ML18143B357
| ML18143B357 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/28/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-430, NUDOCS 8508090055 | |
| Download: ML18143B357 (5) | |
Text
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W1LLMM L STEWART Vice President Nuclear Operations June 28,. 1985 Dr. J. Nelson Grace Regional Administrator Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Gentlemen:
Serial No.
NO/HLM:dn Docket No.
License No.85-430 50-281 DPR-37 Nuclear Operations Department Post Office Box 26666 One James River Plaza Richmond, Virginia 23261 VIRGINIA POWER We have reviewed your letter of May 30, 1985 in reference to the inspection conducted at Surry Power Station on April 8 c-¥* 1985, and reported in IE Inspection Report No. 50-281/~
Our response to the specific violation is attached.
We have determined that no proprietary information is contained in the report. Accordingly, Virginia Power has no objection to this inspection report being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours, 1\\L~
W. L. Stewart Attachment cc:
(w/attach~ent)
Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station
VIOLATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-281/85-11 Appendix J to 10 CFR 50 contains the following requirements:
- 1.
Paragraph III.A.1.(d) requires that for a Type A test, systems which become potential air leakage paths post accident will be drained and vented to the extent necessary to assure exposure of the system containment isolation valves to containment air test pressure at post accident differential pressure.
- 2.
Paragraph III.A.1.(a) requires that if during a Type A test, potentially excessive leakage paths are identified which result in the Type A not meeting the acceptance criteria of Paragraph III.A.5.(b), the Type A test shall be terminated and leakage through such paths measured using local test methods.
Repairs and/or adjustments shall be made and a Type A test performed.
- 3.
Paragraph III.A.3.b.(b) requires, in part, that a supplemental test shall be performed and the difference between the supplemental test data and the Type A test data shall be within 0.25 La.
If the results are not within 0.25 La, the reasons shall be determined, corrective action taken, and a successful supplement test performed.
Contrary to the above, in the period prior to and including September 10-14, 1983:
- 1.
Containment penetration valve alignments to establish the Type A test boundary conditions were performed in accordance with Procedure PT-16.3 as required by Technical Specification 6.4.
PT-16.3 does not contain adequate venting and draining instructions.
As a result, the requirements of Paragraph III.A.1.(d) of Appendix J to 10 CFR 50 were not met in that seven penetrations (Nos. 47, 56A, 56B, 56D, 89, 103, and 104), potential post accident air leakage paths, were not properly vented and drained.
- 2.
Excessive leakage which prevented meeting the acceptance criteria of Paragarph III. A. 5.(b) of Appendix J to 10 CFR 50 was identified subsequent to the start of the Type A test at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, September 13, 1983.
At 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, September 13, 1983, the excessive leakage was isolated (in lieu of repair) and the Type A test was continued until 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> September 14, 1983, at which time the test was terminated.
An NRC staff position has determined that the isolation of a path in lieu of repair and/or adjustments is within the intent of this-re-gulation, provided that after the Type A test, the before and after repair leakage is determined using local leak rate testing methods and appropriate adjustment is made to the Type A test result.
As a result, the requirements of Paragaraph III.A.1.(a) of Appendix J to 10 CFR 50 were not met in that the Type A test, started at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, September 13, 1983, was not terminated and a separate Type A test started and performed subsequent to isolation of the excessive leakage path at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, September 13, 1983.
This resulted in licensee acceptance and reporting to the NRG, as required by Paragraphs III.A.l.(a) and_V.B of Appendix J to 10 CFR 50, an incorrect containment leakage status.
Acceptance of the incorrect containment leakage status further resulted in an unauthorized termination of the Type A test in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by Paragraph III.A.3.(a) of Appendix J to 10 CFR 50 which incorporates the test requirement of paragraph 7.6 of ANSI N45.4.
- 3.
A supplemental (verification) test performed at 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, September 14, 1983, after the conclusion of the Type A test yielded a difference between calculated and metered change in containment air mass of 24.88 pounds during a 1.667 hour0.00772 days <br />0.185 hours <br />0.0011 weeks <br />2.537935e-4 months <br /> test.
Misapplication of the full allowable error to the difference between the Type A test result and supplemental test results of 0.25 La, equivalent to 138 pounds per day, caused the licensee to accept the supplemental test.
When reduced to rates in terms of pounqs per hour, the difference between Type A and supplemental rest results of 15 pounds per hour does not meet the error acceptance limit specified in Paragraph III.A.3.(b) of 5.75 pounds per hour.
As a result, the requirements of Paragraph III.A.3.(b) of Appendix J to 10 CFR 50 were not met and when the difference between the Type A test.result and the supplemental test result did not meet the error acceptance limit, the reason was not determined, corrective action was not taken, and a successful supplemental test was not performed.
RESPONSE
(1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Portions of the violation are acknowledged to be correct.
Each of the examples specified in the notice will be addressed separately.
ITEM (1) indicates that seven penetrations, which during an accident are potential air leakage paths, were not vented and
- drained, as required by Appendix J,
paragraph III.A.d. (d).
Following the inspection, further review, including discussions with Region II personnel, revealed that only two penetrations, numbers 47 and 89, were not properly drained and vented.
However, the measured as-left Type C leakage for these valves was zero; hence, the penalty which should have been added to the Type A results would have had no effect on the test outcome.
ITEM (2) indicates that the 1983 Type A test was not properly restarted after isolation of excessive leakage which prevented meeting the acceptance limit of paragraph III.A.l.(a) of Appendix J. As noted in the report, the start time of 1300 September 13, 1983 was chosen with the expectation that subsequent to filling the secondary system an acceptable leak rate would be obtained.
The volume was apparently not adequate in the steam generators to complete the leak rate test.
A misinterpretation of Appendix J in regards to secondary leakage resulted in the leak rate test not being restarted after manipulating steam generator isolation valves.
This misinterpretation did not materially affect the test results.
ITEM (3) indicates that the supplemental (verification) test was improper and did not meet the requirements of Paragraph III.A.e.(b).
As noted in the inspection report, the verification test was conducted using the pump back technique specified in the Surry Technical Specifications.
As a result of further review since the time of the test, we acknowledge that the allowable error of 0.25 La should have been applied as a leakage rate, and therefore the measured mass difference during the pumpback was improperly compared to La.
This improper comparison led to the termination of the verification test prior to achieving a satisfactory leakage rate error band.
(2)
REASONS FOR VIOLATION ITEM (1)
The two improperly vented penetrations were included in the Type A test procedure lineup. They were not vented and drained due to an oversight in the review of-the procedure prior to initiation of the test.
ITEM (2) The test was not restarted following secondary manipulations due to a belief that a restart was not necessary, as discussed above.
ITEM (3) The verification test procedure incorrectly did not require comparison of La, as a leakage rate per day, to the difference between metered and calculated mass.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Prior to the recently completed ILRT on Unit 2 this refueling, all penetration valve lineups were reviewed and updated to ensure that penetrations required to be vented and drained were verified to be in the correct configuration.
Any penetration which could not be vented had its as-left Type C leakage added to the Type A test final results.
The Type A procedure was reviewed to verify that it adequately presents criteria for test termination, in accordance with Bechtel Topical Report BN-TOP-1.
An attachment was* added to our ILRT procedure (2-PT-16.3) to perform a superimposed leakage verification test in lieu of the makeup method.
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The changes made as a result of the above revisions of the Unit 2 procedure will be permanently incorporated. Similar changes will be made to the Unit 1 procedure prior to their use for the next Unit 1 leak test.
(5)
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance has been achieved in that the necessary revisions were reflected in the Unit 2 test procedure used during the recent successful ILRT.