ML20247D544
| ML20247D544 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/07/1989 |
| From: | Belisle G, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20247D527 | List: |
| References | |
| 50-338-89-12, 50-339-89-12, NUDOCS 8907250230 | |
| Download: ML20247D544 (14) | |
See also: IR 05000338/1989012
Text
____ ._ .- _ .
.. :
7'
p haa
UNITED STAi ES '
=
.R
q
NUCLEAR REGULATORY COMMISSION ~
' ['**
-
U
REGION il
.p
gj
gg
101 MARIETTA STREET.N.W.
'*
ATLAN TA, GEORGI A 30323
.
. ,o "
.... _
.' Report Nos.:
50-338/89-12 and 50-339/89-12
'
. Licensee! _ Virginia. Electric and Power. Company
.
Glen Allen,-VA 23060
Docket Nos.:
50-338 and 50-339
License Nos.:
Facility Name:
North Anna 1 and 2
Inspection Conducted:
April 12-14 and 20-26, 1989
Inspec' tor:
W , g. /J /u h w
' 7 [7[J'9
>
H. L. Whitener
Date Signsd
Accompanying Personnel:
S. M. Shaeffer, April 12-14, 1989
Approved by: b.A*
&;M
[tM -
7/7/8f
G. A. Belisle,% hief
-
'Date Signed
'
.
Test. Programs Section
Engineering Branch
Division of Reactor Safety
SUMMARY
. Scope:
This'. routine, announced -inspection was in' the areas of witnessing the contain-
ment integrated leak rate test, reviewing test procedures, evaluating test
results, and' following up on previously identified items pertaining to leak
Trate testing.
~
' Rasults:
-In the areas inspected, one violation was identified:
Failure to perform local
leak rate (Type _ C)~ tests.on certain containment isolation. valves in a manner
which is as . conservative as apply (ing pressure in the direction the valve must
perform its isolation function
paragraph 4).
Additional problem areas
identified during this inspection include:
'
An evaluation (Engineering-Study _88-31)'which concludes that Type C tests
on globe valves _ performed by applying test pressure in a direction
opposite-to the accident pressure (reverse direction) and which assists in
seating the valves is conservative (paragraph 3).
'
Repair o'r adjustment to the containment boundary prior to the integrated
(T me: A) leak rate test without adjustment for the "as found" leak rate
(paragraph 2.b.(5)).
8907250230 890717
_
ADOCK 05000338
%
0
FDC
g
_
m
.-_m-_-_____:_u.__. - - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
-
._
._
-
.
I^
.
.-
'
2
s
A weakness in: the Type A test procedure 2-PT-61.1 related to penetration
draining (paragraph 2.b(3)).
The inspector concluded that the Type A test was acceptable; however, increased
l
management attention is needed to reduce the number of deviations to the test
-(paragraph 2.b(1)). and establish stable temperature control during the test.
(paragraph 2.b(4)).
- _ _
_ - _ _ _ - - _ _ _ _ - _ .
_ _ .
f;
l
.
.-
,
'
.
l
l
l
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- P. Boulden, Senior Engineer
- M. Bowling, Assistant Station Manager
- R. Driscoll, Manager, Quality Assurance
R. Enfinger, Assistant Station Manager, Operations and Maintenance
- D. Heacock, Superintendent, Engineering
- P. Kemp, Supervisor, Licensing
- J. Leberstien, Engineer
- P. Prendergast, Engineer
J. Stall, Superintendent, Operations
- R. Sturgill, Supervisor, Systems Engineering
- C. Tiernan, Associate Engineer
- V. West, Superintendent, Outage Management
Other Organizations
Bechtel
L. Young, Leak Rate Consultant
K. Pimentel, Leak Rate Consultant
NRC Resident Inspectors
J. Caldwell, Senior Resident Inspector
L. King, Resident Inspector
- J. Munro, RII
- Attended exit interview
- Attended conference call June 30, 1989.
2.
Containment integrated Leak Rate Test - (70313) (Unit 2)
The inspector reviewed and witnessed test activities to determine that the
primary containment integrated leak rate test (CILRT) was perfortiled 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</br></br>N45.4-1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Leakage - Rate Testing of Containment Structures for Nuclear
Reactors; BN-TOP-1, Revision 1 - 1972, Testing Criteria for Intergrated
i
Leakage Rate Testing of Primary Containment Structures for Nuclear Power
Plants; and, test procedure 2-PT-61.1, Reactor Containment Building
Integrated Leakage Rate Test.
Selected sampling of the licensee's activities which were inspected
included:
(1) reviewing the test procedure to verify that it was properly
approved and confctmed with regulatory requirements; (2) observing the
test performance to determine that test prerequisites were completed,
1
l
- -__ _ _ ___--__ _-___
.
._
'
,
.
.~
.'
2
special equipment was installed, instrumentation was calibrated, and
appropriate data were recorded; and (3) evaluating the preliminary leak
rate data to verify that leak rate limits were met.
a.
General Observations
The ' inspector witnessed and reviewed portions of the test prepara-
tion, containment pressurization, temperature stabilization, and data
processing during the periods April 12-14 and April 20-26, 1989, and
concluded the following:
(1) The test was conducted in accordance with an approved procedure.
Procedure changes and test discrepancies were documented.
(2) Selected test prerequisites were found to be completed.
(3) Plant systems required to maintain test control were found to be
operational.
(4) Special test instrumentation was found to be installed and
calibrated.
(5) Data required for performing the containment leak rate
calculations were recorded at 15-minute intervals.
(6) Problems encountered during the test were described in the test
event log.
(7) Pressurized gas sources were properly isolated and vented to
preclude in-leakage or interference of out-leakage through
containment isolation valves.
(8) Selected procedure valve alignments were reviewed against system
drawings to verify correct boundary alignment, and venting and
draining of specific systems.
(9) Temperature, pressure, dew point, and flow data were recorded at
15-minute intervals.
Data were assembled and retained for final
evaluation and analysis by the licensee.
A final Integrated
Leak Rate Test (ILRT) report will be submitted to the Office of
Nuclear Reactor Regulation.
b.
Test Procedure Review - Unit 2 (70307)
The inspector reviewed portions of 2-PT-61.1, Revision 2, dated
March 17, 1989, on site to verify that adequate test controls, valve
alignments, and acceptance criteria were specified.
Also, additional
review was performed in the Regional Office.
Procedure deviation
forms for about 30 procedure changes were reviewed.
These deviations
reflected changes in the preplanned test methods and controls, plant
operating conditions, equipment protection, air compressor check out
- _-__ __-
-_.
_
___-.
e
e
-
.
.
3
,
and. operation, system restoration, and corrections to the procedure.
Procedure valve alignments for a limited selection of systems were
also reviewed.
The systems reviewed included the following:
Drained and
Type C.
Systen,
Vented
Penalty
42
Service Air Supply to
Yes
No
Containment
43
Radiation Monitor Air Return
Yes
No
44
Radiation Monitor Air Supply
Yes
No
45'
Primary Water Supply to
Yes
No
Containment
46
Charging to Loop Fill Header
No
Yes
53
Yes
No
20
SI Accumulator Make up
No-
Yes
108
Steam Generator C Wet Layup
Yes
No
80
Service Water Supply to
No
Yes
RS Hx C
85
Service Water Return from
No
Yes
RS Hx C
56A
Pressurizer Liquid Sample Line
No
Yes
As a result of the on site review of 2-P1-61.1 and additional review
in the Region II office, the inspector observed the following:
(1) Procedure R iiations - The inspector reviewed 30 procedure
deviation forms, most of which contained : multiple changes.
While the changes did not violate regulatory requirements,
excessive changes to the planned procedure have the potential to
,
add confusion to an already complicated test.
Management
attention is needed in this area.
(2) Type C Add-on Leakage - In attachment 6.5 to the test
procedures, 65 penetrations were identified as Type C add on
leakage adjustments to the Type A test.
While no limit has been
placed on add-on leakage, the NRC requires that the Type A test
be performed as close as possible to the post accident
,
!
condition.
Management has taken action to reduce add-on
-_l-_--____--_-___-
- _ -
_ _ _ - _ _ _ _
4
-
.
,-
4
leakages in a request to the NRC to recognize certain penetra-
tions as water sealed.
The inspector concluded that this is an
area where management involvement to achieve a quality test was
evident.
(3) Penetration Draining - 2-PT-61.1 contained a note to drain
certain penetrations as instructed by the test director and/or
shift supervisor.
While the actual manipulations to drain
penetrations were recorded in a log for reference, the sequence
of steps nr identification of low point drains and high point
vents were not ircluded in the procedure.
In that draining
certain penetrations is a key element in achieving a post
accident boundary condition, the inspector identified the lack
of specific instructions as a weakness in the procedure.
At the
exit interview the licensee agreed to incorporate specific
draining instructions.
(4) Temperature Control - As a resuit of an increasing temperature
during the test, the licensee predicted that containment
pressure would exceed the design pressure limit.
Consequently,
adjustments of the chilled water flow tc the air recirculation
coolim; fans were made during the test to maintain pressure
below ine design pressure.
Pressure data taken at periodic
intervals are instantaneous readings and include the effect of
true temperature at that time.
Temperature readings associated
with the pressure readings are the weighted average of a number
of sensors distributed throughout the containment.
Therefore,
the true temperature is lagging the pressure reading.
This
condition has no effect when temperature is constant.
Further,
since the leak rate is determined by the change in parameters,
the errors will essentially cancel out when the rate of change
of temperature remains constant.
However, when temperature is
artificially controlled, some error can be introduced in the
test result.
In this case, because adjustments were small and
the margin between measured leak rate and allowable leak rate
was large, the inspector concluded that the temperature control
did not invalidate the test result.
However, management should
aggressively pursue means of obtaining long term temperature
stabilization.
At the exit interview, management stated that
l
other means of containment temperature control were being
investigated.
(5) Repair of Containment Boundary - Attachment 6.21 to 2-PT-61.1 is
a procedure used by the licensee to perform an air pressure test
on secondary systems inside containment to identify and repair
leak paths.
This test is performed only as a prerequisite to
the Type A test.
Repaired leakage is not quantified for the
purpose of adjusting the Type A test result to an "as found"
condition.
..
__
_
h*
lr
,.
.'
5
The inspector concluded that secondary syctems and associated
l
piping and components inside containment are a part of the post
accident- containment boundary.
Therefore, leakage from
l
containment' through this barrier must be considered containment
leakage.
Further, leakage corrected as a result of repairing
this boundary prior to the Type A test must be quantified and
used in evaluating the overall- performance of the containment.
The licensee maintains that the secondary systems . will be
pressurized at a pressure greater than containment pressure post
accident.
Therefore, any leakage would be from the secondary
system into and not out of containment.
This position would not
normally be acceptable to the NRC which requires that any
containment leakage seal can be established and maintained for
30 days at a pressure greater than Pa.
However, North Anna is a
unique condition.
The containment is maintained at
subatmospheric pressure during normal operation.
Further, the.
accident analysis shows that the containment will again be at
subatmospheric pressure in about one hour post accident.
Maintaining the secondary pressure seal for one hour may be
feasible.
However, where actions based on a judgment are
contrary to the regulation, the NRC must concur in this
judgment.
The licensee agreed to submit this position to NRR for
evaluation.
This matter was identified as an unresolved item as follows:
Unresolved Item 338/89-12-02 and 339/89-12-02:
Verify that
the licensee has submitted the position that the secondary
systems are pressure sealed post accident for a sufficient'
time to allow containment pressure to become subatmospheric
to NRR for evaluation.
The results of the h!RC evaluation
will be reviewed at a future inspection.
c.
Test Performance - Unit 2
(1) Method
The licensee's consultant had data analysis capability for the
total timo analysis in accordance with requirements of BN-TOP-1
)
for a short duration test and mass point-linear regression
analysis in accordance with the recommendations of ANSI /ANS -
56.8 - 1981, Containment System Leakage Testing Requirements,
for a 24-hour test.
The criteria for the short duration test
were not met.
Consequently, the licensee performed a 24-hour
test using mass point analysis.
A four-hour supplemental test
was also performed.
- - _ _ _ _ _ _ _ -.
. _ _ . .
_-
.
.
.-
,
6
-
(2) Test Description
Containment pressurization was initiated at 3:30 a.m.
on
April 21, 1989 and terminated at 3:30 p.m. with a test pressure
of 59.12 psia.
During the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the licensee adjusted
RHR system temperature and established chilled water flow to the
containment recirculation fans to control the rate of increase
of the containment atmosphere temperature.
This was necessary
to maintain the containment pressure between the design pressure
of 45 psig and the test pressure of 44.1 psig.
Temperature
stabilization was achieved and the leak rate test was initiated
at 4:00 a.m., April 22, 1989.
Only minor leakage was identified
l
during the leakage surveys.
No leakage corrections were made
and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test was terminated at 4:00 a.m. on April 23.
Subsequent to the test, temperature control was lost due to
mechanical problems with the auxiliary boiler.
The resulting
temperature transient was stabilized and the verification test
was performed from 7:00 a.m.
to 11:00 a.m. with an imposed
leakage of 5.07 scfm established.
A sequence of test events extracted from the test log are
described in the following table:
Date
Time
Event description
4/21/89
0330
Ain compressors started.
0436
SG pressure recorded:
A = 1.1 psig,
B = 0.1 psig, C = 1.6 psig.
0738
Leakage survey in progress.
1530
Compressors
secured,
containment
pressure at 59.12 psia.
Chilled water
to recirculation fans secured.
1615
Containment temperature and pressure
increasing at a rate which may exceed
design pressure during the test.
1735
RHR System temperature decreased to
reduce heat input to containment.
2200
Chilled water flow to containment
l
recirculation fans initiated to reduce
'
rate of temperature rise.
4/22/89
0348
Temperature stabilization criteria met
over the last four hours.
Test to be
j
l
started at the next data point.
1
1
I
L-_
-
-
-
--
- - _ - - -
.
..
.
,.
7
.
Date
Time
Event Description
(cont'd)-
0400
Test initiated.
1029
Chilled water flow manually disturbed:
brief temperature / pressure transient
resulted in statistical rejection of
one data set.
4/23/89
0000
Computer went down - two data sets
missed.
0400
94 hour0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br /> Mass Point test completed:
.eak rate is 0.024; UCL is 0.027 wt. %
per day.
0404
Chilled water flow lost due 'to
mechanical failure to auxiliary boiler.
0415
Imposed a containment leakage of 5.07
scfm.
0515
Boiler returned to service:
chilled
water flow reestablished.
0611
Containment temperature stabilizing.
0700
Temperature stabilization
reestablished:
Verification
test
started.
1100
Verification test completed.
(3) Test Results - Unit 2
(a) Type A Test
Technical Specification allowable leakage (La) for North
Anna Unit 2 is 0.1 weight percent per day.
Therefore,
the integrated leak rate test leakage limit of 0.75 La
i
as required by Appendix J is 0.075 weight percent per day.
In the period following containment stabilization, the
licensee analyzed the data using both the total time and
mass point analysis methods.
The criteria for a short
duration test were not met.
Consequently, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test
was performed using mass point analysis.
The following are
the calculated leak rate and 95% upper confidence limit
,
'
(UCL) for both the mass point (MP) analysis according to
ANSI /ANS 56.8 and total time (TT) analysis according to
BN-TOP-1:
_ _ _ _ _ - - _ - - -
.
.
-
___
.
..
,
' i
.
~
t
o
..-
,
8
'*-
e
-
Method
Leak Rate *
95% UCL*
0.75 La*
E
E MP
0.024
0.027-
'0.075
TT
0.019
.0.119**
0.075
- Units are in weight percent per day.
.-
- The total time 95% UCL~ reduces to'0.035 at the 24th
hour when the penalties of the BN-TOP-1 method are
dropped.
The inspector reduced. one hour of: data using individual
sensor data and volume weighting factors.
The results
agreed with those generated- by the licensee's program;
l'
subsequently, the mass data generated. by the licensee's
program was used to evaluate the leak rate.
The results
agree with the licensee's res ults.
The inspector concluded
.
that1the licensee had demonstrated that containment leakage'
is- within the allowable leak rate of 0.075 weight percent
'per day.
-(b) Supplemental Test - Unit 2
10.CFR 50, 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
inEleak rate.
The following is an acceptable supplemental
' test' method as in Appendix C of ANSI N45.4.- 1972:
- A known leak ~ rate (Lo) is imposed on the containment
and the. measured composite leak rate-(Lc).must equal,
within 10.25 La, .the sum of the measured leak ~ rate
(Lam) plus the known leak rate (Lo).
The acceptance criteria is expressed as:
Lo + Lam - 0.25 La < Lc < Lo + Lam + 0.25 La
A 4.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> verification test was performed.
The following measured values were obtained:
_TT*
_M_P *
Lam
0.019
0.024
Lo
0.1
0.1
Lc
0.122
0.115
.25La
0.025
0.025
- _ _ _ . -
-
_ _ _ .
. _ _ -
L
x
'
fn
.
,
. . -
9
'
.
.
.
Substituting these values into the acceptance criteria
d
shows that the inequality was. satisfied as follows:
Mass Point *
0.099
<0.115
<0.149
.
. Total Time *
0.094-
<0.122
<0.144-
'
- Units are in weight percent per day
The inspector concluded that the verification test
confirmed the instrument system capability - to. measure-
the containment leak rate.
3.
Review of Engineering Study on Type C Testing
During an inspection;of Unit 1 Type C testing in the period September'28 -
October 2, 1987, the inspector identified certain containment isolation
valves tested by applying test pressure in a direction different from
accident . pressure.
Although this appeared to be nonconservative,
. sufficient information was- not available for an adequate evaluation.
Subsequent'to the inspection the licensee investigated the Type C testing;
identified 13' valves on Unit 1 and 15 valves on Unit 2 that were tested
nonconservatively; took appropriate corrective action for. these valves;
and, issued a justification for continued operation (JCO).
This JC0 was
approved by the Station Nuclear Safety and Operating Com;aittee (SNSOC) on
October 9, 1987.
The licensee has further documanted the station position
on conservatism of Type C testing'in Engineering Study 88-31, approved by
SNSOC on November 10,.1988. .In this study.the licensee concluded:
a.
Tests of diaphragm valves are equivalent _when pressurized from either
the accident or reverse direction.
The inspector concurs in this position.
~b.
Tests of Butterfly vali :s with a balanced disk are equivalent when
pressurized from either the accident or reverse direction.
The inspector concurs in this position with the reservation that the
seat construction must be considered.
c.
Tests of single wedge gate valves are nonconservative when the valve
is pressurized in the reverse direction.
These valves must be tested
by pressurizing in the accident direction.
The inspector concurs in this position.
d.
Tests of globe valves are conservative when the valves are
pressurized in'the reverse direction under the following conditions:
(1) Valve spring closure force is greater than the lifting force
applied by accident pressure.
-
_ _ - - _ - _ -
,,
,
-
-
-
-
- __-
p
,
f
-
.
.,O'
.
10
-
(2) Valves must be oriented such that the packing is exposed to the
test pressure.
(3) Valves must have a hard seat (metal) which will not deform und'r-
-test pressure.
..
The NRC does not agree with the licensee's position.
i
Historically it-has'been a consistent NRC position that a Type C test on a
I
globe valve is nonconservative when pressure applied in a reverse
direction is over the seat assisting the spring in closing the valve.
For
such a valve the accident pressure would be under the seat tending to open
the valve.
Further, this position is generally endorsed by the industry
standards and codes.
Specifically, ASME Boiler And Pressure Vessel Code,
Section XI,1986, Subsection IWV, Paragraph 3423 specifies that globe
valves must be pressurized in the same direction as when the valve is
performing'its function (i.e accident direction for containment isolation
valves) and may be tested from a different direction only.when test
pressure is applied under the valve seat.
This position is in agreement
with 10 CFR 50, Appendix J, paragraph III.C.1.
In regard to the licensee's arguments for reverse testing, the NRC can
agree in' concept that there is some closure .. force to lift force ratio
(C/L) < large .enough that application of test pressure either over or under
the valve seat may have no practical significance.
However, to define
.this ratio would require a major research effort.
Such an effort would as
a minimum, have to investigate effects on leakage due to the size and
design of the valve, various leakage raten, nature of the leakage path,
and repeatability of results.
As to no deformation of metal surface due
to test pressure, the NRC agrees deformation in the sense of distorting
the. seat should not occur from the addition of test pressure.
However,
the NRC maintains that flow between two mated surfaces can be affected by
application of greater or-lesser force on these surfaces.
For instance,
the' C/L ratios for the globe valves identified in the Engineering Study
88-31 varied from 1.5:1 to'270:1.
Concerning testing of the packing, the
NRC agrees that it is necessary to test and maintain packing which may
become a part of the containment leakage boundary post accident.
However,
it is the NRC position that such packing must be tested in addition to,
'not in lieu of, performing a conservative test on the valve seat.
This natter was reviewed by the inspector, Region II management, and the
office of Nuclear Reactor Regulation (NRR) Mechanical Engineering Branch.
It is the NRC conclusion that the Type C test program relative to testing
globe valves does not conform to Appendix J,
Paragraph III.C.1.
requirements.
In that the conservatism of reverse Type C tests on isolation valves is
l
the subject of violation 338/89-12-01 and 339/89-12-01 (paragraph 4), this
matter is considered as a second example of the same violation.
Licensee
I-
management must address appropriate Type C testing of globe valves on both
l
units.
l
L
L
_ _ - - _ _ _ - - _
__
__
.
, , . ,
'
11
4.
Action'on-Previous Inspection Findings
(Closed):
Inspector Followup Items 338/87-33-01 and 339/87-33-01 pertain
to a correction factor applied to rotameters calibrated for atmospheric
pressure and used at 45 psig.
The licensee was to verify through the
vendor that the correction factor is valid for these instruments over a
range of 45 psig.
During review of procedure 2-PT-61.3, Containment Type
C Test, the inspector found that the procedure now requires that a
rotameter be calibrated for the pressure condition.
(Closed):
Unresolved Items 338/87-33-03 and 339/87-33-03, relate to the
licensee's evaluation of potential leakage through the bypass line on the
leak rate test rig.
The inspector reviewed the test results on the bypass
line of the test rig.
The test method verified that there was no bypass
leakage in the air admission valve of the test rig into the test volume.
Therefore previous leak rate testing results were acceptable.
The test on
'
the bypass line of the test rig was incorporated into the Type B and C
test procedures.
In 2-PT-61.3, Containment Type "C" Test, step 3.22 requires the bypass line
test be performed in accordance with attachment 6.5 to the procedure,
whereas the correct attachment number is 6.4.
The inspector informed the
licensee of the - incorrect numbering and asked that the problem be
corrected for all applicable type B and C test procedures.
The licensee
agreed to correct the procedures.
(Closed):
Unresolved Items 338/87-33-02 and 339/87-33-02 concerned the
local leak rate (Type C) testing of certain containment isolation valves
by applying test pressure in a direction different from the direction of
pressure to which the valve would be exposed in the event of a design
basis accident (i.e, reverse testing).
In that' there was insufficient
information available on which to evaluate the conservatism of these
tests, the licensee agreed to further evaluate the valves tested in a
reverse direction.
During this inspection, the inspector reviewed the licensee's evaluation
for . reverse testing which was approved as a justification for continued
operation (JCO) on October 9,1987 by SNSOC.
Six gate valves and seven
globe valves on Unit I were identified as nonconservatively tested in the
reverse direction. Also, as a result of the Type C test review, 15 valves
on Unit 2 were identified as nonconservatien tests.
l
Specifically, the valve design for single wedge gate valves is such that
l
the seat tested by application of pressure in the reverse direction is not
the seat which would be exposed to the accident pressure.
In the case of
the globe valves, the pressure applied in a reverse direction did not test
the packing which would be exposed to accident pressure.
Appendix J, Paragraph III.C.1 states, "the pressure shall be applied in
i
l
the same direction as that when the valve would be required to perform its
l
safety function, unless it can be determined that the results from the
_ _ _ _
_
E
_.
. _ _ _ _ .
_____ -
s
'
.
a
tests for a pressure applied in a different direction will provide
equivalent or more conservative results."
At the exit interview and in a subsequent telephone conversation June 30
1989, the inspector identified Violation 338/89-12-01 and 339/89-12-01 for
failure to meet the requirements of Appendix J to 10 CFR 50 in that:
a.
Type C tests on 13 valves on Unit I and 15 valves on Unit 2 were
being performed by applying test pressure in a direction other than
in the accident direction where this method was not as conservative
as applying the pressure in the accident direction.
b.
Twenty-four globe valves in each unit, identified in the licensee's
Engineering study 88-31, are Type C tested by applying pressure in a
direction which tends to seat the valves and is not as conservative
as pressure applied in the accident direction which would tend to
unseat the valves.
In that this problem relates to testing methods and is programmatic in
nature, only one violation, applicable to both units, is identified.
Issuance of this violation closes Unresolved Item 338/87-33-02 and
339/87-33-02.
5.
Exit Interview
The inspection scope and results were summarized on April 26, 1989, and in
a telephone conference on June 30, 1989, with those persons indicated in
paragraph 1.
The inspector described the areas inspected and discussed in
detail the inspection results listed below.
Proprietary information is
not contained in this report.
Dissenting comments were received from the
licensee,
a.
Violation 338/89-12-01 and 339/89-12-01:
Failure to Type C test
containment isolation valves by applying pressure in the accident
direction when pressure applied in a different direction is
nonconservative, paragraphs 3 and 4.
b.
Unresolved Item 338/89-12-02 and 339/89-12-02:
Verify submittal of
licensee's position that secondary systems remain pressure sealed
post accident for a sufficient time to allow containment pressure to
become subatmospheric to NRR for evaluation, paragraph 2.b(5).
Review the results of the evaluation.
c.
Commitments:
(1) Establish specific penetration draining instructions in
2-PT-61.1.
(2) Establish means of maintaining stable containment atmosphere
temperature.
I
_ _ _ . - - - . _ . - . - - - - - _ - - _ -
_ . - - - .