IR 05000416/1988013

Insp Rept 50-416/88-13 on 880606-10.No Violations Noted. Major Areas Inspected:Local Leak Rate Testing & Verification of Containment Integrity

ML20207D478
Person / Time
Site:	Grand Gulf
Issue date:	07/28/1988
From:	Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207D475	List: IR 05000416/1988013 ML20207D471
References
50-416-88-13, NUDOCS 8808150360
Download: ML20207D478 (9)

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' e UNITED STATES p-p3 f f 00q'o NUCLEAR REGULATORY COMMISSION

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Report No.: 50-416/88-13

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Licensee: System Energy Resources, In Jackson, MS 39205 Docket No.: 50-416 License No.: -NPF-29 Facility Name: Grand Gulf Inspection Conducted: June 6-10, 1988 Inspector: b I.$ ~/ - 27- 88 goH.L. Whiten)r Date Signed Accompanying Personnel: J. Zeiler Approved by: // wt ,_ ?/Ay/

D' ate Signed F. Jape,ing BranchCMief,'

Engineer r Test' Program p ection Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspec' .n was conducted in the areas of local leak rate testing and veritscation of containment integrit Results: 'In the areas inspected violations or deviations were not identifie BS$ejggg$ $$[ j6

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REPORT DETAILS

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-1.- Persons Contacted Licensee Employees

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• L. F. Daughtery, Supervisor Compliance M. Dietrich, Supervisor, Internal Audits

• J. P. Dimmette, Jr., Manager, Plant Maintenance R. E. Douglas, Acting Supervisor, Mechanical Maintenance

• C. R. Hutchinson, General Manager

• A. L. Malone, ISI Coordinator R. V. Moomaw, Assistant Manager, Maintenance

• J. H. Mueller,. Mechanical Superintendent J. Summers, Compliance Coordinator Other licensee employees contac'ed during this inspection included craftsmen, engineers, operators, and administrative personne NRC Resident Inspectors

• R. Butcher, Senior Resident Inspector

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J. Mathis, Resident Inspector

• Attended exit interview Purpose The purpose of this inspection was to verify the development and imple-mentation of programs, controls, procedures, and test activities which ensure that containment integrity is established, monitored, and main-tained consistent with the requirements of the Technical Specifications, Appendix J of the 10 CFR 50, and applicable industry standard . Local Leak Rate Testing (61720)

An important part of monitoring and maintaining containment integrity is the periodic testing performed to verify the leak tightness of containment leakage barrier 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: Administrative Controls 1) 01-S-06-12, Revision 15, GGNS Surveillance Program 2) 01-S-06-5, Revision 17, incident Report / Reportable Events 3) 01-S-07-1, Revision 19, Control of Work On Plant Equipment And Facilities Ir

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4) 01-S-07-2, Revision 10, Test And Retest Control 5) 01-S-07-28, Revision 6, Control Of Work On ASME Section XI Components Test Controls-1) 06-ME-1M23-V-0001, Revision. 28, Contair. ment And Drywell Airlock Seal Leak Test 2) 06-ME-1M61-V-0001, Revision 32, Local Leak Rate Test 3) 07-S-74-(Series) local Leak Rate Test Valve Alignment Instructions 4) 09-S-08-1, Revision 2, Local Leak Rate Test Results Analysis 5) CILRT Report, Unit 1, November 1985 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 eight different components shown below:

Penetration Component Task Card Alignment Procedure Description 9 B21F010A ME0070 07-S-74-821-2 Feedwater Check Valve 44 P42F035 ME2794 07-S-74-P42-1 CCW Return 37 P72F121 ME2948 07-S-74-P72-1 Plant Service Water 50 P45F067 ME2756 07-S-74-P45-1 Orywell and Equipment Sump Drain 5 B21F022A ME2602 -07-S-74-B21-1 MSIV 5 821F028A ME2601 07-S-74-B21-1 MSIV'

21 E12F0288 ME2836 07-S-74-E12-2 RHR TO LPCI 49 EG36F101 ME2930 07-S-74-G3C-1 Transfer Pump Dis-charge f Partial review of other penetrations was also performed and no l problems were identified relative to venting, draining, valve

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identification, valve alignment or system restoratio The

inspectors further verified (based on a 50% sample) that valves l requiring Type C testing in Technical Specification Table 3.6.4-1 are included in the test procedur Although every procedure listed above was not reviewed for the total

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valve alignment in step by step detail, based on the sample reviewed, the inspector concluded that programmatically the licensee has developed a containment local leak rate measurement program which is i

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consistent with the regulatory requirements of the Technical Specification, Section 4.6; 10 CFR 50, Appendix J; and ANSI-N45.4-197 During review of the above procedures, one minor concern was identified and discussed with licensee engineers. On data Sheet I of Procedure 06-ME-1M61-00G1, the licensee uses a correction factor to correct Rotometer readings for slight variations in temperature and pressure from those used in the instrument calibration. At the exit interview, the licensee agreed to contact the vendor to determine if this factor should be a square root function. Subsequent to the inspection, a licensee representative in' rmed the inspector that contact with the Rotometer vendor confirmed that the correction factor is a square root function and the procedure is in the process of being revised. Evaluation shows that there is not significant impact on test results. Test controls are such that the value of the correction factor is essentially one; therefore, the factor does not significantly affect the test results. The inspector had no further questions on this matte In addition to the procedure reviews, the inspectors witnessed the local leak rate test on the containment airlock seals. No problems were identified in the perfonnance of the tes Implementation of the iicensee's program for establishing and maintaining containment leak tight barriers was also reviewe Records of perfo rmance, identification of problems, corrective actions, retest and test acceptance were reviewed for Type C isolation valve testing. A detailed review of Type C testing on the components listed above was performed for the period August 1986 through January 1988. This period includes refueling outages one and two. From the data packages reviewed, the inspector determined:

1 Type C tests are being performed at the required times; 2{ "As found" and "as left" leak rate data are recorded; 3f Maintenance Work Orders (MWO) and Test / Retest control Forms were complete and correlated to the test results according to administrative controls; and, 4) Task Cards were issued for initial test Task Cards are issued for each initial Type C tes These cards have l a unique number identifying a specific component and specify the schedule, the test to be performed and the test procedure. If a valve

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fails the test a MW0 is issued. With each MW0, a Test / Retest Control Form is issued. This process ensures that the test, maintenance and retes t are successfully completed and reviewed by the mechanical maintenance superintendent, ISI Coordinator, and operations. The i _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - -

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inspector tracked the Type C test, repair, MWO and Test / Retest documentation for the components listed above for the 1986 and 1987 refueling outages. No problems were identified in the implementation of the control syste The summation of the combined Type B and C local leak rates is performed according to procedure 09-S-08-1. The ISI Coordinator reviewed all Type B and C test results and maintains a running summaticn of the combined local leakage. The inspector reviewed this ' data from October 1985 through June 1988, and. concluded that a current running total of the combined leakage rate is maintaine No violation, deviations or unresolved issues were identified in program

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implementation. The inspectors concluded that the licensee has implemented

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an adequate program to monitor and maintain the containment leakage barrier . Verification of Containment Integrity (61715)

The adequacy and implementation of the licensee's program designed to ensure and maintain containment integrity was assessed by reviewing the technical adequacy of surveillance test procedures, surveillance test records, administrative controls designed to ensure containment integrity, and conducting personnel interview Procedures Reviewed OP-1M10-M-0001, Revision 28, Containment and Drywell Penetration Isolation Monthly Check OP-1821-R-0006, Revision 30, Containment, Drywell and Auxiliary Building Isolation Valves OP-1821-V-0001, Revision 23, MSIV Operability Test OP-1M71-Q-0002, Revision 25, Containment and Drywell Instrumen-tation Valve Operability Test OP-1E21-Q-0002, Revision 25, LPCS MOV Functional Test

• ME-1M23-V-0001, Revision 28, Containment and Drywell Af riock Seal Leak Test ME-1M23-R-0001, Revision 26, Personnel Airlock Door Seal Air System Leak Test

• OP-1E32-M-0001, Revision 21, MSIV Leakage Control System Blower Test

• EL-1E32-M-0001, Revision 22, MSIV Leakage Control System Heater Operability Functional Test

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OP-1E32-C-0002, Revision 26, MSIV Leakage Control System Cold Shutdown Valve Test OP-1E32-R-0003, Revision 29, MSIV Leakage Control System Functional Test OP-1000-D-0001, Revision 33, ' Daily O'perating Logs

OP-1E61-SA-0002, Revision 21, Primary Containment Hydrogen Recombiner Operability 0P-1E61-R-0005, Revision 21, Primary Containment Hydrogen Recombiner Heatup Test OP-1E12-M-0001, Revision 23, LPSI/RHR Subsystem A Monthly Functional Test OP-1E12-M-0002, Revision 21, LPSI/RHR Subsystem B Monthly Functional Test OP-1E12-Q-0023, Revision 28, LPSI/RHR Subsystem A Quarterly Functional Test OP-1E12-Q-0024, Revision 26, LPSI/RHR Subsystem B Quarterly Functional Test OP-1E12-R-0022, Revision 23, RHR Containment Spray Initiation Logic System Functional Test b. Scope of Procedure and Record Review The inspector reviewed the abose surveillance procedures either totally or partially to verify their technical and administrative adequacy. _ The procedures were reviewed to verify applicable tech-nical specification requirements were met, adequate _ information and instructions were provided, and adequate acceptance criteria and limits were specifie The inspector also reviewed records of the above surveillance tests to ascertain the availability of these system Those containment systems involved in this review included the following areas:

Containment isolation valve alignment, operability, and stroke times (abbreviated as CIV)

Containment personnel airlock (abbreviated as CA)

MSIV Leakage Control System (abbreviated as MSIV-LC)

Containment internal pressure and temperature limits (abbreviated as CPT)

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Containment combustible gas monitoring system (abbreviated as CCGM)'

Containment Depressurization System - Suppression Pool (abbrevi-ated as CDS-SP)

Containment Depressurization System - Containment Spray (abbre-viated as CDS-CS)

Surveillance test records were reviewed to verify that the procedures were performed at the required frequencies; to- verify that test results met acceptance criteria and to ensure that appropriate retests or post-maintenance activities were prescribed as required for failed tests; and, to verify that administrative controls of test results were followed. The following records associated with the previously mentioned containment related and post-LOCA mitigating systems were reviewed by the inspector. Also shown is the applicable Technical Specification which requires the surveillance tes Contsinment Ss. tem Procedure N Records Reviewed TS CIV OP-1M10-M-0001 10/26/87 through 05/08/68 4.6.1. CIV OP-1821-R-0006 11/20/86 through 01/03/88 4.6. CIV OP-1821-V-0001 09/14/87 through 03/12/88 4.6. CIV OP-1M71-Q-0002 02/05/87 through 05/13/88 4.6. CIV .0P-1E21-Q-0002 11/06/86 through 03/20/88 4.6. CA ME-1M23-V-0001 06/01/88 through 06/06/88 4.6.1. CA ME-1M23-R-0001 11/25/85 through 12/24/87 4.6.1.3. MSIV-LC OP-1E32-M-0001 12/31/87 through 05/28/88 4.6.1.4. MSIV-LC EL-1E32-M-0001 01/11/88 through 06/03/88 4.6.1.4. MSIV-LC OP-1E32-C-0002 10/19/85 through 12/17/87 4.6.1. MSIV-LC OP-1E32-R-0003 12/05/85 through 11/33/86 4.6.1.4. .6.1.4.c. .6.1.4.c. CPT and OP-1000-0-0001 04/01/88 through 04/30/88 4.6. CDS-SP 4.6. .6.3. .6.3. CCGM OP-1E61-SA-0002 08/18/86 through 12/30/87 4.6.7. CCGM OP-1E61-R-0005 08/23/86 through 12/30/87 4.6.7.1. .5.7.1. .6.7.1. CDS-CS OP-1E12-M-0001 01/11/88 through 05/11/88 4.6.3. CCS-CS OP-1E12-M-0002 01/04/88 through 06/02/88 4.6.3. CDS-CS OP-1E12-Q-0023 11/10/87 through 03/18/88 4.6.3. CDS-CS OP-1E12-Q-0024 10/13/87 through 06/03/88 4.6.3. CDS-CS OP-1E12-R-0022 10/10/85 through 01/01/88 4.6.3. __-_-__-__ -__--. _ _ _ _ _ - - _ - _ _ - - _ _ _ _ _ - _ - -

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l 7 Findings Summary The procedures reviewed were technically accurate and in conformarice with technical specifications and administrative requirement No unacceptable conditions were observe The inspector's review of surveillance test records resulted in the discovery of only one deficiency which was brought to the attention of licensee managemen The inspector identified what at first appeared to be the performance of a MSIV ' operability ;et=t using an improperly . calibrated (overdue) piece of. test equip '.nt storwatch).

Further investigatior, by the licensee of calibratic , rec irds showed that the stopwatch used had been calibrated appror 'iateif and the prob?em was the incorrect entry of the stopwatch ca ibratio.' due date in the test procedur The inspector's only_ other concern 1.'. this matter was that the licensee's test review and c proval pocess failed to identify what appeared to be the use of t.est equipment with an overdue calibration. However, considering the large volume of records reviewod by the inspector, this problem was considered an isolated instance and not indicative of progrannatic breakdowns. No other pro'olems or concerns were found in the *nspector's record

, revie . Quality Assurarce and Quality Controls The inspector interviewed a management representative of the plant Quality Assurance department to determine QA/QC involvement in containment related activities. QA audit reports were also reviewed for activities related to containment leak rate testing and drywell structural integrity. The inspector determined, based on this review, that QA provides adequate coverage of containment leak rate testing activities and that QA findings and evaluations are well documente No unacceptable conditions were identifie , Action on Previous Inspection Findings (92701) (Closed) IFI 416/86-0'.-J3, Inspect Test Results for Rod Sequence Exchange at Power The inspector reviewed the licensee's Safety Evaluation, ap,wo>ed by the Plant Safety Review Committee on November 21, 1986, con;e:ni 1g <

the deletion of the Control Rod Sequence Startup Test. This st.ortup test was classifi de as being non-essential as determined by tne criteria providec in NRC Question 423.22 of the FSAR. The test was deleted in Revision 1 of the UFSAR, dated December 1986. The inspector had no further questicns in this area and considered this item closed.

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, (Closed) IFI 416/86-01-04, Inspect Test Results of Fuel Pool Heat

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Exchangers e

.(Closed) IFI 416/86-01-0F, Inspect Test Results of RHR Steam Condensing Mode (Closed) IFI 416/86-01-00, Inspect Test Results of Floor Drain Evaporator Performance and Heat Load-(Closed) IFI 416/86-01-07 Inspect Test Results c.f Chemical (faste Evaporator Performance and Heat Load A previous inspection identified these startup tests as not having been performed. The licensee reported that the systems were still untested and had not been placed into service. Testing of these systems is required, per the FSAR, before the systems are placed into service. For tracking purposes, these items will be closed and carried under the new inspector followup item created in this report as follows:

IFI (416/88-13-01): Inspect Test Results of Fuel Pool Cooling Heat Exchangers; RHR Steam Condensing Mede; Floor Drain Evaporator Performance and Heat Load; and, Chemical Waste Evaporator Performance and He:t Loa . Exit Interview The inspection scope and resa!t:; were summarized on . June 10, 1988, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection result Propri-etary information is not contained in this repor i

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