ML18057A258

Forwards Revised Response to Violations Noted in Insp Rept 50-255/89-26.Concurs That Tests Performed Using Instrumented Insp Technique During 1988 Refueling Outage Considered Invalid

ML18057A258
Person / Time
Site:	Palisades
Issue date:	06/01/1990
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006130419
Download: ML18057A258 (6)

See also: IR 05000255/1989026

Text

... * * consumers

Power POW ERi Nii NllCHlliAN'S

PROliRESS

General Offices: 1945 West Parnell Road, Jackson, Ml 49201 o (517) 788-1636 June 1, 1990 Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT -Kenneth W Berry Directdr Nuclear Licensing

RESPONSE TO NRG LETTER DATED NOVEMBER 2, 1989 ON VALIDITY OF PALISADES

PLANT RAFA TESTING AND REVISED RESPONSE TO NOTICE OF VIOLATION

DATED DECEMBER 8, 1989 Consumers

Power Company was informed by letter dated November 2, 1989 that tests performed

using the Instrumented

Inspection

Technique (IIT) during the 1988 refueling

outage are considered

invalid. The hydrostatic

test requirement

was met by utilizing

the Instrumented

Inspection

Technique, an NRG approved alternative

to the ASME code specified

method. As identified

by this NRG letter Consumers

Power Company was required to determine

the basis for the validity of the Instrumented

Inspection

Technique (IIT) testing conducted

at Palisades.

Consumers

Power Company has reviewed RAFA Topical Report 135 (P) and evaluated

the implementation

of the IIT methodology

at Palisades

and has determined

that this testing should be considered

invalid. This determination

is discussed

in Attachment

1. Also, as a result of this determination

we have revised our response to NRG Inspection

Report 255/89026

Notice of Violation. "Instrumented

Inspection

Technique" which was dated December 8, 1989. Our original response to this Notice of Violation

was dated February 6, 1990. Attachment

2 provides our revised response.

The affected systems which were tested at Palisades

using the IIT test ology include the main ste?m system (ASME Class 2) which was tested under test number R0-108 and the auxiliary

feedwater

system (ASME Class 3) which was tested under tests R0-109, R0-110 and R0-111. 9006130419

900601 PDR ADOCK 0500Q255 Q OC0690-0033-NL02 A GM5 *NE7?GYCOMPANY

• * Consumers

Power Company previously

judged these two systems functionally

operable by our letter dated November 13, 1989 to the NRC. Consumers

Power Company will bring the affected systems into full compliance

with the rules of Section XI_ of the ASME code during the upcoming refueling

outage (presently

scheduled

to commence September

15, 1990) by performing

the required system hydrostatic

tests on these systems. /;} . '

Kenneth W Berry Director, Nuclear Licensing

CC Administrator, Region III, USNRC NRC Resident Inspector

-Palisades

Attachments

OC0690-0033-NL02

• I . * * Discussion

of Determination

of Validity ATTACHMENT

1 Page 1 of 2 In an attempt to resolve the question of validity of the testing performed

for these two systems, Consumers

Power Company contracted

the firm Dunegan Engineering

Consultants

Inc _to perform an independent

review of the entire scope of RAFA testing at Palisades.

Mr Harold L Dunegan, PE performed

the review. The scope of Mr Dunegan's

review was all inclusive

in that he reviewed:

RAFA Topical Report 135 (P); all completed

test records at Palisades;

NRC letters dated November 2, 1989 and December 8, 1989; and Palisades

letter to the NRC dated February 6, 1990. Mr Dunegan also visited the RAFA offices in Rivieria Beach, Florida to ask technical

questions

of the personnel

who performed

the testing at Palisades.

Results of his review indicate that the testing could be valid. Justification

would have been based on the fact that if leaks were to develop from the pressure boundary they would have been detected and approximately

located with test instrumentation

which was utilized.

A case in point being that the only leak detected during the R0-108 test was identified

by 3 channels of the acoustic emission equipment.

However, Mr Dunegan concluded

that test results and the technical

information

necessary

for interpretation

or evaluation

of the results were not adequately

reported.

Additionally, problems with certification

of test personnel

were noted. Based on the results of Mr Dunegan's

review, and our own evaluation

we have come to the conclusion

that the RAFA testing performed

at Palisades

should be considered

invalid. Palisades

does not presently

intend to use the Instrumented

Inspection

Technique

in the future. However, if we were to consider using this technique

the following

would be required:

1. An approved topical report addressing

testing of systems using leak monitoring

devices and acoustic leak sensing equipment, and a separately

approved topical report for testing steam filled systems utilizing

acoustic sensors. 2. Attenuation

measurements

must be taken on pipes where more than 50 feet separate valves where sensors are located. 3. A relative calibration

of the waveguide-sensor

combination

to an equivalent

sensor calibration

without a waveguide

must be performed.

4. Technical

data explaining

acceptance

and rejection

criteria of acoustic emission data must be provided.

5. A data log must be kept of acoustic emission response from known leak rates measured in the field and leak rates measured in a test loop . OC0690-0033-NL02

• ATTACHMENT

1 Page 2 of 2 6. Criteria for data acquisition

and evaluation

of situations

requiring

multiple channels of information

to be acquired simultaneously

must be established.

7. An acceptable

calibration

scheme to assure that each channel from sensor-couplant

through electronics

output is operational

and unchanged

must be established.

8. Pressure-time

and temperature-time

curves for each test showing when and where acoustic emission data was taken must be provided.

9. An acoustic emission time curve must be taken for each channel, with at least 10 minutes of background

baseline data with zero flow, and at constant pressure at 50% of proof test pressure.

10. Test data must be reported in a form that will allow an independent

reviewer to evaluate the data. 11. Predetermined

leak rate acceptance

criteria must be included within the test procedure

for measuring

system leakage using leak monitoring

devices. 12. Leak monitoring

devices must be provided for all test boundary valves. 13. Strict compliance

to ANSI N45.2.6 regarding

certification

of test personnel, must be required.

OC0690-0033-NL02

• * * ATTACHMENT

2 Page 1 of 2 Revised Response to Inspection

Report 255/89026

Notice of Violation, "Instrumented

Inspection

Technique" Consumers

Power Company previously

submitted

a response on February 6, 1990 to respond to Inspection

Report 255/89026

Notice of Violation, "Instrumented

Inspection

Technique" dated December 8, 1989. This response is provided as revision to our previous response.

Notice of Violation

255/89026-lA

Interim and post verification

of channel sensitivity, considered

a prerequisite

for acoustic testing was neither performed

nor required by the procedures.

Consumers

Power Company previous response to this item is retracted

and our revised response is that we agree with the NRC's position and accept the tion as written. Notice of Violation

255/89026-lB

The lack of qualified, well designed relationship

between background

noise * level and leak detection

sensitivity

did not permit evaluation

of the bility of environmental

conditions

encountered

during the test . Consumers

Power Company previous response to this item is retracted

and our revised response is that we agree with the NRC's position and accept the violation

as written. Notice of Violation

255/89026-lC

The test procedures

did not define the acceptance

criteria and insufficient

instrumentation

was used. Consumers

Power Company response to this item is retracted

and our revised response is that we agree with the NRC's position and accept the violation

as written . OC0690-0033-NL02

' * * * Corrective

Steps Taken and Results Achieved ATTACHMENT

2 Page 2 of 2 An interim operability

evaluation

of the affected systems (main steam and auxiliary

feedwater)

was prepared and submitted

to the NRC on November 13, 1990. This evaluation

determined

that the affected systems are operable and fully capable of performing

their intended safety functions.

Corrective

Steps to Avoid Further Violations

Consumers

Power Company has determined

that the instrumented

inspection

technique

as implemented

at Palisades

is invalid and will not utilize the technique

in the future unless the issues identified

in Attachment

1 to this letter are suitably addressed.

Additionally, the affected systems will be retested to ASME code requirements

during the upcoming refueling

outage. Also, HAFA has been removed from the Consumers

Power Company Nuclear Operations

Department

Approved Suppliers

List. Date When Full Compliance

Will Be Achieved Consumers

Power Company will bring the main steam system and the auxiliary

feedwater

system into full compliance

with the rules of ASME Section XI during the upcoming refueling

outage by performing

the required system hydrostatic

tests on these two systems prior to completion

of this scheduled

outage . OC0690-0033-NL02