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Insp Repts 50-348/86-25 & 50-364/86-25 on 861107-14 & 1201-05.Violation Noted:Failure to Obtain Local Leakage Measurements Before & After Repairs or Adjustments Made to Containment Boundary
	ML20210A589
Person / Time
Site:	Farley
Issue date:	01/16/1987
From:	Jape F, Whitener H; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20210A526	List: IR 05000348/1986025; ML20210A523; ML20210A563; ML20210A589;
References
	50-348-86-25, 50-364-86-25, TAC-65399, NUDOCS 8702060501
	Download: ML20210A589 (11)
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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-348/86-25 and 50-364/86-25

Licensee: Alabama Power Company

600 North 18th Street-

Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License No.: NPF-2 and NPF-8

Facility Name: Farley 1 and 2 ,

Inspection Conducted: November 7-14, 1966 - Onsite

December 1-5, 1986 - Region II Office

Inspector: M. [ // '

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HJ L. Whi ener Date Signed

Approved by: AM

F. Jape, Chief

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Date Signed

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Test Programs Section

Division of Reactor Safety

SUMMARY

Scope: This routine, announced inspection was conducted in the areas of contain-

ment leak rate testing, including Type A, B and C leak rate testing, and followup

inspection of outstanding items.

Results: One violation was identified - Failure to obtain local leakage measure-

ments before and after repairs or adjustments, which were made to the containment

boundary prior to the Type A test, in order to quantify the leakage correction to

be used to adjust the Type A test result to the "as is" (sometimes called the "as

found") containment leak rate. paragraph Sc.

8702060501 870126

PDR ADOCK 05000348

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

D. N. Morey, Assistant General Manager, Operations

W. B. Shipman, Assistant General Manager, Support

R. D. Hill, Operations Manager

R. M. Coleman, System Performance Supervisor

D. B. Hartline, Test Supervisor

L. D. Huey, System Engineer

Other licensee employees contacted included leak rate test personnel.

Other Organizations

Bechtel - Leak Rate Test Consultants

H. Hill

R. Blum

L. Young

K. Pimentel

Volumetrics ,

T. Scott, Project Engineer, Field Representative

NRC Resident Inspectors

W. Bradford, Senior Resident Inspector

B. Bonser, Resident Inspector

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Attended exit interview

2. Exit Interview

i The inspection scope and findings were summarized on November 14, 1986, with

I those persons indicated in paragraph 1 above and in subsequent conference

calls on December 23 and 30,1986. The inspector described the areas

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inspected and discussed in detail the inspection findings. The following

j new items were identified during this inspection.

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a. Violation 50-348/86-25-01: Contrary to the requirements of Appendix J

to 10 CFR 50, the change in local leak rates resulting from repairs or

adjustments made to the containment boundary prior to the Type A test

I was not measured; therefore, the leakage correction to be used in

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determination of the "as found" ccntainment leak rate could not be

determined (Paragraph 5.c.).

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b. Inspector Followup Item (IFI) 50-348/86-25-02: Evaluate the licensee's

analysis and justification of the " pass" or " failure" status of the "as

found" containment leak rate as presented in the containment leak rate

report to the NRC (Paragraph 5.c.).

c. IFI 50-348/86-25-03: Veri fy that the analysis of the "as left"

containment leak rate includes the local leak rates for penetrations

56, 57 and 46 which were isolated or not vented during the Type A test

(Paragraph 5.b.1).

d. IFI 50-348/86-25-04: Verify that the required testing for isolation

valves Q1E21V116A, B and C is resolved and, if required, appropriate

tests are performed (Paragraph 5.b.(2)(a)).

e. IFI 50-348/86-25-05: Verify that the correct method for testing 16

penetrations identified in FSAR Table 6.2-38 as Type C tests with

water filled piping is resolved and, if necessary, appropriate testing

is performed (Paragraph 5.b.(2)(b)).

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

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items

Unresolved items were not identified during the inspection.

5. Containment Integrated Leak Rate Test (CILRT) - Unit 1 (70313)

The inspector reviewed and witnessed test activities to determine that the

primary CILRT was performed in accordance with the requirements of Appendix J

to 10 CFR 50; ANSI-N 45.4-1972; Technical Specification (TS) 3/4.6.1.2; and,

the Unit 1 test procedure, FNP-1-STP-117.0, Revision 6, " Containment Inte-

grated Leak Rate Test". ANSI /ANS 56.8-1981, "American National Standard

Containment System Leakage Testing Requirements," and Bechtel's BN-TOP-1,

" Testing Criteria for Integrated Leakage Testing of Primary Containment

Structures for Nuclear Power Plants," were used for guidance during the

course of the inspection.

Selected sampling of the licensee's activities which were inspected included:

! (1) review of the 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

l 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.

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a. General Observations

The inspector witnessed and reviewed portions of the test preparation,

temperature stabilization, and data processing during the period of

November 7-14, 1986. The inspector's observations were as follows:

(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 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) Problems encountered during the test were documented in the CILRT

test event log.

(6) Pressurized gas sources, such as instrument air and nitrogen

supply to accumulators, were reviewed for proper isolation and

venting to prevent interference with test results.

(7) Procedure valve alignment was reviewed against system drawings to

verify correct. boundary alignment, and venting and draining of

specific systems.

(8) A temperature survey of the containment was performed to determine

representative locations of the instruments.

(9) In-situ instrument checks were performed to confirm instrument

operability and channel agreement with the data acquisition

system.

(10) Temperature, pressure, dew point, and flow data vere recorded at

15-minute intervals. Data were assembled and retained for final

, evaluation and analysis by the Bechtel Corporation for the licensee.

l A final CILRT report will be submitted to the Office of Nuclear

! Reactor Regulation.

With the exception of Item 7, no problems were identified in the above

l areas. Item 7 is discussed in paragraph 5.b. below.

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b. Procedure Review (70307 and 61720)

The inspector reviewed portions of FNP-1-STP-117.0, Revision 6,

I " Containment Integrated Leak Rate Test," and FNP-1-STP-627, Revision 11,

" Local Leak Rate Testing of Containment Penetrations," on site and

completed these reviews in the Region II office. The review included

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verification that the requirements of Appendix J to 10 CFR 50 and

Technical Specification 3/4.6.1.2 were met with specific attentfon to

acceptance criteria, valve alignments and system venting and draining.

Results of this review are discussed below.

(1) Integrated Leak Rate Test: FNP-1-STP-117.0, Revision 6

The acceptance criteria in FNP-1-STP-117.0 were generally adequate.

One exception was noted in that the acceptance criteria for a 24

hour test (Section 2.1) endorses only the mass point analysis.

The current NRC position requires that the Type A and verification

tests meet the acceptance limits using the total time analysis.

This item had no impact on the leak rate test in.that both the

licensee and his consultant were aware of the total time require-

ment and applied both the mass point and total time analysis

techniques to the test data. The inspector concluded that no

issue existed. The two methods are currently being reviewed

to govern the appropriate acceptance criteria for future leak rate

tests. These documents include a proposed revision of Appendix J

to 10 CFR 50 and a generic letter to all licensees addressing the

acceptable use of mass point and total time analysis methods.

A review of each containment penetration for correct valve align-

ment, venting, and draining in accordance with the test requirements

specified in the FSAR Section 6.2 was performed. An apparent

conflict between the FSAR Section 6.2 and Appendix J or Technical

Specification requirements will be resolved as a separate issue

and is discussed in paragraph 5.b.(2)(b).

Two problems were identified in the valve alignment of the

pressurizer sampling system as follows:

(a) Penetration 56: A non-isolation valve number HV3880 located

between and in-line with the two isolation valves of the

pressurizer steam sample line was closed. This created an

artificial barrier between the containment and outside

atmospheres.

(b) Penetration 57: A non-isolation valve number HV3881 located

between and in-line with the two isolation valves of the

pressurizer liquid sample line was closed. This created an

artificial barrier between the containment and outside

atmospheres.

Also, one problem was identified in the component cooling water

(CCW) return from the excess letdown and reactor coolant drain

tank heat exchangers through penetration 46. This flowpath was

isolated, water filled and not vented for the Type A test. FSAR

Table 6.2-38 requires a Type C test for this penetration; therefore,

the penetration should be vented for the Type A test.

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The inspector reviewed the cause for the above conditions and

found that valves HV3880 and HV3881 in penetrations 56 and 57 are

air operated valves which fail closed on loss of air. A source

of pressurized air inside containment is not permitted during the

Type A test. Consequently, when instrument air to the containment

was isolated, these valves closed. Penetration 46 was not vented

because this manipulation would involve draining a large volume

of chemically treated water with the associated hazard to the

environment.

On the basis of this review, the inspector concluded that these

are isolated cases and that the above alignments are acceptable

providing the local leak rates for penetrations 56, 57 and 46 are

added to the Type A test result. This matter is identified for

followup inspection as: IFI 50-348/86-25-03: Verify that the

analysis of the Type A leak rate in the licensee's leak rate

report to the Commission includes the local leak rates for pene-

trations 56, 57 and 46 which were isolated or not vented during

the Type A test.

(2) Local Leak Rate Tests: FNP-1-STP-627, Revision 11

The acceptance criteria in FNP-1-STP-627 were adequate as related

to Appendix J requirements. The inservice valve program criteria

were not evaluated in this review.

A review of each penetration indicated that the test alignments

are adequately defined. Specifically, block valves, isolation

valves, test connections and vent paths are identified and the

valve positions specified.

Two problem areas were identified in the review as follows:

(a) Certain isolation valves identified for Type C testing are

not included in the Type C procedure. FSAR Table 6.2-39

identifies the containment isolation valves for all contain-

ment penetrations. FSAR Table 6.2-38 identifies the type of

leak rate test to be performed on each penetration. FSAR

Table 6.2-31 provides additional information relative to the

penetrations including explanatory notes applicable to

certain penetrations. Information in these tables show that

the penetrations with manually operated outside isolation

valves Q1E21V116B for penetration 25; Q1E21V116C for pene-

tration 26; and Q1E21V116A for penetration 27 are to be

Type C tested. Penetrations 25, 26 and 27 are reactor

coolant pump seal water supplies. Note 4 to Table 6.2-31

states that these are open paths post-LOCA but also identifies

the manually operated valves outside containment as a second

isolation barrier for these penetrations. Isolation valves

Q1E21V116 A, B and C are not included in the Type C test

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program defined by FNP-1-STP-627, Revision 11. In that these

penetrations are open flow paths post accident; the outside

isolation valves are manually operated; the outside isolation

valves are normally open; and, without operator action these

valves are open post accident; it is not clear if Type C

tests are required by Appendix J. The inspector identified

this matter IF: 50-348/86-25-04: Resolve the matter of

appropriate testing of isolation valves Q1E21V116A, B and C

with NRR and verify any required testing on a defined time

basis.

(b) Certain Type C tests identified in the FSAR are not consistent

with the regulations. FSAR Table 6.2-38 specifies the type

of leak rate test to be performed on the containment pene-

trations. In this table 16 penetrations are identified

as Type C tests with a footnote that these tests may be

performed with the system water filled. This condition is

not consistent with the regulations.

Appendix J requires that Type C tests be performed with air

or nitrogen at a pressure of Pa.where specifically the air

leakage is determined to compare with the air leakage limit

of 0.6La. The exceptions are air lock door seals and seal

water system valves. Door. seal's in some cases may be tested

at less than Pa. A seal water system valve or a water sealed

valve may be tested .with water at 1.1- Pa where water leakage

is measured and compared to a water leakage limit and need

not be considered"jn the 0.6La limit. An air leakage

measurement in a water filled system is not defined.

In addition to Appendix J, Technical Specification 4.6.1.2.d

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requires that Type.B and C tests' shall be conducted with a

gas at a pressure of Pa...except for tests involving airlocks.

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An exception is granted for airlock door seals which are

tested at less than Pa; no exception is identified for Type C

tests. Further, the Safety Evaluation Report does not

identify any approved exceptions to the regulations. The

inspector concluded that the aEceptable test method must be

resolved with NRR for the 16 penetrations identified in the

FSAR as Type C tests with' water filled systems in order to

define the correct Type C test method and' appropriate Type A

test alignment for these., penetrations. - This matter was

identified as IFI 50-348/86-25-05: Resolve with NRR the

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correct method for local. leik rate testing the 16 penetra-

tions identified in FSAR Table 6.2-38 as Type C tests with

water filled system's and verify any required testing on a

defined time basis.

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c. As-Found Containment Leak Rate

The regulations regarding the determination of the overall contain-

ment leak rate prior to any repairs or adjustments to the containment

boundary are as follows:

Paragraph III.A.1.(a) of Appendix J to 10 CFR 50 and paragraph 4.2

of ANSI-N45.4, incorporated into the regulation by paragraph

III.A.3.(a) of Appendix J to 10 CFR 50, require that no repair or

adjustment shall be made to the containment boundary prior to the

Type A test in order to determine the "as is" overall containment

leakage rate. If repairs or adjustments are necessary prior to

the Type A test, the NRC has determined that the intent of the

above regulation (specifically, to determine the "as is" overall

containment leakage rate) is met provided that local leak rate

tests are performed on the affected portion of the containment

boundary to determine the minimum path leak rate before and after

the repairs or adjustments are made; and, the Type A test result

is corrected, using these local leak rate measurements, to

determine the "as is" overall containment leakage rate.

The inspector reviewed the licensee's program for determination of the

overall "as is" containment leak rate with specific attention to:

(1) the development of controls to obtain the required local leak rate

data; (2) the processing of local leak rate measurements to determine

the leakage correction based on the minimum path leakage concept; and,

(3) the effect of the test results on the containment leak rate.

Controls to obtain the required local leak rate data are established

through the outage planning activity and the maintenance work request

systems. The daily planning group identifies any valve which requires

a local leak rate test on the maintenance request. Before releasing a

component for maintenance, the operations foreman verifiee ttat the

required leak rate test has been performe?. The inspector tr,cluded

that the licensee has established controls to obtain an "as found"

containment leak rate.

Containment penetration drawings, Type C test valve alignments and the

tabulation of local leak rate data were examined to eva' uate the

calculation of the local leakage correction. The minimum path leakage

was calculated correctly; however, certain leakage barriers have been

excluded from the "as found" leak rate measurements. F-ior to the

Type A test the "as found" leak rate was not obtained for the equipment

hatch and the fuel transfer tube blind flange seals before removing

these barriers for the refueling outage.

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On reinstallation of these barriers prior to the Type A test, an

as-left local leak rate. (Type B) test is performed and these values

were used in the calculation of the containment "as found" leakage.

The licensee indicated that the seals for the fuel transfer tube blind

flange were replaced; this is considered a repair. Seals for the

equipment hatch were not replaced; however, the fitting, seating, and

torquing manipulations involved with removal and reinstallation of the

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hatch are considered adjustments. These barriers directly isolate

containment atmosphere from the outside atmosphere and are required

Type B tests.

The inspector concluded that repairs or adjustments were made to the

containment boundary prior to the Type A test without quantifying the

change in leakage resulting from these repairs or adjustments in order

to adjust the Type A leak rate to the "as found" condition. Further,

exclusion of components which are potentially direct leakage paths from

the containment . atmosphere to the outside atmosphere from the "as

found" containment leak rate determination normally requires an

exemption to the regulations identified above.

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This matter was identified as a violation as follows:

Violation (50-348/86-25-01): Contrary to the above requirements

when repairs or adjustments were made to the containment boundary

prior to the Type A test the licensee failed to measure the change

in leak rate resulting from these repairs or adjustments by local

leak rate methods in order to determine the overall containment

"as found" leak rate.

The inspector concluded that failure to obtain the leakage corrections

for all repairs or adjustments made to the primary containment boundary

prior to the Type A test renders the overall "as found" containment

leak rate indeterminable.

The licensee is required to submit a containment leak rate test report

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to the NRC with 90 days. In accordance with Appendix J, Paragraphs

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III. A.6 and V.B tnis report must identify the licensee's position on

the " pass" or " failure" status of the overall as-found containment leak

rate and provide the information and analyses on which this position is

based for evaluation by the NRC. This matter was identified for

followup inspection as:

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IFI 50-348/86-25-02: Evaluate the licensee's leak rate test

report and determine the " pass" or " failure" status of the overall

"as found" containment leak rate.

The inspector's evaluation of the licensee's "as found" containment

leak rate excluding the fuel transfer tube blind flange and equipment

. hatch indicate a leak tight containment. The allowable leakage of 0.75

La is 0.1125 wt% per day. The Type A leak rate (95% UCL based on total

time) was 0.054 wt% per day. The leak rate correction, excluding the

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two barriers which were not quantified, was about 0.02 wt% per day. An

adjusted leakage of 0.07 wt% per day leaves a margin of 0.04 wt% per

day within the allowable 0.75 La limit; in other words, the "as found"

leak rate is about 60% of the allowable 0.75 La leakage excluding the

unmeasured corrections for the equipment hatch and fuel transfer tube

blind flange seals.

d. Containment Integrated Leak Rate - Unit 1

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

hour supplemental leak rate test were performed on the Unit 1 primary

containment in the period November 10-11, 1986. Mass point-linear

regression analysis and total time analysis were used by the licensee

to determine the leak rate (Lam) and upper confidence limit (UCL) at 24

hours. The test met the acceptance criteria for both mass point and

total time analysis as shown below; the values are expressed as weight

percent per day.

Mass Point Total Time

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wt%/ day wt%/ day

La 0.15 0.15 (allowable leakage)

0.75 La 0.1125 0.1125 (test acceptance limit)

Lam at 24 hrs. 0.04 0.031

UCL at 24 hrs. 0.042 0.054

The inspector's calculations agree with the above values.

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:

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

l and total time analyses. The values for the equation in terms of

weight percent per day are as follows:

Mass-Point Total Time

l wt%/ day wt%/ day

Composite leak rate, Lc 0.170 0.157

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Type A test leak rate, Lam 0.040 0.031

Imposed leak rate, Lo 0.154 0.154

Error limit, 0.25 La 0.0375 0.0375

Substitution of these values into the acceptance equation demonstrate

that the specified inequalities are satisfied as follows:

Mass-Point 0.156 < 0.170 < 0.231

Total Time 0.147 < 0.157 < 0.222

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Based on this review of test data, the inspector concluded that the

Type A and supplemental tests demonstrate that the "as left" primary

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containment leakage rate is within the specified acceptance limits.

6. Review Of Outstanding Items

(Closed) -IFI 50-348/84-12-02 and 50-364/84-12-02 concerned the use of a

chi-squared statistical test to determine the reliability of source range

neutron detector channels. The inspector verified that the licensee has

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developed and implemented procedure "FNP-0-ETP-3635" dated September 12,

1984, to statistically verify operability of the source range channels.

This item is closed.

(Closed) IFI 50-348/85-39-01 concerns the modification of procedures to

include a confirmation of a negative moderator temperature coefficient

above 70?s power. The inspector determined that a revision to ETP-3605,

step 7.2.3 now requires that prior to reaching 70's thermal / power the

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moderator temperature coefficient (MTC) for 70?s and higher powers will be

verified to be within the Technical Specification limit using procedure

STP-114. Procedure STP-114, paragraph 5 contains the steps to verify the

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MTC at or above 70*4 power.

This item is closed.

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ML20210A589

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