W3P90-1184, Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay

Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay

ML20059B456
Person / Time
Site:	Waterford
Issue date:	08/20/1990
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P90-1184, NUDOCS 9008290088
Download: ML20059B456 (4)

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August.20, 1990 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.- 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 90-14 5 Reply to Notice of Violation Gentlement' '

In accordance with'10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violation identified in Appendix A of the subject Inspection Report. >

If you have any questions concerning this response, please contact L.W. Laughlin at '(504) 739-6720, i Ver truly yours,

, , 'ush RFB/BRL/ssf .

. Attachment '

cc: Messrs. R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR E.L. Blake W.M. Stevenson R.B. McGehee NRC Resident ' Inspectors Office o n~Ui n **'cJ I

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Attachment to l

< - ',. W3P90-1184 Page 1 of 3 ATTACllMENT 1

[NTERGY OPERATIONS l INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A OF INSPECTION REPORT 90-14 VIOLATION NO. 9014-01 Failure to Comply with Technical Specification Requirements while Performing the Local Leak Rate Tests for Containment Penetrations Paragraph 4.6.1.2.d of Waterford Steam Electric Station, Unit 3 (W3) ,

Technical Specifications requires that Types B and C local leak rate tests be conducted with the test pressure (Pa) at 44 psig.

, Contrary to the above, the licensee conducted Types B and C local leak rate tests involving a number of containment penetrations, during the last three refueling outages, using a test method which allowed test pressure to drop below 44 psig during the test performance.

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This is a Severity Level IV violation.

RESPONSE

(1) Reason for the Violation Entergy Operations, Inc. admits this violation and as stated in ,

Licensee Event Report number LER-90-007-00, believes that the root  !

cause was an inadequate test proceduro governing the Local Leak Rate  !

Testing (LLRT) of containment isolation boundaries as required by the Waterford 3 Technical Specifications.

The NRC conducted an inspection _during the period of June 25-29,  !

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! 1990, which included a review of Yi containment local leak rate testing data. During this review, it wu noted that 31 containment .

L penetrations were local leak rate tested at test pressures less than the l l test pressure specified by W3 Technical Specifications. i W3 Technical Specification 4.6.1.2 requires that containment leakage rates shall be determined in accordance with the criteria specified in Appendix J of 10 CFR Part 50, and that Type B and C tests shall be conducted with gas at a pressure at Pa, 44 psig. Pa is the calculated peak containment internal pressure related to the leakage associated 1 with the design basis accident. Type B and C tests detect local leaks  !

and measure the leakage across pressure containing boundaries. Type B test penetrations are containment boundaries other than valves and type C test penetrations are containment isolation valves.

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Attathment to e

.- W3P90-1184  !

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The containment electrical penetrations were tested in accordance with W3 Surveillance Procedure OP-903-114, Local Leak Rate Testing (LLRT), which utilizes the pressure decay method. The pressure decay method involves pressurizing the test volume and measures the change in pressure over a period of time to calculate the leakage rate.

Section IWV-3423e of ASME Section XI allows the use of a correction factor, to correct for the decay in pressure, and normalize test results to the required test pressure. However, Procedure OP-903-114 did not include provisions for the use of a correction factor when the test pressure dropped below 44 psig. In those tests where pressure decay resulted in a test pressure less than 44 psig, the results (local leak rate) were kss conservative than they would have ,

been if a correction factor had been used.

(2) Corrective Steps That Have Been Taken and the Results Achieved ,

Immediate corrective actions included a review of LLRT activities conducted during the last three refueling outages. A total of 37 penetrations ( 31 penetrations in Refuel III were identified in the inspection, in addi!!on to 3 penetrations each from both Refuel I and Refuel II ) were identified as having been tested with test pressures less than 44 psig, without the appropriate correction factor applied to the test results. A correction factor was applied for each of the deficient p9netration tests using a maximum correction factor based on- '

paragraph IWV-3423(e) of ASME Section XI. The calculations resulted in leakage rate increases of 6.7 seem (standard cubic centimeters per minute) f or Refuel I, 2.3 seem for Refuel II, and 24.7 seem for Refuel III. Respective combined total leakage rates were calculated to be ,

36,275 seem for Refuel I, 102,733 seem for Refuel II, and 51,188 seem '

for Refuel III. The combined total leakage rates for each refuel's testing were below the W3 Technical Specification 3.6.1.2 allowable of 630,697 scem. Additionally, the adjusted leakage rate for each individual penetration was found to be acceptable and below given limits. Potentially Reportable Event number 90-33 and Licensee Event Report number LER-90-007-00 were issued in response to this concern.

In addition, a review of LLRT procedures other than OP-903-114 was conducted in an effort to identify additional deficiencies similar to those discussed above. This review did not identify any other deficiencies concerning the use of the pressure decay method for LLRT. A procedural update for OP-903-114 has been scheduled as a result of this review and the subject inspection. Prior to the procedural update, LLRT activities shall be administratively controlled to require the use of a test method other than pressure decay.

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.3 ,* ...- a W3P90-1184 Page 3 of 3  ;

(3)- Corrective Steps Which Will Be Taken to Avoid Further Violations Corrective actions planned, but not yet complete are as follows:

1) Revise _OP-903-114 to include nrauautions and limitations stating the minimum allowable test pressare of 44 psig as stated in Tech Spec 4.6.1.2.d.

2) Revise OP-903-114 to include a correction factor that normalizes ,

reduced pressure test leakrates to 44 psig. Lirait the use of the ;

correction factor to "Information Only" tests where excessive leakage is the cause of reduced pressure. An alternate ' test j method shall be used to validate any reduced pressure test. '

It is believed that the revision of this procedure, coupled with the review of similar test procedures, will prevent the potential for future violations in this area.

(4) Date When Full Compilance Will Be Achieved The procedures discussed above in Section 3 of this response will be ]

revised by September 30, 1990, at which time Waterford 3 will be in

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full compliance.

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