IR 05000400/1988023
| ML18022A689 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/06/1988 |
| From: | Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A594 | List: |
| References | |
| 50-400-88-23, NUDOCS 8809220140 | |
| Download: ML18022A689 (14) | |
Text
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UbllTE0 STATES NUCLEAR REGULATORY COMMISSlON
REGION II
101 MARIETTAST., N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-400/88-23 II Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Ralleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
License No.:
NPF-63 Inspection Conducted:
July 25-9, 1988 Inspector:
l.L.~
H.
. h'n Accompanyin ersonnel:
J.
Zei ler Date Signed Approved by F, Jape, Chief Test Programs Section Engineering Branch Division of Reactor Safety Date Signed SUMMARY Scope:
This routine, unannounced inspection was in the areas of local leak rate testing and verification of containment i'ntegrity.
Results:
In the areas inspected, violations or deviations were not identified.
OOU OOQ
'Within the scope of this inspection, the findings indicated that the licensee has developed and implemented a
program of controls, procedures, and testing as required by Technical Specifications to maintain containment integrity.
Also, appropriate containment related systems were available and adequate procedures were implemented to mitigate releases in the event of a loss of contain-ment integrity following a
LOCA.
jtowever, two weaknesses were identified; one concerning the licensee's procedure for performing the personnel airlock door seal leakage test, and, one weakness involving mathematical and data transposition errors in calculating the total containment local leakage rate (Paragraphs 3.0 and 4.c.).
T'e above conclusions are based on limite'd available plant data, since the plant has not undergone.its first refueling outage during which time more extensive testing and maintenance activities are expected.
A more conclusive review of the licensee's implementation of containment related programs will be.conducted in subsequent inspections when more plant data is availabl ~ g
REPORT DETAI.LS Persons Contacted Licensee Employees S.
Bohanon, Shift Technical Advisor G.
Forehand, Director, QA/QC P. Hadel, Project Specialist, Maintenance Planning
- C. S. Hinnant, Plant General Manager
"E. Johnson, Principle Specialist, Document Services
- L. March, Engineering Technician, Technical Support
"M. M. Pugh, Project Specialist, ISI
"C. E.. Rose, Jr.,
QA Supervisor
- J. Schaub, Senior Specialist, Technical Support
"D. L. Tibbits, Director, Regulatory Compliance
- M. G. Wallace, Senior Specialist, Regulatory Compliance
"L. Woods, Engineering Supervisor, Technical Support Other licensee employees contacted duriag this inspection included engineers, operators, and administrative personnel.
NRC Resident Inspectors
"W. H. Bradford, Senior Resident Inspector
"G.
F. Maxwell, Senior Resident Inspector (Joseph M.
Far ley)
"Attended exit interview Purpose The purpose of this inspection was to verify the development and implemen-tation of programs, controls, procedures, and test activities which ensure that containment integrity is established, mo'nitored, and maintained consistent with the requirements of the Technical Specifications, Appendix J of the
CFR 50, and applicable industry standards.
Local Leak Rate Testing (61720)
An important part of mon3toring and maintaining containment integrity is the periodic testing performed to verify the leak tightness of containment leakage barriers's part of the evaluation of containment integrity, the inspector reviewed the formal procedures established by the licensee to verify local leak tightness of leakage barriers.
Documents reviewed either totally or in part to verify that the licensee has established adequate procedures'and controls included:
PLP-103, Revision 3, Surveillance and Periodic Test Program
PLP-106, Revision 1, Technical Specification Equipment,.Test Program MMM-012, Revision 6, Maintenance Work Control Procedure MMM-019, Revision 0, Post-Maintenance Testing AP-007, Revision 6,.Temporary and Advance Changes to Plant Procedures RMP-006, Revision 1, Records Storage Area ISI-203, Revision 5, ASME Section XI Pump and Valve Program Plan
ISI-114, Revision 0, General Use of Local Leak Rate Testing Equipment ISI-112. Revision 0; Type B and C
LLRT Engineering Personnel Training and Qualification EST-212, Revision 2, Type C Local Leak Rate Tests EST-'209, Revision 3, Type B Local Leak Rate Tests EST-219, Revision 3, Personnel Air Lock Ooor Seals Local Leak Rate Test h
EST-220, Revision 0, Type C
LLRT of Containment Purge Exhaust Penetration (M-58)
EST-221, Revision 0, Type C
LLRT of Containment'Purge Make-Up Penetration (M-57)
EST-222, Revision 0, Procedure for the Type B LLRT of the Personnel Air Lock Barrel (Overall Test)
Portions of the above documents were reviewed in general for assignment of responsibility, adequate instructions, control of test activity, appropriate test intervals, appropriate test parameters, approved. test methods and adequate acceptance criteria.
Also a detailed walk through of the procedures for local leak testing was performed for ten penetrations shown below:
Penetration Oescri tion M-78B M-40 M-44 M-86B M"76A M"12 M"39 M-73A M-77A M-8 Pressurizer Liquid Sample Line Oemin.
Water to PRT Fuel Pool Cooling System Hydrogen Analyzer Accumulator Fill Line Excess Letdown Line CCW from RCP Thermal Barriers Hydrogen Analyzer Sample Suction Nitrogen to SIS Accumulator Normal Charging
i
Partial review, of'.other, penetrations was also performed and no, problems were identified relative to valve identification, valve alignment or system restoration.
Based on this review of a
sample of the leak rate test procedures and portions of the administrative control procedures the inspector concluded that programmatically the licensee has developed a containment local leak rate measurement program which is consistent with the regulatory requirements of the Technical Specification, Section 4.6;
CFR 50, Appendix J; and ANSI-N45.4-1972.
Implementation of the program for establishing and maintaining containment leak tight barriers was also
~eviewed.
This review included a limited amount of data since the plant has not had a
refueling outage and consequently, has not yet performed a periodic Type B and C test program.
Review of available test data and leak rate summations showed that the licensee has established and implemented the controls for maintaining the total Type B and C leak rate summation and has routinely performed the quarterly Type C test of the purge valves.
The inspector reviewed the leak rate summations for a limited number of Type B and C tests performed during a short outage in October 1987 and found that the summation was incorrect.
Further review showed that some minor mathematical and data transposition errors had resulted in a
small error in total leakage.
These errors were corrected before the inspector left the site and the actual leak rate was well below the allowable leakage limit. At the exit interview licensee management stated that a
non-conformance report (NCR)
had been written on this item requiring that the root cause be identified and corrective action'aken prior to implementing the first periodic Type B and C test program.
The inspector considered that the NCR will track and resolve this issue.
The.inspector reviewed the Surveillance and Work,Request and Authorization
.
(WR&A) controls to ensure that a method of tracking a failed leak rate test through the maintenance, retest and review process is defined.
Task sheets are computer generated and issued for each initial Type B and C
test.
These sheets have a unique number identifying a specific component and specify the schedule, the test to be performed andithe test procedure.
If a valve fails the test a
WR&A is issued.
Each WR&A is planned by the Maintenance Planning group who determine if a post maintenance test is required and the appropriate procedure.
The retest is tracked by the test procedure specified on the WR&A.
In addition a Post Maintenance Testing Requirements (PMTR) sheet is now generated with each work request which specifies the retest and requires sign off that testing is successfully completed.
The inspector tracked the failure of M-57, purge valves, on May 2, 1988, and determined that the process had been correctly implemented.
The inspector concluded that the licensee has controls in effect which provide ad'equate assurance that retest of leakage barriers is identified,
'erformed and reviewed.
-A larger data base will be reviewed in the routine inspection program at a future tim.
Verification of Containment. Integrity (61715)---
The adequacy and implementation of the licensee's program designed to ensure and maintain containment integrity was'ssessed by reviewing:
the adequacy of surveillance test procedures; surveillance test records; post-maintenance activities associated with surveillance tests; and guality Assurance involvement in containment related activities.
a.
Procedures Reviewed OST-1029,'Revision 2, Containment Penetration Outside Isolation Valve Verification, (Frequency:
Monthly)
OST-1069, Revision 1, Containment Building Penetration Inside Manual Isolation Valve Verification, ( Frequency:
Usually
Days)
EST-219, Revision 3,
Personnel Air Lock Door Seals Local Leak Test, (Frequency:
Usually 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after containment entry)
EST-222, Revision 0,
Procedure for th'e Type B
LLRT of the Personnel Air Lock Barrel (Overall Test),
(Frequency:
6 Months)
OST-1021, Revision 4,
Operations Surveillance Log, (Frequency:
Daily)
OST-1009':
Revision 3,
Containment Spray Operability Monthly Interval, (Frequency:
Monthly)
OST-1119, Revision 3,
Containment Spray Operability quarterly Interval, (Frequency:
Monthly)
OST-1807, Revision 2,
Containment Spray System:
ESF Response Time, (Frequency:
18 Months)
OST-1809, Revision 2,
Switchover to Recirculation Sumps:
ESF Response Time, (Frequency:
18 Months)
EST-220, Revision 0,
Type C
LLRT of Containment Purge Exhaust Penetration (M-58), (Frequency:
(}uarterly)
EST-221, Revision 0,
Type C
LLRT of Containment Purge Make-up Penetration (M-57), ( Frequency:
quarterly)
RST-206, Revision 3,
Spray Additive System Sodium Hydroxide Concentration Surveillance, (Frequency:
6 Months)
OST-1825, Revision 3, Safety Injection:
ESF Response Time, Train A, (Frequency:
18 Months)
'
OST-1826, Revision 3, Safety Injection,:.ESF Response..Time,.
Train B, (Frequency:
18 Months)
OST-1010, Revision 2,
Containment Cooling System Operability Test, (Frequency:
Monthly)
MST-I0116, Revision 1,
Containment Hydrogen Analyzer System Calibration, Train A or B, (Frequency:
quarterly)
MST-10234, Revision 1, Containment Hydrogen Monitor Operational Test, (Frequency:
Monthly)
MST-I0211, Revision 0, Electric Hydrogen Recombiner Kilowatt Indication Channels Calibration,.A or B, (Frequency:
18 Months)
OST-1030, Revision 3, Electric Hydrogen Recombiner Functional Test, (Frequency:
6 Months)
x b.
Scope of Procedure and Record Review The inspectors reviewed the above surveillance procedures either totally or partially.to verify their technical and administrative adequacy, The procedures were reviewed to verify applicable techni-cal specification requirements were met, adequate information and instruction were provided, and adequate acceptance criteria and limits were specified.
'he inspectors also reviewed test records of the above surveillance tests to ascertain the availability of these systems.
Those contain-ment systems involved in this review included the following areas:
Containment isolation valve alignment checks, stroke time and operability tests (abbreviated as CIV)
Containment personnel airlocks (abbreviated as CA)
Containment internal pressure and temperature limits (abbreviated as CPT)
Containment combustible gas monitoring system (abbreviated as CCGM)
Containment depressurization system
-
containment spray (abbreviated as CDS-CS)
Containment depressurization system - containment spray additive (abbreviated as CDS-CSA)
Containment depressurization system containment cooling (abbreviated as CDS-CC)
Containment ventilation system (abbreviated as CV)
Records Reviewed The following records associated with the previously mentioned
'ontainment related and post-LOCA mitigation systems were reviewed by the inspectors.
Also shown is the applicable Technical Specification which required the surveillance test.
Containment Procedure
~Sstem No.
T.S.
CIV CIV CIV CIV CA CA CPT and CCGM CDS-CS CDS-CS CDS-CS and CDS-CSA CDS-CS CDS"CSA CDS-CC CCGM CCGM CCGM CCGM
.CV CV OST-1029 OST-1069 OST" 1825 01/04/88 through 07/05/88 09/21/87 and 10/26/87 10/29/87 OST" 1826 11/13/86 through 12/15/86 OST-219 OST-222 OST-1021 01/21/87 through 06/27/88 10/31/87 through 05/05/88 06/01/88 through 06/30/88 OST" 1119 OST" 1807 09/17/87 through 04/06/88 10/14/86 through 10/26/87 OST-1809 OST-206 OST-1010 MST-I0116 MST-I0234 MST-I0211 OST-1030 EST"220 EST-221 12/10/86 12/03/87 through 06/07/88 12/03/87 through 05/05/88 10/02/87 through 05/19/88 02/15/88 through 06/08/88 06/01/88 12/26/86 through 01/04/88 06/15/88 05/03/88 OST-1009, 02/02/88 through 06/05/88 4.6.l.l.a 4.6.l.l.a 4.6.3.2.a 4.6.3.2.c 4.6.3.2.d 4.6.3.2.f
- 4.6.3.2,a 4.6.3.2'.c 4.6.3.2.d 4.6.3.2.f 4.6.1.3.a 4.6.1.3.b.1 4.6.1.3.b.2 4.6.1.4 4.6.1.5 4.6.4.1.a 4.6.4,.l.b 4.6.2.1.a 4.6 '.2.a 4.6.2.1.a 4.6.2.1.b 4.6.2.1.c.1 4.6.2.1.c.2 4.6.2.2.c 4.6.2.1.c.3 4.6.2.2.b.2 4.6.2.3.a.l 4.6.2.3.a.2 4.6.4.1 4.6.4.1.a 4.6.4 '.b 4.6.4.2.b.l 4 '.4.2.a 4.6.1.7.2 4.6.1.7.2 Findings Summary For the most part, the procedures reviewed were technically accurate and in conformance with Technical Specifications (TS),
howevers duri'ng the inspectors'eview of Procedure No.
EST-219, Personnel Airlock Door Seals Local Leak Rate Test, several discrepancies and
weaknesses were noted. relating to the procedure or test performance as follows.
Item 1.2 in the purpose section of the procedure stated that the leak rate test will be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each closing or once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during multiple entries in Plant Modes 1-4.
Paragraph III.D.2.b.iii of
CFR 50, Appendix.J states that airlocks opened during periods when containment integrity is required by the plant's TSs (Modes 1-4) shall be tested within 3 days after being opened.
The inspectors made licensee management aware of this disrcepancy and cautioned against using the airlock closing time as opposed to the opening time for the start of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> test requirement.
Similarly, the inspectors discussed with the licensee about the same discrepancy which exists between the closing versus opening wording of TS surveillance requi rement 4.6. 1.3.a and
CFR 50, Appendix J.
The inspectors indicated that in most instances where there exists a conflict between requirements, the more conservative requirement takes precedence, i.e.,
the Code of Federal Regulations in this circumstance.
2.
The licensee's Inservice Inspection (ISI) Engineer responsible for performing the airlock seal tests (TS 4.6.1.3.a)
stated that these surveillance tests were being performed with the assump-tion that the provisions of TS 4.0.2 were applicable.
TS 4.0.2 specifies an allowable 25%
extension of the surveillance interval for TS surveillance requirements.
The licensee's reason for this assumption was that TS 4.6. 1.3.a does not explicitly state that the provisions of TS 4.0.2 were not applicable.
The inspectors reminded the licensee that
CFR 50, Appendix J Paragraph 111.0.2.b.i ii requires a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> test interval and the TS extension does not apply to, the CFR.
At the NRC Exit Interview, the licensee committed to adhere to the
hour test interval.
3.
A weakness was also found in the licensee's controls for triggering the performance of the seal tests.
The licensee's representative stated that presently the tests are performed every monday of the week, and that ISI contacts the control room every wednesday and friday of the week to check if containment entries have been made.
The inspectors considered this to be a
weak triggering mechanism since there exist no procedures or other administrative controls which require ISI to take this action.
At the Exit Interview, the licensee committed to establish appropriate test triggering controls whereby plant operations would be responsible for contacting ISI when containment entries are made.
Further, the inspectors were provided with a copy of a revised Control Room Standing Order, which requires the control room operators to contact ISI. when entry is made and to enter their intials and date ISI.contacted-in the Containment Entry. Lo The inspectors'eview of surveillance test records identified no'iscrepancies.
The inspectors verified that the surveillance tests were performed at the required frequencies; that test results met
'cceptance criteria; that appropriate retests or other post-maintenance 'activities were prescribed as requi red for failed tests; and that appropriate sign-offs, test reviews, and test concurrences were performed.
These findings indicated that required plant programs designed to ensure containment integrity and containment systems designed to mitigate contamination releases in the event of containment integrity failure following a LOCA are in a relatively high state of availability.
However, this conclusion was based on limited available plant data since the plant has operated for only one and one-half years and has not had a refueling outage.
d.
Post-Maintenance Activities completed condition 5.
Exit Interview The inspectors reviewed a small sample of maintenance records associ-ated with local leak rate surveillance test activities.
The objective of this review was to verify that test failures and deficiencies were promptly corrected and that appropriate retests or other functional test requirements were performed.
The inspectors found that in all cases reviewed, post-maintenance testing was as required and in a
timely manner.
No unacceptable s were identified.
The inspection scope and results were summarized on July 29,, 1988, with those persons indicated in Paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results.
Proprietary information is not contained in this report.