ML20154P671

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Insp Repts 50-324/88-16 & 50-325/88-16 on 880324-30.No Violations or Deviations Noted.Major Areas Inspected: Primary Containment Integrated Leak Rate Test (Cilrt),Review of Cilrt Procedure & Evaluation of Cilrt Results
ML20154P671
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 05/18/1988
From: Binoy Desai, Jape F, Whitener H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154P667 List:
References
50-324-88-16, 50-325-88-16, NUDOCS 8806060030
Download: ML20154P671 (10)


See also: IR 05000324/1988016

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UNITED STATES

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NUCLEAR HEGULATORY COMMISSION

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101 MARIETTA STREET, N.W.

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ATLANTA. GEORGI A 30323

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Report Nos.: 50-325/88-16 and 50-324/88-16

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Licensee:

Carolina Power and Light Company

P. O. Box 1551

Raleigh, NC 27602

Docket Nos.: 50-325 and 50-324

License Nos.:

DPR-71 and DPR-62

Facility Name:

Brunswick 1 and 2

Inspection Conducted:

March 24-30, 1988

Inspectors; M, /[ fl

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H. L. Whitener

Date Signed

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B. B. Deriti

Date Signed

Approved by:

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F. Japef ;(ction Chief

Date Signed

Engineering Branch

Division of Reactor Safety

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SUMMARY

Scope:

This rountine, announced inspection was in the areas of witnessing the

Unit 2 primary containment integrated leak rate test (CILRT), review of the

CILRT procedure, evaluation of the CILRT results, and review of the as-found

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leak rate for the primary containment,

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Results:

No violations or deviations were identified.

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8806060030 880520

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ADOCK 05000324

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

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  • M. S. Blinson, Senior ISI Specialist

C. R. Dietz, General Mana

  • E. R. Eckstein, Manager, ger-Technical Support
  • J. R. Holder, Outage Manager

M. T. Long, Engineering Technician

  • R. M.'Poulk, Compliance Project Specialist

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Other persons contacted included leak rate test personnel.

Other Organizations

United Energy Services Corporation

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  • R. Shirk, Leak Rate Test Engineer

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B. Black,

Leak Rate Test Specialist

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NRC Resident Inspector

  • W. Ruland, Senior Resident Inspector

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  • Attended exit interview

2.

Exit Interview

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The inspection scope and findings were summarized on March 30, 1988, with

those persons indicated in paragraph 1 above.

The inspectors described

the areas inspected and discussed in detail the inspection findings.

The

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inspector identified this test as a failed test.

With two failed-Type A

tests in succession, Unit 2 remaint on the accelerated Type A test

schedule.

No dissenting comments were received from the licensee.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.

3.

Licensee Action on Previous Enforcement Matters

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Thissubjectwasnotaddressedintheinspection.

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Unresolved Item

Unresolved items were not identified during this inspection.

5.

Containment Integrated Leak Rate Test - Unit 2 (70313, 70307)

The inspectors reviewed and witnessed test activities to determine that

the primary containment integrated leak rate test (CILRT) was performed in

accordance with the requirements of Appendix J to 10 CFR 50, ANSI-N45.4-

1972Property "ANSI code" (as page type) with input value "ANSI-N45.4-</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., test procedure PT-20.5, "Integrated Primary Containment Leak Rate

Test,,, the criteria of BN-TOP-1, Revision 1-1972, for a short duration

test, and ANSI /ANS 56.8 (exemption to Appendix J to allow Mass Point

analysis).

Selected sam31ing of the licensee's activities which were inspected

included:

(:.) review of test procedures to verify that the procedures

were properly approved and conformed with the regulatory requirements;

(2) observation of test performance to determine that test prerequisites

were completed, special equipment was installed, instrumentation was

calibrated and appropriate data were recorded; and (3) preliminary

evaluation of leakage rate test results to verify that leak rate limits

were met.

Pertinent aspects are discussed in the following paragraphs,

a.

General Observations

The inspectors witnessed and reviewed portions of'the test prepara-

tion, temperature stabilization, and data p'rocessing during the

period of March 24-30, 1988.

The inspectors observations included

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the following:

(1) The test was conducted in accordance with an approved procedure.

Procedure changes and test discrepancies were properly

documented in the procedure.

(2) Test prerequisites selected for review were found to be

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completed.

(3) Selected plant systems required to maintain test control were

found to be operational.

(4) Special test instrumentation was reviewed and found to be

installed and calibrated.

(5) Controls for preventing pressurized air sources inside

containment or externally pressurized penetrations were

established in the test procedure.

(6)

Instructions and documentation for venting, draining, and

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isolation of systems were established in the test procedure.

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(7) Problems encountered during the test were described in the test

event log.

(8) A containment temperature survey was performed to determine

representative locations of instruments..

(9) An in-situ check of CILRT instruments was performed prior to the

test.

(10) Selected procedure valve alignments reviewed against system

drawings to verify correct boundary alignment were adequate.

(11) Selected valve positions observed by the inspectors to verify

conformance to the procedure were adequate.

(12) Temperature, pressure, humidity, and flow data were recorded at

15-minute intervals.

Data were assembled and retained for final

evaluation and analysis by the licensee.

A final leak rate test

report will be submitted to the Office of Nuclear Reactor

Regulation pursuant to Paragraph V of Appendix J to 10 CFR 50.

b.

Procedure Review and Observations (70307) Units 1 and 2

Portions of PT 20.5, Revision 16, "Integrated Primary Containment

Leak Rate Test", dated March 15, 1988, were reviewed to verify that

test conditions, test controls, valve alignments and acceptance

criteria were specified.

The inspectors concluded that test

conditions and controls were specified in detail in the text; valve

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alignments and valve restoration were specified in detail in Table 2;

and system venting and draining was specified in Table 1.

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Permanent Revisions 15,16,17, and 18 to the test procedure were

reviewed.

These chan

(1) clarifying and improving

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test instructions, (2)ges related to:

implementing plant modifications and license

amendments, and (3) accommodating changes in associated support

procedures.

Tne inspectors concluded that these changes are within the

limitations of 10 CFR 50, Appendix J.

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A sample of valve alignments in the test procedure which establish

the test boundary were reviewed in detail against up to date plant

drawings to verify conformance with 10 CFR 50, Appendix, J.

The

valve alignments which were compared with plant drawings included the

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following plant systems:

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NSS System Isolation Valves

Page 42

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NSS System Boundary Valves

Page 43*

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Reactor Recirculation System

Page 44

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Isolation Valves

CAC System, Isolation

Page 45, 46

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Valves

CAC System Boundary Valves

Page 47, 48 *

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Containment Atmospheric

Page 49, 50*

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Monitoring System Isolation

Valves

RWCU System Isolation

Page 69

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Valves

RWCU System Boundary Valves

Page 69

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Instrument Air System Isolation

Page 70

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Valves

Instrument Air System Boundary

Page 70, 71, 72, 73*

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Valves

In the above table the page number refers to the pages in the

procedure where the system valve alignments are listed.

An asterisk

by the page numbers indicates verification of a portion of the valve

listing.

No valve misalignment!, were identified in this review.

In addition, the inspectors verified the position of selected valves

during a walkdown of the 52 ft. level of the drywell.

Based on the sample review, the inspectors concluded that valve

alignments conform to Appendix J requirements and the alignments were

adequately implemented,

c.

Containment Integrated Leak Rate Test (CILRT) Performance - Unit 2

(70313)

(1) Method

The integrated leak rate test was performed at the calculated

accident pressure (Pa) by the absolute test method. Acceptance

criteria were included in the test procedure for Mass Point,

Total Time and Short Duration testing in accordance with the

specifications of ANSI /ANS-56.8-1981, "Containment System

Leakage Testing Requirements"; ANSI-N45.4-1972, "Leakage-Rate

Testing of Containment Structures for Nuclear Reactors ; and,

BN-TOP-1, Revision 1-1972, "Testing Criteria for Integrated

Leakage Rate Testing of Primary Containment Structures for

Nuclear Power Plants ', respectively.

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The computer program for analysis of test data was provided by

United Energy Services Corporation.

The program included

capability for analysis of test data according to the Mass

Point, Total Time or Short Duration test methodologies.

The

test analysis was performed using the Mass Point Methodology.

The test duration was 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The licensee had obtained an exemption to 10 CFR 50, Appendix J

to allow the use of the Mass Point methodology.

The exemption,

Amendment No.144 to License No. DPR-62, was effective as of

February 17, 1988.

(2)-Description

Values bounding the test conditions were as follows:

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Containment Volume

294981 cubic feet

Accident Pressure (Pa)

49 psig % per day

Maximum Allowable Leakage (La)

0.5 wt.

System conditions for performance of the integrated leak rate

test were as follows:

Reactor Vessel

Vented to containment atmosphere:

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water level at about 235 inches.

RHR System

One loop operating in the shutdown

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cooling mode.

Containment Ventilation

Fans tripped:

No forced air flow.

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System

Containment Isolation

Vented, drained, and aligned per

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System

procedure PT 20.5

After the structural inspection, the containment was pressurized

to 65 psia.

The following table gives a brief description of

test events extracted from the test log book.

Date

Time

Event

3/25

1920

Started pressurization of the primary

containment.

3/26

0443

Secured pressurization of containment at 50.5

psig.

0500

Stabilization period started.

0900

Four hour stabilization completed.

Type A test

initiated.

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Date

Time

Event

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(cont'd)

3/26

1140

Leakage survey teams identified packing ) leakage

on valves E 11-F021 (air), CAC-V17 (air and

821-F0328 (water).

Leak rate still under

evaluation:

no repairs made-at this time.

1330

AdjustedRHRcoolingflow.

1630

Increased RHR flow.

2245

RHR loop B put into shutdown cooling mode.

Vessel level dropped about 4 inches.

3/27

0745

Terminated Type A test for the following

reasons:

1.

Over the previous 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> the leak

rate had tended to stabilize in the

range of 0.41 to 0.39 wt.% per day.

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Acceptance Ifmit is 0.375 wt.% per day.

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Reactor Vessel

water

level was

decreasing and approaching a LCO limit.

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Large

swings

in primary system

temperature appeared to be adversely

effecting the leakage rate since there

was no forced air flow.

1200

Reactor vessel water level raised to 235

inches, sumps pumped, RHR loop B returned to

ILRT line up, packing leaks on valves

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E11 F021A and CAC-V17 repaired.

Type A test

restarted.

2130

CAC neader was indicating 12 psig.

The

licensee decided to pressurize the header to

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quantify leakage through valve CAC-V4:

started pressurizing.

2335

CAC header at 44 psig:

started depres-

surizing.

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3/28

0145

CAC header depressurizad and left at 12

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Date

Time

Event

(cont'd)

3/28

1200

Type A test terminated.

Leak rate is 0.307

wt.% per day and UCL is 0.312 wt.% per day.

These values meet the acceptance limit.

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1215

Supplemental test initiated.

Imposed leak

rate is 4.4 scfh, uncorrected.

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Supplemental test terminated. Lc= 0.687 wt.%

per day.

d.

Test Analysis and Results

(1) Type A Test

The Technical Specification for Brunswick Unit 2 specifies the

allowable containment leakage rate as 0.5 wt.% per day of the

containment volume of 294981 cu. ft. at the calculated accident

pressure (Pa) of 49 psig.

Therefore the acceptance limit for

the integrated leak rate (Type A) test (0.75 La) is 0.375 wt.%

per day.

Analysis of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of data, from 1200, 3/27 to 1200, 3/28,

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wt %g the Mass Point methodology yeilds a leak rate of 0.3066

per day.

The calculated leak rate at the upper 95%

confidence limit (UCL) is 0.3123 wt.% per day.

The UCL was

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calculated according to the method of ANSI /ANS 56.8.

Based on

this method the Ty

0.75 La (0.375 wt..ye A test is within the acceptance Ifmit of

. day).

The inspectors calculated weighted averages for containment

temperature, pressure

and vapor pressure using the weighting

factors and individual sensor data for a sample of data sets

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to verify agreement with the weighted averages and mass

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calculations generated by the ifcensee's computer program.

Subsequently, the mass points generated by the licensee's

program were used by the inspectors to calculate the leak rate,

and the 95% upper confidence leak rate.

The inspectors'

calculations agreed with the licensee's calculations.

(2) Supplemental Test

Appendix J requires that a supplemental test be performed to

verify the accuracy of the Type A test and the ability of the

CILRT instrumentation to measure a change in leak rate.

An

acceptable supplemental test method is described in Appendix C

of ANSI-N45.4-1972, as follows:

A known leak rate (Lo) is imposed on the containment and

the measured composite leak rate (Lc) must equal, within f

0.25 La, the sum of the measured Type A leak rate (Lam)

plus the known leak rate (Lo).

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The acceptance criteria is expressed as:

Lo + Lam - 0.25 La < Le < Lo + Lam + 0.25 La

A four hour supplemental test was performed by the imposed leak

rate method described in Ap?endix C to ANSI-N45.4-1972. - The

following values in units of wt.%/ day were obtained using Mass

Point analysis.

Mass Point (wt.%/ day)

Lam

0.3066

Lo

0.4905

0.25 La

0.125

Lc

0.6868

Using these values in the acceptance criteria yields the

following:

0.6721 5 0.6868 5 0.9221

Le = 0.6868 satisfies the above inequality and therefore,

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supplemental test is acceptable.

The inspectors concluded that the "as left" containment leak rate

meets the Appendix J and Technical Specification 4.6. requirements.

6.

Status of Containment Leak Rate Testing

a.

Integrated Leak Rate Test - Unit 2

As discussed above, the licensee completed successful Type A and

supplemental tests starting at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> March 27, 1988.

Prior to

this time a Type A test was run from 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> March 26, to 0845

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hours March 27.

During this test the licensee experienced problems

in maintaining the reactor water' temperature constant.

With no

forced air flow, the changing heat source affected the stabilization

of the containment atmosphere.

However, the Mass Point leak rate

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appeared to stabilize in the range of 0.39 to 0.4 wt.% per day over

the last 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the test.

When the test was terminated at 0745

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hours on March 27 the Mass Point leak rate was 0.395 and the UCL was

0.398 wt.% per day.

While these leak rates are less than the

Technical Specification allowable leakage of La (0.5 wt % per day),

they do exceed the Appendix J Type A acceptance leak rate of 0.75 La

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(0.375 wt.% per day).

Prior to rettarting the Type A test the

licensee pumped out the sumps, raised tita reactor vessel water level

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and repaired packing leakage on two valves, 511-F021A and CAC-V17.

Since leakage repair was made in order to meet the Appendix J 1eak

rate acceptance limit, the inspectors identified this test as a

failed integrated leak rate test at the exit interview.

Unit 2

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remains on an accelerated test schedule requiring a Type A test at

each refueling outage until two Type A tests in succession are

performed successfully.

This matter was discussed with licensee

management at the exit interview.

b.

ocal Leak Rate Tests Unit 2 (61720) (70313)

The inspectors reviewed preliminary results of the Type.B and C tests

to determine if leakage repairs would result in a failed "as-found"

leakage.

Although preliminary, the summations indicated no extremaly

large penetration leak rates were identified except the drywell head

seal and feedwater Penetrations SA and 98 which could not be

pressurized.

Visual examination of the drywell head seals showed the

outer seal was damaged while the inner seal appeared intact.

The

licensee concluded that no significant leakage from the drywell would

have occurred due to the inner seal.

Analysis of the cause of the

outer seal failure is still in progress.

In Penetration 9A only one

valve (inside check valve F010A) was leaking severely.

The outboard

valve (F032A) leak rate was only 4 scfh.

In penetration 98, both

isolation valves were leaking severely and could not be pressurized.

This would exceed a leak rate of La by the minimum path leak rate

analysis and results in an "as found" leak rate which exceeds the

allowable limits of 0.75 La.

The inspectors concluded that the "as

found" leakage condition of the containment represents a failed test

according )to the requirements of 10 CFR 50, Appendix J, Paragraph

III.A.5.(b , and III.A.6.(b).

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