ML19324B314

Partially Withheld Investigation Rept 4-87-011.Major Areas Investigated:Review of Whether Util Reported False as-found Leakage Rate Values in Integrated Leak Rate Test Rept

ML19324B314
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/19/1989
From:	Driskill D, Hayes B, Van Cleave V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19324B311	List: ML19324B310 ML19324B314
References
4-87-011, 4-87-11, NUDOCS 8911060037
Download: ML19324B314 (36)

Text

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l CASE No.

4-87-011

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Nuclear Regulatory Commission

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Report of Investigation b

Arkansas Power and Light:

l Intentional Violation of 10 CFR, Part 50, L

Appendix J

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Reponed by 01: RIV 6

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15':/,';U,5 POWER AliD LIGHT:

1 ItTEl:TIONAL VIOLATION OF 10 CFR, PART 50, APPEND 1X d i

Licensee:

Case No.: 4-87-011

- Arkanses Power and Ligtt Report Date: April 19,1989 Pest Office Box 551 Little Rock, Arkanses 72203 Control Office: 01:RIV Docket No.: 50-313/368 Status: CLOSED Reported by:

Reviewed by:

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- Virper.ta van cleave Investigator for Donald D. priskill, Dyector Office of Investigations Office of Investi iatichs-f Field Office, Region IV Field Office ' Reg <on IV Participating Personnel:

Approved by:

L Joseph Tapia, Project Engineer

&f Ben B. myes, Director Office of Investigations i

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y SYNOPSIS In NNember i9E7 the Nuclear Regulatory Comission (NRC). Region IV (RIV).

Regional Administrator requested an investigation to detemine if Arkansas Power and Light (AP&L) reported false as-found leakage rate values in the integrated leak rate test (ILRT) report written as a result of the ILRT conducted at Arkansas Nuclear One (AND) Unf t 2 in April 1985. During the conduct of this ILRT. although two valves in the post accident samplin

. (PASS) return line were founc 10 be leaking, both the as-found and as g system eft leakage rates reported for these valves were identical in the ILRT report forwarded by AP&L to the NRC.

The Office of Investigations (01:RIV) investigation determined that ne as-found leakage rate of the PASS line was calculated by AP&L prior to the reversal of the improperly installed valves. The figure reported in the ILRT report for the as-found leakage rate was actually the rate calculated after reversal of the valves. Although internal AP&L documentation and testimony by.

AP&L employees indicated that AP&L employees were aware of the false figures in the ILRT report. AP&L officials made no attempt to resolve the matter with

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the NRC. Documentation and testimony further revealed that, had the leakage rates been properly reported, the as-found ILRT test would have been declared a failure.

The investigation further disclosed that following the discovery of the i

improperly installed valves. AP&L's Engineering Department r.otified the NRC of the event by telephone in accordance with the requirements of 10 CFR Part 50.72. Additionally. Engineering prepared a report of abnomal conditions (RAC) and forwarded it to the Plant Safety Connittee (PSC) which detemined' that a Licensee Event Report (LER) in accordance with 10 CFR, Part 50.73 should be prepared and forwarded to the NRC regarding the incident. This I

decision by the PSC was subsequently overruled by the Licensing Division which determined that a LER would be prepared and forwarded to the NRC for information purposes only. A draft LER was prepared but was never finalized or sent to the NRC. AP&L officials were unable to explain why this draft LER remained in the Licensing Division for over two years without finalization.

It was detemined that an AP&L employee knowingly reported false as-found leakage rate values for the PASS return line on the ILRT re rt forwarded to the NRC following completion of an ILRT at ANO Unit 2 in ril 1985.

In addition company officials were aware that no as-found les age rate was c.cmputed for the PASS line but failed to notify the NRC of this and failed to finalize and forward an LER to the NRC regarding this event.

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SYNOPS15 In November 19E7. the Nuclear Regulatory Comission (NRC). R6 pion IV (RIV),

Regional Administrator requested an investigation to detemine if Arkansas Power and LigM. (AP&L) reported false as found leakage rate values in the integrated leak rate test (ILRT) report written as a result of the ILRT conducted at Arkansas Nuclear One (ANO) Unit 2 in April 1985. During the conduct of this ILRT, although two valves in the post accident samplipp system I

(FA55) return line were found to be leaking, both the as-found and as-eft leakage rates reported for these valves were identical in the ILRT report forwarded by AP&L to the NRC.

The Office of Investigations (01:RIV) investigation detemined that no

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as-found leakage rate of the PA55 line was calculated by AP&L prior to the i

reversal of the improperly installed valves. The figure reported in the ILRT J

report for the as-found leakage rate was actually the rate calculated after i

reversal of the valves. Although internal AP&L documentation and testiseny by i

AP&L employees indicated that AP&L employees were aware of the false figures in the ILRT report, AP&L officials made no attempt to resolve the matter with the NRC. Documentation and testimony further revealed that, had the leakage rates been properly reported, the as found ILRT test would have been declared i

a failure, i

1 The investigation further disclosed that following the discovery of the i

improperly installed valves, AP&L's Engineering Department notified the NRC of l

the event by telephone in accordance w<th the requirements of 10 CFR part j

50.72. Additionally,EngineeringpreparedareportofabnormalcondItions i

(RAC)andfemardedittothePlantSafetyConnittee(PSC)whichdetermined that a Licensee Evtnt Report (LER) in accordance with 10 CFR Part 50.73 should be prepared and forwarded to the NRC regarding the incident. This

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r decision by the PSC was subsequently overruled by the Licensing Division which detemined that c LER would be prepared and femarded to the NRC for information purposes only. A draft LER was prepared but was neve. finallred or sent to the NRC. AP&L officials were unable to explain why this draft LER l

rentined in the Licensing Division for over two years without finaliattion.

It was determined that en AP&L employee knowingly reported falso as found leakage rate values for the PAS $ return line on the ILRT report forwided to the NRC following completion of an ILRT at ANO. Unit t in April 194;,.

In addition company officials were aware that no as-found leakape rate was computed for the Pass line but failed to notify the NRC of this and failed to finalize and forward an LER to the NRC regarding this event.

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f TAELE OF CONTENTS l

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SYN 0F$l$.............................................................

1 ACCOUNTAL1LITY.......................................................

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l AFPLICABLE REGULAT10N$...............................................

7 DETAILS OF INVESTIGATIONS............................................

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l Purpose of Investigation........................................

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1 54ckground.......................

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l Interview With Licensing Engineer, ARO.....

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Interview With m $uclear Licensing and SafetyklantLicensingEngine 10 i

Interview With m.

Specialist, AW0................................................

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Interview With M. Plant Licensin It Interview With M. Engineer II,g Supervisor. ANO.

AN0..............

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interview With m. Plant Engineer and 1985 ILRT Test Director. AN0.............................................

13 Interview With m. Mechanical Engineering l

l 59pervisor. A 14 i

Interview With

. Plant Engineering i

Supervisor, AN 14 i

Interview With

. General Mana I

AN0.......................................ge r for P l ant Support.

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Interview With special projects Manager. ANO...

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Interview With

. Consultant....................

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l Interview With Start-up Engineer. Sechte1.......

16 Interview With ngineering Specialist for Special Services and T 1..................................

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Interview With

. Supervisor of Special Services and Testing Group, echte..................................... 13 Review of ILRT Report...........................................

20 Review of LLRT Data Sheets.....................................

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Review of ILRT Chrono 1 ical L tt i

Review of Memo from to Dated March 4. 1986.......

22 Dated March 17 1987 Review of Memo from M to Internal AP&L Memo from M......

23 Review of AND-87-11302:

Dated g/tt/87.......................................'...........

23 Review of Action Tracking Form From M to M to M to M Dated 10/15/87.............................

24 Review of Memo from to M Dated 12/17/87.............

24 Review of RAC-t-8516 t

5/1 85............................. 25 Revtew of Memo From to Dated May 8. 1985..........

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Review of Memo From M to M on 5/g/85..................

26 Review of LER Number AN0: 85-2-00626.............................' 26 I

Review of Minutes of PSC Meeting Number PSC-85-0gl..............

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Re vi ew of NRC Computer Records.................................

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Revi ew of AND Engi neeri ng Log................................... 26 i

Review of Overdue RACs..........................................

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Case No. 4 87-011 5

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TABLEOFCONTENTS(Continued)

.PASt.

Review of Records Obtained From Bechtel Engineering.............

27 Re view of I E Inf onna tion Notice #85 71.......................... 28 Review of AND Response to It Notice 86 71.......................

28 Pequest for Office of General Counsel (DGC) Interpretation of 10 C F R, Pa rt 60. Ap pend i x J a nd OGC ' s Res ponse................. 29 W111 fulness / Intent..............................................

29 A9ent's Conclusion..............................................

31 LIST OF EXHIBIT5.....................................................

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APPLICABLE REGULATIONS i

Ailecatice: Allened Violation of 10 CFR. Part 50. Appendix J Reportino l

Ff0V1rement l

10 CFR, Part 50 Appendix J. !!!. Leakepe Testing Requirements.

l 10 CFR, Part 50, Appendix J V.

Inspection and Reporting of Tests.

l 10 CFR, Part 50.71.

Maintenance of records, making of reports.

10 CFP, Part 50.73.

Licensee event report system.

Title 42 USC Section 7236 of the Atomic Energy Act (AEA) of 1954, as amended i

Section186(t): Revocation.

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Case No. 4 87-011 8

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DETAILS OF INVESTIGATION Purpose e' investination This investigrtion was initiated to detemine whether Arkansa's Power and Light (AF&L) Arkersas Nuclear One (ANO) Personnel attempted to deceive the Nuclear Pegulatory Comission (NRC) by(reporting false as found leakage rate values in the integrated leak rate test ILRT) report written as a result of the ILRT conducted at Unit P in April 1985.

Beckeround An WRC required ILRT was conducted in April 1965 at the Unit 2 contaiment of AWO. Nring the conduct of this ILRT. it was discovered that two Target Rock solenoid valves. 25V5633-1 and 25V5633 2. in the post accident sampling system comple)ted.

(FA55 return 11ne were leaking. This line was isolated and the 14RT was After completion of the ILRT the engineering department detemined ths.t the leak was due to the Improper installation of these isolation valves which rendered them incapable of resisting pressure in opposition to the nomal direction into the containment sump suction line. To i

j correct this problem, the valves were reversed. After reversal, a local leak rate test (LLRT) was conducted on the PA55 return line.

In AP&L's report sent to the NRC concerning this ILRT both the as-found and the as-lef t leakage rates for valves 25V5633-1 and 25V5633 2 were identical.

i The NRC had expected that the as-found values would have been greater than the as-left values since it had been discovered that these two valves were leaking I

due to their improper installation. On January 13. 1986 NRC issued NRC Inspection Report 50 368/85-15.

In this inspection report, the identification of the as found leakale in the PAS $ line and the need to include this leakage as a penalty to the !.RT rasults were considered as unresolved items.

The NRC subsequently received a copy of an internal AP8'. memorandum dated March 4. 1986, which stated that the reported as found leakage rate values in the ILRT report were actually the as-left values, and the as-found values for this PA55 return line had not been measured. However, the licensee took no further action to resolve this sletter.

1987,theNRCRegionIV(RIV)RegionalAdministratorrequested On November 5 anOfficeofInvestigations(01:RIV)investogationoftheILRTconductedin April 1985 of the Unit I containment at AN0 to determine whether erroneous as-found leakage values were reported to the NRC in en attempt to deceive the agency and avoid additional ILRTs that might have been required had the licensee notified the NRC of the true as-found leakate rete results (hhibit1).

Interview With M. Licensine Ennineer. AND M was interviewed by NRC Investigator Virginia Van Cleave and NRC ProjectE ineer Jo eph Tapia on January 11-12. 1988, at AND. Russellville. AR (hhibit t.

stated that part of her duties was to serve as a liaison between AN and the NRC r insediate supervisor was M. plant Licensing Supervisor.

stated that an ILRT was conducted of AN0's Case No. 4-87-011 9

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i Unit 2 in April 19P5. During the ILRT, it was discovered that two Target Rock

i solenoid valves in the PASS return line were leaking. This line was isolated and the 1LRT was completed. Following completion o" the ILRT, it was dis-covered that these two valves were installed backwards and could not withstand the containment pressure during the ILRT. The valves were reversed and an LLRT was performed on this line. M admitted that the as found leakage shown in the ILRT report for this line was actually the as left leaka9e rate computed following the reversal of the valves. There was no explanet' on in the ILRT report concerning this design deficiency or the valves' reversal.

Accordin to M no caltv14 tion of the as-found leakage rate was ever made.

stated that Tapia and M AN0's ILRT Test Director, had a difference of opinion as to the proper interpretation of 10 CFR, part 50,' Appendix d and the interpretation of the ILRT conducted in April 1985. However, she acknowledged that no one at ANO attempted to resolve this difference until Tapia elevated the issue from en unresolved ites to a violation.

In September 1987, M, Special Project Manager, requested that M. Enpinter calculate an estimated as-found leakage rate for air and water for tais PAIS line in its initial as-found position.

W en the improperly installed valves were initially discovered, a report of abnormal conditions (RAC)fety gensnittee {;P$C) wh ch determined that a Licensee was repared b theEppineeringDepartmentand fomarded to the plant sa Event Report (LER) should be prepared and forwarded to the NRC regarding this incident since it involved a breach of containment. M stated that M. Plant Licensing Engineer, received this RAC and prepared a draft LER which was never finalized or femarded to the NRC. W stated that she was unaware of the reasons this LER was not finalized and sent to the NRC.

m tated that on March 17. 1987 she prepared a memorandum to M in s

which she stated that the as-found ILIT conducted in April 1985 should be considered a failure since no actual as-found leakage rate of the PAS 5 return line had been determined. She further recensnended that the NRC Ap&L's be notified of assessment these events. She stated that she received no response to her memorandum.

According to M the PA$$ return line in huestion was installed in 1983 inresponsetotheThreeMileIsland(TMI incident. The desi tions were generated by techtel personnel)who, in her opinion,gn specifica-should have included an LLRT requirement but did not do so. Additionell, M stated that Sechtel representatives were present during the April duct of the ILRT. Bechtel representatives prepared the ILRT report and reviewed it. M was unaware of any contact between Ap&, and techtel concerning this specific LLRT.

Interview With M. plant Licension Ensincer Mp W was interviewed by Investigator Van' Cleave and project inser Tapia en January 11,1988 stated

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that in 1985 part of at ANO in Russellville AR (Emnibit 3).his duties included prei Unit 2.

He recalled receiving a RAC in 1985 concerning two Target Rock i

solenoid valves in the PASS return line which had been found leaking during i

the ILRT. He stated that he received this RAC from the PSC which had deter.

. mined.this was a reportable event stace it involved a breach of n einment.

M stated that he prepared a draft LER and femarded it to for his Case No. 4-87-011 10 6

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i approval, m recalled that be. W. and M. Manager of 5ptcial Projects, discussed the ILRT and the RAC. Although the inc< dent had I

tten reported by AF&L engineers to the NRC by telephone in compliance with l

10 CFR Part 50.72, W and M detemined it was not reportable under 10 CH lert 69.73. M stated that W and M detemined this was i

en ILRT repertable issue and should be included in the formal ILRT report i

subnitted tc the NRC. M told to prepare an LER for infomation purposes oni but, according to

. he never received his draft LER from M.

stated that at approximately the same time period he was t

removed from Unit 2 responsibility. Conteevently, he ferget about this LER since he never received it from M. M stated that approximately one

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month ago 6. the engineer now responsible for Unit ! LERs. asked him about this RAC and the LER. M said be told M that he was unaware of the status of the LER and was unable to assist M in locating l

his draft LER.

i Interview With

^. Nuclear Licensinn and Safety Soecialist. Ah0 m was interviewed by Investigator Van Cleave and Project Engineer Tapia t

on January 11, 1986, at AND in Russellville. AR (Exhibit 4). M stated i

that in approximately November 1987 he had been assigned an action item by M requesting that he review reportability requirements and detemine l

reportability of an incident which had occurred during the conduct of an ILRT i

of AN0's Unit 2 in 1985. According to M. following the discovery that two valves in the PA55 return line were leaking,ded to 11censin partment the Engineerin prepared a RAC in May 1985. This RAC was forwar the p5C which had detemined that this was a reportable event. Ma that i

following receipt of the action item in November 1987, h obtained a copy of the pert' pent RAC fromM orM. He then asked about the draft LER Dut, although M recalled preparing one in 1985, he was unable to toca11 where it could be located. M stated that he located the LER y

somewhere in the Licensing Division, probably in M office.

M stated that it was unusual for W to review a draft LER. Normal procedure at ANO was to prepare an LER in Licensing and forward it to the PSC l

for their concurrence. AP4L had a computer tracking system for incomplete RACs which, according to M showed this RAC as charged to the P5C secretary.

1 M stated that he reviewed all documentation and prepared and forwarded a assorandum to M on December 17. 1987 in which he outlined the events i

surrounding the conduct of the ILRT in 1985. He stated that on May 1. 1985, the shift supervisor and engineering personnel detemined that this taproper installation of the valves was reportable to the NRC in accordance with 10 CFR parts 50.72 and 50.73. In order to comply with 10 CFR 50.72, engineering ennel notified MRC headquarters of the event by telephone on May 1.1985.

subsequently prepared an RAC and forwarded it to the pSC. According to PSC minutes for May 15, 1985, i dic that the FSC concurred that is event was reportable to the NRC.

stated he was enable to locate av documentation te provide a basis for changing this decisiont however, the LER was never finalized by AP&L and forwarded to the NRC.

M stated it was his conclusion that should this incident occur today it would be reportable to the NRC under 10 CFR Parts 50.72 and 50.73. m 1

Case No. 4 87-011 11

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qualified this detemination by saying that his conclusion was based on current. interpretations of NRC regulations. He declined to state conclusively that the event should have been reported in 1986.

stated that he had no involvement in the conduct of the ILRT and no per e pation in discussions involving the RAC and LER at the time of preparation.

j Interview With -

. Plant Licensina sveervisor. AWO M was interviewed by Investigator Van Cleave and proat AND in Russellville. AR stated that i

January 11. 1988, the Licensing Division had no direct involvement in the cohduct of ILRTs.

i M hand ed the conduct of ILRTs. the preparation of the ILRT reports, and made all decisions concerning these matters. M recalled that Licensing i

received a RAC in 1985 concerning two valves found to be leaking during the conduct of an ILRT of AN0's Unit 2.

According to M. M was assigned i

the retponsibility of preparing an LER on this event following receipt of the RAC from the PSC which had detemined that it was a reportable event. W' recalled that Licensing detemined this would be reported for information

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purposes only, but was unable to recall Licensing's reason for reversing the l

PSC's decision. However. M

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• M detemined this would be i

reported in the ILRT report and not with an LER. M prepared a draft LER but W stated he was unable to recall why the LER was never finalized or sent to the NRC. M was also unable to explain why the RAC and draft LER remained on his desk for over two years without action bein taken on it.

M admitted.that he never returned the draft LER to andsaiditjust

'stipped through the cracks.'

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The as-found leakage figure reported in the ILRT report was. according to i

M actually the asC eft leakage rate computad after reversal of the 1mproperly installed valves. M temitted that no determination of the actual as-found leakage rate for this line was made prior to the reversal of the valves. M further admitted that although Tapia's inspection report identified this as an unresolved item. Ap6L did not pursue the matter after forwarding it to Engineering and Technical Support for resolution until Tapia elevated the matter to a violation. According to M. 'you have to set priorities and cannot do everything.'

i interview With 6 Ennineer II ANO m was interviewed by Investigator Van Cleave and jectEngineerTapia on January it.1988, at ANO in Russellville. AR (Eshibit 4. M stated that he was present at night durine the 1985 ILR" in quest on but said he had no involvement in the dec'sion making process. All decisions were handled by

. although techtel provided ILRT expertise end several.fepresentatives Who were present during the conduct of the ILRT. m recalled the discovery of the improper installation of the valves in the PASS return line and their subsequent reversal but did not recall anyWiscussion concerning the as-found and as-left fi9eres to,gorded in'the'3LRT report. -

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In September 1987. M stated that he received on action item from M requesting that he calculate an estimated as found leakage rate for both air l

and water for this PAS $ line. A said that he performed two estimated leakage rates assuming these valves were still in their initially improperly installed position. Based on these estimated calculations. M stated l

Case No. 447-011 12 l

I that tt deteminst that the as found lea 6 age rate of these two valves exceeded the maximum allowable leakage rate for the ILRT. Consequently the ILRT perfomed in.1985 should have been considered a failed ILRT.

stated thet he forwarded the results of his calculations to M throu

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1etervin Uith

. Plant Ennineer and 1985 ILRT Test Director.

I 29, was interviewed by Investigator Van Cleave and Project Engineer Tapia on January 12,1988, at Ak0 in Russellville. AR (Exhibit 7). M stated that he was the AND person responsible for the ILRT conducted on Unit 2 in 1985. M stated that a leak was discovered in the Pass return line. the i

line was isolated, and the ILRT was completed. Followin

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1LRT. Engineering discovered that two valves in the PA$$g completion of the line were installed backwards and thus were unable to withstand containment pressure. _M stated that on his instruction the Instrumentation Department at AND reversed these valves and then conducted an as-found LLRT. Consequently, according to M the as-found LLRT test results were identical to the as-left LLRT test results. M maintained that this was entirely his decision and he forwarded these figures of as found and as-left leak rates to Bechtel in California to be incorporated into the official AND ILRT report.

W claimed that he had several reasons for using the same figure for the as found and as left leakage rate. W stated tsat prior to the installa-tion of the PA$$ line containing the valves, the penetration in question was classified as a Type A test. However, upon installation of the PA$$ line, a unique situation was created which did not really fit Type A or Type C testing criteria.

M admitted that when the Tarpet Rock solenoid valves were installed AND neglected to place them on the ist of Type C testable valves.

Consecuently, the design deficiency went undetected from the time of their installation.

In orgler to correct the leakage problem. M stated that the valves ha reversed in order to seal in the accident direction.

According to this reversal made the valves Type C testable, so they were added to t e LLRT list. Additionally. W stated that he did not measure the as found leakage rate since the valves were not testable in the as found pcsition. There were not adequate valves installed for pressuri-nation in the accident direction and the valves were located in tw contain-ment sump drain line whici, was always filled with water. M maintained that the leaking fluid was water, not air. WEEEER admitted that it would have been possible to measure the water flow through the valves during the j

ILRT. but he maintained that the flow of air would not be directly comparable 4

to the flow of water.

Additionally with the as found leaksee rate, beca. W stated that he was not concerned use he believed the leakage was the result of an installed design deficiency. According to M. a design deficiency i

was not subject to MAC review. because the intent of the Appendia.1 tepulation,

was to identify containment degradation.

W admitted that APR's ANO Unit t ILRT would have been a failed as-founa ILRT in 1985 had all water drained from the sump and air been allowed to escape from the vent.

He further admitted that the ent on the ILRT toport l

was erroneous and afsleading. At the very least.

conceded. he should have clarified the issue on the ILRT report or declared the 1985 ILRT as-feend 4

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test a failure.

i Case No. 4-37-011 13

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _, _, _. _ _ _ _ _ _ _ _ _. _ _.. _ _ _ _ ~ _. _ _ - - - -

_--...,--,m

Stated that another valve, Number PCCW 38, was not quantified during the L T.

The as found leakapa for this valve was listed as inoperative on the !LRT report. M contended that this was a different situation because this particular valve could not be tested. Was not under water and was already on a required Type C test list.

Interview With rvisor. AN0 M was interviewed by Investigator Van Cleave and Pro oct En i er Tapia i

on January 17,1988, at AND in Russellville, AR (tshibit 8.

stated that he was M ispediate supervisor.

clat to be unable to l

L T in 1985 or the pre recall the events surrounding the conduct of theHe stated that he let his 'best man'. M p j

i l

tion of the ILRT ort.

i handle the !LRT.

initially denied knowledee that the as found and j

j as-lef t leakage rates included in the ILRT report for the PA55 line in question were identical. However, after reviewing a memorandum which was routed to him concernin this issue, he admitted that he 'gvessed he must have known about this.'

admitted that the as-found figure on the ILRT report for this line was erroneous and stated "I gdess we made a mistake.' He r

denied this was an attempt to hide any problems at ANO from the NRC.

l M prepared a memorandum dated September 18,1985, following AN0's i

receipt of NRC 1[ Infomation Notice 85 71. This Notice, dated August !!,

i l

1985, was sent by the NRC to all nuclear power reactor facilities holding an operating license or construction permit. Its purpose was to clarify some l

teminology in 10 CFR, Part 60, Appendix J, in order to avoid potentially l

i nificant problems pertaining to containment integrated leak rate tests.

In memorandum, he stated that if AP&L interpreted and reported all LLRT data as suggested by the hRC, AP&L wop 1d be doins ILRTs at every refueling outape. M stated that he believed a failed ILRT might result in an l

i l

increased test schedule, but he denied this belief had any effect on the ILRT l

l report prepared in 1985. Accordine to

, he received this impression i

from training he received from 8116ert nwealthCorporation(811bert).

cont <need to maintain he had no clear recollection of the events i

surrounding the ILRT.

i i

INVESTIGATOR'S NOTE: Tapia's review of Gilbert's training manual revealed no reference to an increased test schedule following the failure i

of an ILRT.

Interview With M. Plant Ennineerine Smerviser. AND

~

M was interviewed by Investigator Van Cleav's and Pro.iec inser Tapia l

stated on January 1 atANDinNessellville,AR(Exhibitg)he no recollec-i supervisor. M maintained that that he was tion of the ANO Unit 2 !>RT test which was conducted in 1945.* men shown documentation concerning this test which indicated his participation M het he could not statedthathe'musthavehadagoodreason"forhisactionIlhavingtakenany recall what those reasons might have been nor could he recaAccording to M action concerning the JLRT.

would have to speak with regarding this ILRT and the LLRT tests and j

W to ' refresh or memory.*NWhen asked by the investipator if his testi-eeny was that he recalled nothing about anything to do witi the ILRT testing l

Case No. 4-87-011 14 ae m.r--

.r-weh.

_...__erv-a.e,..

l

)

~

in In$ ano subsequent events. W stated *yes* that was a true ststement, te recalled nothing about anything.

Interview With

. General Mananer for Plant support. AND j

W was interviewed by Investigator Van Cleave and Project Engineer Tapia on January !?.1DM. at Aho in Russellville. AR (lahibit 10). M stated that during 190!3 he was attending a senior Reactor Operator License class and consecuently, was seldom at the ANO facility. However, on May 1. 1985. M statet he prepared a RAC requesting that a before and after leak rate test be l

conducted on penetration RP 66 which i luded the PA55 return line found to be l

1eaking due to a design deficiency.

stated that on the same RAC he also i

reevested that th PA55 return line on Unit 1 be examined for a similar design deficiency.

stated that he intended that Engineering perfo m an LLRT of I

the PA55 line be ore the valves were reversed. He had no explanation as to why his order for the conduct of an as found LLRT on this PAS $ return line was i

not complied with. M maintained that AP&L could have calculated a leakage rate for this line even if an estimate had to be made. The estimate could have been accurate and, according to M would have been the proper way to i

handle the problem.

i i

stated that he had familiarised himself with *this LLRT business.'

stated that he had determined that not only should the as found leakage rate ave been computed before the design deficiency was corrected, but the discovery of the improperly installed valve was a reportable event which i

should have been rep 6rted to the NRC. M stated that he had only recently

^

learned that no as-found leakage rate was computed and that the Instrumen-l tation Division had reversed the valve prior to perfoming an LLRT. M l

stated that he had no direct knowledge of this action, the conduct of the ILRT or the preparation of the ILRT report. He reiterated that an as-found i

leakage rate on the PA$$ line should have been calculated prior to the valves' j

reversal. M said he did not find explanations offered by AN0 for this not having been done to be acceptable.

' Water in the susp is not an acceptable i

isolation valve.'

Interview With M. Soecial Projects Mananer. AND M was interviewed by Investigator Van Cleave and Project E ineer Tapia AR(Exhibit 11).

stated on January it.1988, at ANO in RussellvilleIns the conduct of that he was not present in Russellville dur LRT of Unit 2 in 1985. However. W stated that he had familiarised himself with the events surrounding the ILRT by reviewing the matter extensively and requesting documentat< on from many individuals involved in the ILRT. M stated that the ILRT as-found leakage rate for the PA$$ retten line in question was incorrectly reported in the ILRT report. M claimed that he sid not understand and could not explain AN0's rationale for rting i

• identical as-found and as-left fievres for this PAS $ line.

further admitted that this LLRT 'was not handled well." In his opinion. M attempted to make a significant event appear less significant.

1 M admitted that he should not have been satisfied with a meno he received l

l en March 4.1986 from M. In this memorandum attempted to l

Justify figures shown on the ILRT report, but stated he did not read the memorandum closely enough and accepted it as written.. M said that 1

l l

Case No. 4 87-011 15 1

initially Ah'0's engineers were confused because there was a water versus an air penetration ci the FA55 line. However.

conceded that this should i

not have resulted in an incorrect entry on t e T report for the as-found leakape rate.

i M stated that he was unable to explain why the LER regarding this matter was not forwarded to the NRC in response to the RAC which was prepared in l

May 1986.

M said that the PSC detemined the improper installation of i

the valves and return lines was a reportable event since it involved a breach of containment. M said he had been unable to locate any documentation to provide a basis for changing the P5C's initial decision regardinp this matter.

I M said that, since the as-found leakage rate for this Pall ine re arted in the ILRT report was n orrect. AP&L intended to issue a corrected 1.RT l

report utilising estimated as-found leakage rate for this PASS line i

and declaring a failed as-found Unit 2 1985 ILRT.

Interview With M. Consultant M was interviewed by Investigator Van Cleave and Project Engineer Tapia on January 13, 1988, at AP&L's corporate offices in Little Rock. AR (Exhibit 12). M stated that he had been the manager of special projects at ANO until June 6. 1985. As art of his duties, he also served as the Chairperson of the P5C.

said he had a hasy recollection of events l

during that time period because he was in transition between Russellville and i

the Little Rock. AR corporate offices. He recalled discussing the RAC in

+

question with M. but was unable to recall deciding to report the LER to the NRC for inferination only. m said that the reason for doing this would be to avoid including this LER in the Systematic Assessment of Licensee t

i Performance (SALP) scores.

M stated that it was very unusual for M to review a draft LER.

Usually drafted the LER and forwarded it with the RAC to the PSC.

M recalled that he first became aware of the problem of the valves in the PA55 return line when the PSC received a RAC prepared by Engineering in l

May 1985.

According to M. there was a computer tracking hstem for the incomplete RAC ut this specific RAC must have be n lo t in t

'to act on* pile on were the Licensing Division'gh the crack."s responsibility, and he was unab1 revide en desk and " fell throu said the incomplete RACs explanation as to why the LER was not femarded to the NRC.

said he was unfamiliar with the figures on the ILRT report but maintained that it i

would be incorrect identical as-found and as-left figures in these l

circumstances. In opinion it would have been sore appropriate for ANO to declare a fail as-found ILRT or to qualify the ILRT report with a i

note regarding the events involved in the LLRT conducted on the PASS return i

line.

Interview With M. Start-vo Engineer. Secht91 Mwas interviewed by investigator Van Cleave and Project Engineer Tapia on 4

February 10, 1 at Bechtel Engineering Corporation in San Francisco CA i

(Exhibit 13).

stated that he was present during M0's 1985 Unit t ILRT.

l According to

. AN0's main representative during the conduct of the ILRT Case No. 4-87-011 16 2

.. - -.., _. _ -, _ _ _ _ _ _ _ _ _. _ -,, - _ _ ~ -.. _,, _ _... _ _ _ _..

vas M.

recalled that the PAS $ return line was isolsted in order to complett the L'l test.

E stated that normal practice was to continue with an ILRT with an isolated line and to make corrections to the ILRT test rasults based on LLRT test results of any leakin) valves. M stated that curing ifH. industry practice was to add into tae results of the ILRT test a penalu equal to the 65-left leakage rate of an isolated valve. However, M stated that industry standard had changed, and it was now industry practice to report two values on as-found va ut l

and an as-left value after repairs of the valve. prior to repairs of the valve M stated this chan resulted from the issuance by the NRC of Inspection and Enforcement (IE)ge Bulletin 85-71 in August 1985. M stated that techtel representatives were i

not present at ANO during the conduct of any LLRis. He said he first became aware that the valve in question was installed in a position which allowed J

flow from the containment at about the time the ILRT report was being i

prepared. M stated it was his belief the valves were re-installed in the reverse dir ion to hold containment pressure, and then were local leak rate

tested, stated he was unaware if AP&L engineers attempted uct an as-found LLRT prior to the reversal of the valves. According to his group simply supperized the LLRT results provided by AP&L and inc uded them as i

an appendix to the ILRT report. He said that techtel, if necessary, added LLRT results for certain penetrations to the ILRT test results as a penalty.

M defined as-found leakage t as leakage of the containment prior to any repairst however, according to

, in 1985 Sechtel only addressed the as-left leakage rate of the containment. The as-Tound leakage rate for Type 8 and C tests was reported for inclusion in Appendix ! of the AN0 Unit t ILRT t

I report but not for inclusion as a penalty. W maintained that during the conduct of this ILRT,M stated that Bechtel now applies both as found andonly the as le to the Type A test.

es-left penalties utilizing a minimum pathway as defined in the NRC IE Notice 85-71. However, prior to the issuance of this notice, techtel utilised only the maximum pathway penalty.

M stated he never discussed the LLRT results with anyone at AP&L. Upon bein shown the notation in the ILRT logbook which indicated that someone at r

el discussed the LLRT test results for this PAS $ return line with

. he stated that was not in his handwriting.

further stated that t

he had no discussion with anyone at AN0 regarding the at that these two figures were identical. M stated he was unable to explain why these figures for as-found and as-left leakage rates were identical and in fact, admitted he would not expect them to be the same. He said he wouId have anticipated that the leakage rate of this line would be substantial. M admitted that it would have been appropriate for techtel representatives to question these figures because they were aware there was a problem with the 1

PAS $ return line. However, M maintained that in 1985 Sechtel representatives were only concerned with the as-left results because these were the only figures used as a correction to the ILRT. M did not recall questioning these figures but now othnitted that they should not have been identical. M stated that the valves in question were included in part 4 of the ILRT report but not in Appendix ! as 8 and C valves because these valves were not Type B and C testable valves. M stated that these valves were not tested after completion of the ILRT because lines had been 1solated during the conduct of the ILRT. According to the ILRT report g

contained no notation to explain the problem with the valves design and/or Case No. 4-87-011 17 L

installatior, because lechtel policy has not to include a reason for any eacessive leslage discovered during the conduct of an !LRT. W reiterated that the technique for applying penalties prior to receipt of the NRC IE bulletin was te adjust the Type A test by the as-lef t value and report the i

as left !LRT value, not the as found ILRT value.

J l

stated that valve t-CCW 38 was shown as inoperative in the ILRT report.

1 However, although this valve was initially determined to be inoperative and the leakage determined to be high by an unquantifiable amount, this was not taken into consideration in the results of the ILRT because corrections applied only to the as lef t value and the valve in question was repaired prior to the ILRT.

Entorview With

. Eecineerina $oecialist for Encial Services and "es,1ec. Bechtel M was interviewed by Investigator Van Cleave and project Engineer Tapia on

[

February 10,1988, at Bechtel in San Francisco, CA (Exhibit 14). W stated that he was present during the conduct of AN0's Unit t ILRT in 1985. He stated that se and M were the senior techtel representatives present at Ak0. Their primry ANO contact was M M admitted that he wrote a i

notation in Bechtel's lopbook concerning this ILRT that stated on February 29 1985, at 1400. "Found that post loca sample of containment sump was leaking' t

water when drain valve was opened. Closed root valve on the sample system.

According to M, Appendix J of 10 CFR. Part 50 has been interpreted in many different ways. He stated thst Appendix J stated that one must quantify a leakage if on is going to isolate the line in order to conduct the ILRT.

i According to

. in 1985 it was not standard industry practice to evaluate en as-found ILRT. Common industry practice was to report only an as left ILRT. In 1985 according to M. industry standard was to adjust an ILRT based on leakage in the as-left condition and not prior to making repairs.

However, following NRC issuance of IE Notice 85-71. industry standards i

changed. m viewed the issuance of IE Notice 45 71 as a request from the NRC that the industry ut111 e both as-left and as-found values. According to M. current practice at Bechtel was to conduct a test of the as-found condition of the isolated line, conduct repairs perfere another LLRT. take the difference, and apply that value to the Type A test results as a penalty to the as found leakage rate. M defined as-found as prior to any adjustments on a particular isolated valve. He defined as-left as the state of the valve following any repairs or adjustments. m stated be was uncertain if the figures on the PAS $ return line should have been the same but. in his opinion, en LLRT would have been conducted following the conduct of the ILRT and included in the ILRT report. W asserted that in 1985, he would have expected only one leakage rate, the,as-left, to be reported in the ILRT report.

M stated that he wrote the entry in the logbook on May 14,1985,which stated 'M gave the following LLRT results on stloca sampling line valves: Eg.43FCCM:11.74FCCM." M recalled that telephoned him and reported those figures, but he was unable to recall their significance. He stated that at the time M telephoned him he probably understood that these figures were to be reported as as-left leakage rates in the ILRT report. E stated that the entry could be interpreted as Case No. 4-87-011 18

~.

signifying that valve one was leaking 29.4FCCM and valve two was leaking 11.4FCCK. M stated he was unable to determine whether one wou1(_expett tbc Fall leakage rate to be higher for as-found than for at left. M stated tbt.t at some point which he cannot recall he became aware that these Since they were isolation linesId not recall M

valves were irstelled backwards.

MW stated he did not believe this incident was significant.

any discussion with AF&L representatives concerning the addTtion of these valves to the salve lineup or whether these valves were already included in this lineup.

M stated that Bechtel employees were not present during the conduct of the LLRis. LLRT date was sent by M to techte) for incorporation into the 1LRT report.

stated he did not have any input into the preparation of the !LRT report.

also stated that he had no recollection of any further discussion concerning leakage rates to be reported for this PAS $ line. Normal practice was for techtel to report what was provided to them by the utility.

M was unable to recall if the LLRT was conducted on this pA$$ line before i

or after the valves were reversed. He also stated he had no knowledge as to j

why AP&L reported identical figures for es.found and as left leakage rates for without touching the isolation valve. pinion as found connoted testing as isproper pro ese off this line. M stated that in his o the line, test '

t. and record that value as the as-found leakage rates perfore mainten n or repairs retest, and record that value as the as-left leakage rate.

states that Bechtel's practice in the ILRT report was to record that a line was found leaking and/or a valve isolated. The ILRT report did j

not sention hev a valve was repaired or what corrective action was performed following the ILRT.

{rouD.BecMeItervigw k'ith M. Suoervisor of 50ecial Services and Testinn l

i ta M was interviewed bhechtel 1!stor Van Cleave and PSanFrancisco,CA(Ex octEhin Investi bit t on February 10. 1988, at i

stated that he supervised the group which assisted utilities in the perfor-sence of ILRTs. He stated he was not present during the ILRT conducted at AND's Unit 2 in 1985. However, standard policy was for F.echtel representatives on site to telephone his with a report at the end of each shift. He stated he had no recollection of the ILRT being halted to locate leaks or of the isolation of the PAS $ return line until he reviewed the logbook. According to M. if a line was isolated as a result of leakage.

normal procedure was to perform an LLRT following the ILRT and add the results as a penalty to the ILRT results. M stated that the LLRTs in question were conducted by AP&L employees, and Bech el representatives were not present the conduct of these tests.

stated he had no discussions with during&L employees concerning this PAS $ return line..

av AP According to M. there have been numerous evolutions of containment testing over the years. He explained that in an ILRT lineup all valves were in post accident position. A penalty must be taken for any valve or pene-tration not in +ost accident alignment.

If isolation of a line er valve was necessary, an L RT was performed on that specific 11ne or valve following the ILRT, and results of the LLRT were added to the ILRT value.

In 1985 according to M. industry standard was to utilize maximum pathway l

1eakage. Hinimum pathway leakage was utilized following issuance of MRC IE l

Ca',e No. 4 87-011 19 m..

_ _ _,,,.. _,_ _,_ _ _ r

_y

,,_,,y_.,_,_

l Notice 85 71. W explained that maximum pathway was either the total penetration 1 Lage or the lereer leakage value obtained of two valves in a i

series.

stated that IE Notice 86 71 first linked the as-found and as left conditions into the ILRT. However. M stated some industry personnel maintained that there was still no valid reason to. calculate en as found Type g and C test total. m said that in the context of the en LLRT prior to reversing the valves.would not have expected AP&L to co 1985 interpretation of Appendix J he Normal procedure at that time was to utilite only the as-left eskape rate for en isolated line. M stated that under current industry standards if there was a block on a penetration during the ILRT. an as-found leakage test would be performed and ne minimum pathway would be utilized. M claimed this was a big change from prior industry standards. According to M. AP&L representatives probably determined they wanted both as-found an 5 ft values for LLRTs and that was the reason they recorded both values.

stated that if there was no problem with the line, as-found was identical to as-left. If there was a problem in the line, engineen repaired the line, retested it, and determined the as-left value. For both B and C tests, the as found leakage rate was perforned prior to repairs or adjustments.

M recalled no communicat. ion with M concerning the LLRT data submitted by M to Bechte). Sechtel incorporated the data provided by M into the ILRT report. M stated tset if he reviewed the entries in question in the ILRT report without knowledge of events under discussion, his assumption would be.that only one test was conducted at that time. He would further assume that this test was the as-found leakage rate and since the same value was recorded for both as-found and as-left, no changes were made to the line. According to M. the leakage rate reported was not a large leakage value and appeared to be reasonable for a small valve in a small line in a local test. M further claimed that the leak in question was c

water and it was difficult to equate a 11guld leakage n ir leaksee because they affect the valve in a different manner.

stated that M asked him ap r tely one week og i f chtel could revise this particular report, stated he told that they could do so but he did not believe the report needed revising in the 1985 context."

continued to maintain that many changes had occurred in testing procedures over the last three years. Issues involved included minimum patways versus i

i maximum pathways, different methods of analysis, and hary interpretations of Appendix J.

Review of ILRT Resort Av.ust 19.T RAert.,a of which was forwarded by AP&L to the NRC i,n

• In the ILR.

and

• as-iefi ieakage rates re,orted or m i

e l

l PA15 return line were identical as shown below (Exhibit 16):

LLRT Data for Valves R$V5633-1 and t$V5633 2

)

penetration Valve Actual Found Act$alLeft l

Adfft.

AE$E 1191921.

1.91hitt.

I 118.

l 2P66

/

iSV-5633-1 29.43 23.43 5/10/85 2P66 ISV 5633-2 11.10 11.10 5/10/85 Case No. 4-87-011 20 l

l

1.

l W E: 2PS 129 was closed to keep these valves from leaking water.

LLRT Data for Yalves 25V 5634 1 and 25V 5634 2 i

i Accm Leakage l

Penetration Yelve Actual Found ActuafLeft i

kumber humber Leakane h

pjlg, j

2P67 25V-5634-1 5.51 5.51 5/8/85 l

2P67 25V-5634 2 5.54 5.54 5/8/85 l

l t

ROTE: These valves were within the boundary for ILRT.

j Page ! cf the ILRT Report stated that 'at 1400 on 4/29/85, the POST-LOCA l

sample line to the containment sump was found to be leaking water when the drain valve (2851042))was open.10 secure the leak, the root valve to the l

samplesystem(!PS-189 was closed.'

l a

Page 10 of the ILRT report stated that " Valve IPS-189 at penetration number

?P 66 was hand tightened during the test. A LLRT performed after the com-pletion of the ILRT gave a result of 29.43 acco for that penetration.'

i Appendix 1 of the ILRT contained results of LLRTs conducted during this ANO.

Unit 2. refueling outape. Penetration Number IP-65 was emitted from the list i

i l

cf Type C tests < neluded in Appendix 1.

Penetration Number IP-66 was also omitted from LLRT data which was taken just I

prior to the May 1985 ILRT.

l l

Also included in the ILRT Report was ILRT data obtained during refueling I

outage #3 from 9/27/83 to 1/p/84. This data included the following coment f

I for penetration number IP-40:

As Found' leakage was unable to be determined.'

i A letter from M to b dated 6/16/85 forwarded AN0's LLRTs from 6/15/81 to present to 8echte1. Also included were *LLRT nsults for penetre-tion 66* which *contains valve tPS-189 which was closed by hand during ILRT."

+

The LLRT data was incorporated into the ILRT Report prepared in draft by i

1 and f ed to M for his coments on 6/1/85. A letter from to on 6/18/85 stated AP&L had completed their review of the i

preliminary I report and was returning it with their cements. Following i

consideration of these coments. 8echtet was authorized to complete' and submit the final ILRT Report.

i*

A review of the copy of the ILRT Report with handwritten corrections and changes made by W revealed no changes concerning the PAS 5 vutern line and penetration number RP-66. No coment or clarification was made by M l

concerningthefollowingstatementincludedintheAnalysisandInterpretation section of the Report:

Valve RPS-149 at penetration number IP-66 was tiend tightened during the test. A LLRT performed after the completion of the ILRT Save a result of 29.43 acca for that penetration." However,M did I

cement on page 1-7 concerning LLRT data for penetrations RP61 and 2P62. For Case No. 4-87-011 21

---

.,,,,-,,-.---.,,__..,._._n-,-.,_,-._

h these penetrations. figures were reported under the Actual Found Leakage j

column, and M notation stated "This is as-left data.*

The final ILRT Report prepared by Bechtel included a li' t of information s

pertinert to the ILRT which was retained by ANO. Contained in this list was the following:

"The procedure and all data that would verify completion of d

penetrations and valve testing (Type B & C tests), including as-found leakage 1

rates, corrective action taken, and final leakage rate."

Review of LtRT Data Sheets Two LLRT data sheets were prepared by AP&L for penetration number IP-66: one i

for valve 25V-56331 and one for valve 25V-5633-2 (Exhibit 17). For pene-tration nt,mber 2P 66, they both state:

"Date performed Found Test 5/10/85.

Date Performed Left Test 11ef t blank)

• The Actual Found Leakage and the Actual Left Leakage recorded on these sheets were the same, although the section headed 'As found* was filled out and the section headed "As left" was left blank on both data sheets.

P,eview of ILRT Chronolonical Lon i

During the ILRT, a chronological log of events was recorded and retained by AND(Exhibit 18). An entry dated 4/30/85 at 11:00 stated: " Valve lineup restored to the original lineup as required for ILRT except 2PS-18g is closed i

to prevent water lesk from sump." According to the log, the ILRT was i

completed on 5/1/85. No further mention was made of Valve RPS-183.

Review of Memorandum from M to M Dated March 4.1986 In this memorandum M outlined and explained his actions and decisions j

concerning the asdound leakage rate of the PAS $ return line as follows (Exhibit 13):

(1) The Type C leakage rate reported was as-left and not as-found.

(2) The as-found rate was not measured because:

(a) Valves were not Type C testable as found because adequate l

valves were not installed for pressortsation in the accident direction.

(b) Valves were in the containment sump drain INe which was always floo6ed with water. Leaking fluid was water not air.

l (3) While one could make a quantitative measurement of water flow.

through valves it would not be directly comparable to the I

volumetric flow of air.

l (4) Before the installation of the PA$$ line. Ip-66 was classified as a Type A penetration. Once the PAS $ line was installed, the penetra-tion no longer fit the exact requirements of Appendix J because t$V-5633-1 and -t now received containment 1se1a~ tion signals to close. As e result. RP-66 set the definition of Type C test in accordance with Appendix J.

l (5) Sir.co these valves were not originally placed on the list of Type C valves, the design deficiency went undetected from installation. To correct this, the valves were turned to seal in the accident direc-tion which meant they were now Type C testable. Following this reversal, the valves were added to LLRT procedures.

Case No. 4-87-011 ft

4 (6) Tbt design of this penetration was unique and did not clearly fit i

Type A or C.

(7) There was a design deficiency

.(L) ANC would have failed as-found ILRT if all water had drained from i

the sump and air was allowed to escape from the vent.

l (9) The intent of the NRC regulation was to identify degrading contain-Fent integrity, not to find installed design deficiencits.

Feview of Memorandum from M to M Dated March 17. 1987 This memorandum stated that no quantitative measurement of leaf. age was determined of the Target Rock solenoid valves found leaking during the ILRT (Exhibit 20). According to N. a desijn change was perfsreed to reverse the installatien of the valves which were tien added to the Type C testing prop' ram. $ne further stated that the as-found leakage data in:19ded.in the ILR report was actual 1 the as-left leakage as determined by LLRT after reversing the valves, he ILRT report contained no en lanation of this I

condition as required by 10 CFR 50. Appendix J. !!!.A. a). Additionell.

becausa ne determination of the as-found leakage was made. it was opirion that the first attempt on the ILRT should be considered a 61ture.

Review of AN0-87-11302:

Internal AP&L Memorandum From Dated 9/22/E7 An internal AP&L memorandum by M dated 9/12/87 concerned a review of two l

previously unresolved items. 368/8515 01 and 368-8515-02 which resulted in two violations of 10 CFR 60. Appendix J (Exhibit 21).

assigned the l

following " action line items to AP&L employees for resolution.

• 1.

Containment Modification,ction IV. Special Testing Requirements. Part A -

10 CFR 50. Appendix J se requires that a modification be followed by either a Type A. B. or C test as applicable for the area affected by the modification. Thu post-accident sampling system design installation modified containment penetrations IP66 and EP67 sump recirculation lines. The valves in the sample line receive a containment isolation signalandthusrequireaTypeCtest(localleakratetest). This test was not performed at the time of installation (1383).

Action: M to address the following in relation to the Pass valves installation:

l The reason for the violation I

Corrective actions taken and results achieved l

Corrective actions to prevent recurrence l.

Date of full compliance 2.

10 CFR 50

p. J Section III. Leakage Testing Requirements. Part A -

I Type A test ILRT. requires that if potential excessive leakage paths l

are identified, the T.vpe A test shall be terminated and the leakage measured using local FeakaJe testing methods. When the PA$$ valves i

the test was completed.g the May 1985 ILRT. the valves were isolated and indicated leakage durin No determination was made of the as found leakage.

I i

Case No. 4-87-011 23 l

Action to address the follcwing in re,lation to the ILRT as four.c leakage of the PA55 valves:

> The reason for the violation i Corrective actions taken and results achieved l Corrective actions to prevent recurrence J Date of full compliance 3.

Additional review of the report of the May 1985 ILRT report indicated areas that need to be revised. The as found leakage for outages tR2 and PR3 LLRTs is not listed. Penetration 2P52 was not 'ipoperative' as indicated in the report. The LLAT as found leakage including the value detemined for the PAS $ valves, should be used to adjust the ILRT leakage rate. The report indicates that the test methodology data analysis utilized was mass point techniques per AN5-66.8 - 1981 while the technical specifications reference. AN$1 N45.4 - 1972, applies either a point to-point or a total time method. The report should be revised to i

indicate compliance with AN51 N45.4 - 1972 methodology.

Jlcti>n Mto develop an action plan to accomplish revision of the ILRT.*

Review of Action Trackina Fom From to to M tc M g gL10/15/a7 In a memo from M to M which was routed to and then to M. M requested an evaluation of the as-found condition of the PAS $

line valves and an estimate, based on this evaluation and mock-up testing, of theexpectedleakagerateofairinndwater(Exhibitit). W also requested a detereination of any currer.t reporting requirements based on the l

[

estimated leakage of the PASS valvet in the May 1985 ILRT configuration.

On g/24 and g/25/87. M perfomed calculations and arrived an stimsted leakage rate for air and water. In a memorandum from to dated 10/30/87. M stated that, based on 6 calculations.

I the maximum allowable as-found leakage rate for these valves was exceeded. As a result of this failure to meet acceptance criteria in accordance with Appendix J. a report was required to be filed with the NRC.

leview of Memorandum From M to M Dated 12/17/87 l

M was asked to review reportability decisions and requirements for events described in RAC-t-85165 written by engineering on 5/1/85 afhon the design I

deficiency involving the installation of two Target Rock solenoid valves in the PA$$ line was d'scovered.

.e In a memorandum from M to M dated 12/17/87 M stated he discovered that the shift supervisor and engineering personnel tattially determined this event was reportable under 10.CFR 50J2 and 50.73.v (Exhibit 23)Accordingto The RAC 1 i

that a 50.72 report was made to NRC at 1120

, this RAC was discussed at the PSC meeting on on 5/1/85.

l 5/15/85, and the PSC concurred that this was a re riable event. However, an l

LER was never written to report the event, so said he 4ssumed this l

l Case No. 4-87-011 24

4 decision was chan ed but he was unable to locate documentation to support this position.

stated. "...if an event similar to the one described in RAC-7 65165 were to occur today it would probably be detemined to be reportable per 10 CFR 50.71 Ang 10 CFR 50.73. This is not to say, however, that tre event should have been reported in 1985." M claimed it was difficult to detemine reportability of past events because 'although the rule i

and reporting requirements have not changed since 1984, evaluations for

~

reportability of events are based on current interpretations from those used in 1985.*

ktview of RtC-2 85165 Dated 5/1/85

~

to garding the two leaking On5/1/85.aRACwaspreparedbyEgx t

v4.1ves in the FAS$ return line t 24.

requested that Engineering correct the problem and "also assess the adequacy on ANO-l' and " assure that before and af ter leak rate is calculated on IP-56.*

It PAC-2 85165 AF&L engineers stated that the leak discovered during the ILRT occurred because " Target Rock Solenoid Valves are designed such that a higher pressure on the downstream side will lift the seat and aller flow, even if valve is electrically closed."

!nitial engineering design and subsequent review of tesign by ANO plant enpineering did not recognize reverse flow characteristic of Target Rock so enoid valves. DCP80-2043 did not specify l

LLRT of affected penetrations."

l l

Crders were issued to reverse the direction of these valves which would result i

in their proper setting and then perform leak rate tests. The RAC indicated l

that en ineering review had revealed a similar problem on ANO-1. Engineering l

issued 1 EAR 85-1610 to resolve the similar problem with AND-1.

Enpineers detemined the discovery of this improper installation of these va ves was reportable to the NRC to comply with 10 CFR 50.72 under "An event found while in shutdown that if found wten at power would have resulted in i

condition."y being seriously degraded or the plant beleg in an unantlysed plant safet This was reported to the NRC by telephone at 1120 on 5/1/85.

i Engineers detemined the discovertof this ingroper installation of these va ves was reportable per 10 CFR 60.73 under Event er condition where plant safety was seriously degraded or the plant was in (A) an unanalysed condition.

(B) a condition outside design basis, or (Q) a condition affecting plant stfety not covered by operating and emergency procedures." And "Any event or condition that alone could have prevented fulfillment of a s6afety function (e.g. total loss of EFW, HPI. Containment Isolation. AC power, etc.)."

M notation on the RAC dated 5/1/85 stated his concurrence that this was reportable per 10 CFR 50.73 based on containment leakeet during an ILRT which was greater than allowable i.e., an unanalyzed condition and loss of containment isolation.

Review of Memorandum From to Dated May 8. 1985 In this memorandum. W stated 1p5-89 was closed following the start of the test due to a water leak (Exhibit 253. This identified a design deficiency. but W asserted that th9s was not contributing to an air leak Case No. 4-87-011' 25

.c,

.---,.w--..---..-..,---,.w,rm%,r.,es,-,.ww%,,w.m,,.-.,-,,%e--_

.-,w-.-..,,3-.,mm-,,.=.g-,-

because the system was nomally filled with water. m concluded that *it is ey opinion that we have complied with the requirement of 10 CFR 60, i

Appendix 0, and that the test results indicate an acceptable as found condition and an acceptable as-left condition.'

Review of Memorandum from to 6 f

W stated that the recent !LRT of ANO-t revealed leakage of sump water l

through closed valves caused by a failure during design and design review to recognize that flow would occur in a Target Rock solenoid valve ' f the down.

stream was higher than the upstream pre 6sure (Exhibit 261 Although the valve I

indicated it was closed, the containment !LRT pressure lifted the valve and resulted in a loss of containment isolation. M requested that M i

notify his engineers of this metter to prevent a recurrence.

Review of LtR Number AN0:85-2 00626

[

i Investigation revealed that LER Number ANO 85 2-00626 dated 5/t3/85 was never senttothaNRC(Exhibit 27). The draft LER which was discovered in the Licensing Division stated that it was orepared 'for infomation only.' The LER stated that an ILRT revealed a leakage in the Target Rock solenoid valves used for containment isolation of the Pals sample return line to the contain-ment sump which resulted in a water leak but did not cor, tribute to an air l

1eak. Due to the design characteristics of the valves, they were reversed to correct the problesi. The LER further stated that 'A LLRT after this modifica-l tion yielded satisfactory results.' 'This report was submitted for infomation purposes. A full report of the I RT will be submitted per Appendix J.*

Review of Minutet of PSC Meetina Number PSC-85-Og1 Plant safety Committee meeting #PSC-85-031 held 5/15 Pass Reactor Building Sun Exhibit 28). A determina-of RAC #2-85165:

tion was made by the PSC that the matter was reportable to the NRC.

i Review of WRC Comp crRecor@,

NRC computer records indicated Re rtable Event #00647 was reported by AN0 to l

Operations Officer M on 85at1816(Exhibit 23). NRC computer printout stated AP&L notiff that during an ILRT, two solenoid valt es t

in PASS leaked which tasted the test to feil. The valves were to be repaired.

M stated he notified Region 4 (L. Martin) of this t'eport'from AP&L.

Arview of AN0 Ensinterina Lan AN0' acallwasmadetotheNRCon5/d85at1120: ' Notified NRC of ILRT leaks" and 1125: *Notifict NRC Resident l

ILRTleak"(Exhibit 30).

Review of Overdue RACs In a memo dated 1/21/87, ove u RAC -

as ce rimod as ' Conditionally Significant' and assigned to the secretary. RAC RAC-2 85165 did not appear on a 9/15/87 Itst of overdue RACs (Exhibit 31).

Case No. 4-87-011 26 j

i..

~ -

_..,_.,___...,_,._..p......,_.,__.,_

l IFY[$TIGAT0F.'$ h0TE:

Investigation failed to reveal any action taken I

between these two dates regarding the RAC or any reason for the change in l

.its status, j

Feview of Records Obtained From Bechtel Encineerine (3) A log book maintained by Bechtel personnel during the ILRT of ANO.

l Unit 2.includedthefollowingentries(Exhibit 32):

• 4/2p at 1400 - Found that post LOCA sample of containment sump was leakirig water when drain valve was open. Closed root valve on the sample system."

l

• 4(I30 at 1215 - !LRT line up in effect. Exceptions are Fressurization and i

hJLRTPressandverificationlines i

J Post LOCA sampling" In a different color ink and dated after Bechtel loyees' return to

• 5/14/85 - M gave the f 3 ewing otRT resuits in California:

P051 LOCA sampling line valves 2g.43 SCCM 11.74 $CCM" i

(2) Bechtel Construction Inc. and AP&L entered into master contract #8 002-G for ANO dated 3/1g/75. According to the Authorization for Task perfor-mance Under Master Contract, this !LRT of Unit 2 was scheduled to start 4/1g/65 and end 6/1g/85. The +ersons named as responsible for this task were: AP&L - M. and Sec stel - M. project Engineer. The i

thorization was signed by6(Exhibit 33)).

on 3/ 5/85 for AP&L and by l

on 4/g/85 for Bechtel The Authorization included techtel review of the job site, the procedures. !LRT instrumentation and data acquisition systems. During pressurization equipment, and system status prior to the ILRT.

the ILRT. Bechtel was to provide personnel for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day test l

coverage, computer hardware and software leakspe rate calculations, technical direction during the Type A test, ana ysis and interpretation of ILRT data, direction to leak search teamsI and detamination of satisfactory completion of the ILRT. Sechte personnel were responsible for preparing the ILRT Report for AP&L's approval. Specifically excluded from the contract was local leakage rate testing and re and Type C as defined in Appendix J to 10 CFR part 60). porting

, Type B4towever, techtel i

did prepare a local leakage rate suumarp report from data en he LLRTs provided by AP&L, as noted in a letter Prem techtel power to dated 2/22/86.

Included with the LLRT data was a routing slip with the t

notation: 'LLRT data on R$V-5833-1 & 2.

Eps-lag was closed to keep these valves from leaking water." Copies of the LLRT data sheets for these valves were attached to this routing slip. As stated earlier in this report, references en these data sheets to "As Left were incomplete and left blanL.

[

Case No. 4 87-011 27 t

w

~~ '

I' Review of IE Infomation Notice #85-71 i

On 8/2?/854 the NRC issued infomation notice #85-71 in an attempt to clarify j

therelationshipbetweenacontainmentILRTandLLRTs(Exhibit 34). Recent reviews by the NRC of ILRTs revealed that some utilities were perfomin t

l repairs and adjustments prior to conducting Type A tests without proper y adjusting Type A test results for Type B and C leakage rates which resu ted in an inability to detemine the actual as-found condition of the containment.

IE Notice (85-71 sumarized the NRC position as follows:

(1) No R&As are to be made to the containment prior to the conduct of the ILRT.

(2) Type B and C tests may be performed before or after the ILRT as long as no R&As are made to the containment.

(3)

If R&As are perfomed before the Type A test, an LLRT must be perfomed to detemine leakage rates before and after R&As. The as l,

found Type A test results should be obtained by adding the difference between the leakage rates before and after R&As to the as-left Type A test result following conclusion of the test. The ILRT must be declared a failure if the as-found Type A test result, including appropriate penalties as a result of LLRTs, exceeds acceptance criteria of Appendix J.

l AN0,R_gsponse to 1E Notir,s 85-71 (1) M pcsition concerning IE Notice 85-71 as sumarized in a menerandumdatedg/12/85(Exhibit 35).

stated that, altWgh he "did not personally agree with the NRC interpretation."

information submitted to the NRC for the last AND 1 and t ILRTs was l

sufficient t et the " change in NRC interpretation of Appendix J."

According to reported results indicated that both as-found conditions wou d meet the acceptance criteria for a successful ILRT fiventhenewinterpretation. The results submitted for previous LRTs were not sufficient to determine as-found leakage rates. He l

said it was his belief th

-found condition of LLRTa was not 1

recorded prior to 1981.

roccamended continuing to file an ILRT report, an as-found minimum pathwRy leakage rate, and an

+

l~

as-left LLRT. He also recommended a review of all LLRT procedures to ensure correct recording of data to detemine minimum pathway leakage.

(2) ta action tracking form signed byM but written by M stated: " Caution: if we interpret and report LLRT data as NRC zuggests, we will probably be doing ILRTs every refueling outage" (Exhibit 36).

(3) reviewed IE Notice 85-71, M resporae, and the current proceduresatANO(Exhibit 37). He stated at it was his c; pinion that the purpose of the IEN was to state NRL idethods for integrating pre-ILRT LLRT results with ILRT results to determine ttee as-found containment leakage rate. 'It is evident from the attached documentation that this methodology has been used for at least two Case No. 4-87-011 28 m--

.,.,,e-..

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u-..-

=-.avwe,,,---.---r.,

h..

i years." M mandated that both as-found and as-lef t LLRT data

"(

should be reported for each Type B and C penetration. "Curraht ANO tractice and procedures for local leak rate tests are adequate since bcth the 'as-found' and 'as-left' data are taken and recorded."

"This data is also provided as an attachment to the latest 1LRT reports." M said that AND did not assess leakage saving using NRC methodology, but he recomended doing so because it would be beneficial to the utility.

(4) tated in a memo dated 1/6/86 that. in accordance with Infomation Notice 85-71 (procedures should be revised to agree with coments. ILRT Exhibit 38).

Recuest for Office of General Counsel (OGC) Interoretation of 10 CFR. part 50.

40endix 0 On March 24, 1988, Investigator Van Cleave requested an official interpre-tation by NRC OGC of certain tems referred to in 10 CFR. part 50. Appendix J.

On August 31, 1985, a memorandum was received from OGC addressing this request. According to this memorandum, the issuance of NRC IE Notice 85-71 had no bearing on NRC official interpretation'of Appendix J and was issued to the nuclear industry for information prposes only. The OGC interpretation defined as-found leakage rate as the rate prior to any needed repairs or adjustments" and as-left leakage rate as the

• rate following any needed repeirs or adjustments." OGC further stated that in certain situations.

licensees were reouired to perfom a LLRT to detemine as-found leakage prior to repairs or adjustments and perfom another LLRT after repairs or adjustments to determine the as-left leakage rate. Following completion of theTypeAtest,apenalty(theas-foundleakageminustheas-leftleakage) must be added to the ILRT to calculate the adjusted ILRT.

W111 fulness / Intent Allegation:

Alleged Violation of 10 CFR. part 50. Appendix J Reporting Requirement A.

An ILRT conducted at the Unit.2 containment of ANO in April 1985 resulted in the discovery that two valves in the PAS $ return line were leaking due to their improper installation. However, in Ap&L's report to the NRC concerning this ILRT both the as-found and the as-left leakage rates for tuse two vaIves were identical (Exhibits 1 and 16).

B.

Interviews with AN0 employees revealed that several believed the reported to the NRC (Exhibits 2. 4.,6. 7.y have been incorrectly leakage rates shown on the ILRT report ma S.10.11.and12).

C.

AP&L personnel admitted no actual as-found laakage rate for the PAS $

return line was computed, and the as-found leakege rate reported in the ILRT report was the as-left leakage rate com>uted after reversal

~

of the improperly installed valves (Exhibits 2. 5. 7.10. and 11).

l e

Case No. 4-87-011 29

5 D.

M stated that in her opinion. the initial ILRT should have been considered a failed ILRT due to AP&L's failure to determine the

.as-found leakage rate (Exhibits'2 and 20).

E.

A RAC was prepared by the Engineering Department and forwarded to the PSC which detemined that a LER should be prepared and femarded to the NRC concerning the discovery of the improperly installed valves. Although a LER was drafted it was never finalized or forwarded to the NRC. At some point, the PSC decision was-overruled, and a detemination was made to prepare a LER for infomation purposes only (Exhibits 23, 24. and 28).

F.

Although AP&L engineers reported the incident to the NRC by tele-phone in compliance with 10 CFR Part 50.72. Licensing Division determined it was not reportable to the NRC under 10 CFR, Part 50.73 (Exhibits 23,24,27,29.30.and31).

G.

M stated the draft LER remained on his desk for over two years, ust " slip d through the cracks." and was never finalized Exhibit 5.

H.

M stated that he calculated an estimated as-found leakage rate for both air and water for the PASS line. Based on his estimated calculations the ILRT perfomed in 1985 should have been consideredafailedILRT(Exhibit 6and22).

I.

ANIMlulE stated that, on his instruction, the improperly installed valves were reversed before engineers performed an LLRT on the PA$5 line. He said he was solely responsible for reporting identical as-found and as-left leakage rates on this PASS line. Ne claimed since this was a design deficiency it was not subject to NRC review.

~

However, he admitted the entry in question on the ILRT report was erroneous and should have been clarified or the 1985 ILRT as-found testshouldhavebeendeclaredafailure(Exhibit 7,19.and25).

J.

Bechtel engineers stated they were not-present at ANO during the conduct of the LLRTs and simply used the figures given to them by M in the preparation of the ILRT report. h ey claimed that prior to the issuance of NRC IE Information Notice 85-71, industry t,

practice was to only address the as-left leakage rate of the L

containment end not be concerned with the as-found leakage rate (Exhibits 13,14.and15).

L K.

The LLRT data sheets prepared by AP&L showed identical as-found and as-left leakage rates for this line although only the section headed l

"As-found" was'ccepleted and 'As-left" was left blank (Exhibit 17).

L.

Internal AP&L' documentation revealed that AP&L employees were aware that no as-found leakage rate had been computed on the line in question (Exhibits 20. 21. and 22).

N.

AP&L officials altered their ILRT procedures following NRC issuance of IE Infomation Notice 85-71 on August 22,1985(Exhibits 35,36, 37,and38). However m claimed AP&L procedures for the last Case No. 4-87-011 30 l>

I

- - - ~ ~ - _, _.. _

_, ~ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ __ _ _____________

L.

AND 1 and AND P ILRTs were sufficient to meet the " change in NRC I

irterpretation of Appendix J" (Exhibit 35).

e N.

Official NRC interpretation of Appendix J was not changed as a result of IE Infomation Notice 85 71. This notice was issued for informationpurposesonly(Exhibit 39).

Acent's Conclusion W knowingly and willfully reported false as-found leakage vate values l

for the PASS return line on the ILRT report following c letion of an ILRT at i

ANO, Unit 2 in April 1985. Company officials, including

,M.

t M. anW, knew that no as-found leakage rate was computed for the l

PASS line but failed to notify the NRC of this and failed to finalize and forward a LEP to the NRC regarding this event.

i

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THIS PAGE LEFT BLANK INTENTIONALLY

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- Case No. 4-87-011 32

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g. '

LIST OF EXHIBITS

. Exhibit ho.-

Description 1.

Region IV Regional Administrator's Request for Iny'est19ation, dated November 5. 1987 2

Report of Interview with M dated January 11-12. 1988 l

3 Report of Interview with M. dated January 11. 1988 A

Report of Interview with M. dated January 11. 1988 5

Report of Interview with M. dated January 11. 1988 l

6 Repert of Interview with W. dated January it.1988 7

Report of Interview with M. dated January it.1988 7

8 Report of Interview with M. dated January 12, 1988 9.

- Report of Interview with M. dated January 12, 1988 t

i i

.10 Report of Interview with M. dated January it.1988 f

(

L 11 Report of Interview with M. dated January it.1988 l

12 Report of Interview with M. dated January 13. 1988 13-Transcript of Interview with M. dated February 10. 1988 14 Transcript of Interview with M. dated February 10. 1988-i 16 Transcript of Interview with M. dated February 10. 1988 l

16 ANO. Unit 2. ILRT Reart, dated April 30 and Ma'y 1,1985 l.

pages 1-10 and 1-1 tirough 1-2 l

i7 ANO LLRT Data Sheets S r Penetral @ Number 2 W ~ ~ ~

~

yg 1;..

18 AND ILRT Chronological Log %

Mi i

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• e c.

19

$ Memorandum from M to M dated. March 4.1986 -,-

+ +

1:. t a.7u-

.:s 20 Memorandum from M to M. dated March 17. 1987 atp e-r 1s

.sa. r.,

21 AN0-82-113Q2:_-dP&L Memorandum from M.. dated Septembogit.4987.

22 Memorandum from Mo M. dateT5Etober4N987, and

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Reply 23 Memorandum from M to W. dated December 17,1987 Case No. 4-87-011 33 4

.-,.-..--,,-,~...,----,,---...,.,,,.,,-n-._-_,

3, o

LIST OF EXHIBITS Exhibit,.

i ho.

Description 24 RAC-2-05165, dated May 1, 1985 I

25 Memorandum from M to M. dated May 8, 1985 26 Memorandum from m to M. dated May 9, 1985 27 LER Numoer AN0:85-2-00626 J

2C Minutes of PSC Meeting Number PSC-85-091 2g NRC Computer Reccrd Regarding Reportable Event #00647 30 AND Engineering Log, dated May 1. 1985 31 ANO Memorandums Regarding Overdue RAC #RAC-2-8516E 32 Bechtel Logboek Maintained During ANO Unit 2 ILRT 33 Bechtel and AP&L Contract fB-002-6 34 NRC IE Infomation Notice #85-71 l

35 hemorandum from M dated September it. 1985 36 Action Tracking Fom by M M), dated September 18, l

1985 37 Review of LLRT Procedures at ANO by M (Action Tracking Fors Completed January 10.1986) l 38 Memorandum from M. dated January 6. 1986 3g NRC OGC Interpretation of 10 CFR. Part 50. Appendix J. dated August 31, 1988 l

l L

l Case No. 4-87-011 34

_-