IR 05000293/1980020
| ML19332A946 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/03/1980 |
| From: | Caphton D, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19332A942 | List: |
| References | |
| 50-293-80-20, NUDOCS 8009190081 | |
| Download: ML19332A946 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND' ENFORCEMENT Region I Report No'.
50-293/80-20-Docket No.
50-293 License No. DPR-35-Priority Category C
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Licensee: Boston Edison Company M/C Nuclear-800 Boylston Street
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Boston, Massachusetts. 02199'
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Facility Name:
Pilarim Nuclear Power Station. Unit 1 Inspection at:
Plymouth, Massachusetts Inspection conducted:
May 4-8,
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Inspectors:
JO W. A. Rekito, Reactor Inspector date sfgned
date signed
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Approved by:
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'D. L. Capht'on, Chief, Nuclear Support Section
'date signed No. 1t, RO&NS Branch
Inspection Summary:
i-Inspection on May 4-8, 1980 (Report No. 50-293/80-20)
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l-Areas Inspected:
Routine unannounced inspection of Containment Leak Rate
Testing and licensee action ~on previous inspection findings. The inspection involved 42 inspector-hours onsite;by one regional based inspector.
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Results: Of the two areas inspected, two items of r.oncomnliance were found in one area' (Infraction - Failure to conduct CILRT in accordance with 10 CFR '
50,-Appendix J,' Paragraph 3.g; and Infraction.- Failure to perform l'ocal leak rate test following maintenance, Faragraph 4.b).
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Region I Form 12 -
(Rev. April-77)
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DETAILS 1..
Persons Contacted The below listed technical and supervisory personnel were contacted.
P. Cafarella, Performance Engineer F. Famulari, Senior Mechanical Engineer
- C. Guilbert, Consultant..(S&W)_
- E. Graham, Senior Plant Engineer
- R. Machon, Assistant Station Manager
- P. McGuire,. Station Manager M. McLaughlin, Senior Compliance Engineer
- R. Parry, Consultant (S&W)
R. Silva, Maintenance Staff Engineer B. Sivigny, Chief Maintenance Engineer
- P. Smith, Chief Technical Engineer
- S. Wollman, Senior Performance Engineer NRC Personnel K. Roberts, Resident Inspector The inspector also talked with ano interviewed other licensee personnel during the inspection. They included members of the operating and tech-nical staffs.
- denotes those present at the exit interview.
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2.
Licensee Action on Previous Insoection Findinas a.
Items Closed Unresolved Item (293/80-04-01):
Procedure 8.7.1.4, Revision 2, "Pri-mary Containment Integrated Leak Rate Test," has been revised to spec-ify the proper acceptance criteria and use of the mass point method of data analysis.
The procedure revision also corrected the valve lineup for the containment pressure transmitters. These items are considered resolved.
Unresolved Item (293/80-04-03):
The inspector reviewed records for the flow transmitter orifice, used for local leak rate testing, which certified traceability to the National Bureau of Standards.
The item is considered resolved.
Unresolved Item (293/80-04-09):
Procedure TP.80-10,' Revision 1,
" Visual Examination" has been revised to include verification of
' spring hanger settings. The inspector also reviewed records to verify
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that settings had been checked for all spring hangers examined during
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the 1980 refueling outage. 'These items are considered resolved.
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b.
' Items Remaining Open
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Unresolved Item (293/80-04-02):
Local leak rate test. device bypass.
Thejinspector re' viewed a draft Procedure Change Notice 1(PCN) for
. Procedure 8.7.1.5.whici1 inclu'ded a prerequisite to check.the leak tightness of the bypass isolation valve.' This action appears to
.be acceptable but the itea will remain open_pending approval and
~ implementation of the procedure change.
Unresolved Item-(293/80-04-10): _ T.S. Hydraulic Snebber Inspection-
Schedule. The inspector reviewed an office memorandum which increased
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the survefilance frequency for' accessible snubbers from 18 months to
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12 months due to failure of the RHR snubber during the last inspec-tion..However, the licensee has not -yet completed his review of
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the HPCI snubber replaced during the last inspection period..The-
. inspector discussed his concern for delaying the decision on this-I snubber.because its'effect would increase the inspection frequency to six months. This item remains unresolved pending the licensee's
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further action and review by NRC:RI.
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Inspector Follow Item (293/77-15-08):
T.S. Hydraulic Snubber Lockup Rates. The inspector requested to see documentation for piping system design thermal expansion rates ;during _heatup to verify that these values do not exceed the snubber lockup _ rates. The licensee stated this 'information was available in their engineering office and would
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be provided to the NRC resident inspector. This item remains unre-solved pending receipt of the necessary information and review by the NRC.
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- Primary Containment Integrated Leak Rate Test (PCILRT)
a.
General
On May 4-8, 1980, Pilgrim Unit 1, performed their second periodic PCILRT. The test was conducted at a test pressure of 23 psig in
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.accordance with Procedure 8.7.1.4, Revision 2, " Primary Containment
' Integrated Leak Rate Test," dated April 26, 1980. The inspector
' reviewed.the procedure, witnessed various portions of the test, verified qualifications-of test personnel, and independently verified i
calculations of the test results.
Details of the test are discussed below.
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b.
Procedure Review The inspector reviewed Procedure 8.7.1.4, Revision 2, "PCILRT" for technical adequacy and compliance with 10 CFR 50, Appendix J, ANSI N45.4, and Pilgrim Technical Specifications.
The inspector identified the fact that the procedure required meas-
- uring reactor building atmospheric pressure and temperature every four hours. ANSI N45.4 requires this data to be recorded hourly.
The licensee revised the procedure to record this data each hour during the test.
c.
Valve Lineup Review On a sampling basis, the inspector checked the PCILRT procedure valve lineup sheets to verify that:
Valve lineups were provided for each penetration;
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Valves were positioned correctly;
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Proper vent paths were provided; and,
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Artificial-leakage barriers were not created which could mask
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containment leakage.
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i The inspector identified the following problems with systen alignments:
(1)
Pressure Switch PS 5030 was isolated and vented. The licensee corrected the procedure to have this switch lined up for normal operation during the test.
(2)
Penetration 47 used for the supplemental verification test was isolated creating an artifical leakage barrier.
The licensee corrected the procedure to vent these two lines downstream of containment isolation valves (CIVs)~Pl4A and P14B during the test.
(3)
Penetrations 26 and 205 used for the Containment pressurization were isolated thus creating an artifical leakage barrier. The licensee cerrected the procedure by venting these lines to atmosphere outboard of CIVs A0 5033A, A0 5033B, and A0 5033C.
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Instrumentation The inspector. reviewed the calibration records for the resistance temperature detectors, dew point instruments, pressure detectors and verification test flowmeters.
Their calibration prior to the PCILRT were found to meet appifcable accuracy requirements and were traceable to the National Bureau of Standards, e.
Chronology 5/5 0500 Commenced pressurization.
0900
. Identified gross water leakage from 8" pipe flange on a line from the RCIC turbine exhaust to the torus.
1000 Above mentioned flange bolts were tightening in an attempt to. repair the leak.
1200 Commenced depressurization.
1500 Measured leakage from RHR valve 1001-36A packing to be approximately.5 gpm and then tightened packing gland to stop leakage.
5/6 0230 Performed local leak rate test on 8" RCIC exhaust line
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Measured leakage 6.63 standard liters per minute (SLM).
0400 Repaired 8" RCIC exhaust line flange by replacing double 0-ring seals.
Post repair leak test measured zero leakage.
0630 Commenced pressurization.
1200 Pressurization completed.
Commenced four hour temper-ature stabilization.
1700 Identified air leakage from open vent in Nitrogen Makeup line and discovered that CIV A0 5033A was in the open
position.
1800 Closed CIV A0 5033A.
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5/7 0325 Closed vent valve A on the compressed air supply header to isolate leakage past valves A0 4356 and A0 5046.
0525 Closed vent valve H-4 to isolate leakage in Oxygen
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analyzer line past CIV 5065-23.
1800 Recorded data indicated leak rate was within the accept-ance criteria.
5/8 0301 Completed PCILRT and commenced supplemental verification test.
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0701 Completed verification test.
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0300 Performed local leak rate tests for the leakage paths isolated during the PCILRT.
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Plant Tours The' inspector accompanied licensee personnel on various plant tours both before and during the PCILRT.
During these tours, test boundaries were surveyed for evidence of leakage and on a sampling basis, selected valves were verified to be in the correct position.
During one of these tours, the inspector questioned the existance of a 6" manual isolation valve and blank flange which appeared to be part of the test boundary. The licensee's representative explained that this was pcrt of a design modification (PCCR 79-29) for the Containment Atmospheric Dilution System scheduled to be completed at a later date. The licensee's representative satisfied the inspector's concern by initiating a change to the procedure to identify and include the modification as an extension of the PCILRT boundaries.
No unaccept-able conditions were identified, g.
Leakage Repairs Paragraph III. A.l.(a) of 10 CFR 50, Appendix J requires that no repairs or adjustments be made following the containment closure inspection.
The NRC position regarding the provisions of this paragraph were iden-tified during a previous inspection 293/80-04 on January 28-31, 1980.
It was clarified at that time that identified leakage paths could be isolated, provided the leak. path is locally tested before repair and leakge is added to the PCILRT.results to obtain the 'as found' leakage.
The inspector further emphasized the need to carefully control such isolations and repairs lduring the test to avoid invalidating test resul ts.
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During the PCILRT, one repair and one adjustment to the containment isolation boundary were made without measuring (quantifying) the 'as found' leakage.
They are:
(1) Attempted repair (tightening) of an 8" flange on the RCIC turbine exhaust line at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on May 5,1980.
(2) Made adjustment by closure of valve A0 5033A in the containment
. atmospheric control system at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> on May 6, 1980.
The two actions identified above represent a failure to comply with
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Containment Leakage testing requirements and constitute, an item of noncompliance with 10 CFR 50, Appendix J.
(293/80-20-01)
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PCILRT Results (1)
Initial Attempt The initial attempt of the PCILRT, from 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> till 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on May 5,1980 revealed a known leakage of 0.5 gpm from RHR valve 1001-36A and an unknown gross leakage from the 8 inch RCIC Tur-bine exhaust flange.
The licensee's initial evaluation identified the leakage to be in excess of the test acceptance criteria.
Be-cause the 'as found' flange leakage was not measured before re-pair and.therefore unknown, the inspector conservatively assumed the total containment 'as found' leakage to have failed to meet the acceptance criteria and therefore, identified the initial attempt at this periodic type A test to be a failure.
The licensee acknowledged these comments.
(2)
Successful Test After repairs of leaks identified during the initial PCILRT
attempt, the containment was repressurized and a successful test run from 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> on f4y 7 to 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> on May 8,1980.
Preliminary calculation indicated leakage at the 95% upper con-fidence level to be 0.383 weight percent per day (%/ day). The test acceptance criteria is 0.596 weight %/ day.
The inspector noted that the measured leak rate of 0.383 is not corrected for any change in the containment free volume due to water accumulation.
The inspector independently calculated the leak rate, using raw data from the test with the results being identical to and /erifying the accuracy of the licensee's leak rate calculations.
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Future Test Schedule Paragraph III.A.6.(b) of Appendix J states that if two consecutive periodic Type A tests fail to meet the acceptance criteria then tests shall be performed at each refueling, not to exceed 18 months, until two consecutive periodic tests meet the acceptance criteria.
The inspector noted that the initial attempt of the 1976 and 1980 periodic Type A test at Pilgrim failed to meet the acceptance cri-teria and that the licensee was therefore subject to the increased frequency of tests as described above. The licensee acknowledged this comment and stated that following his evaluation of the 1980 test events he would submit plans for future test schedules in his PCILRT Report.
4.
Local Leak Rate Testing (LLRT)
a.
Test Witness On May 4, 1980, the inspector witnessed the Type B local leak rate test on the Containment Equipment Hatch double 0-ring seal.
The in-spector verified that the test was conducted in accordance with the approved procedure 8.7.1.5, Revision 7, dated January 18, 1980,
" Local. Leak Rate Testing of Primary. Containment Penetrations and Iso-lation Valves." The inspector observed that test instruments were properly calibrated, the operator appeared to be knowledgeable of the procedure and suitably qualified and the results appeared to be satis-factory. No unacceptable conditions were identified.
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Special Testing Requirements
Paragraph IV.A of Appendix J requires that any modification or replace-ment of a component which is part of the primary reactor containment i
boundary be followed by the applicable type leakage rate test.
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Paragraph VII.E of PNPS Procedure No. 8.7.1.3, Revision 2, dated January 4,1980,' Local Leak Rate Test stated "Whenever maintenance is performed on any of the tested valves, seals or penetrations which affect their leak tight integrity, such valve, seal or penetration must be retested..."
Following the identification of the leak from the 8 inch RCIC turbine exhaust line flange during the PCILRT, the inspector requested to see the test records and maintenance records for this component.
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Review of Maintenance Request No.- 080-696, dated April 15,.1980 re-
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vealed that'the RCIC.-flange was disassembled on May 2,1980 to inspect
the adjacent stop check valve 1304-64.
The-licensee's. representative stated that the post work testing requirement (LLRT) was not performed
. due to an oversight and inappropriate closeout of the maintenance request documentation.
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Fa11ure to perfonn a local leak rate test of the RCIC turbine exhaust line flange, which is part of the reactor containment boundary, following maintenance on May 2,1980 constitutes an item of noncom-
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pliance with 10'CFR 50, Appendix J and PNPS Procedure No. 8.7.1.3.
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(293/80-20-02)
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Maintenance-Activities-The inspector noted that two of the problems encountered during the PCILRT were caused in part, by the licensee's maintenance activities. They were:
(1) MR No. 080-696, Failure to perform required post work retest discussed
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in Paragraph 4.b of this report; and (2) MR 080-4122 used to replace solenoid valve SV-5033A.
It was discovered during the PCILRT that this valve would not close by its normal means because the air supply was
connected incorrectly. The licensee's representative explained that this
maintenance request final review had not been completed and the installa-tica error would have been identified during the functional operability test for this valve.
The inspector questioned the licensee's representative about remaining outstanding work activities,.especially those affecting reactor contain-ment integrity and other safety related components.
.The'. licensee's representative stated that a special review has been started of all work activities from the recent refueling outage.
This review is intended to verify the proper and complete close out of all safety related maintenance requests prior to the next plant startup.
1This matter will receive further review during a subsequent inspection.
-(293/80-20-03)
6.
Surveillance of Hydraulic Shock Suppressors (Snubbers)
-The~ inspector. reviewed Procedure 3.M.4-28, Revision 6, dated March 7, 1980, Inspection of Hydraulic-Shock.Suppressors (snubbers), Mechanical Shock
~ Arrestors : Pipe Hangers and Restraints.
As a result of this review, the inspector questioned the adequacy of the procedural guidance.. The
. licensee's. representative satisifed.the inspector's concerns by initiating a procedure change notice (PCN) to improve clarification of the acceptance
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. criteria and document review of the inspection results on the. data sheet.
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1No items'of. noncompliance were-identified.
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Control Room Observations The inspector observed Control Room operations on both day and evening -
shifts.
Activities reviewed included: manning requirements, status of-plant syster.s, and equipment tagging requirements.
No items of noncompliance' were observed.
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Unresolved Items Unresolved items are matters about which more information is required to determine acceptability.
ParagrapF 1.b of this report contains unresolved items.
9.
Exit Interview
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The inspector met with licensee representatives (See Detail 1 for Attendees)
at the conclusion of the inspection on May 8, 1980. The inspector summarized the scope and findings of the inspection at that time.
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