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Insp Repts 50-245/85-16 & 50-336/85-22 on 850603-07 & 12-17. Violation Noted:Failure to Follow Procedures for Test Instrument Calibr
	ML20134E103
Person / Time
Site:	Millstone
Issue date:	08/06/1985
From:	Jerrica Johnson, Kucharski S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20134E092	List: ML20134E089; ML20134E097; ML20134E103;
References
	50-245-85-16, 50-336-85-22, NUDOCS 8508190615
	Download: ML20134E103 (10)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report Nos. 50-245/85-16

50-336/85-22

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Docket Nos. 50-245

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50-336

Category

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License Nos. ORP-21

Priority

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DRP-65

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Licensee: Northeast Nuclear Energy Company

P. O. Box 270

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Hartford, Connecticut 06101

Facility Name: Millstone Nuclear Power Station, Unit 1 & 2

Inspection At: Waterford, Connecticut 06385

Inspection Conducted: June 3 - 7, 1985 and June 12 - 17, 1985

Inspectors:

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S. D. Kucharski, Reactor Engineer

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Approved by: _

J.'R. Johnson, Chief, Operational

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Programs Section, 08, DRS

Inspection Summary:

Inspection on June 3 - 7, 1985 and June 12 - 17, 1985

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(Inspection Report Nos. 50-245/85-16, 50-336/85-22

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Areas Inspected:

Unit 1:

Special, unannounced inspection, June 13, 1985, of the calibration

records for the instrumentation used in Local Leak Rate Tests (LLRT). The

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inspection involved 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months onsite by one region based inspector.

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Results: No violations were identified.

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Unit 2: Routine, announced inspection of the containment leakage testing pro-

gram including review of the Containment Integrated Leak Rate Test (CILRT) and

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Local Leak Rate Test (LLRT) procedures, CILRT witnessing, CILRT and LLRT test

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results review, and general tours of the facility. The inspection involved 68

hours onsite by one region based inspector.

Results: One violation was identified (Failure to follow approved procedures

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for test instrument calibration, paragraph 2.6).

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OETAILS

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Persons Contacted

Northeast Utilities

R. J. Ashey, Control Room Operator

- R. Bates, Senior Engineer

G. J. Closuls, QA/QC Supervisor

- T. Dorcinguez, Reilability Engineer

- L. Georgian, Engineer

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J. J. Keenan, Operations Assistant

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- J. J. Kelley, Unit 2 Superintendent

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- D. Kross, Unit 2, I & C Supervisor

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P. Pikul, Reliability Engineer

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"W. Romberg, Station Superintendent

R. Schleicher Jr., Unit 2, I & C Assistant Supervisor

J. Smith, Engineering Supervisor

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S. Stadnick, Plant Engineer

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Bechtel Corporation

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- G. Bone, Shift Test Ofrector - ILRT

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U.S. NRC Personnel

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- J. T. Shediosky, Senior Resident Inspector

Denotes those present at exit meeting on June 7,1985.

- Denotes those present at exit meeting on June 17, 1985.

2.

Containment Local Leakage Rate Testi.:3

2.1 Documents Reviewed

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SP 2605C, Containment Leak Test-Type B, Revision 6, 12/2/83

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SP 26050, Containment Leak Test-Type C, Revision 6, 3/29/84

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SP 2605E, Containment Personnel Airlock Leak Test, Revision 5,

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11/30/84

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1C 24368, Local Leak Rate Test (LLRT) Box Calibration, Revision 1

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5/23/84

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LLRT Calibration records, Unit 1 and 2

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Records of LLRT activities conducted during the recent outage

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including test results, related repairs and retest documentation

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Selected system Orawings, Piping and Instrumentation Otagrams.

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2.2 Scope of Review

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The inspector reviewed the above documents to ascertain compliance

with regulatory requirements of Appendix J to 10 CFR 50, Millstone

Unit II Technical Specifications, applicable industry standards and

with station administrative guidelines.

The inspector also witnessed

local leakage testing, held discussions with the licensee regarding

the documentation of test results, the repair and retesting following

failed tests, and the relationship of these items to the "As-found"

and "As-left" condition of containment as applied to CILRT results.

Further details are discussed below.

2.3 Procedure Review

The procedures reviewed were technically accurate and in conformance

with the regulatory requirements of Appendix J to 10 CFR 50 and appli-

cable industry standards.

The LLRT coordinator and associated licen-

see personnel have inspected piping configurations to assure that the

appropriate line up drawings in the LLRT procedures are accurate and

in accordance with leakage testing requirements. The inspector veri-

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fled several of these valve line ups during inside and outside tours

of the containment building. No unacceptable conditions were identi-

fled.

2.4 Test Witnessing

On June 5,1985, the inspector witnessed a type C LLRT of penetration

40 which involved the containment purge exhaust valves (AC-6 and 7).

The test was conducted with procedure SP 26050 using a licensee man-

ufactured test box.

The results of the test for the total leakage of

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the penetration was 1616 SCCM which is below the acceptable limit.

The inspector verified that the test was being conducted in accord-

ance with the approved procedure, and that the technicians involved in

the test were knowledgeable of requirements and use of the test in-

struments.

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No unacceptable conditions were identified.

2.5 LLRT Instrumentation Calibration (Unit 1)

The inspector reviewed the calibration records for the flow trans-

mitters, temperature gages and pressure gages used in the LLRT test

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rig. The instruments were appropriately calibrated and marked with

current calibration stickers.

The inspector did note that on one of

the flow indicators there was no identification tag.

The identifi-

cation tag is the only means of identifying that instrument with

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the calibration records. The inspector brought this to the attention

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of the licensee, who in turn agreed to permanently mark the instru-

ment. Once the instrument was removed from the test box it was noted

by the licensee that the identification tag was on the back side of

the instrument which was not in view during the inspection. No

unacceptable conditions were identified.

2.6 LLRT Instrument Calibration (Unit 2)

The inspector reviewed the calibration records for the flow indi-

cators, temperature gages and pressure gages used in the LLRT test

rigs.

From a review of these records the inspector determined that

all the instruments have not been calibrated. The following discrep-

ancies were noted:

There were no calibration stickers on the flow indicator for all three

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LLRT test rigs.

There were no calibration stickers on the temperature gages for all

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three LLRT test rigs.

Section 2.1, of IC 24368, Local Leak Rate Test Box Calibration,

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requires the flow indicator to be returned to vendor for calibration

every three years. The last calibration date shown for the flow

meter was October, 1980 and the licensee was unable to provide more

recent calibration records.

Section 7.2 of IC 24368 requires recording on I & C form 2436B-1

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the date the flow indicator was last calibrated and the date cali-

bration is due.

There was an "N. A." recorded in both spaces.

Section 7.2.1 of IC 24368 states, "If the flow indicator is due for

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calibration - remove and return to vendor for calibration." This

was not performed.

The method of calibration for the temperature gage on the LLRT box

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is not specified in IC 24368.

The licensee removed the LLRT test boxes and sent the flow indicators

to the vendor to be calibrated. Based on the results of the cali-

bration check it was determined that none of the type B and C tests

had to be redone.

Performance of LLRT with noncalibrated instrumentation is a vio-

lation(50-336/85-22-01).

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2.7 Test Results

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The inspector reviewed the LLRT results summary and discussed analyses

of test failures, repairs and retests with the licensee.

The inspec-

tor noted that the licensee was recording a minimum leakage for LLRT's

during which there was no movement in the rotameter scale. This is

an acceptable conservative approach by the licensee.

The "As-found" and As-left" leak rate for every test done on each

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Type B and C penetration are documented by the licensee in the LLRT

summary and are planned to be in the CILRT test report.

Based on a

preliminary review of the data, the "As-found" leakage was approx-

imately 34,000,000 SCCM which is greater than the allowable leakage

of 0.6 La and the "As-left" leakage was approximately 124511.7 SCCM

which was within the allowable leakage total of 0.6 La.

Based on

these results the licensee submitted an Licensee Event Report No.

85-003/3L-0 on April 4,1985 when they first suspected a problem

with their LLRT. No unacceptable conditions were identified.

3.

Containment Integrated Leak Rate Test (CILRT)

3.1 Documents Reviewed

Section 5.2.9 of the FSAR

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Section 3.6.1.2 of the Technical Specifications

SP 2605B, Containment Leak Rate Test - Type A Revision 4, 6/4/85

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ACP-QA-9.05, Monitoring of QA Activities, Revision 12, 2/28/83

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Monitor 285-03, Integrated Leak Rate Test (ILRT), Revision 0, 6/10/85

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Engineering Calculation Z-ENG-098, ILRT Support / Deviation of Equation

Expressing Containment Dome Volume as a Function of Dome Radius,

Revision 0, 11/22/83

Engineering Calculation 2-ENG-102, ILRT Support /RTD Failure

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Analysis, Revision 1, 11/22/83

GRE-83-236, Internal Free Volume of Millstone Unit 2 Containment,

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Revision 0, June 9, 1983

CILRT Log Book

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CILRT Instrumentation Calibration

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Test Results

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Selected Piping and Instrument Drawings.

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3.2 Scope of Review

.The inspector reviewed the above listed documents for technical

adequacy and to ascertain' compliance with the regulatory

requirements of Appendix J to 10 CFR 50, Technical Specifications

and applicable industry standards. The inspector noted the

procedure required a minimum test duration.

This is acceptable to

the NRC based on the procedure meeting the requirements of Bechtel-

Power Corporation's Topical Report BN-TOP-1, " Testing Criteria for

ILRT of Primary Containment Structures for Nuclear Power Plants."

The procedure referenced (and was in general conformance with)-

industry standard ANS/ ANSI 56.8 - 1981, " Containment System Leakage

Testing Requirements." The inspector witnessed activities related

to the CILRT and the subsequent verification test. The inspector

also performed an independent calculation of the test results.

3.3 Procedure Review

The inspector reviewed the documentation for technical adequacy and

for consistency with regulatory requirements, guidance and licensee

commitments. Review of the procedures' acceptance criteria, test

methods, and references indicated adequate conformance with Appendix

J to 10 CFR 50.

In a random sampling basis, the inspector reviewed the procedure

valve line ups for piping penetrations. This review was to ensure

that systems were properly vented and drained to expose the contain-

ment isolation valves to containment atmosphere and test differ-

ential pressure with no artificial boundaries. No unacceptable

conditions were identified.

3.4 CILRT Inst'rumentation

The inspector reviewed the calibration records for the resistance

temperature detectors (RTD's), dewpoint instruments, precision

pressure detectors, and verification test flow meters.

TMir cali-

brations prior to CILRT were'found to meet applicable accurccy

requirements and were traceable to the National Bureau of Standards.

No unacceptable conditions were identified.

3.5 CILRT Chronology

June 14, 1985

1200.- Completed test preparation and the containment inspection

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2248 - Commenced Pressurization

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2347 - Lost Dewcell ME 8064 - increase volume fraction of Dewcell

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ME 9772

June 15, 1985

0240 - Pressure at 10.2 psig

performed walk through to check for

leakage. Minor leaks found.

1200 - Pressure at 48.54 psig

performed walk through with NRC

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inspector. Minor leaks.

1400 - Completed Pressurization at 54.2 psig

1600 - Temperature and Pressure dropping

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1715 - Started to re pressurize due to low pressure

1750 - Completed Pressurization at 54.2 psig

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1808 - Commenced Stabilization Period

2159 - Secured stabilization period due to dropping pressure -

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Pressure was still above minimum but it was a precautionary

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2223 - Completed Pressurization at 54.2 psig

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2243 - Commenced Stabilization period

June 16, 1985

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0243 - Minimum stabilization time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and temperature

criteria have been satisfied.

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1100 - Conducted walk through to check penetrations for possible

leaks

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1700 - Completed official test period. Duration 14 hour1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months s-15

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minutes

1830 - Commenced Supp,lemental verification test

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1845.- Stopped stabilization period due to problems with flow meter

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2045 - Changed arrangement of flow meter for verification test

2122 - Commenced 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months stabilization period

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2222 - Commenced flow verification test

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June 17, 1985

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0222 - Completed verification test

0339 - Commenced depressurization of containment

3.6 Test Performance / Control

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The CILRT was performed within the procedural guidelines. Procedural

precautions were adhered to, especially those relating to manipu-

lations of containment boundaries after the commencement of testing.

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No unacceptable conditions were identified,

3.7 Test Results Reviewed

The licensee evaluated the test results for the June 16, 1985 14.25

hour period, between 0245 and 1700.

The calculated leakage rate

at the upper confidence limit was 0.129 wt %/ day for the mass point

calculation and 0.363 wt %/ day for the total time method. The test

acceptance criteria is based on a 0.75 La which is equivalent to

0.375 wt %/ day. The inspector performed an independent calculation

of the test results using the raw data from the test to estimate the

accuracy of the licensee's leak rate calculation. The inspector

performed the calculation using first the air mass data and then

the average temperature, pressure and vapor pressure. The results

are as follows:

1. Licensee

Mass point - 0.127 wt %/ day, UCL - 0.129 wt %/ day

Total time - 0.132 wt %/ day, UCL - 0.363 wt %/ day

2. NRC

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Air mass Calculation

Mass point

0.12697 wt %/ day,

UCL - 0.12913 wt %/ day

Total time

0.15821 wt %/ day,

UCL - 0.29783 wt %/ day

b.

Average temperature, pressure, vapor pressure

Mass point

0.12717 wt %/ day,

UCL - 0.12931 wt %/ day

Total time

0.16103 wt %/ day,

UCL - 0.31028 wt %/ day

The above values do not include the results of the LLRT's that were

performed prior to the ILRT. A preliminary review of that data

incorporated into the inspection calculations shows the following

results.

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1. Licensee

a.

"As-Found" leakage = 19.348 wt %/ day

(1) "As-found" data exceeds the 0.5 wt %/ day

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"As-left" leakage = 0.0014 wt %/ day

(1) Mass point - 0.1284 wt %/ day, UCL = 0.1304 wt %/ day

(2) Total Time - 0.1334 wt %/ day, UCL = 0.3644 wt %/ day

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NRC

a.

Air Mass Calculation

(1) "As-Found" Leakage = 19.348 wt %/ day

(a) "As-Found" data exceeds the 0.5 wt %/ day

(2) "As-Lef t" leakage = 0.0014 wt %/ day

(a) Pass point - 0.12837 wt %/ day, UCL - 0.13053 wt %/ day

(b) Total time - 0.15961 wt %/ day, UCL - 0.29923 wt %/ day

The inspector concluded and the licensee concurred that the

"As-found" results based on a 1.0 La resulted in a failed ILRT.

The results of the "As-left" ILRT based on a 0.75 La was an

acceptable test. The inspector informed the licensee based on the

failed 1.0 La ILRT that a schedule applicable to subsequent Type A

tests is required to be submitted to the NRC for review.

The CILRT was followed by a successful superimposed leak verifi-

cation test. The licensee imposed a leak of 29.76 SCFM or 0.500 wt

%/ day on the existing leak. The measured verification test leak was

0.178 wt %/ day for mass point calculation and 0.364 wt %/ day for

total time based on the 95% UCL. The test results were within the

acceptance criteria band. The inspector also verified these results

by independent calculations. The results were as follows:

a. Licensee

1.

Mass Point Band

(.504 < 0.678 < .754)

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Total Time Band

(0.638 < 0.864 < 0.988)

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b. NRC

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Mass Point Band

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(0.504 < 0.67807 < 0.754)

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Total Time Band

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(0.638 < 0.86322 < 0.988)

No unacceptable conditions were identified.

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4.

Facility Tours

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The inspector made several tours of the facility, including the control

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room, auxiliary building and containment building. During these tours the

inspector observed operations and activities in progress, implementation

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of radiological controls, and the general condition safety related equip-

ment.

In addition, the inspector examined the containment system bound-

artes, component tagging, and instrumentation to support the CILRT. During

these tours the inspector also observed licensee personnel checking for

evidence of leakage and verifying selected valves to be in the correct

position according to procedure requirements.

The inspector also checked

for leakages using the licensee ultrasonic leakage detector, the Ultra

Probe 2000. No unacceptable conditions were identified.

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5.

Independent Calculations

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The inspector performed independent calculations of the test results of

the CILRT and the subsequent verification test.

Details are included in

Section 3.7 of this report.

6.

QA/QC Involvement

During the performance of the ILRT the inspector verified QA involvement

in monitoring the test. When questioned, the QA personnel were knowledge-

able of their responsibilities on how to perform their duties and who to

report their findings to.

The inspector, however did observe that there

was no QA involvement to monitor the end of the test, the verification

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test or the depressurization of containment. This observation was brought

to the at.tention of licensee management.

7.

Exit Meeting

A meeting was held on June 7,1985 and on June 17, 1985 to discuss the

scope and findings of the inspection as delineated in this report. At

no time during this inspection was written information provided to the

licensee.

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ML20134E103

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