IR 05000254/1986016

Insp Repts 50-254/86-16 & 50-265/86-16 on 861009-1204. Violations Noted:Failure to Take Corrective Action to Preclude Repetition & to Document Activities Affecting Quality

ML20207N004
Person / Time
Site:	Quad Cities
Issue date:	01/06/1987
From:	Mendez R, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207M969	List: IR 05000254/1986016 ML20207M968 ML20207M982
References
50-254-86-16, 50-265-86-16, NUDOCS 8701130380
Download: ML20207N004 (19)

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U.S. NUCLEAR. REGULATORY COMMISSION

REGION III

Reports No. 50-254/86016(DRS); 50-265/86016(DRS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2 Inspection At: Cordova, Illinois Inspection Conducted: October 9 through December 4, 1986

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Inspector: R. Mendez //6. /2 7 Date M ~ b Approved By: M. A. Ring, Chief '

If 4f f7 Test Programs Section Date

! Inspection Summary Inspection on October 9 through December 4, 1986 (Reports No. 50-254/86016(DRS);

No. 50-265/86016(0RS))

Areas Inspected: Routine announced inspection by a Region based inspector of the Containment Integrated Leak Rate Test (CILRT) procedure, CILRT performance witnessing, CILRT results, local leak rate test results, action on previous inspection findings, and licensee event report followup. NRC inspection modules utilized during this inspection included 70307, 70313, 70323, 61720 and 9270 Results: Two violations were identified (failure to take corrective action to preclude repetition - Paragraph 7; and failure to document activities affecting quality - Paragraph 8.a.(1)).

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a DETAILS 1. Persons Contacted Commonwealth Edison Cc. (CECO)

+ *R. L. Bax, Station Manager

+*R. Robey, Services Superintendent

• T. Tamlyn, Production Superintendent ,

4*E. Mendenhall, Technical Staff l

+ *M. Kooi, Regulatory Assurance

• C. Norton, Quality Assurance

• J. Kopacz, Technical Staff Supervisor K. Hill, Technical Staff E. Weinferter, Technical Staff B. B. Stephenson, Manager, Department of Nuclear Safety ,

V. Stavropoulos, Station Nuclear Engineering  !

I. M. Johnson, Nuclear Licensing L. F. Gerner, Regulatory Assurance Department M. S. Turbak, Operating Plant Licensing G. Price, Maintenance Staff J. Glover, Nuclear Services Technical N. Kalivianakis, Division Vice President

+ Willoughby, Quality Assurance Inspector

+ Spedl, Assistant Superintendent

• Denotes persons attending the preliminary exit meeting of October 16, 198 Denotes persons attending the CILRT meeting in Region III offices on November 20, 198 + Denotes persons attending the exit meeting of December 3 or 4,198 The inspector also contacted other licensee personnel including members of the technical, operating and regulatory assurance staf . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (265/85018-04): It was previously identified that certain containment isolation valves were consistently failing their local leak rate tests and that the Technical Specification limit of 0.6La had been exceeded during every outage since the initial Unit 2 startu The concern was that the licensee's corrective action program was not adequate to preclude repetition. The licensee was requested to submit a list of isolation valves that were consistently failing their local leak rate tests, summarize the corrective actions taken to correct the failures and to state the long range plans to preclude repetitio ,- .

On August 2, 1985, the licensee responded in writing to the '

unresolved item listing the failed valves and outlining the proposed corrective actions. The licensee listed valves where the leakage was small and no pattern of chronic failures existed. These valves were repaired and retested and no further action was take The licensee also listed a second set of valves which have exhibited excessive leakage. The problem valves and the action or proposed corrective actions are as follows:

(1) Main Steam Line Drain Valve (220-1) - The licensee issued Work Request No. WR-Q H1003 to initiate action to repair this gate valve. Repairs included cleaning the valve, repairing the valve disc and disc guide and lapping the valve seat. The valve was local leak rate tested after repairs on May 21, 1985, together with Valve No. 220-2. The combined leakage of the two valves was 6.42 SCFH. Valve No. 220-1 was tested again before any repairs and adjustments on October 11, 1986, and the leakage measured 12.8 SCFH. The licensee, however, has not decided whether to replace the valve with a similar one during this refueling outage or investigate a better valve for the type

&pplication, that is, a globe valve instead of a gate valv (2) Feedwater Check Valves (220-58A and 588; 220-62A and 628) - The licensee determined that the primary problem with the feedwater

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check valves is that they are used to isolate a high pressure water line but are tested with low pressure air (48 PSIG).

According to the licensee, this testing method does not include a way to firmly seat the disc prior to testing, and consequently, the testing would not simulate eitto operating or accident conditions that would act to seat % valve. In August 1984, the valves were disassembled and the 0-rings on the disc assembly were replace In March 1985, valves 220-58A and 220-62B were tested and the

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as-found leakage was determined to be 1921 SCFH and 790 SCFH, respectively. The licensee issued Work Request No. 41492 to

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repair these two valves. The two valves, No. 220-58A and No. 220-628, were tested again and the measured as-left leakage was 16 SCFH and 5 SCFH, respectively (no repairs were made to valves No. 220-588 and No. 220-62A). The difference in the as-left and as-found values appears to be due primarily to repairs and adjustments and not to the testing method used by the licensee. Additionally, the as-found leakage of the check valves continues to be excessive. The feedwater check valves are considered a chronic problem by the licensee. On June 25, 1985, the licensee issued Action Item Request (AIR) No. 85-12 to their Station Nuclear Engineering Department (SNED) to investigate this problem and determine a solutio _ _ - - _ - - . - . . _ _ -_- __. _ _ - - -. - - ,

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W (3) Drywell Purge Butterfly Valves (1601-23, 24, 60, 61, 62, 63)

The licensee inspected the valves and determined that.their seating surfaces were at the end of their useful life. Work Requests Nos. WR-Q41926, Q42341, Q41927, Q42345 were issued to replace valves 1601-23, 24, 60, 63, respectively, with new l valves. All six butterfly valves were tested on April 29, 1985,

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before repairs and the combined leakage was 342 SCFH. On May 24, 1985, after.the four valves were replaced, the as-left leakage was approximately zero. Replacement of the valves appears to have corrected the problem of excessive leakag During this inspection the leakage rate was determined to be

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9.0 SCF (4) HPCI Steam Exhaust (2301-45) - The licensee determined that this check valve does not function adequately for more than one cycle and consequently, it is not the best choice for this application. The licensee issued Action Item Request No. 4-86-20

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to investigate a replacement for this valve, but has not decided on a final corrective actio (Closed) Unresolved (254/86006-01): This unresolved item also deals

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with the adequacy of past licensee corrective action relating t excessively leaking containment isolation valves as was identified for Unit 2. The licensee was also requested to address the question of isolation valves which have repeatedly failed local leak rate tests. The licensee identified the following valves as having

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chronic problems:

(1) Feedwater Check Valves (220-58A, B; 220-62A, B) - The licensee

issued AIR No. 85-12 to SNED to investigate this problem and

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determine a solution. See unresolved item 265/85018-04 abov (2) Drywell Drain Sump Valves (2001-3, 4, 15, 16) - The licensee determined the position of these valves caused the local leak rate test failures. The original valves were installed in the

! inverted position and the air operators were positioned below the valves which caused sediment and crud to accumulate at the bottom. This prevented the air operator from tightly seating

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the valve. Work Request No. Q46386 was issued to modify the i valves so that the valve and operator are in the upright position. This action was complete by March 21, 1986. The as-left combined leakage for all the valves was measured to be approximately 10 SCFH.

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(3) HPCI Steam Exhaust Valve (2301-45) - The licensee concluded l that the original check valve had proven inefficient for its l application. Work Request No. Q4636 was issued to initiate

action to replace the existing valve with a new one. The

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modification consisted of replacing the old valve with a l

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new one which has a different seating design and elastomer

material that will provide a longer valve lif Valve replacement was completed by March 14, 198 The results of

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the as-found type C test on the original valve was indeterminate,

, that is, the valve could not be pressurized. On March 4, 1986, the as-left result, after the modification, was 0 SCFH.

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(4) Drywell Purge Butterfly Valves (1601-23, 24, 60) - The licensee issued Work Request No. Q48234 to repair the excessively l leaking valves. The licensee investigated the problem and

! found that by making adjustments to the valve disc, the valves were able to pass the local leak rate test. Therefore, the l valves were not disassembled for repairs. The above valves

! are tested together with valves 1601-61, 62, 63. The as-found combined leakage was determined to be 207 SCFH (the Technical Specification is 0.6La or 294 SCFH for all valves and penetrations). After repairs and adjustments the valves were type C tested on March 17, 1986, and the as-left leakage was 81 SCFH. Correct.ive action for these valves does not appear appropriate.

l l (5) Drywell Head (X-4) - (See Paragraph 8 of this report).

Unresolved Items 265/85018-04 and 254/86006-01 have been escalated to a violation (See Paragraph 7 of this report).

f 3. Licensee Event Report Followup l (0 pen) Licensee Event Report No. 86-02-00 (254/86002-11): Three main steam isolation valves were reported as having failed their local leak rate test The licensee found that some of the valve seats were pitte Repair of the valves included lapping the valve seats or replacing the

main valve discs and stems. The licenset.'s long term corrective actions l include the use of a new valve lapping tool and development of a l preventative maintenance program for the valve operators to assure adequate valve seating forces.

No violations or deviations were identified in this are . Containment Integrated Leak Rate Test Procedure Review Procedure Review The inspector reviewed Test Procedures QTS 150-6, Revision 5, "Short Duration Primary Containment Leak Rate Test," and Procedure QAP 1100-T6, Revision 5, "4-2 IPCLRT Valve Line Up," relatise to the l requirements of 10 CFR Part 50, Appendix J, ANSI N45.4-1972 and the FSA The licensee had also developed a procedure to run a 24-hour ANSI /ANS-56.8-1981 (mass point) test in the event the short duration l test would not yield acceptable results. The inspector in"ormed the

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licensee that the mass point method did not have a regulatory basis, l that is, ANSI /ANS-56.8 is not mentioned as an acceptable .titernative l

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in 10 CFR Part 50, Appendix J.Section III A.3(a) of Appendix J states in part, "All Type A tests shall be conducted in accordance with the American National Standard N45.4-1972. The licensee subsequently performed two integrated leak rate tests in accordance with BN-TOP-1, which is acceptable. All other inspector comments were satisfactorily resolve Clarifications of Appendix J Requirements To ensure the licensee's understanding of Appendix J requirements, the inspectors conducted numerous discussions with licensee personnel during the course of the inspection. The following is a summary of the requirements discussed with the license (1) The only methods of data reduction acceptable to the NRC are total time or point-to point as described in ANSI N45.4-1972 including a statistically calculated instrument error analysi The following options are available to the licensee and are suggested in the follcwing order:

(a) Total time (< 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration test) in accordance with Bechtel Corporation Topical Report BN-TOP-1 must be followed in its entirely except for any section which conflicts with Appendix J requirement (b) Total time (> 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration test) using single sided 95% UC (c) Proposed Regulatory Guide MS 021-5, Regulatory Position No. 13. If this method is utilized, the licensee must submit an exemption request to the NRC and receive approval for its use prior to the expiration the Type A test frequency requirements stated in the Technical Specification (2) Periodic Type A, B, and C tests must include as-found results as well as as-left results. In order to perform Type B and C tests prior to a Type A, an exemption from the Appendix J requirement must be obtained from NR The exemption request must state how the licensee plans to determine the as-found condition of the containment since local leak rate tests are being performed ahead of the CILRT. An acceptable method is to commit to add any improvements in leakage rates, which are the results of repairs and adjustments (R&A), to the Type A test results using the " minimum pathway leakage" methodolog This method requires that:

(a) In the case where individual leak rates are assigned to two valves in series (both before and after the R&A), the penetration through-leakage would simply be the smaller of the two valves' leak rates.,

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(b) In the case where a leak rate is obtained by pressurizing between two isolation valves and the individual valve's leak rate is not quantified, the as-found and as-left penetration through-leakage for each valve would be 50 percent of the measured leak rate if both valves are repaire (c) In the case where a leak rate is obtained by pressurizing between two isolation valves and only one valve is repaired, the as-found penetration leak rate would conservatively be the final measured leak rate, and the as-left penetration through leak rate would be zero (this assumes the repaired valve leaks zero).

(3) Penetrations which are required to be Type C tested, as described in the FSAR and SER, must be vented inside and outside the containment during the CILRT. All vented penetrations must be drained of water inside the containment and between the penetration valves to assure exposure of the containment isolation valves to containment air test pressur The degree of draining of vented penetrations outside of containment is controlled by the requirement that the valves be subjected to the post-accident differential pressure, or proof that the system was built to stringent quality assurance standards comparable to those required for a seismic syste (4) Whenever penetration configurations during a CILRT deviate from the ideal, the results of LLRTs for such penetrations must be added as a penalty to the CILRT results at the 95% confidence level. This penetration leakage penalty is determined using the " minimum pathway leakage" methodolog This methodology is defined as the minimum leakage value that can be quantified through a penetration leakage path (e.g. , the smallest leakage of two valves in series). This assumes no single active failure of redundant leakage barriers. Additionally, any increase in containment sump, fuel pool, reactor water, or suppression pool level during the course of the CILRT must be taken as a penalty to the CILRT results. If penalties exist, they must be added (subtraction is never permitted) to the upper confidence level of the CILRT result (5) The start of a CILRT must be noted in the test log at the time the licensee determines that the containment stabilization has been satisfactorily completed. Reinitializing a test in progress must be " forward looking," that is, the new start time must be the time at which the decision to restart is made. This also implies that the licensee has determined that the test has failed, and has enough data to quantify the leakage rat Any deviation from these positions should be discussed, and documented, with the NRC inspector as they occur to avoid later

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invalidations of the test result Examples of acceptable deviations of reinitializing the start time of the test in the past are: time at which a leakage penetration which has an obvious effect on the test data was secured, accidental opening and later closing of a valve which has an obvious effect on the test data, the time at which an airlock outer door was closed and the inner door was ope (6) The supplemental or verification test should start within one hour after the completion of the CILRT. If problems are encountered in the start of the supplemental test, data recording must continue and be considered part of the CILRT until the problems are corrected and the supplemental test can begi (7) For the supplemental test, the size of the superimposed leak rate must be between 0.75 and 1.25 times the maximum allowable leak rate La. The higher the value, the better. The supplemental test must be of sufficient duration to demonstrate the accuracy of the test. The NRC looks for the results to stabilize within the acceptance criteria, rather than the results being within the acceptance criteria. Whenever the BN-TOP-1 methodology is being used, the length of the supplemental test cannot be less than approximately one-half the length of the CILR (8) During a CILRT, it may become necessary to reject or delete specific sensors or data points due to drifting or erroneous sensors, or data outliers. Date rejection criteria should be developed and used so that there is a consistent, technical basis for data rejection. One example of an acceptable method for treating data outliers is described in an appendix to ANSI /ANS 56.8-1981. Sensor data rejection criteria should be plant specific and based upon a sensor's trend relative to the average scatter, slope, and/or absolute output of the senso (9) An acceptable method for determining if the sum of Type B and C tests equals or exceeds the 0.60 La Appendix J limit is to utilize the'" maximum pathway leakage" metho This methodology is defined as the maximum leakage value that can be quantified through a penetration leakage path (e.g., the larger, not total, leakage of two valves in series). This assumes a single active failure to the better of two leakage barriers in series when performing Type B or C test (10) Test connections must be administratively controlled to ensure their leak tightness or otherwise be subject to Type C testing. One way to ensure their leak tightness is to cap, with a good seal, the test connection after its us Proper administrative controls should ensure valve closure and cap reinstallation within the local leak rate testing procedure, and with a checklist prior to unit restar , -.

(11) Whenever a valve is replaced, repaired, or repacked during an outage for which Type A, B, and/or C surveillance testing was scheduled, local leak rate testing for the as-found as well as the as-left condition must be performed on that penetratio In the case of a replaced valve, the as-found test can be waived if no other containment isolation valve of similar design exists at the sit No violations or deviations were identified in this are . Containment Integrated Leak Test Witnessing (Unit 2) Instrumentation The inspector reviewed the calibration data and determined all the-instruments used in the CILRT had been properly calibrated and that the correct weighting factors had been properly placed in the computer program as required. The following instrumentation was used during the test:

Type Quantity RTD's 32 Dewcells 10

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Pressure Gauges 2 Flowmeter 1 On October 13, 1986, before the start of the second CILRT, RTD

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l No. 28 in subvolume No. 10 was deleted from the data scan due to lack of output readings. The second test used the data from 31 RTD's. No other sensors or data sets were rejected during the second tes Temperature Survey The inspector reviewed the results of the temperature survey performed by the licensee prior to containment pressurizatio The survey was performed with the fans off inside the drywel The CILRT was also performed with the fans off. The results of the temperature survey for the containment were adequat Witness of Test l The licensee attempted to perform an as-found Type A test at the l

start of the Unit 2 outage. The inspector witnessed two CILRT's

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on October 13 and 15, 1986, and noted that test prerequisites (except those mentioned below) were cet and that the appropriate revision to the test procedure was followed by test personnel. Valve lineups for the following systems were verified to ensure that no fluid could enter the containment atmosphere and that adequate venting and draining was provide ,

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System Penetration Drywell Pneumatic Suction X-32D Service Air to Drywell X-21 Instrument Air to Drywell X-22 Drywell Main Exhaust X-23 Core Spray to Reactor X-16 Nitrogen Make-up X-26 RHR Containment Spray X-39 Drywell Purge Inlet X-26 On October 11 and 12, 1986, the licensee performed as-found local leak rate tests (LLRT's) on penetrations and valves that have experienced excessive leakage in the past. On October 11, 1986, a Type C test was performed on MSIV A0-2-203-20 with unsatisfactory results. The resultant leakage was determined to be 36.8 SCF The individual MSIV valves have a Technical Specification limit of 11.5 SCFH. On October 12, 1986, the licensee attempted to perform a Type B test on the drywell head but was unable to quantify the leakage across the gasket. The leakage of the drywell head was determined to be greater than the flow capacity of 60 SCFH. The licensee reported the above two incidents to the NRC and has issued LERs on these conditions. Despite the apparent LLRT failure of the drywell head, the licensee continued on with the ILRT in order to try and quantify drywell headseal leakage and any other leakage that might be presen No violations or deviations were identified in this are . Test Results Evaluation CILRT Data Evaluation (First Test)

Upon satisfactory completion of the stabilization period an as-found short duration BN-TOP-1 CILRT was started on October 13, 1986, at 64 psia with data collected and reduced by the licensee every 15 minutes. The containment of Quad Cities Unit 2 is limited to a leakage rate of 0.75 wt.%/ day (0.75 La). The following results were obtained (units are in weight percent per day).

Measurement Licensee Inspector Leakage rate measured 0.826 0.834 during CILRT (Lam)

Lam at upper 95% 0.940 0.950 confidence level On October 13, 1986, at about 10:00 a.m., the licensee determined that the leakage rate at the upper confidence level had stabilized at approximately .9 wt.%/ day and would not drop below the acceptance

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criteria of 0.75 wt.%/ day. The as-found CILRT was declared a failur At this point the licensee decided to replace the drywell head gasket and restart the CILRT as soon as a local leak rate test was completed on the drywell hea On October 14, 1986, the inspector notified Region III of the Unit 2 drywell head local leak rate test failure which had caused the Unit 2 CILRT to fail. The Region expressed concern with the licensee's plan to restart the CILRT with all the uncertainties of the drywell head which had a history of unreliable local leak rate test results. At 10:30 a.m. a telephone conference was conducted between Region III management, licensee corporate management in Chicago, and the licensee management at Quad Cities. The topic of discussion was generally the licensee's inability to pass an as-found CILRT. Unit 1 had failed the July 1984 and April 1986 CILRTs while Unit 2 had failed the February 1984, May 1985, and now the October 1986 CILRTs. Both Unit 1 and Unit 2 are on an accelerated CILRT schedule as specified in Appendix J,Section III.A.6(b), which requires a Type A test every outage when two consecutive Type A tests fail to meet the applicable acceptance criteria. The Region discussed the Unit 1 and 2 drywell heads which had failed (Appendix J limit of 0.6La was exceeded) the Unit I local leak rate tests in 1982 and 1984 and now failed the Unit 21986 tes In addition, the Unit 1 and Unit 2 containment isolation valves have had a chronic history of failures (seeunresolveditems 254/86006-01 and 265/85018-01). Furthermore, main steam isolation valves have exceeded Technical Specification leakage limits several times during recent outages which have

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resulted in LER's 265/86006-LL (2 valves failed), 254/86002-LL l (3 valves failed) and during this outage MSIV A0-2-203-2D exceeded Technical Specification limits. The Region also expressed concern regarding uncontrolled work inside the drywell. The licensee stated that they had recognized the problem with the drywell head gasket and were confident that the Garlock material gasket would prevent future drywell head failures. In addition, the licensee had developed corrective action to repair excessively leaking valves or investigate the possibility of replacing old valves with new one Furthermore, the licensee was certain that their present controls would prevent unauthorized work in containmen The Region expressed concern that the CILRT could be invalidated by the NRC for the reasons above and because the licensee could not ensure a local leak rate test that would quantify the amount of leakage through the drywell head gasket (if greater than 60 SCFH)

as has been the case when the drywell head has failed previous l Type B tests. This concern was raised since the drywell head was

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going to be removed for refueling sometime after completion of the CILRT. The drywell head would then be Type B tested again prior to starting up the unit with a method that cannot be quantified I over 60 SCFH.

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Also discussed during^the telephone conference was the unacceptability of the ANSI /ANS-56.8 mass point method for data reduction. The licensee agreed to the BN-TOP-1 short duration test in future CILRT' On October 14, 1986, at approximately'12:30 p.m., the licensee's corporate management gave Quad Cities approval to proceed with the second CILRT.' The licensee stated that continuing with the second Type A test would give them an opportunity to quantify the leakage--

of the drywell head. The possibility of extending the scheduled outage was also considered by the licensee in their decision to continue with the tes The Region and the licensee met in Region III on November 20, 1986, to discuss-the licensee's CILRT failures, containment isolation valve and drywell head problems and the question of data reduction since the only acceptable methods are ANSI N45.4 and the BN-TOP-1 short duration tests, b. CILRT Data Evaluation (Second Test)

The licensee completed work on the drywell head and a Type B test was performed. No leakage was detected. On October 15, 1986,  !

upon satisfactory completion of the required stabilization period an 8-hour short duration CILRT was performed at 64 psia. Data was collected and reduced by the licensee every 15 minutes. The inspector monitored and evaluated leak rate data to verify the licensee's calculations of the leak rate and instrument performanc The results are as follows: (units are in weight percent-per day).

Measurement Licensee Inspectors Leakage rate measures 0.302 0.323 during ILRT (Lam)

Lam at upper 95% 0.343 0.361 confidence level Appendix J acceptance criteria at 95% UCL<0.75La or <0.75 wt.%/ da c. Supplemental Test Data Evaluation ,

After satisfactory completion of the 8-hour CILRT, a known leakage (based on the inspector's independent readings and calculations) of 8.9 SCFM, equivalent to 1.072 weight percent per day was induce Data was collected and analyzed by the licensee every 15 minute After five hours, the supplemental test was terminated with ,

satisfactory results as indicated by the following summary (units are in weight percent per day).

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Measurement Licensee Inspector Measured leakage rate 1.471 1.499 during supplemental, Lc Induced leakage rate, Lo 1.072 1.072 Lc - (Lo + Lam) 0.097 0.104 Appendix J acceptance criteria: -0.25 < [Lc - (Lo + Lam)] < + 0.25 as indicated above, the licensee's veriTication test results were satisfactor d. Data Evaluation Correction The inspector questioned the licensee regarding a discrepancy in the second decimal place of all their calculated results during the CILRT

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and the verification test. The error was approximately 0.02 wt.%/ day and would not have affected the total overall results. The licensee obtained a copy of the computer program and looked for apparent mistake The licensee found that the reactor water level multiplica-tion constant which corrects for total containment volume was incorrect. The value placed in the program was 28.635, but should have been 25.0. After correcting the program the licensee reperformed the calculations with the following results (in wt.%/ day).

Measurement Licensee Inspector Leakage rate measured 0.323 0.323 during ILRT (Lam)

Lam at upper 95% 0.362 0.361 confidence level Measured leakage rate 1.494 1.499 during supplemental The above licensee results are not official; however, the licensee stated they will make the necessary corrections in their final 90 day CILRT report to the Regio e. CILRT Valve Lineup Penalties Due to penetration configuration which deviated from the penetration requirements for the CILRT, the results of local leak rate tests for each penetration must be added to Lam at the 95 percent UC Since the licensee performed an as found CILRT, the results of local leak rate tests were not available. The licensee has committed to quantify the minimum pathway leakage for the following penetrations or leakage path _- . _ _ ___ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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Penetration Drywell Floor Drain Drywell Equipment Drain HPCI Steam and Drain 09Analyzer l CTeanup Demineralizer RHR Feedwater RCIC Steam Exhaust and Drain SRM/IRM Purge TIP Purge Check Valve ECAD All Electrical Penetrations This item is open pending review of the valve lineup penalties (265/86016-01).

f. As-Found Condition of CILRT Results The as-found condition is the condition of the containment at the beginning of the outage prior to any repairs or adjustments to the containment boundary. Since the licensee performed the CILRT prior to repairs of containment isolation valves and penetrations (except drywell head), the only adjustment was due to valve lineup penalties that deviate from the ideal. The licensee is limited to a total as-found leakage of 0.750 wt.%/ day at the 95% upper confidence level. Without penalties the leakage of the second CILRT test was calculated to be 0.361 wt.%/ da However, the leakage of the as-found first test was 0.95 wt.%/ day which results in a leakage of approximately 0.59 wt.%/ day for the drywell hea As indicated above, the as-found condition exceederi the allowable limit of Appendix J. (0.75 wt.%/ day). The excessive as-found leakage was largely due to the drywell head. The CILRT's performed in 1984 and May 1985 also exceeded the as-found Appendix J limit due to non quantification of containment isolation valves. As more than two consecutive as found CILRT's have failed to meet the acceptance ,

criteria in 10 CFR 50, Appendix J, and as required by '

Section III.A.6(b) of 10 CFR 50 Appendix J, a Type A test shall be performed at the next plant outage for refueling unless exempted by the NR No violations or deviations were identified in the review of this are One area requires further review and is considered an open ite _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ - ____ -__ _____ _ -__

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. . * Local Leak Rate Test Results During two previous inspections, several concerns were raised regarding the adequacy of licensee corrective action related to excessively leaking containment isolation valves and penetrations for both Units 1 and Units 2 (refer to unre;olved items 265/86018-04 and 254/86006-01). The valves and penetrations which have had a history of chronic local leak rate test failures are oiscussed in Unit 1 Report No. 50-254/86006 and Unit 2 Report No. 50-265/85018. The licensee's Technical Specification and 10 CFR 50, Appendix J, limit the total leakage for penetrations and valves subject to Type B and C tests to 0.6La (294 SCFH). However, the licensee has exceeded their Technical Specification leakage rate for the last eight Unit 2 outages in 1974, 1976, 1978, 1979, 1981, 1983, 1985 and the present 1986 outage. In addition, the licensee has exceeded the allowable leakage rate for at least the last four Unit 1 outages in 1979, 1982, 1984 and 198 During a review of work requests and modification packages, the inspector noted that in some instances the licensee had identified some chronically lerking valves, such as the HPCI steam exhaust valve 2301-44 and the Drywell Orain Sump Valves 2001-3, 4, 15 and 16. With respect to these valves, the licensee war in the process of correcting the excessive leakage prior to identification by Region III inspectors, as discussed in Paragraph 2 of this report. However, with respect to Main Steam Line Drain Valve 220-1, Feedwater Check Valves 58A, 588, 62A and 628, Drywell Purge Butterfly valves and the drywell head gasket, the licensee had not previously taken adequate corrective action to preclude repetition as evident by the consistent violation of the 0.6La leakage rate limit. This failure by the licensee to arsure that measures be establi-he1 to assure that corrective action is taken to preclude repetition is (,.isidered a violation of 10 CFR 50, Appendix B, Criterion XVI (254/86016-01; 265/86016-02).

As previously stated in Paragraph 2, the licensee had been requested to submit a list of valves and penetrations that were consistently failing their local leak rate tests and to summarize corrective action plans to preclude repetition. On August 2, 1985, the licensee responded to Unresolved Item 265/85018-04 and on July 24, 1986, the licensee responded to Unresolved Item 254/86006-01. The inspector reviewed these letters and other corrective action records pertaining to the valves and penetrations. A review of these records indicates the licensee is in the process of resolving or has properly resolved the problem with excessively leaking valves and penetrations. Consequently this violation does not require a written respons One violation was identified in this are _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _

. . . Drywell Head Gasket Gasket Material Documentation (1) On January 6,1986, the Unit I drywell head failed a local leak rate test. The leakage was found to be greater than the 60 SCFH capacity of the flowmeter, and therefore, the leakage was assumed to be in excess of the Appendix J limit of 0.6La (294 SCFH). The Unit 1 drywell head had previously failed a local leak rate test on September 6, 1982. Consequently, the drywell head failures, in part, had caused Quad Cities Unit 1 to fail three consecutive CILRTs. (The 1984 CILRT also failed.)

The licensee determined that the drywell head flange gasket material experiencing problems was made by J-BAR Incorporated, Compound No. 240 This gasket material is a 40 durorreter ,

red silicon rubber made to AMS Specification No. 3301. The licensee had forverly used a gasket recomended by the flange designer, Chicago Bridge and Iron (CBI) which was also a 40 durometer red silicon rubber but made by Garlock (Material No. 8364) manufactured to ASTM Specification No. D395. The inspector requested documentation relative to the compatibility of the J-BAR and Garlock gaskets or an engineering evaluation or study that would indicate whether the gasket made by J-BAR was a like for like material as the one made by Garlock. The records could not be produced by the licensee nor could the licensee determine why Quad Cities switched material type but determined thdt the date J-BAR started shipping drywell head gaskets to Quad Cities also coincided with the start of gasket test failures. On December 3, 1986, the inspector reviewed quality records and purchase documents relating to the gasket material. The inspector noted a lack of adequate documentation relating to a justification for using a gasket material other than the one recommended by the vendo CFR 50, Appendix B, Criterion XVII requires that records shall be maintained to furnish evidence of activities affecting quality and that the records include the results of reviews and materials analyses. Contrary to the above, the licensee changed gasket material type without maintaining opproved quality records to demonstrate compliance. This is considered a violation of 10 CFR 50 Appendix B, Criterion XVII (254/86016-02; 265/86016-03).

(2) The inspector conducted further discussions with the licensee regarding the drywell head gasket. The licensee stated that the Garlock and J-BAR gaskets were purchased to an ASTM and an AMS standard, respectively, which contain similar specification criteria. However, ASTM Specification No. D395 and AMS Specifi-cation No. 3301 were not available at the site and a comparison could not be made. In addition, the inspector was informed that the licensee had not performed a 10 CFR 50.59 review for the change. A 50.59 review

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e e o is performed when a proposed change involves an unreviewed safety question. The licensee stated that a 50.59 review was not believed necessary because a change had not been made, that is, the Garlock and J-BAR gaskets are both 40 durometer silicon rubber. Finally, the inspector discussed with the licensee the applicability of the Garlock gasket for its present use. A Commonwealth Edison Nuclear Services Department letter dated February 28, 1986, states that CBI does not recommend the Garlock No. 8364 gasket for use in radiation or steam environments. The licensee stated that CBI was being overly conservative in their recommendation. The above matters are considered unresolved and will be reviewed in a subsequent inspection (254/86016-03; 265/86016-04). Gasket Material Testing On January 16, 1986, the licensee issued action Item Record (AIR)

No. 4-86-06 to determine the cause of the Unit 1 drywell head gasket failures. Samples of the J-BAR material were sent to the licensee's Systems Material Analysis Department (SMAD). Samples of Garlock No. 8364 were also sent to SMAD. The two different samples were subjected to temperature ranges of 250* to 350 F in a steam / water envitonment. The licensee determined that the Garlock gasket was superior to the J-BAR gasket in the Unit 2 drywel However, Nuclear Services made no recommendation on the Unit 2 drywell since it had not experienced any failure and because the temperature measured by the Unit 2 drywell head was 40 F cooler than that on Unit On October 12, 1986, during the latest CILRT, the Unit 2 drywell head failed the local leak rate test. Discussions with the licensee indicated that they will use the Garlock, Material No. 8364 originally specified by CBI for both units. The Garlock gasket, which had been obtained from Dresden station, was installed on the Unit 2 drywell head on October 13, 198 The drywell head was Type B tested and the result was 0 SCF The licensee is continuing their efforts to investigate an alternate gasket material for the drywell hea One violation and one unresolved item were identified in this are . Post CILRT Work in Containment The inspector discussed and reviewed the licensee's administrative controls of work inside containment during outages. The following procedures administratively control welding and cutting, security and access into the drywell during unit outages and are briefly discussed below:

o s o Title Procedure Number Fire Prevention For Weldirg and Cutting QMP 100-3 Security D'Jring Unit Outage QMP 1900-12 Access to the Drywell or 3uppression Chamber QAP 1150-2 Initial Entry to the Drywell or Suppression Chambers QAP 1150-3 Drywell Entry Log QAP 1150-51 Access to High Radiation Areas QAP 1150-4 Procedure QMP 100-3 controls cutting, grinding and welding in all areas in the plant outside designated welding areas. In order for anyone to cut, grind or weld, permit QMP 100-S1 must be issued before work is started. Prerequisites for work in containment include: obtaining the Operating Engineer's authorization and signature; contacting Rad / Chem and establishing a fire watch; describing the work to be performed; and documenting the location of the work. Permit QMP 100-S1 expires at the end of the shift and is returned to the Supervisor authorizing the wor Procedure No. 1900-12 controls access to the drywell and the refueling flJor during a unit outage. A rad / chem technician is assigned to record entries and keep time of all personnel who must enter the drywell. In addition, a guard is posted near the entrance to assure that only authorized personnel and materials are permitted into the containmen During the CILRT, the inspector noted that a guard was posted at the drywell entrance at all time A " Security Access Permit," form QAP 1900-12 is used to document authorization into the drywel Clearance to enter the drywell is also established through the plant's security computer syste The rest of the procedures listed above establish additional radiological and habitable environment limitations, hold points, tool logs and the necessary controls and logs to assure that no unauthorized entry is permitted. The licensee's administrative controls of post CILRT work appears adequat . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both. An Open Item disclosed during the inepection is discussed in Paragraph . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An Unresolved item disclosed during the inspection is discussed in Section 8.a.(1).

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O * O 12. Exit Interview The inspectors met with licensee representatives denoted in Paragraph I during the inspection on October 16, 1986, in Region III on November 20, 1986, at the conclusion of the inspection on December 3, 1986 and by telephone on December 4,198 The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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