ML20137W225
| ML20137W225 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/02/1985 |
| From: | Cline W, Gloersen W, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137W136 | List: |
| References | |
| 50-369-85-39, 50-370-85-40, NUDOCS 8512100203 | |
| Download: ML20137W225 (9) | |
See also: IR 05000369/1985039
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.W.
ATLANTA, GEORG! A 30323
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DEC 0 41985
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Report Nos.:
50-369/85-39 and 50-370/85-40
Licensee:
Duke Power Company
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422' South Church Street
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Charlotte, NC 28242
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Docket Nos.:
50-369 and 50-370
License Nos.:
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Facility Name: McGuire 1 and 2
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Inspection Conducted: October 15 - November 8, 1985
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Inspectors:
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G.
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Date Signea
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Date Signed
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. Approved by:
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W. E. Cl}fef Seciion Ckfef
Date Sigr.ed
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Emergency Preparedness and Radiological
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Protection Branch
-Division of Radiation Safety and Safeguards
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SUMMARY
Scope: -This special announced inspection involved 85 inspector-hours in the
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areas of preoperational testing _ n.
adequacy of surveillance activities
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regarding control room and auxiliary building ventilation systems.
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Results:
One deviation was identified - failure to complete preoperational
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testing of the Control Room Area Ventilation (CV) system in accordance with FSAR
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commitments.
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8512100203 851204
DP
ADOCK 05000369
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R.
L. Gill, Licensing
- D. J. Rains, Superintendent of Maintenance
- B. H. Hamilton, Superintendent of Technical Services
- M. Sample, Superintendent of Integrated Scheduling
- R. A. Johansen, Test Engineer, Surveillance
- D. S. Marquis, Performance Engineer
- N. McCraw, Compliance Engineer
- P. Roberson, Associate Engineer, Performance
Other licensee employees contacted included technicians, and office
personnel.
- Attended exit interview October 17, 1985
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- Attended exit interview October 17, 1985, and November 6, 1985
2.
Exit Interview
The inspection scope and findings were summarized on October 17, 1985, with
those persons indicated in Paragraph 1 above. The inspectors discussed the
need for _ evaluation of preoperational filter system testing of the auxiliary
building ventilation system (Paragraph 5) to ensure adequacy of Technical
Specification (TS) surveillance requirements to demonstrate operability.
The inspectors informed licensee representatives that the status of
preoperational testing of the control room area veinti'.ation system would be
considered an unresolved item subsequent to revius of all testing and
engineering evaluation records by cognizant NRC management.
Licensee
representatives acknowledged the inspectors' comments. On November 6, 1985,
the inspectors informed licensee representatives that the unresolved item
concerning failure to conduct a proper air-aerosol uniformity mixing test
for the control room area ventilation system as detailed in the FSAR was a
deviation (Paragraph 5).
Licensee representatives acknowledged the
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inspectors' comments and did not identify as proprietary any of the material
provided to or reviewed by the inspectors during this inspection.
-3.
Licensee Action on Previous Enfcrcement Matters
(0 pen) Deviation 50-369/85-30-02 & 50-370/85-32-01: VA Filter Testing not
performed per the FSAR and Regulatory Guide 1.52.
This item will remain
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open subsequent to receipt of formal response from licensee.
(Closed) 50-370/85-30-03 & 50-370/85-32-02:
VA Filter Testing Adequacy.
Following review of data provided from supplemental filter testing of the
Unit 1 & 2 VA systems (Paragraph 8.a), the VA system was deemed adequate to
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perform its intended function and surveillance activities were deemed
acceptable to demonstrate system operaoility as specified by Technical
Specifications.
4.
Unresolved Items
Unresolved items were not identified during the inspection.
5.
Filter Testing (92702)
a.
The
inspectors
reviewed
Unresolved
Item
(50-369/85-30-03,
50-370/85-32-02) concerning preoperational nuclear air-cleaning filter
testing for the Auxiliary Building Filtered Exhaust Systems (VA). The
inspectors noted that the Unit 1 VA system failed the Air Distribution
Test and testing was not conducted for the Unit 2 system as described
in Section 8.3.2 of ANSI N510-1975, Testing of Nuclear Air-Cleaning
Systems. Section 9.4.2.3 of the McGuire Nuclear Plant FSAR detailed
in place testing of the VA systems to be in compliance with Regulatory
Guide 1.52, Design, Testing, and Maintenance Criteria for Post-Accident
Engineered Safety Feature Atmosphere Cleanup System Air Filtration and
Adsorption Units of Light Water Cooled Nuclear Power Plants.
Furthermore, Regulatory Guide 1.52 obligated the licensee to ANSI
N510-1975.
The inspectors reviewed preoperational test procedure TP/0/A/1450/02,
Preoperational Filter Test for Auxiliary Building Filtered Exhaust
Trains 1 & 2, dated 1/27/81, and noted that airflow distribution tests
were not within the
20% of the average velocity for the Unit 1 system
as required by ANSI N510-1975.
Furthermore the inspectors noted that
airflow distribution tests had not been conducted for the Unit 2 VA
system.
The licensee responded to this air distribution test failure
by contracting a vendor to perform an engineering evaluation of the VA
system.
The evaluation consisted of a laboratory study of HEPA filter
efficiency as a function of air velocity. The inspectors reviewed the
laboratory test results and noted that the completed tests did verify
HEPA filter efficiency but did not evaluate the adequacy of the airflow
distribution as required.
The inspectors informed cognizant licensee
representatives that the laboratory study did not meet
the
preoperational air distribution test requirement of Section 8.3.2 of
ANSI N510-1975.
In addition the inspectors noted that this air
distribution test was a prerequisite for in place leak testing of the
installed system required by Technical Specification 4.7.7.b
to
demonstrate operability.
The inspectors discussed with cognizant licensee representatives the
revised ANSI N510-1980 and its guidance on performing the air
distribution test.
Differences between the 1980 Standard relative to
the 1975 Standard for conducting the air distribution test are:
(1)
velocity measurements are preferably made downstream of the HEPA
filters to improve air flow distribution entering the charcoal absorber
beds;
(2)
for filter banks containing ten or more filters, the
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minimum number of velocity measurements will be one in the center of
each filter;
and (3)
for systems containing fewer than ten HEPA
filters in a single bank, the minimum number of velocity measurements
will be ten and will include one reading in the center of each filter
in the bank.
Following telephone discussions among NRC Region II,
Office of Nuclear Reactor Regulation, and cognizant licensee
representatives a Confirmation of Action Letter (CAL) detailing use of
ANSI N510-1980 for evaluation of air distribution in the VA systems was
issued (Paragraph 6).
b.
In addition, the inspectors reviewed the preoperational filter testing
for the following systems:
Annulus Ventilation, Containment Purge,
Spent Fuel Pool, and Control Room Area. For all systems, excluding the
Control Room Area Ventilation (CV), the required preoperational tests
were conducted in accordance with ANSI N510-1975.
c.
From review of TP/1/A/1450/01, Preoperational Filter Test for Control
Area Outside Pressure Train 1 & 2, dated 1/19/81, the inspectors noted
that both the air distribution and the air-aerosal mixing uniformity
tests as described in Sections 8 and 9 of ANSI N510-1975 were deleted
from the procedure.
Licensee representatives informed the inspectors
that a thorough search was in progress to determine the status of
completion
and/or
if
any
engineering
evaluations
regarding
preoperational testing of the CV system was conducted. Following
discussion between NRC and cognizant licensee representatives, a CAL
requesting verification of completion of all prerequisite tests
pursuant to ANSI 510-1975 for the CV system (Paragraph 6) was issued.
In a letter dated October 29, 1985 to NRC Region II, licensee
representatives stated that the CV systems contain only one HEPA filter
and the air distribution test was deemed unnecessary.
Cognizant NRC
Region II and NRR personnel concurred with this interpretation for
elimination of the air distribution test.
However, the inspectors
informed licensee representatives that valid in place testing of the
Control Room Area Ventilation system would not be pcssible without a
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uniform air-aerosol tracer-air mixture.
In their response dated
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October 29, 1985, cognizant licensee representatives deemed the
air-aerosol mixing uniformity test unnecessary based upon the updated
ANSI
N510-1980
standard.
The
inspectors
informed
licensee
representatives that Sections 6.4.3 and Table 6.2.3.-4 of the FSAR
stipulated that in place testing of the Control Room Area Ventilation
(CV) Systems was in compliance with Regulatory Guide 1.52 (Revision 2,
March 1978) which in turn obligated the licensee to ANSI N510-1975.
Furthermore, the inspectors informed licensee representativcs that
Section 9 of ANSI N510-1975 Air-aerosol Mixing Uniformity Test is
required and considered a prerequisite for required surveillancs tests
described by Technical Specifications. In view of the above findings,
the
inspectors
informed
licensee
representatives
that
the
preoperational tests performed on the CV systems were not performed as
documented in the FSAR and .would be considered a deviation to
documented FSAR commitments (50-369/85-39-01, 370/85-40-01).
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One deviation was identified - failure to conduct preoperational testing of
the CV system as committed to in the FSAR.
6.
Confirmation of Action Letters (92702)
After discussion and review of the VA and CV systems preoperational filter
testing records among NRC and licensee representatives, the following
Confirmation of Action Items were issued:
a.
During a telephone conversation on October 22, 1985 between NRC
Region II
management and Duke
Power Company
General
Office
representatives, the following Confirmation of Action items were
discussed:
Conduct air flow distribution tests for the auxiliary building
ventilation filter systems and submit written test results to the
Regional Office by October. 28, 1985.
These tests will be
conducted in accordance with ANSI N510-1980, unless other criteria
are established with the Office of Nuclear Reactor Regulation.
If acceptance criteria for the air flow distribution tests are not
met, provide an analysis cf the adequacy of the systems capability
to meet the design function including the appropriateness of the
surveillance program.
This analysis will be provided to the NRC
by October 29, 1985.
Review past test records to verify that all prerequisite tests
pursuant to ANSI N510-1975 for the control room ventilation system
have been conducted.
Advise NRC by October 29, 1985, of the
results of this review.
Licensee representatives concurred with the action items and a
Confirmation of Action Letter was transmitted to the licensee on
October 23, 1985.
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b.
During a telephone conversation between cognizant NRC and Duke Power
Company representatives on November 1,1985, additional action items
regarding the CV systems were discussed.
Following the discussion,
licensee representatives agreed to conduct the air-aerosol mixing
uniformity test for the CV filter systems by , November- 8,
1985, in
accordance with ANSI N510-1975. A CAL to the licensee regarding this
item was issued November 5, 1985.
Two Confirmation of Action Letters were issued during this inspection.
7.
Procedures, Records and Engineering Evaluations (92702)
The inspectors reviewed selected procedures, records, and engineering
evaluations applicable to determination of the adequacy of preoperational
in place filter testing for plant ventilation systems.
The procedures,
records and evaluations reviewed are as follow:
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(1) TP/1/A/1450/01 Preoperational Filter Test for Control Area Outside Air
Pressure Filter Trains 1 & 2, 11/12/80 - 1/15/81.
(2) TP/2/A/1450/23 Containment Air Release and Addi. tion Ventilation System.
Filter Train Acceptance Test, 2/28/83.
(3) TP/1/A/1450/18 Preoperational Filter Test for Spent Fuel Ventilation
' Exhaust Filter Train, 11/3/80 - 12/30/80.
(4) TP/0/A/1450/19 Annulus Ventilation System Filter Train Acceptance Test
3/4/83 - 4/15/83.
(5) PT/0/A/4450/01 In-Place Test of HEPA and Carbon Absorber Filters,
8/17/81
(6) PT/0/A/4450/17 Safety Related Filter System Run Time 4/30/84.
(7) MP/0/A/7450/09 CVI Charcoal Filter Removal and Replacement, Rev. 2,
1/29/85
(8) TT/0/A/9100/104 Air / Aerosol Mixing Uniformity Test for 0APFTs 1 & 2,
11/6/85
(9) TT/1/A/9100/101A Auxiliary Building Ventilation System Air Flow
Distribution Measurements I, 10/23/85.
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(10) TT/1/A/9100/1018 Auxiliary Building Ventilation System Air Flow
Distribution Measurements II, 10/23/85.
(11) TP/0/A/1450/02 Preoperational Filter Test for Auxiliary Building
Filtered Exhaust Trains 1 & 2, 11/3/80-1/24/81.
.(12) Memo to File MC-1211.00-14 Supplemental Testing of High Efficiency Air
Filter Elements,1/27/81
(13) Auxiliary Building Ventilation System Engineering Evaluation of
Supplemental Filter Testing, Letter to Mr. H. R. Denton, Director,
Office of Nuclear Reactor Regulation from Mr. H.
B.
Tucker, Vice
President Nuclear Production, Duke Power 'Com'pany dated October 28,
1985.
(14) Letter to Dr. J. N. Grace, Regional Administrator, US NRC Region II
from H. B. Tucker, Vice President Nuclear Production dated October 29,
1985.
No violations or deviations were identified.
8.
Review of Filter Testing Results (92702)
The inspectors reviewed and discussed selected ventilation system test data
as noted in the following paragraphs,
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a.
Auxiliary Building Filtered Exhaust Trains
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Licensee representatives conducted velocity distribution measurements
for the auxiliary building ventilation systems on October 25-26, 1985.
Velocity measurements were conducted at the following ventilation
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system component areas:
prefilter-upstream, HEPA filter-downstream,
and charcoal absorber bed-upstream. A summary of the results for the
VA systems for both units is presented in Table 1.
-Velocity
measurements were slightly outside of the established ANSI N510-1980
guidelines of
20% deviation from the mean value at the HEPA filter
exit for both units. However, following review and evaluation of the
individual flow distribution measurements at both the HEPA exit (-29 to
+26%) and carbon absorber bed ' inlet areas (-9 to +12%) by cognizant
NRC-NRR and Region II personnel, the air flow distribution was deemed
adequate for the VA system to meet its intended function and all
surveillance test results as required by Technical Specification were
deemed acceptable.
b.
Control Room Area Ventilation (CV) Air-aerosol Mixing Uniformity
Testing
On November 6-7, 1985, licensee representatives completed air-aerosol
mixing uniformity testing for the CV systems. A Region II inspector
observed and verified that testing was conducted in accordance with
ANSI N510-1975. Results of the tests for both ventilation systems were
within the acceptance criteria of
10% deviation from the mean value
as specified in the standard. A summary of the results far the two
filter systems _is presented in Table 2.
No violations or deviations were identified.
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TABLE 1
Summary of Supplemental Auxiliary Building Ventilation (VA) Air Distribution
Tests for McGuire Nuclear Plant October 1985.
(% Deviaiton From Mean Value)
HEPA Downstream
Charcoal Bed Entrance-Upstream
(% Deviation)
(% Deviation)
Unit 1
-29 to +23
-9 to +12
Unit 2
-22.0 to +26.0
-7 to +9
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TABLE 2
Summary of Air-Aerosol Mixing Uniformity Tests (% Deviaiton From Mean Value)for
the Control Room Area Ventilation (CV) System at McGuire Nuclear Plant
November 1985
Upstream
Downstream
(%' Deviation)
(% Deviation)
Unit 1
-4.66 to 5.7
-8.05 to 9.20
-Unit 2-
-8,55 to 9.93
-7.09 to 7.58
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