IR 05000445/1989039
| ML20247L120 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/17/1989 |
| From: | Ray Azua, Seidle W, Singh A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247L088 | List: |
| References | |
| 50-445-89-39, 50-446-89-39, NUDOCS 8908010148 | |
| Download: ML20247L120 (7) | |
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APPENDIX-
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION'IV-
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LNRC Inspect 1on Report: 50-445/89 39-Construct' ion Permits: CPPR-126 5C-446/89-39 CPPR-127..
Dockets:: 50-445-
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Licensee: TV. Electric 400 North Olive", L.B. 81 LDallas,sTexas 75201-
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Fasility Name: Comanche l Peak Steam Electric Station (CPSES)
- Inspection-At: CPSES. Glen Rose, Somervell County,, Texas InspectionCondbeted: June 26 through July 6, 1989
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Inspectors:-
Sh W 7/il P
A. Singh,\\Mactor Inspector, Plant-Systems.
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Section, Division of Reactor Safety
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T. V. Azua7 Reactor Inspector, Test Programs
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s Section, Division of Reactor Safety
' Approved:
7//7/87
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W. C. SeidleQ Chief, Test Programs Section Date Division of Reactor Safety L
Inspection Sumary-Inspection Conducted June 26 through July 6, 1989 (Report 50-445/89-39)
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l Areas-Inspected: Routine, announced inspection of the Comanche Peak Steam Electric Station.:(CPSES), Unit I containment integrated leak rate test (CILRT).
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\\k 8908010148 890718 PDR ADOCK 0500044S.
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Results:. Within the area inspected, no, violations or. deviations were
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identified. The CILRT'and administrative procedures were reviewed with an observation made with regard to the vagueness of.the tagging requirements in
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the CILRT. procedure. A plant walkdown was performed and a portion of the valve lineup was reviewed along with the controlled copy of the test procedure. No
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concerns were raised, but an observation was made with regard to the tagging process-(i.e..'twodifferenttypesoftagswereused)..Thetestdatawere j '
reviewed, using the NRC CILRT computer code. No concerns were raised in this-
= area. The-conservatism and attention to detail demonstrated by the licensee.
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personnel, during the conduct of this test were found to be worthy of. notice.
. Inspection Conducted June'26 through July 6, 1989 (Report 50-446/89-39)
Areas Inspected: No inspection of CPSES, Unit 2 was conducted.
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DETAILS:,
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Persons Cont' acted
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TU Electric f
- H. Bruner Senior Vice President, TU Electric
- M. R. Blevins,- Manager, Nuclear Operations Support
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'*W. Guldemond, Manager, Site Licensing.
S. Ellis, Manager, Performance & Testing-
-J. O. Martin, Initial Startup (ISU) Manager, Performance & Testing
- S.-Palmer, Stipulation Manager
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- T. Rcbbins, Containment Integrated Leak Rate Test (CILRT) Director, i
Performance & Testing
- J. Greene. Site Licensing L. Gilliam Engineer, CILRT Test Support, Performance & Testing Bechtel
.A. Salley'. ILRT Consultant
- B. Patel, ILRT. Consultant l.
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- E. Ottney, Program Menager
- M.'Thero. Training
- 0. Thero, Consultant NRC
- R. Warnick, Assistant Director for Inspection Programs J. Wiebe Senior Project Inspector.
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- S. Bitter, Resident Inspector, Operations
- Denotes those present during the exit interview held on July 3, 1989.
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The NRC inspector also interviewed other licensee employees during the course of the inspection.
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CILRT Procedure Review (70307)
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i The NRC inspectors reviewed Procedure No. EGT-701A,-Revision 1, j
" Containment Integrated Leak Rate Test."
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J The NRC inspectors reviewed.the procedure to verify that the licensee had incorporated the associated regulatory requirements and commitments.
In addition, the procedure was verified to have the proper approvals, as
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indicated by appropriate signatures.
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1 The NRC inspectors chose some randomly selected systems (containment spray
. system, component cooling water system, and safety injection system),
which were addressed in Procedure No. EGT-701A, Attachment 3, for review against the~ licensee's piping and instrumentation diagrams (P& ids). This
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was.done to determine, with reasonable assurance, that all the appropriate valves in the selected systems were addressed in the procedure. The NRC inspectors also reviewed the test position of the valves, 10 ted in the
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same procedure, to verify that the associated systems were placed in ccrrect alignment for the performance of the CILRT.
l-The CILRT procedure deicribed the method in which the CILRT was to be performed. The Tyre a test method chosen by the licensee was the Mass Point Analysis Tr.chnique, as described in ANSI N56.8-87, " Containment System Leakage Testing Requirements." The test duration was set at g
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24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by the NRC (stated in the Federal Register, u
Volume 53, No. 220, dated November 15,1988) whenever a licensee chooses to use the Mass Point Analysis Technique. The NRC inspectors reviewed the licensee's test method and found it to be technically adequate.
The NRC inspectors reviewed the temporary changes that were made to Procedure No. EGT-701A, and found them to be acceptable. The licensee did not alter the technical content of the procedure or change the way in which the test was being perfe w d.
The NRC inspectors also verified that these changes were apprwved, 6. iadicated by the appropriate signatures.
During the review of Procedure No. EGT-701A, the NRC inspectors noted that TV Electric's Administrative Procedure No. STA-605, Revision 6, " Clearance and Stfety Tagging," dated July 16, 1988, was listed as a reference document. This administrative procedure listed the criteria for using the
" TEST IN PROGRESS" tags, and required that plant personnel have proper authorization prior to removing these tags or altering the position of the tagged equipment.
In addition, the administrative procedure described the
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methodology used for independent verification. The NRC inspectors noted
that this reference was not addrested in the body of the procedure and that there was no direct requirement for any of the valves or equipment to be tagged prior to, or during, the performance of this test, nor was there a requirement on how post line up verification was to be conducted.
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imperative, during the performance of the CILRT test, that all the proper systems be subjected to the test pressure, and that there are no systems
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that are masked due to inadvertent valve closure or inadequate valve l
alQnment. One method used to assure this is the tagging process, with a l
well defined independent verification program. The valve alignment l
program described in CILRT Procedure No. EGT-701A was vague in the area of verification and tagging and was open to interpretation (i.e., tagging could be considered optional, with full faitt being placed on the operators and other plant personnel to identify the valves being used in the test). The NRC inspectors relayed this observation to the license _ _ _,
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The NRC inspectors also reviewed the training records abd qualifications of the TV Electric personnel and operatnrs involved in the CILRT and verified that they met the requirements set forth in Training
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Procedure IRA-311, Revision 0, " Test Department Qualification," dated i
April 4, 1988.
In addftion, the NRC inspectors reviewed Training j
Procedure No. TRA-304, Revision 4, " Instrumentation and Control Section
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Training Program (Interim)," dated Nov(mber 21, 1988; and Training Procedure No. TRA-321 Revision C, " Instrumentation and Controls Section Training Program," dated November 21, 1988. These procedures listed the qualification and training requirements far the instrumentation and controls (180) personnel involved in calibrating some of the, test equipment used in the CILRT. The NRC inspectors also reviewed the training records of these I&C personnel. The procedures and the lesson plans were found to be acequate. The TU Electric plant personnel involved with the CILRT were found to have met all the requirements set forth in the above stated procedures.
No violations or deviations were identified in the review of this program area.
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CILRT Surveillance (70313)
The NRC inspectors performed several tours of the containment building and the auxiliary building. This was done to inspect the test equipment installed for the CILRT and to monitor the valve lineup process.
The valve lineup process was performed using Attachment 3 to Procedure No. EGT-701A, along with other sert 4 ns of the procedure. The NRC
. inspectors noted that two types or M Js were being used for the CILRT valve. alignment. One type was the 'EST IN PROGRESS" tag, which was covered in Procedure No. STA-605, and the other type was a local leak rate test (LLRT) tag.
It was noted by the NRC inspectors that the LLRT test tag did not list the valve position, nor did it identify the valve number, whereas the " TEST IN PROGRESS" tags provided all of this information. The NRC inspector reviewed the tagging procedure, STA-605, to determine the effectiveness of this tagging process. The NRC inspectors found the tagging procedure to be acceptable and that the " TEST IN PROGRESS" tags were easily recognized by the plant personnel who had been trained on the meaning of these tags. The LLRT tags, on the other hand, did not correctly identify the test in progress and were not as widely identifiable by all the plant personnel. Tha NRC inspectors made the observation that use of only one type of tag for the test may be less confusing.
The NRC inspectors observed 213 of the approximate 600 valves that had been positioned and tagged for this test; no errors or discrepancies were noted.
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f-6-The calibration' documentation for the Weed Instrument Company Platinum resistance temperature detectors (RTDs), Model SP101-1B-C-4-C-4-0-0 and
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the DewTrak humidity transmitters, EG&G Modelt200, was reviewed by the NRC
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inspectors. Both the RTDs and humidity transmitters were found to be in calibration for the period encompassing the testh
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The NRC inspectors accompanied the licensee on the final walkdown of the containment building on July 3, 1989. It was noted that all pressure retaining vessels, such as fire extinguishers and aerosol cans, had been removed in addition to combustible material, such as trash and wood.
Wooden boxes and wooden instrumentation covers, that were left in the containment building, were verified to have been fire treated.
The NRC inspectors witnessed the closing of the personnel airlock and the airlock seal test, and verified that it was performed in accordance with lest Procedure No. EGT-719A, Revision 2, " Leak Test of Containment Airlock Seals." Containment pressurization was initiated on July 3, 1989. The
.NRC inspectors reviewed the licensee's controlled copy of Procedure
,No. EGT-701A, to verify that the proper sections had been signed off, and that all the prerequisites had been met.
The licensee began the accumulation of data for the 24-hour test at 2:30 a.m. on July 6, 1989. During the acquisition of data, the licensee identified some leaks which were isolated for subsequent repair and retest (locally).
In addition, the licensee identified a steam generator vent valve that had been closed to measure steam generator pressure. The valve had been accidentally left in that position contrary to procedure requirements. The licensee submitted a test deficiency report as soon as the deficiency was identified. The licensee, at this time, decided to reinitiate the 24-hour test as a result of these findings, even though there was no technical requirement and it appeared that the success of the test was not in question. The licensee stated that tneir intent was to perfom as accurate a test as possible without deficiencies. The test was reinitiated on July 6, 1989, at 2:30 p.m.
The NRC inspectors reviewed th'e test station logs, in addition to taking sample data from the CILRT station instrumentation. The NRC inspectors evaluated this data using the NRC CILRT computer code and performing manual calculations. The NRC results were not identical to the licensee's, due to the difference in methods used (NRC code used the Total Time Analysis Method), but the results were close and followed a similar trend.
The CILRT 24-hour test was completed on July 7, 1989, at 2:30 p.m.
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verification test was initiated on the same day at 3:30 p.m. and was
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completed at 7:30 p.m.
The leaks that were detected and isolated during the test will be repaired and locally tested. The results of these tests will be added to the results of the CILRT. The total results should not
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exceed the.75 La limit, identified in Chapter 10 of the Code of Federal
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.Regulatior:s,. Part 50. Appendix J..The NRC inspectors will. perfonn a J
' review of the results when the final report.is issued. The results'of
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this review will be documented in a separate NRC report.
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The NRC inspectors found that the attention to detail and~ conservatism,
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noteworthy.
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No violations'~or deviations were identified in the review of this program
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Exit Interview
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'.. An earlylexit' interview was conducted by-the NRC inspectors on July 3,
1989. At this meeting the. scope and findings of the inspection, which-involved review._of procedures, walkdown of systems, and observation of valve-alignment, were sumarized. The: licensee did not identify, as proprietary, any'of the information.provided to, or reviewed by, the NRCl inspectors. Because.of time constraints and availability of personnel, an.
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exit interview was not conducted on July 6, 1989.
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