ML20210A589
| 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: |
| References | |
| 50-348-86-25, 50-364-86-25, TAC-65399, NUDOCS 8702060501 | |
| Download: ML20210A589 (11) | |
See also: IR 05000348/1986025
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET.N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.: 50-348/86-25 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.:
Facility Name:
Farley 1 and 2
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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:
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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
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
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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
The inspection scope and findings were summarized on November 14, 1986, with
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those persons indicated in paragraph 1 above and in subsequent conference
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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
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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
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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:
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(1) review of the test procedures to verify that the procedures were properly
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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
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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.
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A final CILRT report will be submitted to the Office of Nuclear
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Reactor Regulation.
With the exception of Item 7, no problems were identified in the above
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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,
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" 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.
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
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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.
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
requires that Type.B and C tests' shall be conducted with a
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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
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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
correct method for local. leik rate testing the 16 penetra-
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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
hatch are considered adjustments.
These barriers directly isolate
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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
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
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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
wt%/ day
wt%/ day
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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
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and total time analyses.
The values for the equation in terms of
weight percent per day are as follows:
Mass-Point
Total Time
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wt%/ day
wt%/ day
Composite leak rate, Lc
0.170
0.157
Type A test leak rate, Lam
0.040
0.031
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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
containment leakage rate is within the specified acceptance limits.
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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
developed and implemented procedure "FNP-0-ETP-3635" dated September 12,
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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
moderator temperature coefficient (MTC) for 70?s and higher powers will be
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verified to be within the Technical Specification limit using procedure
STP-114.
Procedure STP-114, paragraph 5 contains the steps to verify the
MTC at or above 70*4 power.
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This item is closed.
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