IR 05000295/1985033

Insp Repts 50-295/85-33 & 50-304/85-34 on 850913-30.No Violations or Deviations Noted.Major Areas Inspected:Unit 2 Containment Integrated Leak Rate Test (Cilrt),Unit 1 Cilrt Rept & Resolution of Unit 1 Violations & Open Items

ML20133H115
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/09/1985
From:	Guldemond W, Maura F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133H110	List: IR 05000295/1985033 ML20133H107
References
50-295-85-33, 50-304-85-34, NUDOCS 8510160274
Download: ML20133H115 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-295/85033(DRS); 50-304/85034(DRS)

Docket Nos. 50-295; 50-304 License Nos. OPR-39; DPR-48

. Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, Illinois Inspection Conducted: September 13-30, 1985 Inspector:

MM F. Maura /r>/f/pg ~

Date Approved By- . G. Guldemo CbI /#

OperationalGP,rograms Section Date Inspection Summary Inspection on September 13-30, 1985 (Report Nos. 50-295/85033(DRS);

50-304/85034(DRS))

Areas Inspected: Routine, announced inspection by a region based inspector to witness the Unit 2 Containment Integrated Leak Rate Test (CILRT); review the Unit 1 CILRT report dated November 30, 1984; and review resolution of

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previous violations and open items on Unit 1. The inspection involved 48 inspector-hours onsite by one NRC inspector including 25 inspector-hours onsite during off-shifts. An additional 3 inspector-hours of inspection effort were required at the regional office by one NRC inspecto Results: No violations or deviations were identified.

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DETAILS Persons Contacted

+* Cascarano, Technical Staff Supervisor J. Hutsebaut, Engineer, Technical Staff

+ R. Lane, Lead Engineer, Technical Staff

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• A. Ockert, Assistant Technical Staff Supe:9isor

• T. Rieck, Superintendent Services J. Tiemann, Engineer Technical Staff

• Denotes persons attending the preliminary exit meeting on September 17, 198 + Denotes persons contacted during telephone exit of September 30, 198 The inspector also contacted other licensee personnel including members of the technical and operations department . Licensee Action on Previous Inspection Findings (Closed) Violation (295/84-11-01): Performance of a Type A test of < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> not in accordance with the requirements of BN-TOP- The licensee (Corporate Office) held a meeting to inform all stations that Type A tests must be of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration unless specific advance NRC approval for a < 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test had been received. By letter (P. LeBlond to J. Keppler), dated August 16, 1985, the licensee committed to follow BN-TOP-1 in its entirety,

, except where it conflicts with Appendix J requirements, for tests of less than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duratio (Closed) Violation (295/84-11-02A and B): Supplemental tests, following Type A tests, not properly performed. The licensee has obtained an appropriate set of equations and graphs from the rotometer manufacturer to ensure proper use of correction factors when require (Closed) Open Item (295/84-11-03): Licensee will modify Technical Specification to permit the performance of Type A test at Pa. By letter dated January 30, 1985 (R. Cascarano to H. Denton) the licensee requested a Technical Specification change which allows

. Type A test to be performed at Pa. By letter dated August 27, 1985 (J. Norris to D. Farrar) the NRC approved the change.

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3. 1985 Containment Integrated Leak Rate Test - Unit 2 Procedure Review The inspector reviewed procedure TSS 15.6.10A, Revision 12, and the changes processed during the test, to assure regulatory requirements were me In addition to other areas already covered in this report or in Inspection Report No. 295/84-11; 304/84-11, the following requirements of Appendix J were discussed with the licensee on September 30, 1985 to ensure his understanding of the regulations: ,

(1) Test connections must be administratively controlled to ensure their leak tightness or otherwise be subject to Type C testing. One way- to ensure their leak tightness is to cap, with a good seal, the test connection after its use. Proper administrative controls should ensure cap re-installation within the local leak rate testing procedure, and with a checklist prior to unit restar (2) The water level in the steam generators must be low enough to ensure it does not enter the main steam lines unless flooding the lines is called for in the loss of coolant emergency procedur (3) Whenever the~ valve cor.5igurations during the CILRT deviate from the ideal valve lineup requirement the results of local leak rate tests for such penetrations must be added (subtraction is never permitted) as a penalty to the CILRT test result The penalty is determined using the

" minimum pathway leakage" for that penetration (do not assume a cingle failure). This same method is used in determining the Type A as-found condition when repairs and adjustments (R & A's) are performed ahead of the CILRT as a result of Type B and C testin '

(4) Whenever a valve is replaced, local leak rate testing is required. For repairs or repacking, local leak rate testing is required if the repair or repacking performed is part of the containment boundary. The local leak rate tests must include as-found and as-left result Instrumentation The inspector reviewed the calibration data and determined that the instruments used in the ILRT had been calibrated and that the

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. o licensee's calculated weighting factors and pressure correction constants were placed into the computer program as required. The following instrumentation was used throughout the test:

Type Quantity RTDs 29 Dewcells 9 E Pressure Gauges 2 Flowmeters 1

, Witness of Test The inspector witnessed portions of the ILRT on September 15-17, 1985 and noted that test prerequisites were met. The test was performed with the containment fan coolers off. Valve lineups for the following systems were verified correct to ensure that no fluid could enter the containment atmosphere and that proper venting was provided:

(1) Waste gas (2) Containment air monitoring (3) Service air (4) Nitrogen (5) Instrument air (6) Penetration pressurization 4 (7) Isolation valve seal water Since no deviations from the required valve lineups occurred, and no repairs were performed on any penetration prior to the ILRT, the calculated leakage rate.at the 95% UCL constitutes the as-found, as well as the as-left, condition of the containmen During pressurization the personnel airlock inner door shaft seals leaked excessively. The licensee closed the outer door and opened the containment to airlock equalizing valve for the duration of the test.

! ILRT Data Evaluation

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A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ILRT was performed during September 15-17, 1985 with data being collected and reduced by the licensee every 10 minute At 1154 hours0.0134 days <br />0.321 hours <br />0.00191 weeks <br />4.39097e-4 months <br /> on September 16, 1985 the data acquisition system

- (DAS) lost its power due to a breaker trip caused by an overload condition. This was not recognized by the licensee for almost an hour. Power to the DAS was not restored until 1353 hour0.0157 days <br />0.376 hours <br />0.00224 weeks <br />5.148165e-4 months <br /> As a result, two hours of data was lost during the middle of the test period. The licensee wrote a temporary procedure change to permit the loss of the two hours of data provided the test results demonstrated that prior to the interruption the calculated leak rate had stabilized and that sufficient data sets were taken to ensure an accurate representation of the leak rate. The inspector reviewed the raw data and the test result obtained

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prior to and after the power interruption to the DAS and determined that very little scatter existed in the data and that the trends observed prior to the power failure continued after the power to the DAS was restored and the pressure sensors had an opportunity to regain their internal temperatur To prevent similar problems in the future the licensee has changed its software to warn test personnel if the elapsed time between data sets exceeds 15 minutes. In addition, the licensee plans to dedicate an electrical circuit to the DAS during future tests to prevent an undesirable overload tri The inspector independently monitored and evaluated leak rate ,

data to verify the licensee's calculations of the leak rate and instrumentation performanc There was acceptable agreement

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between the inspector's and licensee's results as indicated by the following summary (units are in weight percent per day).

Measurement Licensee Inspector

Leakage rate measured during ILRT (Lam) 0.0 2 0.023 ,

Ltm at upper 95%

confidence level 0.023 0.024 i

Appendix J acceptance criteria at 95% of ULC = 0.75 La = (0.75)

(0.100 wt %/ day) = 0.075 wt %/ da '

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e. Supplemental Test Data Evaluation After the satisfactory completion of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ILRT on September-17, 1985, a known leakage (based on inspector calculations) of 7.58 scf/ min, equivalent to 0.095 weight percent per day was induce The inspector independently monitored and evaluated leak rate data to verify the licensee's test result After approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> the supplemental test was terminated with

, satisfactory results as indicated by the following summary (units are in weight percent per day).

Measurement Licensee Inspector (5 HRS)

Measured leakage rate Lc, i during supplement tests 0.103 0.105 Induced leakage rate, Lo 0.096 0.095 Lc-(Lo+ Lam) -0.015 -0.013 l Appendix J acceptance criteria -0.018 < [Lc-(Lo+ Lam)]<+0.018

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. * Penetration Bellows At the request of the Office of Nuclear Reactor Regulation, the inspector reviewed the design of the Zion containment penetration bellows and determined that the bellows are capable of being Type C tested at accident pressure (Pa). Isolatior: Valve Seal Water System (IVSW)

The inspector discussed tile design of the IVSW with the license It is the inspector's understanding that the system, as designed, may not perform its function if one of the penetration valves which the system is supposed to seal remains open (i.e., the seal water pressure at the other penetrations may drop below 1.1 Pa). During

the exit interview the licensee stated that by design the piping configuration may restrict the flow to ensure its operabilit This is an Open Item (295/85033-01; 304/85034-01) pending review of the design and preoperational data to be made available by the licensee during a future inspectio Secondary Side of Steam Generators

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The inspector verified that the water levels in the secondary sides of the steam generators remained below the main steam line outlet No violations or deviations were identifie . Review of Zion Unit 1 Reactor Containment Building Integrated Leak Rate Report The inspector reviewed the licensee's " Zion Generating Station Unit 1 Reactor Containment Building Integrated Leak Rate Test" report submitted to the NRC on November 30, 1984 and determined that it accurately reports the leak rates and events regarding the Unit 1 Type A test performed in July 198 No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensce or both. An open item disclosed during the inspection is discussed in Paragraph . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the Type A test on September 17, 1985, and summarized the scope and findings of the inspection by telephone at the conclusion of the inspection on September 30, 1985. The licensee representatives acknowledged this information. The inspector also 4 discussed the likely informational content of the inspection report with regards to documents reviewed by the inspector during the inspectio The licensee did not identi y any such documents as proprietar _ . , ,, . .. _ _ - _ _-._ . __ __. _