IR 05000277/1989006
| ML20245D500 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/12/1989 |
| From: | Eapen P, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245D498 | List: |
| References | |
| 50-277-89-06, 50-277-89-6, 50-278-89-06, 50-278-89-6, NUDOCS 8905010020 | |
| Download: ML20245D500 (15) | |
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i U.S. NUCLEAR REGULATORY' COMMISSION-
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REGION I
' Report Nos. 50-277/89-06
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50-278/89-06-Docket No.'
50-277 50-278 License No.
DPR-44 DPR-56 j
Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3
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. Inspection At:
Delta, Pennsylvania Inspection Conducted: ' February 27 - March 7, 1989 Inspectors:
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p ph M Golla, Reacror Engineer date
' Approved by:
b / 2.-. P9 s
' fo<~ Dr. _ P. K. - Eapen, Chie0 (
date
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Special Test Programs Section, EB, DRS
' Inspection Summary:
Inspection on February 27 - March 7, 1989 (Combined Inspection Report Numbers 50-277/89-06, 50-278/89-06)
Areas Inspected:
Routine announced inspection of followup of previously identified open items in the. Inservice Testing (IST) and Local Leak Rate Testing
'(LLRT) areas.
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Results:
No new violations or deviations were identified.
Seven open items were closed.
Four open items were reviewed and modified. Seven previously
' identified IST related weaknesses are detailed in this report and have been adequately addressed by the licensee. Also, a discussion of the results of the
' Unit 2 January 1989 Containment Integrated Leak Rate Test and Unit 3 Local Leak Rate Testing is' presented.
8905010020 890424 PDR ADOCK 05000277
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Details 1.0 Persons Contacted 1.1 Philadelphia Electric Company T. Burkhart, Test Engineer C. Campbell, Reliability Eng.neer
T. Cribbe, Regulatory Engineer
A. Cipolla, IST Coordinator G. Daebeler, Superintendent Technical
G. Hanson, Regulatory
J. Rovansek, Nuclear Quality Assurance
J. Pratt, Manager Quality Assurance
1.2 U.S. Nuclear Regulatory Commission
T. Johnson, Senior Resident Inspector
R. Urban, Resident Inspector Denotes those present at the exit meeting held on March 7, 1989.
- 2.0 Unit 2 January 1989 Containment Integrated Laak Rate Test Results Update (70323)
In combined inspection report 50-277/89-02 and 50-278/89-02 the inspector reported that the as-found containment leak rate did not meet the acceptance criteria.
This was based on the licensee's preliminary determination utilizing as-found and as-left local (Type C) leakage.
Upon further review of cest results and an issue concerning the as-found condition of main
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steam drain line isolation valve MO-77 it has been determined that the overall containment integrated leak rate test (CILRT) results have met the acceptance criteria in both the as-found and as-left c>ndition.
The as-found j
leak rate of MO-77 was in question due to circumstances during the outage
which resulted in the valve not receiving a valid as-/ound local leak rate test.
(The eventi, which precipitated this occurance are detailed in com-bined inspection report no. 50-277/87-09 and 50-27C/87-09. This issue was also identified as unresolved item 50-277/87-09-01 which is closed out in this report.) It has been demonstrated by the licensee however, that this valve was in fact a leak tight boundary.
It served as a boundary valve for testing the MSIV's on 3/14/87.
This test involved pressurizing the reactor vessel.
The inboard MSIV's, HPCI Steam Supply, RCIC Steam Supply, and the Main Steam Line Drains were all part of the pressure boundary.
In past tests, it was always necessary to maintain flow with the pressurizing
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system in order to maintain test pressure due to leakage of the different j
boundaries.
During the test conducted on 3/14/87 make-up flow was stopped l
for as much as fifteen minutes at times, indicating that the boundary valves l
were tight.
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This adequately
,onstrates the leak' tight integrity of the valve. The l
licensee.has con..ervatively assigned an as-found leakage of 10,000 cc/ min.
.to the valve. This assignmant is based on historical valve performance.
and the licensee's best. conservative engineering judgement. This was found acceptable by the inspector.
It is the licensee's policy to perform LLRT on all Appendix J tested valves before performing maintenance on them.
This issue is viewed as an isolated occurrence due to administrative weak-i nesses described in combined inspection report nos. 50-277/87-09 and-
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50-278/87-09. These weaknesses have been resolved to the satisfaction of
.the inspector.
(See closeout of unresolved item no. 50-277/87-09-01_in
.this report)..'The January 1989 Unit 2 CILRT as-found leak rate therefore is considered to have met the ace.eptance criteria. Test results are.
presented below:
January 1989 Unit 2 CILRT Result As-Left:
0.214 wt.%/ day As-found:
0.214
+ 0.135-(Add-on leakage due to LLRT improvements 0.345 wt.%/ day before the test. This value includes
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10,000 cc/ min. "or M0-77.)
Acceptable s 0.375 wt.%/ day
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.The results of this test will further be evaluated by the inspector upon receipt of che licensees summary technical report on the test.
3.0. Unit 3 Local Leak Rate Testing During Extended Outage The inspector discussed with the licensee the local leak rate testing frequency' requirements delin'eated in 10 CFR 50, Appendix J.
The frequency require.nent for types B and C. LLRT's, except tests for airlocks, is that they shall be performed during reactor shutdown (this was done at the beginning of the present extended outage) or other convenient intervals, but in no case at intervals greater than 2 years. The two year LLRT interval will be reached in April 1989 for many Unit 3 containment bound-aries. The Unit 3 reactor vessel is however, completely defueled. The licensee has asked for an interpretation of the rule since Unit 3 is not scheduled for refueling until July 1989.
Since there is no need at this time for containment integrity and since conducting local leak rate testing would not enhance safety (reactor vessel completely defueled) it was stated to the licensee that in this case the 2 year Frequency requirement 'is not applicable. The inspector
'did state.however, that prior to Unit 3 startup all containment boundar?es must be tested per the requirements of Appendix J.
The licensee was fully aware of this requirement.
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-4-4.0 Follow-up of Previously Identified Open Items (92702)
i 4.1. (Closed) Severity Level IV Violation 50-277/87-32-01(a) and 50-278/87-32-01(a): IST Program Uncontrolled This violation was cited against 10 CFR 50, Appendix B, Criterion VI,
" Document Control" because the licensee's second 10 year IST program for pumps and valves was found to be distributed to different site organizations as an uncontrolled document.
Changes were being made locally by users without formal review or approval.
i The inspector verified that proonm distribution and revision is now
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controlled.
The licensee has issued a new " Corporate ISI/IST Administrate 1ve Manual" to control the ISI und IST programs.
This manual e*tablishes the Corporate Nuclear Engineering Department as the responsible entity for controlling the program.
The new administrative manual also establishes controls for IST program development, implementation, reporting, and other administrative controls.
The inspector performed a review of a sampling of changes made to the program and found no deficiencies. The program is
also under review'at this time by NRR. The establishment of this corporate i
administrative manual which governs the development and distribution of the ISI/IST program satisfies the requirements in 10 CFR 50, Appendix B, Criterion VI for which the violation was cited.
This item is closed.
4.2 (Closed) Severity Level IV Violation 50-278/87-32-01(b): Failure to Complete Surveillance Test Documentation This violation was written against 10 CFR 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings." The occurrence which precipitated the violation was the failure by the licensee to complete the " Additional Action Reg. ired" portion of a surveillance test procedure for a test with measured parameters in the " Alert" range.
The licensee's investigation of the occurrence determined that Administra-tive Procedure A-47, Rev. 8 did not contain adequate instructions for completing the Additional Action section of the cover sheets for IST related surveillance tests (ST's) nor did it designate who was responsible for completing the section.
In response to the violation the licensee has revised procedure A-47 to include adequate instructions for completing the
" Additional Action Required" section of IST rela 9d ST's and to identify who has responsibility for completing the secti.e Also, a memorandum was issued to shift managers indicating responsibii "./ for filling out the Additional Action section while the A-47 revisi u was being prepared.
In addition to this, surveillance test cover sheets were revised to include a
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specific line item for Alert Range information.
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The inspector reviewed these changes and found them acceptable The inspector also reviewed a representative sample of surveillance tests dating back to the issuance of the violation.
No recurrences of this violation were found.
This violation is closed.
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i i-5-(. Closed) Severity Level IV violation 50-277/87-32-02(a) and 4.3
$_0-278/87-32-02(a):
Improper IST Pump Acceptance Criteria j
l This violation was written because the licensee's acceptance criteria for inservice pump testing did not conform to ASME Section XI, IWP-3100 requirements.
IWP-3100 requires that, for pumping systems "the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value."
Contrary to this, the licensee's procedure 6.10-3 contained acceptance criteria in the form of windows that permitted simultaneous nlus or minus deviation of pressure end flow from the reference values.
N :e windows provided more latitude than permitted by the ASME section M Cade.
In response to this violation the licensee has established criteria based on an acceptance band that relates to the pump curve.
This pump curve is established by the licensee by performing a capacity or basel ne test.
The representative curve then serves as the reference values.rescribed by IWP-3100 in the ASME Code. The acceptable, alert, and required action ranges are built around this reference curve and adhere to the requirements i.n Table IWP-3100-2 " Allowable Ranges of Test Quantities." This was verified by the inspector.
This method meets the intent cf the requirements. This item is closed.
4.4 (0 pen) Severity Level IV violation 50-277/87-32-02(b) an 50-278/87-32-02(b):
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Failure to Meet Section XI Requirements for Pump Bearing Temperature _
Measurements This violation was written because the licensee failed to meet the require-i ments'of ASME Section XI for pump bearing temperature measurements for the HPCI pump.
The licensee has stated that the reason for the violation was a result of an inadequate review on their part of the IST program.
The licensee had previously submitted a relief request to the NRC for meeting IWP-3500(b) pump bearing temperature measurement requirements for several pumps. The HPCI pump was mistakenly omitted from this relief request.
The licensee has submitted a new relief request (February 1988) describing their rational for not meeting the requirements of IWP-3500(b) for measur-ing pump bearing temperature for their HPCI pump.
The dispensation of this relief request is pending NRC review.
This item remains open until NRC headquarters has completed its review of the relief request.
4.5 (0 pen) Unresolved Item 50-277/87-32-05 and 50-278/87-32-05:
No Full Stroke Exercise for Valve VV-23-61 During the previous inspection it was noted that HPCI pump suction check valve VV-23-61 is not full stroke exercised per ASME Section XI, IWV-3522 requirements. The surveillance procedure ST-6.58 stated that " full flow may not be possible through MD-31" which is in the flowpath established for exercising VV-23-61.
The licensee's IST program at the time did not include a relief request for not full stroke exercising this check valve.
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-6-L The inspector reviewed tu status of this item.
The licensee has submitted
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a relief-request for this. valve and others stating their basis for relief.
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In each case the licensee has proposed'that the valves be disassembled at
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refueling outages-to' verify full flow stroking.
This item will remain-
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open:pending the NRC review of the relief requests.
l 4.6 (Closed) Unresolved Item 50-277/87-32-06 and 50-278/87-32-06:
j Incorrect Valve Stroke Time Criteria
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A. review by'the inspectors of surveillance procedure ST-6.9F, Rev. 8 data sheets determined that exceeding IST valve stroke time criteria did not result in a valve being declared inoperable.
This is contrary to ASME Section XI, IWV-3417(b) which requires that corrective action be initiated immediately, and if the condition is not or cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the: valve be declared inoperative.
The inspector, during this current inspection, reviewed revised ST-6.9F, Rev. 12 which now requires compliance with the above stated requirement.
All other ST's were reviewed and revised as necessary by the licensee.
The inspector also reviewed a letter from the PBAPS technical superintendent to site. staff clarifying ASME code requirements. These actions were found to adequately address thi.s item.
The inspector audited the licensee's test records and found no.similar recurrence. This item is closed.
4.7. [ Closed)' Unresolved Item 50-277/87-32-07 and 50-278/87-32-07:
Valve Leak Rate Trending Criteria This item was initiated because leak rate testing records for various containment isolation valves indicated that requirements of Section XI, IWV-3426 and 3427, for the establishment of ' leak rate and trending criteria,
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and corrective action were not met.
This was.an apparent violation of
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Section XI. The licensee however, stated at the time that criteria did l ',
exist but it was not located before the inspection exit meeting.
In the
licensee's tcrmal written response to this item it was stated that leakage i
criteria was indirectly ^ established by the ST's which state " verify no offscale leakage." This means that the individual leak rate limit for all LLRT valves was that of the full scale of the test equipment used or 9000 sec/ min.
The licensee has since established more definitive single valve i
leakage criteria (SVLC) for LLRT valves'.
They are presently rewriting all LLRT procedures to account for this and other program improvements.
The l
inspect r reviewed a sample of these procedures and found them to adequately addres, this issue.
This item is closed.
'4.8 (0 pen) Unresolved Item 50-277/87-32-08 and 50-278/87-32-08:
Full Stroke Exercising of Testable Check Valves This item addresses the full stroke requirement of ASME Code Section XI, IWV-3522(b) for check valves. The valves in question are testable check
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valves manufactured by Rockwell which appear only to stroke 30 degrees of swing of the valve disk. The Rockwell valves in question are-I i
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J AC-2-13-022 A0-2-14-013A,B A0-2-23-018 g
A0-3-13-022 A0-3-14-013A,B A0-3-23-018 i
~The licensee has submitted exemption requests for each of these valves.
In each case the licensee has provided their basis for relief.and proposed alternate testing to be full stroke testing of these valves.during refueling L
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upon valve disassembly. This item remains open pending NRC review of these l
relief requests.
4.9 (Closed) Unresolved Item 50-277/86-25-10:
Inappropriate Method of Valve Stroke Timing This item concerns the licensee's'former method' of IST valve stroke timing.
When this item was opened it was discovered by the inspectors that the licensee tested the stroke time of motor operated valves (MOV's) from
" light to light" indication in the control room. This method of stroke time. testing only timed the valve between the upper (open) and lower (close) limit switch and not the actual time required to fully stroke the valve.
.The inspector verified that this item has been addressed by the licensee.
An acceptable method of stroke time measurement is to begin measurement when the valves control switch is moved and end when the desired position indication is the only light that is illuminated. This usual method'is known'as the " switch to light" method and has been adopted by the licensee.
The inspector verified that IST implementing procedures have been revised to incorporate this method.
Furthermore, a new administrative procedure
.(A-127) which is' currently in the draft stage directs the utilization of this method.. ' The licensee is also conducting MOVATS testing and maintenance to_rebaseline IST reference valves and verify that switch to light timing accurately portrays a valves stroke time.
This item is closed.
4.10 (Closed) Unresolved Item 50-277/87-09-01: Unacceptable Local Let.k Rate Test Results At MSIV Drain Line Penetration This item was opened to track the licensee's corrective actions for maintenance and testing activities associated with MSIV drain line
. penetration N-8.
This penetration was the subject of an LER which was written by the licensee to address local leak rate test (LLRT) failure and inadequate control of containment isolation valve (CIV) maintenance of the associated valves.
The following paragraphs summarize the background on the issue.
On April 7, 1987, with Unit 2 in the Shutdown Condition for refueling, the inboard and outboard Main Steam Line Drain Isolation Valves, which are subject to local leak rate tests as specified in 10 CFR 50, Appendix J, had unsatisfactory test results because no "as-found" leakage rates were determined for penetration N-8 from a valid test. An "as found" LLRT was p. h
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L when the valve motor leads'were inadvertently reversed following maintenance activities. The consequences of the event were minimal.because the out-board valve was demonstrated to be an effective pressure boundary during the Main Steam Isolation Valve LLRT, conducted on March 14, 1987. The valves were repaired and successfully retested on September 23, 1987. The inspector, during this inspection, discussed ' corrective and preventive measures with the licensee and determined that adequate measures have been instituted.
. Investigations-revealed that the cause of this event was inadequate maintenance procedures in that:
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When the motor was replaced or rewired during the previous operating cycle, the motor leads were swapped; however, the wires were not properly relabeled, nor was a temporary drawing change implemented.
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When the Operator lifted the leads while applying the-block for the motor control center preventive maintenance, he was not required to, and thus did not tag them accordingly.
3.
When the Maintenance Request Form (MRF) for the motor control center preventive maintenance was rescheduled,.no operability test was performed.following the equipment clearance because no work was performed; i.e., Section 6 of the MRF which documents work performed and defects found, was not completed.
To prevent future breaker miswiring, procedure S.8.3.0, " Removing And Returning To Service Of 480 VAC And 250 VDC Motor Control Center Buckets" has been implemented to ensure that leads are properly lifted and replaced.
In addition to this, PFE-12 " Procedure For Removal And Installation of Limitorque Operators Size'SMB-000 Through SMB-5" was instituted to provide
. instructions for removal and installation of Lin.itorque motor operators.
The necessity of strict compliance and attention to detail was re-emphasized by management to all shift personnel, and Section 9 of the Operators Manual,
" Procedures and Operator Aids" was written to specifically cover procedural adherence. Also, administrative procedure A-26A, " Procedure For Corrective And Preventive Maintenance Using CHAMPS" was revised to require verification of operability any time leads are lifted, even if the MRF has been canceled and no work has been performed.
The inspector reviewed these measures taken to prevent recurrence and found them appropriate and adequate. No similar occurrence has happened since this event. This item is closed.
4.11 (0 pen) Unresolved Item 50-277/87-12-01 and 50-278/87-14-01:
Reverse Direction Testing of Containment Isolation Valves This item was opened because numerous gate, globe, and butterfly valves leak tested under the provisions of 10 CFR 50, Appendix J were noted by the inspector as being tested in a direction other than that which the valve would be required to perform its safety function. This is referred L
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to as reverse direction testing. According to paragraph III.C.1, Appendix J, 10 CFR 50, this is acceptable provided that the test yields equivalent or more conservative results. The inspector at the time did not find any objective evidence that the reverse direction tests would provide equivalent or more conservative results than forward direction tests.
The licensee at the time of inspection had relief requests submitted
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for reverse direction testing of valves. This item was opened to track the issue until the final disposition of them.
Final disposition of these relief requests are still pending NRC review.
In the mean time the licensee has performed comparative reverse versus forward direction LLRT's on several valves and demonstrated that reverse direction testing of specified valves yielded results which were more conservative than forward direction testing, thereby strengthening their justification for relief.
This item will remain open pending final disposition of the relief requests.
4.12 (Closed) Unresolved Item 50-277/87-12-02 and 50-278/87-14-02: As-Found and As-Left LLRT Data Taking Requirements This item was opened because data sheets in the licensees administrative control procedure, ST 20.000 " Local Leak Rate Test Performance And Tracking" did not have specifications regarding as-found and as-lef t data taking requirements.
The inspector reviewed the licensee's revised procedure ST 20.000, Rev. 4 (still under internal review) for conformance with the intent of IE Infor-mation Notice 85-71. This information notice gives guidance on as-found and as-left LLRT requirements.
It was determined that ST 20.000 now meets the intent of IE Information Notice 85-71 with regard to LLRT as-found and as-left data taking requirements.
It was also determined that the licensee's entire LLRT program is under revision. The inspector reviewed one of the licensees prcposed sample procedures for local leak rate testing and data sheets for tracking minimum and maximum pathway leakage running total.
These documents are well written, reflect good technical expertise, and demonstrate the licensees conformance with the requirements for local leak rate testing. This item is closed.
4.13 (Closed) Severity Level IV Violation 50-277/85-23-01 and Unresolved Item 50-278/85-23-01:
Failure to Conduct Adequate Local Leak Rate Testiqg This violation and unresolved item have been the subject of continued discussions between the licensee and the NRC. They were written when it was discovered by an NRC inspector that several valves, due to their installed configuration, did not receive 10 CFR 50, Appendix J local leak rate tests which measured packing leakage as well as seat leakage.
The valves in question were Unit 2 Torus Vacuum Relief Valve A0-2502B and Unit 2 Drywell Air and Nitrogen Purge Valve A0-2520. These valves were the subject of the violation. The valves which ware the subject valves of the unresolved item were Unit 3 valve numbers A0-3506, 3521B, and 35028. These valves were all identified as being oriented in such a way that the valve stem (packing) was not subjected to LLRT test pressure.
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-10-The licensee has pc.rformed a tharough review of all primary containment penetrations for both units'at Peach Bottom Atomic Power Station to identify
. all instances where the inboard containment isolation valve is outside containment and where the packing on the inboard valve is exposed to the
. primary containment and is not tested in accordance with Appendix J requirements.. This type of orientation was the subject of the violation and unresolved item. Of the 154' piping containment penetrations per unit, 80 penetrations have their inboard isciation valve outside containment.
-Of these 80 penetrations, 8 penetrations have been identified that have containment isolation valves with untested packing and were not identified in the licensee's previously subnitted exemption requests.
The status of these_ penetrations can be summarized as follows:
Two of the 8 penetrations should have been included in the exemption requests previously submitted. These penetrations (No.'225 and 227)-are for lines that terminate below torus water level and are continuously subjected to the head of water in the torus. The penetrations were included in a revised exemption request.
- The six-remaining penetrations contain containment isolation valves whose
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- pac King is' not currently Type C tested.
Five of these six penetrations contain valves that are three inch or smaller.
Rather than perform special qualitative testing on these valves, block valves and/or test taps will'be added to permit Type C testing of the packing in full compliance with Appendix J.
The remaining penetration contains the 20 inch Torus Vacuum Relief Butterfly Valve (AO-2502B) that was the subject of the July 1985 Notice of Violation.
Philadelphia Electric Company obtained written ' confirmation from the valve manufacturer that there is no significant difference in the sealing capabilities of the valve regardless of which direction the; test pressure is applied.
Therefore, a modification will be performed to. turn the valve such that the packirg will be tested in full compliance with Appendix J.
The Drywell Air and Nitrogen Putge Butterfly valve A0-2520 has already been turned such that the packing will be tested in full compliance with Appendix J.
In addition to the above the licensee has identified the following three categories of primary containment penetrations which need'to be addressed:
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Small manual block valves that are not containment isolation valves but are used to form the boundary for performing Type C tests.
Eleven (11) penetrations contain manual block valves located outside
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primary containment between the primary containment and the inboard containment isolation valve. These valves are normally open and do not constitute the primary containment isolation boundary, but are used for blocking purposes for the performance of Type C tests on the containment isolation valves.
These valves are oriented such that their stem packing is not currently part of a Type C test boundary.
A modification will be performed uch that the stem packing is included in the Type C test boundary, and as a result, tested in full compliance with Appendix J.
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Small normally open root. valves on instrumentation lines,
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Small manual root valves are located on the following groups of instrumentation lines:
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Instrument lines that communicate with primary containment atmosphere.
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Instrument lines that penetrr.te the reactor pressure vessel.
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.The -instrument. lines that communicate with primary containment
' atmosphere are provided with root valves that are nornally open manual globe valves-(2" and smaller). The root valves whose stem packings which are not currently subjected to Type C testing have been identified by the licensee.
These valves are containment isolation valves as
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designated in UFSAR Table 7.3.1. Modifications will be implemented to allow Type C testing of the stem packing on these containment isolation valves.
Instrument lines that penetrate the reactor pressure vessel are equipped
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downstream side. The stem packing for the manual globe valves are subjected _to 1000 psig reactor pressure during operation. These instrument lines'will be subject to a visual inspection during the reactor pressure. vessel hydrostatic test performed every refueling outage at.a pressure of 1000 psig.
This pressure is well above the 49.1 psig test pressure requirements of Appendix J.
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the visual inspection provides verification of stem packing integrity that is comparable to a Type C test and therefore meets the intent of Appendix J.
Type C testing is not proposed for these valves.
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Vents, drains' or sample elements located between the primary contain-ment and the first (inboard) containment isolation valve.
The vents, drains and sample elements located between primary contain-ment and the first (inboard) containment isolation valve were found to be oriented such that their stem packing was not exposed to the primary containment, thus no modifications are necessary to these valves.
The licensee's commitments regarding the above was stated to the inspector as follows:
Prior to returning Units 2 and 3 to service, a Type A Integrated Leak 1:
Rate' Test will be performed subjecting all of the packing leakage l
paths identified above to a test that confirms their integrity. The instrument lines discussed above will be subject t' the visual inspection at 1000 psig during the hydrostatic te2 furing the next refueling outage. 'The modifications will be performed and Type C tested prior to the end of the next outage on each unit in which no Type A test is performed.
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-I2-If this does not take place, a Type A test will be performed at each refueling outage until the stated modifications are completed.
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Based on the modifications already made and the commitments stated above, it is felt that the licensee has adequately addressed these issues. This violation and unresc1ved item are therefore closed.
5.0 Identi_ fled Inservice Testing Weaknesses During Inservice Testing Combined Team Inspection 50-277/87-32 and 50-278/87-32 several weaknesses were identified in addition to the violations and unresolved items which were cited. The inspector, during this inspection, reviewed the licensees actions taken to correct or strengthen these identified weaknesses. All 7 weaknesses were adequately addressed by the licensee.
Details on each are presented below.
5.1 Lack of Identification of Valve Position During the inspector's overview of the IST program the inspector determined l
that the program did not indicate the position or positions required for safety-related functioning of any of the valves. Therefore, it was not possible to conclude whether this was identified for each valve and whether the procedures called for appropriate valve testing.
The lack of identification of the safety related valve position (open, closed, or both) in the program listing was considered a weakness.
In order to address this weakness a new column was added to the valve table in the IST Program which designates the safety related position (open, clos (d or both) of each valve. This addition was included in the revision to the Second 10 year Interval IST Program. As part of the revision process to the IST Program, all Surveillance Tests were reviewed to verify that the prescribed testing is appropriate for each valve's safety related position (s).
This adequately addresses the stated weakness.
5.2 Lack of Capability to Verify Test Schedule Adherence By_ Component
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The inspector determined that the licensee's Surveillance Test (ST) program l
was basically a TS surveillance originated system and ASME Section XI
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Inservice Tests were folded into the ST program.
Verification of test schedule adherence by component could not be readily done since the components are within the system oriented program. To determine when tests were performed the ST for that system had to be reviewed to see what valves were included.
Then the results for the I
individual valves could be extracted from the test data results.
l The tracking system did not cross reference by component.
This could have
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led to occasions where a component test was missed.
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In order to make tracking IST components less cumbersome the licensee has L-
- developed a computer program to track all inservice testing on a component and ST basis..The inspector reviewed with the licensee the capabilities of the program..Section XI tested components can now be easily tracked.
=E This adeq'uately addresses this weakness.
- 5.3 Lack of Specifying Corrective Actions and Inoperability Procedure No. ST 6.10-2 and 3 for the High Pressure Service Water System requires:that valve stroke times be recorded.
Limiting stroke times are-specified for each valve. -If the limiting stroke time for any valve is exceeded, the test results are considered unsatisfactory and indicated as such on the.ST cover sheet.
However, the ST did not specify the corrective actions that should be taken or when the valve must be declared inoperable--
g in accordance with IWV-3417.
Lack of specifying corrective actions and declaration of inoperability was considered a weakness.
All'of t'he lic_ensee's IST su'rveillance tests are being reviewed and revised as necessary.to alleviate future confusion with valve stroke time accept-ability and operability.
The inspector reviewed the revised subject ST 6.10-2 and a sampling of other ST's and found that appropriate revisions were made.
This adequately addresses this weakness.
5.4 Confusion with Dual Stroke Time Limits Review of surveillance procedure ST-6 5, rev. 42, identified two stroke
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time. limits for valves M0-4(5)-245.
A Technical Specification limit of 15 seconds and IST limit of 19 seconds indicated that the IST limit will never be a controlling value since exceeding the. Technical Specification limit would require corrective action.
Identification of an IST limit higher than the Technical Specification limit is inappropriate.
All IST related ST's were reviewed by the licensee and dual stroke time limits have been eliminated.
Further, IST stroke time limits have been recently rebaselined after M0 VATS testing and maintenance.
Stroke time limits are appropriately derived from valve performance.
This adequately addresses this weakness.
5.5 Delay In Correcting Proceduce During the inspector's review of the ST-6.5B, rev 4, test performed in March, 1986, a note was made on the procedure that step 11 included a
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typographical error by referencing valve MD-23-21 twice rather than MO-23-21 once and MO-23-31 once. This typographical error still existed in revision 5.
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IThe delay'in correcting procedure.was considered a weakness. The inspector. verified that: surveillance procedure ST 6.5B was revised to correct the typographical error. -This adequately addresses this issue.
5.6 Inability to Verify proper post Maintenance Test Maintenance Request Forms (MRF) were generated as a result of performing.
The MRFs required repair of.the 502A and B discharge check valves. The closed out MRF for the 502A valve indicated that the m
valve was repaired and that post-maintenance testing was performed.
However, it c'ould not be verified through official records that the testing verified the proper functioning of the valve in both the fully open'and fully closed positions. This procedure was not appropriate for post maintenance testing as it did not require backflow testing explicitly.
The inability to verify proper post maintenance valve functional testing from the MRF is considered-a weakness in record keeping.
.The licensee has revised ST 6.10-3 to incorporate testing 502A, B, C, D check valves in the forward and backward direction.
They have also
. reviewed and revised as necessary other IST related ST's to ensure backflow testing of discharge check valves.
The inspector reviewed the affected procedures'and.found the revisions made adequately address this weakness.
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- 5.7. Limited QA/QC Overview of IST This was cited as a weakness because the licensee had allocated its QC surveillance manpower to activities other than IST. An IST audit (QA Audit No.'Ap 86-106, December 1986) was reviewed by'the inspectors but this audit' concentrated mainly on NDE and visual inspection.
The' licensee now has comitted to seperate IST from the annual pBApS ISI audit scope and treat it independently.
This will permit'the auditors-to focus attention on technical issues required for inservice testing by ASME Section XI.
The inspector, during this inspection, reviewed the audit report for the first of these annual IST audits. Audit No. PA88-504-IST was performed in November 1988.
The inspector noted that this audit was more effective in
'that findings were more technical than administrative in nature and that attention was focused strictly on IST.
This approach appears at this time to have' strengthened the licensees QA effectiveness in the area of inservice testing. The licensee has another IST audit planned for November 1989.
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-15-6.0 Management Meetings Licensee management was informed of the purpose and scope of the inspection at the entrance interview. The findings of the inspection were discussed with the licensee at an interim exit meeting held March 3, 1989 and were summarized again at the final exit meeting on March 7, 1989. 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 inspector. The licensee did not indicate that the inspection involved any proprietary information.
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