ML20195G007
| ML20195G007 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/26/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NT-87-0055, NT-87-55, TAC-65399, NUDOCS 8703030768 | |
| Download: ML20195G007 (9) | |
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EhCLOSURE 2 re e escrc mari 10CFR Part 2 Febrw.ry 26, 1947 Docket Nos. 50-348 50-364 U. 8. Nuclear Regulatory Opmed salon AT'IN: Document Ccotrol beek washington, D. C.
20555 Joseph M. Farley Nuclear Plant. Units 1 and 2 PEC Inspection.of November 7-14, 1986 RE: Report PAmber 50-348/86-25 This letter refers to the alleged violatico cited in the subje:t inspectico report which states:
"During the PAaclear neg21 story Commission 05C) i on conducted cm m:rmber 7-14, 1986, on sito and r 1-6, 1946, in the Region II OCliot, a vietation of let requirements was identified. The violation involved the failure to detarmine the "as is" containment integrated leak rate of the Urdt 1 primary ecotainment.
In accordance with the "General Statement of Policy and Procedure for Mpc Enforcement Actions,' 10CFR Port 2., Agpendix C (466), the violation is listed below:
Paragragt III.A.1(a) of A6pendix J to 10CTR50 and Paragraph 4.2 of AMBI-M45.4-1972, incorporated into the r ations by Paragraph III.A.3(a) of Appendix J to 1
, regaire that the Type A test shall be perfocaed prior to making any recnirs or adjustments to the containment boundary so that the '
(also called "as found") containment integrated leak n be detoruined.
Mwre repairs or adjustaants to the containment boundary prior to the Type A test are necessary, Paragraph III.A.1(a) in conjunction with Paragraph III.A.1(b) of Appendix J to 10CTR50 permit the repairr, or adjustments provided:
(1) the change in leakage rate resulting from such repairs or adjustments is "s,
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l C. s. melear Regulatory commission February 26, 1987 Page 2 i
' determined using local leakage testing methods; and (2) the corrective actim taken, the change in leakage rate detecnined frcm the local tests, and the 'as is" emtairseent integrated leakage rate determined frce the local leakage and Type A test results are obtained, and the results are included in the report j
to the Commission.
s contrary to the above, eating the IM6 mit 1 setes11as autmp, repairs or adjustments were made to the fuel transfer tube kind flange and emtrinnent building equipment hatch prior to the Type A test. The change in leakage rate resulting from these repairs or adjustments was not musured using local leakage test methods. Failure to quantify the change in leakage rate resulting from these r rs or adjustments to the containment boundary renders the culation of the "as is" containment integrated leakage rete indeterminsMe."
This is a Severity 1Avel IV Violation (Supplement I).*
Admission or Denial The MC 100tice of Violaticrr states thatt Repairs or adjustments not permitted by A;-vlix J were made a.
to various ccaponents prior to the Type A test; b.
The change in leakage rate resulting from the repeirs or I
adjustments ws not s.easured; and Failure to determine the change in leaka9e rate renders the c.
calculation of the "as is" contatrument integrated leakage i
rate indetsrminahle.
Pwer C:mpany categorically denies that alleged violation Alem 50-348/16-25-01 occurred. The basis of this denial is that while the events described in the alle9ed violation did occur, these actions, when viewed in the full ccetext of the re9ulation, were not in violatic.n of 10CFR$4, Appendix J.
Event Description and 10CrR50 Accendix J Provisions A description of the events which occurred and the provisions of 10CTR50, Appendix J, mder which these actions are permitted is provided belw:
10CTR50, Appendix J, paragraph III. A.1.(a) states "During the period betwusn the completion of one Type A test and the initiation of the catainment inspection for the subsequent Type A tests, repairs or adjustments shall be mode to compcoents whose leakage exceeds that specified in the Technical Specification as scen as practical after identification." The thit 1 seccod periodic integrated leakage rate
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U. 3. tuelear megulatory comunissian February 26, 1987 P9e 3 test (NRT)wascompletedonApril 14, 1984 and the centairument inspection for the third periosic m na initiated on nwomber 6, 1986. During this period, the fuel transfer tube and containment equipment hatch wre opened in October 1946 to accesumodate routine seveth refueling outage activities. Their opening and suboegaent closing did not constitute 'regairs or 6.W 2e."
Fnirther, even if the and clos were construed to be '
rs er adjustments
- eeen se eering the ported ty Appendix J prior to initiatise of the containment imagestaan for the ILRT.
Since the opening of these components la essential for refueling outage cperations and in an effort to ensure that the integrity of these wwits was restored 'as soon as practical after identification", local leakage rete tests were performed following reinstallation of the sealing c+4nts and prior to perforssoce of the IIJtt.
Provisiens of paragraph III permit necessary repairs or adjustments as stated in I!!.A.1.(a); 'If during a Type A test... potentially excessive leaka paths are identifioW... or which result in the Type A test rot see the acceptance criteria..uthe Tyse A test shall be terminated and leakage through such paths shall be measured using local leakage testing methods. Repairs and/or adjustments to equipent shall be made and a Type A test performed.
Ihe correcti w action taken and change in leakage rate determined from the... local leak and Type A tests shall be included in the report to the Commission..." As stated above, removal of the equipment hatch and tval transfer tube covers occurred prior to the initiation of the containment inspection and wre therefore not performed "Aring a Type A test." since the work performed on these s
-ts did not occur 'Aring the Type A test' and thus did not ce terstantion of the A test 9er performing repairs or adjustments, no correctiw ans wre regaired and therefore there is ac *shenge in leakage rete detssutmed from the
... local leak test" to be reported.
Performance of routine local leakage rate tests follo<ing cwor installation is not considered corrective action.
Paragra6h !!!.A.1(b) states that
- Repairs of maloperating or leaking valves shall be made as necessary. Information on any valw closure malfunction or valw leakage that requires correctin action betece the test shall be included la the report submitted to the Commission." This paragraph specifically addresses valves which are subject to Type C testing and is therefore not applicable to the 'r pair or adjustment" of the equissment hatch or fuel transfer tube which are subject to Type a testing, slnce their design incorporates resilient seals.
With regard to ANSI N45.4-1972, paragraph 4.2 states tht "For retesting, an initial record proof test shall be conducted... before preparatory repairs are made." tile these provisions e.re somewhat iguous, the implication is that an initial record proof test should be performed during construction to establish and document a baseliv leakage rate value.
Following this initial record proof test and establishment of the baseline leakage value, "local and integral tests kU*
g U. 8. Welear Replatcry Commission Pcbruary 26,198; Page 4 may be performed and ary necessary work done to brine the leakage rate within the specified limits."
Therefore, it seems tiet these requirements are applicable only to certain actions repired as a part of the initial contairment rational tests and are not intended to be applied to subsequent peri e laakage rate tests pertocasd ineetvies.
Iristi,eleal Review of Licensine issues A historical review of issues and policies is required to fully understand the Alabama Power company position on the "as found containment IIJe issue.
In 1971, a proposed A detailed reporting r=ppendix J issued for public comment contained 45 proposed rule stated tht:
3 and directlen for leakage repair. The If leak repairs of testable ccuponents are performed prior to the conduct of the Type A test, the re<hetion in leakege shall be measured and added to tho' Type A test result.
If.this asasured reduction in leakage exceeds the acceptance criteria of section III.A.7., this information shall be included in the report submitted to the Commission as required by section V.B. (36 Ped.-
Reg. 17053, 17054 (August 27, 1971)1 This proposed provision was deleted in the final rule.
leo explanation of this deletion was prwided in any documents or tranacripts associated with this rulemaking evetlable in the pslic record, leevertheless, it is fair to conclude that the Commission, in deleting the provision, rejected it as a binding part of the regulation.
In 1977, Parley m: lear Plant, Unit 1 was licensed.
The Safety Evaluation Deport, Joseph M. Parley leuclear Plant, Units 1 and 2, M.mzG-15M34, states, in part, 'The preposed coactor contairment leakage testing program coglios with the requirements of A6pendia J to 10Crt Part 50... Based on our review of the applicant's proposed testing program described in the PSAR, we have concluded tatt it meets the i
requirements of Appendia J and General Design criteria loos. 52, 53, and 54 of Appendix A to 10CFR Part 50 and is acceptable." MJRaG-0117, Supplement 300. 4 to it.asG-75M34, states, in part.
6.2.5 _ Containment 14akage Testing Program I
We have reviewec the applicant's contairment leak testing program as presented in section 6.2 of the Final safety Analysis Report, as amended through Ameruksent 72, for ccq11ance with the containment
'i leakage testing requirements specified in Appendix 3 to 10CFR Part 50, "Primary menctor containment 14akage 14 sting for Water-cooled 3
P M r Reactorr.*
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Compli mce with Appendix J provides adequate assurance that containment integrity can be verified throughout the service lifetime and that leakage rates will be periodically b
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U. 8. Welear Regulotary Ccussission rcbruary 26, 1947 u
Page 5 checked &tring service on a timely basis to maintala leakaya within the specified limits. Maintaining c atainment leakage within specified limits provides reasonable assurance that, in the event of a radioactivity release within the contalmeent, the less et containment atmoghere through leak the limits specined for the site... paths will not be in excess of Addit'onal staff effert on containment leak testing that will Inad to a revisim of Appendix J is being done in conjunction with the Of fice of Standards Development. The revised Appendix J vill be applicable to all plants depending on their licensing status and desi p.
The containment ItJtT program ms dmloped &lring inal phases of
- >1 ant cenoteestion. It has been utillsos for seal toets en mth units and for the three inservice tests conducted en thit 1 and the one inservice test conducted m thit 2 to date.
The results of these tests have been within the acceptance criteria and the program has been reviewd by the WC Staff.
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In a January 11, 1962 WC memorandum, respmding to a regaest for clarificatim of the provisions to 10CTR Part 50, Appendix J by J. H.
Sni6zak, R. Mattson indicated that if repairs or adjustaants were made, as a result of type B and C testing programs, or other reasons, to the prur,ary containeerit beurdary prior to the Type A test sequence, leakage rates before and after the repair and adjustments must be determined.
The adjustments would then be added to the measured Type A test results to deteraine the 'as found* type A teet results.
This menorandum, in essence, imposed a new WC Staff position interpretattom of A6pendit J fren the staff position een the Parley Muclear Plant Safety 27aluations (SER) were written.
to in Supplement 4 to the Mit.Pcesibly, the mow Staff position is the one alluded During an August 6,1962 mc Inspection Exit Conference, E. Brecks of the MtC requested that "before and after" leakage test recults be included in future test reports in order to evaluate apparent potential containment degradatica.
In an August 12, 1962 telephone conversation, the rarley helear Plant Staff agreed to report as-found leakages as part of the Type A Test Report.
on August 12, 1945, It Infocmation mtice No. 85-71, "containment Integrated I4ak Rate Tests,' ws issued. The It Hotice, in essence, pressalgated the WC Staff position contained in the January 11,1982 NRC memorardum to all utilities.
Bowever, it should be noted that the It Informatim Notice itself states that this is a suggestim and does not constitute an NRC reg 11rement.
On October 29, 1966, the WC proposed an amerdment to 10CFR50 Appendix J which would update the criteria and clarify questions of interpretatien in regards to leakage rate testing. Reporting of "as-found" and "as-lef t" leakage rates and an 'as-found* acceptanct criteria were included in the proposed amerdment,
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- v. s. melear neplatory comatulan F;bruary 26, 1987 Fage 6 Based m a Novesdner 1966 site lac inspection by R. L. Whitener and subsequent telephone conversations, Farley Welear Plant was cited with a Notice of Violation en January 26, IM7.
Based on this historicel review, several important aspects of the leakage rate issue become evident.
a) la 1971, tins IRC and then deleted W
Aggendix J 41 4 have regstred dote on
'te-feuser ans 'as-left' leakage rates if repairs were conbetad prior to the Type A test. The Type A test results would have been adjusted based on these results, b) Between 1971 and IM2, the NRC reviewed the Parley helear Plant tas program and stated it was acceptable on c) The RC Staff positien apparently chan9ed in 1982 rest,1 ting in the issuance of It Information Notice 85-71, eseequent letc Inspector re ultimately, quests for "as-found" leakage rates, and, a proposed amendment to 14Cft50,.4ppendix J.
Definition of Adjustments and Repairs rinally, Alema Power Ccapany does not consider that the renoval and subsequent reinstallation of the fuel transfer tube blind flange or equipaent hate cover constitutes a repair or adjustaent. These activities are performed in accordance with proce& ires dich delineete
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4 the steps required to properly install the covers and thstr bolting and to define the torpe values necessary to ensure that the reinstallation is adequate to provide activities are mandlar % id. integrity.
In principle, these to the mee of actor operators e ensure j
the leak tightases of contairment isolatim valves die are i
typically regalred to apen and reclose ramerous times between scheduled local and/or integrated leek rate tests. Wwre ade for either marmi actions controlled by procedure, quate centrols exist or automatic
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predeteruined valve seating actions performed by motor operaters, the assurance of leak tight integrity is provided without performing additional leak rate tests after sech cycle.
It should be noted that the replocement of the seals on the fuel transfer tube blind flange was performed as a matter of routine good erking practice and camot be considered a repair or corrective action taken as the result of any identified or suspected excessive leakage.
the 3riginal equipment hatch seals were reused and the resulting post-installation leak rate test results were well within the acceptance criteria. A&$itionally, there is no reason for the blind flange type penetraticos to degrade doe to the following.
a) The penetrations are not under pressure during the cycle.
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February 26, 1987 w
l Page 7 b)~ The penetrations are not disturbed once they are leak tested.
c) the seals for the equipment hatch are thoc y inspected betere re-use. If any signs of degradation to wear are l
roted during the refueling cutage, the seals are replaced.
d) Wie seals See the Smet transfer tube hiand M are renewed each outage.
e) the p nt hatch and the fuel transfer tube blind flange have de *o" ring type seals which would roeptire both *o" rings to fall before leakage could occur through the l
Suma ry In summary, Alabama Power Ccapany did perform the actions stated in the alleged violation but did no in complete coeliance Mth the requirements of 10CrR$0 Aspendix J and Net R5.4-1972 as referenced therein. The actions taken are not considered to constitute repairs or adjustments which are prohibited by the subject r ation and standard vithin the time frames defined therein. As a t, Alabama Powr Corepany considers the 11JtT report submitted to the letC by letter dated February 9,1947 to be ccuplete with respect to the reportlag of corrective actions. The leakage rate test results cited in this report were obtained by Mcdorming the tests in Mrict with the regulations and sh ndards and are well within the criteria.
Based on the historiani review of the leakage rata tesse and a review of 10 Crit 50 2 J. 11aha== Power that there is currently no to detsemise
- for repairs or adjustments between a Type A test start af the j
containment inopoeties foc the mest Type A test.
detetskestion is rted by the proposed amendment to 10C7R50 J dtich would i
ude this re Although a verbal temat. ma gde during the August 12, quiremmet.
1962 telephone conversation, it is not the basis of the i
Hotice of Violation. Therefore Alabama Power Congesy den 6es that it violated the requirements of 10CFR50 Appendix J because the stated requirements are not part of iterR50, Appendiz J, het are instead a new staff position developed in 1942. Therefore, in the absence of any re9ulation or standarB which regaired the adjustment of integrated leakage rate te=t results using local leakage rate tests data (taken before the start of or following completion of the IIJtr), the IIM values stater. are fully determinable and are considered accurate within the limits specified in the requirements and within the limits achievable using accepted in&astry practices and @y %.
tven though Ale=== Power Company does not believe that 10CrR50 Appendix J requires "as-found" testing as stated in the Notice of violation, we understand the (*r==ission's positice on this issue and the plant staff l
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U. S. telear hogalatory comadesien rebruary 26, 1987 Page 8 has made substantial efforts to perform local leaka accordance with wrbal requests frce the WC 8taff.ge sets testing in Alabama Power company will continue a good faith effort to coopesges Wth the Commission in obtaining the test data in accordance utth regaests from the staf f.
As stated in the cesusission's heport mambers 50-HSA2-21 and 50-36012-20 dated t/ Nut 2, Alabama power casessy agemed to report as-famd leakage as part of the red Type A Smet
. As commitment p made to ad t the A In tad
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Leset
'this is consistent with the requirerents of 1 Aspeedia J paragraph v.s.3.
Reascm for violation Please refer to the discussion under M issien or Denial' 7
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,x w.n Doe to the reasons stated above it is believed that the penetrations in questico had not degraded and that no corrective action is required.
Corrective ' steps taken to Avoid rurther'vio atTan' Not applicable.
Date of Full Ccepliance Not 4;pliemble.
Affiraatico I affirm that this response is true and lete to tha t of my kncwledpe, information, and belief, me tien.
An this letter :,s not considered to be of a proprietary naturt.
'me sutnittal due date for this letter was verbally deferred until
'nuroday, Febcuary 26,1M7 kg Mr. Luis moyes in a conversation with Mr. R. P. Mcdonald en February 24,1 If there are any questions, please advise.
Respectfully submitted, N 70 7
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R. P. Mcdonald RPtWttd.:ds t-T. S. 7 Attachments cc: Mr. L. B. Lcog Mr. E. A.
s Mr. N. H. Bradford i
a ENCLOSURE 3 NRC POSITION STATEMENT The proposed rule as issued in Federal Register, Volume 36, No.167 -
August 27, 1971; the statement of consideration and the rule as issued in Federal Register, Volume 38, No. 30 - February 14, 1973; and, ANSI-N45.4 - 1972 i
require the "as is" (also called "as found") overall containment leak rate measurement.
This position is further amplified by the statements in para-
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graph III.A.1 (a) of Appendix J and paragraph 4.2 of ANSI-N45.4.
Para-graph III.A.1.(a) requires that "during the period t>etween the initiation of the containment inspection and 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 "as is" condition as practical."
The requirement stated that in this sentence is to determine the leak rate for the "as is" containment condition.
The fact that no repairs or adjustments shall be allowed during the time from the containment inspection until the Type A test is performed, which is that period of time when the containment is pressurized and air leakage paths can j
be identified, supports this requirements.
This limitation in no way implies that at any time before the containment inspection, changes to the "as is" containment leakage condition can be made without determining the effect of i
these changes on the "as is" containment leak rate.
If repairs cr adjustments are made without the "as-is" measurement, containment integrity cannot be accurately assessed.
ANSI-N45.4 requires that no repairs shall be made prior to the Type A test.
The position is also reiterated in the Statement of Consideration issued with the rule which identifies that the proposed rule was modified to specifically require reporting of reduction in leakage to enable to AEC to detennine if the allowable leakage would have been excteded in the event of an accident.
Our position is also consistent with the NRR clarification of the regulation issued in a memorandum, Mattson to Sniezek, dated January 11, 1982, and in IE Notice 85-71, issued to all licensees August 22, 1985, to inform them that they may be incorrectly interpreting the regulation.
The violation was issued for the failure to demonstrate the leakage change as a result of manipulating components prior to the Type A test which have the potential for leakage through large sealing surfaces (see paragraph II.E. and II.F of Appendix J).
The licensee implies that there is a functional difference in the equipment hatch and fuel trans fer tube flange penetrations from a normai valve penetration, and suggests that manipulation of these components is not rightly 4
considered as repairs and adjustn.ents.
A five point argument as to why no i
leakage through these barriers would be expected is presented.
RIl believes that a potential for leakage always exists when large sealing surfaces are disturbed.
Knowledge of leakage conditions by actual measurement is prefera-j ble.
Assumed leakage values based on engineering evaluations, may be an acceptable alternate where significant considerations such as high radiation exposure or excessive costs are involved.
In this case neither was submitted.
RII, therefore, concludes that the violation as issued is valid and we request your support in this position.
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