ML20023D973
| ML20023D973 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/05/1983 |
| From: | Rybak B COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20023D968 | List: |
| References | |
| 6306N, NUDOCS 8306060212 | |
| Download: ML20023D973 (6) | |
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O Commonwrith Edison O / one First Nat:onal Plaza. Chicago. Ilknois O "7 Address Reply to: Post Othce Box 767 Chicago, lihnois 60690 April 5, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Unit 1 Response to I. E.
Inspection Reports 50-254/82-24 and 50-265/82-28 NRC Docket Nos. 50-254 and 50-265
Dear Mr. Keppler:
The subject NRC Inspection Reports deal with the conduct of an Integrated Primary Containment Leak Rate Test (IPCLRT) for Quad-Cities Unit 1 in December, 1982.
Although there were no items of non-compliance, the NRC noted two items that are of significance:
1.
It was determined that the computer program used in the conduct of the IPCLRT is not subjected to the same quality assurance requirements as the procedures used to implement the test.
A response was requested for this open item.
2.
The NRC's review of the last 2 consecutive IPCLRT's for Unit One indicated that they apparently failed to meet the acceptance criteria o f 10 CFR 50, Appendix J, Therefore, it is the contention of the NRC that this necessitates the performance of an IPCLRT on Unit One during each refuel outage until 2 consecutive tests meet the acceptance criteria.
Attached is a response to item 1. above which outlines the corrective actions taken to prevent recurrence.
Commonwealth Edison disagrees with the NRC's conclusion relative to item 2.
A response is also attached for this item, indicating the bases for disagreement.
Please be advised that we are still researching this issue and that (1) additional justification for our position may be forth-coming (2) a request for a meeting with Region III for justification of their position on this matter may be made and (3) possible appeal to NRR for resolution of this matter.
We trust you will give full consideration to our enclosed response.
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8306060212 830531
'fl 00 e i N PDR ADOCK 05000254 O
n J. G. Keppler April 5, 1983 Please address any q sestions on this matter to this office.
Bo ybik Nuclear Li nsin Administrator rh/lm cc:
R.
Bevan NRR R. Gilbert NRR Resident Inspector Quad Cities Resident Inspector Dresden 6306N
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r ATTACHMENT I Response to Open item 50-254/82-24-01; 50-265/82-28-01 It was noted by the inspector that a major portion of the IPCLRT held December 14, 1982 through December 16, 1982 was performed by the plant computers and computer sof tware. This software did not undergo the same level of review and approval prior to the test as the test procedures.
To rectify this situation, a Station On-Site Review was held on Feb rua ry 28, 1983 which documented the computer program used for the computation for the Integrated Leak Rate Test. The documentation package contains a flow chart, a program listing, and a series of benchmarks for the program written by Station personnel. The pro-gram flow chart and listing were supplied to show the exact coding used to accomplish the calculations. A series of benchmarks docu-ments the accuracy of the calibrations and compares the results to several examples given in Appendix B of the BN-TOP-1, Revision 1, November 1,1972 topical report. The comparison of results indicated the results of the Station's computer program were well w~1 thin the computational accuracy of the BN-TOP-1 report results.
Revisions to this computer program and other computer programs used for conducting an IPCLRT will be similarly reviewed.
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ATTACHMENT 2 Quad-Cities Unit One IPCLRT Schedule The NRC Region 111 contends that the Quad-Cities Unit One LLRT results (Type B and C testing) during the Fall 1982 refueling outage constitute a failure to satisfy the IPCLRT (Type A test) acceptance criteria in 10 CFR 50, Appendix J. Section Ill.A.5.(b).
It appears that regularly scheduled Type B,and C testing as required by Section Ill.D.2 and 3 may not be performed prior to the Type A test or that a penalty must be added on to the Type A test result equal to the total "as-found n.inus as-lef t" leak rate for all leakage paths from the Containnent.
Region til also contends that the Type A test for Unit One in February of 1979 also failed to meet the acceptance criteria.
During the Type A testing in 1979, a leakage path was discovered from the Containnent through Drywell cooler instrument air lines. On this occasion it was necessary to make repairs correcting the leakage, repressurize the Containment, and re-start the Type A test including a stabilization phase. Therefore, Quad-Cities Unit One must perform a Type A test each refueling outage until two consecutive Type A tests meet the acceptance requirements (reference Section Ill.A.6.(b).).
The Station disagrees with the Region lli position for a number of reasons. Let us first examine the contention that Type B and C tests performed in September of 1982 found to exceed the acceptance criteria in Sections Ill.B.3 and III.C.3 causes the Type A test performed in December of 1982 to automatically fall to comply with Section Ill.A.5.(b). Section A.5.(b). states
" Acceptance Criteria -..
(2) Peak pressure tests shall be conducted.
Lam shall be less than 0.75 L.
If local leakage a
measurements are taken to affect repairs in order to meet the acceptance criteria, these measurements shall be taken at a test
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,s pressure of P." The acceptance criteria specifically states that a
local leakage measurements (LLRT) and repairs may be perforned in order to meet the acceptance requirements. The opposite position is apparently being taken by Region 111.
Section li t.A.I. defines the pretest requirements for Type A testing and gives the intended purpose of Type A testing, namely to test the Containnent in as close to the "as is" condition as practical.
Section Ill.A.1. states, "During the period between the completion of one Type A test and the initiation of the Containnent inspection for the subsequent Type A test, repairs or adiustments shall be made to components whose leakage exceeds that specified in the Technical Specification as soon as practical after identification." The pretest Containnent inspection, as defined in Section V. A., is the start of a Type A test.
Type B and C test results in excess of Technical Specification limits were not only anticipated in Section Ill.A.I.
but were also excluded from consideration in the Type A test.
There is ne reference in 10 CFR 50, Appendix J, to the "as found" Type A test results referred to by Region Ill.
Section Ill.A.1.
gives the explicit goal of determining an "as is" Containnent leakage af ter all repairs made necessary by Type B and C test results have been performed.
The contention by Region Ill that Quad-Cities Unit One has failed to satisfy Type A test acceptance criteria for two consecutive Type A tests depends on the presumption that the February, 1979 testing failed to meet the acceptance criteria.
We believe this was not the case.
Section Ill.A.I. states "If during a Type A test, including the supplemental test potentially excessive leakage paths are identified which will interfere with satisfactory completion of the test, or which result in the Type A test not meeting the acceptance criteria.
the Type A test shall be terminated and the leakage through such paths shall be measured.... Repairs and/or adjustments to
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equipment shall be made and a Type A test performed." In February, 1979, such a leakage path was identified. The test was terminated. Repairs were made; another Type A test was performed which satisfied the Type A test acceptance criteria of an Lam less than 0.75 La.
Region i ll seems to be contending that the first test failure makes the second test also a failure.
In fact, there have been two consecutive Type A tests that meet the acceptance criteria given in 10 CFR 50, Appendix J. Section Ill.A.5.(b).
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