ML18151A046
| ML18151A046 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/08/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8709140350 | |
| Download: ML18151A046 (7) | |
See also: IR 05000281/1986036
Text
'-<* ,.
Docket ~o. 50-281
. License No. DPR-37
SEP O 81987
Virginia Electric and Power Company
- ATTN:
Mr. W. L. Stewart, Vice President,
Nuclear Operations
P. 0. Box 26666
Richmond, VA
23261
Gentlemen:.
SUBJECT:
NRC INSPECTION REPORT NO. 50-281/86-36
Thank you for your letter of April 8, 1987, in response to our Notice of
- Violation issued with Inspection Report 50-281/86-36 on March 2, 1987.
We
have evaluated your response and have concluded, on the basis identified in
Enclosures 1 and 2 to this letter, that the violation is correct as issued.
Accordingly, please ptovide an additional response to the Notice of Violation
pursuant to the provisions of 10 CFR 2.201 to this office within 30 days of the
date of this letter.
Enclosure 3 to this letter discusses your cont~inment integrated leak rate test
status.
As indicated in our letter of March 2, 1987, the "as found" Containment Inte-
grated Leak Rate Test (CILRT) is classified as a
11fai led" test.
Pursuant
to the requirements of Paragraph III.A.6(b) of Appendix J to 10 CFR 50, your
plant remains on the accelerated integrated leak rate test schedule until you
successfully pass two consecutive Type A leak rate tests.
If you request, and are granted, an exemption to the regulations by the Office
of Nuclear Reactor Regulation (NRR) which will allow the exclusion of certain
Type C tests results from the overall containment integrated leak rate, we will
re-evaluate your test status and schedule.
Should you have any questions regarding this letter and the enclosure, please
contact the Project Section Chief.
Enclosures:
(See page 2)
8709140350 870908
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Sincerely,
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J. Nelson Grace
Regional Administrator
,],
Virginia Electric and Power Company
2
Enclosures:
.
1.
Evaluation of Surry Denial
of Violation
2.
Explanation of the Elements
in the NOV
3.
Evaluation of the Containment
Leak Rate .Status
cc w/encls:
R. F. Saunders, Station Manager
N~ E. Clark, Manager - Nuclear
Programs and Licensing
bee w/encls:
- NRC Resident Inspector
Project Section Chief
F. Jape
H. Whitener
F. Maura, RIII
G. Arndt, Res.
Oocument Control Desk
Commonwealth of Virginia
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ENCLOSURE 1
EVALUATION OF SURRY DENIAL OF VIOLATION
Our evaluation of your denial of Violation 50-281/86-36-02 dated April 8, 1987,
indicates that you may have misunderstood the issue cited. The following para-
graphs and Enclosure 2 clarify the statement of the violation and the regulations
cited in support of the violation.
In your response you stated that you are in compliance with Paragraph III.A.l(d)
of Appendix J to 10 CFR 50.
Specifically, for Penetrations 46, 63, 64, and 66
through 71, you state that these penetrations are normally filled with water
and operating under post-accident conditions.
Therefore, according to
Paragraph III.A.l(d):
1) these penetrations are not required to be vented and
drained during the Type A test; 2) Type C tests must be performed on* these
penetration isolation valves; and 3) the Type C test results must be reported to
the Commission.
Our review indicates you met these conditions.
We agree with
your conclusion that you are not in violation of the above requirements of
Paragraph III.A.l(d) of Appendix J.
The citation, as issued, was against the requirements of Paragraph II.
Specifically, Paragraph II.E requires that the Type A overall integrated
leakage rate test include a summation of leakage through all potential leakage
paths.
For the nine penetrations identified, you established a water seal
during the Type A test and failed to adjust the Type A test result, using the
Type C test results, to obtain the overall containment
11as left
11 and "as found
11
1 eak rate.
As a basis for this position you state that the systems associated with these
penetrations are normally filled with water and operating under post-accident
conditions. While your assertion may be correct, it does not necessarily satisfy
the requ*irements of a water sealed system specified in Paragraph III.C of
Appendix J.
Standard Review Plan 6.2.6 requires that NRR review the design of
any system identified as a water sealed system to verify that, based on a single
active failure of any system component, the system design is consistent with the
requirements of Paragraph III.C.
NRR would not normally review a system for a
water seal unless it is specifically identified as such in the application.
Technical Specification Table 3.8-2 indicates these nine penetrations are
evaluated as potential air leakage paths.
No additional documentation could be
produced to support an NRR design review.
Consequently, the NRC must conclude
that these penetrations have not been qualified as water sealed penetrations.
In addition to the nine penetrations you consider water sealed, you also
excluded leakage through penetration 38, which was corrected prior. to the
Type A test, from the
11as found
11 containment integrated leakage rate .
In the exit interview at the conclusion of the inspection, your position was
that the above leakages would be excluded from the final Type A test result and
no further action would be taken.
Your position was confirmed in your
Integrated Leak Rate Test report which specified the official final leak rate
excluding the above leakages.
(This matter is also discussed in Enclosure 3.)
_Enclosure 1
2
While we believe your Technical positions may have some merit, you have not
established a legal basis on which to exclude leakage through the containment
boundary, from the "as left" and "as found
11 containment integrated leak rate.
Without a legal basis established by NRR review and approval on some other
defined basis, the regulations require that the overall containment integrated
leak rate include a summation of all potential air leakage paths and any
leakage corrected prior to the Type A test.
We conclude that the violation is correct as issued *
,,.
ENCLOSURE 2
EXPLANATION OF THE ELEMENTS IN THE NOV
In that the regulations cited in the Notice of Violation may have led to a
misunderstanding of the viol at ion, we offer the following brief statements of
our perception of the format used:
1.
Paragraph II of Appendix J was stated first to identify the specific
requirement that all potential leakage paths must be included in the final
Type A leak rate.
2 .. Paragraph !II.A.1.(d) was stated to highlight the fact that the penetra-
tions are not required to be drained and vented but Type C tests must
be performed.
3.
Paragraph III.C was stated to point out that a penetration identified
for a Type C test is normally considered as a potential air leakage path
uhless otherwise evaluated by NRR in accordance with the requirements of
- this paragraph for a water sealed system.
4.
Technical Specification Table 3.8-2 was identified in that it indicates
that NRR has not qualified the nine penetrations you identify as water
sealed.
No additional documentation indicating that NRR has reviewed the
system design for these penetrations was provided during the inspection.
If additional documentation has been identified which relates to this
question, we will reevaluate our findings.
5.
The statement of violation was worded to show that you had two options
to achieve the requirements of Paragraph II:
to vent and drain the
penetrations or to use the Type C test results to adjust the overall
integrated leak rate.
The violation is that you did not implement
either option .
'.J'
ENC 1_0SURE 3
EVALUATION OF THE CONTAINMENT LEAK RATE STATUS
Your containment Integrated Leak Rate Test report submitted to the Commission
on March 30, 1987, specifies the official overall containment integrated leak
rate at the 95% Upper Confidence Limit (UCL) as 0.0638 wt.% per day ("as left")
and 0.0728 wt.% per ciay (
11as found").* This analysis excludes containment
leakage for nine penetrations (46, 63, 64, 66, 67, 68, 69, 70, 71) which you
consider water sealed post accident (discussed in IE Report 50-281/86-36,
paragraph 2.a.(3)) and leakage through penetration 38 for which you consider
your evaluation and corrective action as justification to exclude the corrected
leakage (discussed in IE Report 50-281/86-36, paragraph 4.e). Since the above
leak rates are less than the allowable leakage of 0.075 wt.% per day, you
conclude that you have successfully passed both the "as left
11 and
11as found'i
containment integrated leak rates.
The information provided to the inspector at tbe time of this inspection and
documented in IE Report 50-281/86-36, indicates that NRR has neither reviewed
nor approved the nine penetrations, listed above, as water sealed penetrations.
Additionally, no record is available to indicate that the corrective action
plan, system modifications and procedural changes you have implemented relative
to penetration 38 have been evaluated and accepted by NRR as a sufficient basis
on which to exclude the leakage corrected prior to the Type A test from the
11as found
11 integrated leak rate.
As. indicated in Enclosure 1,' you have not
established a legal basis to exclude containment leakage measurements required
by the regulations from the final
11as left
11 and
11as found
11 containment integrated
1 eak rate.
Although not reported as the official test results, you provide in your report
the containment integrated leakage rates, including the leakage through the
above penetrations, as 0.065 wt.% per day (
11as left
11 ) and 0.27 wt.% per day
(
11as found
11 ).
Based on the data presented in your report we concur that the
"as left
11 containment leakage rate of 0.065 wt.% per day is within the allowable
leakage limit of 0.075 wt.% per day.
We, therefore, have no question regarding
the startup and operation of the plant after the leak rate test. However, we
disagree with* your conclusion that you have passed the
11as found
11 integrated
leak rate. The "as found
11 leak rate of 0.27 wt.% per day exceeds the allowable
leakage limit.
As indicated in our letter of March 2, 1987, your November 1986 Type A test
has been classified as a failed test for the
11as found
11 containment condition.
Pursuant to the requirements of 10 CFR 50 Appendix J, Section III.A.6(b) your
plant remains on the ~ccelerated integrated leak rate test schedule.
The position embodied in our Tetter of March 2, 1987, and in this letter does
not reflect a judgement as to the merit of your technical positions.
Our
inspector made no attempt to perform a license and system design review.
The
responsibility for reviews of this nature is assigned to NRR.
If you choose
Enclosure 3
2
- . j
t*
to obtain the appropriate review through NRR and are granted exempiions which
establish a legal basis for exclusion of the penetration leakage disc..uss*e*d
above, the Region will, based on the result of this review, reevaluate fne
status of your November 1986
11as found" leak rate and your integrated leak.rate
test schedule .