ML20066E059

Responds to NRC Re Violations Noted in IE Insp Rept 50-249/82-08.Corrective Actions:Typed Version of Calibr Records for Flow Meter Used During Induced Leakage Phase of Integrated Leak Rate Test Received from Vendor

ML20066E059
Person / Time
Site:	Dresden
Issue date:	09/13/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20066E051	List: ML20066E059
References
NUDOCS 8211120402
Download: ML20066E059 (6)

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[i )D Commonwealth

, Edison one First Nitionit Plaza. Chicago, Ilknois i

(V Address Reply to: Post Office Box 767 Chicago, Illinois 60690 September 13, 1982 Mr. James G. Keppler, Regional Administrator Directorate o f Inspection and Enforcemen t - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Subj ec t : Dresden Station Unit 3 Response to Items of Noncompliance in I.E. Inspection Report No.

50-249/82-08 NRC Docket No . 50-249 Re ference (a): C. E. Norelius letter to Cordell Reed dated July 29, 1982.

Dear Mr. Keppler:

Reference (a) provided the results of a routine safety inspec-tion conducted by Messrs. 1. Jackiw, F. Maura, and D. Robinson, o f your o f fice on April 20, 22-25, a nd Ma y 10 a nd 21, 19 82, of activities at our Dresden Nuclear Power Station Unit 3. During that inspection, certain activities appeared to be in non-compliance with NRC requirements.

The first item of non-compliance apparently resulted from our continuing attempts to shorten the duration of containment integrated leakage rate tests to less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, provided we obtain NRC concur-rence as specified in ANSI Standard N45.5-1972. We are continuing to seek your concurrence with these shorter tests. Howe ve r , the actual integrated leak rate test which was conducted for Dresden Unit 3 on April 24 and 25, 1982, extended for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance wi th ANSI N4 5.4-19 72, and Dresden approved procedure DTS 1600-7, Rev. 4.

Because a short duration test was not conducted, there was no need for DTS 1600-7 to specify a leakage calculation method which is in agreement with the technique specified in the Bechtel Topical Report BN-TOP-1. We believe, therefore, that the apparent item o f noncompliance is inappropriate and should be withdrawn.

The second item of non-compliance specifies that calibration records were not available for the flow meter that was used during the induced leakage phase o f the integrated leak rate test. The flow meter had been recalibrated by the vendor shortly before the test was conducted. We acknowledge that the time delays in obtaining a typed version of the calibration certificate from the vendor did not permit us to have a fermal calibration document available for the inspectors' 8211120402 821104 SEP 141882 DR ADOCK 05000249 PDR

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J. G. Keppler September 13, 1982 review during the test. However, the inspectors were shown the handwritten copy of the calibration data supplied to us by the vendor.

De have also now received the typed version of that certificate of calibration. Therefore we believe that we have been and remain in compliance with 10 CFR 50, Appendix B, Criterion XVII, which requires that sufficient records be maintained to furnish evidence of activities af fecting safety. We believe that an "open item" for subsequent review by your inspectors would have been more appropriate to document the concerns raised at the time o f this inspection, and that the apparent item of non-compliance should be withdrawn.

Please address any questions that you or your staff may have concerning this matter to this of fice. The date for submitting this response was discussed with Mr. W. Little of your o ffice in an August 27, 1982, telephone conversation.

Very truly yours, L. O. DelGeo rg e Director of Nuclear Licensing TJR/lm Attachment 1

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! l 1 COMMONWEALTH EDISON COMPANY i ATTACHMENT-A-i 1 j- RESPONSE TO NOTICE OF VIOLATION i

i-

, The ' items of non-compliance identified in Appendix A o f the NRC

! letter-dated July 29, 1982, are responded to in the following

• paragraphs:

4-t Item o f Non-Compliance i 1. 10 CFR 50, Appendix J, requires that all Type A tests shall be conducted in accordance with the provisions of ANSI N45.4-1972.

i ANSI N45.4-19 72 requires a lcakage rate test period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I

unless it can be demonstrated to the satisfaction of those respon-1 sible for the acceptance o f the containment structure that the

! leakage rate can be accurately determined during a shorter term period. BN-TOP-1, Revision 1, dated November 1,1972 (Bechtel Corporation's Topical Report) is the only short-term duration,

. general test method, which has received NRC's approval. BN-TOP-1, i Revision 1, requires that the data analysis be based on the total time calculations based on the ANSI N45.4 formulas.

l 10 CFR 50, Appendix B , Criterion V, requires that activities i affecting quality be prescribed and accomplished in accordance with documented procedures which include appropriate quantitative or

qualitative acceptance criteria ~for determining that the activities have been satisfactorily accomplished. -

j Contrary to the above, on April 24, 1982, the licensee was ready to j terminate the leakage rate data acquisition phase and start the i verification phase af ter approximately six hours of data acquisition, l based on the mass plot calculations which are not in accordance with l ANSI N45.4-1972, paragraph 7.9, and BN-TOP-1, Revision 1, Section

6. Before the start of the test, the licensee was aware that in i order to perform a short duration ILRT, he had to calculate the

! leakage rate based on the total time equations of ANSI N45.5 and

, BN-TOP-1.

In addition, test procedure DTS 1600-7, Revision 4, was inadequate in that it failed to address the requirements for performing a short-term duration CILRT, and personnel performing the test were not properly indoctrinated and trained to assure proficiency in the performance of short-term duration CILRT.

I Discussion i

! On April 24 and 25, 1982, a containment integrated leak rate test was i conducted for Dresden Unit 3 in accordance with Dresden approved i procedure DTS 1600-7, Revision 4. The test was conducted over a period j greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, which exceeds the testing time specified in ANSI N45.4-1972, and 10 CFR 50, Appendix J. The calculational method speci-4 fled in DTS 1600-7 is the mass plot calculation which is an acceptable i

O method and has previously been reviewed and approved by your staff for containment integrated leakage rate tests which extend for a 24-hour duration. Further, because the test did extend for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, DTS 1600-7, Revision 4, did not need to address the requirements for performing a short duration test, and personnel performing the test did not need to be indoctrinated and trained to ensure proficiency in the performance of a short duration test. Therefore, we see no basis for a

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non-compliance to 10 CFR 50, Appendix B, Criterion V, and believe that this non-compliance should be withdrawn.

The issues raised in the non-compliance apparently concern our intent to conduct a short duration test without incorporating the total-time equa-tions which are specified in Bechtel Topical Report BN-TOP-1, Revision

1. That calculational method is not included in the Commonwealth Edison integrated leak rate test computer program because we had not been infornied until just prior to the test that we needed to comply with the Bechtel Topical Report for a short duration test. We are unaware of any of ficial NRC document including 10 CFR 50, Appendix J, any Regulatory Guide, or Technical Specifications, which promulgates the Bechtel Topical Report as the only acceptable method of a short duration test. We have now reviewed the Bechtel Topical Report, however, and are incorporating the calculational techniques into our computer program.

However, in this instance, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test was conducted in accordance cith approved standards and procedures, and in our judgment this apparent item of non-compliance should be withdrawn.

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Item o f Non-Compliance

2. 10 CFR 50, Appendix B, Criterion XII requires that instruments and other testing devices used in itctivities affecting quality be properly controlled, calibrateJ, and adjusted at specified periods to maintain accuracy within necessary limits. Criterion XVII requires that sufficient records be maintained to furnish evidence of activities affecting safety. The records shall include qualifi-cation o f equipment.

Contrary to the above, cal.ibration records for the flowmeter used during the verification phase of the leakage rate test were not available at the site while the flowmeter was oeing used.

Discussion The flowmeter used during the verification phase of the leakage rate test had been calibrated on January 19, 1982, using instruments trace-able to NBS Standaros with the calibration period valid for six months.

On April 13, 1982, a second calibration was performed by the vendor who aas on site for other work associated with the integrated leak rate test. This second calibration was performed in the same manner as the original and resulted in minor changes to the previous calibration.

Because the calibration was performed so close to the beginning of the integrated leak rate test, the vendor was unable to provide us with a typed version of the certificate of calibration for the flowmeter prior to the actual test. However, the vendor did provide us with a handwrit-ten version of the calibration information, and this information was available for review by the inspectors during the test.

We have now received the formal typed certificate of calibration for the flowmeter. We believe that we are in compliance with Criterion XVII in that we have sufficient records to furnish evidence of activities af fecting safety.

De believe that the apparent item of non-compliance was issued prematurely in this instance and in our judgment should be withdrawn.

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3 I

Item o f Non-Compliance

3. Technical Specificaton 6.2. A states that detailed written procedures addressing surveillance and testing requirements shall be. prepared, approved, and adhered to. Station procedure DTS 1600-7, Revision 4, required that valve MO-3-1402-25A be in the closed position and valves S0-3-2301-29 and S0-3-2301-30 be in the open position during the performance o f ILRT.

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Contrary to the above, three valves, MO-3-1402-25A, 50-3-2301-29, and S0-3-2301-30, were found in positions other than those specified by the procedure.

Corrective Action Taken and Results Achieved For reasons discussed below, the test was conducted in the intenced manner and immediate corrective actions were not necessary, however, a temporary procedure change was written to document the acceptable position of /alves S0-3-2301-29 and S0-3-2301-30.

Corrective Action Taken to Avoid Further Non-compliance In accordance with Dresden approved procedure DTS 1600-7, certain valving arrangements are made prior to conducting an integrated leak rate test to assure the test is conducted properly. A checklist is attached to the procedure to specify the " desired position" of these valves prior to the test. All valves on the checklist were placed in the proper position snd were independently verified to be in that position. Then, caution cards were attached to the valves to indicate that they were placed in that position for the integrated leak rate test. However, the position o f valve MO-1402-25A was changed during the test because it was used as the means to maintain, as required by the procedure, reactor water level at 50 inches instrument level. To ensure there is no confusion in the procedure, a section will be added which specifies the normal makeup method o f maintaining a constant reactor vessel water level using the MO-1402-25A valve. Also , the checklis t will be changed to indicate that the valve is "normally closed" as opposed to just "c lo s e d " .

Valves S0-3-2301-29 and S0-3-2301-30 automatically isolated on high containment pressure (greater than 2 pounds pressure) during containment pressurization. We are preparing a permanent change to the procedure to vent the 2304 piping downstream of the isolation valves during the test. The position of these valves before or during the test in no way invalidated the test results.

Date When Full Compliance Will Be Achieved The procedure changes described above will be made prior to the date when the next containment integrated leak rate test is conducted at Dresden Station.

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