IR 05000293/1982004
| ML20042A349 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/19/1982 |
| From: | Bettenhausen L, Pullani S, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042A342 | List: |
| References | |
| 50-293-82-04, 50-293-82-4, NUDOCS 8203230350 | |
| Download: ML20042A349 (11) | |
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50293-81 09 30 50293-81 12 30 U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
50-293/82-04 Docket No.
50-293 License No. DPR-35 Priority
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Category C
Licensee:
Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Power Station, Unit 1 Insoection at:
Plymouth, Massachusetts Inspection conducted: January 25-29, 1982
Inspectors:
M 18-81 W. A. Rekito Reactor Inspector date signed.
2 -18-83 S. M lattk, Reactor Inspector date signed LJ A reg k A<
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R. J. Summers, R~eactor Inspector date signed Y/f M Approved by:
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L. H. Bettenhausen, Chief, date signed Test Program Section, Engineering Inspection Branch Inspection Summary:
Inspection on January 25-29, 1982 (Recort No. 50-293/82-04)
Areas Inspected:
Routine, unannounced inspection of containment leakage rate testing; testing of new and modified systems; and licensee action on previous inspection findings. The inspection involved 78 inspector-hours onsite by
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l three region-based NRC inspectors.
Results: Two violations were identified in one area:
(1) Failure to properly
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implement approved procedures, (Paragraph 3.d and 4) and (2) Failure of drawings and procedures to identify existing valves (Paragraph 4).
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Details 1.
Persons Contacted The below listed technical and supervisory personnel were contacted.
- H.
Balfour, Staff Assistant
- P.
Cafarella, Shift Technical Advisor
- P.
Cormier, Shift Technical-Advisor
- E. Graham, Management Services Group Coordinator
- N. Gabriel, Maragement Services Group
- R. Machon, Nuclear Operations Manager
- C. Mathis, Deputy Manager
- M. McLoughlin, Compliance Engineer
- K. Roberts, Chief Maintenance Engineer
- J. Seery, On-site Safety and Performance Group Leader
- S. Wollman, Shift Technical Advisor NRC Personnel
- H. Eichenholz, Resident Inspector J. Johnson, Senior Resident Inspector The inspector also talked with and intervieied other licensee personnel during the inspection. They included members of the operating and technical staffs.
- denotes those present at the exit interview held January 29, 1982.
2.
Licensee Action on Previous Inspection Findings a.
Items Closed Unresolved Item (293/80-04-04):
Drywell head installation procedure; re: NRC IE Bulletin No. 78-09. The inspector reviewed records of the drywell head installation from the 1980 refueling outage.
Approved procedure 3.M.4-3 had been used. As reported in NRC Inspection l
Report No. 50-293/81-30, the licensee plans to use a newly developed l
procedure 3.M.4-48 to install the drywell head in the future. This
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item is closed.
Inspector Follow Item (293/80-20-03):
Completion of maintenance activities affecting the primary containment boundary. The licensee completed a special review to verify the proper and complete close
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out of all safety related maintenance requests during the 1980 refueling outage. To prevent recurrence of problems with incomplete
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maintenance activities the licensee has Provided training and guidance to responsible maintenance personnel on post work testing requirements i
as detailed in procedure 8.7-1.3, Local Leak Rate Test Program, and l
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activities affecting primary containment boundaries in general. As an additional control the licensee has established a Refueling Outage Startup Department which reviews all maintenance work requests in~accordance with procedure SV-4, Revision 0, Refueling Outage Startup Postwork Test Process Planning and Implementation. This item is closed.
b.
Items Remaining Open Unresolved Item (293/77-26-04):
Controls for test, vent and drain (T, V & D) lines which form part of the primary containment boundary ensure that leakage barriers are in place. The inspector observed special "ID/ WARNING" tags which were attached to the applicable T, V
& D line valves. This red tag stated that the normal position of the valve is closed and to contact the watch engineer before opening it.
The licensee also verifies the closure of these valves following local leak rate testing on the appropriate data sheet and in Procedure 8.2.3 " Visual and Manual Inspection of Primary Containment Isolation Valves One inch and Smaller". The above controls appear to be adequate, however, the licensee and the inspector recognize that both the Local Leak Rate Test Procedure 8.7.1.5 and Procedure 8.2.3 do not identify all applicable T, V & D line valves. This problem is discussed further in paragraph 4 of this report. This item
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remains open pending corrections to and implementation of the above procedures.
3.
Containment Leakage Rate Testing a.
Docut.ents Reviewed
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Procedure 8.7.1.3, Revision 5, Local Leak Rate Test Program.
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Procedure 8.7.1.5, Revision 11, Testing of Primary Containment Penetrations and Isolation Valves.
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Procedure 8.7.1.6, Revision 8, Local Leak Rate Test of MSIV(s).
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Procedure 8.7.1.7, Revision 7, Local Leak Rate Test of Personnel
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Air Lock.
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Procedure 8.7.1.8, Revision 6, Local Leak Rate Test of Feedwater Check Valves.
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Records of Local Leak Rate Testing activities including test results and related repair documentation.
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NRC letter to BECo dated April 28, 1981 transmitting a Safety Evaluation Report regarcing compliance with 10 CFR 50 Appendix J, Containment Leak Testing at Pilgrim I.
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b.
Scope of Review The inspector reviewed the above documents to ascertain compliance with regulatory requirements of 10 CFR 50 Appendix J and Technical Specification 4.7.
The inspector also witnessed selected local leak rate test (LLRT) activities and held discussions regarding the'
relationship between LLRT failure results and the Primary Contdinmerit Integrated Leak Rate Test (PCILRT) evaluation of "AS FOUND" condition.
Further details and inspection findings are described below.
c.
Scope of Testing Based on a conclusion of the SER, the licensee committed to LLRT the four TIP Ball Valves (A-D).
The inspector noted that-these valves were not included in the approved procedure 8.7.1.5.
The licensee explained that all penetration test sketches (Figures and attachments to procedure) were being re-drafted during the course of LLRT this outage for a major procedure revision. The licensee showed the inspector a copy of the penetration test sketch tJ used and initiated a change to procedure 8.7.1.5 by SR0 chai No. 82-04, dated January 26, 1982 which incorporated the four. Ball Valves.
This action satisfied the inspector's concern.
d.
Feedwater Check Valve Testing Based on a conclusion of the SER, the licensee committed to LLRT all four feedwater check valves 58 A&B and 62 A&B with air.
Test records revealed that all four valves were tested on October 20, 1981; were found to have unacceptable leakage and were repaired and retested on Decembar 2, 3 and 4, 1981 in accordance with procedure 8.7.1.8 revision 6.
The licensee representative described.the method used to test these valves with air which the inspector noted was different from the method prescribed in procedure 8.7.1.8, revision 6, describing testing the inboard valves 58 A & B with a water seal.
The licensee representative acknowledged this fact and stated that the tests conducted on the four days noted were not performed in strict accordance with the approved revision 6 of procedure 8.7.1.8.
He also initiated a procedure revision to specify the correct method of testing these valves with air only. The inspector determined that the proposed procedure revision and the method used to perform the tests were technically adequate for meeting the regulatory requirements.
However, performance of the tests on the dates noted and in a manner described represent an apparent failure to properly implement approved procedures. This example, along with the one described in paragraph 4, constitute a violation of Technical Specification 6.8.A.
e.
Test Witnessing On January 27, 1981, the inspector witnessed a type C local leak rate test of the reactor vessel head spray line (Penetration X-17)
valves MOV-1001-60 and MOV-1001-63.
The test was conducted in
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accordance with approved procedure 8.7.1.5, revision 11 following maintenance performed to reduce stem packing leakage on valve MOV-1001-60. The result of 20-30 standard liters per minute (SLM)
did not meet the acceptance criterion and was determined to be through seat leakage on valve MOV-1001-60.
It was decided to request valve disassembly and disc-seating surface repair.
On January 28, 1981, the inspector witnessed a type C local leak rate test of the outocard MSIV A0-203-2A. The test was cond; ted in accordance viith approved procedure 8.7.1.6 revision 8, following maintenance performed to reduce val /e seat leakage. The results did not meet the acceptance criterion; at the inspection's and, the licensee was evaluating possible further corrective actions.
On both occasions the inspector verified that the tests were conducted in accordance with the approved procedures and that the related maintenance and work permit documentation was in accordance with applicable procedure requirements. Additionally, the inspector observed that the test instruments were properly calibrated and the test personnel appeared to be knowledgeable of the procedure and suitably qualified.
No unacceptable conditions were identified.
f.
Test Results The inspector reviewed the LLRT Results Summary and discussed with the licensee analysis of test failures and status of retests.
Several significant problems were encountered.
Five (MSIV(s), (all four inboard valves and one outboard) had unacceptable leakage upon initial tests and had to be repaired and retested.
In addition, the initial tests on four other penetrations (Torus Purge Exhaust X-227, Instrument Air Supply X-228E, and both Feedwater Lines X-9 A & B)
resulted in excessive unacceptable leakage past both redundant boundaries. The inspector noted that this problem was of particular importance because it represanted the "AS FOUND" state of the primary containment system to be in excess of the Technical Specification allowable leak rate limit.
The inspector also explained that the overall primary containment system leakage improvements resulting i-from repairs of these penetrations and others prior to the PCILRT
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are expected to be added to the results of the PCILRT for determination l
of the "AS IS" test results in accordance with 10 CFR 50 Appendix J.
This requirement had been previously identified to the licensee in the Safety Evaluation Report sent on April 28, 1981.
g.
Technical Specification Changes The present TS 3/4.7A, Primary Containment does not identify all containment boundaries required to be local leak rate tested. The NRC letter dated April 28, 1981 requested that the licensee propose TS changes to include this information. The licensee has not responded
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to this request and was unsure of the necessity to do so but stated (
that the matter would be pursued by their licensing department.
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This matter is considered unresolved pending review of licensee's further action and response to the request.
(Unresolved item 50-293/82-04-01).
h.
Plant Modifications Affecting Primary Containment Integrity The inspector reviewed a sample of plant modifications that affect the primary containment. Reviewed were the H2/02 Analyzer System, the Post Accident Sampling System and the Panel C-19 System (Backup Coolant Leak Detection System).
The review consisted of an audit of the PDCRs and related documentation, and discussions with licensee personnel.
It was understood that these modifications are not yet complete and therefore final documentation of the work was not available for review.
However, based on the audit.and subsequent discussions, it was determined that the licensee is taking appropriate action to maintain containment integrity and to meet the containment testing requirements.
4.
Drawing and Procedure Discrepancies From September 26, 1981 until this inspection, the licensee was conducting local leak rate tests of primary containment penetrations and re-drafting piping sketches of test configurations for inclusion in a revision to procedure 8.7.1.5, Testing Primary Containment Penetrations ar, Isolation Valves.
During this period, it was discovered that many piping system test, vent and drain (T, V & D) connections and valves existed that were not identified on the latest revision of the system drawings (P& ids).
Some example of discrepancies are:
Primary Containment Penetration X-23, Reactor Building Closed Cooling
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Water (RBCCW) supply line has a single valve drain connection located outside the drywell between the penetration and the containment isolation valve (CIV) identified as 6"-238 which is not shown on Drawing M-215, revision E4. This drain connection and valve is relied upon as both a system and primary containment boundary.
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Primary Containment Penetrations X-51 A (B), Residual Heat Removal (RHR) vessel injection lines, each have three double valved drain connections, one located outside the drywell between the penetration and CIV M0-1001-A (B) and the other two inside the drywell between the penetration and manual valve 101-33 A (B).
None of these six connections or twelve valves are shown on drawing M-241, revision E2.
The connections and valves outside the drywell are relied upon as both system and primary containment boundaries.
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Primary Containment Penetration X-17, RHR Vessel Head Spray line, has three double-valved drain connections, one located outside the drywell upstream of CIV MO-1001-60 and two located inside the drywell downstream of CIV MO-1001-63. None of these three connections or six valves are shown on drawing M-241, revision E2.
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Primary Containment Penetration X-22, Instrument Air Supply to
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drywell line, has two manual header block valves located inside the drywell. Drawing M-220, revision E5 shows only one to exist.
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Primary Containment Penetration X-18, Drywell floor sump pump discharge line, has a single valve drain connection located inside the drywell which is not shown on drawing M-232, revisicn E4.
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Primary Containment Penetration X-19, Drywell equipment sump pump discharge line, has a single valve drain connection located inside the drywell which is not shown on drawing M-232, revision E4.
Licensee management personnel were unable to explain reasons for or justification of the above examples of drawings not reflecting the as built condition.
The licensee also stated that this is possibly representative of a generic problem and they intended to initiate a special priority task effort to examine all piping systems to confirm or correct the accuracy of applicable drawings.
The inspector expressed a concern for the system of administrative controls to ensure that all system valves were properly aligned and the following applicable operating procedures were reviewed:
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PNPS Procedure 2.2.30, revision 11, Reactor Building Closed Cooling Water System.
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PNPS Procedure 2.2.86, revision 13, Residual Heat Removal System.
PNPS Procedure 2.2.19, revision 12, Low Pressure Coolant Injection
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System.
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PNPS Procedure 2.2.71, revision 5, Radwaste Collection System.
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PNPS Procedure 2.2.36, revision 7, Instrument Air System.
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PNPS Procedure 8.2.3, revision 2, Visual and Manual Inspection of Primary Containment Isolation Valves 1" and Smaller.
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PNPS Procedure 2.2.11, revision 2, General Plant Operating Procedure.
It was determined that the " Valve Check List" which is Appendix A to each of the system operating procedures did not include the T, V & D connections which were not identified on the drawings as described above, except for the Instrument Air System procedure 2.2.36 whose
" Valve Check List" included approximately 50 valves with the notation
"Not on P&ID".
Licensee management personnel stated that this problem, like the drawing errors, is possibly generic and that all applicable procedures would be corrected along with the priority effort to correct system P&ID(s).
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Findings 1.
Procedure 1.3.8, revision 25, Document Control, section 4.C, requires that notification be given to the_ Management Services Group when it is observed that a P&ID should be revised. As of January 29, 1982, this notification requirement had not been initiated by several licensee personnel who were aware of certain drawing errors described since October 1981.
This example of failure to properly implement an approved procedure along with the example described in paragraph 3.d constitutes a violation of Technical Specification 6.8.A.
(293/82-04-02).
2.
ANSI N18.7-1972 requires that system startup procedures include confirmation that valves are properly aligned.
Procedure 2.1.11 states blank valve lineup forms (Appendix A to System Operating Procedures) be used to conduct all valve lineups.
Collectively the examples given above for T, V & D valves not being identified on the system P&ID and the positions not being specified on the system valve check lists constitutes a violation of 10 CFR 50 Appendix B, Criterion V, and Technical Specification 6.8.A which incorporates ANSI-N18.7-1972.
(293/82-04-03)
5.
Review of Licensee Event Reports (LER's)
The following LER's were reviewed:
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LER 81-053/03L-0, dated October 7,1981 (Appendix J Related Valves -
Containment Leakage Rate Testing failure of Torus Purge Exha.;t Valves A0 5042 A & B)
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LER 81-065/03L-0, dated January 26, 1982 (Main Steam Isolation Valve Loose poppet hold-down bolts discovered on MSIV A0-203-2A)
The inspector reviewed the LER's listed above, to verify that the details of the event were clearly reported, including the accuracy of the description of the cause and the adequacy of corrective action. The inspector determined whether further information was required from the licensee and whether the event should be classified as an abnormal occurrence. The inspector also verified that the reporting requirements of Technical Specifications and applicable licensee procedures had been met, and that the appropriate corrective actions had been or are being taken.
The inspector identified no unacceptable conditions regarding these Licensee Event Reports.
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Testing of New or Modified Systems The objective of this area of inspection was to ascertain whether the licensee's startup testing program associated with the installation of new or modified systems or equipment for correction of the drywell high temperature (DHT) problem is in conformance with the regulatory requirements
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and licensee's approved procedures and administrative controls. Towards this objective, the inspector reviewed the testing program, reviewed certain documents, reviewed test procedures and reviewed completed test records on a sampling basis.
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Review of Documents The inspector reviewed the following Plant Design Change Requests (PDCR) associated with the DHT problem, specifically from the viewpoint of testing requirements:
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PDCR 81-09, Refurbishment of the Salt Service Water Chlorination and Residual Chlorine Monitoring Systems
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PDCR 81-41, Drywell RTD Replacement
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PDCR 81-55, RBCCW Heat Exchanger Channel Modification
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PDCR 81-57, Drywell Cooling Improvement Instrumentation
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PDCR 81-60, Replacement of Cables in Primary Containment
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PDCR 81-70 Plant Cooling Betterment Addition: Drywell Cooler Vent and Drain Valves PDCRs 81-57, 81-60, and 81-70 identified certain testing requirements
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for which either specific test procedures were attached to these PDCRs and/or Temporary Procedures (TP) were referenced in the PDCRs as listed below.
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PDCR 81-57-02, Approved 12-17-81, Preoperational Test for PDCR 81-57, Plant Betterment Program Drywell Cooling Improvement Instrumentation
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TP-81-95, Revision 2, Postwork Testing of Replacement of Cables in the Primary Containment (Test Procedure for cables identified in Table 1 of PDCR 81-60)
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TP-82-03, Revision 2, Motorized Valve Operators on Motor Operated Valves, Inspection and Deficiency Correction The inspector reviewed the above test procedures for technical adequacy and administrative controls.
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b.
Review of Test Records The inspector reviewed selected samples of the following test records:
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'TP-81-95, Postwork Testing on Replacement of-Cables in the Primary Containment
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TP-82-03, Motorized Valve Operators on Motor Operated Valves, Inspection and Deficiency Correction
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PDCR 81-09, Calibration and Functional Check Records of RTDs installed under this PDCR c.
Inspection Findings The inspector brought to the attention of licensee personnel the fact that the Yarway level instrumentation is presently calibrated for the higher drywell temperature and may require further recalibration if the actual drywell temperature (af ter the improved drywell cooling system is operational) is significantly different from the present calibration basis. The inspector confirmed with the licensee personnel that the required procedures will be developed prior to startup.
The inspector asked the licensee personnel whether any temporary procedures are developed for monitoring the performance of the new or modified systems during the power ascension phase of the plant startup and/or the permanent plant procedures'are revised for this purpose.
The licensee personnel' replied that the required procedures will be developed prior to startup.
The inspector had no further questions at this time. The inspector did not identify any deviation or violation.
7.
Facility Tours The inspector made several tours of the facility to observe activities in progress.
Specific observations included implementation of equipment tagging and radiological controls during testing, maintenance and modification work. No unacceptable conditions were identified.
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Unresolved Items Items about which more information is required to determine acceptability are considered unresolved.
Paragraph 3.g of this report contains an unresolved ite.
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Exit Interview The inspector met with licensee representatives (see Detail 1 for attendees)
at the conclusion of.the inspection on January 29, 1982. The inspector summarized the scope and findings of the inspection at that time.
Regarding the drawing and procedural discrepancies identified in paragraph 4, the Nuclear Operations Manager committed to initiate corrective action by the week of February 1,1982.
He further stated that this action would include a high priority task. effort to confirm the accuracy of all
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system P&ID(s) and related operating procedures.
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