IR 05000293/1987002
| ML20210U575 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/02/1987 |
| From: | Anderson C, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20210U536 | List: |
| References | |
| 50-293-87-02, 50-293-87-2, NUDOCS 8702180517 | |
| Download: ML20210U575 (6) | |
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i U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 87-02 Docket No. 50-293 License No. DPR-35 Priority
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Category C=
Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Generating Station Inspection At:
Plymouth, Massachusetts Inspection Conducted: January 5-9, 1987 Inspectors:
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ph A/G lla, Reabfor Eiigineer date
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Approved by:
CliffprdJ. Anderson, Chief date
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Plant Systems Section, EB Inspection Summary: Routine unannounced inspection of local leak rate test program administration, results evaluation, and followup of previous inspection findings.
Results: No violations or deviations were identified.
I B702180517 870210 PDR ADOCK 05000293 O
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DETAILS 1.0 Persons Contacted
- J. Bellefeuille, On Site Safety & Performance Group Leader
- M. Brosee, Maintenance Section Manager P. Cafarella, NED, FS&MC
- F. Famulari, QC Group Leader A. Felix, Performance Engineer
- R. Grazio, Field Engineering Section Manager
- D. Sanbend, Nuclear Training
- J. Seery, Technical Section Manager
- R. Sherry, Chief Maintenance Engineer E. Ziemianski, Management Services Section Manager NRC
- H. Gray, Lead Reactor Engineer
- H. Kaplan, Lead Reactor Engineer
- J. Lyash, Resident Inspector
- M. McBride, Senior Resident Inspector
- Indicates those present at the exit meeting held January 9, 1987.
2.0 Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (50-293/83-03-05)
Inconsistencies between.various documents (FSAR, TS, Procedures, STA Memo) for containment isolation valve descriptions. On February 8,1983, the resident inspector provided
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the licensee a list of 73 questions on primary containment isolation valves (PCIV's). The inspector discussed the status of this unresolved item with a representative from the B.E. Co. Compliance Department and reviewed B.E. Co. Office Memorandum 86-016 dated January 31, 1986 which addresses the item.
The memorandum responded to 71 of 73 inspector questions and indicated that the last two questions were being worked on. The memorandum reflected an extensive effort by B.E. Co. to resolve the item. Verification of changes to PCIV list, procedures, and drawings and closure of this item will be performed by the resident inspector.
3.0 Local Leak Rates Testing (LLRT)
The purpose of this inspection was to ascertain that LLRT is being admin-istered adequately, and conducted in compliance with the requirements and commitments referenced in the following sections. Procedures were re-viewed for their technical adequacy to perform the intended activities.
Other LLRT record keeping and related documentation was reviewed to de-termine the adequacy of overall administrative control of the LLRT program.
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3.1 References
Pilgrim Nuclear Generating Station Technical Specifications Section 4.7.A
10 CFR; Part 50, Appendix J, Primary Reactor Contairment Leakage Testing for Water Cooled Power Reactors
Final Safety Analysis Report (FSAR)
ANS1/ANS 56.8-1981, Containment Systems Leakage-Testing Requirements 3.2 Documents Reviewed
Procedure No. 8.7.1.3, Local Leak Rate Test Program, Revision -13
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Procedure No. 8.7.1.5, Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valves, Revision 28
i Procedure No. 1.5.3, Maintenance Requests, Revision 18 Procedure No.1.8, Master Surveillance _ Tracking Program, Revision 4
Procedure No.1.8.2, PM Tracking Program, Revision 1
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Procedure No. 2.2.125, Containment Isolation System, Revision 4 i
B.E. Co. Quality Control Inspection Report No. 86-1-18-A,-- 189, 20A, 208, 20C covering the QA Surveillance -of Testing and Maintenance of MSIV-203-ID.
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Office Memorandum DMG86-256 established a LLRT failure analysis team.
- Dailey Status Sheet - shows LLRT related information in a collated form, e.g. total No. Type "B" LLRTS passed / failed, etc...
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Adjustment to LLRT Leakage Summary - shows LLRT resultant
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running total
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PNPS LER No. 86-015-0, Primary Containment Local Leak Rate Test Frequency i
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PNPS LER No. 86-011-0, Leakage Past MSIV's in Excess of LLRT Criteria
Procedure No. 8.7.4.1.2, Primary Containment -Integrated Leak Rate Test, Revision 2 3.3 Administrative Control The inspector interviewed selected licensee personnel and reviewed documentation relevant to the administration of the local leak rate testing program. Adequacy of administrative control of the program was verified by an audit in the following areas:
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Local Leak Rate Test Procedure - This procedure no. 5 was found to be technically correct to perform LLRT utilizing the mass flow-in method. Test data sheets include relevant information such as; test cart no., calibration due dates for the individual instruments used, date and time of test, check-offs for certain test prerequisites, etc...
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Recording of Individual and Tota 11 zed Results - The licensee has three documents which provide a comprehensive record of test results and program status. The three documents are; LLRT Status Matrix, Daily Status Sheet, Adjustment to LLRT Leakage Summary.
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Master Surveillance Tracking Program - The licensee has incor-porated primary containment isolation valves (PCIVs) and other containment pressure boundaries (CPBs) which are required to be local leak rate tested in accordance with 10 CFR 50, Appendix J into their master surveillance tracking program. This program tracks the performance and documentation of all surveillance tests required at Pilgrim Nuclear Power Station (PNPS) with major emphasis placed upon Technical Specification required surveillances.
Local leak rate testing of PCIVs.and CPBs are in this category.
The program collects daily data updates from a master log and issues weekly surveillance test schedules plus three weeks of projected surveillance tests. Through the use of this program, the minimum 2 year surveillance frequency for PCIVs and CPBs is identified.
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Valve Maintenance - The inspector reviewed documentation per-taining to valve maintenance including procedures governing maintenance requests and the tracking of preventive maintenance.
Also reviewed were several examples of fully administered maintenance requests and maintenance summary and control forms.
All of the documentatior, reviewed was orderly. The various maintenance request forms, maintenance summary and control documents etc..., provided for thorough administrative control of valve maintenance.
No unacceptable conditions were identifie.
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3.4 Failure of LLRT "As-Found" Criteria At the time of the inspection the majority of the "as-found" LLRT's were completed. A review of the latest local leak rate test daily status sheet showed that 93 of 100 Type "B" LLRT's were completed with no failures and 114 of 123 Type "C" LLRT's were completed with 10 failures.
It was shown that leakage through 5 of 8 main steam isolation valves (MSIV's) was in excess of the Technical Specifica-tion limit set forth for-individual MSIV's.
In addition, when MSIV leakage is totaled using maximum pathway leakage methodology the total leakage through MSIV's alone is greater than that allowed through all primary containment isolation valves.
The licensee has acknowledged this and has written a licensee event report (LER) on the subject pursuant to 10 CFR 50.73. The inspector discussed efforts to improve the leak tight integrity of the MSIV's with the licensee. The licensee, during the current outage, has rebuilt all eight MSIV's due to pilot poppet degradation. Also, the MSIV's were modified and refurbished during the 1984 refueling outage. The present "as-found" LLRT results show improvement over the last period. Prior to restart of the unit the MSIV's must pass the LLRT acceptance criteria.
In response to LLRT acceptance criteria failures the licensee has assembled an LLRT Failure Analysis Team. The inspector discussed the efforts of the team with the licensee. The licensee indicated the team was established to conduct root cause analysis and make-recommendations to correct and prevent future failures.
The inspector also reviewed documentation pertaining to team efforts thus far.
Fifteen CIV's (including 5 of 8 MSIV's and 4 of 4 feedwater check valves) and the personnel airlock shaft seal have received root cause failure analysis and corrective / preventive maintenance.
3.5 Local Leak Rate Test Frequency On June 13, 1986, with the plant in cold shutdown, a review of local
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leak rate test completion dates showed that greater than two years had elapsed since 69 Type "B" tested components and 39 Type "C" tested components had successfully passed LLRT.
Boston Edison had
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previously applied the minimum two year interval for LLRT on a programatic basis rather than on a percomponent basis. This issue has been addressed by the licensee in an LER (No. 86-015-01) and is under review by NRR. The licensee, however, is now conducting its LLRT program on a minimum two year test frequency per individual com-ponent. All components testable under Appendix J will be retested toward the end of the outage to ensure proper test frequency after
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startup.
4.0 QA/QC Coverage The inspector discussed coverage of local leak rate testing with several QA and QC representatives and reviewed selected quality control' inspection l
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reports.
It was determined from the discussion that QC monitors work which is initiated as the result of a. maintenance request (such as LLRT's)
and that QA covers other nonmaintenance request generated activities.
It was also determined that QC covers at least one of every LLRT type (elec-trical pen, PCIV, etc...) and approximately twenty-five percent of all LLRT's performed. The inspector noted that QC surveillances of LLRT's were fully documented and well organized.
No unacceptable conditions were identified.
5.0 Containment Integrated Leak Rate Testing (CILRT)
The inspector discussed with the licensee provisions for the upcoming CILRT currently scheduled for Mr.y 1987.
Included in the discussion were the following two issues surrounding containment leak testing:
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The determination of an "as-found" CILRT result from a test done with containment pressure boundaries in an "As-Left" condition.
This will be the case for the May 1987 CILRT.
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Use of the Mass Point Calculational Method, endorsed in ANSI /ANS-56.8-1981 for determining leak rate from averaged raw data. The Pilgrim Nuclear Power Station CILRT Procedure (No. 8.7.4.1.2, Rev. 2) indicates usage of the mass point method. The inspector informed the licensee that this method is not sanctioned by 10 CFR 50, Appendix J.
6.0 Exit Meeting Licensee management was informed of the purpose and scope of the inspec-tion at the entrance interview. The findings of the inspection were periodically discussed and were summarized at the exit meeting on January 9, 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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