IR 05000454/1986035

Insp Repts 50-454/86-35 & 50-455/86-22 on 860711-0917. Violations Noted:Failure to Follow Procedures - Paragraph 3.C & Failure to Follow Requirements of App J - Paragraph 6.a

ML20215C137
Person / Time
Site:	Byron
Issue date:	10/02/1986
From:	Maura F, Mendez R, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215C108	List: IR 05000454/1986035 ML20215C103 ML20215C131
References
50-454-86-35, 50-455-86-22, NUDOCS 8610100110
Download: ML20215C137 (11)

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U.S. NUCLEAR REGULATORY COMISSION

REGION III

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Reports No. 50-454/86035(DRS); 50-455/86022(DRS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: July 11 through September 17, 1986 M7#,0 h Inspectors: F. A. Maura /o/7/9C R 36 Date Approved By: M. A. Ring hief /o 7I Test Programs Section Date

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Inspection Summary Inspection on July 11 through September 17, 1986 (Reports No. 50-454/86035(DRS);

50-455/86022(DRS))

( Areas Inspected: Routine announced inspection by Region based inspectors of

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the containment integrated leak rate test (CILRT) procedure, CILRT performance witnessing; review of CILRT results; review of post CILRT work control inside containment; and review of local leak rate test (Type B and C) procedure and test result NRC modules utilized during this inspection included 70307, 70313, 70323 and 6172 Results: Two violations were identified (failure to follow procedures -

Paragraph 3.c; and failure to follow the requirements of Appendix J -

Paragraph 6.a).

8610100110 861003 PDR ADOCK 05000454 G PDR

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DETAILS 1. Persons Contacted Commonwealth Edison C T. Biggs, Startup Test Engineer B. Coleman, Startup Test Engineer J. Copeland, Startup Test Engineer

• R. Guse, Project Construction Department Engineer

• • D. McKean, Startup Test Engineer

• • R. Tuetken, Startup Superintendent

• • R. Ward, Services Superintendent

• E. Wurz, Startup Test Engineer Sargent & Lundy Engineers M. Ader S. Putman Volumetrics, In D. Peyvan

• Denotes persons attending the preliminary exit meeting of July 16, 198 ** Denotes persons attending the exit meeting of September 17, 198 The inspectors also contacted other licensee personnel including members of the technical, operating and regulatory assurance staf . Containment Integrated Leak Rate Preoperational Test Procedure Review Procedure Review The inspectors reviewed preoperational test procedure No. 2.58.61, Revision 2, " Integrated Leak Rate Test," relative to the requirements

! of 10 CFR Part 50, Appendix J, ANSI N45.4-1972, the FSAR, and the SE All inspectors' comments were satisfactorily resolve Clarifications of Appendix J Requirements To ensure the licensee's understanding of Appendix J requirements, the inspectors conducted numerous discussions with licensee personnel during the course of the inspection. The following is , summary of the requirements discussed with the license (1) Periodic Type A, B, and C tests must include as-found results as well as as-left. In order to perform Type B and C tests prior to a Type A an exemption from the Appendix J requirement must be obtained from NRR. The exemption request must state how the licensee plans to determine the as-found condition of the containment since local leak rate tests are being performed ahead of the CILRT. An acceptable method is to commit to add

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any improvements in leakage rates, which are the results of repairs and adjustments (R&A), to the Type A test results using the " minimum pathway leakage" methodology. This method requires that:

(a) In the case where individual leak rates are assigned to two valves in series (both before and after the R&A),

the penetration through leakage would simply be the smaller of the two valves'~ leak rate (b) In the case where a leak rate is obtained by pressurizing between two isolation valves and the individual valve's leak rate is not quantified, the as-found and as-left penetration through-leakage for each valve would be 50 percent of the measured leak rate if both valves are repaire (c)' In the case where a leak rate is obtained by pressurizing between two isolation valves and only one valve is repaired, the as-found penetration leak rate would conservatively be the final measured leak rate, and the as-left penetration through leak rate would be zero (this assumes the repaired valve leaks zero).

(2) Penetrations which are required to be-Type C tested, as described in the FSAR and SER, must be vented inside and outside the containment during the CILRT. All vented penetrations must be drained of water inside the containment and between the penetration valves to assure exposure of the containment isolation valves to containment air test pressur The degree of draining of vented penetrations outside of containment is controlled by the requirement-that the valves be subjected to the post-accident differential pressure, or proof that the system was built to stringent quality assurance standards comparable to those required for a seismic syste (3) Whenever penetration configurations during a CILRT deviate from the ideal, the results of LLRTs for such penetrations must be added as a penalty to the CILRT results at the 95%

confidence level. This penetration leakage penalty is determined using the " minimum pathway leakage" methodolog This methodology is defined as the minimum leakage value that can be quantified through a penetration leakage path (e.g.,

the smallest leakage of two valves in series). This assumes no single active failure of redundant leakage barrier Additionally, any increase in containment sump, fuel pool, reactor water, or suppression pool level during the course of the CILRT must be taken as a penalty to the CILRT result If penalties exist, they must be added (subtraction is never permitted)-to the upper confidence level of the CILRT result (4) The start of a CILRT must be noted in the test log at the time the licensee determines that the containment stabilization has been satisfactorily completed. Reinitializing a test in progress must be " forward looking," that is, the new start

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time must be the time at which the decision to restart is mad This also implies that the licensee has determined that the test has failed, and has enough data to quantify the leakage rat Any deviation from these positions should be discussed, and documented, with the NRC inspector as they occur to avoid later invalidations of the test results. Examples of acceptable deviations of reinitializing the start time of the test in the past are: time at which a leaking penetration which has an obvious effect on the test data was secured, accidental opening and later closing of a valve which has an obvious effect on the test data, the time at which an airlock outer door was closed and the inner door was ope (5) The supplemental or verification test should start within one hour after the completion of the CILRT. If problems are encountered in the start of the supplemental test, data recording must continue and be considered part of the CILRT until the problems are corrected and the supplemental test can begi (6) For the supplemental test, the size of the superimposed leak rate must be between 0.75 and 1.25 times the maximum allowable leak rate La. The higher the value, the bette The supplemental test must be of sufficient duration to demonstrate the accuracy of the test. The NRC looks for the results to stabilize within the acceptance criteria, rather than the results being within the acceptance criteri Whenever the BN-TOP-1 methodology is being used, the length of the supplemental test cannot be less than approximately one-half the length of the CILR (7) During a CILRT, it may become necessary to reject or delete specific sensors or data points due to drifting or erroneous sensors, or data outliers. Data rejection criteria should be developed and used so that there is a consistent, technical basis for data rejection. One example of an acceptable method for data outliers is described in an appendix to ANSI /ANS 56.8-1981. Sensor data rejection criteria should be plant specific and based upon a sensor's trend relative to the average scatter, slope, and/or absolute output of the senso (8) The water level in the steam generators during the CILRT must be low enough to ensure it does not enter the main steam lines unless flooding of the main steam lines is called for the in the loss of coolant emergency procedur (Applicable to PWRs only)

(9) An acceptable method for determining if the sum of Type B and C tests exceeds the 0.60 La Appendix J limit is to utilize the

" maximum pathway leakage" metho This methodology is defined as the maximum leakage value that can be quantified through a penetration leakage path (e.g., the larger, not total, leakage of two valves in series). This assumes a single active failure to the better of two leakage barriers in series when performing Type B or C test !

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(10) Test connections must be administratively controlled to ensure their leak tightness or otherwise be subject to Type C testing. One way to ensure their leak tightness is to cap, with a good seal, the test connection after its use. Proper administrative controls should ensure valve closure and cap reinstallation within the local leak rate testing procedure, and with a checklist prior to unit restar (11) Whenever a valve is replaced, repaired, or repacked during an outage for which Type A, B, and/or C surveillance testing was scheduled, local leak rate testing for the as-found as well as the as-left condition must be performed on that penetratio In the case of a replaced valve, the as-found test can be waived if no other containment isolation valve of similar design exists at the sit No violations or deviations were identifie . Containment Integrated Leak Rate Test Witnessing (Unit 2) Instrumentation The inspector reviewed the calibration data and determined all the instruments used in the CILRT had been properly calibrated and that the correct weighting factors had been placed in the computer program as required. The following instrumentation was used throughout the tes Type Quantity RTD's 25 Dewcells 10 Pressure Gauges 2 Flowmeter 1 During the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> full pressure test, pressure gauge No. 2 was deleted from the data scan due to erratic (step changes) behavio The test data was reinitialized using only pressure gauge No. No other sensors and no data sets were rejected during the tes Temperature Survey The inspector reviewed the results of the temperature survey performed by the licensee prior to containment pressurizatio The survey was performed with the reactor containment fan cooler fans (RCFCF) off. Both the reduced pressure and the full pressure CILRT were performed with the RCFCFs off. The results of the temperature survey are satisfactory for the containment condition under which performe Witness of Test The inspector witnessed portions of the reduced pressure and full pressure CILRTs on July 12-16, 1986 and noted that test

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prerequisites were met and that the appropriate revision to the test procedure was followed by test personnel. Valve lineups for the following systems were verified to ensure that no fluid could enter the containment atmosphere and that adequate venting and draining was provided:

System Penetration (s)

Instrument-Air P-39 Offgas Hydrogen Recombiners P-13, P-23, and P-69 Reactor Building Drains and Vents System P-65 Service Air P-56 Chilled Water P-5, P-6, P-8, and P-10 Process Sampling H 7 Monitor P-45 Chemical and Volume Control System P-28, and P-4 Containment Floor Drains P-47 Containment Spray P-1 and P-16 Process Sampling P-70 During a walkdown to verify valve lineups, the inspector observed that offgas hydrogen recombiner drain valves 20G142 and 20G143 were found in the closed position. Valves 20G142 and 20G143 are located approximately 20 feet below the containment isolation valves 20G082 and 20G084 and vent valves 00G070 and 00G068, respectively. In order for valves 00G070 and 00G068 to be properly vented they must be in the open position to prevent water accumulation and also to vent and drain portions of systems which may be considered open to containmen Byron Procedure Pre-Operational Test No. 2-58.61, Section 7.3 states in part, "Each System penetrating the containment will have its valves lined up per step 7.3.2." Step 7.3.2, titled,

" Final Lineup for ILRT," requires that valves 20G142 and 20G143 be in the open position. Contrary to the above, the two valves were observed to be in closed position. Although, valve lineup checklist 7.3.2 had been initialed and dated. This failure by the licensee to assure that activities affecting quality be accomplished in accordance with prescribed procedures is a violation of 10 CFR 50, Appendix B, Criterion V (455/86022-01). Subsequent to the identification of the improper valve lineup, the licensee performed a 100% reinspection and found no other problems. The inspector also reviewed six other systems and found no other valves improperly lined up. This violation does not require a written respons During the full pressure test, the personnel airlock inner door shaft seal leaked excessively. The licensee closed the outer door and opened the inner door for the duration of the test. The start of the full pressure test was reinitialized on July 14, 1986, to data set number 60 or 1/2 hour after the closing of the airlock outer door. At 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> on July 14, 1986, the licensee sealed a leak in the emergency airlock inner door shafts with silicone grease. The full pressure test was again reinitialized at 2100 hour0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> On July 15, 1986 at about 7:00 a.m., the licensee determined that electrical penetration E-25 was leaking excessively and was isolated by closure of valve 2NT0220. After the CILRT the penetration was disassembled, cleaned, and reassemble A Type B test was performed with satisfactorily results (no leakage).

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The inspector requested that the licensee investigate the reason for the airlocks shaft seals failure since they had recently been tested locally with satisfactory results (no leakage). After the CILRT the shaft seals were disassembled and cleaned; however, the licensee stated that no reason for their failure during the CILRT could be foun The licensee speculates that since these were the original seals (about 10 years old without any significant door cycling) the door cycling experienced between the local tests and the CILRT may have contributed to their failure. Another possible explanation for their different behavior between the two types of tests is the test duration. The local tests (Type B) are four hours in length while prior to their excessive leakage during the full pressure CILRT the seals had been at about 38 psia for approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and at full pressure (60 psia) for about 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> The seals were replaced with a new type per the vendor's (CB&I)

recommendation. The new shaft seals on the emergency latch inner door were tested with satisfactory results (no leakage).

The remaining shaft seals will be tested as part of the Technical Specification surveillance requirement . Test Results Evaluation Reduced Pressure CILRT Data Evaluation Upon satisfactory completion of the required stabilization period a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CILRT was performed at 38.2 PSIA (.64 Pa) during July 11-13, 1986, with data being collected and reduced by the licensee every 15 minutes. The inspectors independently monitored and evaluated leak rate data to verify the licensee's calculations of the leak rate and instrument performanc There was agreement between the inspectors' and licensee' results as indicated by the following summary (units are in weight percent per day).

Measurement Licensee Inspectors Leakage rate measured .025 .025 during ILRT (Ltm)

Ltm at upper 95% .029 .029 Confidence level Appendix J Acceptance Criteria - This test in combination with the full pressure ILRT is used to establish the maximum allowable leakage rate Lt for future reduced pressure tests at Pt= 38.2 PSI Full Pressure CILRT Data Evaluation Following completion of the reduced pressure CILRT the containment was pumped to approximately 60 PSIA and a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CILRT performed during July 14-15, 1986 following satisfactory completion of the required stabilization period. The data base was reinitialized twice as stated in Paragraph 3.c. Data was collected and analyzed

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by the licensee every 15 minutes. The inspectors independently monitored and evaluated leak rate test data to verify the licensee's calculations of the leak rate and instrument performance. There was excellent agreement between the inspectors' and licensee's results as indicated by the following summary (units are in weight percent per day).

Measurement Licensee Inspectors Leakage rate measured 0.022 0.022 during ILRT (Lam)

Lam at upper 95% 0.025 0.025 Appendix J acceptance criteria at 95% UCL = 0.75 La = 0.075 wt %/ da Appendix J acceptance criteria for future reduced pressure tests:

Lt (at Pt= 38.2 psia)= La4Pt/Pa =0.1 (0.80) =0.080 wt %/ da c Supplemental Test Data Evaluation After the satisfactory completion of the full pressure 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CILRT a known leakage (based on inspectors' independent readings and calculations) of 7.73 SCFM, equivalent to .099 weight percent per day was induced. Sdata was collected and analyzed by the licensee every 15 minute The inspectors independently monitored and evaluated leak rate data to verify the licensee's results. After approximately seven hours the supplemental test was terminated with satisfactory results as indicated by the following summary (units are in weight percent per day).

Measurement Licensee Inspectors Measured leakage rate 0.132 0.132 during supplemental Induced leakage rate, Lo 0.099 0.099 Lc - (Lo + Lam) 0.011 0.011 Appendix J acceptance criteria: -0.0251[Lc - (Lo + Lam)]1+0.025 d. Recirculation Sump Pipe Penetration Each recirculation sump penetration sleeve has a valve which vents the sleeve-to pipe cavity to the containment atmosphere. This valve, which is normally closed, was not included in the CILRT procedur Following the CILRT the licensee determined that the penetration boundary did not experience test pressure during the CILRT. The licensee performed local tests and the results were added as a penalty to the CILRT results at the 95% UCL. The licensee has modified the piping configuration of Unit 2 to make the valve more accessible. The Unit 1 configuration will be modified at the next

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refueling outage. Pending completion of the modification and test

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procedure updating this is an Open Item (454/86035-01; 455/86022-02).

. CILRT Valve Lineup Penalties Due to penetration configuration which deviated from the ideal penetration lineup requirements for the CILRT, the results of local leak rate tests for each penetration must be added as a penalty to Lam at the 95 percent UCL. The following penalties must be added using the minimum pathway leakage method:

Local Leak Rate Based on Latest Test (Units are Penetration in SCFH)

Recirc Sump Sleeves 2 Electrical Penetration E-25 0 Emergency Air Lock Shaft Seals 0 Pressurization Penetration Blind Flange 0 Steam Generator Blowdown 0 Total = 2 SCFH = .0004 wt %/ day The final as left CILRT leakage rate including all lineup penalties was 0.026 wt %/ da No violations or deviations were identified, however, one issue requires further review and will be followed as an open ite . Review of Post CILRT Work in Containment The inspectors discussed with the licensee the control of work activities inside containment. The licensee indicated that construction activities inside containment would continue after the CILRT, but that the work activities would be controlled. By letter dated July 17, 1986 the licensee informed all contractors that any activity affecting the containment liner (welding, cutting, grinding, etc.) requires the written approval of the CECO Project Construction Head Engineers. In order to establish a baseline and to make a determination as to the adequacy of the licensee's control of work on the containment the inspectors performed a walkdown of the liner. The inspectors, along with licensee personnel, walked down the containment liner at the 377', 401', 410', 426', and 462'

elevations. The inspectors looked for indentations, gouges, burns or marks, scratches and unpainted grind marks. All the above marks were noted by the inspectors and were documented by licensee personne During the walkdown, the inspectors noted five gouges or pits ranging from one that was about 3/8 inches in diameter to one that was approximately an 1/8 inch deep. Since the gouges had white paint over them, it was determined they were not new; however, it was difficult to determine whether any of the gouges were deep enough to penetrate completely through the containment liner. The licensee agreed to grind off the pain The inspector observed all five gouges with the paint removed and noted that none of the gouges penetrated completely through the 1/4 inch liner. The licensee indicated that since none of the gouges penetrated completely through the liner no further action would be taken except to paint over the gouge _ _ . _ __ . _ - . _ _ _ . . . ~ . _ _

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During the. containment inspection, the inspector noted that the liner leak 1 chase channels had their 1/4" plugs removed. The licensee stated that while

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there is no concern regarding corrosion of unpainted liner surface behind the channels the plugs will be installed and left on during future test ~

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The inspector informed the licensee that they must submit to NRR their

justification for the. performance of future CILRTs with the channel plugs

installed. This is an Open Item (454/86035-02; 455/86022-03) pending license submittal to NRR and NRR acceptance of justification.

F No violations or deviations were identified, however, one issue requires

. further review and will be followed as an open item.

j Local Leak Rate (Type B and C) Preoperational Test i Procedure Review e

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The inspectors reviewed preoperational test procedure No. 2.058.60, Revision 1, " Primary Containment B and C Local Leakage Rate Test,"

for testing method, acceptance criteria, and penetrations to be

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tested and determined that it met the requirements of 10 CFR 50,

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Appendix J, ANSI N 45.4, and the FSAR commitments with one exception.

10 CFR 50, Appendix J requires that containment penetrations fitted

with expansion bellcws be Type B leakage rate tested. A review of the containment penetrations showed that the fuel transfer tube is i fitted with three expansion bellows which are part of the containment boundary. The licensee's preoperational test procedure No. 2.058.60, j Revision 1 did not include testing of the fuel transfer tube bellows.

In response to the inspector's inquiry the licensee stated that neither Unit 1 preoperational nor the Type B periodic test programs

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included testing of the Unit 1 fuel transfer tube bellows. The j licensee had not received an exemption from the testing requirements

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of Appendix J for the fuel transfer tube bellows of either Uni Failure to conduct a leak rate (Type B) test of the Unit 1 fuel i transfer tube bellows during the preoperational test program and

during the first periodic local leak rate test (Type B and C) program on December 1985, and, failure to establish a preoperational testing l program and develop a periodic test program which includes the fuel

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transfer tube bellows of Units 1 and 2 is a violation of 10 CFR 50, Appendix J (454/86035-03, 455/86022-04). Following the identification of this violation by the inspectors the licensee tested both Units'

, fuel transfer tube bellows at Pa with satisfactory results (no leakage).

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The inspector reviewed the following specific penetration procedures i to ensure proper venting and draining and the use of a satisfactory test method. No problems were identified.

(1) Step No. 9.5 - Fuel Transfer Tube Penetration Blind Flange

! Leakage Rate Test i

, (2) Step No. 9.6 - Equipment Door and Integral Personnel Lock l Leakage Rate Test

(3) Step No. 9.8 - Containment Purge System (VQ) Local Leakage

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Rate Test (covering penetrations P-95, 96, 97 and I-3)

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(4) Step No. 9.10 - Chemical and Volume Control System (CV) local Leakage Rate Test (covering penetrations P-28 and 41)

(5) Step No. 9.11 - Reactor Building Drains and Vents System (RE)

Local Leakage Rate Test (covering penetrations P-11 and 65)

(6) Step 16. 9.23 - Safety Injection Safety (SI) Local Leakage Rate Test (covering penetration P-55) Test Results Review The inspectors reviewed the results of all Type B and C final tests and determined that:

(1) the sum of all containment penetration boundarios and isolation valves leakage rate (including the summation of tha errors)

using the maximum pathway method was 130.47 scfh or 0.28 La, where the acceptance criteria is < 0.6 L (2) where specific containment boundaries had a more restrictive Technical Specification acceptance criteria (such as airlock gaskets, containment normal purge isolation valves and mini-flow purge isolation valves) the results were well within ,

the Technical Specification limit (3) whenever the initial test gave unsatisfactory results the licensee wrote a deficiency on the specific boundary, the problem was corrected and the boundary retested, Reverse Direction Testing The inspectors reviewed the design of the twelve inboard isolation valves (three plug valves, one globe valve, and eight butterfly valves) which are tested in the reverse direction. The review showed that testing in the reverse direction gives equivalent or more conservative results than when testing in the direction of accident pressur . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 4.d and . Exit Interview The inspectors met with licensee representatives denoted in Paragraph 1 during the inspection on July 16, 1986 and at the conclusion of the inspection on September 17, 1986. The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur _ . _ _ . . _ _ _ __ _ _

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