IR 05000277/1987012
| ML20214S726 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/01/1987 |
| From: | Anderson C, Chung J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214S713 | List: |
| References | |
| 50-277-87-12, 50-278-87-12, NUDOCS 8706090388 | |
| Download: ML20214S726 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-277/87-12 Report No.
50-278/87-14 50-277 Docket No.
50-278 DPR-44 License No.
DPR-56 Priority - -
Category C
Licensee:
Philadelphia Electric Co.
2301 Market Street Philadelphia, PA 19106 Facility Name:
Peach Bottom Units 2 and 3 Inspection At:
Delta, Pennsylvania Inspection Conducted: April 20-24, 1987 Inspectors:
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Jid W. thund', Lead R6 actor Engineer
' date Approved by:
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!U C. Anderson, Chief, Plant Systems Section date Inspection Summary:
Inspection on April 20-24, 1987 (Combined Report Nos.
50-277/87-12 and 50-278/87-14).
Areas Inspected:
Routine, unannounced inspection of Containment Integrated Leak Rate Test (CILRT) procedure; test witnessing and preliminary evaluation of Local Leak Rate Test (LLRT) results; and facility tour.
Results: No violations or deviations were identified 8706090388 87060tf PDR ADOCK 05000277-G PDR
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DETAILS 1.0 Persons Contacted Philadelphia Electric Company J. Campbell, Engineer J. Cotton, Superintendent-Services G. F. Dawson, Maintenance Engineer
- R. S. Fleischamann, Manager, PBAPS
- A. Fluvio, Technical Engineer W. Fredricks, Engineer
- J. Jordan, Performance Engineer
- D. Shaulis, Test Engineer B. Smith, Startup Engineer D. Warfel, Maintenance Supervisor Observers
- H. Abendroth, Atlantic Electric Co.
- M. Phillips, Public Service Electric and Gas Co.
Bechtel J. Bodnar V. W. Morris USNRC
- T. Johnson, Senior Resident Inspector The Inspector interviewed other licensee employees during the course of inspection.
NOTE:
- Denotes those present at the exit meeting on April 24, 1987.
2.0 Local Leak Rate Testing (LLRT)
The purpose of this inspection was to ascertain that the LLRT was conducted in compliance with the requirements and commitments referenced in the following sections 2.1 and 2.2, and that the test results met the acceptance criteria specified in the station procedures and Appendix J, 10 CFR 50. The procedures were reviewed for their technical adequacy to perform the intended activities.
2.1 References
10 CFR; Part 50, Appendix J. Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors l
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Technical Specifications Final Safety Analysis Report (FSAR)
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ANSI /ANS 56.8-1981, Containment Systems Leakage Testing Requirements
USNRC I&E Information Notice No. 85-71; Containment Integrated Leak Rate Tests 2.2 Documents Reviewed Administrative Procedure, A-26A, Procedure for Corrective and Preventive Maintenance using CHAMPS, Revision 4.
- A-25, Preventive Maintenance Program, Revision 3.
A-14, Plant Modification, Revision 12.
Licensee Event Report (LER), No. 87-002-00, Local Leak Rate Tests (LLRT), March 13, 1987.
Surveillance Test, ST 20.000, Local Leak Rate Surveillance Test Program, Revi sion 1.
Maintenance Work Instructions, December 31, 1986.
Internal Memorandum on Temporary Procedure Changes, April 21, 1987, from R. S. Fleischmann.
Proposed Changes to Technical Specifications, October 10, 1986.
LLRT History Log Book Findings (1). The inspector noted that numerous gate, globe, and butterfly valves were tested in a reverse direction for the LLRT.
In accordance with paragraph III.C.1, Appendix J, 10 CFR 50, a type C test in the reverse direction is acceptable, provided that the test yields equivalent or more conservative results.
The inspector did not find any objective evidence that the reverse direction tests would provide equivalent or more conservative results than that of the forward direction tests.
However, the licensee submitted an amendment to technical speci-fication on October 10, 1986, in which the reverse direction
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LLRTs were proposed.
This item is an unresolved item pending final disposition of the proposed changes to the technical specifications and subsequent NRC inspection (50-277/87-12-01; 50-278/87-14-01).
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(2). The inspector was informed that valve. failure trending guide-lines would be developed and implemented in six months. The guidelines would enhance the preventive maintenance program for those isolation valves with failure records.
(3). Administrative control procedure, ST 20.000, Local Leak' Rate Surveillance Test Program, needs some clarification regarding the "As Found" and "As Left" data taking requirements. The procedure incorporated the "As Found" and "As Left".LLRT requirements and was consistent with the intent of the NRC IE'
Information Notice 85-71. However, data sheets in the procedure did not have specifications as to "As Found" and "As Left" data taking requirements. The licensee stated that the procedure, ST 20.000 and associated data sheets, would be revised by January 1,1988 to clarify the data taking procedures and requirements for the "As Found" and "As Left" LLRTs. This is an unresolved item pending implementation of the revised procedures and sub-i sequent NRC inspection (50-277/87-12-02; 50-278/87-14-02).
(4). A Main Steam Line Drain valve, M0-74, was identified as a leaker
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and was disassembled on March 17, 1987 for repair.
However, prior to the repair the valve should have been leak-tested for an "As Found" leak rate in accordance with the requirements
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specified in the station LLRT surveillance program.
This failure to measure the "As Found" LLRT and subsequent failures to meet the LLRT limits imposed in the Limiting Conditions for Operations, technical specifications, resulted in a Licensee Event Report (LER) per 10 CFR 50.72 and 73 reporting
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requirements. The inspector determined and the licensee con-curred that a contributing factor to the above failure was an inadequate procedure, ST 20.000, as discussed in the previous item (3).
In addition to the ST 20.000 revision, to prevent recurrence of such failures the licensee revised administrative
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procedure, AP-26A on February 23, 1987 (PORC No. 87-82). The revision incorporated a provision to verify the "As Found" LLRT-requirements in the Maintenance Request Form (MRF). This revision would enhance the "As Found" LLRT program, in conjunc-tion with the failure trending program discussed in the above-Section (2).
(5). Surveillance test procedure ST 30.134 specified a provision which would permit water tests for Residual Heat Removal (RHR) sample isolation valves, A0-8098A-D and A0-8099A-D, to meet the LLRT requirements. The inspector was informed that these valves were not containment isolation valve as defined in the technical j
specifications, and that the system would be normally filled with water during a postulated accident.
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The inspector determined that the rationale for such water tests was acceptable for the valves, and no unacceptable conditions were identified.
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2.3 Test Witnessing The inspector witnessed the performance of test activities to verify that:
approved test procedures were available and in use.
the procedures were adequately detailed to assure satisfactory performance.
parts and materials were properly identified.
qualified test equipment and tools were used.
A portion of ST 20.042-1, LLRT "B" RHR Injection Valve, M0-10-258, was witnessed on April 22, 1987.
Test instruments included Heise pressure gauge and a flow meter.
They were calibrated on March 21, 1987. The test was performed at full accident pressure of 49.2 psig and a flow measurement technique was employed.
The test pressure was maintained for an hour for stabilization, followed by one hour of data taki'g. The leak rate data was taken every 15 minute intervals.
"As Found" leakage was 2,803 cc/ min.
This exceeded the previous leakage value of 960 cc/ min.
The licensee stated that a Maintenance Request Form, MRF, would be issued to tighten the valve leak in order to reduce the leak rate for the "As Left" LLRT value.
The inspector noted that the test procedure, ST 20.042, contained numerous temporary changes. However, no unacceptable conditions were identified.
2.4 Test Results Evaluation The Technical Specification require that the total of LLRT results be limited to sixty percent of permissible leakage (0.6La). This is equivalent to 73,407 cc/ min. A running total of "As Found" LLRTs was 59,232 cc/ min on March 12, 1987. This was within the acceptance limit.
On March 13, 1987, a LLRT was performed on penetration No.
510 using a surveillance procedure ST 20.082.
This "As Found" LLRT value was 66,552 cc/ min.
This represents an increase of 66,462 cc/ min over the previous "As Left" leak rate measurement for the penetration. This excess leakage from penetration No. 51D increased the running total of LLRTs to 125,694 cc/ min.
This exceeds the acceptance criterion of 73,407 cc/ min by more than 50,000 cc/ min.
In accordance with an event reporting requirement, the licensee issued a LER No. 87-002-00 on the excess leak rate. A subsequent repair on the leaker reduced the "As Left" LLRT result to 620
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cc/ min. This was within the acceptance criterion. A similar event was repeated on penetration No. 8 on April 7, 1987 when LLRTs were
performed per ST 20.021 and 20.022. Due to excessive leakage, the flow meter for the LLRT measurement went off-scale.
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Even though no unacceptable conditions were identified, the inspector noted the excessive "As Found" leakages. The inspectors questioned the adequacy of the licensee's preventive measures to minimize such leakages. The licensee stated that failure trending guidelines would be implemented in six months to monitor the leakers. They stated that they plan to improve the preventive maintenance program.
The following selected LLRT records'and associated MRFs for the past 2 years were reviewed:
ST 202.029, LLRT Main Steam Line Drain Penetration No. N-8,-
Revision 4, March 21, 1986, performed April 7, 1987; March 16,
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1987 failed MRF 87021A3; March 15, 1987 - failed, SMRF 3742; April 8, 1987.
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ST 20.058, LLRT-SV-2671D, 29780, penetration No. N-51B,
Revision 3, performed April 6, 1987.
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ST 20.006, LLRT-CRD Removal Hatch Penetration No. N-6, j
Revision 4, performed August 15, 1986.
ST 20.003-A, LLRT-Drywell Equipment Access Double 0-Ring,
penetration No. N-1, Revision 5, performed March 24, 1987.
- ST 20.045-1, LLRT-Core Spray "B" Loop, penetration No. N-16A, performed July 5,1985.
MRF 8504365, CRD Hatch, completed June 22, 1985; procedure i
M.7.5 used.
MRF 8606172, MO-2-14-012B, completed August 12, 1986.
i MRF 8504406, M0-2-02-074, completed June 24, 1985.
MRF 8606034, M0-2-02-077, completed August 11, 1986.
MRF 8503652, M0-2-02-077, completed July 11, 1984.
MRF 8600573, MSIV A0-2-01-0860, completed January 25, 1986.
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MRF 8501789, A0-2-01-0802, completed April 29,-1985.
MRF 8560101, A0-2-01-080A, Inboard MSIV-RPs Limits, completed December 19, 1985.
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MRF 8503229, A0-2-01-080A, Packing, completed June 18, 1985.
MRF 8661278, SV-26710, completed April 15, 1987; Operational Verification Form (0VF), LLRT April 6,1987.
MRI 8502223, A0-2-01-0860, MSIV, completed April 15, 1985.
MRF 8503223, A0-2-01-0800, completed June 18, 1985.
MRF 8560185, A0-2-01-086A, completed December 12, 1985.
MRF 8560184, A0-2-01-080D, RPs Limits, completed December 19, 1985.
MRF 8502192, Tor s Penetration N-220, completed June 24, 1985.
Within the scope of this review, no unacceptable conditions were identified.
3.0 CILRT Procudures The inspector noted that the procedures for the containment Integrated Leak Rate Test (CILRT) were not in conformance with the analysis methodology specified in Appendix J, 10 CFR 50.
The licensee employs both Total-Time (TT) and Mass Point (MP) methods.
However, the acceptance criteria and the official test method in their records are based on the mass point method.
Subsequently, the licensee revised procedures ST 12.5-1 for unit 3 and ST 12.5 for unit 2 on April 23, 1987, so that the official test method would be the total time method.
The above revisions to the procedures would conform the station CILRT methods with the Appendix J requirements.
4.0 Personnel Training and Qualifications The qualification and training of selected test personnel were discussed with a licensee representative.
In addition the inspector evaluated the performance of test engineers during the test witnessing.
The inspector determined that the test engineers qualifications met the requirements specified in ANSI N 18.1-1971 " Selection and training of nuclear power plant personnel" They were knowledgeable of their responsibilities and technical aspects of leak testings.
No unacceptable conditions were identified.
5.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable, or whether they are violations or deviations.
Paragraph 2.2 contains two unresolved item _. _ _ ___ ___ - ____
l 6.0 Tours The inspector made several tours of the plant including turbine building, I
penetration areas, drywell, control room, and refueling floor, in order to
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monitor activities related to performance of the LLRTs.
No unacceptable conditions were identified.
7.0 Exit Meeting Licensee management was informed of the purpose and scope of the inspection at the entrance interview.
The findings of the inspection were periodically discussed and were summarized at the exit meeting on April 24, 1987.
Attendees at the exit meeting are listed in Section 1.0 of this report.
At no time during the inspection was written material provided to the licensee by the inspectors.
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