IR 05000387/1980022
| ML17138B623 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/30/1980 |
| From: | Caphton D, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17138B622 | List: |
| References | |
| 50-387-80-22, NUDOCS 8012100392 | |
| Download: ML17138B623 (10) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I II 3
. ~5II-387 5II-22 Docket No.
50-387 License No.
GPPR-101 Priority Category Licensee:
Penns lvania Power and Lioht Com an 2 North Ninth Street Allentown', Penns 1 vania 18101 Facility Name:
Susquehanna Steam Electric Station, Unit
Inspection at:
Salem Township, Pennsylvania Inspection conducted:
August.
2 -28, 1980 Inspectors:
W. A. Rekito, Reactor Inspector dat signed date signed Approved by:
. Caphton, Chief, Nuclea Support Section No. 1, R08NS Branch da e sign d
3~
ate s gned Ins ection Summar
Ins ection on Au ust 25-28, 1980 Re ort No. 50-387 80-22 3~5:
.
df
5
3
22 ment leak rate test procedures, inservice test program for pump.and valves, sur-veillance of pipe supports and restraints, and a general plant tour.
The inspection involved 26 inspector-hours on site by one region based NRC inspector.
Results:
No items of noncompliance were identified.
Region I Form 12 (Rev.
April 77)
18012100394
DETAILS 1.
Persons Contacted Penns lvania Power and Li ht Com an
"G. Adams, Operations Supervisor
"J. Blakeslee, Jr., Senior Results Engineer
"S. Cantone, Acting Plant Superintendent
"T. Clymer, Senior NgA Analyst
"E. Gorski, Acting guality Supervisor
"J. Green, gA Supervisor-Operations D. Thompson, Assistant Plant Superintendent Bechtel Power Cor oration, E. Figuard, Assistant ISG Supervisor
"M. Fulkerson, ISG Test Engineer
"R. webster, ISG Supervisor U.S. Nuclear Re ulator Commission
"G. Rhoads, Resident Reactor Inspector The inspector also interviewed other licensee personnel during the inspection.
"Denotes those present at the exit interview.
2.
Containment Inte rated Leak Rate Test CILRT aa Documents Reviewed Procedure P59.2, Revision 5, DRAFT, "Containment Integrated Leak Rate Test" Susquehanna FSAR Section 6.2.6, Primary Reactor Contai.nment Leakage Rate Testing.
Dwg.
No. M-113, Revision 13, Reactor Building Closed Cooling Mater.
Dwg.
No. M-126, Revision 10, Containment Instrument Gas.
Dwg.
No. M-139, Revision 3, MSIV Leakage Control System.
Dwg.
No. M-141, Revision 10, Nuclear Boile 'Dwg. 'No. M-144, Revision 9, Reactor Mater Cleanup.
Dwg.
No. M-,148, Revision 7, Standby Liquid Control.
Dwg.
No. M-149, Revision 12, Reactor Core Isolation Cooling.
Dwg.
No. M-151, Revision 15, Residual, Heat Removal.
.
Dwg.
No. M"157, Revision 13, Containment Atmospheric Control.
b.
~Sco e The inspector reviewed DRAFT procedure P59.2,
"Cohtainment Integrated Leak Rate Test",
Tor technica1 adequacy and comp1iance with 10 CFR 50, Appendix J, ANS N45.4, and Susquehanna FSAR.
The inspector also dis-cussed various aspects of the CILRT with the licensee's representatives including current NRC positions concerning leak rate testing and the licensee's plans for the preoperational CILRT.
Mith the exception of the items noted below, the inspector identified no inadequacies and had no further questions in this area.
c.
Acce tance Criteria The procedure provides the option of conducting a short duration (less than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) test in accordance with the Bechtel Power Corporation's Topical Report BN-TOP-l, "Testing Criteria for ILRT of Primary Contain-ment Structures for Nuclear Power Plants",
which provides data analysis using both mass point and total time methods.
This type of short duration test is acceptable to the NRC but because of inherent bias on the total time method of data an'alysis, the inspector informed the licensee's representative that the NRC will evaluate the success of the test using the mass point method.
In addition the procedure acceptance criteria had no provisions to correct the calculated leakage rate for; (1) systems isolated oi not properly vented and drained, or (2) changes in the test volume (containment, free air volume) during the test.
In summary:
L 9 95K UCL + K < 0.75 L
where; L
8 95K UCL is the calculated leakage rate using mass point at the 9% upper confidence level, L is the maximum allowable leakage rate at containment peak accident pkessut e,
J y-
K is a conservative correction factor including Type C test results for systems which could become potential leakage paths that are isolated or not properly vented and drained; Corrections for sump, reactor vessel, and suppression pool level increases.
Since the procedure acceptance criteria does not include the above identified corrections, this item is unresolved=and is designated (387/80-22-01).
d.
Value Lineu Review On a sampling basis, the inspector reviewed the CILRT procedure valve lineup sheets to verify that:
Each penetration was provided with a valve lineup; Containment Isolation Valves (CIYs) were in the correct positions; Proper drain and vent paths were provided; and Artificial leakage barriers were not created which could mask containment leakage.
During this review the inspector identified the following two problems:
(1)
The current valve lineup does not drain the two recirc pump seal water supply lines to expose the seating surface of CIVs 1F013A and 1F0138 to the containment atmosphere as specified in FSAR table 6.2-22 and required by 10 CFR 50 Appendix J.
(2)
The current valve lineup sheets verify the position of instrument sensing line root valves but does not verify the position of each instrument local isolation valve.
The inspector stated that this verification was necessary to assure that CILRT boundaries included instrumentation which are containment leakage barriers during a post LOCA condition.
The licensee acknowledged and agreed to correct these discrepancies.
This item is unresolved and designated (387/80-22-02).
e.
Leaka e
Re airs The inspector noted that the test procedure did not contain any precau-tions against repairing identified leaks and discussed with the licensee's representative the provisions of paragraph III.A.1.(a). of Appendix J
regarding leakage repairs.
The inspector explained. the NRC position that, if during the CILRT potentially excessive leakage paths are identified,.the leak may be isolated and the CILRT restarted provided:
(1)
The leak path is locally testable and is in fact tested both before and after repair; (2)
The pre-repair leakage is added to the CILRT results to obtain the "as found" leakage; and (3)
The post-repair leakage is added to the CILRT results to obtain the "as left" leakage.
The inspector further noted that such repairs must be carefully con-trolled during the test to avoid invalidating test results.
The licensee's representative acknowledged these comments.
3.
Local Leak Rate Testin LLRT a.
~Sco e
The inspector reviewed LLRT procedure TP 1.22, Revi'sion 1, in addition to documents listed in paragraph 2.a., for technical adequacy and com-pliance with 10 CFR 50 Appendix 3, ANS N45.4, and Susquehanna FSAR.
The inspector also discussed various aspects of LLRT with the licensee's representative including optional test methods acceptable to the NRC and the licensee's plans for the preoperational LLRT program.
The first LLRT activities are scheduled to start in September 1980.
No items of noncompliance were identified, however several inspector concerns for the LLRT procedure adequacy are described below.
b.
Procedure Review and A
royal The inspector noted and questioned the appropriateness of the LLRT procedure being reviewed and approved by the Integrated Startup Group (ISG) Supervisor.
The Assistant Station Superintendent stated that the procedure and test results would be reviewed and approved by the station Test Review Board, as though it were a preoperational test procedure.
This commitment satisfied the inspector's concern but the item will be reviewed at a later date to ver ify the additional review and approval.
(387/80"22-03)
c.
Acce tance Criteria Section 2.2.(l) of the test procedure specifies that "Containment isolation valves subject to hydraulic Type C tests shall have leakage rates that do not exceed the hydraulic leakage limits specified by plant technical specifications".
The inspector noted that Susquehanna TS have not been issued and the licensee's representative explained that the proposed TS do not include specific leakage limits for hydraulic Type C LLRTs which are permitted in 'lieu of pneumatic tests by specific FSAR approval.
The licensee's representative further identified a Startup Field Report No. 1065, dated 4/15/80, which identified this problem and requested the Engineering Oepartment provide the needed Acceptance Criteria.
This matter is considered unresolved pending specification of an acceptable acceptance criteria for hydraulic Type C LLRTs.
(387/80-22"04)
d.
Procedural Guidance The inspector noted that the LLRT procedure referenced ANSI/ANS 56.8, Draft No. 2/Revision 3 dated November 15, 1978,
"Containment System Leakage Testing Requirements".
Further, the licensee's representative explained the intent of the LLRT program was to meet the testing pro-visions of this Oraft Standard to the extent possible.
The inspector identified the following specific areas where the LLRT procedure guidance was not consistent with the guidelines of ANSI/ANS 56.8 and as such the technical adequacy is questionable.
(1)
The LLRT procedure does not identify test instrument requirements for accuracy and range limitations.
(2)
The LLRT procedure does not provide guidance for results error analysis or instrument minimum sensitivity to be used when recording and evaluating data.
(3)
'The pressure decay method of test described in the LL$T procedure assumes that temperature is stable/constant if dT <10 F per 10 minute interval.
The inspector stated that the NRC requires changes in temperature be included in the leak rate calculation for pneumatic pressure decay tests.
The licensee's representative acknowledged these concerns and agreed to correct the test procedure.
The above items are considered unresolved and collectively designated (387/80-22"05).
Surveillance of Pi e Su ort and Restraint S stems The inspector held discussions with licensee representatives regarding plans for surveillance of shock suppressors (snubbers)
on safety related piping.systems.
All safety related snubbers at the Susquehanna Plant are of the mechanical design and,the licensee's represntative stated that their proposed technical specifications presently do not include any surveillance requiremnts for mechanical snubbers.
The inspector informed the licensee's representative about, proposed changes to the Standard TS (NUREG-0123, Revision 2) which include surveillance requirements for mechanical snubbers and is expected to be issued soon.
The licensee's representative acknowledged these comments and stated they were expecting such changes and would prepare for them.
The inspector found no unacceptable conditions and had no further questions in this area.
5.
Inservice Testin of Pum s and Valves The inspector held discussions with the licensee representatives regarding plans for preservice and inservice testing of safety related pumps and valves in accordance with ASME B&PV Code Section XI.
The licensee is presently developing the applicable inservice testing program description and has committed to submit it to the NRC for review by January 1, 1981.
The licensee's representative further explained that implementing inservice surveillance test procedures are scheduled to be completed by March 1981 and will be used to conduct preservice tests and obtain necessary baseline data.
Included in these discussions were identification of specific code inservice test requirements and acceptable test methods for meeting these require-ments.
The inspector identified no unacceptable conditions and had no further questions in this area at this time.
6.
,Plant Tours The inspector made several tours of the facility during the course of the inspection including the reactor building, primary containment, control structure and the control room.
During these tours the inspector observed work in progress and the general condition of safety related components, such as pumps, valves, penetration assemblies and piping supports.
No unacceptable conditions were identifie.
Unresolved Items Unresolved 'items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations.
Unresolved items are identified in paragraphs 2.and 3 of this report..
8.
Exit Interview The inspector met with li'censee representatives (see Details 1 for attendees)
at the conclusion of the inspection on August 28, 1980.
The inspector summarized the scope and findings of the inspection at that time.
With regard to the findings in paragraph 3, the Station Superintendent stated that resolution would be completed prior to initiating local leak rate test activities.