05000366/LER-1992-001, :on 920109,errors in Plant Drawing & FSAR Result in Missed TS Surveillances.Caused by Errors in Plant Drawing.Leak Rate Test of Penetration Performed,Procedures Revised & Penetrations Modified

:on 920109,errors in Plant Drawing & FSAR Result in Missed TS Surveillances.Caused by Errors in Plant Drawing.Leak Rate Test of Penetration Performed,Procedures Revised & Penetrations Modified

ML20092A362
Person / Time
Site:	Hatch
Issue date:	01/03/1992
From:	Beckham J, Tipps S GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-2032, LER-92-001, LER-92-1, NUDOCS 9202100078
Download: ML20092A362 (7)

LER-1992-001, on 920109,errors in Plant Drawing & FSAR Result in Missed TS Surveillances.Caused by Errors in Plant Drawing.Leak Rate Test of Penetration Performed,Procedures Revised & Penetrations Modified

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(x)
3661992001R00 - NRC Website

text

- _ _. _

Gemgia Fbwer Company

- 40 invemest Center Pwkway ftast Office Dom RM Bimxngham A1ataama 3%'01 lelephone 205 677 7279 m

seOlgia power J. T, Beckham, Jr.

Wee PieE; dent-- Nuclea Hatch P oject HL-2032 002899 February 3, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,-D.C.

20555 PLANT HATCH - UNIT 2 NRC DOCKET 50-366

.0PERATING LICENSE NPF-5 LICENSEE EVENT REPORT ERRORS IN PLANT DOCUMENTS RESULT IN MISSED TECHNICAL SPECIFICATION SVRVEILLANCES Gentlemen:

In-accordance with the requirements of 10 CFR 50.73(a)(2)(i), Georgia Power Company is submitting the enclosed Licensee Event Report (LER) concerning errors in plant documents which resulted in missed Technical Specification surveillances.

This event occurred at Plant Hatch - Unit 2.

Sincerely, lp{

/

/ J. T. Beckham, Jr.

OCV/a

Enclosure:

LER 50-366/1992-001 cc: (See next page.)

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's Corgill POWCf U.S._ Nuclear Regulatory Commission February 3, 1992 Page Two cc:

Georoia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U.S. Nuclear Reculatory Commission. Washinaton. D.C.

Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion 11 Mr. 5. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch 002283 700775.

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FACilllY hAMt (1) iWi l hsMbin (i) m f4 PIR2r llATQi, UNIT 2 05000366 L

glS IITLE (4)

ERROPdi IN PJ ANT DRAWING AND PSAR RESULT IN MISSED TECINICAL SITEIFICATIONS SURVEIUANCES EVEhl DATE (5)

LER huMBER (6)

' REFORT DATE (1)

OTHER FACIEITIES lhVOLVED (6) 90hTH DAY YEAR TEAR SEQ hum REV M0 KIN DAY YEAR FACILITY hAME5 DOCAET huMBER(5) 05000 01 09 92 92 001 00 02 03 92 05000 THI5 REPORT 15 SL')M1 IED FUR 5UANT TO InE REQulREMEhT5 Of 10 Cfd (11)

DPERAT!hG MODE (9) 1 20,402(b) 20 405(c)

P00ER 20.405(a)(1)(1) 50.36(c)(1) 50.73(a)(2)(tv) 73,71(b) 50.73(a)(2)(v) 73.71(c)

[EVEL 100 20.405(a)(1)(1i) 50.36(c)(2) 50.73(a)(2)(vii) 01HER (Spectf3 in T

20.405(a)(1)(tit) 50.73(a)(2)(i)

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% NO AB51RACT (16) on 1/9/92 at 1400 CST, Unit 2 was in the Run mode at a power level of 2436 CMVT (100% rated thermal power). At that time, non-licensed plant Engineering personnel determined that a local leak rate test of Primary Containment penetration X-222A had not been performed as required by Unit 2 Technical Specifications section 4.6.1.2.d.

Also, it was determined-that the penetration had not been verified to be closed at least once every 31 days as required by Unit 2 Technical Specifications section 4.6.1 1.a.1.

A visual inspection of the penetration's sealing device performed on 1/9/92 revealed it to be intact, with no visible or audible signs of leakage or signs of deterioration.

Georgia Power Company determined that the penetration did not have to be declared inoperable until a leak rate test could be performed. The NRC was informed of this on 1/9/92. The leak test was done on 1/10/92 after a test volume was installed in order to allow the penetration to be tested.

The penetration's as-found leakage rate was zero actual cubic centimeters per minute (ACCM).

This event was caused by errors in a plant drawing and the Unit 2 Final Safety

(

Analysis Report (FSAR).

Plant drawing S-28719 incorrectly showed the penetration's cealing device as one not requiring a local leak rate test or periodic inspection to veri;f it was closed.

The Unit 2 FSAR also incorrectly identified penetration X-222A as not requiring a local leak rate test.

Corrective actions include performing a teak rate test of the penetration, revising applicable procedures to include checks of the penetration, modifying the penetration, and inspecting the remaining penetrations in inaccessible areas of Unit 2.

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TEXT-CONTINUATION p..

FACillTY NAML (1).

, DOCKET NUMBIR (!)

LER huMBER (5)-

PAG ( (3)

YEAR HQ NUM KEV PiRifIIAl m,-UNIT 2 05000366 92 001 00 2

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uu-PLIANT'AND SYSTEM IDENTIFICATION General Electric. Boiling Water Reactor

'EnergyLindustry Identification System codes are identified in the text as (Ells Code XX).

DESCRIPTION OF EVENT-On 1/9/92 at 1400 CST, Unit 2 was in the Run mode at a power level of 2436 CMWT

-(100%' rated thermal power), At that time, non licensed plant Engineering-personnel were reviewing the results of a walkdown of accessible Unit 2 Primary

- Containment-(Ells = Code Nil) penetrations, The walkdown, completed 12/13/91, was

part of the corrective action.for an event described in LER 50-366/1991 018, dated 7/3/91.

Engineering' personnel determined from their review that a local leak rate.(Type B) test of Primary Containment penetration X~222A, a spare penetration in the Unit 2. Suppression Chamber, had not been performed as required by Unit'2 Technical Specifications section 4,6,1,2.d.

This specification requires that local leak rate tests of Primary Containment fpenetrations be performed during each shutdown for refueling, but in no case at intervals-greater than two years, The-as-found configuration of the penetration's sealing device, a bolted blind flange with'a gasket, was such that a local leak rate test was required by the LUnit 2 Technical. Specifications, but the penetration was not included in plant procedure 42SVaTET 001 2S, " Primary Containment Periodic Type B and Type C Leakage Tests,"

Engineering personnel documented the failure to perform a local leak-rate test on this penetration on a Deficiency Card as required by plant administrative control procedures.

It.was later noted that the penetration also had not been verified to be closed at least once every 31 days as required by

~

Unit-2 Technical Specifications section 4.6.1.1,a,1.

~ Plant Nuclear Safety and Compliance. personnel and additional Engineering personnel inspected the penetration on 1/9/92. They found the penetration,

. blind flange -and gasket to be in good condition with no visible or audible signs of leakage or' signs'of deterioration.

(This inspection, in effect, satisfied the surveillance 1 requirements of section 4.6.1.1.a,1.)

This

- information;was conveyed to NRC' personnel during the afternoon and.evenin6 Of 1/9/92 along with-the _ fact that the penetration's sealing-device had been. tested

- successfully several' times during overall integrated containment leakage.rato c(Type A) tests, fit was also noted this was a spare penetration not subject to wear'or-deterio' ration from repeated openin5 and closing and it was unlikely to-Lhave,been disturbed since the last, successful Type A-test in 1989 The NRC was informed it was Georgia Power. Company's position that the penetration did not have to be considered inoperable until a local leak rate test could be performed and thelpenetration's leakage. rate determined, It was agreed the penetration did not have to.be considered inoperable and the local leak rate test would be performed-as expeditiously as possible.

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A-TEXT CONTINUATION ar s, f fulf NANt (1) 00CK(1 NUMB (R (2)

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PAGt (3)

YEAR SEQ NUM RIV PIANT HATCH, tNIT 2 05000366 92 001 00 3

of TIT)

The sealing device for penetration X-222A did not have a test connection to allow a Type B test to be performed, Therefore, a method had to be devised to

- test-it.

It was decided to fabricate a test volume with a test connection, place it over the blind flange and gasket, and weld it to the penetration.

The plant's Architect / Engineer reviewed the test volume proposed by plant Engineering personnel and prepa*ed a safety evaluation supporting its temporary installation.

The sketch of the test volume and the safety evaluation were

- reviewed and approved by the Plant Review -Board in meeting number 92-003 on 1/10/92 at 0826 CST per the requirements of procedure 30AC ops 005 05,

" Temporary Hodification Control." The test volume was fabricated using 10 inch, schedule 80 carbon steel (Type SA106, Grade B, Class 2) pipe per the approved Engineering sketch and welded to the penetration on 1/10/92 per Maintenanca Work Order 2 92-0095 and the approved temporary modification.

On 1/10/92 at 1650 CST, a Type B test of penetration X-222A was begun per procedure 42SV TET 001 2S which had been temporarily changed to includa a local leak rate test of the penetration. At 1940 CST, the test was satisfactorily completed. No leakage was found.

The test volume was then removed from the penetration per Maintenance Work Order 2 92-0095.

Non-destructive examination of the areas of the penetration to which the test volume was velded was

_ performed and no problems were found.

CAUSE OF EVENT

This event was caused by errors'in a plant drawing and the Unit 2 FSAR.

Plant drawing S-28719 incorrectly showed the penetration's sealing device as one not requiring a local leak rate (Type B) test or periodic visual inspection to verify 11t was closed.' The drawing showed the penetration sealed by a welded cap. A welded cap is not subject to the requirements of Unit 2 Technical

, Specifications section 4.6.1,1.a,1 or 4.6.1.2,d because it is not a. sealing

- device which could-be opened and it does not fit the definition of those devices requiring a Type B test, respectively.

The actual sealing device, a bolted blind flange and a gasket, is subject to bath requirements. Unit 2 FSAR Table 13,8-5 also incorrectly identified penetration X-222A as requiring only a Type A test.

As a result of these errors,_this penetration was not included in the surveillance procedures _for periodic visual inspection arid a Type B test.

It could not be determined why the drawing did not reflect the actual configuration of the penetration.

No record of the drawing being revised or the penetration being nodified could be found. A rebruary 1984 Maintenance Request to tighten one of tne nuts on the flange indicated the as found configuration existediat that time. No records of a Type B test _having been performed on the penetration were-found.

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TEXTm CONTINUATION FACILITY NARI (1)

DOCAll NUMBER (!)-

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PAGE (3)

YEAR 5IQ hu4 RIV PIANT liATut,1 NIT 2 =

05000366 92 001 00 4

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REPORTABILITY ANALYSIS AND SAFETY ASSESSMENT

.l This report is required per 10 CFR $0.73(a)(2)(1) because a condition prohibited by the plant's Technical Spacifications existed.

The requirements of Unit 2 Technical ~ Specifications sections 4.6.1.2.d and 4.6.1.1,a.1 had not been met for Primary Containment penetration X 222A.

Due to errors in plant drawing S 28719 and Unit-2-FSAR Table 3.8-5,- local leak rate (Type B) tests had not_been performed on the penetration as required by section 4.6.1.2.d, and periodic verification that the penetration was closed was not performed as required by section 4.6.1.1.a 1, The. Primary Containment is-designed to limit the leakage of radioactive materials-released from a breach of the nuclear system process piping during and following the postulated Design Basis Accident.

The limitations on Primary Containment leakage, as contained in the Unit 2 Technical Specti nations, ensure that total containment leakage is less than that which would rebult in offsite doses greater _than those'alloi.ed by 10 CFR 100.

The Unit 2 Technical Specifications require periodic verification testing of the leak tight integrity of individual-Primary _ Containment penetration isolation barriers.

The purpose i

of these tests is co assure. leakage through the Primary Containment penetration isolation barriers _does'notLexceed allowable leakage values as specified in the Technical Specifications and accident analyses.

In the event described in this report, it was found that one of the containment isolation barriers, the blind flange and gasket for penetration X 222A, had not been tested in accordance with the requirements of the Unit 2 Technical Specifications.

Specifically, the penetration barrier had not been subjected to

.the required local leak rate test nor had it been verified to be closed once every 31 days. The leak tight integrity of the containment, including penetration X-222A, had been verified periodically as part of the overall integrated containment leakage rate,_ or Typo A, test.

While the Type A test did not test penetration X-222A specifically, it.did verify _the overall. Primary

/ Containment-leakage was within acceptable limits. Leakage through' all containment isolation barriers, including the-blind flange and gasket for l penetration X-222A, was verified - to be less than that: specified in the Unit 2

. Technical Specifications and accident analyses.

Upon discovery of this event, a local leak rate test was performed on penetration X 222A.

No leakage was found (i.e., its as-found leakage was zero).

Because this is a spare ~ penetration, its isolation barrier is not subjected to use (e.g., opening and closing during normal plant operations, removal and replacement _during refueling) which could result in the degradation of the ability of the blind flange and; gasket to limit leakage through the penetration.

Therefore, it is reasonable-to conclude its leakage has always been within acceptable limits and it'has been in the isolated (closed) condition during unit operation.

L Based on the above analysis _it is concluded that this event had no adverse impact on the public health and safety.

This analysis is applicable to all power = levels and operating conditions for which Primary Containment integrity is required.

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0304 LICENSEE EVENT REPORT -(LER) i TEXT ~ CONTINUATION l

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FACILITT NAAt (1).

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PAGE (3)

Y[AR 5[Q HUM RLV PIANT HA'lut, UNIT 2 -

05000366

- 92 001 00 or 5

- l MT CORRECTIVE' ACTIONS A: temporary test volume was installed over the penetration per approved plant procedures to allow a Type B test to be performed.

Procedure 42SV TET-001 2S

,was temporarily changed to include a Type B test of penetration X 222A and the t

penetration was tested on 1/10/92.. The penetration's as found leakage _ rate was b

zero actual cubic centimeters per minute (ACCM). The test volume was then

removed, i

Procedure 34SV Si'V 011 2S, " Primary and Secondary Conta'inment Integrity LDemonstration," will be revised to include the required 31 day verification that penetration X-222A is closed. This revision will be effective by 2/9/92 when the _ next verification of this penetration is due.

- A physical walkdown of -the Unit 1 Primary Contaitunent penetrations and the accessible portion lof_the. Unit 2 Primary Containment penetrations has been completed. _ A~ review of the Unit 2 valkdown resdts led directly to the discovery-of this event.

A review of all of the walkdown results did not reveal any_other similar problems,

~A physical walkdown of the non accessible portion of the' Unit 2_ Primary Contair, ment penetrations will be performed by the end of i he-Fall 1992 Unit-2. refueling outage as previously committed to in LER I

t

- 50 366/1991-018.

Penetration X 222A will be modified during the-Fall 1992 Unit 2 refueling outage either to add a test connection so a local leak rate test can be performed or to-change'the spare penetration's sealing device so a local leak rate test is not required. Unit 2 FSAR Table 3.8+5, procedures 42SV-TET 001-2S and

. 34SV SUV 01125, and drawing S-28719 will be revised as necessary to reflect the c

chosen' option.

ADDITIONAL INFORMATION

No' systems.other than Primary Containment were affected by this event.

Penetration X 222A is'a spare penetration; consequently, its condition can 7

= affect:no-other systems or components.

No failed components' caused or resulted from this event.

A. previous similar event in which it was discosered that required testing had not been performed on a Primary Containment penetration was reported'in.LER 50-366/1991-018;-dated 7/3/91. -Corrective actions for that event included a walkdown of-both units' Primary Containment penetrations.

These walkdowns led-

~ directly to the discovery of this event. To date, no other problems have been-

.foand.

Only non accessible. Unit 2' penetrations remain to be walked down and-this will be done per the commitment and schedule given in LER 50-366/1991-018,

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