IR 05000413/1989033
| ML19353B113 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/21/1989 |
| From: | Belisle G, Whitener H, John Zeiler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19353B112 | List: |
| References | |
| 50-413-89-33, 50-414-89-33, NUDOCS 8912110222 | |
| Download: ML19353B113 (11) | |
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[Naisq'o NUCLEAR REGULATORY COMMISSION
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UNITED STATES
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REGION 11
$
101 MARIETTA STREET,N.W.
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'e ATLANTA, GEORGI A 30323
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Report.Nos.: 50-413/89-33 and 50-414/89-33 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242
Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52
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Facility Name: Catawba 1 and 2 Inspection Conducted: October 30 - November 3,1989 Inspector:'
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H. L. Wtiitener D&te Stigned
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Inspector:
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.Date Signed Approved by:
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G. A. Belisle, Chiefd Date ' Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:
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This routine, unannounced inspection was conducted in~ the areas of containment
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local-leak rate testing, verification of containment integrity, and action on previous-inspection findings.
Results:
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The licensee's programs-for establishing and maintaining containment integrity and for performing local leak rate tests for containment isolation boundaries appear strong and-well controlled.
Local leak rate test engineers possess a good. knowledge of test requirements, procedures, and industry practices.
The inspectors were 'particularly pleased with the licensee's strict controls governing the containment penetration venting and draining process.
The inspectors identified two concerns from the local leak rate test program l-review:
1) not performing Type B leak rate tests on the conductor seals for
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certain electrical penetration designs (paragraph 2.c), and 2) pressurizing certain containment isolation valves in the non-accident direction (paragraph
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2.d).
8912110222 891127 PDR ADOCK 05000413 Q
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a" A strength was also identified regarding the licensee's ~ plans for an automated valve failure trending program for the early detection of valve degradation and the prediction of valve failures (paragraph 2.e.).
In the areas inspected, no violations or deviations were identified.
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O REPORT DETAILS 1.
Persons Contacted Licensee Employees
- B. Beaver, Performance Engineer
- J. Forbes, Superintendent Technical Services
- M. Geckle, Performance Engineer
- R. Glover, Compliance Engineer
- M. Hutcheson, Performance Engineer
- V. King, Regulatory Compliance
- T. Owens, Station Manager Z. Taylor, Performance Engineer Other licensee employees contacted during this inspection included engineers, operators, technicians, and ad:ninistrative personnel.
NRC Resident Inspectors
- M. Lesser, Resident Inspector
- W. Orders, Senior Resident Inspector
- Attended exit interview 2.
Containment Local Leak Rate Testing (61720)
An important part of monitoring and maintaining containment integrity is periodic local leak rate testing to verify leak tightness of containment leakage barriers.
The purpose of the inspection activities in this area was to ascertain that the licensee's local leak. rate test (LLRT) program was being conducted in compliance with NRC requirements.
The inspectors reviewed LLRT procedures, evaluated test results, conducted walk-downs of.
containment related systems, and reviewed containment isolation valve (CIV) maintenance records.
a.
LLRT Procedure and Administrative Control Review j
The inspectors examined the following documents:
I-PT/1(2)/A/4200/01B Electrical Penetration 0-Ring Leak Rate L
Test (LRT)
i PT/1(2 /A/4200/01C Containa. ant Isolation Valve LRT PT/1
/A/4200/01D Fuel Transfer Tube LRT PT/1
/A/4200/01G Mechanical Penetration Bellows Integrity PT/1
/A/4200/01H Equipment Hatch LRT PT/1
/A/4200/01J Electrical Penetration SF6 Gas LRT PT/1
/A/4200/01L Controlling Procedure for Type B and C LRT PT/1(2 /A/4200/01M Incore Instrumentation Thermocouple Penetration LRT L
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PT/1
/A/4200/01P NF Penetration LRT PT/1
/A/4200/01R Spare Penetrations LRT OP/1
/A/6200/20 Venting and Draining Procedure for Type C LRT Memorandum For File No: CN-180.25: LRT Acceptance Criteria Reactor Containment Building Integrated Leak Rate Test Report (Portion related to Type B and Type C leak Rate measurements for Unit 1 dated November 1987 and Unit 2 datedMarch1989)
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Although every LRT-procedure listed above was not reviewed for the total valve alignment in step by step detail, the inspectors verified that the following attributes were included in the procedures to
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ensure adequate leak rate testing of containment isolation boundaries:
(1) LLRTs were performed at containment integrated leak rate test (CILRT) peak design pressure, (2) The LLRT program utilized approved methods for testing containment penetration boundaries and CIVs, (3) Penetration leakage rates were determined-using the maximum pathway leakage, (4) The criteria and response for LLRTs.and combined leakage rate failure were incorporated in the test program procedures,_
(5) Repairs and modifications to containment isolation boundaries and CIVs were preceded and followed by LLRTs, and (6) LLRTs were performed at the correct frequency.
A detailed review was performed for valves in the following penetrations to verify adequate alignment for venting, draining, and adequate boundary alignment for leak rate testing:
Penetration Description M-212 Nitrogen to Pressurizer Relief Tank M-220 Instrument Air M-235 Pressurizer Sample M-331 Nitrogen to Accumulators M-358 Refueling Water Pump Suction M-377 Refueling Cavity Fill Line From these reviews no problems were identified relative to penetration venting, draining, valve identification, valve alignment, or system restoration, The inspectors were particularly impressed
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H with the licensee's controls for the penetration venting and draining
process.
Procedure OP/1(2)/A/6200/20, which controls these activities, provides pre-determined and approved valve alignments, detailed instructions, and precautions for accomplishing these lineups.
The strict control of these activities ensures that penetrations are properly drained of all fluid before leak rate testing.
Two concerns were identified during the overall review:
1) not performing Type B tests on the D. G. O'Brien electrical penetrations, and 2) pressurizing certain containment isolation valves in the non-accident direction (reverse testing).
These concerns are discussed further in paragraphs 2.c and 2.d below.
The inspectors concluded that with the possible exception of two concerns, the licensee has developed a containment local leak rate measurement program which is consistent with the regulatory requirements of the Technical Specification (TS), Section 3/4.6; 10 CFR 50, Appendix J; and ANSI-N45.4-1972.
b.
Implementation of the Leak Rate Program Implementation of the program to establish and maintain containment leak tight barriers was reviewed.
Records of performance, identification of problems, corrective actions, retest.- and test tance were reviewed for Type C testing.
A detailed review of accep(2)/A/4200/01C was performed for the previous refueling outage on PT/1 Unit 1 (November 1988-January 1989) and on Unit 2 (March-May 1989).
Also, the controlling procedure (summation of measured leakages)
l PT/1(2)/4200/01L, and local leak rate data incorporated into the
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L integrated leak rate test reports (Unit 1, November 1987) and Unit 2 (March 1989) were reviewed.
From review of this data the inspectors determined:
(1) Data sheets in PT/1(2)/4200/01C were correctly completed and the j
data were correctly transferred to Enclosure 13.56 (tabulation of all valve tests).
Test acceptance limits were specified and
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l (2) Test data were correctly transferred to PT/1(2)/4200/01L for l
obtaining the summation of leak rate measurements.
(3) As-Left, maximum path leak rates were maintained well below the allowable 0.6 La leakage limit for Type B and C tests.
(4) Pre-and post-maintenance leak rate testing were adequately controlled through the maintenance work request system.
(5) Tests were performed at the required frequency.
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The inspectors concluded that the licensee has adequately implemented the leak rate program as currently defined, c.
Electrical Penetration Testing D. G.. O'Brien electrical penetrations consist of an 0-ring sealed flange incorporating hermetically glass-sealed electrical connector mcdules welded into the flange.
The modules consist of two electrical connectors welded on each end of a section of steel pipe to form a pressure vessel Electrical insulation within' the connectors is provided by the circumferential glass employed in the hermetic sealing operation.
The penetration assembly is sealed on the outboard end by using a mounting flange with double metal 0-ring seals.
From review of the local leak rate test procedures, the inspectors noted that the licensee performs Type B testing on only the 0-ring seals for the electrical penetrations.
The licensee had previously evaluated the glass to metal conductor seals and determined that Type B. testing was not required based on the design and their interpretation of the requirements of 10 CFR 50, Appendix J.
The inspectors determined that further penetration design and construction data were needed from the licensee and the electrical penetration manufacturer in order to determine if Appendix J Type B testing requirements were met by the licensee for_ the metal conductor seal.
Ttis matter was identified as Inspector Followup Item (IFI) 50-413,414/89-33-01: Review D. G. O'Brien Design Data to Determine If LLRT Requirements Have Been Met.
d.
Reverse Direction Testing The leak rate system engineer identified thirteen valves which were reverse tested (pressurized in the non-accident direction) on Unit 2; a similar number were expected to exist on Unit 1.
Appendix J requires that reverse testing be demonstrated conservative relative to pressurizing the valves in the accident direction. Documentation demonstrating the conservatism of these tests was not available for review.
At the exit interview licensee management agreed to provide the NRC a documented evaluation for reverse tests for Units 1 and 2 by January 3,1990.
This evaluation will be reviewed by the NRC to determine if 10 CFR 50, Appendix J, Type C testing requirements were met. This matter was identified as IFI 50-413,414/89-33-02: Review Licensee's Evaluation of Reverse Testing Certain CIVs.
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c.
Leak Rate Test Maintenance Controls
The inspectors tracked the repair and retest of several valves to determine if controls for these activities were adequate.
A work request for maintenance is generated when a valve fails to pass its-local leak rate test.
This request is sent to maintenance planners who -prescribe the work procedures and post-maintenance testing requirements.
For a Type C tested valve, the Performance Department would automatically be indicated on the work order to have retest responsibility.
When maintenance is completed, the work order package-is routed back to Performance and leakage retest of the valve is performed.
Completion of the work request constitutes verification that all tests have been performed as required.
Based on the sample of work request packages reviewed, the inspectors concluded that the licensee has implemented a workable system to ensure that maintenance and retest of CIVs are satisfactorily.
completed.
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The inspectors discussed programs for trending CIV leak rate test
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failures with the licensee.
The responsibility for tracking leak l
rate test results is assigned to the containment integrity system expert. The system expert is responsible for trending and analyzing parameters. (such as leak rate test data) in an attempt to detect valve degradation and to predict failures.
At this time, manual l
tracking of this data is performed due to the limited number of valve failures which have occurred.
However, the licensee currently plans
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to monitor leak rate test data using the station's existing computer tracking system, Performance Monitoring Data Base System (PMDBS).
The inspectors viewed these plans as positive action toward a more i-
- efficient and effective valve preventive maintenance program.
l Within the areas inspected, no violations or deviations were identified.
3.
VerificationofContainmentIntegrity(61715)
l The purpose of the inspection activities in this area was to verify the
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adequacy and implementation of procedures and controls designed to maintain containment integrity and to mitigate contamination releases in the event containment integrity is lost following a loss-of-coolant accident (LOCA),
a.
Primary Containment Integrity Controls
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The inspectors reviewed Operations Procedure OP/1/A/6100/01,
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Controlling Procedure for Unit Startup, which ensures all necessary plant conditions are established for reactor startup.
It was verified that the procedure included the following minimum provisions that ensure primary containment integrity exists before the plant enters operational modes which require containment integrity:
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(1) All penetrations not capable of being closed by automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges,- or deactivated automatic valves, i
(2) All equipment hatches are closed and sealed.
(3) Each containment air lock is operable, (4) Containment leakage rates are within TS limits, (5) Sealing mechanisms associated with each penetration are operable.
i The inspectors also reviewed procedures. PT/1/A/4200/02A, Monthly Outside Containment Integrity Verification, and PT/1/A/4200/028, Cold
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Shutdown Containment Integrity Verification.
Together these procedures implement TS Section 4.6.1.1.a which ensure containment integrity by verifying that all containment penetrations not capable of being closed by operable automatic CIVs, but required to be closed during accident conditions, are closed by valves, blind flanges, or deactivated automatic isolation valves. The inspectors verified that these procedures included all applicable containment isolation
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boundaries.
Completed records for PT/1/A/4200/02A were reviewed for the previous six months of Unit 1 operation.
Completed records,for L
PT/1/A/4200/028 were reviewed since December 1987.
The inspectors l
verified that all valves were inspected and-found to be in their L
correct position.
Using PT/1/A/4200/02A, the inspectors conducted a visual walk-down of
selected Unit I manual containment isolation valves to verify that these valves were in their required positions. This included visual inspection of 22 outside isolation valves from penetrations M-215, M-216, M-219, M-220, M-277, M-278, M-321, M-337, M-372, and M-373.
The inspectors observed that all valves were either closed or locked closed as required by the procedure, b.
Containment Systems Designed to Mitigate Contamination Releases The following containment related systems designed to mitigate the-consequences of contamination releases following a LOCA were inspected for compliance with plant TSs:
Containment Personnel Air Locks Containment Annulus Ventilation System Containment Purge System Containaent Spray System Hydrogen Recombiners
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The inspectors reviewed the following surveillance procedures and verified that the procedures complied with applicable plant TS l
requirenents,. that adequate information and instruction were provided, and that adequate acceptance criteria and limits were specified:
PT/1/A/4200/01E Upper Containment Personnel Air Lock Leak Rate Test PT/1/A/4200/01F Lower Containment Personnel Air Lock Leak Rate Test PT/1/A/4450/03A Annulus Ventilation System Train IA Operability Test
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PT/1/A/4450/03B Annulus Ventilation System Train IB Operability Test PT/1/A/4450/01A Annulus Ventilation Filter Train Performance Test PT/1/A/4450/03C Annulus Ventilation System Performance Test PT/1/A/4200/41A Containment Purge Valve Leak Rate Test PT/1/A/4200/41B Containment Air Release and Addition Isolation Valves PT/1/A/4200/06C Containment Spray Valve Lineup Verification PT/1/A/4200/048 Containment Spray Pump 1A Performance Test
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PT/1/A/4450/04C Hydro 9en Recombiner Performance Test The inspectors reviewed surveillance records listed in Table 1 for these procedures and verified that the surveillances were performed at the required frequencies, surveillance results met acceptance criteria or limits, and appropriate sign-offs, reviews, and concurrences were performed.
Table 1 Containment System Procedure No.
Records Reviewed TS Upper and PT/1/A/4200/01E 01/26/89 and 06/26/89 4.6.1.3.b Lower Air PT/2/A/4200/01E 01/26/89 and 06/22/89 4.6.1.3.b Locks PT/1/A/4200/01F 01/19/89 and 07/07/89 4.6.1.3.b PT/2/A/4200/01F 01/25/89 and 07/17/89 4.6.1.3.b Annulus PT/1/A/4450/03A 05/21/89 to 10/08/89 4.6.1.8.a Ventilation PT/1/A/4450/03B 05/07/89 to 09/24/89 4.6.1.8.a PT/1/A/4450/01A 08/27/87 and 09/15/88 4.6.1.8.b PT/1/A/4450/03C 09/15/89 4.6.1.8.d Purge Systems PT/1/A/4200/41A 03/28/89 to 10/18/89 4.6.1.9.3 PT/1/A/4200/41B 04/21/89 to 08/11/89 4.6.1.9.4
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Containment System Procedure No.
Records Reviewed TS
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(cont'd)
Containment PT/1/A/4200/06C 04/24/89 to 09/11/89 4.6.2.a Spray PT/1/A/4200/04B 01/15/89 to 07/28/89 4.6.2.b PT/1/A/4200/040 01/19/89 to 10/13/89 4.6.2.b
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Hydrogen PT/1/A/4450/04C 01/05/88 to 08/11/89 4.6.4.2.a Recombiner No discrepancies were observed from review of these records.
The inspection findings indicated that required plant systems and components designed to ensure containment integrity were being tested as required by plant TSs.
Within the areas inspected, no violations or deviations were identified.
4.
ActiononPreviousInspectionFindings(92701)
A previous inspection conducted September 18-22,1989,(SeeNRCInspection Report _ Nos. 50-413, 414/89-27) identified an inconsistency in the licensee's Inservice Testing (IST) of certain check valves. The licensee committed to revise applicable IST procedures and to full flow test these valves within six nonths from the date of the inspection in order to comply with the full flow test guidelines stated in Generic Letter 89-04.
During'this inspection, it was learned that the licensee may not be able to meet the above commitment within the time agreed upon.
At the exit meeting the inspectors requested that the licensee provide NRC (Region II)
their reasons for not meeting this commitment date and their alternate plans in writing.
For tracking purposes, this matter was identified as IFI 50-413, 414/89-33-03:
Review Licensee's Full Flow Testing of Check Valves as Comitted to in NRC Inspection Report 89-27.
5.
Exit Interview
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The inspection scope and results were summarized on November 3,1989, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below. Proprietary information is not contained in this report.
l Item Number Description and Reference 50-413,414/89-33-01 IFI - Review D. G. O'Brien Design Data to Determine If Leak Rate Test Requiremcnts wereHet(paragraph 2.c).
50-413,414/89-33-02 IFI - Review Licensee's Evaluation of Reverse Local Leak Rate Testing Certain Contain-ment Isolation Valves (paragraph 2.d).
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50-413,414/89-33-03 IFl - Review Licensee's Full Flow Testing of Check Valves as Connitted to in NRC Inspection Report Nos. 50-413,414/89-27 (paragraph 4).
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