ML20137W225

Insp Repts 50-369/85-39 & 50-370/85-40 on 851015-1108. Deviation Noted:Failure to Complete Preoperational Testing of Control Room Ventilation Sys Per FSAR Commitments

ML20137W225
Person / Time
Site:	Mcguire, McGuire
Issue date:	12/02/1985
From:	Cline W, Gloersen W, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137W136	List: ML20137W133 ML20137W198 ML20137W225
References
50-369-85-39, 50-370-85-40, NUDOCS 8512100203
Download: ML20137W225 (9)

See also: IR 05000369/1985039

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A Kthq UNITED STATES

So NUCLEAR REGULATORY COMMISSION

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o REGION 11

101 MARIETTA STREET, N.W.

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• * ATLANTA, GEORG! A 30323

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DEC 0 41985 ,

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Report Nos.: 50-369/85-39 and 50-370/85-40

Licensee: Duke Power Company  !

422' South Church Street  !

Charlotte, NC 28242

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Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 l

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Facility Name: McGuire 1 and 2

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I Inspection Conducted: October 15 - November 8, 1985 i

Inspectors: Wp(3 bo 'l BuyIk l%$

G. B'. Kulo Date Signea

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h s. 6 L a 'i. 0,odu M i

(n W. B. Glt)er en A Date Signed j

. Approved by: y M fo/.2/fy"

W. E. Cl}fef Seciion Ckfef Date Sigr.ed  !

Emergency Preparedness and Radiological i

Protection Branch

-Division of Radiation Safety and Safeguards i

SUMMARY

Scope: -This special announced inspection involved 85 inspector-hours in the

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areas of preoperational testing _ n. adequacy of surveillance activities l

regarding control room and auxiliary building ventilation systems. -

Results: One deviation was identified - failure to complete preoperational I

testing of the Control Room Area Ventilation (CV) system in accordance with FSAR ,

commitments. l

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8512100203 851204

DP ADOCK 05000369

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• R. L. Gill, Licensing

• • D. J. Rains, Superintendent of Maintenance

• • B. H. Hamilton, Superintendent of Technical Services

• • M. Sample, Superintendent of Integrated Scheduling

• • R. A. Johansen, Test Engineer, Surveillance

• • D. S. Marquis, Performance Engineer

• • N. McCraw, Compliance Engineer

• • P. Roberson, Associate Engineer, Performance

Other licensee employees contacted included technicians, and office

personnel.

• Attended exit interview October 17, 1985 .

• • Attended exit interview October 17, 1985, and November 6, 1985

2. Exit Interview

The inspection scope and findings were summarized on October 17, 1985, with

those persons indicated in Paragraph 1 above. The inspectors discussed the

need for _ evaluation of preoperational filter system testing of the auxiliary

building ventilation system (Paragraph 5) to ensure adequacy of Technical

Specification (TS) surveillance requirements to demonstrate operability.

The inspectors informed licensee representatives that the status of

preoperational testing of the control room area veinti'.ation system would be

considered an unresolved item subsequent to revius of all testing and

engineering evaluation records by cognizant NRC management. Licensee

representatives acknowledged the inspectors' comments. On November 6, 1985,

the inspectors informed licensee representatives that the unresolved item

concerning failure to conduct a proper air-aerosol uniformity mixing test

for the control room area ventilation system as detailed in the FSAR was a

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deviation (Paragraph 5). Licensee representatives acknowledged the

inspectors' comments and did not identify as proprietary any of the material

provided to or reviewed by the inspectors during this inspection.

-3. Licensee Action on Previous Enfcrcement Matters

(0 pen) Deviation 50-369/85-30-02 & 50-370/85-32-01: VA Filter Testing not

. performed per the FSAR and Regulatory Guide 1.52. This item will remain

open subsequent to receipt of formal response from licensee.

(Closed) 50-370/85-30-03 & 50-370/85-32-02: VA Filter Testing Adequacy.

Following review of data provided from supplemental filter testing of the

Unit 1 & 2 VA systems (Paragraph 8.a), the VA system was deemed adequate to

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perform its intended function and surveillance activities were deemed

acceptable to demonstrate system operaoility as specified by Technical

Specifications.

4. Unresolved Items

Unresolved items were not identified during the inspection.

5. Filter Testing (92702)

a. The inspectors reviewed Unresolved Item (50-369/85-30-03,

50-370/85-32-02) concerning preoperational nuclear air-cleaning filter

testing for the Auxiliary Building Filtered Exhaust Systems (VA). The

inspectors noted that the Unit 1 VA system failed the Air Distribution

Test and testing was not conducted for the Unit 2 system as described

in Section 8.3.2 of ANSI N510-1975, Testing of Nuclear Air-Cleaning

Systems. Section 9.4.2.3 of the McGuire Nuclear Plant FSAR detailed

in place testing of the VA systems to be in compliance with Regulatory

Guide 1.52, Design, Testing, and Maintenance Criteria for Post-Accident

Engineered Safety Feature Atmosphere Cleanup System Air Filtration and

Adsorption Units of Light Water Cooled Nuclear Power Plants.

Furthermore, Regulatory Guide 1.52 obligated the licensee to ANSI

N510-1975.

The inspectors reviewed preoperational test procedure TP/0/A/1450/02,

Preoperational Filter Test for Auxiliary Building Filtered Exhaust

Trains 1 & 2, dated 1/27/81, and noted that airflow distribution tests

were not within the 20% of the average velocity for the Unit 1 system

as required by ANSI N510-1975. Furthermore the inspectors noted that

airflow distribution tests had not been conducted for the Unit 2 VA

system. The licensee responded to this air distribution test failure

by contracting a vendor to perform an engineering evaluation of the VA

system. The evaluation consisted of a laboratory study of HEPA filter

efficiency as a function of air velocity. The inspectors reviewed the

laboratory test results and noted that the completed tests did verify

HEPA filter efficiency but did not evaluate the adequacy of the airflow

distribution as required. The inspectors informed cognizant licensee

representatives that the laboratory study did not meet the

preoperational air distribution test requirement of Section 8.3.2 of

ANSI N510-1975. In addition the inspectors noted that this air

distribution test was a prerequisite for in place leak testing of the

installed system required by Technical Specification 4.7.7.b to

demonstrate operability.

The inspectors discussed with cognizant licensee representatives the

revised ANSI N510-1980 and its guidance on performing the air

distribution test. Differences between the 1980 Standard relative to

the 1975 Standard for conducting the air distribution test are: (1)

velocity measurements are preferably made downstream of the HEPA

filters to improve air flow distribution entering the charcoal absorber

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beds; (2) for filter banks containing ten or more filters, the

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minimum number of velocity measurements will be one in the center of

each filter; and (3) for systems containing fewer than ten HEPA

filters in a single bank, the minimum number of velocity measurements

will be ten and will include one reading in the center of each filter

in the bank. Following telephone discussions among NRC Region II,

Office of Nuclear Reactor Regulation, and cognizant licensee

representatives a Confirmation of Action Letter (CAL) detailing use of

ANSI N510-1980 for evaluation of air distribution in the VA systems was

issued (Paragraph 6).

b. In addition, the inspectors reviewed the preoperational filter testing

for the following systems: Annulus Ventilation, Containment Purge,

Spent Fuel Pool, and Control Room Area. For all systems, excluding the

Control Room Area Ventilation (CV), the required preoperational tests

were conducted in accordance with ANSI N510-1975.

c. From review of TP/1/A/1450/01, Preoperational Filter Test for Control

Area Outside Pressure Train 1 & 2, dated 1/19/81, the inspectors noted

that both the air distribution and the air-aerosal mixing uniformity

tests as described in Sections 8 and 9 of ANSI N510-1975 were deleted

from the procedure. Licensee representatives informed the inspectors

that a thorough search was in progress to determine the status of

completion and/or if any engineering evaluations regarding

preoperational testing of the CV system was conducted. Following

discussion between NRC and cognizant licensee representatives, a CAL

requesting verification of completion of all prerequisite tests

pursuant to ANSI 510-1975 for the CV system (Paragraph 6) was issued.

In a letter dated October 29, 1985 to NRC Region II, licensee

representatives stated that the CV systems contain only one HEPA filter

and the air distribution test was deemed unnecessary. Cognizant NRC

Region II and NRR personnel concurred with this interpretation for

elimination of the air distribution test. However, the inspectors

informed licensee representatives that valid in place testing of the

Control Room Area Ventilation system would not be pcssible without a

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uniform air-aerosol tracer-air mixture. In their response dated

October 29, 1985, cognizant licensee representatives deemed the

air-aerosol mixing uniformity test unnecessary based upon the updated

ANSI N510-1980 standard. The inspectors informed licensee

representatives that Sections 6.4.3 and Table 6.2.3.-4 of the FSAR

stipulated that in place testing of the Control Room Area Ventilation

(CV) Systems was in compliance with Regulatory Guide 1.52 (Revision 2,

March 1978) which in turn obligated the licensee to ANSI N510-1975.

Furthermore, the inspectors informed licensee representativcs that

Section 9 of ANSI N510-1975 Air-aerosol Mixing Uniformity Test is

required and considered a prerequisite for required surveillancs tests

described by Technical Specifications. In view of the above findings,

the inspectors informed licensee representatives that the

preoperational tests performed on the CV systems were not performed as

documented in the FSAR and .would be considered a deviation to

documented FSAR commitments (50-369/85-39-01, 370/85-40-01).

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One deviation was identified - failure to conduct preoperational testing of

the CV system as committed to in the FSAR.

6. Confirmation of Action Letters (92702)

After discussion and review of the VA and CV systems preoperational filter

testing records among NRC and licensee representatives, the following

Confirmation of Action Items were issued:

a. During a telephone conversation on October 22, 1985 between NRC

Region II management and Duke Power Company General Office

representatives, the following Confirmation of Action items were

discussed:

Conduct air flow distribution tests for the auxiliary building

ventilation filter systems and submit written test results to the

Regional Office by October. 28, 1985. These tests will be

conducted in accordance with ANSI N510-1980, unless other criteria

are established with the Office of Nuclear Reactor Regulation.

If acceptance criteria for the air flow distribution tests are not

met, provide an analysis cf the adequacy of the systems capability

to meet the design function including the appropriateness of the

surveillance program. This analysis will be provided to the NRC

by October 29, 1985.

Review past test records to verify that all prerequisite tests

pursuant to ANSI N510-1975 for the control room ventilation system

have been conducted. Advise NRC by October 29, 1985, of the

results of this review.

Licensee representatives concurred with the action items and a

Confirmation of Action Letter was transmitted to the licensee on

October 23, 1985.

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b. During a telephone conversation between cognizant NRC and Duke Power

Company representatives on November 1,1985, additional action items

regarding the CV systems were discussed. Following the discussion,

licensee representatives agreed to conduct the air-aerosol mixing

uniformity test for the CV filter systems by , November- 8, 1985, in

accordance with ANSI N510-1975. A CAL to the licensee regarding this

item was issued November 5, 1985.

Two Confirmation of Action Letters were issued during this inspection.

7. Procedures, Records and Engineering Evaluations (92702)

The inspectors reviewed selected procedures, records, and engineering

evaluations applicable to determination of the adequacy of preoperational

in place filter testing for plant ventilation systems. The procedures,

records and evaluations reviewed are as follow:

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(1) TP/1/A/1450/01 Preoperational Filter Test for Control Area Outside Air

Pressure Filter Trains 1 & 2, 11/12/80 - 1/15/81.

(2) TP/2/A/1450/23 Containment Air Release and Addi. tion Ventilation System.

Filter Train Acceptance Test, 2/28/83.

(3) TP/1/A/1450/18 Preoperational Filter Test for Spent Fuel Ventilation

' Exhaust Filter Train, 11/3/80 - 12/30/80.

(4) TP/0/A/1450/19 Annulus Ventilation System Filter Train Acceptance Test

3/4/83 - 4/15/83.

(5) PT/0/A/4450/01 In-Place Test of HEPA and Carbon Absorber Filters,

8/17/81

(6) PT/0/A/4450/17 Safety Related Filter System Run Time 4/30/84.

(7) MP/0/A/7450/09 CVI Charcoal Filter Removal and Replacement, Rev. 2,

1/29/85

(8) TT/0/A/9100/104 Air / Aerosol Mixing Uniformity Test for 0APFTs 1 & 2,

11/6/85

(9) TT/1/A/9100/101A Auxiliary Building Ventilation System Air Flow

Distribution Measurements I, 10/23/85. '

(10) TT/1/A/9100/1018 Auxiliary Building Ventilation System Air Flow

Distribution Measurements II, 10/23/85.

(11) TP/0/A/1450/02 Preoperational Filter Test for Auxiliary Building

Filtered Exhaust Trains 1 & 2, 11/3/80-1/24/81.

.(12) Memo to File MC-1211.00-14 Supplemental Testing of High Efficiency Air

Filter Elements,1/27/81

(13) Auxiliary Building Ventilation System Engineering Evaluation of

Supplemental Filter Testing, Letter to Mr. H. R. Denton, Director,

Office of Nuclear Reactor Regulation from Mr. H. B. Tucker, Vice

President Nuclear Production, Duke Power 'Com'pany dated October 28,

1985.

(14) Letter to Dr. J. N. Grace, Regional Administrator, US NRC Region II

from H. B. Tucker, Vice President Nuclear Production dated October 29,

1985.

No violations or deviations were identified.

8. Review of Filter Testing Results (92702)

The inspectors reviewed and discussed selected ventilation system test data

as noted in the following paragraphs,

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a. Auxiliary Building Filtered Exhaust Trains

Licensee representatives conducted velocity distribution measurements

for the auxiliary building ventilation systems on October 25-26, 1985.

Velocity measurements were conducted at the following ventilation

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system component areas: prefilter-upstream, HEPA filter-downstream,

and charcoal absorber bed-upstream. A summary of the results for the

VA systems for both units is presented in Table 1. -Velocity

measurements were slightly outside of the established ANSI N510-1980

guidelines of 20% deviation from the mean value at the HEPA filter

exit for both units. However, following review and evaluation of the

individual flow distribution measurements at both the HEPA exit (-29 to

+26%) and carbon absorber bed ' inlet areas (-9 to +12%) by cognizant

NRC-NRR and Region II personnel, the air flow distribution was deemed

adequate for the VA system to meet its intended function and all

surveillance test results as required by Technical Specification were

deemed acceptable.

b. Control Room Area Ventilation (CV) Air-aerosol Mixing Uniformity

Testing

On November 6-7, 1985, licensee representatives completed air-aerosol

mixing uniformity testing for the CV systems. A Region II inspector

observed and verified that testing was conducted in accordance with

ANSI N510-1975. Results of the tests for both ventilation systems were

within the acceptance criteria of 10% deviation from the mean value

as specified in the standard. A summary of the results far the two

filter systems _is presented in Table 2.

No violations or deviations were identified.

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TABLE 1

Summary of Supplemental Auxiliary Building Ventilation (VA) Air Distribution

Tests for McGuire Nuclear Plant October 1985.

(% Deviaiton From Mean Value)

HEPA Downstream Charcoal Bed Entrance-Upstream

(% Deviation) (% Deviation)

Unit 1 -29 to +23 -9 to +12

Unit 2 -22.0 to +26.0 -7 to +9

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TABLE 2

Summary of Air-Aerosol Mixing Uniformity Tests (% Deviaiton From Mean Value)for

the Control Room Area Ventilation (CV) System at McGuire Nuclear Plant

November 1985

Upstream Downstream

(%' Deviation) (% Deviation)

Unit 1 -4.66 to 5.7 -8.05 to 9.20

-Unit 2- -8,55 to 9.93 -7.09 to 7.58

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