ML20205A496

Insp Repts 50-369/86-16 & 50-370/86-16 on 860609-13. Violation Noted:Failure to Determine as-found Leak Rate for Unit 2 Primary Containment

ML20205A496
Person / Time
Site:	Mcguire, McGuire
Issue date:	07/31/1986
From:	Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205A477	List: ML20205A473 ML20205A486 ML20205A496
References
50-369-86-16, 50-370-86-16, NUDOCS 8608110385
Download: ML20205A496 (7)

See also: IR 05000369/1986016

Text

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NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-369/86-16 and 50-370/86-16

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Licensee: Duke Power Company

422 South Church Street

Charlotte, NC 28242

Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and NPF-17

Facility Name: McGuire 1 and 2

Inspection Conducted: June 9-13, 1986

Inspector: N I. /Md e 7 ' #/ ' f6

H.' L. Whitener Date Signed

Approved by:

F. Jape, STction Chief

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Date Signed

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection was conducted in the areas of

primary containment integrated and local leak rate testing.

Results: One violation was identified - Failure to determine the as-found leak

rate for the Unit 2 primary containment, paragraph 7.

8608110385 860805

PDR ADOCK 05000369

G PDR

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REPORT DETAILS

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1. Persons Contacted

Licensee Employees

• T. McConnell, Station Manager

• W. Suslick, Performance, General Office

• R. Johansen, Performance

P. Roberson, Performance Engineer

• D. Smith, Performance Engineer

• N. McCraw, Compliance Engineer

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NRC Resident Inspector

W. Orders, Senior Resident Operator

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• Attended exit interview

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2. Exit Interview

The inspection scope and findings were summarized on June 13, 1986, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings. The

licensee requested an opportunity to discuss the issues with Region II

management subsequent to the Region review of the inspection findings.

This discussion was held via telephone on July 29, 1986.

New items identified during the inspection include:

Violation 370/86-16-01: Failure to obtain the as-found leak rate for

the Unit 2 primary containment, paragraph 7.

Inspector Followup Item 370/86-16-02: Review the results of the

licensee's examination of isolation valve maintenance to determine the

" pass" or " fail" status of the Unit 2 as-found containment leakage,

paragraph 7.a.

Inspector Followup Item 369/86-16-01: Review the procedures

established to track and control determination of the as-found leak

rate, paragraph 7.b.

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

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to or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

i This subject was not addressed in the inspection.

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4. Unresolved Items

Unresolved items were not identified during the inspection.

5. Containment Integrated Leak Rate - Unit 2

A 24-hour containment' integrated (Type A) leak rate test and a four hour

supplemental leak rate test were performed on the Unit 2 primary containment

in the period May 25-26, 1986. Mass point-linear regression analysis was

used by the licensee to determine the leak rate (Lam) and upper confidence

limit (UCL) at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The test met the acceptance criteria for both mass

point and total time analysie. as shown below; the values are expressed as

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weight percent per day.

Mass Point Total Time

wt%/ day wt%/ day

La 0.3 0.3 (allowable leakage)

0.75 La 0.225 0.225 (test acceptance limit)

Lam at 24 hrs. 0.0785 0.0758

UCL at 24 hrs. 0.0833 0.095

A four hour supplemental test was performed -in accordance with the

recommendations of Appendix C of ANSI N45.4-1972. The measured composite

leak rate was within the upper and lower acceptance limits specified by the

equation:

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Lam + Lo - 0.25 La < Lc < Lam + Lo + 0.25 La for the mass point analysis.

The values for the equation by mass point analysis in terms of weight

percent per day are as follows:

'wt%/

day

Composite leak rate, Lc 0.385

Type A test leak rate, Lam 0.0785

Imposed leak rate, Lo 0.241

Error limit, 0.25 La 0.075

Substitution of these values into the acceptance equation demonstrate that

the specified inequalities are satisfied as follows:

0.2445 < 0.385 < 0.3945

Based on this review of the computer printout of test data, the inspector

concluded that the Type A and supplemental tests demonstrate that the

primary containment leakage rate is within the specified acceptance limits.

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6. Leak Rate Test Program

Plant Procedures

The ~ inspector reviewed the overall leakage rate program for McGuire to

verify that procedures have been developed and implemented consistent with

the regulatory requirements. Documents reviewed either totally, or in part,

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a. PT/2/A/4200/01A - Containment Integrated Leak Rate Test and Structural

Integrity Test

b. PT/2/A/4200/018 - Electrical Penetration Leak Rate Test

c. PT/2/A/4200/01C - Isolation Valve Leak Rate Test

d. PT/2/A/4200/01D - Fuel Transfer Tube Leak Rate Test

e. PT/2/A/4200/01E - Upper Containment Personnel Lock Leak Rate Test

f. PT/2/A/4200/01F - Lower Containment Personnel Lock Leak Rate Test

g. PT/2/A/4200/01G - Mechanical Penetration Leak Rate Test (Bellows Test)

h. PT/2/A/4200/01H - Equipment Hatch Leak Rate Test

1. PT/2/A/4200/01J - Unit 2 Containment Leakage (Controlling procedure to

ensure that the required leakage summations are completed)

J. PT/2/A/4200/01N - VP (Purge and Ventilation) Valve Leak Rate Test

k. PT/2/A/4200/010 - Air Lock Isolation Valve Leak Rate Test

1. PT/2/A/4200/01P - Penetration (Ice Condenser) Leak Rate Test

m. PT/2/A/4200/01Q - Penetration Leak Rate Test (Special Conditions)

n. PT/0/A/4200/22 - New Penetration Leak Rate Test (Special Test)

o. TT/2/A/9100/147 - 2NI1208 Local Leak Rate Test (Special Retest)

Although every procedure listed above was not reviewed for total valve

alignment in step by step detail, the inspector concluded that program-

matically the licensee has developed and implemented a containment leak rate

measurement program. The program is consistent with the regulatory

requirements of the Technical Specification, Section 3/4.6; 10 CFR 50,

Appendix J; and, ANSI N45.4 with the one exception of determining the

as-found primary containment leakage rate. The as-found leakage rate is

discussed further in paragraph 7.

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A detailed walk-through was performed for the local leak rate (Type C)

testing of three penetrations in procedure TP/A/4200/01C. These

penetrations were M373, Glycol System; M353, Fire Protection System; and

M280, Sample System. Partial review of other penetrations was also

performed and no problems were identified relative to venting, draining,

valve identification, valve alignment and system restoration. The inspector

further verified that all penetrations requiring Type C testing in Technical

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Specification Table 3.6-1 are included in the test procedures.

As left leak rate results are tracked and summarized in procedure

TP/A/4200/01J. Enclosures 13.1,13.2, and 13.3 specify the results of the

Type A test, Type C bypass leakage and the Total Type B and C leakage based

on maximum leak paths, respectively. Appropriate acceptance criteria were

specified in this procedure and compared with measured leakage as follows:

Limits Measured Total

Bypass leakage 0.07La (9514 SCCM) 2811 SCCM

Total Type B & C leakage 0.6La (81,552 SCCM) 4192 SCCM

The inspector concluded that the as left local leakage rates are well below

the acceptable limits.

l 7. As-Found Leak Rate

Paragraph III.A.3(a) of Appendix J to 10 CFR 50 incorporates the require-

ments of ANSI N45.4 - 1972 into the regulations. Relative to the Type A

leak rate test, paragraph 4.2 of ANSI N45.4 states, in part, "for retesting,

an initial record proof test shall be conducted at time periods and

pressures established by the responsible organization before any preparatory

repairs are made. This will disclose the normal state of repair of the

containment structure and a record of the results shall be retained."

By a memorandum, dated January 11, 1982, NRR provided a staff position to

clarify the statement, " normal state of repair." This memorandum states

that if repairs or adjustments are made to the containment isolation

boundary prior to the Type A test, the leakage reduction effected by these

repairs or adjustments must be quantified and the Type A test result

adjusted in order to determine the containment " normal state of repair" or

specifically the as-found containment leak rate. In that there appeared to

be a misunderstanding by some licensee's as to what the regulations require,

IE Notice 85-71, August 22, 1985, was promulgated to clarify the intent and

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the requirements of this regulation. The inspection findings in this area

are discussed below for Units 1 and 2.

a. Unit 2

Review of local leak rate testing performed on McGuire Unit 2 during

the current refueling outage indicates that the as-found leakage was

not obtained for the Type C tests in all cases before repairs or

adjustments were made. From the test records, nine penetrations were

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characterized as having excessive leak rates. In some cases, the

leakage exceeded the capability of the flow meter (>2000 SCCM) and in

one case, the penetration could not be pressurized. However, the test

data sheets, work requests, and a computer printout of maintenance job

descriptions showed that after repair of only one valve in each of

these nine penetrations the leak rate for the penetration was reduced

to an acceptable low value. Thus the minimum path leakage through the

penetration is available for these nine penetrations. The leakage from

these penetrations was in the range of 0.001 wt% per day and will not

significantly effect the Type A test result. However, it was found

that preventive maintenance was intentionally performed on a number of

the isolation valves before an as-found leak rate was obtained.

Although precise data was not readily available, the licensee estimated

that as many as 50% of the isolation valves were exposed to this

main +.enance which has the potential of affecting the leak rate.

At the exit interview, the inspector identified this matter as an

apparent violation as follows: Violation 370/86-16-01: Contrary to

the requirements of the Technical Specification, Section 4.6.1.2 and

10 CFR 50, Appendix J, paragraph III.A.3(a) which incorporate the

requirements of ANSI N45.4-1972, paragraph 4.2 into the regulations;

the licensee failed to determine the Unit 2 as-found containment leak

rate prior to performing repairs or adjustments which can effect the

measurement of the as-found leakage.

The matter of whether the Type A test performed on Unit 2 in May 1986

is a passed or failed test was also discussed with the licensee. The

licensee believes that the maintenance records contain enough detail to

determine if the type of maintenance performed could effect valve leak

rates.

These records will be examined to see if the as-found leak rate can be

quantified.

At the exit interview, the inspector identified the status of the

Type A as-found leak rate as an inspector followup item: IFI

370/86-16-02: Review the results of the licensee's examination of

l isolation valve maintenance to determine the as-found leak rate status

of Unit 2.

b. Unit 1

The inspector also reviewed the licensee's action to determine the

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as-found leakage on Unit 1 which is scheduled for a Type A test in July

l 1986. From discussions with management and personnel involved in

performing the local leak rate testing, the inspector determined that

the licensee has implemented controls to obtain the as-found leak rate

for Unit 1.

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For the current outage, the Planning group has the responsibility of

routing all work . requests involving maintenance on containment

isolation valves .to the Performance group prior to the maintenance.

The Performance group evaluates the work requests to determine if a

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, leak rate test must be performed prior to maintenance and/or post  :

maintenance. Through coordination of the Planning, Performance, and

Maintenance groups control of as-found leakage measurements has been

established.

In addition to the current outage maintenance, the Performance group

has reviewed all pre-outage scheduled maintenance to identify any

required as-found leak rate tests.

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While the controls established by the licensee appear adequate, these

. controls have not yet been formalized into procedures.

At the exit interview, the inspector identified this matter as an inspector

followup item:

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IFI 369/86-16-01: Review the procedures established to track and

control determination of the containment as-found leak rate.

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