ML20248A443
| ML20248A443 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/27/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8908080272 | |
| Download: ML20248A443 (4) | |
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$u ?e'a"luunnra MEMEAAr5 Peasawsc General off ces: 1945 West Pernall Road, Jackson, MI 49201 e (517) 7881630 l
July 27, 1989 l
l Nuclear Regulatory Commission l
Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
RESPONSE TO INSPECTION REPORT 85-020 - CONTAINMENT INTEGRATED LEAK RATE TEST l
l (CILRT)
Big Rock Point is scheduled to perform a Type A Integrated Leak Rate Test of the containment during the 1989 Refueling Outage.
The following is provided 1
to inform you of current plans for the 1989 ILRT and resolution of items resulting from the previous ILRT, performed in 1985; as documented in Inspection Report 85-020 dated November 21, 1985.
Current piens are to start the ILRT during the period of July 24-28, 1989.
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The test will be performed in accordance with the method described in Bechtel 1
Report BN-TOP-1, Rev 1 instead of the " mass point" method used in the previous tests. As discussed in our Technical Specification Change Request dated May
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25, 1989, use of this method should reduce the impact of diurnal effects which inherently cause testing problems due to the Big Rock Point containment design. If the Bechtel short duration test is inconclusive, the test will default to the conventional 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> method.
Associated with use of the Bechtel method was a need to remove a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration restriction contained in the Big Rock Point Technical Specifications.
The change request submitted May 25, 1989 did address this issue and has been reviewed by NRR personnel including the Big Rock Point Project Manager. Per conversations with the BRP Project Manager, all questions / comments associated with the change request have been resolved and the Amendment is in the proces-sing stage, however, issuance is not expected until after July 28, 1989 due to the 30 day Federal Register posting requirements.
In reviewing this timing, it was mutually agreed that the Bechtel type test could be conducted prior to receipt of the Amendment. Final acceptance of the results from the Bechtel type test and submittal of the 1989 ILRT Report would occur after receipt of the Amendment. This position has been discussed with the Big Rock Point Project Manager.
8908080272 890727 PDR ADOC.K 0500 5
l OC07 9-0009-NLO2
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. Nuclear Regulatory Commission Big Rock Point Plant Response to IR 85-020 (CILRT)
July 27, 1989 l
The Five open items rerulted from the 1985 ILRT Inspection Report 85-020 and their reaolution are:
I 1.
" Step 3.12 allows local leak rate test corrections to be made to the Type A test results. The inspector noted that this is the only place in the procedure that refers to correcting the Type A test results and is vague in that it does not specify what type of correction (s) is to be made. The inspector stated that provisions should be made in the procedure to l
monitor all water levels in containment and assign a penalty to the Type A test results if water levels increase during the test (e.g.- steam drum);
monitor the pressure of any unvented pressurized vessel within containment and take a penalty if pressures decrease during the test (e.g. - control rod drive accumulators); take penalties for penetrations that should, but are not, exposed to the Type A test pressure. This is considered an open item (155/85020-01(DRS)) pending inspector review of the revised CILRT procedure."
l Resolution - The 1989 CILRT procedure now provides instructions for correcting Type A test results due to the itens listed above.
I 2.
"The inspector noted that the procedure has no data rejection criteria to determine if a sensor is faulty or if whole data sets are bad. Thr inspector stated that the only time sensors / data sets may be rejected is l
if they satisfy these rejection criteria or a strong physical reason exists to do so (e.g. - sensors output goes to zero/ data is invalidated l
due to inadvertent pumping of air into containment). This is considered an open item (155/85020-02(DRS)) pending the inspector's review of the revised CILRT procedure."
l Resolution - The procedure now requires that all sensor data be used and rejection occur, only after evaluation. This evaluation, where a sensor is susp ct, will be conducted using the guidance of Appendix D of ANSI /ANS
- 56.8.
3.
" Step 5.33 pertaining to the use of the Integrated Leak Rate Monitoring system specified that data is taken at 15 minute intervals and after any 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of successive data, the data are compiled and a final integrated leakage rate will be computed. This step implies that if a test took 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> or greater to obtain satisfactory results, it would be acceptable to l
use the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of data for the official test results. This inter-pretation was confirmed when the inspector questioned licensee personnel involved in the test.
The inspector informed the licensee that this is not acceptable and that all data must be used unless a legitimate reason (e.g. data rejection criteria, physical anomaly or inadvertent change in tu,t conditions) exists not to use certain data. This is considered an open item (155/85020-03(DRS)) pending the inspector's review of the revised CILRT procedure."
Resolution - The procedure now requires that all data from the declared
" start of test" will be used unless a legitimate reason exists.
l OC0789-0009-NLO2 1
Nuclear Regulatory Commission 3
Big Rock Point Plant Response to IR 85-020 (CILRT)
July 27, 1989 4.
"The inspector noted that the procedure specified that the size of the superimposed leak for the purpose of the supplemental verification test be 0.75 La.
This is contrary to the requirement of ANSI N45.4-1972 and is not consistent with the NRC position that the quantity of gas bled from containment be between 0.75 and 1.25 La.
The inspector ensured that the size of the superimposed leak for this test was greater than 0.75 La.
This is considered an open item (155/85020-04(DRS)) pending the inspector's review of the revised CILRT procedure."
Resolution - This requirement has been addressed in the revised procedure.
See Section 5.10.b.
5.
"To insure the licensee's understanding of how to calculate an as found penalty the inspector and a member of the licensee's staff went over in detail the methods to determine an as found penalt, The following is a summary of what was discussed:"
(1) In the case where individual leak rates are assigned to two valves in series, the penetration through leakage would simply be the smaller of the two valves' leak rates.
(2) In the case where a leak rate is obtained by pressurizing between two isolation valves and the individual valve's leakage is not quantified, the as found penetration through leakage would be 50 percent of the measured leakage and the as left penetration through leakage would be
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zero (this assumes one or both of the repaired valves leaks zero).
l (3) In the case where a leak rate is obtaincd by pressurizing between two isolation valves and only one valve is repaired, the as found penetra-l tion through leakage would conservatively be the final measured leak rate and the as left penetration through leakage would be zero (this assumes the repaired valve leaks zero).
"The inspector stated that the licensee should incorporate the above methodology into a procedure to ensure the correct interpretation of the requirements in the future. This is considered an open item ('55/85020-05(DRS)) pending the inspector's review of the procedure."
Resolution - The revised procedure now addresses the " minimum pathway" methodology to correct any repairs or adjustments to determine as-found conditions.
Per conversations with Mr. I. N. Jackiw of Region Ill, Consumers Power under-stands that a Region III Inspector will not be available to cover this test and that the Recident Inspector will menitor test performance. Tor this reason, a copy of this response and the test procedure will be provided to the Resident Inspector.
OC0789-0009-NLO2
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,Nyclear Regulatory Commission 4
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Big Rock Point Plant i
Response to IR 85-020 (t % RT) l July 27, 1989 l
Based upon the actions taken, Cor:<umers Power Company concludes adequate l
resolution of the concerns addressed by the Open Items.
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Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspe.ter - Big Rock Point l
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l OC0789-0009-KLO2
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