IR 05000423/1985011

Insp Rept 50-423/85-11 on 850325-28.No Violation Noted.Major Areas Inspected:Containment Leakage Testing Program, Including Procedure Review of Preoperational Integrated Leak Rate Test & Structural Integrity Test

ML20128A038
Person / Time
Site:	Millstone
Issue date:	05/16/1985
From:	Bettenhausen L, Bettenhauser L, Gesalta L, Kucharski S, Vito D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128A007	List: IR 05000423/1985011 ML20128A003
References
50-423-85-11, NUDOCS 8505240107
Download: ML20128A038 (8)

Text

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,b- [ U.S. NUCLEAR REGULATORY COMMISSION-REGION I

' Report-N /85-11 Docket No. 50-423 License No. CPPR-113 Priority --

Category C Licensee: Northeast Nuclear Energy Company P. O. Box 270 -

Hartford, Connecticut -06101 Facility Name: Millstone Nuclear Power Station, Unit No. 3

' Inspection At: Waterford, Connecticut Inspection Conducted: March 25-28, 1985 Inspectors: -

D. J. Vi , Reactor gineer / date 11 -

S. Kuchar E1 Reactor Engineer v6Ar

/ dat'e b

L. Gesalta, Philippine Atomic Y3

date V

. Energy Commission (Observer)

Approved by: 8 L. H. Bettenhausen, Chief, date Operations Branch, DRS Inspection Summary: -Inspection on March 25-28, 1985 (Inspection Report No. 50-423/85-111 Areas Inspected: Routine, unannounced inspection of the containment leakage testing program including procedure review of the preoperational Integrated Leak Rate Test (ILRT), Structural Integrity Test (SIT) and Local Leak Rate Test (LLRT) procedures, LLRT test witnessing and test results review, and general tours of the facility. 'The inspection involved 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> by two region based inspector Results: No violations were identifie PDR ADOCK 05000423 G PDR

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DETAILS-1. ' Persons' Contacted Northeast Utilities / Stone & Webster J. Barnes, Lead Test Engineer-S&W

D. Blumenthal, NUSCO Construction QA

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• J. Connolly, ILRT/LLRT Test Engineer G. Cox, Computer Services Engineer-NUSCO A. Dominguez, Test' Engineer-NUSCO

• M. Gentry, Assistant Startup Supervisor-NNECO K. Gray, Staff Assistant-NUSCO CQA

. A. Gulesserian, Assistant Project Engineer-NUSCO

• J. LaWare, NUSCO Construction QA B. Lawton, Structural Engineer-S&W

• R. .Martel, Startup Engineer-S&W

'D. Miller, Startup Manager-NNEC0 0. Taylor, ILRT/LLRT Test Engineer R. Viviano, Assistant Project Engineer-NUSCO U.S.'IRC

• T. Rebelowski, Senior Resident Inspector

• Denotes those present at exit meeting on March 28, 1985. Containment Local Leakage Rate Testing 2.1 Cocuments Reviewed

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Preoperational Test Procedure T3312 AIM 03, Local Leak Rate Test-Type C, Revision 0, Approved October 11, 1984

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MNPS-3 FSAR Section 6.2.6, Containment Leakage Testing

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Calibration Records for LLRT Test Boxes

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Test Results for LLRT's performed to dat Selected Piping and Instrument Drawings l

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-W The inspector reviewed the above listed documents to determine

, -compliance with the regulatory requirements of Appendix.J to

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10 CFR'50,-draft Technical Specifications and applicable: industry.

E -standaFds and with station administrative guidelines. The inspector-

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also witnessed selected local leak rate testing activities.and held

~ discussions with test personnel;regardin'g-the organization and control _of;the~LLRT program ~and-the documentation of test'result Further details are discussed belo /2.3 iProcedure Review

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7The Type'C test-procedure wasitechnically accurate and in conformance with the regulatory requirements of Appendix J to 10 CFR 50 and ap-11 cable industry standards. Valve lineups are being verified by' test

personnel-via walkdowns prior to.the tests.to assure that' appropriate u lineup drawings exist in the'LLRT procedure and that the valve line-

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. ups reflect design configurations. The' inspector verified several

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of these valve: lineups:during-tours of the inside and outside of the s

Jcontainment building. :No. unacceptable conditions were identifie *1 2.49 Test' Witnessing-l0n March 26, 1985,..the inspector witnessed the post-maintenance Type C leakage' testing of the nitrogen supply line isolation valves

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3GSN*CTV105'and 3GSN*CTV8033. The test.was conducted in accordance

, ytth an approved procedure and the results were acceptable. The inspector verified the documentation of the test results. The-inspector observed the test personnel to be familiar with the test l equipment and knowledgeable of the valve lineup and the:use of the'

. procedure. No unacceptable conditions were identifie , 2.5 LLRT Instrument Calibration

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.The inspector.rev_tewed.the calibration records for the rotameters

and pressure gages used in the LLRT test boxes. The instruments

were appropriately. calibrated and were marked with current cali-

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bration stickers. No unacceptable conditions were identifie _

2.6 Test Results

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, The inspector reviewed the LLRT results summary and discussed analysis of the test results and the status of repairs and retests with test personnel. The inspector noted that the test results of zero-leakage were being recorded for LLRT's during which the float-material'in the lowest scale rotameter did not discernibly move. The inspector. stated that a conservative approach would be to record a leakeage equal.to one-half of the smallest increment marked on the rotameter scale. The test personnel acknowledged the inspector's

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observation and agreed to change the procedure and recorded results

'accordingly. The inspector had'no further questions at this tim '

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-3. Containment-Integrated Leakrate AND Structural Integrity Test Documentation Review 3.1 : Documents Reviewed

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Preoperational Test Procedure 3-INT-2002, Integrated Leak' Rate-Test and Structural Integrity Test, Rev. O, January 18, 1985, g(draft).

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MNPS-3 FSAR

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Section 6.2.6, Containment-Leakage Testing

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_ Table-14.2-2, Item 15-Preoperational. Test-LLRT

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Table 14.2-1, Item 70-Preoperations1 Test-ILRT

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NUREG-1031, Safety-Evaluation Report Related to the Operation of Millstone Nuclear Power Station Unit 3, July 1984

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Preoperational~ Test Procedure T3312BP, Containment Leakage Monitor, Rev. O, Approved February 15, 1985

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. Stone & Webster Calculation US(B)-297, Temperature Sensor Placeraent Analysis, January 30, 1984

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Stone & Webster Calculation US(B)-317, ILRT Parameters, February 22, 1985-

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Stone & Webster Purchase Specification 2190.070-725, Structu-ral Acceptance Test for Concrete Primacy Reactor Containment

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Draft Technical Specifications 3/4.6.1.1 Containment Integrity 3/4.6.1.2 Containment' Leakage 3/4.6.1.3 Containment Airlocks

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Calibration Records for ILRT Pressure Instruments

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Selected Piping and Instrument Drawings 3.2_ Scope of Review The inspector reviewed the above listed documents for technical adequacy and to determine compliance with the regulatory require-ments of Appendix J to 10 CFR'50, FSAR preoperational testing com-

.mitments and applicable industry standards (ANSI N45.4-1972 and

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ASME Section III, Division 2, Article CC-6000). The inspector also

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_ performed an independent calculation of the allowed leakage rate (La) and of several of the RTD volume fraction .'I

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3 .' 3 Procedure Revie "

-The-inspector reviewed the:most recent draft of the ILRT/ SIT Proce '

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dure (3-INT-2002) .for technical. adequacy and for consistency with-

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- regulatory , requirements, guidance,' and licensee commitments. The-inspector.noted severalsprocedural deficiencies relating to test ,

.and calculational methods. These deficiencies are delineated as follows:

, J Use of Mass' Point Calculation t

The' inspector noted that'although',the Mass Point leakage rate was calculated by the ILRT program, it was not men-

'tioned in the procedure for comparison to test acceptance criteria. Although the BN-TOP-1 Total Time method and its related trending requirements -are :useful for indication of s

potential sensor malfunctions, the Mass Point leakage rate calculation is more physically accurate-than the Total Time

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calculation when the data set is statistically accurat The test coordinator acknowledged that the NUSCO-ALERT-

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program (same- ILRT-program used on Millstone -1, Millstone 2, and Haddam Neck) dces calculate a Mass Point leak rate and an _ associated 95% Upper Confidence Limit (UCL) on the Mass Point leak rate. The test coordinator agrcad to include the Mass Point calculation in the procedure and to compare its calculated 95% UCL leakage to the test acceptance cri-terion(50.75La). Minimum Test Duration The procedure stated that the ILRT could be-completed in as little as six hours. ~The inspector stated.that the NRC position on the minimum time for short duration ILRT.was eight hours. The test coordinator had no problem with this and agreed to change the procedur Volume Fractions .

The inspector performed several independent calculations of the containment volume fractions for the RTDs to be used during -the ILRT. The results of the independent calculations revealed a number of errors in the Stone &

Webster calculation (US(B)-297). The inspector asked that the volume fraction calculations be rechecked prior to the performance of the ILRT. The test coordinator committed to-do this and change the procedure if necessar E__- _____ __'

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Also,~the procedure stated that an equal volume fraction of 0.2;would be1 assigned to each of the five (5) dewcells

• because " containment air will be-homogenous and relatively Ldry." iThe inspector stated that the Itcensee should wait

. -until'the dewpoint surveys are taken (per Preoperational

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' Test Procedure T3312BP, Rev. O, Approved February 18~ 1985)-

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-to determine the validity of this_ statement. There are two

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dewcells. located in the dome area:of containment and three

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located in the_ lower compartments. :The dewpoint surveys-

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-should be used not only for verifying volume fractions but for providing guidance for volume fraction reassignment w -

should one or more of_the dewcells fail during the tes ' We N Channels The Millstone 3 Safety Evaluation Report (NUREG-1031) has

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specifically stated that a technical justification should

.be provided by~the applicant to demonstrate the integrity

'of the' weld channel design. This information-is to be-reviewed by NRC to determine whether or not the containment s

liner weld channels should be' vented during the ILRT. The inspector wac provided with ~a copy of Stone & Webster Cal-

.culation 12179-NS(B)-149, Leak Chase Analysis, February 12, 1985. The calculation contained infsrmation similar to that provided by other reactor licensees who have been

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exempted from venting-the liner weld channels during the ILRT. However, the test coordinator could-not provide definitive' proof that NRR had approved this justificatio The inspector stated that this item would have to be resolved prior to performing the ILRT without venting the containment. liner weld channel Structural Integrity Test (SIT) Procedure Content The instructions for pressure increases, decreases, and holds during the SIT Sequence are in'cluded in the main-body of 3-INT-2002. The test method and data analysis portions of the SIT are included in Appendix N to 3-INT-2002. The inspector noted that although Appendix N was formatted in accordance with ANSI 18.7-1976, there was a limited amount of_information contained in each procedural section. Al-most all of the procedural steps referred to a specific reference (2.3) for additional detail. This reference is the Stone & Webster Purchase Specification for the SIT (Spec. 2190.070-725). The inspector noted that a reference which contains so much information pertinent to the perfor-mance of the test should not be considered a reference but a part of the procedure. Test personnel have agreed to

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either integrate the Specification into 3-INT-2002 or to attach it as an additional Appendix. This will be verified by the inspector prior to the performance of the tes F

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f. , : FQC Verification- for SI I iThe inspector noted that while FQC verification of SIT strain gage installation was included as a procedural pre-

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requisite, there was no mention of FQC verification'of the:

installation of the deflection ~fnstruments. The test coor--

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'dinator_ stated that this changewill be made-to the proce-

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The procedural deficiencies listed above 'are to be resolved'

prior to'the performance of the ILRT/ SIT.and are collectively '

L designated as Unresolved Item 50-423/85-11-0 ~

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-3.4 lILRT Instrumentatio f The inspector _ reviewed the calibration records.for the.two preci-sfon pressure' detectors. The calibrations met applicable accu-

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racy requirements and were traceable to the National Bureau of ,

Standards. -The calibration records for the RTDs and dewcells were not available-for inspection.. These records will-be re-'  ;

viewed during'a future NRC:RI inspectio . Independent Calculation

The inspector performed an independent calculation of the allowed leakage '

(rate (La) to determine 3-INT-2002) if the leakage for the verification band reported test superimposed in the

>1eak was' procedure appropriat The inspector determined the superimposed leakage band in the.ILRT proce-1 dure to be acceptable. .Also, the. inspector performed independent calcula - *

'tions.of several of the RTD volumes and volume fractions. The majority o the independently calculated values were slightly different than those re -

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ported in Stone & Webster Calculation US(B)-297,-January 30, 1984. The

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-inspector brought this to the attention of test' personnel. While the in-spector acknowledged that small volume differences will have minimal effects:

on test results due' to the large volume of the containment (~2.3X10 I ft.3),

it was also noted that a large number of small errors could cumulatively

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cause a.significant' problem. The inspector requested that the RTD volume fraction' calculations be rechecked prior to the performance of the ILR .This was. identified previously as a part of Unresolved Item 50-423/85-11-0 _

. A/0C Involvement Preoperational LLRT, ILRT and SIT activities are to be monitored on a

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sampling basis by QA/QC personnel. The inspector verified this through

. discussions with QC monitoring' personnel, by observation of their mont-toring activities, and by review of QC checklists. The checklists indi-cate-that the more.important portions of these testing activities will be monitored by QC personnel. No unacceptable conditions were identifie .

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The . inspector made several tours of 'the containment building; exterior containment penetration areas, the control room and other areas of the '

facility to observe' containment leakage testing activities, component tag '

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ging, other work in progress and~ general housekeeping.-'No unacceptable conditions were identifie .

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c Exit Meetin A meeting was held on' March 28,.1985 to di. cuss the' scope and' findings of-

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the-inspection as delineated in this _ report. Ac no time during this in-- ,

spection was written information provided ta the license w

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