IR 05000456/1987033
| ML20236B783 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/16/1987 |
| From: | Mendez R, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236B776 | List: |
| References | |
| 50-456-87-33, 50-457-87-28, NUDOCS 8710260349 | |
| Download: ML20236B783 (12) | |
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'U.
S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/87033(DRS);50-457/87028(DRS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-72; No. CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690
Facility Name: Braidwood Station, Units 1 and 2 Inspection At.: Braidwood Site, Braidwood, Illinois l
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Inspection Conducted: August 20 through October 6, 1987 f $668 i
Inspector:
Fi. Mendez
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Approved By:
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Test Pr grams Sec ion Date
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Inspection Summary
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Inspection on August 20 through October 6, 1987 (Reports l
No. 50-456/87033(DRS); No. 50-457/87028(DRS))
Areas Inspected:
Routine, announced safety inspection by a Region III inspector of licensee action on previous inspection findings; containment integrated rate test (CILRT) preoperational procedure; CILRT test witnessing; CILRT results; and local leak rate test (type B and'C) procedure, test j
performance, and results. NRC modules utilized during this inspection
included 61720, 70307, 70313, 70323, 92701, and 92702.
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Results:
No violations or deviations were identified.
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8710260349 871020 PDR ADOCK 05000456 G
PDR l
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1.
Persons Contacted
- P. L. Barnes, Regulatory Assurance Supervisor
- R. C. Bedford, Regulatory Assurance
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- M. Inserra, Test Review Board Supervisor
- M. Azar, Start-Up Test Engineer
- R. Yungh, Operations Engineer
- B. Peacock, Tech Staff Engineer
- T. Lewis, Project Start-Up
- T. Simpkin, Regulatory Assurance
- P. Hart, QA Engineer C. Swenson, Start-Up Test Engineer J. Glover, Nuclear Services Technical
- Denotes persons attending the exit meeting of October'6, 1987.
The inspector also contacted other licensee personnel including members of the technical, operating, and regulatory assurance staff.
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2.
Licensee Action on Previous Inspection Findings
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(0 pen) Open Item (456/86023-01):
The licensee' performed the Unit 1 l
Type A test with the 1/4" leak chase channel plugs installed.
In addition, the licensee informed Region III' inspectors that future Type A tests would be performed with the plugs installed. The i
licensee was informed by the inspectors that they must either vent
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the leak chase channels in containment or submit to NRR.their
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justification that plugged leak chase channels are acceptable when j
performing Type A tests. On April 29, 1987,, the licensee submitted
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to NRR a letter outlining their justification for performing Type A
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tests with the plugs installed. During the current Unit 2'CILRT,
the licensee performed the test with_the plugs installed on the leak j
chase channels around' penetrations. NRR has not responded to the
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licensee's request.
This matter is open pending resolution by NRR.
b.
(Closed) Violation (456/86023-020?:
Failure to' establish a-t preoperational testing program wh:ch included testing of the fuel
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transfer tube bellows. The licensee initiated corrective' action and-I established a program to test the fuel transfer tube bellows.
Sections 5.11 through 5.22 in test Procedure 1BwVS 6.1.2.d-1,
" Primary Containment Type B and C Local Leakage Rate Tests," covers the leakage rate testing of the fuel transfer tube sleeve bellows.
l In addition, the inspector reviewed the preoperational local leak'
rate tests data documented'in Procedures BwPT-PC-10 and BwPT-PC-50 for the Unit 1 and Unit 2 fuel transfer tube bellows, respectively.
A review'of the procedure and the test data indicated acceptable-results.
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3.
.C'ontainment Integrated Leak Rate Preoperational Test Procedure Review-(Unit 2)
a.
Procedure Review The inspector-reviewed preoperational test Procedure BwPT-PC-51, Revision 1, " Integrated Leak Rate Test"' including Test Change Requests for conformance with 10 CFR 50, Appendix J; the FSAR; and the SER.
The. inspector's comments were discussed with the licensee during the course of the inspection.
All. inspector' comments were:
satisfactorily resolved, b.
Clarification of Appendix J Requirements
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To ensure th'e licensee's understanding of Appendix J requirements, the inspector conducted numerous discussions with licensee. personnel l
during the course of the inspection.
The.following is a summary of i
the clarifications discussed with the licensee.
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l (1) The only methods of data reduction acceptable to the NRC are total time or point-to point as described in ANSI N45.4-1972 including a statistically calculated instrument error' analysis.
The following options are available to the licensee.
(a) Total time (<24 hour duration test) in accordance with Bechtel Corp.' Topical Report BN-TOP-1, Revision 1.
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Whenever BN-TOP-1 is used it must be followed in its entirety except for any.section.which conflicts with Appendix J requirements.'
l (b) Total time h24 hour duration test) using single sided-95% UCL.
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(c) Proposed Regulatory Guide MS 021-5, Regulatory Position l
No. 13.
If this method.is utilized, the licensee must l
submit as exemption request to NRC and receive approval for its use prior to the expiration of the Type A. test i
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frequency requirements stated in the Technical
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Specifications.
(2) Periodic Type A,' B,. and C tests must include as-found results as well as the as-left.
If Type B and C tests are conducted prior to a Type A, the as-found condition of' the containment must be calculated by adding any improvements in leakage' rates, which are the results of Repairs and Adjustments (R&A), to the l
Type A test results using the " minimum pathway leakage" L_
methodology.
This method requires that:
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(a) In the case where individual leak rates are' assigned to L
two valves in series (both before and after the R&A),'the l '-
penetration through-leakage would simply be the smaller.of the two valves leak rates.
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-(b)
In the case where a leak rate is obtained by pressurizing
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between two isolation valves and the individual valve's i
leak rate is not quantified, the as-found'and as-left
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penetration through-leakage for each valve would be l
50 percent of.the measured leak rate if both valves are
repaired,
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(c)
In the case where a leak rate is obtained by pressurizing
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between two isolation valves and only one valve is i
repaired, the as-found penetration leak rate would i
conservatively be the final measured. leak rate, and the i
as-left. penetration through leak rate would be zero (this
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assumes the, repaired valve leaks zero).
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Whenever a reduced pressure test is performed, the leakage
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rate Ltm shall be less than 0.75 Lt.
If-local leakage measurements are taken to effect repairs in order to meet-the acceptance criteria, these measurements shall be taken at.a
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l test pressure Pt.
j (3) Penetrations which are required to be Type C tests, as
described in the FSAR and SER, must be vented inside and j
outside the containment during the CILRT.
All vented j
penetrations must be drained of water inside the containment
and between the penetration valves to assure exposure of the j
containment isolation valves to containment air test pressure.
The degree of draining of vented penetrations outside of
'l containment is controlled by the requirement that the valves be j
subjected to the post accident differential pressure, or proof.
l that the system was built to stringent quality assurance-
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standards comparable to those required for a seismic system.
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(4) Whenever penetration configurations during a CILRT deviate from the ideal, the results of LLRTs.for such penetrations must be j
added as a penalty to the CILRT results at the 95% confidence i
level.
The penetration leakage penalty is determined using the
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" minimum pathway leakage" methodology.
This methodology is j
l defined at the minimum leakage value that can be quantified
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through a penetration leakage path (e.g., the smallest leakage
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i of two valves in series)..This assumes no single active i
failure of redundant leakage barriers.
Any' increase in i
containment sump, fuel pool, reactor water, or suppression pool j
level during the course of the CILRT must also be taken as a penalty to the CILRT results.
If penalties exist, they must be i
added (subtraction is never permitted) to the upper confidence
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level of the CILRT results.
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i (5) The start of.a CILRT must be noted in the test log at the time i
the licensee determines that the containment stabilization has i
been satisfactorily completed.
Reinitializing a test in i
progress must be " forward looking," that is, the new start time i
must be-the time at which the decision to restart is made.
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This also' implies that:the licensee has determined that the test has~ failed and has enough data to quantify the leakage.
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Any deviation from these positions should be. discussed, L
and documented, with:the NRC inspector as'they occur'to avoid '
later invalidations.of the test results.'
Examples of-
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acceptable deviations.of reinitializing th'e start time of the j
test in the past are:
time'at which a leaking penetration i
which has an obvious'effect on the test data was secured,,
j accidental opening and later closing of a valve which has~an j
obvious effect on the test data, the time at which an airlock j
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outer door was closed and the inner door was open.
(6) 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 l
until the problems are corrected and the supplemental test can l
begin.
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(7) 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 better.
The supplemental test must be of sufficient duration to demonstrate l
the accuracy of the test.
The NRC looks for the results to l
stabilize within the acceptance' criteria, rather than the results being within the acceptance criteria.
Whenever the BN-TOP-1 methodology is being used, the length of the supplemental test cannot be less than approximately one-half of the CILRT.
l (8) 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.
Dr.ta rejection criteria should be developed and used so that there.is a consistent, technical l
basis for data rejection.
One example'of an acceptable
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method for data outliers is described in an appendix to ANSI /ANS 56.8-1981.
Sensor. data rejection criteria should be
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plant specific and based upon a' sensor's trend relative to the average scatter, slope, and/or absolute output of the sensor.
(9) 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 forLin the loss of coolant emergency procedure.
(10) An acceptable method for determining if the sum of Type B and C test exceeds the 0.60 La Appendix J limit is to utilize.'the
" maximum pathway. leakage" method.
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 tests.
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(11) Test connections must be administratively' controlled to ensure their leak tightness or_be subjectrto Type'C testing.
One way to ensure their leak tightness is to'. cap,1with 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 restart.
(12) 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 penetration.
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' site.
No violations or deviations were. identified.
4.
Containment Intec.ated Leak Rate Test Witnessing (Unit 2)
'4 a.
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 test:
Typ_e Quantity RTDs 25..
Dewcells
Pressure Gauges
Flowmeter
One out of two dewcells in Subvolume 2 Data Acquisition System (DAS)
channel number 32 was deleted from the data scan early during the full pressure test due to erratic (large step change) behavior.
No other sensors and no data sets were rejected during the test.
b.
Temperature Survey The inspector reviewed the results of the' temperature survey performed by the licensee prior to containment l pressurization.
The survey was performed with the Reactor Containment' Fan Cooler Fans
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(RCFCF) off.
Both the~ reduced pressure and the full pressure CILRT
were performed with the RCFCF's off.
The results of the temperature survey'are satisfactory for the condition under which performed.
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Witness of Test
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y The inspector witnessed portions of the reduced pressure _ and full'
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pressure CILRT's on September 6-9, 1987, 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 correct to ensure that no' fluid could enter the containment atmosphere and the proper venting.was -
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provided:
System Penetration (s)
Instrument Air-f ' P-39 Fire Protection P-34 Component Cooling P-24 Containment Spray P-1.
Chemical & Volume Control System P-28, P-71, P-37 Offgas Hydrogen Recombiners P-23 Reactor Building Drains & Vents System
--P-11'and P-65 Containment Floor Drains P-47-Service Air
.P-56 Integrated Leak Rate Test System P-4 g
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Chilled Water P-6 and P-10
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Reactor Coolant (Pressurizer Relief)
P-44 Residual Heat Removal P-75'
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On September 5, 1987, at about 3:30 p.m. upon completion of the
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Structural Integrity Test (SIT), but prior to the reduced pressure CILRT, the licensee performed an inspec. tion'of containment.~ The inspection revealed water about two-three inches deep on the containment floor'and a high recirculating sump level. The source; l
of the water was determined to be from the C cold leg drain line which connects to the Reactor Coolant Drain Tank (RCDT).
Valve 2CV8350, which is in this line, was not in the fully. closed position and ' allowed water from the residual heat removal system to leak through the vent on the RCDT..The water was pumped out of containment.
On September 6,1987, at about 12:15 a.m. the containment was flooded again.
The operations department, in an attempt to increase Reactor Coolant System (RCS) inventory, caused water to~ leak into.
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g containment to a dept $f.about Gree Jnches.
Inthisincide5t,an
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operator opened Valve,2SI88120 manually in order to fill the reacto n -
vessel to the center IW Y ce the hot leg using w ter from the
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Refueling Wate'r Storage Tank (RWST).
When the operator attempted tc3 close the valve, th Mclutch would not engage and consequently could I not clos ? S valve " The operator closed the breaker to the valve J and called t>t Unit h Nuclear Station Operator (NS0) to close the i valva at the mein cdntrol board.
The Unit 2'Nhd could not be contacted since he Lif responded to e feedwateb pump trip on Unit 1.
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The feedwater pump trip caused a load reject to 110 Mw on Unit 1.
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Consequently, with Vahe 2SI88128 open, water which had been, *
s accumulating in the steam ynarator 2. pilled through tM generator manways which had been partially left open fm(qted,GM CRRT.
The water in containment was cleaned up a second time.
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l During the reduced pressure test, Valves 2VQ011 and 2VQ912, which D,
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are part pf the containment, pressurization line, were noticed to be
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leaking. The licensee was enable to fully isolate the leak ed I
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decided to blank off the line by Valve 2VQ011.
Prior to the start
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of the full pressure test a blind flange was placed on tid contair, @ t pressurization line.
No problems were encountered
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during thp(f,ull pressure test.
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No violatidop or deviations were identified.
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Test Results EvaluatWm
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i Reduced Presstre CILRT Dat@lua't ig
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i stabilizct?pn period, a 24-hour CILRT Sas performed at 38.6 psia i.
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(.65 Pa) d@ing September 7-8,1986, 'A th dat h,being collected and
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reduced by the licensee every 15 t%utes.
The inspector
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independently monitored, and evahiated the leak rate data to verify
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the licensee's calcul&thn~cf tiie leak' rate and instrument-perfccmante.
There wag Mcelletf af'ceeniert-hetween-tha insp2 tor's and lic@See's results as indicated by dei folfowing Ommary s(units rf y
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are in weight percente d r day).
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Measurement
' 'Liceidee Inspector
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g, Leakage rate measured D.L94 0.064
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during ILRT (Ltm)
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Ltmayppper95%
0.084 0 084 I
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cone dence leve.i i
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s AppemNx J acceptance c)rii.hria - This test in combination wkn the
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i full pr(iisers ILRT is use'd tn establish the maximum dlowa e,
leakagerateLtforfuturerehycedpressuretestsa3Pt=;P46 psia.
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b.
' Full Pressure CILRT Data Evaluation.
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Following completion of the' reduced pressure CILRT, the containment'
I was pressurized to'60.3 psia and'a 27.75 hourLCILRT performed during September 8-9, 1986, _ following satisfactory. completion of the required-temperature stabilization' period.. Data was' collected and analyzed by the' licensee every 15 minutes.
The. inspectors monitored and. evaluated the. leak-rate test data to verify the' licensee's'
l, calculations of. the leak rate and -instrument performance..Again there was' excellent agreement between the inspector's and licens'ee's i
results as. indicated by the following summary (units are in' weight
percent per day).
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Measurement
. Licensee Inspector Leakage rate measured 0.044 0.044 dQring ILRT (Lam):
Lam at upper 95%-
0.049 0.049 confidence level
Appendix J acceptance criteria 95% UCL 10.75 La 10.075 wt %/ day.
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Appendix J. acceptance criteria for future reduced pressure tests:
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(1) Lt (at Pt = 38.6 psia) $La-Pt/Pa 10.1 (0.804) 10.080 wt %/ day.
(2) 0.75 Lt = 0.75 (0.080) = 0.060 wt %/ day.
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Supplemental Test Data Evaluation After the satisfactory completion of ~ the full pressure 24.iour CILRT j
a known leakage of 7.72 scf/ min, (based on inspector's independent readings and calculations) equivalent to 0.100 weight percent per day was induced.
Data was collected and analyzed by the licensee every fifteen minutes.
The inspector independently monitored and evaluated the leak rate data to verify the licensee's results.
After 4.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />, the supplemental test was terminated with satisfactory results as indicated'by the following summary (units arelin weight percent per day).
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Measurement
~ Licensee'
Inspector Measured leakage rate, Lc,
_0.158 0.158 during. supplemental test Induced leakage rate, Lo 0.100 0.100 Lc - (Lo + Lam)
0.014 0.014
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Appendix'J acceptance criteria: - 0.025 1 [Lc - (Lo + Lam)] 1 + 0.025
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CILRT Valve Lineup Penalties
Due to. valve' configurations which deviated from the ideal j
penetration valve lineup requirements for the CILRT, the results of:
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local leak rate test for such penetrations must be added as a
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penalty to Lam at the 95% UCL.
The licensee is committed to' adding
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the.following penetration leakage using the, minimum pathway leakage
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method:
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l P-82 Steam Generator ~ Blowdown'2A P-83 Steam Generator Blowdown 2A
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P-80 Steam Generator Blowdown 28 P-81 Steam Generator Blowdown 2B
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'P-88 Steam Generator Blowdown 2C j
i P-89 Steam Generator Blowdown 2C l
l P-90 Steam Generator Blowdown 20 h-
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P-91 Steam Generator Blowdown 20
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P-98 Fuel Transfer Tube P-4 Containment ILRT Pressurization
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I-3 Containment ILRT Pressure P-36 H Monitor Return
The licensee has not completed local leak rate testing of all the above penetrations.
Consequently, a CILRT valve lineup penalty could not be calculated.
Penetrations P-4, P-36, and I-3 had not-been tested at the time of the exit on October 6, 1987.
The.results of the completed local leak rate tests will be reviewed in a future inspection.
This item is open pending a review of the results'
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(457/87028-01(DRS).
I No violations or deviations were identified, l
l 6.
Local Leak Rate (Type B and C) Preoperational Test I
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Procedure Review l
The inspector reviewed preoperational. test procedure BwPT-PC-50,.
l Revision 0, " Primary Containment 8 and C Local Leakage Rate Test,"
l for testing method acceptance criteria, and penetrations to be l
tested and determined that it met the requirements of 10 CFR 50,
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Appendix J, ANSI N45.4 and the FSAR commitments.
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The inspector reviewe'd the following specific penetration testing i
procedures 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.
(2) Step No. 0.6 - Equipment Door and. Integral Personnel Lock Leakage Rate.
(3) Step No. 9.8 - Containment Purge system (VQ) Local Leakage Rate-Test (covering penetrations P-94,' 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. Vent System (RE)
Local Leakage Rate Test (covering penetrations P-11 and.65).
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i (6) Step No. 9-12 - Reactor Coolant (Pressurizer Relief) System.
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l (Rx) Local Leakage Rate Tests.
b.
Test Witnessing The inspector witnessed the local leak rate testing of containment isolation valves 2H0VVQ001A, 2H00VVQ001B, 2H0VVQ002A,.and 2H0VVQ0028.
The inspector verified that the tests were conducted in accordance with the approved procedure; test equipment was properly installed; test data was' collected and recorded properly; personnel-conducting the test were knowledgeable of the testing being performed; deficiencies and test problems were documented; and that test changes were processed in an approved manner.
c.
Test Results Review The inspector reviewed the results of all completed Type B and C preoperational tests and determined that:
(1) The sum of all containment boundaries and isolation valves leakage rate (including the summation of the errors) using the
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maximum pathway method was thus far 44.4 SCFH or 0.1 La where i
the acceptance criteria is <0.6 La.
The licensee has completed
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i local leak rate tests on all penetrations except P-4, P-36, and I-3.
A final result of the total.B&C type tests is expected I
after testing of the three penetrations mentioned above (see Open Item 457/87028-01).
(2) The final leakage measured for each penetration tested was'.kept below the administrative limit of 23 SCFH or 0.05 La.
Several isolation valves did not initially meet the acceptance criteria, but deficiencies were written and the valves were reworked until an acceptable leakage rate was attained.
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n (3):.Where specific: boundaries'had,a.more-restrictive: Technical
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2SpecificationJacceptanceicriteriaL(such as airlock. gaskets,-
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containment. normal' purge: isolation: valves and mini.-flow purge..
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, isolation valves), the results.were well within.the: Technical
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- Specification _n' 11mits.
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' Reverse Dire'ction Testing The inspector reviewed.the' design.of eleven isolation valvesL.
numbers 20G079, 20G080,i20G081, 20G05A, 2VQ005A,--2VQ002A,_2VQ004A, ?
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'2VQ001A,32RF026, 2FC012,fand 2FC009-w.tich are tested in the' reverse
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. direction.
The, review ~showed that teiting'in the< reverse direction;
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gives conservative results compared tr. testing in the direction ~of<
j-accident pressure.
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'No violations or deviations were identified.
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7.
Open Items.
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- e Open items are matters.which have'been discussed with
- the licensee, which b
will be reviewed by the' inspector and which involve:some action on the.
- l part of the NRC:or licensee or both.
An open item-disclosed'during the <
l inspection is discussed in Paragraph 5.d.
8.
Exit-Interview The-inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at'the conclusion'of the inspection on.
October 6, 1987.
The inspector' summarized the scope and results of.the j
inspection and discussed the.likely content of.'this inspection report.
'l The licensee acknowledged thefinformation and did not indicate that any.
i of the information disclosed during the inspection could be considered i
proprietary in nature.
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