ML19256D258

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IE Insp Rept 50-289/77-11 on 770404-19.Noncompliance Noted: Failure to Implement Integrated Leak Rate Test Procedure
ML19256D258
Person / Time
Site: Crane Constellation icon.png
Issue date: 05/10/1977
From: Higgins J, Martin T, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19256D184 List:
References
50-289-77-11, NUDOCS 7910170770
Download: ML19256D258 (12)


See also: IR 05000289/1977011

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U.S. NUCLEAR REGULATORY COMMISSION

0FFICE OF INSPECTION AND ENFORCEMENT

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Region I

Report No.

77-11

Docket No.

50-289

Category

C

License No. l'R-50

Priority

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Licensee:

Metropolitan Edison Comoany

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P. O. Box 542

Readino, Pennsylvania

19603

Facility Name:

Three Mile Island, Unit 1

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Inspection at: Middletown, Pennsylvania

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Inspection conducted: April 4-19, 1977

/o[77

Inspectors:

gins

date signed

/J.' C.p& k

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T. T. Martin

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' date signed

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date signed

Approved by:

P.6.1 M h

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E. C. McCabe, Jr., Chief, Nuclear

date signed

Support Section No. 1, RO&NS Branch

Inspection Sumary:

Inspection on Apri's 4-19, 1977

(Report No. 50-289/77-11)

Areas Inspected:

Routine unannounced inspection: refueling activities, including

fuel handling, core verification and operator training; diesel generator maintenance

and sampling system valve replacement; planned testing of systems disturbed during

refueling; snubber surveillunce; and, integrated leak rate testing.

The inspection

involved 119 inspector hours on site by two NRC inspectors.

Results:

Five areas were inspected, with no noncompliances found in four.

One

apparent item of noncompliance was found in one area (deficiency - failure to

implement integrated leak rate test procedure - Paragraph 8.g.(2)).

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DETAILS

1.

Persons Contacted

The below technical and superviscry level personnel were contacted.

a.

Metropolitan Edison

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Mr. R. Barley, Lead Mechanical Engineer

Mr. N. Brown, Administrator, Nuclear and Technical Training

Mr. J. Colitz, Unit 1 Superintendent

Mr. W. Cotter, Supervisor, Quality Control

Mr. R. Harper, I&C Maintenance Supervisor

Mr. C. Hartman, Engineer

Mr. N. Hernoisey, Maintenance Foreman

Mr. J. Heverling Security Specialist

Mr. J. Hillbish, Lead Nuclear Engineer

Mr. D. Huffman, Technical Support Engineer

Mr. G. Kunder, Supervisor of Operations

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Mr. E. Lawrence, I&C Foreman

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Mr. J. Moran, Licensing Engineer

Mr. J. O'Hanlon, Unit Superintendent of Technical Support

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Mr. J. Potter, QC Assistant

Mr. M. Shatto, Nuclear Engineer

Mr. B. Smith, Shift Superintendent

Mr. R. Summer, Nuclear Engineer

Mr. R. Van Stry, Administrator, Nuclear and Technical Training

b.

Other Licensee Personnel

Mr. R. Ely, Gilbert Associates Engineer

Mr. M. Nelson, General Public Utilities Service Corporation

Engineer

Mr. R. Shirk, Gilbert Associates Engineer

c.

NRC Accompanying Personnel

Dr. D. Lurie, Applied Statistics Group, Executive Director for

Operations, USNRC (April 14-16,1977)

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2.

Previous Inspection Item Uodate

(Closed) Unresolved Item 289/77-09-12:

Review of Surveillance

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Procedure 1303-6.1, Revision 3, dated April 9,1977, against

Appendix J to 10 CFR 50, American National Standard N45.4-1972 and

Technical Specification 4.4 showed that concerns noted in item 77-

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09-12 were adequately addressed. Additionally, several systems

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identified as not properly vented were corrected by the issuance of

a procedure Temporary Change Notice.

The inspector had no further

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questions in this area.

3.

Refueling Activities

Log and record review, personnel interviews, and video tape viewing

was employed to verify accomplishment of the following.

a.

Fuel handling crew training.

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b.

Pre-refueling equipment surveillance tests.

c.

Containment Integrity Establishment.

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d.

Core criticality monitoring during new fuel insertion.

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e.

Periodic Boron concentration determination.

f.

Fuel accountability records maintenance,

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g.

Daily refueling equipment and cavity status surveillance

checks.

h.

Licensed operator assignments.

i.

Core assembly final verification.

The refueling was completed in five days with no significant pro-

blems encountered.

No unacceptable conditions were identified.

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4.

Refueling Maintenance

a.

Work Requests Selected for Revier

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(1) WR#16974 - Replacement of Diesel Control Circuit BFD

Relays.

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(2) WR#19361 - Inspection and Replace,.ent of Diesel Cam

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Shaft and Rollers.

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(3) WR#19524 - Replacement of Secondary Sampling System

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CA-V54 Valve Seats.

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b.

Acceptable Areas

No unacceptable conditions were found in the areas of work

approval, quality assurance requirements, redundant system

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operability checks, post-maintenance test requirements,

jumper control, and maintenance personnel qualifications.

c.

Unresolved Area

}.

The licensee designated First Class Electrician and helper

performing the BFD relay replacement were observed by licens-

ee QA and the NRC inspector. A procedural fault was detected

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by the observers and a procedure change was effected in the

prescribed manner. When a second fault was detected, the

entire procedure was reviewed, resulting in identification

of a third fault. Completion of the procedure identified

two more faults, one of which had been caused by the pro-

cedure changes. Actual equipment performance was evaluated

to be proper. The inspector questioned the validity of the

already accomplished use of this procedure on the

"A" diesel,

especially the assurance of operability in all modes.

This

is Unresolved Item 77-11-04.

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5.

Startup Planning

Plans to verify, before startup, operability of systems disturbed

during the outage were reviewed, including post-maintenance testing,

selected precritical checklists, and the plant heatup and startup

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procedtres. No unacceptable conditions were identified by this

review,

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6.

Snubber Operability Surveillance

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Examination of the licensee's snubber test rig and observation of

a demonstration of its capabilities indicated that test capability

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was limited to the ability to check snubber stroke and verify lock-

up and bleed capability without defining the velocities involved.

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The licensee later obtained and the inspector witnessed use of a

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functional test de/ ice which showed that some snubbers did not meet

test criteria. This area will be reinspected.

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7.

CILRT Chronology

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The inspector witnessed the initial periodic CILRT at Three Mile

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Island, Unit 1.

A general chronology of the witnessed events

follows:

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4/13

Initial Containment Inspection - Reactor Building

interior not ready for CILRT.

4/14

Containment Inspection completed satisfactorily.

4/15 0500

Commenced pressurization.

1130

Pressurization stopped for internal inspection per

procedure at 12 psig.

No problems noted.

4/16 0600

Reactor Building p assure at approximately Pa + 0.2

psi. Commenced stabilization period.

1000

Stabilization period complete.

1230

Initial leak rate measurements indicate mass point

leakage of 0.2%/ Day.

Licensee began leak searches.

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2100

After 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> of data mass point technique leakage

is 0.1847%/ Day with a 95% confidence interval of

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0.0160%/ Day.

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2115

Licensee has corrected sore packing and fitting leaks

during the leak surveys.

(e.g. PP-V46 packing leak,

BS-V37C and BS-V37D reducer leaks)

2300

Leak rate appears to have decreased.

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4/17

0245

Pressure has dropped approximately 0.2 psi.

License

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repressurized Reactor Building to Pa + 0.2 psi.

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0730

After 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> leak rate is approximately Lt.

2130

17.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> data indicates a mass point leakage of

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0.1094%/ Day with a 95% confidence interval of 0.0083%/

Day.

2230

Commenced pressurizing steam generator "A" to 50 psig.

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2400

During the day, licensee had conducted extensive leak

searches using SNOOP leak detection fluid, ultrasonic

detectors, flowneters and pressure gages.

Valve line-

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ups have been shifted several times and some leaks have

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been repaired without performing local leak rate checks.

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These repairs included the atmosphcric flanges down-

stream of LR-V3 and seven leaks behind the leak rate

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test panel.

4/18

0100

There appears to be possible diurnal bias in the test

data with higher leak rates during the day (warm,

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clear and sunny) and lower leak rates at night (cold

and clear). The licensee is conducting various evolu-

tions that also could affect the leak rate, making it

difficult to sort out the various effects.

0300

Licensee has depressurized steam generator "A" and

rechecked system lineups.

Commencing new 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

CILRT.

0630

Mass values again dropping off with daylight.

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Licensee has positioned equipment hatch shield in

an attempt to limit diurnal cycling of containment.

1800

Mass values leveling off with sunset.

2400

Mass vaks showing an increasing trend although

there is noticeably more data scatter than during

the day.

4/19

0300

After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of data, mass point leakage is

0.0553%/ Day with a 95% confidence interval of

0.0098%/ Day.

0730

Commenced superimposed leak test.

1200

Calculated leakage is below the lowest acceptance

criterion for the verification test after 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

This could be due to weather conditions negating

the diurnal effect previously measured.

Today is

cloudy and not as warm as were the previous 2 days.

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1530

Eight hour verification test completed. At approx-

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- imately 1330 the sky cleared and mass values began to

drop. This duplicated weather conditions during the

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CILRT.

Preliminary calculations indicate

that the superimposed leak rate falls within the

acceptance criteria.

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8.

CILRT Results

a.

Initial CILRT Failure

Test data taken on April 16, 1977, with the Reactor Building

at Pa (50.6 psig) indicated a leakage by mass point analysis

of 0.1847%/ Day.

Since packing and fitting leaks were repaired

without preliminary local leakage tests, the leakage from indi-

vidual paths is unknown. Also, valve lineups were shifted and

the steam generators were partially pressurized with instrument

air.

Both section III.A.1.(a) of Appendix J to 10 CFR 50 and pre-

cautions 3.5 and 3.6 to S.P. 1303-6.1, Three Mile Island Reactor

Building Integrated Leak Rate Test Procedure, prohibit leak

repair during a continuing CILRT.

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The initial CILRT was consequently evaluated by the inspector

as a failure due to:

approximately 2 days of data indicating a leak rate in

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excess of the acceptance criteria; and,

the many fitting and packing leaks corrected after the

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start of the test.

b.

Satisfactory CILRT

The Three Mile Island CILRT was conducted pursuant to Surveil-

lance Procedure 1303-6.1, Revision 3, dated April 9,1977.

The final CILRT was conducted from 0300, April 18,1977, to

0700, April 19,1977. A very noticeable diurnal effect in the

measured mass data was experienced.

Preliminary analysis of

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the test data from 0300, April 18,1977, to 0700, April 19,

1977, indicates that this CILRT met the acceptance criteria.

The inspector's independently calculated leak rate by the mass

point technique was 0.0553%/ Day with a 95% upper confidence

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level limit of 0.0651%/ Day. The data from 0500, April 18,1977,

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to 0500, April 19,1977, indicates a lower leak rate of 0.042%/

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Day.

c.

Verification Test

Verification test results appear to be satisfactory with a

measured , leak rate of 0.099%/ Day.

The verification test accept-

ance c.iteria are:

(Li + Lam

.25 La) < Lvm < (Li + Lam + .25 La) where:

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= Superimposed Leak Rate = 207 SCFH = 0.056%/ Day

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Lam = Measured containment leak rate = 0.055%/ Day during

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the CILRT

La = Maximum allowable leak rate = 0.1%/ Day

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Lvm = Measured leak rate during the verification test

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= 0.099%/ Day

Thus:

0.086 4 0.099 < 0;136.

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d.

Acceptable CILRT Areas

Except as noted in other sections of this report, the following

areas were identified as acceptable.

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(1) General inspection of accessible interior and exterior

surfaces of the containment structures and components

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prior to the CILRT for indice2 ions of Structural dete-

rioration.

(2)

Inspection of reactor building to verify that no high

pressure sources were present and that instrumentation

was suitably located.

(3) Review of instrument calibration records.

(4) Witnessing of licensee data takers during the CILRT's.

(5)

Independent verification of raw data conversion to com-

puter inputs.

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(6) Review of various system lineups for proper system venting

and imposition of any artificial leakage barriers.

(7) Witnessing of quality control participation in CILRT.

(8) Verification that test prerequisites were satisfactorily

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met.

(9) Witnessing of performance of test and control room personnel

during the CILRT, including determination of proper manning

with qualified personnel, proper use of procedures and main-

tenance.of the Log of Events.

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(10) !?tness of leak searches of the pressurized containment

volume with leak detection fluid, ultrasonic detector,

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pressure gages and flowmeters.

(11) Icposition of the superimposed leak rate during the verifi-

cation test.

(12) Independent calculation of test results from raw. data.

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e.

Type C Testing

The licensee currently does not Type C test CIV's in systems

not vented during the Type A test and normally filled with

water and open to the containment under post accident con-

ditions as required by Section III.A.I.(d) of Appendix J.

He has, however, requested an exemption from NRR. The in-

spewtor had no further questions in this area.

f.

Reactor Building Inspection

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During the initial Reactor Building inspection on April 13,

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1977, the inspector identified several areas of concern:

bottles of pressurized gas in the Reactor Building, some " lay

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flat" type plastic was impeding venting of containment isola-

tion valves; some instrumentation was not placed per the pro-

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cedure; puddles of water were on the reactor building floor;

and, weld channels used during.preoperational testing of the

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liner were not vented.

During the second inspection on

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April 14,1977, the inspector confirmed that the above areas

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were corrected except for the weld channel venting. The

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licensee had vented readily accessible weld channels (34 of

an estimated 75 total).

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Since the licensee was unable to show that the ueld channels

would survive a Design Bas {s Accident, they constituted a

potential artificial leakage barrier during the CILRT. This

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item (77-11-02) will be referred to NRC management for further

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review.

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g.

Valve Lineups

Inspector sampling check of valve position conformance to pro-

cedure valve lineup 3.heets and of venting of systems external

to the test vohme to prevent artificial leakage barriers

identified no inadequacies, except as noted in the following.

(1) During the leak search, pressure gages were placed on

the vents of two zones of the PP system to aid in leak

detection.

These constituted artificial leakage barriers

and were removed for the final CILRT.

During a Reactor

Building tour the inspector noted a pressure buildup in

part of the PP zone to the equipment hatch door seal's.

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That zone of the PP system was vented but a shut pressure

control valve isolated the portion between the door seals

from the vent path.

The licensee vented this area and

also the corresponding area of the PP system associated

with the personnel air lock. The inspector had no further

questions in this area.

(2) Valve LR-V7

At approximately 5:30 a.m. on April 17, 1977, valve LR-V7

was found shut when required to be open by step 6.4.e.(4)

of S.P. 1303-6.1.

This valve provides the vent path for

the containment isolation valve LR-V1.

The licensee sub-

sequertly opened valve LR-V7.

This is an item of non-

compl'ance of the Deficiency level (77-11-01).

h.

Type C Correction to Test Results

The licensee operated the Reactor Building Industrial Cooling

System during the Type A test.

The containment isolation

valves of this system were therefore not subjected to the post

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accident differential pressure, necessitating correction of

the Type A test results based on Type C tests of containment

isolation valves RB-V2A and RB-V7.

The recently completed

Type C tests of the valves totaled 12,380 SCCM or 0.0071%/ Day.

This leak rate was added to the preliminary Type A results to

obtain a corrected mass point leak rate of 0.0624%/ Day, which

is less than the acceptance criteria of 0.075%/ Day.

The

corrected leak rate at the 95% upper confidence level is

0.0722%/ Day, which is also less than the acceptance criteria

of 0.1%/ Day. The inspector had no further questions in this

area.

9.

Future CILRT Schedule

Section III.A.6.{a) of Appendix J to 10 CFR 50 requires that the

Commission review and approve the licensee's schedule applicable to

subsequent Type A tests, if any periodic Type A test fails to meet

the acceptance criteria. As stated in detail 7.a. the licensee

failed his initial CILRT attempt; the schedule for future Type A

tests is designated unresolved item 77-11-03.

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10. Unresolved Items

Items about which more information is required to determine accept-

ability are considered unresolved.

Paragraphs 4.c, 8.f and 9 of

this report contain unresolved items.

11. Exit Interview

A management meeting was held at Three Mile Island Nuclear Station

on April 19, 1977, with Mr. J. Colitz to describe the findings of

the inspection, including the Item of Noncompliance, the unresolved

items and the CILRT failure.

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