ML20132C985
| ML20132C985 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/29/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20132C709 | List: |
| References | |
| FOIA-85-425 NUDOCS 8505030140 | |
| Download: ML20132C985 (6) | |
See also: IR 05000206/1985012
Text
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NUCt. EAR REGULATORY COMMISSION
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MEMORANDtM FOR:
r
Dennis F. Kirsch, Acting Director
Q $b46S
.,
Division of Reactor .4fety and Projects
Region Y
Fr0N: James G. Partlow, Director
Division of Inspection Programs
Office cf Inspection and Enforcement
SUBJECT:
INSPECTIONS BY IE PERSONNEL - SAN ONOFRE
IE Inspection Report No. 50-206/85-12; 50-361/85-09; $0-362/85-08, dated
April 10, 1985, provides the results of an inspection perfomed by IE per-
sonnel covering the operations, surveillance
42700, 71707, 71710, 61700, 61726, and 38701 and procurement areas (IPs
Generating Station (SONGS). at the San Onofre Nuclear
One aspect of this inspection was to provide an input to assess regional
implementation of the IE inspection program. Based on a review of inspection
reports and 766 data (tabulated in the enclosure) for the previous two years,
the following observations were made relative to SONGS:
1. The minimum and basic programs of IE Manual Chapter 2515 have been
implemented in the operations, surveillance, and procurement areas.
The quality of the associated reports was considered above average.
7.
The two unresolved items associated with the vital batteries were
not previously identified in the regional inspection reports,
although the written inspection program could have led to their
discovery. This area has been identified as a generic weakness
throughout all the regions and has been separately addressed in an
IE Office Direhor memorandum to Regional Administrators dated
February 26,155
3. Region V inspection reports had identified several weaknesses in
the licensee's performance for controlling system lineups. Some
.
of the Re
actions. gion V findings in this area led to escalated enforcement
'
.
IE inspection findings 50-361/85-09-04 and 50-361/85-09-05
- ,f . appear
findings.to be consistent with the previously identified Rygfon V
,
4. Region Y Inspection Report 50-206/84-19; 50-361/84-24; 50-352/84-24
'
identified housekeeping weaknesses in the same area of the Unit 2
,
Safety Equipment Buf1 ding as did the IE inspectors in Paragraph 2.c
of their report. e
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ennis F. Kirsch - 2-
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5. Unresolved Item 50-206/85-12-01 pertains to the licensee's apparent
failure to detemine the as-found condition for the. containment
integrated leak rate test (CILRT) perfomed on Unit 1 during May/ June
1984. This issue was not previously identified despite the fact that
the CILRT had been reviewed as part of Inspection Report $0-206/84-13;
50-361/84-16; 50-362/84-17. We note , however, that uncertainty may
-
exist among licensees and within the NRC concerning the proper inter-
'
.,
pretation of some qf the regulatory requirements applicable to CILRTs,
l particularly the requirement to detemine and report the as-found
!
-
. condition. Consequently, we are revisin
procedures (IPs 70307, 70313, and 70323)g the applicable
and have drafted an inspection
, Information Notice for issuance in the near future.
, 6 The two concerns associated with the surveillance testing of the
Unit 3 auxiliary feedwater pusps (Unresolved Items 50-362/85-08-01
- and50-362/85-08-02) had not been previously identified in the
mgional inspection reports. However, the licensee mistakes that
! led to these identified conce ms occurred relatively recently
(November 1984 - January 1985) and the affected area had not yet
been sampled by Region V inspectors.
! Based upon our limited review of the licensee's operations and surveillance
i activities, we generally concur in the Region V assignment of a SALP rating of
J category three in operations and category two in surveillance for the SALP
l period July 1, 1982 through May 30, 1983.
l
i
James 0. Partlow, Director
l Division of Inspection Programs
! Office of Inspection and Enforcement
1 Enclosure:
j As stated
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Enclosure
1
766 OATA SUMMARY FOR SAN DNOFRE UNITS 2 AND 3 ;
m.
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A. flant Operations ! -
d. Program Requirements (Minimum / Basic and Supplemental Programs) l
'
reviewed during the tgspection.
'
- -
a. IP 71707 - Operational Safety Verification - done daily /
weekly / biweekly,
b. IP 71710 - ESF System Walkdown - done bimonthly.
c. IP 42700 - Procedures - done when required (Supplemental Program).
2. Inspections Conducted.
PROCEDURE REPORT FROM TO STAFF PCT STATUS
NUMBER DATE DATE HRS COMPLETE
a. IP 71707-Unit 2 8243 122282 011983 18 100 C
8303 011683 030183 44 100 C
8310 030183 032283 20 100 C
8315 032383 060283 72 100 C
8322 032683 042283 -- --- -
8324 042583 060283 38 100 C
8325 060383 070583 35 100 C
8327 070683 080383 36 100 C
8329 080483 091683 49 100 C
8333 091783 102833 16 100 C
8340 102983 120983 25 100 C
8343 121083 012184 30 100 C
8406 012284 022984 34 100 C
8411 030784 042984 7 100 C
8416 043084 061184 39 100 C
8418 061184 080584 42 100 C
8424 090684 101284 188 100 C
., 8427 101584 111383 82 --- -
-
8435 111484 121584 27 100 C
'
b. IP 71707-Unit 3 8235 122282 011983 7 100 C
8303 012483 022083 10 100 C
8304 011683 030183 44 100 C
, '
-
8308 030183 032283 18 100 C
- 8311 022183 032583 18 100 C
j '
8313 032383 060283 48 100 C
1", 8321 032683 042283 12 's i 100 C
8323 042583 060283 36 100 C
8324 060383 070583 23 - 100 C
8326 070683 080383 26 100 C
8327 080483 091683 100
-
21 C
8331 091783 102883 18 100 C
8339 102983 120983 79 100 C
- - _ . - . -
_ _ . . _ - _ _ _ _ _ . _ _ _ _ _ __,_ . _ . . . _ - _ _ _ _ _ _ _ _
_ _ _ - . _ . . - ~ . . _
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REPORT FROM TO STAFF PCT STATUS
PROCEDURE
NUMBER DA1E DATE HR5 COMPLETE ,
8342 121083 I 012184 41 100 .
C
-
8406 012284 022984 34 100 C
- 8411 030784 042984 30 100 C
8417 043084 061184 37 100 C
8418.- 061184 080584 72 100 C
100 8
l . 8424 090684 101284 133 C
8428 101584 111384 37 --- -
l' 8435 111484 121584 22 100 C
,
8310 030183 03228 6 100 C
i' c. IP 71710-Unit 2
10 100
8315 03238 060283 C
8325 060383 070583 16 100 C
8329 080483 091683 10 100 C
8340 102983 120983 18 100 C
8416 043084 061184 6 100 C
! -
8418 061184 080584 -- ---
8424 090684 101284 19 100 C
-
8435 111484 121584 -- ---
,
d. IP 71710-Unit 3 8313 032383 063283 10 100 C
i 100 C
1
.
8324 060383 070583 16
8327 080483 091683 20 100 C
l 8339 102983 120983 20 100 C
i
8417 043084 061184 7 100 C
j 8418 061184 080584 24 100 C
I 8424 090684 101284 20 100 C
8435 111484 121584 -- --- -
e. IP 42700 Unit 2 Not accomplished during this period.
f. IP 42700 Unit 3 Not accomplished during this period.
l
,
B. Surveillance
1. Program Requiryments (MinimuW8asic and Supplemental Programs)
j reviewed during,the inspection.
' a. IP 61725 ' Surveillance Test and Calibration Program -
done every 3 years.
. b. IP 61726 Monthly surveillance observation - done monthly. !
'
'
- c. IP 61700 - Surveillance - done when required.
I
2. Inspections conducted. '
,
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STAFF PCT STATUS
REPORT FROM TO
PROCEDURE COMPLETE ..
DATE DATE HRS
NUMBER I
,!
012483
!
022083 8 - 100 . C
a. IP 61726 Unit 2 8305 022183 032583 5 100 C
- 8312 100 C
030183 033183 2
8316 3 100 C
' 8327 070683 080383
091683 6 100 C
8329L. 080483 C $
091783' 102883 2 100
8333 100 C
.
~
102983 120983 4
8340 -
121083 012184 3 ---
8343 --- -
8406 012284 022984 -
1 20 C
8411 030784 042984
5 100 C
8416 043084 061184
C
8418 061184 080584
010284 5 100 C
8424 090684 -- -
8427 101584 111384 32
3 100 C
8435 111484 121584
012483 022083 7 100 C
b. IP 61726 Unit 3 8303 032583 5 100 C
8311 022183 C
030183 033283 2 100
8315 C
070683 080383 1 100
8326 --- -
8327 080483 091683 -
8 100 C
8331 091783 102883
--- C
8339 102983 120983 -
-
---
121808 012184 2
8342 C
012284 012184 2 ---
8406 50 C
8411 030784 042984 2
13 100 C
8417 043084 061184
061184 080584 5 60 C
8418 C
090684 101284 7 100
8424 -
101584 111384 2 ---
8428
111484 121584 4 /100 C
8435
012183 17 100 C
c. IP 61700 Unit 2 8301 010383
010383 012183 6 100 C
d. IP 61700 Unit *, 3 8301
'
e. IP 61725 Unit ,d Not accomplished during this period.
,
f. IP 61725 Unit 3 Not accosplished during this period.
C. _ Procurement
~
-
.1. Program Requiments (Minumum/ basic and supplemental programs) re-
- viewed during the inspection. ,;
[{
a. IP 38701B Procurement Program - done each inspection' period. ;
J
b. IP 387028 - Receipt, Storage and Handling of Equipment and
.
Materials Program done each inspection period. l
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c. IP 387006 - Procurement - no longer required.
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REPORT FROM TO STAFF PCT STATUS
PROCEDURE ,
HRS COMPLETE H
NUMBER DATE DATE
a. IP 387008-Unit 2 8307 020783 021183 7 100 . C
IP 387008-Unit 3 8307 020783 021183 7 100 C
b.
- .
060484 060884 17 100 C
c. IP 387018-Unit 2 845
- d , IP 387018-Unit 3 8415 060484 060884 16 --- C
e. IP 387028-Unit 2 8415 060484 060884 8 100 C
f. IP 387028-Unit 3 8415 060484 060884 8 --- C
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MEMORANDUM FOR:
.,
Dennis F.TKirsch, Acting Director
Division of Reactor Safety and Projects
Region V
1
FROM:
James G. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
SUBJECT:
INSPECTIONS BY IE PERSONNEL - SAN ONOFRE
IE Inspection
April 10, 1985,Report No. 50-206/85-12; 50-361/85-09; 50-362/85-08, dated
sonnel covering the operations, surveillance, and procurement a
42700,
Generating 71707, 71710,
Station 61700, 61726, and 38701) at the San Onofre Nuclear
(SONGS).
One aspect of this inspection was to provide an input to assess regional
implementation of the IE inspection pmgram. Based on a review of inspection
the following observations were made relative to SONGS: reports an
1.
The minimum and basic programs of IE Manual Chapter 2515 have been
implemented in the operations, surveillance, and procurement areas.
The quality of the associated reports was considered above average.
2.
,
' The two unrtsolved items associated with the vital batteries were
not previously identified in the regional inspection reports,
although the written inspection program could have led to their
discovery.
This area has been identified as a generic weakness -
throughout all the regions and has been separately addressed in an
l
IE Office Direhor
February 26,1985memorandum to Regional Administrators dated
! 3
! Region V inspection reports had identified several weaknesses in
-
'
thethe
of Itcensee's
Re performance for controlling system lineups. Some
. actions. gion V findings in this area led to escalated enforcement
-
.
IE inspection findings 50-361/85-09-04 and 50-361/85-09-05 '
,J. appear
findings. be consistent with the previously identified Ryglon V
to
~
4 Region V Inspection Report :~ .
50-206/84-19; 50-361/84-24; 50-352/84-24
.
identified housekeeping weaknesses in the same area of the Unit 2
Safety
of theirEquipment
report. Butiding as did the IE inspectors in Paragraph 2.c
g.g, q gyga, y,g
2.h
,
_ _ _ - . . - -
,
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~
.
-- - .
s
.
- -
ennis F. Kirsch - 2-
_
5. Unresolved Item 50-206/85-12-01 pertains to the licensee's apparent
failure to detemine the as-found condition for the containment
integrated leak rate test (CILRT) perfomed on Unit 1 during May/ June
1984. This issue was not previously identified despite the fact that
-
the CILRT had been reviewed as part of Inspection Report 50-206/84-13;
50-361/84-16; 50-362/84-17. We note , however, that uncertainty may
.
- exist among licensees and within the NRC concerning the proper inter-
pretation of some qf the regulatory requirements applicable to CILRTs,
- particularly the reqtrirement to detemine and report the as-found
- -
. condition. Consequently, we are revisin
prvcedures (IPs 70307, 70313, and 70323)g the applicable
and have inspection
drafted an IE
Information Notice for issuance in the near future.
6. The two concerns associated with the surveillance testing of the
Unit 3 auxiliary feedwater pumps (Unresolved Items 50-362/85-08-01
and 50-362/85-08-02) had not been previously identified in the
'
,
regional inspection reports. However, the licensee mistakes that
led to these identified concerns occurred relatively recently
(November 1984 - January 1985) and the affected area had not yet
been sampled by Region V inspectors.
Based upon our limited review of the licensee's operations and surveillance
activities, we generally concur in the Region V assignment of a SALP rating of
category three in operations and category two in surveillance for the SALP
period July 1, 1982 through May 30, 1983.
t
James 0. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
As stated
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Enclosure
! -
766 DATA SUPMARY FOR SAN ONOFRE UNITS 2 AND 3
m
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A. flant Operations ! -
d. Program Requirements (MinimunVBasic and Supplemental Prtgrams)
reviewed during the gspection.
- - '
'
a. IP 71707 - Operational Safety Verification - done daily /
weekly / biweekly,
b. IP 71710 - ESF System Walkdown - done bimonthly.
c. IP 42700 - Procedures - done when required (Supplemental Program).
2 Inspections Conducted.
PROCEDURE REPORT FROM TO STAFF PCT STATUS
NUMBER DATE DATE HRS COMPLETE
! a. IP 71707-Unit 2 8243 122282 011983 18 100 C
! 8303 011683 030183 44 100 C ;
i 8310 030183 032283 20 100 C .
l 8315 032383 060283 72 100 C I
8322 032683 042283 -- --- .
8324 042583 060283 38 100 C
, 8325 060383 070583 35 100 C
8327 070683 080383 36 100 C
8329 080483 091683 49 100 C
8333 091783 102833 16 100 C
'
8340 102983 120983 25 100 C
8343 121083 012184 30 100 C 1
8406 012284 022984 34 100 C
'
8411 030784 042984 7 100 C
8416 043084 061184 39 100 C
8418 061184 080584 42 100 C
8424 090684 101284 188 100 C
., 8427 101584 111383 82 --- -
-
8435 111484 121584 27 100 C
b. IP 71707-Unit 3 8235 122282 011983 7 100 C
8303 012483 022083 10 100 C
. 8304 011683 030183 44 100 C
-
2
-
8308 030183 032283 18 100 C
'
8311 022183 032583 18 100 C
) ; 8313 032383 060283 48- 100 C l
- i i~ ~ 8321 032683 042283 12 ^* i 100 C
!
8323 042583 060283 36 100 C
8324 060383 070583 23 - 100 C
-
8326 070683 080383 26 100 C
8327 080483 091683 21 100 C
8331 091783 102883 18 100 C
8339 102983 120983 79 100 C
_ _ _ . . - - - , . . . - - . _ _ _ - - . . . . . . . . . . - . . - . -
-. - . . . - _ _ . _ .
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PROCEDURE REPORT FROM TO STAFF PCT STATUS
NUMBER DATE DATE HR$ COMPT.ETE ,
! 41 100
8342 121083 012184 .
C
-
8406 012284 022984 34 100 C
. 8411 030784 042984 30 100 C
-
8417 043084 061184 37 100 C
8416- 061184 080584 72 100 C
100 *
. 8424 090684 101284 133 C
8428 101584 111384 37 --- -
8435 111484 121584 22 100 C
c. IP 71710-Unit 2 8310 030183 03228 6 100 C
8315 03238 060283 10 100 C
8325 060383 070583 16 100 C
8329 080483 091683 10 100 C
8340 102983 120983 18 100 C
8416 043084 061184 6 100 C
8418 061184 080584 -- --- -
8424 '090684 101284 19 100 C
8435 111484 121584 -- --- -
- d. IP 71710-Unit 3 8313 032383 060283 10 100 C
l . 8324 060383 070583 16 100 C
8327 080483 091683 20 100 C
8339 102983 120983 20 100 C
8417 043084 061184 7 100 C
8418 061184 080584 24 100 C
8424 090684 101284 20 100 C
8435 111484 121584 -- --- -
e. IP 42700 Unit 2 Not accesplished during this period.
, f. IP 42700 Unit 3 Not accomplished during this period.
B. Surveillance
-
1. Program Requirp*nents (MinimunV8asic and Supplemental Programs)
reviewed during, the inspection,
a. IP 61725 "S6rve111ance Test and Calibration Program -
done every 3 years.
. b. IP 61726 Monthly surveillance observation - done monthly.
IP 61700 - Surveillance - done when required.
'
c.
_
- >2 ~
.. ' 2 Inspections conducted. '
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TO STAFF PCT STATUS
PROCEDURE REPORT FROM
HR$ COMPLETE si
NUMBER DATE DATE
l
012483
!
022083 8 ' 100 C
a. IP 61726 Unit 2 8305 032583 5 100 C
- 8312 022183
030183 033183 2 100 C
8316
- 070683 080383 3 100 C
8327
080483 091683 6 100 C
E'i
8329L
091783 102883 2 100 C
- 8333 C
'
8340 102983 120983 4 100
-
8343 121083 012184 3 ---
--- -
8406 012284 022984 -
030784 042984 1 20 C
8411
043084 061184 5 100 C
8416 C
8418 061184 080584
010284 5 100 C
8424 090684 -
8427 101584 111384 32 --
8435 111484 121584 3 100 C
012483 022083 7 100 C
b. IP 61726 Unit 3 8303 5 100 C
8311 022183 032583
8315 030183 033183 2 100 C
8326 070683 080383 1 100 C
--- -
8327 080483 091683 -
8331 091783 102883 8 100 C
120983 - --- C
8339 102983 -
8342 121808 012184 2 ---
012184 2 --- C
8406 012284
8411 030784 042984 2 50 C
8417 043084 061184 13 100 C
8418 061184 080584 5 60 C
8424 090684 101284 7 100 C
-
8428 101584 111384 2 ---
8435 111484 121584 4 /100 C
010383 012183 17 100 C
c. IP 61700 Unit 2 8301
010383 012183 6 100 C
d. IP 61700 Unit #3 8301
9
'
e. IP 61725 Unit ,d Not accomplished during this period.
,
f. IP 61725 Unit 3 Not accosplished during this period.
,
C. _ Procurement
- .
-
.1. Program Requirinents (MinusunVbasic and supplemental programs) re-
l ,;
t ,- 7 - viewed during the inspection.
a. IP 387018 Procurement Program - done each inspection' period.
i
. b. IP 387028 - Receipt Storage and Handling of Equipment and
Materials Program done each inspection period.
c. IP 387008 - Procurement - no longer required.
_ _ _ _ _ _ _ . _____ ___,_ _ ' ]
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PROCEDURE .
REPORT FROM TO STAFF PCT STATUS
NUMBER DATE DATE HRS COMPLETE
'
a. IP 387008-Unit 2 8307 020783, 021183 7 100 . C
b. IP 387008-Unit 3 8307 020783 021183 7 100 C
- .
c. 060484 060884 17 100 C
IP 387018-Unit 2 845
IP 387018-Unit 3 8415 060484 060884 16 --- C
d.
e. IP 387028-Unit 2 8415 060484 060884 8 100 C
f. IP 387028-Unit 3 8415 060484 060884 8 --- C
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April 30, 1985
MEMORANDUM FOR: F. Randall Huey. Senior Resident Inspector
San Onofre Nuclear Generating Station
FROM: A. D'Angelo, Resident Inspector
SUBJECT; INSPECTION REPORT NO. 50-206/85-12, FINDING CONCERNING
CONTAINMENT INTEGRATED LEAK RATE TEST AT SAN ON0FRE UNIT 1
During a recent Headquarters' team inspection at San Onofre, a finding was
identified by the team which concerns the San Onofre Unit 1 Containment
Integrated Leak Rate Test (CILRT). The unresolved item which the team had
raised concerns the performance of an as-found analysis for Type A ILRT test.
The requirements for this test are contained in 10 CFR Part 50, Appendix J and
are discussed in the body of this memo.
Appendix J requires the performance of a periodic leak rate test on the
primary containment to verify that containment integrity is in tact. Three
test types are discussed in Appendix J for leak testing of primary reactor
containments. These tests are designated Type A, B, and C and are performed
as follows:
Type A test - This test is an integrated test of the entire reactor
containment which is generally performed once every three and one-third
years. .
Type B test - A test designed to locally test a containment penetration
which contains resilient seals, gaskets, or a sealing compound.
Type C test - A local test designed for testing containment isolation
valves which would not fall under category B type test. Both B and C
tests are generally performed on a two year cycle between Type A test.
A licensee performing a Type A test would normally test all penetrations by
utilizing Type B and C test methods prior to conducting a Type A test. This
is_done primarily to insure an acceptable Type A test since this test requires
the entire containment be pressurized to the calculated maximum accident
containment pressure. Should a Type B or C test fail, the licensee would then
conduct the necessary maintenance work to bring the tested penetration leakage
rate within allowable limits. The post-maintenance test on this penetration '
would be another. Type B or C test, as appropriate, to demonstrate that the
penetration local leak rate is within acceptable limits. Once all the
penetrations are locally tested and found to be satifactory, the licensee }l
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would then begin to conduct the integrated Type A test for the entire fj
containment.
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Therefore, the Type A test would yield as-left data since all penetrations had
been previously tested and any necessary maintenance or adjustment would have i
been performed. The licensee would then document all test data, including the
local leak rate tests which were performed just prior to the Type A, and
submit the technical report to the Director of Nuclear Reactor Regulation. 1
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The issue that has been raised by the Headquarters' team is that the licensee
has submitted a CILRT report which was conducted in June of 1984 which did not
contain an analysis of the as-found condition of the Unit I containment. The
licensee has submitted their Type A results along'with all Type B and C tests
results (pre and post maintenance) to the NRC but has not included an as-found
analysis of the primary containment leak rate and therefore, violated a
requirment of 10 CFR Part 50, Appendix J.
The as-found analysis would be calculated by utilizing the Type A CILRT test
just conducted, and adding to that measured leak rate (which is the as-lef t
condition) the difference in local leak rates (Type B or C) where maintenance
and/or adjustment were made to isolation valves. The result would then be a
calculated leak rate for the as-found (or as-is) condition of the containment.
Appendix J specifies the leakage testing requirments for Type A test within
Paragraph III.A.1 which states the following:
" Containment inspection in accordance V.A shall be performed as a
prerequisite to the performance of Type A test. During the period
between the initiation of the containment inspection and the performance
of the Type A test, no repairs or adjustments shall be made so that the
containment can be tested in as close to the tas-is' condition as
practicable".
At first reading, it would appear that the licensee has clearly violated the
Appendix J requirement as stated above. However, closer inspection of
Appendix J states the following in the very next sentence:
"During the period between the completion of one Type A test and the
initiation of the containment inspection for the subsequent Type A test,
repairs or adjustments shall be made to components whose leakage exceeds
that specified in the technical specification as soon as practicable
after identification. If during a Type A test, including the
supplemental test specified in III.A.3.(b), 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 III.A.4.(b) or III. A.5.(b), the Type A test shall be terminated
and the leakage through such paths shall be measured using local leakage
testing methods. Repairs and/or adjustments to the equipment shall be l
made and a Type A test performed. The corrective action taken and the l
change in leakage rate determined from the test and overall integrated i
leakage determined from the local leak and Type A test shall be included
in the report submitted to the Commission as specified in V.B."
Appendix J appears to make a distinction in that the period of time between
the initiation of the containment inspection and the performance of the Type A
test, no repairs shall be made to the containment. However, Appendix J also
states that during periods between periodic Type A tests, repairs or
adjustments shall be made to components whose leakage rates exceed Technical
Specification requirements. Therefore, it appears that if the licensee does
not declare their containment inspection to start until after all local
leakage rate tests have been completed, they would then be in compliance with
Appendix J.
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Appendix J also references an American National Standard (ANSI) which is
N45.4-1972, Leakage Rate Testing of Containment Structures for Nuclear
Reactors. This standard sets forth various test methods to be used for
containment leakage rate tests. This standard contains in Paragraph 4.2
titled Retesting:
"For retesting, an initial record proof test shall be conducted at time
periods and pressures-established by the responsible organization before
any preparatory repairs are made. This will disclose the normal state of
repair of the containment structure and a record of the results shall be
retained. If the results of this test prove that the containment leakage
rate exceeds the specified maximum, local and integral tests may be
performed and any necessary work done to bring the leakage rate within
the specified limits. A proof leakage rate test shall then be made to
demonstrate that the maximum allowable leakage rate is not exceeded."
The ANSI standard requires that no preparatory repairs be made until a Type A
test is preformed. However, this, in my opinion, is not intended to require
that during the three and one-third year period between periodic Type A tests
that no repair and/or adjustment be made until a subsequent Type A test is
performed, but merely to state that no preliminary exercising or adjustments
to valves be made prior to the start of a Type A test. It would be
unreasonable to interpert this paragraph as requiring that no repair and/or
adjustment be made until a Type A CILRT could be performed. Also, a local
leak rate such as Type B or C performed pre and post maintenance and that
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difference added to the Type A would yield essentially the same results.
Clarification on this issue is given in an internal NRC memorandum from R.
Matson to J. Sniezek, dated January 11, 1982. The memorandum states the
following in the third paragraph, "If repairs and/or adjustments made as a
result of the Type B and C testing programs, or other reasons, are made to the
primary containment boundary prior to the Type A test sequence, local leak
tests must be performed on the affected portion of the containment boundary to t
determine the leakage rates before and after the repairs and adjustments. The
"as-found" Type A test result can then be obtained by adding the difference
between the affected path leakages before and after the repairs and/or
adjustments, to the overall measured Type A test result. A periodic Type A
test should be called a " failure" if the "as-found" Type A test results (with
or without leakage
allowable correction from local leak tests) exceeds 0.75 La (maximum
rate)."
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Unfortunstely this clarification and guidance was not documented in an IE
bulletin or notice or other document to the industry and therefore the
industry did not have this interpretation from NRC available prior to the
conduct of Type A tests.
' In an effort to identify any previous enforcement actions, I conducted a
review of all enforcement actions taken by the agency during 1983 and 1984 in
an effort to identify whether this occurrence has been documented at other
facilities. The results of my search revealed that one Notice of Violation
has been issued to a licensee, the Wisconsin Public Service Corporation, which
is the licensee for Kewaunee, Docket No. 50-305. A review of the NOV revealed
that the. licensee.had performed Type B and C tests prior to performing the
Type A test and failed to add the pre and post repair differential _ leakage to
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obtain an as-found value for containment leakage. This is the identical
situation which is occurring at San Onofre. The basis for the violation
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however, is the Kewaunee Technical Specification which discusses the
performance of Type A test and states in paragraph 4 that, "The periodic test
shall be performed without preliminary leak detection survey or leak repairs."
Therefore, in the case of Kewaunee, the violation is very clear in that the
technical specification specifically prohibits preliminary leak test or repair
prior to the c;nduct of a Type A. This requirement is not contained in the
San Onofre Technical Specifications.
Another violation is in preparation in Region III on the identical subject.
This violation is against the Northern States Power Company, Docket No.
50-263. The basis of the Region III proposed violation is as follows:
" Appendix J, paragraph III.A.I.a states: "During the period between the
initiation of the containment inspection and the performance of a Type A test,
no repairs or adjustments shall be made so that the containment can be tested
in as close to the ias-is' condition as practicable".". The Region III
violatien has been proposed, however, there exists disagreement within Region
III on the basis and requirement of this violation and the issue has been
referred to I&E Headquarters for resolution. Based on my review of NOV's
generated since 1983, only the proposed Region III NOV would be identical to
the San Onofre Unit I situation.
I have also conducted an informal survey of several licensees and one
architect engineer within Region V to determine current industry practice.
The organizations contacted were Arizona Public Service, Pacific Gas and
Electric and the Bechtel Power Corporation, San Francisco Division. All three
organizations performed their periodic Type A test in the identical fashion
that Southern Californa Edison Co. performs their Type A test. All three
organizations stated that, to the best of their knowledge, it is industry
practice to perform a local leak rate test, perform maintenance and/or
adjustment, if needed, perform a post maintenance local leak rate (Type B or
C) and then start the containment inspection for the CILRT.
The dilemma at hand then is one of enforcing an interpretation, as discussed
in the January 11, 1982 letter above, by NRR of a regulation which is not
clear. I recommend that no Notice of Violation be issued at present and
further suggest that the agency take action to clarify the NRC's position on
the current Appendix J.
Original signed
Anthony J. D'Angelo
Resident Insepctor
San Onofre Nuclear Generating Station
ec: D. F. Kirsch
A. E. Chaffee
P. H. Johnson
C. Clark
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EEM0HANDUM FOR FILE
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May 15, 1985
SUBJECT: FSAR Requirements for Specific Acceptance Testing
of Safety Related Batteries
San Onofre Nuclear Generating Station, Units 2 & 3
PURPOSE: The purpose of this memorandum is to document the
results of a review to determine if specific acceptance
tests were completed as prescribed by FSAR 8.3.2.
DISCUSSION: The FSAR required that the first performance test
of battery capacity be carried out within the first two
(2) years of service. This and other capacity tests
were done under startup testing. The particular
procedures used to accomplish this testing were Startup
Procedures 2PE-448-01 and 3PE-448-01 The objectives
of these procedures are to demonstrate that the 125V DC
power systems provides a reliable source of power under
normal and emergency conditions, and is capable of
supplying the design load capacity under emergency l
conditions. This was done through the use of specified
capacity tests, recommended by IEEE 450 and specified
' as objective 1.5 and 1.8 of Procedures 2PE-448-01 and
3PE-448-01. Objective 1.5 requires verifying the name
plate rated capacity of the battery. This in
accordance with IEEE 450 is an Acceptance Test as well
as a Performance Test. Objective 1.8 requires
verifying the ability of the battery to meet the
designed (calculated) DC load requirements of the
125V DC power system (Class IE). This in accordance
with IEEE 450 is a Service Test. The initial
energization of the batteries occured in 1979 and the
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performance of Procedures 2PE-448-01 and 3PE-448-01
occured within two years of the initial energization
date. The successful complation of these tests
satisfies the requirements of FSAR Section 8.3.2.
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Hemorandum For File -Page 2- May 15, 1985
CONCLUSION: NSSS Engineering has concluded that the
requirements of FSAR 8.3.2.2.1.8, IEEE 450-
_1975. Recommended Practice for Maintenance. Testing,
and Reolacement of Larce Stationary Tvoe Power Plant
' and Substation Lead Storage Batteries. have been
adequately satisfied by the performance of Startup Test
Procedure
Unit 3. 2PE-448-01 for Unit 2 and 3PE-448-01 for
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R. RADAKOVIC
Approved:- <[
f.,' Briggs III
Supervising Engineer II
RR006/mdr
ec: J. T. Reilly
K. L. Johnson
H. E. Morgan
,
P. A. Croy
R. A. Neal
D. Shull
CDM Files
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