ML17179A647
| ML17179A647 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/21/1992 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9212300287 | |
| Download: ML17179A647 (3) | |
Text
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A UNITED STATES
. W NUCLEAR REGULATORY COMMISSld9 REGION Ill 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60137 OCT 2 1 1992 rj l'f\\A Dr--
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MEMORANDUM FOR: *John A. Zwolinski, Assistant Director for Riii Reactors, NRR FROM:
SUBJECT:
Edward G. Greenman, Director, Division of Reactor Projects REQUEST FOR TECHNICAL ASSISTANCE (TASK INTERFACE AGREEMENT)
FOR DRESDEN STATION - STANDBY GAS TREATMENT SYSTEM AS-FOUND SURVEILLANCE TESTING (AITS #92-0616)
In the attached memo, Walt Rogers, SRI, Dresden, identifies an issue with the testing of adsorbers at the Dresden site. While the licensee is committed to American National Standard (ANS) NlS.7-1972 which requires the recording of the as-found*condition during surveillance testing, no such requirement is in the procedural guidance for ANSI N510-1975. ANSI N510-1975 was adopted in association with a Technical Specifications change in 1976.
While we agree that no violations of Technical Specifications occurred, we are concerned because without as-found testing, it is impossible to judge whether the adsorbers are performing their function over an extended period of time due to gasket degradation, media shifts, and mechanical damage to the canisters. Our experience has been that the as-found testing of instruments, pumps, etc. have been invaluable in determining adverse trends in equipment performance.
While no gross leakage was detected in the 1991 testing of adsorber canisters at Dresden, it would appear that some periodic tests should be performed to determine that a safety problem does not exist.
Since there have been past regulatory inconsistencies with regard to as-found adsorber tests, a backfit analysis would be required to impose testing. Riii believes a backfit analysis should l>e performed tp ~etermine ::*;_f...,the safety
- significance of the* issue requires ~'that... -some.'as.:found testtng :of>adsQrbers.be done at specified intervals.
21~041 9212300287* 921021 J PDR ADOCK 05000237 P
John A. Zwolinski 2
OCT 2 11992 Should you have any questions, contact R. C. Knop of my staff at (708) 790-5547.
Attachment:
As stated cc w/attachment:
H. J. Mi 11 er C. E.. Norelius W. G. Rogers, SRI TSS DRP Division Directors, RI, Rll, RIV, RV
~)~~
~ Edward G. Greenman, Dire or
~* Division of Reactor Projects
MEMORANDUM FOR:
FROM:
SUBJECT September 28, 1992 R. C. Knop, Chief, Reactor Projects Section 1B Walt G. Rogers, Senior Resident Inspector Dresden Nuclear Power Station DRESDEN STATION -
STANDBY GAS TREATMENT SYSTEM AS-FOUND SURVEILLANCE TESTING Dresden Technical Specifications (T/S) require the standby gas treatment system (SBGTS) charcoal absorber leakage bypass test to be periodically preformed.
On May 17, 1991, the *B" train SBG~ failed multiple bypass tests following maintenance cin the absorbers.
The licensee contributed the ~ailures primarily to degradation of the absorber caniste~ gaskets.
An "As-found" leakage bypass test was subsequently preformed on the "A" SSGTS train :n May 19.
Again, the TIS acc2ptance criteiia was not met.
~fter the ca~ister gaskets were replaced and the absorber door mechanism was repaired the "A" train acceptance criteria was met.
An NRC inspection revealed the May 19 test was the only time "As-fourj" testing had been prefo~med on either SBGTS trains.
The licensee is cc~mitted to American National Standard (ANS) NlB.7-1972.
NlB.7-1972, Secticn =.4, "Test and Inspections After Startup", requiring surveillar.c~ p:--oced~:re= to record the "As-found" condition during testing.
However, a November
!~, 1976, Dresden Safety Evaluation, associated with changes to the S3GTS systeffi TIS, indicated the licensee was required to preform the bypass test in accordance with the procedural guidance provided in the American National Stan~ar: (ANSI)
~510-1975.
ANS! N510-1975, Section 12.!, "Pur~~se," allows :he bypa=s leakage test to be performed following filter train reassembly if sa~ples of j:scrbent are to be taken for laboratory analysis.
Additionally, discussion wit~ Region*
III, Division of Reactor Safety staff members, indicated en 4 orcement =~ the ANSI t..JlS.7 "As-found" testing requirements may not be app:*o;:riate due :c ;:::;ast regulatory incc~sistenciei.
Commonwealth Edison Co~pany*s (CECo) position is that "As-~:*unc**
tE*sti:-~ cf the charcoal absorbers is not required per tne guidance provide: in ANSI
~JSl0-1975.
Also, no "As-found" charcoal absorber bypa:s te:stin:::; ::;
currently performed at the other five sites.
The resident sta~f beli=~es the "As-found" testing req~irement of ANSI 16. 7-i972 supersedes t~*= ;::roced.. rc.:
guidance outlined in ANSI NSl0-1975.
This issue is an unreso!~=~ ite~ :~
inspection report 50-237/92020(DRP) and 50-2~9/92020(DRP).
Please provide appropriate regulatory guidance as to the en~orceabilit-cf the "As-found" testing requirements per ANSI 18-7 for the charcoal absorbe' trains used at CECo fdcilities.
"'" !o:!f,f-Dresden Nuclear Power Station cc:
Bruce Burgess, DRS, RIII