IR 05000254/1989024
| ML20043G944 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/15/1990 |
| From: | Lougheed V, Maura F, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20043G940 | List: |
| References | |
| 50-254-89-24, 50-265-89-24, NUDOCS 9006210343 | |
| Download: ML20043G944 (20) | |
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,e .y , . . g - , U.S. NUCLEAR REGULATORY COMMISSION , (,!, 'i
REGION III
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e 'd . - '. s p . Report,,No.,50-254/89024(DRS); 50-265/89024(DRS) y , $ -' . c ..
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DocketNos.50h254;$0-265 Licenses No. DPR-29; DPR-30 - ,, (, # ' i Licensee: ' - Commoriweal'th^ Edison Company " f.
Post Office Box 767 '
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- Chicago, IL 60690 > ' ' - , . . , + .* l t /
,-gr , , y3 FaciiityName: Quad Cities Nuclear Power Station - Units 1 & 2 .+ t M y, ,l ,i
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- Jv Inspection At:
Cordova, IL 61241 'f ' ' ' > ., , ,, . Inspectior) Conducted: October 30, 1989 - May 18, 1990 Is ct'o s: bee *4h 6//Nf8 ' i.
L ~ F.'A. Paura Dat'e ' )bel b/ ql9o ( / ' V..Potougheed Date' ,
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pproved By: / L /Nonte P. Phillips, Chief D6te l Operational Programs Section l.
I ' L . Inspection Summary
' Inspection on October 30, 1989 through May 18, 1990 (Reports No. 50-254/89024(DRS);- 50-265/89024)). Areas Inspected: Routine, announced, inspection.by regional" based inspectors ~il-the local leak rate test program on both units, the containment integrated , leak rate test (CILRT) procedure (both units) review of the CILRT test . results (unit 1 only), review of licensee actions on previous inspection ' findings, and onsite review of licensee reports of non-routine events.
NRC= modules used during this inspection were 61720, 70307, 70323,'90712, 90713, 92700,-92701 and 92702.' ' Results: 'Two violations were identified during this inspection (inadequate.
- corrective action - Section 7 a; and failure to perform 10 CFR 50.59 evaluation , -or inadequate evaluation - Section 7,c). -Four unresolved items were - identified (status of Unit 1 containment - Section 2.b; exemption for main ' steam isolation valves Section 7 b; testing of butterfly valve' flanges _- Section 7.g; and improvement of local leak rate test procedures - Section 8), i . , 0006210343 000615 ' , PDR ADOCh 050002T'4 . ' O FDL f M.
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y ~ - . i , ' jut , L The licensee continued'to have problems with their local leak rate test ' program.
Although they appeared to be making progress in reducing main steam'
4 . isolation valve problems, other penetrations continue to cause as-found ' failures of both the local and integrated tests.
The licensee had implemented , an aggressive maintenance program, especially in regard _to_the feedwater check valves and felt confident that this would reduce the failure rate of these , valves..A list of chronic failures for both units is listed in Section 7 of
J this. report,
e The Unit I containment integrated leak rate test (CILRT) failed in the as-found-condition. Although the Unit 2 integrated test is not discussed in this report, .the licensee acknowledged that the as-found result was also a failure, based on ' . minimum pathway leakage thrnugh various penetrations ~ The licensee remained-on accelerated testi, s.* will perform an integrated test during the next refueling outage o' each, t.
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' ,, !-ti j t ' l ' I'. - Persons Contacted , f ' ' J' Commonwealth Edison Company ' 4,5 J. Abel,.BWR System Design Engineering [ 1,2,3 T. Barber, Regulatory Assurance r 1,2,3 R. Bax, Station Manager !
D. Bucknell, Assistant Tech Staff Supervisor '
D. Craddick, Assistant Maintenance Superintendent uh 1,3,4 J. Dierbeck, Technical Staff Supervisor.
. C. Edmondson, Mechanical Maintenance Foreman ,
B..Fancher BWR Supervising Design Engineer . , 4,5 J. Glover, M&SS ILRT Engineer ' 4,5 A. Haber-Kovach, BWR Systems Design Engineer ,
K. Hill, Technical Staff Engineer c
N. Kalivianakis, BWR Operations Manager , " ' 4,5 G. Klopp PRA Supervisor' ' 2 'R. Kornetta, Technical Staff Engineer , 1-K. Perkins, Technical Staff Engineer '
G. Price, Maintenance Staff Assistant ' ' 2,3,5 R._Robey,' Technical Superintendent 1-J. Rolfes Technical Staff Engineer D. Schumacher, Technical Staf f Engineer ' .y 4,5.
J. Silady, Nuclear Licensing. .
G. Spedi, Production Superintendent-
S. Stapp.-Quality Assurance '
R. Stols, Licensing Administrator . 1 K. Sturtecky, Technical Staff Engineer
R. Tuetken, BWR Projects Manager
R. Walsh, Technical Staff Engineer 3, J. Wethington,-Quality Assurance Superintendent
J. Wunderlich, Regulatory Assurance , $,, ' General Electric 's . ... .'J. Elliott, Resident Engineer % - . < , I ', ,c, US,NRC, , ', ' , 41; m a ,, , '[~ -' *
5 H. J. Hiller, Director, Division of Reactor Safety i , , - 5' ,G. C. Wright, Chief, Operations Branch, DRS .. C--
4,5-e ' M. P. Phillips, Chief, Operational Programs Section, DRS < . 'R Higgins, Senior Resident Inspector, ' " '"' " y;, }; R.!Bocanegra, Resident Inspector . . ' . , , 'y
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J. Shine, Resident' inspector
W. D. Shafer, Chief,' Branch 1. DRP
R. Lerch, Project Engineer, ORP
Attended preliminary exit interview on November 4, 1989
Attended preliminary exit interview on April 12, 1990
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Attended exit interview on April 26, 1990 i.
Attended meeting held May 17, 1990 at CECO Downers Grove Office
Attended meeting held on May 18, 1990 at Region-III Office The inspectors also interviewed other licensee employees including , [ members of the operations and maintenance staff and the technical and i corporate engineering staff.
2., Licensee Event Report Followup (90712 and 92700) a.
(closed) Licensee Event Reports (254/87016-LL; 254/87019-LL; 254/89014-LL; and 265/90003-LL): Containment isolation valves exceeded the 0.6 La limit and resultant ILRT failure.
These are-being closed even though the licensee has yet to submit their supplemental evaluations.
The repetitive failure to meet the local i g} - leak rate test acceptance criteria is being tracked as a violation, % % (See Secti.on 7.a.)
/ N m y - , , i, b.. '(Closed)7 Licensee Event Report (254/90001-LL) and Open Item i ' ' , 3' + , K254/89026-02): Newly Identified Penetrations Requiring Local c A y'f )
' m , *, _eak Rate Testing.
On December 7, 1980, the licensee informed t
' ,, , f :,the region that seven pathways had been identified for addition '+ ( t ' , . , L ~i ' to the Type B and C testing program.
This finding came as a result ,
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f ~ for testi_ng,;or not testing, each penetration.
It was the inspectors "
e understanding,that these penetrations had been challenged during the' s
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? [, ti D ' Unitjl, CILRT.< The seven pathways were: M ,
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.(1);?drywellReactor building closed cooling water (RBCCW) inlet / outlet to .. , . c., ', ? - , s ,7 N q ( V*; .i, (2) Core spray discharge (both loops) ' , , t;;, s (3) Instrument air to drywell/ torus ,, ' ' f,)-} (4)- Service air. to drywell ! (5) Standby liquid control discharge .(6) Clean demineralized water to drywell
(7) Drywell air sampling lines (twenty-one -inch lines)
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On January 8, 1990, the licensee submitted a voluntary LER on this ! c(
subject.
During a site inspection on April 1990 the inspectors J , r4,-a"> reviewed the LER and after discussions with the licensee determined
that none of the penetrations had been correctly vented during the 4e.
. Unit 1 Type A test, therefore, a penalty to the as-left results at ' the 95% UCL was required for the pathways.
Discussions with the L licensee showed that the service air line check valve was repaired
' and tested so that a value (minimum flow path) existed which could
be added to the Type A test results.
No testing was performed on the other pathways.
As a result the actual leakage rate and , l integrity of the Unit I containment at the. time of unit startup was unknown.
On May 18, 1990, a meeting was held in the region in order to address operability of Unit 1.. At this meeting the;1icensee presented information as to why the unit should be allowed to j ,' operate until the. scheduled refueling outage (late October 1990).
After considerable discussion, the licensee was requested to submit
L a Temporary Waiver.of Compliancr. from the requirements of Technical Specification Section 3/4.7.A.2.
This Temporary Waiver of Compliance > and Emergency Technical Specification changes were submitted to NRR on May 19, 1990.
The Temporary Waiver of Compliance was granted on May 22, 1990., i.
Failure to conduct Type B and C testing on the seven pathways . i , ' identified for_ Unit I during and prior,to the 1989 refueling outage ' is an Unresolved Item (254/89024-01(DRS)). The status of the unresolved item will be determined upon the licensee completing the necessary modifications and performing testing of the penetrations.
. For Unit 2, the licensee performed the required modifications to permit testing the penetrations during the Spring-1990 refueling outage.
As-found and, where required, as-left testing was performed.
Because of the actions taken the integrity of the Unit 2 containment l was known prior to unit'startup; Failure to; conduct Type B and C H testing on the seven pathways identified for Unit 2 prior to the 1990 refueling outage is a violation (265/89024-01(DRS)) of 10 CFR 50, Appendix J, requirements. However, because the licensee identified the , violation, because it was-properly reported, and because of the
' ' , corrective actions already taken by the licensee, this violation l-meets the criteria of 10 CFR 2, Appendix C, Section V.G.1 and no "c.
violation will be issued.
' . - e i ' < , ' ' N ' L-This tER is being closed as its resolution for Unit 1 is being tracked
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- [ through the unresolved item.
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(Closid) Licensee Event Report (254/90002-LL): Failure to Meet X " li - Secondary Containment Isolation Requirements.
The licensee determined-M,. ' that the failure was due to instrumentation location, and did not.
' , truly result in' loss of secondary containment.
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L 'l Previously Considered in the Design of Secondary Containment Pressure ' > , Control" discusses the creation of a pressure differential due to.. i ' s- !' " ' air density changes when outside conditions are much colder than j i .< ' inside ones.
The licensee took a conservative measurement of q ')- ' ,; - V ,
- differential pressure by locating their instrumentation near the tbp
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This pressure measurement would be - - . ', d
- less than one taken near the center or bottom of the building.
' Since the requirement is to maintain an average differential s , ' ! pressure, use of the instrumentation located at the top of the - - containment structure is a conservative measure.
No further work ' ' ' ' f is necessary on the licensee's part due to this LER.
- _ 3. a _ Licensee Action ori Prev,iously Identified Items (92701, 92702) I ,,e ' i . , - " i a-(closed) Violation (254/86016-01, 265/86016-02): Failure to take i, ' adequate corrective action in regard to local leak rate test failures.
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. The repetitive failures are being tracked in a new violation being issued in this report.
(See Section 7a).
b.- (Closed) Violation (254/86016-02, 265/86016-03): Change of drywell.
head gasket material without maintaining approved quality records: ' Tho licensee has implemented a program to ensure that spare parts receive the proper classification.
This program was described in . I QAPs 600-4 and 1500-S2.
The licensee was in the process of further , I upgrading these procedures in order to implement Generic Letter lr 89-02, regarding commercial grade procurement.
The inspectors reviewed the parts classification for the gasket material, and noted ,
that it required the gasket to be purchased as Commercial Grade,
for safety-related use.
Additionally, the inspectors found that ' -the drywell head gasket failures have not recurred since the.
l licensee reverted to the original gasket material.
This item is ' L considered closed.
[E c.
(Closed) Unresolved Item (254/86016-03; 265/86016-04): Change of ~ 'drywell head gasket nTaterial without. performance of a 50.59 leview ~ . , . Lor evaluation that standards were similar: The station _ returned to'
the use of the original gasket material,.following evaluation and ' l4 testing'. Therefore no 50.59 was required.
The. inspector reviewed ! - the licensee's test results-as contained in Bate 11e Report " Testing L.
and Evaluation of BWR Drywell Head Seal Materials," dated 8/3/87 f' and the System Material Analysis. Department Report on Gasket Materials; A , f (A87-495, dated"9/10/87).
As noted above, no failures of-the drywell - head gasket have occurred since~the licensee returned to using the , , , original gasket material.
Therefore,-the inspector!! concluded that l' - ' no further action on the part of the licensee'was necessary.- This , item is considered closeds - - , < 't . iL . f
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(Closed) Violation (265/88016 01): Failure to follow Out-of-Service procedure when obtaining a temporary lift of equipment.
The licensee had revised their procedures to clarify the requirements for. obtaining temporary lifts to equipment that is out-of-service.
The licensee also provided training to operations, maintenance, and technical , staff personnel to ensure that further errors did not occur.
This item is considered closed.
4.
Containment Integrated Leak Rate Test Procedure (70307) , ( , a.
Procedure Review ' , The inspectors. reviewed surveillance procedures QTS 150-1, Revisions 16 and 17 " Integrated Primary Containment Leak Rate Test - (IPCLRT)" and QTS 150-8, Revisions 2 and 3. " Determination of Total Containment Leak' Rate" as well as various checklists relating to - performance of the CILRT, relative to the requirements of 1 - 10 CFR Part 50, Appendix J; ANSI N45.4-1972, and the licensee's l< . . ~ Technical Specifications.
Discussions were held with the licensee regarding these procedures.
Specific discussion topics related to , - the methodology of valve lineups and calculation of test results.
All inspectors' comments were resolved; however, in some ' cases the resolution consisted of the deletion of the incorrect guidance contained in the. reviewed procedure with no new guidance given.
The licensee planned to condense the numerous procedures and checklists that presently constitute the CILRT program into one procedure.
This procedure would. include all the required guidance ' !: to perform the test and calculate the as-found and as-left containment. leakage rate.
. b.
Clarification of Appendix J Requirements
> Toinsurethelicensee'sunderstandingofAppendixJrequirements, e i , , ,. and,other applicable requirements, the inspectors conducted numerous
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The following is a summary of the primary clarifications i t ' q <,
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' ' L' ' (1) Periodic Type A, B, and C tests must include as-found results . p i . I r p as hell as as-left.
If Type B and C tests are conducted prior h ' ~ . .
c, , to a, Type A, the as-found condition of the contaihment' must be u
- , k N, t calculated by adding any improvements in leakage rates', which< / s if' ~,. ,y, are the results of repairs and adjustments (RA), to the Type A , , , l ', ,' , test results using the " minimum pathway leakage" methodology.
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, i (a),In the case where individual leak rates are assigned to.
! ' ' l two valves in series (both before and after RA), the~ { penetration through leakage would simply be the smaller of - the two valves' leak rates.
(b) In the case where a leak rate is obtained by pressurizing between two isolation valves, and the__ individual valve's i
leak is not quantified, the as-found and as-lef t
t penetration through-leskage for each valve would be 50% of q the measured leak rate if both valves are repaired.
, , i (c) In the case where a leak rate is obtained by pres.urizing-J ( between two isolation valves and'only one valve is
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> repaired, the as-found penetration leak rate would be ' either the final measured leak rate, or one half of the F originally measured leakage, whichever is less.
However ' .in either case, the as-left penetration.through leak rate would be zero (this assumes the repaired valve leaks 'zero.)' ' (2) - All air sources lef t inside containment during'a CILRT must be vented to atmosphere during the test.
If they are not vented, > ! _ -then they must be monitored.' In the latter case, the CILRT - " penalty taken needs to take into account the readability and sensitivity of the monitoring instrumentation.
If the air . ~ ' ' sources are neither vented nor monitored,-the penalty added~to ~it' c the CILRT results most assume that the air source pressure "
' dropped from its design pressure to the test pressure during j' (j ',f.q . , _,p %,, ,the course of the test.
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. ' (3) _When determining the results of the Type B and C tests, the ( ~
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iminimum readability, accuracy, and sensitivity of the 1., . , _ i instrumentation needs to be accounted for.
No leakage rates t ' > ^ , ii.
' should be reported as zero, but rather reported as the minimum ~ ? ' g ,, q
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? ' 6.T, "! ' Si cont'ainme'nt Integrated Leak Rate Test Result Review, Unit'l (70323 and 90713)r; ' ' ,z . .ih b; II Y(a. !Rhview of' Instrumentation Data M
> ., . , ' - ^ ; y > . ,gt 'eThe ins,p6ctors reviewed the calibration data and determined that all' o . c;dtheinstrumentsused'intheCILRThadbeenproperlycalibratedand l ' ' that the correct weighting factors had been placed in the computer ' e L ,? 'N program as required._ The following' instrumentation was used - ,[O L throughout.the test: = + . %n ,\\d'I
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RTDs (Thermistors)
L .. , Humidity (Dewcells)
t - . Pressure gauges (Vibrating cylinder)
' ! Flowmeter (Rotameter)
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knspectionReportNo. 50-373/89017(DRP) documented our inspection of . ' ? ? s i
- the trial tests of ceramic thermistors for use as temperature - I, . r.
sensors during containment integrated leak rate tests (CILRT).
The ' ' ' , s4 tests were conducted at the LaSalle Station.
On October 17, 1989, , ' ' lthe licensee submitted to the NRC the " Evaluation of Thermistors Temperature Sensors For Use In Integrated Leakage Rate Testing" p report of the data obtained during the trial tests.
The inspector- ' - reviewed the report and concluded that the use of hermetically- - sealed, glass encapsulated ceramic thermistors in lieu of platinum e RTDs was acceptable for CILRTs.
. ' b.
CILRT Data Evaluation A 6.17 hour CILRT was performed during November 15, 1989, at 64 psia following satisfactory completion of the required temperature stabilization period.
Data was collected every 10 minutes.
The inspectors independently evaluated leak rate data for 6.67 hrs (up l to the valving of the superimposed leak rate) using BN-TOP-1 total i time formulas to verify the licensee's calculations of the leak rate and instrument performance. There was good agreement between the inspector's and licensee's results as indicated by the following summary (units are in weight percent per day).
.. . Measurement Licensee Inspectors (6.17hr) (6.67 hr) Leak rate measured 0.379 0.375 duringCILRT-(Lam)- ' ~ Lam at upper 95% 0.448-0.442 confidence level , Appendix J acceptance criteria at 95% UCL: <0.75 La = <0.750 wt% day.
At the completion'of'the CILRT and the supplemental test, corrections- ' to the calculated Lam at the 95% UCL due to changes in volume of various water sources inside containment were calculated.
The - inspectors it. depend 6ntly verified that no correction to Lam at the-95% UCL was required, s h ' g '. [ (
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Supplemental Test Data Evaluation - 5.., ' ' Af ter the satisfactory completion of the CILRT, a known leakage rate ^ N of 8.26 scfm, equivalent to 1.012 wt%/ day was. induced.
Data was collected and analyzed by the licensee every 10 minutes.
The r-inspectors independently evaluated leak rate calculations using the datasubmittedbythelicensee,includingthepost.testcalibration '* "U ' ; of the; flowmeter, to verify the licensee s results..After 3.33 %' hours, the supplemental test was terminated with satisfactory " L results as indicated by the following summary (units are in / < 4.. wt%/ day).
' , < , . ., 4L Measurement Licensee Inspectors t
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' J.,7 Measured leakage rate, Lc, 1.350 1.350
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" ' during supplemental test '; 4' < , , , ' p4 Inducted leakage rate, lo 1.012 1.012 ' > '
s > - '!o i$;, f .Lc.(to + Lam) -0.041-0.037
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Append'ix J acceptance criteria -0.250 < [Lc -(Lo + Lam)) '< 0.250 ' l' ' ' '
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c CILRT Valve Lineup Penalties, - i , , Due to valve configurations which deviated from the ideal ' 'f', f 1.
penetration valve lineup requirements for the CILRT, the results of , ,
LLRTs for such penetrations must be added as a penalty to Lam at the _
' ' > 95% UCL.
The following penalties.must be added using the " minimum . pathway leakage" methods: " Local Leak Rate Test Value , . " Penetration (System) (Units are"in SCFH)
'E' Primary sample valves 0.035 ACAD, 1.5 RHR A-3.02 g.
, , RHR B 7.72 i c Feedwater 6.72 Drywell floor drain pump
Orywell equipment drain pump
- RCIC steam exhaust 4.22
. ~ ' RCIC drain.
5. 0 ' - . '. ': HPCI steam exhaust 1.61 ' HPCI drain 0.5 ^ Electrical-penetrations 4.83 Oxygen analyzer
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1. t;';i 1-262-2-3A, B;and 4A, B
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le - % ' ". i RBCCW outlet
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< ' 4' Clean demineralized water
Drywell air sample lines
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- ('f l Total Type B and C Leakage Penalty = >35.4 scfh, equivalent to
-.>0.072 wt%/ day.
- These penetrations have never been Type C tested, therefore, their
' -"as-left" leakage rate was unknown.
Since the valve lineup for these' penetrations during the CILRT was not correct, the "as-lef t" ' condition of the Unit 1 containment was unknowr,at the time of unit l< .startup.
This is discussed in Section 2.b.
d.
As-Found Condition of Containment . .,' ' The as-fo'und condition is the condition of tne containment at the beginning'of the outage prior-to any repairs or adjustments to the containment boundary., The inspectors reviewed the licensees's summary of the containment penetration LLRTs (Type B and C) . performed prior to the CILRT in order to determine the amount of leakage rate improvement due to ras.
Based on the. results revi6wed, the inspectors determined that the amount of the leakage improvement priortotheCILRTwas>2492scfh(serviceairkenetrationcouldnot- , ' be pressurized), or the equivalent of >4.871 wt / day.
Based on-this, the final containment leakage rate, at the 95% UCL, was >5.412 wt%/ day.
As in the case of the as-left condition several penetrations were not tested and their leakage rate could not be accounted for in .." , 'the above value; however, the as-found leakage rate has exceeded the maximum limit of <0.75 wt%/ day.
The containment was considered to have failed its as-found periodic CILRT.- < No violations or deviations were identified.
6.
Review of Reactor Containment = Building Integrated Leak Rate Test Report- ' for Unit 1 (90713) i The inspectors reviewed the " Reactor Containment Building Integrated Leak . " Rate Test, Quad ~ Cities Nuclear Power Station, Unit 1, November 14-15, J-1989" report submitted by the licensee on February 6, 1990. While the Q e t report accurately describes the results obtained during the Type A and e - ' , ps '
verificationi> tests, it failed to address the effect that several untested (sm;" S y
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)y,, T ;. , . 3(C PT" / i p f, _* . a - l; > a , ,, , ~ 1. I ! '# ' - > + , , , ,, ' - '
, ., i ' I ,) ' '.
1 , andtnon-vented pathways could have on the "as-found" and "as-left" containment test results.
These pathways are discussed in LER 90-001, dated, January 8, 1990.- This issue is discussed in Section 2.b.
.
i , i., No' violations or deviations were identified.
7.
Review of Local Leak Rate Testing (Type B&C) (61720) a.
. Program Status The licensee has had a continuing problem with their local leak rate test program.
(See Inspection Reports 50-265/89018, 50-254/86006, 50-254/86016, and 50-265/86018.) This has resulted in their exceeding the 10 CFR 50 Appendix J as-found acceptance criteria for both the summation of Type B and C results using.the maximum flow path method (<0.60 wt%/ day)' and for the CILkT;using the minimum flow path method , ., (<0.75 wt%/ day) for a considerable number of years.
Presented below ,' I is a table, for each unit, showing valves or systems that have had a (. chronic problem with failures.
Following the table is a discussion of the licensee's corrective actions to date.- ,, 'The licensee has been unable'to implement a successful corrective action program resulting in as-found leakage which fall within the above acceptance criteria.
In addition the liceii:ce has neither > adjusted the surveillance test.ing program.nor the preventive l maintenance program to be commensurate with the demonstrated I.
unreliability of these containment isolation valves to perform their
safety function throughout an entire fuel cycle.
This continued failure to demonstrate adequate corrective actions is considered a i violation of10 CFR 50, Appendix B, Criterion XVI and Criterion II ' < as implemented by the Commonwealth Edison Company Quality Assurance Topical Report CE-1-A, Revision 57 (254/89024-02(DRS) and 265/89024-02(DRS)).
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f sa
-- , , a e," e g... , . , , J: Valve, h .74 - 76: 77:
80 82 - 84 ~86
.89 ' , n4 .t s , s , wi 'MSIV A in k ' e X X-( ' + ' . . -X1 XD.
c %g V: MSIV A outi 1" X-X ' ' ' . . fV.
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X X, X X t 'a > h d! MSIV C out " ' X X -~ X X , ' !, - ,. 4 A MSIV D iniJ e, X X.
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X X: j '* i~ a ' < ' ? _- ... , ., .i . ,s ' Drywell Exhaust-X X-X X ' , , , n, n> u. . ' , , a ]# J Drywe,ll; Floor: Drain: X-X' X
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X 'X-X .X-X - + .- o ' W.
, JCADKin Drywell X' X . _u ., , , '\\' {u., Drywell Head Access Hatch X-X
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' UNIT 2 VALVE FAILURE HISTORY .
' Year of Test.
, Valve
76 78'
81-83
86
90 ) MSIV A in. X X X-MSIV A out X X X X.
X X MSIV B in X X X' MSIV B out X X X MSIV C in X X H MSIV C cut X ' s MSIV D in X q MSIV.D out X, X , . : . l I i Feedwater Check Valves
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X.
~X'
n: w . " , - . . ,.y+ .. L DryywelliFjoor Drafn, X X j .. HPCI,. Steam Exhaust X X X ' ' !- , , u' . > . , < b,;.; Main Steam Isolation Valves - , t , . , , Although the MSIVs have. had 'a history, of failing, the licensee has c
experienced a. decrease in-leakage from these valves over the-lasti four years.
This appears to be due to' increased preventative: . maintenance as well as better testing methodology.
Unit 2 has only . - had one valve failure in the last four years.
Unit I had two valves
, ' fail during the last outage, but none the cycle before, Continued ' efforts should result in acceptable leakage results in future < outages.
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., , <w. ...n, _ , + b The licensee has in their technical specifications and procedures . ' ' . "i 'that the MSIV leakage results do not need to be added to the Type B&C: f.g i
, ' l+ totals.c The inspectors requested that the licensee produce the , ? Y exemption from the requirements of 10 CFR Part 50, Appendix J, which allows them to remove the MSIVs from the totals.
The licensee was i '
yr X unable to produce this exemption by the end of the inspection.
This 'has been made an Unresolved Item (254/89024-03(DRS) and .' 265/89024-03(DRS)) pending the production of the exemption or:the . correction of the technical specifications.
'
., " '
- c, Feedwater Check Valves
, , The feedwater (FW) check valves have'been a continual source of leakage for the licensee.
The; licensee has attributed the failures, to (1) testing requirements - the valve was designed for high pressure water usage, but was. tested with low pressure air; (2) valve = manufacturing idiosyncracies - the valve used was only available in
" rough casting" as a commercial grade item; and (3) test methodology,- the only drain in the line is upstream of one of the
, i isolation valves; therefore, the valve has to open to allow draining of the test volume.
Once open there is insufficient p' essure to reseat it.
(1) Testing Requirements Following a LOCA the FW check valves could be e> posed to l containment atmosphere.
Therefore 10 CFR Part.!0, Appendix J, ' requires that the valves be tested at containmet.t design l pressure (48 psig) with air as the testing medium.
Since the s valves were originally designed for high pressure water, the 1icensee modified the valves to attempt to provide a better , sealing surface.
i
r l-Modification M4-1(2)-83-43, which was installed in the 1983/84 time frame, added a rubber 0-ring to the valve trim in an s attempt to reduce leakage.' In order to add the 0-ring, the modification added a machined groove in the valve trim.
The inspectors reviewed the. modification approval letter, including ' 10 CFR 50.59 evaluation.
The inspectors noted that the 50.59 F analysis was inadequate in that it did not properly consider the effects on valve leakage requirements, as contained in technical specification 3/4.7.1.
Addition of a machined groove-- ~ combined with the failure of~the non-safety-related 0-ring would increase the leakage through the valve.
The 50.59 analysis only. addressed valve operability and did not consider i
, ,the requirement on the valve as a containment isolation barrie_r e f xfollowing an an tient.
The failure.to properly consider all f J^g ~, . s safety functio... of the valve is considered a violation of Y, .. -
4 p /,[, ", f i 10 CFR 50.59 (254/89024-04a(DRS) and 265/89024-04a (DRS)). ,
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Jed to experience failure of the FW check M Thei licensee cont ' o
. ' - . ' [ p' valves, including failures due to 0-ring degradation.
In 1987, . E ,f sJ the licensee performed an engineering evaluation and determined j that the material used in the non-safety-related 0-ring was i , ,,
ffj unsuited for nuclear service.
The licensee then changed the
, ' 7*) 0-ring material to a compound better suited for the conditions ' that it would see.
In' discussions with the licensee, the
" inspectors noted two concerns with this change: first, no i 50.59 evaluation was performed to show that the material change , did not affect the' safety functions of the' valve.
Secondly, the licensee continued to classify the 0-ring as a non-safety- " related part, even though its failure could prevent the FW check- .; , r . valves from performing their safety function.
Failure to
perform a safety evaluation when the 0-ring material was .; changed is considered a violation of'10 CFR 50.59 j '(254/89024-04b(DRS); 265/89024-04b(DRS)). The licensee ' , , l' stated that the original classification of the part was obtained from BWR Engineering..In 1987, when the material was . - changed, the station did not rereview the basis for 0-ring ,, parts classification.
The. licensee acknowledged that the ., -0-ring performed a safety function and stated that a concerted effort was.being made to verify and/or. correct all'of the.
' c c stations' spare parts classifications.
This is being done as
part of their response to Generic Letter 89-02 " Actions to > improve the Detection of Counterfeit and Fraudulently Marketed Products."
- (2) Valve Improvements The FW check valve is an 18" tilting check' valve manufactured by Crane Corporation es a commercial grade item.
Over the r years the licensee improved the quality.of the valve once ' . ' , ' received.
(The following items.are not necessarily.in order of occurence.) Fof example, the licensee imposed tolerence ' requirements on the location-of the valve hinge pins in order
' .to ensure better closing characteristics of the disc.
The. licensee added spacers to the bushings in order to ensure that ~ -' sideways movement of the valve disc was minimized.
The licensee provided sturdier hold down clamps and hinge pins to ensure that s O the(valve disc did not shift during operation.
The maintenance ' f' department was taking a positive and aggressive approach towards . . w.. A improving-the valve and reducing the leakage.
'
m% v , 1M (. (3) cTest Methodology L '% , % $'e (3 y q yj
q, 'r i ;The licensee had only one drain on the FW check valve test volume, e , + This drain is inside the drywell upstream of the inside check i p.- '
, , gy ,a> valve. 'In order to drain the line, valve 1(2)-270-59A(B) opened 7' ; k a s .y - , f; lA (YE C A fjl
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4: , , ' Land then reseated.
The licensee stated that there was insufficient - - ,
, I ' ' %4, i I ' pressure to reseat the valve following draining, although it may have been properly seated prior to' draining.
The licensee has
) requested that additional drain lines be added to the test ' ' f i
- }t volume so that the volume could be drained without lifting any
. , t n-of-the valves.
This modification request was.being processed at ' g the tinie of the inspection.
' d.
Main Steam Drain - , These valves were replaced in 1987/88 with a higher pressure class valve under Modification M4-1(2)-85-48. The licensee experienced less leakage this last cycle following the modification.
L e.
Cleanup Suction This valve failed the last three cycles on Unit 1.
There has been o.
only one failure on Unit 2, and that was in 1976.
The licensee , l' performed a modification (M4-1(2)-88-29) on both units during the 1989-1990 outages in order to replace the piping with stainless steel - piping to prevent stress corrosion cracking.
As part of this modification the valve on both units was also replaced with a stainless + steel one.
f.
Drywell Purae - i l The licensee has experienced sporadic problems with this four valve volume.
All four valves in the-Unit 2 purge line were replaced during one outage, which appeared to reduce the failure rate for.
this penetration.
The licensee ~ stated that the Unit I valves have been~ replaced one at a time rather than all at once, and that this has contributed to the Unit 1 continuing failure rate..The licensee
~ will establish a preventive maintenance program based on the experienced life expectancy of.the valus, as discussed below.
g.
Drywell Exhaust > The licensee has attributed the failures of this six valve volume
,.,
to several different factors.
The first has been that the 24 inch '" ' butterfly valves did not have a 40 year life expectancy and-required 7i( sN j periodic; replacement.The9 have been replacing the valves and were estthlichin .- (The purge line used the tame type valve.)
I .- i f,' ' j '. ', U
preventative mai.9enar.ce schedule to prevent further failures.
. ' f ' \\ i Secondly, the licensee stated that there was a relief valve in the . s( .
6 liite set to relieve at 50 psig.
The licensee routinely pressurized l ', t '
c . , y? '; (1 ,the lines to two psi above test pressure (48 psig) in order to - (it , >- s ensure that any pressure losses due to the test equipment were
" . - ?, minimized; This would result in reaching the relief valve ~ ; , ' . ,, ,1* - 4
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s -. o [ setpoint.
Also any downward drift in the relief valve setpoint would result in the valve opening during the test.
The licensee had f not, at the time of the inspection, determined required actions in regard to the relief valve.
~ < ' The. inspectors examined a replacement valve for one of the 24" , butterfly valves and noted that the flanges and packing on the ! containment side of the upstream valves were.not testable when the , penetration is pressurized between the valves.
The requirement to ! perform Type B testing of the flanges and packing was being met for
Lthe "as left" condition by the performance of a CILRT every outage.
' . However, when the licensee-returns to a normal CILRT test schedule, then Type B testing of the flanges and packing will have to be. ' performed in accordance with Appendix J.
'The licensee was asked to determine how the testing requirements for these flanges would be met.
This is an Unresolved Item (254/89024-05(DRS) and i 265/89024-05(DRS)). ' h.L Drywell-Floor Drain Sump Valves These valves were originally installed with the operators upside down (pointing towards the floor).
In 1985'the licensee' modified
the valves to have the operators upward.
This appeared to' reduce the leakage.
However, the valves have continued to show higher than
expected leakage rates.
The licensee was evaluating changing the valve to a type which was not as sensitive to crud or other particulates, since any dirt or other small particles which went into e.
' the sump would end up in the line.
The evaluation was not complete . ( at the time of the inspection, p ('; 1.
HPCI Steam Exhaust' Check Valves s
.
~ ik h.
,' This valve like the feedwater checks, has e'perienced repeated c failures.
Unit I has traditionally experir.nced worse failures than ' '
.y i . Unit 2.
The licensee has attributed som'.: of these failures to.
i ! < t * Edegradation of the soft seat due to s%am impingement.
In 1985, the licensee switched to a valve design which moved the soft seat 3 material away fro ~m the steam path.
They ordered two different
}
- +
'
,
, , ' , , valves (of basically the same design) and installed one during the D '
', C ' 1985 refueling out' age on Unit 1.
This valve, manufactured by C&W,' i -t . did not last the cycle.
It was replaced in 1987 by a Marlin valve, ~
H ! qs~ which still further recessed the soft seat, in 1987.
This also did _ ' not last,a cycle.
The Unit 2 valve was replaced in 1988, and failed in : the^1990(testing.
The inspectors examined the valves and noted that ' ' the-soft seating material appeared to have been-torn away from the , valve seat.- The licensee suspects HPCI operation at low loads, which'
causes the valve to chatter, was contributing to the failures.
.3 c ' $< !The licensee proposed to modify the HPCI surveillance procedures to '
,. reduce.the time spent at low loads.
The licensee replaced the failed > .t ,. '1
.
41
9 - - -. -
.~ l i
, 4 e .
v :.-
> valves with a like-for-like replacement, and requested corporate ' nuclear engineering to resolve the problem.. The inspectors discussed with the licensee the likelihood that the presently installed valves
J , may fail early in the operating cycle.
The licensee committed to ' performaleakratetestonthevalvesmid-waythroughtheoperatIng '
m ' cycle, and to replace the valves as necessary.
, N . i +
- l,J1 87, Review of Local Leak Rate Testing (Type B and C) Program t
_ ., ..,, i.s ThiinspeEtors reviewed the following local leak rate testing (LLRT) ) ,! '
[% procedures relative to the requirement of 10 CFR Part 50, Appendix J.
,,the FSAR, and the Technical Specifications:
- -
.- < - ., , ^^ !. '* _ -Local Leak' Rate Test, Pressure Decay Method, QTS 100-1, Rev. 9-f r ! l: i * s Local Leak Rate Test, Flowmeter Method, QTS 100-2, Rev. 9 '
Several' individual LLRT procedures (for specific valves) were also - ^ reviewed.
'y , , . . .
,
The inspectors' comments were satisfactorily resolved except as noted
'
'
s
<
y ' a.
The inspectors were not able to assure that all penetrations ' ' > requiring Type B and C testing were being tested, since neither the . UFSAR nor the lechnical Specifications included a listing of all l penetrations indicating whether. Type B and C was required or not.
. -, The inspectors repeated to the licensee the need for the development l of such a UFSAR Table to be submitted to NRR for their review and approval.
This issue has been discussed several ti.nes with the Corporate ILRT Engineer for applicability to the Presden, Quad Cities and Zion sites.
The-licensee stated that the development of such a table for submittal to NRR was in progress, with a scheduled ' ,. I completion date during 1990.
b.
The LLRT practice.during the Unit 1 outage (1989) was to perform , the majority of the tests using the pressure decay method.
After discursions with the licensee a shift to the constant pressure - makeup flow method was noted during the Unit 2 outage _ l , (1990) for a majority of the penetrations.
c. - The. inspectors reviewed the test practices and the equipment used to perform the constant pressure - makeup flow tests.
It was the licensee's practice to place the pr_e sure gauge at the penetration and to start the test approximately 2 psi above Pa, therefore, no correction for pressure drop between the test rig and the penetration would be required.
The pressure regulator in use on the test rig appeared to have a dead band larger than desirable and was sluggish in its response to j !
, ., ^
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' . (_t. . pressure changes due to flow changes.
In addition an internal pressure drop of approximately 2 psi was noted at flows typical for penetrations with marginal leakage rates.' By the time of the Unit 2 outage the licensee had replaced the pressure regulators with a much more responsive model.
The inspectors had no further comments regarding the testing.
d.
The inspectors also had questions as to how minimum and maximum pathway leakages were being determined, especially for the four and s < i six - valve purge volumes.
A meeting was held in the Region on February,13, 1990. During this meeting, the licensee discussed the ' ., test methodology for each penetration.
Neither the individual o penetration nur the generic test procedures contained the necessary , guidance to make such determinations.
The guidance given in the CILRT procecare QTS 150-8 was flawed and was deleted prior to the Unit 2 outage.
This issue is an Unresolved Item (254/89024-06(DRS);. .- 265/89024-06(DRS)) pending the licensee's revision of its LLRT
,'y procedures and reviews by the inspectors. ' ' , ., , . i9.
Unresoived items ' , ,, , . .~ i .t , . NN . Unresolved items are matters about which more information~ is required iri/ t , N [ ' or' der to ascertain whether they are acceptable, violations or '.
' .y.
i ?'5' ?' ., deviations.-UnresolveditemsdisclosedduringtheinspectIonare \\I'3;i e ' ' y, discussed.in Section 2.b, 7.b, 7.g, and 8.d ' - , , ..e s.
. , r ,s] 10.; Exit Interview ,' , ,, . w,- < , -, ,
The insipectors met with licensee representatives.(denoted in Paragraph 1).
a - . , - l s throughout3 the inspection.
A preliminary exit was conducted on ' j
.< November.4,1 1989, and on April 12, 1990, prior to leaving the site.
The
e , ", - ,' ', final exit interview, following the review of all the data submitted by i ' therlicensee, was conducted on April 26, 1990.
Additional meetings were , ,.:3* held May 17-18, 1990 to discuss operability of Unit I containment.- The ' t s 9A
- . inspectors summarized the scope and findings of the inspection.
The ! licensee acknowledged these findings.- The inspector also discussed the " likely informational content of.the inspection report with regards to;
> documents or processes reviewed by the inspector during the inspection.
[ l . , ' The licensees did not identify any such documents or processes as
- i proprietary.
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