ML20053E197
| ML20053E197 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/11/1982 |
| From: | Bettenhausen L, Pullani S, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053E187 | List: |
| References | |
| 50-219-82-06, 50-219-82-6, NUDOCS 8206070688 | |
| Download: ML20053E197 (12) | |
See also: IR 05000219/1982006
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
Region I
Report No.
50-219/82-06
Docket No.
50-219
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License No.
Priority
Category
C
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Licensee:
GPU Nuclear Corporation
P. O. Box 388
Forked River, New Jersey OS731
Facility Name:
Oyster Creek Nuclear Generating Station
Inspection at:
Forked River, New Jersey
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Inspection conducted:
Marc
17-19, 31 and April 1, 2, 5, 6, 1982
Inspectiors:
C
d
W. A. Rekito Reactor Inspector
/ datg signed
L a-
s/n/n
S. V. -ftfilanf, Reactor Inspector
date signed
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date signed
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5////tCL '
Approved by:
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L. H. ~8ettenhausen, Chief,
date signed
Test Program Section
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Inspection Summary:
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Inspection on March 17-19, 31 and Aoril 1, 2, 5, 6, 1982
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Areas Inspected:
Routine, unannounced inspection of licensee action on previous
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inspection findings; primary containment penetration leakage testing program;
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and witness of the primary containment integrated leakage rate test.
The
inspection involved 118 inspector-hours onsite by two region-based inspectors.
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Results:
Violations were identified in two areas:
(1)
Failure to make a required LER, (Paragraph 3.4) and
(2)
Failure to properly implement approved procedures (Paragraph 3.7,
3.8,4.6).
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DETAI_LS
1.
Persons Contacted
+M. Budaj, Manager, Saecial Projects
J. Carroll, Director Station Operations
P. Feidler, Vice President and Director
K. Fickeissen, Director, Plant Engineering
K. Hutko, Test Engineer
+M. Laggart, Licensing Supervisor
- +J. Molnar, Manager, Core Engineering
+T. Quintenz, Manager, Plant Engineer
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J. Sklar, Test Engineer
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+J. Sullivan Jr. , Plant Operations Director
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NRC Personnel
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+J. Thomas, Resident Inspector
+C. Cowgill, Senior Resident Inspector /
ottom)
The inspector also talked with and interviewed other licensee personnel
during the inspection.
They included members of the operating, technical,
and maintenance staffs.
- denotes those present at the exit interview held March 19, 1982.
+ denotes those prescnt at the exit interview held April 6, 1982.
2.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (219/80-10-04):
Schedule for leakage rate
testing modifications. The licensee has planned and scheduled the
completion of applicable piping system modifications during the forthcoming
(1981) refueling outage. This schedule was committed to in a letter to
the NRC dated June 27, 1980. The NRC found this schedule for achieving
conformance with 10 CFR 50 Appendix J acceptable as documented in a
Safety Evaluation Report sent to the licensee on March 4,1982.
This
item is considered resolved.
(Closed) Unresolved Item (219/80-10-05):
Incomplete acceptance
criteria in the local leakage rate test procedure. On June 27, 1980
the licensee approved and implemented a special procedure 665.5.020,
Integrated Local Leak Rate Summary.
The inspector reviewed and verified
that this procedure included all applicable acceptance criteria, for
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local leak rate testing, from 10 CFR 50 Appendix J and the Technical
Specifications.
This item is resolved.
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(Closed) Unresolved Item (219/80-22-02): Maintaining electrical
penetrations pressurized with nitrogen.
The licensee had not conducted
the engineering evaluation to determine the applicable requirements
but stated that it would be done as priorities permit. During this
inspection the inspector examined a sampling of approximately 15
electrical penetrations and observed that all pressure indicators were
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reading above 10 psig.
Based on these observations and the licensee's
response to NRC Bulletin 77-06, which describe the need for a nitrogen
environment but no specific pressure, this item is closed.
(0 pen) Violatior[s (219/80-10-02, 81-05-10, 81-08-01) and Immediate
Action Letter 81-20:
Failure to meet Inservice Testing (IST) requirements
for safety related puips and valves.
The licensee is still not conducting
insarvice tests and evaluating results in accordance with Section XI
of ASME B&PV Code. A licensee letter to NRC dated March 18, 1982
describes the delay of implementing these test activities beyond the
previously committed schedule for achieving total compliance with the
regulations. The inspector stated that delay of the stated corrective
action plan would be considered during the Licensee Performance Appraisal
for the recent assessment period.
Followup on these items and review
of the implemented test program will be included in a subsequent
inspection.
3.
3.1 Documents Reviewed
-- Procedure 665.5.003, Revision 3, Main Steam Isolation Valve Leak
Rate Test
-- Procedure 665.5.004, Revision 0, Feedwater Isolation Valve Leak
Rate Test
Procedure 66.5.006, Revision 3, Local Leak Rate Testing
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-- Procedure 665.5.020, Revision 0, Integrated Local Leak Rate
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Summary
-- Special Procedure 82-038, Revision 0, dated March 26, 1982,
Feedwater Check Valve Leak Rate Test with Leaking Maintenance
Valve.
-- Procedure 665.5.003.1, Revision 0, dated April 4, 1982, Leak
Testing MSIV's in Series (NS03A and NSO4A) or (NS038 and NSO48)
-- Records of Local Leak Rate Testing (LLRT) activities conducted
during recenc outage including test results, related repair and
retest documentation.
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Summary Technical Report for Reactor Building Containment Building
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Integrated Leak Rate Test - 1980, submittad to the NRC October 7,
1980.
NRC letter to licensee dated, M$rch 4, 1982, transmitting a
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Safety Evaluation Report regarding compliance with 10 CFR 50
Appendix J, Containment Leakage Testing at Oyster Creek.
Selected system operating procedures and drawings (P & ids)
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3.2 Scope of Review
The inspector reviewed the above documents to ascertain compliance
with regulatory requirements of 10 CFR 50 Appendix J and Oyster
Creek Technical Specifications..
The inspector also witnessed
selected LLRT activities and held discussions regarding the
relationship between LLRT failure results and the Primary Containment
Integrated Leak Rate Test (PCILRT) evaluation of "AS FOUND"
condition.
Further details and inspection findings are described
below.
3.3 Test Results
The inspector reviewed the LLRT Results Summary and discussed
analysis of test failures and status of test results with the
licensee.
Several significant problems were encountered. The
initial tests of two penetrations (Main Steam line A and Main
Steam drain to Condenser Hotvell) resulted in unacceptable leakage
past both redundant boundaries. The inspector explianed that the
overall primary containment system leakage improvements resulting
from repairs of these penetrations and others prior to the PCILRT
are expected to be added to the results of the PCILRT for determination
of the "AS IS" test result in accordance with 10 CFR 50 Appendix
J.
This requirement was acknowledged by the licensee. Preliminary
evalautions of LLRT results for this purpose appeared to be
adequate.
3.4 Reportability
The licensee submitted event reports (82-19 and 82-20) identifying
abnormal degradation of the primary containment for the two
penetrations with unacceptable leakage past both boundaries.
The
inspector inquired about li.ensee intentions to report other
valves with LLRT results exceeding their allowable TS limit of
11.9 SCFH necessitating repairs to reduce leakage.
In accordance
with Procedure 104, Control cf Nonconformances and Corrective
Action, the test engineer submitted a Deviation Report on February
26, 1982 identifying twelve Containment Isolation Valves whicn
were found to exceed their TS allowable leakage. This report was
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later evaluated by the Department Manager, Plant Operations
Manager, Safety Review Manager and Manager of Operations who
concluded that the occurance would be reported as part of the
PCILRT Technical Summary Report and not as an LER.
The inspector
acknowledged the need for this information in the Technical
Summary Report but stated that operation with unacceptable LLRT
results represented a reportable occurence as identified in
Regulatory Guide 1.16 paragraph C.2.a(2)(c).
The inspector
further explained that the intent of this requirement, during
outage periods when containment isolation is not required, could
be satisfied by an initial notification with a single LER supplement
following ccmpletion of all LLRT(s).
In addition to the recent LLRT failuras the inspector reviewed
the results of the LLRT program from the 1980 Refueling Outage
and determined that the LLRT failures were not properly reported.
Failure to submit an LER for containment isolation leak rate test
failures from the recent outage and the 1980 Refueling Outage
constitutes a violation of TS 6.9.2, Reportable Occurrences.
(219/82-06-01).
3.5 Test Witnessing
On March 18, 1982, the inspector witnessed a LLRT of Containment
Isolation Valves V-22-28 nd V-22-29.
The test was conducted in
accordance with approved procedure 665.5.006, following maintenance
performed to reduce leakage on valve V-22-29.
The results of the
test were unacceptable in that the test volume could not be
pressurized beyond 27 psig with the capacity of the test equipment.
The valve was again disassembled and disc-seating surface repaired.
A subsequent LLRT was found to be acceptable.
The inspector verified that the tests were cenducted in accordance
with the approvcd procedures and that the related maintenance and
work permit documentation was in accordance with the applicable
procedural requirements.
Additionally, the inspector observed
that the tcst instruments were properly calibrated and the test
personnel appeared to be suitably trained in their use.
No
unacceptable conditions were identified.
3.6 Feedwater Check Valve Testing
The licensee attempted to test all four feedwater check valves
with air.
However, excessive water leakage past the manual
isolation valve on the "A"
line prohibited a LLRT with air on
valve V-2-73. As an alternative, the licensee prepared Special
Procedure 82-038 and conducted a hydraulic leakage test on this
valve resulting in 0.
gpm leakage.
Additionally the outboard
valve (V-2-71) was tested with air and resulted in excessive
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leakage of 85 SCFH. The licensee evaluated this result and concluded
that the excessive leakage was not representative of the valve's
leak tightness due to use of the valve seat drain connection for
the test pressurization connection.
Based on the results of the water test conducted on redundant
valve V-2-73 and the previous commitment to perform necessary
piping modifications to achieve total conformance with 10 CFR 50
Appendix J during the next refueling outage, the condition was
considered acceptable.
3.7 Main Steam Isolation Valve Tests
Due to the method of testing inboard isolation valves, step 8.1.2
of Procedure 665.5.003 requires that the leak rate measured for
the outboard MSIV be added to the measured inboard valve leakage
to obtain a conservative value.
Likewise, the leak rate measured
for drain valves V-1-110 and V-1-111 must be added to the leak
rate measured for valves V-1-106 and V-1-107.
Review of LLRT
records (Data Sheets) revealed that this procedural calculation
requirement was not adhered to on three occasions:
February 28, 1982 - NS03B (IB MSIV) leakage reported as zero
while NSO4B (OB MSIV) reported as 11.49 SCFH
March 17, 1982
- Valves V-1-106, V-1-107 leakage reported
as zero while V-1-110, V-1-111 reported as
gross (could not measure.)
March 28, 1982
- NS03 A (IB MSIV) leakage reported as zero
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while NS04A (OB MSIV) reported as 22.9 SCFH.
During discussions with the responsible test engineers, they
stated that they were not aware of the procedural calculation
requirement and overlooked it.
As corrective action the ifcensee prepared a special procedure
665.5.003.1, Leak Testing MSIV's in Series (NS03A and NS04A) or
(N503B and NSO4B). On April 5, 1982 a satisfactory test was
performed on NS03A and NSO4A with a combined leakage of 4.57
SCFH. As of April 6,1982 the licensee had not yet corrected the
unacceptable test results of V-1-106, V-1-107 from March 17,
1982.
Improper calcula+. ion of test results on the occasions noted
represent an apparent failure to properly implemcnt approved
procedures. This example, along with the ones described in
paragraph 3.8, and 4.6 constitutes a violation of Technical Specification 6.8.1.
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3.8 Corrective Action for Test Failures
On March 28, 1982 MSIV-NSO4A was LLR tested, resulting in unacceptable
leakage of 22.9 SCFH. After recognizing some stem packing leakage,
the test engineer obtained maintenance personnel assistance to
tighten the packing. An immediate subsequent LLRT resulted in
acceptable leakage of 0.7158 SCFH.
procedure 105, Conduct of Maintenance, Section 4.1, states that
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all observed instances of failures, malfunctions, equipment
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deficiencies and deviations from acceptable performance which
require maintenance to correct shall be identified and documented
on a job order form which is used to initiate, track and document
maintenance activities performed by Oyster Creek personnel.
On March 28, when NSO4A failed, the LLRT and the packing was
tightened and no maintenance job order form was initiated. As of
April 6, 1982 the licensee could not provide the dccumented form.
During discussions with the responsible test engineer, he stated
that at the time of the occurrence he felt that a maintenance job
order form was not required to document the tightening of valve
packing.
Improper conduct of maintenance without required documentation on
this occasion represents failure to properly implement approved
procedures.
This example,-along with examples described in
parcgraph 3.7 and 4.6, constitute a violation of Technical Specification 6.8.1.
4.
Primary _ Containment Intearated Leak Rate Test (PCILRT)
4.1 General
On March 30 through April 4,1982, Oyster Creek Nuclear Generating
Station performed a PCILRT as required by TS 4.5.D.
The test was
performed in accordance with Procedure 666.5.007, Revision 5,
dated July 29, 1981.
The inspector reviewed the test procedure,
witnessed preparations and various portions of the test.
Further
details and inspection findings are described below.
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4.2 Procedure Review
The inspector reviewed the PCILRT Procedure along with the documects
listed in paragraph 3.1 for technical adequacy and to ascertain
compliance with Technical Specifications and commitments for
compliance with 10 CFR 50, Appendix J.
The inspector also discussed
various aspects of the PCILRT with the licensee's representative,
including guidance asailable in industry standard ANSI /ANS 56.8-
1981. With the exception of the item described below the inspector
identified no unacceptable conditions.
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Section 5.9.3 of the procedure provides an equation for correcting
the calculated leakage rate for liquid volume changes in the
containment.
The inspector identified an error and questioned
the validity of this equation.
The licensee agreed that the
equation was in error and committed to correcting it prior to
calculating the final official leak rate.
Recognizing that this
correction would have a very minor effect on the test results,
the inspector considered the licensee's committment acceptable.
However, the matter is unresolved pending NRC review of the
licensee's corrective action.
(219/82-06-02)
4.3 Instrumentation
The inspector reviewed the calibration records for resistance
temperature detectors, dewpoint instrumencs, pressure detectors
and verification test flowmeters. Their calibration prior to the
PCILRT were found to meet applicable accuracy requirements and
were traceable to the National Bureau of Standards.
The inspector
also verified that the instrument system specified in the test
procedure satisfied the instrument selection guide of ANSI /ANS
56.8-1981.
The inspector observed operation of the automatic
data collection system during conduct of the test.
The inspector
had no further questions regarding instrumentation.
4.4
Inspection Tours
The inspector conducted inspection tours independently and with
licensee personnel both before and during the PCILRT. During
these tours, test boundaries were surveyed for evidence of leakage
and, on a sampling basis, selected valves were verified to be in
correct positions according to procedure requirements.
During these tours no significant leakage was identified. However,
on April 2, 1982 the station air system inside the Reactor Building
was found to be pressurized.
This system was used as the test
pressurization source. After the start of the test, it had been
isolated and vented to prevent any possible air addition to the
containment past test boundary valves V-6-135 and V-6-136.
Subsequent to this, at approximately 4:00 am, the system vent was
closed with tne belief that the system would remain depressurized.
At approximately 1:30 pm, the sytem was again depressurized
(vented). After evaluation of the test data trending, the licensee
concluded that having the service air system pressurized during
this short time period had no measurable effect on the test
results. This event was documented in the test Abnormal Event
log.
The licensee stated that prior to the next PCILRT this
system would be modified to provide local isolation and venting
of that penetration.
No violations were identified as a result
of this problem.
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4.5 PCILRT Chronology
March 30
Completed the drywell inspection
March 30
1945
Commenced pressurizing the containment
March 31
Experienced problems with the drywell
recirculation fan motors drawing high
amperage and breakers tripping.
0430
Performed LLRT on drywell airlock which
revealed outer door leakage.
0615
Commenced depressurizing the containment
due to problems with drywell recirculation
fans
1430
Ccmpleted depressurization of the containment
Containment entry made and drywell
recirculation fans re-adjusted to lowest
speed setting.
April 1
0315
Commenced pressurizing the containment
again
1300
Completed pressurization at test pressure
(Pt) of 37.37 psia
1630
Began temperature stabilization period
Conducted leak surveys
2200
Temperature stabilization Complete.
Started 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test period data collection
April 2
Continued inspections for leaks and
test data collection
0130
Dewcell instruments appeared to be
unstable. Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later
returned to normal stable condition
1200
Prelimary calculations indicate leak
rate will be acceptable
1800
Radiological problems discovered in
Reactor Building
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2225
Completed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test period data
collection
2255
Commenced 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> verification test with
an indicated leakage rate of 3.95 SCFM
April 3
0530
Dewcell readings unstable again and
test to be continued
1740
Completed the verification test and
commenced depressurization of the containment
4.6 Conduct of Test and Procedural Control
During performance of the test, the inspector identified several
concerns regarding adherence to the test procedure and proper
procedural control as described below.
Step 7.3 of the test procedure requires completion of the test
valve lineup verification (checkoff sheets) and step 7.3.16
requires verification that instrument racks are aligned per
Procedure 410, Placing Instrument Racks RK-01, 2, 3 and 4 in
Service. On March 31, the inspector identified that valve V-38-
1021 had not been verified to be open on the valve checkoff sheet
and the normal instrument alignment verification per Procedure
410 had not been started even though the test pressurization had
started the previous day, March 30.
The licensee responded to this by immediately verifying valve V-
38-1021 open and initiating a sampling verification of instrument
alignment.
Later, the licensee conducted an alignment verification
for all containment instrumentation per Procedure 410. This was
completed on April 5, with no discrepancies noted.
Section 4.9 of the test procedure requires that personnel performing
the test shall sign the cover page to document that the precautions
have been read and understood. On March 31, the inspector identified
that no personnel had as yet signed the cover page although test
pressurization started on March 30.
The test director explained
that further training of personnel would be done later that day.
On April 1, the inspector noted that test engineers had satisfied
this requirement.
On April 5, the inspector noted that the
operations staff supporting the test had also signed the cover
page.
Section 4.2 of the test procedure requires that the control room
operator log the reactor vessel flange temperature hourly during
the test. On April 2, the inspector noted that the day shift
reactor operator was not logging the flange temperature as required
and was not aware of the procedural requirement to do so.
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Procedure 107, Procedure Control, requires that " Temporary Change"
revisions to procedures be documented on a Station Controlled
Distribution Document Request (Form 103-1) and that the GSS/GOS
will ensure that this form is completed when he approves the
revision. On March 31 the inspector noted that four " Temporary
Change" revisions had been executed in the working copy of Test
Procedure 666.5.007 on March 28, 29, and 30 without being documented
on Form 103-1.
The test director responded to this by documenting
these revisions on the required Forms 103-1.
Procedure 107, Procedure Control, and TS 6.8.3 permit " Temporary
Change" revisions to procedures provided they do not change the
intent of the original procedure. The inspector questioned the
justification for one " Temporary Change" revision which deleted
the requirement to vent the Instrument Air System Piping inside
the drywell and, as such, changed the scope of the test boundaries,
the intent of the test procedure, and possibly violated the
requirements of 10 CFR 50 Appendix J.
The licensee later determined
that the initial " Temporary Change" revision was not justified
and that the system was required to be vented. On April 5 a
" Temporary Change" revision was executed to delete the original
" Temporary Change" revision.
In addition, the licensee documented
this system alignment error in the test Abnormal Events Log. The
licensee plans to correct (adjust) the results of the PCILRT by
adding the results of a LLRT for the Instrument Air System
penetration which was incorrectly omitted from the boundaries of
the test.
The inspector considered the corrective action acceptab'.e.
At the end of the test the inspector noted that a total of twelve
" Temporary Change" revisions were executed.
The inspector commented
that this appeared to be excessive, not in agreement with the
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intent of Procedure 107, and that most could have been handled by
the normal review and approval cycle prior to the start of the
test.
The specific problems identified above represent an apparent
failure to properly ir:1cment approved procedures. These examples,
along with the ones described in paragraph 3.7 and 3.8, collectively
constitute a violation of Technical Specification 6.8.1 and
(
6.S.3. (219/82-06-03).
4.7 PCILRT Results
The licensee evaluated the test results for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period
starting at 22:25 hours on April 1 and ending 22:25 hours on
April 2, 1982.
The calculated leakage rate at the 95% upper
confidence level was 0.273 weignt reccent per day.
The test
acceptance criterion is 0.375 weight percent per day.
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The inspector noted that the above calculated leakage rate of
0.273 is not corrected for the change in containment free volume
due to water accumulation in the sump or addition of LLRT results
,
for the Instrument Air System penetration. Additionally, this
value represents the Conta; ament System "AS LEFT" overall leakage.
An evaluation of any leakage improvement resulting from repairs
performed prior to the PCILRT is needed to determine the Containment
System "AS FOUND" overall leakage.
Both values are expected to
be reported in the Technical Summary Report.
The inspector independentiv calculated several mass values and
the leakage rate, using raw data from the test. The results were
identical to and verified, the accuracy of the licensee's leak
rate calculations.
5.
Facility Tours
The inspector made several tours of the facility including the Reactor
Building and the Control Room.
During these tours, the inspector observed operations and activities
in progress, implementation of radiological controls, general condition
of safety related equipment, component tagging and system operations
to support the PCILRT.
6.
Unresolved Item
Items about which more information is required to determine acceptability
are considered unresolved.
Paragraph 4.2 contains an unresolved item.
7.
Exit Interview
The inspector met with licensee representatives (see detail 1 for
attendees) on March 19, 1982 and at the end of the inspection on April
6, 1982.
The inspector summarized the scope and findings of the
inspection at those times.
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