IR 05000338/1987033

Insp Repts 50-338/87-33 & 50-339/87-33 on 870928-1002.No Violations or Deviations Noted.Major Areas Inspected:Review of Containment Isolation Sys Local Leak Rate Program, Including Review of Test Procedures & Valve Alignments

ML20236R798
Person / Time
Site:	North Anna
Issue date:	11/17/1987
From:	Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236R793	List: IR 05000338/1987033 ML20236R791
References
50-338-87-33, 50-339-87-33, NUDOCS 8711240033
Download: ML20236R798 (7)

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@ Riou UNITED STATES '

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o NUCLEAR REGULATORY COMMISSION

[ n REGION 11 g j'  ; 101 MARIETTA STREET. .

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• 2 ATLANTA, GEORGI A 30323

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Report Nos.: 50-338/87-33 and 50-339/87-33

.i Licensee: Virginia Electric and Power Company -

Richmond, VA 23261 .j

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I Docket Nos.: 50-338 and 50-339' License Nos.: NPF-4 and NPF-7-

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Facility Name: North Anna 1 and 2 Inspection Conducted: September 28 October 2, 1987-Inspector: N I //l /[o,f./ // - / d" l'7 ff. ' L . Whi te n b r Date Signed Approved by: '

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Date Signed'

F. Jape, Chief /

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Test Programs Section Division of Reactor Safety SUMMARY-Scope: This routine, unannounced inspection was in the areas of review of the-containment isolation system local leak rate program including review of. test procedures, valve alignments and observation of; testin l Results: No violations or deviations were identifie I

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REPORT DETAILS ~

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l Persons Contacted

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Licensee Employees

~* W. Harrell,LStation Manager

• E. Kane, Assistant Station Manager .. .

• L. Bowling, Assistant. Station Manager, Nuclear Safety and Licensing 1

• J. A. Stall, Superintendent, Technical Services-

• 0. A. Heacock,-Supervisor, Surveillance and Test Engineering

• P. A. Pendergast, Surveillance and Test Engineer i

• G. Harkness, Lice'nsing Coordinator J J. Leberstein, Licensing Engineer L. Lane, Controi Room Operator NRC Resident Inspectors

• J. Caldwell, Senior Resident Inspector L. King, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on October 2,1987, withL those persons indicated in paragraph.1' above. -The inspector described the areas inspected and discussed in detail .the inspection finding No' :)

dissenting comments were received from the license d The following new items were identified during this inspection:

.] Inspector Followup Item 338/87-33-01 .and 339/87-33-01: Review licensee's evaluation of the use of the. vendor rotameter calibration l correction factor for deviation of 45'psig (Paragraph 5.b.-). j 1 Unresolved Item 338/87-33-02 and 339/87-33-02: Review ' licensee's 1 l evaluation of reverse testing. of containment . isolation valve l L (Paragraph 5.b.). q

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' Unresolved Item 338/87-33-03 and 339/87-33-03: Review licensee's evaluation of potential leakage through the bypass line on~the leak :

rate test rig (Paragraph 5.c.), i The licensee did not identify as proprietary any of the. materials provided; l to or reviewed by the inspector during this inspectio !

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Licensee Action 'on Previous' Enforcement' Matters This subject.was not addressed'in the inspectio I Unresolved Items ,

Unresolved items are . matters about which more .iriformation is required to ~ l determine whether . they are acceptable ~ or may ' involve : violations or- l

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deviations. Two unresolved items related to ~ each unit 'and: identified-during this inspection are discussed in paragraphs.5.b. and . Containment Local. Leak Rate Test Program Units 1 and 2 (61720)

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-1 plant Procedures-The inspector reviewed the overall local.. leakage -rate program : for.-

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North Anna to verify that procedures 1 have been - developed :and implemented consistent with the regulatory requirements. Documents'

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reviewed either totally, or in part, included:

(1) 2-PT-61.3.4, " Total Leak Rate Calculation" The procedure establishes the controls for tracking and summing .

the individual Type .B and ~C local ' leak rate tests to verify that

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leakage is within the. limi (2) 2-PT-61.2.3, " Containment Type B Test - Equipment Hatch"'

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(3) 2-PT-61.2.1, " Containment Type B. Test - Electrical Penetrations" l (4) 2-PT-61.2.2, " Containment Type B Test - Fuel Transfer-Tube" (5) 2-PT-61.3.2, " Containment Purge Valves Type C Test - As Found" (6) 2-PT-61.3.3, " Containment- Purge Valves Type C Test - As Lef t

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(7) 2-PT-61.1, " Containment-Airlocks - Leakage Rate" The procedure specifies the instructions for the. full press'ure

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test of the airlock I (8) 2-PT-61.3, " Containment Type C Test"

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Based on the review of portions of the 'above procedures ona : sampling - q

[~ basis, the inspector concluded that the licensee has developed 4 and .

implemented procedures which address the essential' elements--of- the - ,

local leak rate test regulatory-requirement '

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I Comments'On' Test Procedures During the procedure review, some concerns L were . identified and discussed with the licensee. These items do' not affect the above ,

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conclusion that the local. leak rate test program .is defined, buti relate more to test. method :(1) 2-PT-61.3.2, " Containment Purge Valves Type C Testi"As found" In ' this' procedure, and . several' other . test procedures, : the .

inspector identified anomalous statements: relating "to' the-

- calibration of. flow meters as follows:-

"Whenever possible, use a rotameter that was calibrated at 45: l psig when testing by the make up method. When-.possible,- usef a -)

rotameter that was calibrated. at 14.7 psia whe'n testing.by th .;

leak through method- . If..a. rotameter must.be used at a' pressure other than its calibration pressure, multiply the indicated: y

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reading by the appropriate correction factor. gi'en; v in .

.. Attachment Show the calculation in theLremarks section-and '

record the corrected leak rate." j The correction. factor referenced above is.prov'ided'in the vendor  ;

manual as follows: l F = F IPt.x Tcl 1/2 lPc Ttj 'j l_ _I o

Where: i F'is'the corrected flo Fo is the indicated flow on the rotameter calibrated scal Pt is.the test absolute pressur Pc is the instrument calibration absolute pressure,:

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Tc is the ins _trument calibration temperature ( R).

Tt is the test temperature ( R). u The NRC would normally expect a test p'rocedure to; specify that l l the instruments to be usedm are calibrated. for the appropriate-test condition The concern is ' that the correction? factor, .

which is acceptable for minimal differences from'.the calibrated-conditions, may introduce. an -error when used to ' correct 1 differences of the order of 45-psi. If an error is introduced, l the measure of flow could- be. outside ' of- the 2% < accuracy specified for instrument calibratio . -l o

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i; At the exit interview, licensee management agreed to verify th validity of the correction factor, for the flow instruments.and; range of pressures specified in the test' procedure'with the flow meter vendor. This matter is identified as

Inspector Followup Item (338/87-33-01 and s 339/87-33-01):

Review the evaluation for, using the rotameter correctio factor in the vendor's manual for ,the' range of- pressure specified in the Type B and C leak rate. test 1 procedure (2) 2-PT-61.3, " Containment Type C. Test"

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The inspector reviewed a small sample of. the. valve alignments

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l .for Type C testing'and determined that:in some_ cases,;where both.

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isolation valves were L located outside L containment, .the local .

test was performed by; presurrizing ;between 'the valves. This-results in testing the inner valve.in~the reverse (non-accident).

direction. Discussion with the lice'nsee indicated thatL some of:

j these' valves were globe - or_ gate = valves which arei not"normally

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considered conservative when tested -in the. reverse directio Sufficient detailed . information on: which - to evaluate 'the conservatism of these tests . was : not' available- .in the' test -

procedure. At the exit interview,.the licensee? agreed to review the test valve alignments to. identify the ' valves-. tested in the .

reverse direction; the type. of Evalves; and/ the in .line j orientation of the seat, packing Land bonnet ' seals. This- ,j evaluation along with the. justification for considerin'g the 1 tests conservative will tue provided to .the NRC' for review. In a subsequent telephene call between Plant Management an Region II, October 9, 1987,Lthe 1,1censee further agreed that any ,

valves identified with untested boundaries, such asi packing,  ;

would be properly tested prior'to startup'of either Unit 1 or '

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This matter was identified as:

Unresolved Item (338/87-33-02 and . 339/87-33-02): . Review- 1 licensee's evaluation . for reverse testing sof containment isolation valve i

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c. Observations-

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The inspector witnessed the Type C test on Penetration'No. 89, Air Ejector Vent. The test was conducted in~accordance with'an. approved;

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procedure which was present at the test' site. .When this test failed-to meet the leaksge limit, the test? personnel processed work. requests; '

to have the penetration . repaired. The ' maintenance procedure- d contained instructions that subsequent to maintenance aclocal lea !

rate test must be performe Control of pre- and post-maintenance =

leak rate testing is discussed further;in paragraph . _ _ - - _ _ _ _ _- -_- .-

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During the test, the inspector observed that ' leak - rate . test ' rig

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utilized a bypass' line. which bypasses othe flow meters for rapid pressurization of the test volum Isolation .of the . bypass line during .a test is provided by. an air admission valve which is not-routinely checked for leak tight isolation ~ of' the. bypass lin If-the air admission ' valve leaks,. the , potential exists for make-up air g flew to the test volume 'which is; not detected by the flow meter At the exit' interview,- licensee management agreed to ' verify that there is no bypass leakage in' the air admission valve of'the test. rig

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which will affect previous test results and to. establish a' positive method for ensuring isolation of the bypass lin This matter was identified as:

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. .. 1 Unresolved ' Item '(338/87-33-03 'and' 339/87-33-03):- . Review- .l licensee's verification that previous Type B and C test results 3 are acceptable-and action takenLto ensure that_no bypass leakage 1 can occu ] Test Results

.f The controlling procedure for local- leak rate testing, PT-61. requires that a leak rate logbook will be maintained which confirms and updates the containment . leakage status. Only Type.B and C leak rate measurements related to the--0.6 La limit - are recorded in this-log.

l Review of the log showed that Type B and C; testing . since the j l integrated leak rate tests in 1984 had been performed'at the required j l frequency for both units. The as left leak rate was in general no i more than one half of the allowable-leakag ;

, Additional Leak Rate Areas Reviewed Type A Leak Rate Test l

The Safety Evaluation Report (SER), Supplements to the ' SER, and portions of Chapter 6 of the- updated. FSAR (UFSAR) we're' reviewed . to i identify any exemptions to Appendix'J- and the isolation l boundary requirements for the integrated leak rate- (Type A) te s t -. 'No Appendix J exemptions were identified in the SER and Supplements In ;

Chapter 6 of the UFSAR, - Table 6.2-72 identifies _ the penetration- -'

alignment for.the Type A test. This -table. was added 'to the UFSAR subsequent to NRR review of the initial FSAR and is not addressed in-the SER and Supplements. There are 'eight explanatory notes to this

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table some of which indicate that Type C leakage corrections will not be made for certain systems which will be flooded and operating, or isolated, during the Type A test. Also', the Type'A test procedure is

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in the process'of revision and not available for' review at this tim At the exit interview, the inspector 1 informed :the licensee that'

review of the table and Type A test'. procedure _would'be performed'at a-

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future time consistent.with the next scheduled Type A tes b. "As found" Leak Rate The licensee stated that determination of the "as found" integrated leak rate will be controlled by the Type A test j procedure. ' This-procedure is in the process of. revision and was. not' available for review.at this tim However, the inspector'was able<to' determine?

that the licensee has established the control. process to ensure _that'

pre- and post-maintenance leak rate data are obtained for containment I isolation. va l v'e s . This control .is established 'through the maintenance procedures'and work order system. The Shift; Supervision -i is responsible for determining . the pre and post-maintenance leak 1

rate testing requirements and - assuring. that these requir.ements ' are ;

identified and performed. The inspector reviewed a general valvet maintenance procedure,- MMP-C-6V- The ._ shift : supervisor .i s: s responsible for identifying ~t he required leak' rate testing .i n Attachment 4.0 of this procedure by periodic Ltest procedure numbe q i The inspector concluded that the licensee has established controls .to i obtain the leak rate data required - to determine the "as found" integrated leak rate. The control and. processing- of this = data will; be reviewed in relation to the Type A test at a future time.

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