ML20027A971
| ML20027A971 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/16/1982 |
| From: | Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20027A962 | List: |
| References | |
| 50-324-82-21, 50-325-82-21, NUDOCS 8209160232 | |
| Download: ML20027A971 (12) | |
See also: IR 05000324/1982021
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MAR ETTA ST., N.W SUITE 3100 -
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ATLANTA. GEORGIA 30303
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Report Nos. 50-324/82-21 and 50-325/82-21
Licensee: Carolina Power and Light Company
411 Fayetteville Street
Raleigh, NC 27602
Facility Name:
Brunswick 1 and 2
Docket Nos. 50-324 and 50-325
License Nos. DPR-62 and DPR-71
Inspection at Brunswick site near Southport, NC
Inspector:
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H. L. Whitener
Date Signed
Accompanying Personnel:
D. C. Kirkpatrick, IE, Division of Engineering QA -
July 2-8,1982
W. Marinelli, IE, Division of Engineering QA -
July 2-7,1982
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Approved by:
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Engineering Inspection Branch,/f //
Date Sig'ned
F. Jape, Section Chief
Division of Engineering and Technical Programs
SUMMARY
Inspection on June 8-11 and July 1-16, 1982
Areas Inspected
This routine, announced inspection involved 184 inspector-hours on site in the
areas of witnessing leak rate testing, review of leak rate procedures, review of
leak rate test results, and inspection of snubbers.
Results
Of the four areas inspected, no violations or deviations were identified.
8209160232 820818
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- C. Dietz, General Plant Manager
- R. Morgan, Manager of Plant Operations
- W. Tucker, Manager, Operations
- aE. Bishop, Manager, Technical Support
- J. Soone, Supervisor Engineering
- B. Hinckle, Project Engineer
- D. Warren, Plant Engineer
- R. Poulk, Jr. , Regulatory Specialist
Other licensee employees contacted included leak rate test personnel.
Other Organizations
General Physics
- D. Prevatte, Consultant Engineer
- E. Levinson, Consultant Engineer
Johnson Control
C. Nelson, Lead Technician
NRC Resident Inspector
D. Myers, Senior Resident Inspector
L. Garner, Resident Inspector
- Attended exit interview on June 11, 1982
- Attended exit interview on July 16, 1982
2.
Exit Interview
The inspection scope and findings were summarized on June 11, 1982, with
those persons indicated by an * in paragraph 1 above and on July 16, 1982,
with those persons indicated by an # in paragraph 1 above.
Matters
discussed at these interviews are as follows:
June 11, 1982:
The inspector informed the licensee that the integrated test procedure,
PT 20.5, appeared to meet Appendix J requirements.
However, due to
licensee's intent to further revise the procedure, a final review would
be made at the time of the test. The major issue to be resolved is venting
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and draining of systems. The licensee acknowledged the inspector's comments
and stated. that a request for exemption to certain Appendix J requirements
is under consideration (paragraph 5.b).
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July 16, 1982:
(1) The inspector acknowledged that, as left, the Unit 2 containment
system meets the leak rate requirements of Appendix J but the neces-
sity to correct leakage during the Type A test in order to meet the
acceptance limits indicates an apparently failed test.
In that it
was also necessary to make leakage repairs in order to meet the
acceptance limits, during the Type A test on Unit 2 in December 1977,
it appears that the Unit 2 containment has failed two consecutive
Type A tests.
The Region II findings will be forwarded to NRR for
evaluation (paragraphs 5.c.2, 5.c.3 and 6).
(2) The inspector discussed the NRC position that the licensee should
evaluate the "as found" overall containment leakage each outage based
on local leak rate measurements which are made each outage. Since the
licensee was into a valve maintenance and modification program before
the intent of this position was made clear, the inspector stated that
it would be acceptable for the licensee to make the best conclusion
possible based on local leak rate data and evaluation of those valves
for which data is not available.
The licensee stated that this reveiw would be performed.
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(3) The inspector stated that the licensee's position on draining of
certain systems for the Type A test is not consistent with the NRC
understanding of Appendix J requirements. This issue was resolved for
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the current test by addition of Type C test results for systems not
drained, to the Type A test result. The licensee should resolve this
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matter with NRR before the next Type A test (paragraph 5.b).
(4) The inspector stated that an example of inadequate venting was identi-
fied during review of local leak rate valve alignments in PT 20.3,
" Local Leak Rate Testing of Containment Isolation".
The inspector
identified this matter as an unresolved item pending completion of
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the valve alignment review to determine if this is an isolated case
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or indication of procedural inadequacy UNR 325/82-21-01 and 324/82-
21-01 (paragraph 7).
(5) The inspector expressed the NRC concern that: (1) the Type C testing
did not identify and result in the correction of the miscellaneous
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leakages which were identified by the Type A test; and (2) that the
licensee's procedures did not maintain control of equipment to prevent
leakage paths, specifically the RHR relief valve gagging bolt.
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The licensee stated that these concerns would be addressed and a
response ready within 60 days (September 14, 1982). This matter is
identified for inspector followup as IFI 325/82-21-02 and 324/82-21-02
(paragraph 7).
(6) The inspector stated that he had inspected installed piping supports
and restraints and had identified no problems in this area (paragraph
8).
The licensee acknowledged the inspector's findings and commented as indi-
cated above.
3.
Licensee Action on Previous Enforcement Matters
Not inspected.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions. New unresolved item identified during this inspection is discussed
in paragraph 7.
5.
Integrated Primary Containment Leak Rate Test
(61719)
The inspector witnessed and reviewed test activities to determine that the
primary containment integrated leak rate test (ILRT) was performed in
accordance with the requirements of Technical Specification 3/4.6.1,
Appendix J to 10 CFR 50, ANSI 45.4, and test procedure PT 20.5, " Integrated
Primary Containment Leak Rate Test".
The inspection was a coordinated
effort involving the Resident Inspectors and a Region II leak rate
specialist.
Selected sampling of the licensee's activities which were inspected include:
(1) review of PT 20.5 to verify that the test procedure was properly
approved and conformed to the regulatory requirements listed above;
(2) observation of test performance to determine that test prerequisites
were completed, special equipment was installed and calibrated, and that
appropriate data were recorded and analyzed; and (3) preliminary evaluation
of leakage rate test results to verify that leak rate limits were met.
Pertinent aspects of the test are discussed in the following paragraphs.
a.
General Observations
The inspector witnessed and/or reviewed portions of the test prepara-
tion, containment pressurization, temperature stabilization and data
processing during the period of July 1-16, 1982. The following items
were inspected:
(1) The test was conducted in accordance with an approved procedure
maintained at the test control center.
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(2) Selected test prerequisites were reviewed and found to be
completed.
(3) Selected plant systems required to maintain test control were
reviewed and found to be operational.
(4) Special test instrumentation was reviewed and found to be
installed and calibrated.
(5) Data required for the performance of the containment leak rate
calculations were recorded at 15 minute intervals.
(6) Problems encountered during the test were described in the test
event log.
(7) Pressurized gas sources were reviewed for proper isolation and
venting to preclude in-leakage or interference of out-leakage
through containment isolation valves.
(8) Procedure valve alignment was reviewed against system drawings to
verify correct boundary alignment and venting and draining of
specific systems.
(9) A sampling of valve positions was observed to verify conformance
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to procedure valve alignment.
(10) Temperature, pressure, dew point, and flow data were recorded at
15 minute intervals. Data were assembled and retained for final
evaluation and analysis by the licensee's consultant, General
Physics. A final ILRT report will be submitted to the Office of
Nuclear Reactor Regulation.
With the exception of items (7) and (8), no problems were identified
during review of the above items.
Regarding item (7) above, the inspectors found that the instrument. air
pressure, nominally 100 psi, could not be vented off the outboard
isolation valves IA-V101 and IA-V103. The plant design provides only a
single manual isolation valve on the instrument air lines penetrating
containment.
Since this system must remain pressurized during the test to traintain
the plant in a safe condition, there is a potential that air leakage
into containment during the test could reduce the measured Type A test
(ILRT) leak results. To reduce the potential that this system will
affect the Type A test results, the licensee specified in Section V.31
of PT 20.5, that a local leak rate measurement (Type C) of leakage
through IA-V101 and IA-V103 will be made just prior to and just after
the Type A test. Any measured leakage will be reduced to zero or will
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be accounted for in the Type A leak rate calculations. The inspector
observed the local measurement made prior to the Type A test.
The
measured in-leakage was 0.2 SCFH, which will be added to the final
Type A test result.
Regarding item (8) above, the licensee disagrees with the NRC position
on the meaning of Appendix J with regard to draining certain systems
outside containment.
Consequently, some systems were not drained
during the integrated leak rate test. Discussion with test personnel
and review of the test procedure showed that, due to other considera-
tions, the Type C leakage measurements for isolation valves in systems
not drained outside containment were being added to the final inte-
grated leak rate measurement.
The inspectors concluded that the
resulting leakage rate would be representative of a leak rate measure-
ment obtained with these systems drained in accordance with Appendix J.
Venting and draining of systems are discussed further in paragraph 5.b.
b.
Integrated Leak Rate Test Procedure Review
At a previous inspection the licensee had agreed to revise the
" Integrated Primary Containment Leak Rate Test" procedure, PT-20.5, to
provide for adequate venting and draining of systems prior to using
this procedure for the Unit 2 integrated leak rate test (see IE Report
50-324/81-13 and 50-325/81-13). To avoid a loss of critical path time
in the event that the procedure did not properly reflect the require-
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ments of Appendix J,
the inspector agreed to review the revised
procedure prior to the Unit 2 ILRT. This review was performed at the
plant during June 8-11, 1982, with plant engineers and the licensee's
consultant, General Physics. The review was performed by comparing the
procedure valve alignment with system controlled drawings for each
penetration of the primary containment to determine that all isolation
vent, drain and block valves, and any valves within the test boundary
were identified and properly positioned by the procedure valve align-
ment.
Additional considerations in determining the proper valve
alignment for the integrated test included items as follows:
(1) System operational function for pre-accident and post-accident
conditions.
(2) System quality as it relates to potential leakage paths for
pre-accident and post-accident conditions.
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(3) System alignments necessary to support safe shutdown of the
reactors.
(4) System alignments necessary to p* ovide integrated leak rate test
control.
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The inspector concluded that the procedure as reviewed, contained
adequate provisions for test control, safe shutdown of the reactor
and system alignment,
System venting and draining remained under
discussion while this review was in progress.
Licensee management
reached a position that draining of certain non-safety related and
non-seismic Category I systems outside containment is not required by
Appendix J and further decided to change the test procedure, PT 20.5,
to reflect this position.
.The licensee based his position on the
condition that unless a seismic event is postulated to occur at the
same time as the LOCA, there is no mechanism which would cause even
non-safety grade, non-seismic Category I systems outside containment to
fail.
The licensee set up a conference call on June 11 to discusss
this position. The call included the NRC Licensing Project Manager,
Containment Systems Branch (CSB) personnel, Resident Inspector, and the
Region II specialist on the line with CP&L corporate licensing
personnel and plant engineers.
In the conference call CSB personnel
stated that in evaluation of potential containment leakage post-
accident, no credit is given for a system which is not designed to
safety system, sesimic Category I standards, and therefore, assured to
remain intact and functional post-accident.
CSB declined to attempt
specific system evaluation from general information presented over the
telephone but stated that they would review a licensee request for
exemption to Appendix J venting and draining requirements if the
licensee would submit a detailed systems description and the basis for
the request. The licensee concluded that as a first step in resolving'
this issue, a letter clearly stating the plant's position would be sent
to Region II.
For the current test certain systems would not be
drained but Type C local leakage measurements for isolation valves in
these systems would be added to the integrated test result. At the
exit interview on June 11, the inspector identifieJ the area of venting
and draining of systems as unresolved pending revicw of the licensee's
final system alignments.
On returning to the site for the integrated leak rate test during the
period July 1-16, 1982, the inspector reviewed the revised test proce-
dure, PT 20.5.
The procedure identified system vent and drain status
and those systems for which the Type C leakage would be added to the
Type A test result.
The inspector concluded that addition of Type C leakage results to the
Type A test result for isolation valves in those s'
ems not drained
would result in a leak rate comparable to that whic. tould be obtained
if these systems were drained in accordance with Appendix J require-
ments.
The inspector had no further questions on system venting and
draining for this test. However, some of the Type C leakage was added
to the Type A test result for reasons other than the fact that the
system was not drained outside containment. The licensee's position in
this matter remains contrary to the NRC position.
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c.
Integrated Leak Rate Test Performance
(1) Method
The containment leak rate was determined by the mass point
analysis and linear regression techniques on a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
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of mass data recorded at 15 minute intervals.
Containment
pressure was full accident pressure (49 psig). A statistical 95*e
upper confidence limit (UCL) was calculated.
(2) Test Description and Sequence of Events
Initial pressurization of primary containment began at 4:00 p.m.,
July 8, 1982. Pressurization was secured at 12:00 p.m. with the
containment at 64.9 psia.
At this time, severe leakage was
evident.
The measured leak rate from 3:30 a.m.
to 5:00 a.m. ,
July 9 was 7.6 wt. % per day, 20 times the allowable leakage of
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O.375 wt. % per day. Most of this leakage was through RHR relief
valve E11-F055A. The gagging bolt from the valve cap was missing.
Af ter the bolt was replaced, the leak rate measured from 5:00 a.m.
to 12:00 p.m. was 0.65 wt. *; per day. The leak rate continued to
exceed the allowable leakage of 0.375 for the next 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />
trending in the range of 0.5 to 0.4 wt. $ per day.
In this
period, July 9 through July 12, the licensee continued to search
for and identify leakage paths. No one large leak could be found;
however, numerous miscellaneous small leaks from almost zero to an
estimated 5 SCFH were identified.
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The licensee concluded that the identified miscellaneous leakage
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would have to be repaired in order to nieet the allowable leak rate
limit.
Types of identified leak paths included valve packing,
valve bonnets, connectors, fittings, flanges, and pump seals.
At 1:00 p.m. July 12, the licensee initiated leakage repair. A
partial list of systems in which leakage was identified included:
Core Spray (CS), Containment Air Control (CAC), Containment Air
Monitoring (CAM), Residual Heat Removal (RHR), and Traversing-in-
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core-Probe (TIP).
Many of the leaks identified in these systems were minor; however,
when a number of these leaks were repaired the integrated leak
rate was reduced to 0.3 wt. % per day.
(3) Test Results
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lhe 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> integrated leak rate measurement (Lam) was made from
6:30 p.m. July 12 to 6:30 p.m. July 13.
The preliminary calcu-
lation of measured leakage was 0.301 wt. % per day. The value is
in good agreement with the value of 0.302 wt. *; per day calculated
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by the inspectors. . The upper confidence limit (UCL) was
0.31 wt. % per day. At this time, add-on leakage was estimated to
be 0.012 wt. % per day which would yield a total leak rate of
0.322 wt. % per day.
This value meets the acceptance limit of
0.375 wt % per day. The final value will be reviewed when tne
final ILRT report is received.
Appendix J requires that a supplemental test be performed to
verify the accuracy of the Type A test and the ability of the ILRT
instrumentation to measure a change in leak rate. A known leak
rate (Lo) is imposed on the containment and the measured composite
leak rate (Lc) must equal, within
0.25 La , the sum of the
measured leak rate (Lam) plus the known leak rate (Lo).
The acceptance criteria is expressed as:
Lo + Lam - 0.25 La s Lc s Lo + Lam + 0.25 La
Results of the verification test show that the composite leak rate
Lc was within limits as follows:
Lc (measured)
0.856 wt. % per day
Lo (imposed)
0.501 wt. L per day
Lam (measured)
0.301 wt. % per day
.25 La (La = 0.5%)
0.125 wt. % per day
Using these values in the criteria yields the following results:
0.677% s 0.856% s 0.927%
Using Lc measured by the licensee, the inspector calculated the
following results:
0.674% s 0.856% s 0.924%
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These calculations show reasonable agreement.
The inspector
concluded that the integrated leak rate test results were within
the acceptance criteria specified in Appendix J to 10 CFR 50 and
the Technical Specifications.
6.
NRC Positions on Appendix J To 10 CFR 50 (92706)
Paragraph III.A.1 of Appendix J requires that during a Type A test no
repairs or adjustments shall be made so that the containment can be tested
in the "as is" condition.
If the containment leakage fails to meet the
acceptance criteria of Appendix J, the Type A test shall be terminated,
repairs made, and the Type A test performed. The overall integrated
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leakage (i.e., the "as is" condition of the containment) shall be deter-
mined from the change in leakage resulting from repairs and adjustments
and the Type A test result. These results shall be included in the report
to the Commission. Further, paragraph III.A.6(a) requires that if a peri-
odic Type A test fails to meet the acceptance criteria, the schedule
for future Type A tests will be reviewed and approved by the Commission.
Paragraph III. A.6(b) requires that if two consecutive periodic Type A tests
fail to meet the applicable acceptance criteria, a Type A test shall be
performed at each shutdown for refueling or approximately 18 months,.
whichever occurs first, until two consecutive Type A tests meet the
acceptance criteria.
The inspector informed licensee management at the exit interview on July 16
that the current Unit 2 integrated leak rate test appears to be a failed
test in that containment leakage failed to meet the applicable acceptance
criteria of Appendix J until component repairs and adjustments were made to
reduce the leakage on July 9 (RHR relief valve E11-F055A) and on July 12
(numerous miscellaneous leak paths).
The nature of these leaks and some
systems in which repairs were made are discussed in paragraph 5.c.2 above.
The inspector also stated that his review of the integrated leak rate test
performed on Unit 2 in December 1977 indicated that this was also a failed
test. The containment leakage did not meet applicable acceptance criteria
of Appendix J until component repairs and adjustments were made. The more
significant leakage paths identified during the Type A test performed
December 11-15, 1977 are documented in IE Inspection Report No. 50-324/77-29
and 50-325/77-29 and the licensee's ILRT Report submitted to the Commission
on March 15, 1978, as required by paragraph V of Appendix J.
The inspector
advised the licensee that Region II will further evaluate this apparent
failure of two consecutive integrated leak rate tests and forward the Region
findings and recommendations to the Office of Nuclear Reactor Regulation for
evaluation.
7.
Local Leak Rate Test program (61720)
Inspection of the local leak rate program was a coordinated effort between
the Region inspector and the Resident Inspectors.
In review of test imple-
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mentation and documented results it was found that certain valves which
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require Type C testing had been deleted from test procedure PT 20.3, " Local
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Leak Rate Testing of Containment Isolation", in Revision 11, dated March 31,
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1981. This matter was reviewed with the licensee and his consultant.
The
licensee stated that the valves deleted which require Type C testing would
be reinstated in the procedure PT 20.3.
The inspectors reviewed the list
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of valves reinstated by temporary revision to PT 20.3 for Unit 2 and con-
cluded that the required valves had been reinstated. The Resident Inspector
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also reviewed Type C testing performed on Unit I and determined that these
valves and certain additional penetrations bad not been tested on Unit 1
-within the 24 month time limit specified in the Technical Specifications.
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This matter is discussed in detail in IE Report Nos. 50-325/82-28 and
50-324/82-28.
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In review of local leak rate valve alignments the inspectors noted that for
test No. CAC-3, test of penetrations 25 and 205, the procedure did not
identify the vent valves V152 and V153 or the makeup and interting header
block valves V57 and V58 downstream of isolation valve CAC-V4. Failure to
position these valves properly could result in an inadequate test.
Interviews with test personnel indicated that the isolation valve CAC-V4 had
been properly vented during the test. The licensee stated that this proce-
dure alignment would be corrected.
The inspector identified the failure to specify adequate venting in the
procedure valve alignment as an unresolved item 325/82-21-01 and 324/82-
21-01 pending completion of the review of local leak rate valve alignments
to determine if this is an isolated case or indication of an inadequate
procedure.
The inspector also expressed the concern that the local leak rate test
program did not identify and result in the correction of the miscellaneous
leakage noted during the integrated test. This matter and the concern over
failure to control equipment to prevent leakage through the RHR relief valve
Ell-FOSSA were discussed at the exit interview. Licensee management agreed
to review the Type C program with the intent to determine if improvements
can be made.
This item was identified for inspector followup as IFI 325/-
82-21-02 and 324/82-21-02.
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8.
Hydraulic Shock Suppressors (61729)
The inspector reviewed pisnt modification 81-104 for Unit 1 snubber valve
block modification and testing by Bergen-Paterson. In March 1981 a generic
control valve body problem for snubbers in Unit 2 was identified.
These
snubbers were rebuilt as required based on results obtained from functional
testing of all the snubbers (see LER 2-81-41 and supplement dated January 7,
1982). At a subsequent outage on Unit I in April - July 1981, the control
valve body was replaced with an improved wear-resistant body on all Unit I
The vendor certified that all snubbers were tested and met
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velocity requirements specified by the licensee and test procedures.
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inspector determined that the vendor procedures were approved by the vendor
QA group, specified the skill level of personnel performing the work,
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contained detailed step-by-step instructions for assembly and testing of the
snubbers, and contained appropriate acceptance criteria.
Procedures
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reviewed included the following:
a.
Hydraulic Shock and Sway Arrestor Subassembly and Pre-Calibration
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Techniques, issued 5/4/79.
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b.
Hydrualic Shock and Sway Arrestor Final Assembly and Calibration,
issued 6/15/79.
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c.
Final Assembly and Calibration Using the Hanna - Fluid Racine Hydraulic
Test Stand, issued 1/11/80.
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When reviewing the status of Unit 2 snubbers, the inspector was informed
that all snubbers in Unit 2 were replaced with new snubbers during the
current outage and that the vendors certification of testing was on file.
In that new snubbers have been installed the inspector did not further
review functional testing data at this time.
In addition to the above reviews, the insoector examined a number of
snubbers selected at random in the Unit 2 drywell. These were checked for
proper fluid level, proper installation, tightness of fasteners, and freedom
f rom lockup. No problems were identified.
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