulatory requirements; (2) observation of

test performance to determine that test prerequisites were completed, special l equipment was installed, instrumentation was calibrated and appropriate data were recorded; and (3) preliminary evaluation of leakage rate test results to verify that leak rate limits were me Pertinent aspects are discussed in the following paragraphs.

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3 General Observations The inspector witnessed and reviewed portions of the test preparation, temperature stabilization, and data processing during the period of November 7-14, 1986. The inspector's observations were as follows:

(1) The test was conducted in accordance with an approved procedur Procedure changes and test discrepancies were properly documented in the procedur (2) Test prerequisites selected for review were found to be complete (3) Selected plant systems required to maintain test control were found to be operationa (4) Special test instrumentation was reviewed and found to be installed and calibrate (5) Problems encountered during the test were documented in the CILRT test event lo (6) Pressurized gas sources, such as instrument air and nitrogen supply to accumulators, were reviewed for proper isolation and venting to prevent interference with test result (7) Procedure valve alignment was reviewed against system drawings to verify correct. boundary alignment, and venting and draining of specific system (8) A temperature survey of the containment was performed to determine representative locations of the instrument (9) In-situ instrument checks were performed to confirm instrument operability and channel agreement with the data acquisition syste (10) Temperature, pressure, dew point, and flow data vere recorded at 15-minute intervals. Data were assembled and retained for final

, evaluation and analysis by the Bechtel Corporation for the licensee.

l A final CILRT report will be submitted to the Office of Nuclear

! Reactor Regulation.

With the exception of Item 7, no problems were identified in the above l areas. Item 7 is discussed in paragraph 5.b. below.

l l Procedure Review (70307 and 61720)

The inspector reviewed portions of FNP-1-STP-117.0, Revision 6, I " Containment Integrated Leak Rate Test," and FNP-1-STP-627, Revision 11,

" Local Leak Rate Testing of Containment Penetrations," on site and completed these reviews in the Region II office. The review included i

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verification that the requirements of Appendix J to 10 CFR 50 and Technical Specification 3/4.6.1.2 were met with specific attentfon to acceptance criteria, valve alignments and system venting and drainin Results of this review are discussed belo (1) Integrated Leak Rate Test: FNP-1-STP-117.0, Revision 6 The acceptance criteria in FNP-1-STP-117.0 were generally adequat One exception was noted in that the acceptance criteria for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test (Section 2.1) endorses only the mass point analysi The current NRC position requires that the Type A and verification tests meet the acceptance limits using the total time analysi This item had no impact on the leak rate test in.that both the licensee and his consultant were aware of the total time require-ment and applied both the mass point and total time analysis techniques to the test dat The inspector concluded that no issue existe The two methods are currently being reviewed to govern the appropriate acceptance criteria for future leak rate tests. These documents include a proposed revision of Appendix J to 10 CFR 50 and a generic letter to all licensees addressing the acceptable use of mass point and total time analysis method A review of each containment penetration for correct valve align-ment, venting, and draining in accordance with the test requirements specified in the FSAR Section 6.2 was performed. An apparent conflict between the FSAR Section 6.2 and Appendix J or Technical Specification requirements will be resolved as a separate issue and is discussed in paragraph 5.b.(2)(b).

Two problems were identified in the valve alignment of the pressurizer sampling system as follows:

(a) Penetration 56: A non-isolation valve number HV3880 located between and in-line with the two isolation valves of the pressurizer steam sample line was closed. This created an artificial barrier between the containment and outside atmosphere (b) Penetration 57: A non-isolation valve number HV3881 located between and in-line with the two isolation valves of the pressurizer liquid sample line was closed. This created an artificial barrier between the containment and outside atmosphere Also, one problem was identified in the component cooling water (CCW) return from the excess letdown and reactor coolant drain tank heat exchangers through penetration 4 This flowpath was isolated, water filled and not vented for the Type A test. FSAR Table 6.2-38 requires a Type C test for this penetration; therefore, the penetration should be vented for the Type A tes "

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The inspector reviewed the cause for the above conditions and found that valves HV3880 and HV3881 in penetrations 56 and 57 are air operated valves which fail closed on loss of air. A source of pressurized air inside containment is not permitted during the Type A test. Consequently, when instrument air to the containment was isolated, these valves closed. Penetration 46 was not vented because this manipulation would involve draining a large volume of chemically treated water with the associated hazard to the environmen On the basis of this review, the inspector concluded that these are isolated cases and that the above alignments are acceptable providing the local leak rates for penetrations 56, 57 and 46 are added to the Type A test result. This matter is identified for followup inspection as: IFI 50-348/86-25-03: Verify that the analysis of the Type A leak rate in the licensee's leak rate report to the Commission includes the local leak rates for pene-trations 56, 57 and 46 which were isolated or not vented during the Type A tes (2) Local Leak Rate Tests: FNP-1-STP-627, Revision 11 The acceptance criteria in FNP-1-STP-627 were adequate as related to Appendix J requirements. The inservice valve program criteria were not evaluated in this revie A review of each penetration indicated that the test alignments are adequately defined. Specifically, block valves, isolation valves, test connections and vent paths are identified and the valve positions specifie Two problem areas were identified in the review as follows:

(a) Certain isolation valves identified for Type C testing are not included in the Type C procedur FSAR Table 6.2-39 identifies the containment isolation valves for all contain-ment penetration FSAR Table 6.2-38 identifies the type of leak rate test to be performed on each penetratio FSAR Table 6.2-31 provides additional information relative to the penetrations including explanatory notes applicable to certain penetration Information in these tables show that the penetrations with manually operated outside isolation valves Q1E21V116B for penetration 25; Q1E21V116C for pene-tration 26; and Q1E21V116A for penetration 27 are to be Type C teste Penetrations 25, 26 and 27 are reactor coolant pump seal water supplies. Note 4 to Table 6.2-31 states that these are open paths post-LOCA but also identifies the manually operated valves outside containment as a second isolation barrier for these penetrations. Isolation valves Q1E21V116 A, B and C are not included in the Type C test

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program defined by FNP-1-STP-627, Revision 11. In that these penetrations are open flow paths post accident; the outside isolation valves are manually operated; the outside isolation valves are normally open; and, without operator action these valves are open post accident; it is not clear if Type C tests are required by Appendix The inspector identified this matter IF: 50-348/86-25-04: Resolve the matter of appropriate testing of isolation valves Q1E21V116A, B and C with NRR and verify any required testing on a defined time basi (b) Certain Type C tests identified in the FSAR are not consistent with the regulations. FSAR Table 6.2-38 specifies the type of leak rate test to be performed on the containment pene-tration In this table 16 penetrations are identified as Type C tests with a footnote that these tests may be performed with the system water filled. This condition is not consistent with the regulation Appendix J requires that Type C tests be performed with air or nitrogen at a pressure of Pa.where specifically the air leakage is determined to compare with the air leakage limit of 0.6La. The exceptions are air lock door seals and seal water system valves. Door. seal's in some cases may be tested at less than Pa. A seal water system valve or a water sealed valve may be tested .with water at 1.1- Pa where water leakage is measured and compared to a water leakage limit and need not be considered"jn the 0.6La limi An air leakage measurement in a water filled system is not define In addition to Appendix J, Technical Specification 4.6.1.2.d

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requires that Type.B and C tests' shall be conducted with a gas at a pressure of Pa...except for tests involving airlocks.

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An exception is granted for airlock door seals which are tested at less than Pa; no exception is identified for Type C test Further, the Safety Evaluation Report does not identify any approved exceptions to the regulation The inspector concluded that the aEceptable test method must be resolved with NRR for the 16 penetrations identified in the FSAR as Type C tests with' water filled systems in order to define the correct Type C test method and' appropriate Type A test alignment for these., penetrations. - This matter was identified as IFI 50-348/86-25-05: Resolve with NRR the

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correct method for local. leik rate testing the 16 penetra-tions identified in FSAR Table 6.2-38 as Type C tests with water filled system's and verify any required testing on a defined time basi .

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7 As-Found Containment Leak Rate The regulations regarding the determination of the overall contain-ment leak rate prior to any repairs or adjustments to the containment boundary are as follows:

Paragraph III.A.1.(a) of Appendix J to 10 CFR 50 and paragraph of ANSI-N45.4, incorporated into the regulation by paragraph III.A.3.(a) of Appendix J to 10 CFR 50, require that no repair or adjustment shall be made to the containment boundary prior to the Type A test in order to determine the "as is" overall containment leakage rate. If repairs or adjustments are necessary prior to the Type A test, the NRC has determined that the intent of the above regulation (specifically, to determine the "as is" overall containment leakage rate) is met provided that local leak rate tests are performed on the affected portion of the containment boundary to determine the minimum path leak rate before and after the repairs or adjustments are made; and, the Type A test result is corrected, using these local leak rate measurements, to determine the "as is" overall containment leakage rat The inspector reviewed the licensee's program for determination of the overall "as is" containment leak rate with specific attention to:

(1) the development of controls to obtain the required local leak rate data; (2) the processing of local leak rate measurements to determine the leakage correction based on the minimum path leakage concept; and, (3) the effect of the test results on the containment leak rat Controls to obtain the required local leak rate data are established through the outage planning activity and the maintenance work request systems. The daily planning group identifies any valve which requires a local leak rate test on the maintenance request. Before releasing a component for maintenance, the operations foreman verifiee ttat the required leak rate test has been performe?. The inspector tr,cluded that the licensee has established controls to obtain an "as found" containment leak rat Containment penetration drawings, Type C test valve alignments and the tabulation of local leak rate data were examined to eva' uate the

calculation of the local leakage correction. The minimum path leakage was calculated correctly; however, certain leakage barriers have been excluded from the "as found" leak rate measurements. F-ior to the Type A test the "as found" leak rate was not obtained for the equipment hatch and the fuel transfer tube blind flange seals before removing these barriers for the refueling outage.

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On reinstallation of these barriers prior to the Type A test, an as-left local leak rate. (Type B) test is performed and these values were used in the calculation of the containment "as found" leakag The licensee indicated that the seals for the fuel transfer tube blind flange were replaced; this is considered a repai Seals for the equipment hatch were not replaced; however, the fitting, seating, and torquing manipulations involved with removal and reinstallation of the

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hatch are considered adjustment These barriers directly isolate containment atmosphere from the outside atmosphere and are required Type B test The inspector concluded that repairs or adjustments were made to the containment boundary prior to the Type A test without quantifying the change in leakage resulting from these repairs or adjustments in order to adjust the Type A leak rate to the "as found" condition. Further, exclusion of components which are potentially direct leakage paths from the containment . atmosphere to the outside atmosphere from the "as found" containment leak rate determination normally requires an exemption to the regulations identified abov '

This matter was identified as a violation as follows:

Violation (50-348/86-25-01): Contrary to the above requirements when repairs or adjustments were made to the containment boundary prior to the Type A test the licensee failed to measure the change in leak rate resulting from these repairs or adjustments by local leak rate methods in order to determine the overall containment

"as found" leak rat The inspector concluded that failure to obtain the leakage corrections for all repairs or adjustments made to the primary containment boundary prior to the Type A test renders the overall "as found" containment leak rate indeterminabl The licensee is required to submit a containment leak rate test report s

to the NRC with 90 days. In accordance with Appendix J, Paragraphs

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III. A.6 and V.B tnis report must identify the licensee's position on the " pass" or " failure" status of the overall as-found containment leak rate and provide the information and analyses on which this position is based for evaluation by the NR This matter was identified for followup inspection as:

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IFI 50-348/86-25-02: Evaluate the licensee's leak rate test report and determine the " pass" or " failure" status of the overall

"as found" containment leak rat The inspector's evaluation of the licensee's "as found" containment leak rate excluding the fuel transfer tube blind flange and equipment

. hatch indicate a leak tight containment. The allowable leakage of 0.75 La is 0.1125 wt% per day. The Type A leak rate (95% UCL based on total time) was 0.054 wt% per day. The leak rate correction, excluding the

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two barriers which were not quantified, was about 0.02 wt% per day. An adjusted leakage of 0.07 wt% per day leaves a margin of 0.04 wt% per day within the allowable 0.75 La limit; in other words, the "as found" leak rate is about 60% of the allowable 0.75 La leakage excluding the unmeasured corrections for the equipment hatch and fuel transfer tube blind flange seal Containment Integrated Leak Rate - Unit 1 A 24-hour containment integrated (Type A) leak rate test and a four hour supplemental leak rate test were performed on the Unit 1 primary containment in the period November 10-11, 198 Mass point-linear regression analysis and total time analysis were used by the licensee to determine the leak rate (Lam) and upper confidence limit (UCL) at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The test met the acceptance criteria for both mass point and total time analysis as shown below; the values are expressed as weight percent per da Mass Point Total Time

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wt%/ day wt%/ day La 0.15 0.15 (allowable leakage)

0.75 La 0.1125 0.1125 (test acceptance limit)

Lam at 24 hr .04 0.031 UCL at 24 hr .042 0.054 The inspector's calculations agree with the above value A four hour supplemental test was performed in accordance with the recommendations of Appendix C of ANSI-N45.4-1972. The measured composite leak rate was within the upper and lower acceptance limits specified by the equation:

Lam + Lo - 0.25 La < Lc < Lam + Lo + 0.25 La for both the mass point l and total time analyse The values for the equation in terms of weight percent per day are as follows:

Mass-Point Total Time l wt%/ day wt%/ day Composite leak rate, Lc 0.170 0.157

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Type A test leak rate, Lam 0.040 0.031 Imposed leak rate, Lo 0.154 0.154 Error limit, 0.25 La 0.0375 0.0375 Substitution of these values into the acceptance equation demonstrate that the specified inequalities are satisfied as follows:

Mass-Point 0.156 < 0.170 < 0.231 Total Time 0.147 < 0.157 < 0.222

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Based on this review of test data, the inspector concluded that the Type A and supplemental tests demonstrate that the "as left" primary

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containment leakage rate is within the specified acceptance limit . Review Of Outstanding Items (Closed) -IFI 50-348/84-12-02 and 50-364/84-12-02 concerned the use of a chi-squared statistical test to determine the reliability of source range neutron detector channels. The inspector verified that the licensee has

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developed and implemented procedure "FNP-0-ETP-3635" dated September 12, 1984, to statistically verify operability of the source range channel This item is close (Closed) IFI 50-348/85-39-01 concerns the modification of procedures to include a confirmation of a negative moderator temperature coefficient above 70?s powe The inspector determined that a revision to ETP-3605, step 7.2.3 now requires that prior to reaching 70's thermal / power the

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moderator temperature coefficient (MTC) for 70?s and higher powers will be verified to be within the Technical Specification limit using procedure STP-114. Procedure STP-114, paragraph 5 contains the steps to verify the

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MTC at or above 70*4 powe This item is closed.

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