IR 05000352/1987017

Insp Rept 50-352/87-17 on 870615-19.No Violations or Deviations Identified.Major Areas Inspected:Test Witnessing & Administrative Control of Local Leak Rate Testing & Tours of Facility

ML20236C186
Person / Time
Site:	Limerick
Issue date:	07/09/1987
From:	Anderson C, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236C157	List: IR 05000352/1987017 ML20236C155
References
50-352-87-17, IEIN-85-071, IEIN-85-71, NUDOCS 8707290365
Download: ML20236C186 (8)

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< U.S. NUCLEAR REGULATORY COMMISSION L: r ~ REGION I

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Report No. '50-352/87-17 a

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. Docket No. '50-352

, License No' . NPF-39- ,

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Philadelphia: Electric Company

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Licensee:

2301 Market Street Philadelphia, Pennsylvania -19101-

. Facility;Name:~ . Limerick Nuclear Generating' Station, Unit -1: 1

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Inspection At: Limerick, Pennsylvania ~

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Inspection Conducted: . June 15-19,'1987 lInspectorsi '7"7" 7-ph.Apolla,;ReactorTngineer date'

Approved.by: /d an[ 7-7-'87 .

fClifSystem ford /J on, Chief, Plant :date on, EB, DRS Inspection Summary': -Inspection on June 15-19, 1987 (Inspection' Report N /87-17)-

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NreasInspected: Routine unannounced inspection of test witnessing and 1 administrative-control of local-leak rate testing and tours of-the facilit !

Results: No violations or deviations were identifie l 8707290365 ADOCK 0500 B70721 2[  ;

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DETAILS

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.1.0' Persons' Contacted E 'J. Berlin, Test Engineer R; Bonn'ette', Technical Assistant

'S.eDennett,-Maintenance Foreman ..

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• G. ' Edwards ,. Technical.' EngineerE

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• J., Franz, Plant Manager

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T. Grim, QC-Engineer

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J. Grimes, I&C Supervisor W. Lewis, Test Engineer- .

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l L , *J. McC1 wain,' Lead Audito'r QA

• J. Muntz,' Performance.' Engineer D. Neff, Complia_nce Engineer

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Li Perkowski,'Sr. Technical Assistant l D. Shaner,. Technical. Assistant-  !

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0; Sustaita, Technical . Assistant

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B.'Tracey, Technical Assistant i NRC ,

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Kelly, Senior Resident Insoector '

• S. Kucharski, . Resident' Inspector 1

• Indicates'.those present'at the exit meeting held June 19, 198 .0 Local Leak Rate Testing (LLRT)-

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2.1; General M

The purpose'of this inspection was to a*,certain that loca'r leak rat testing =is being administer'ed' adequately and conducted.ia. compliances -i

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with the requirements and commitments referenced'in the following R

, section. LThe LLRT procedures were reviewed.for technical adequacy Lto perform.the intended activity- Other record keeping and LLR .

related documentation was reviewed to determine adequacy of the .

overall administrative control of the local leak rate. test progra I

2.2 References

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10 CFR; . Part 50, Appendix J, Primary Reactor Containment Leakage. Testing for Water Cooled Power. Reactors-

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Limeri.ck Unit 1 Technical Specifications Sections 3/4.6.1, Primary Containment

Final Safety Analysis Report (FSAR)

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ANSI /ANS 56.8-1981, Containment Systems Leakage Testing Requirements  !

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USNRC I&E Information Notice No. 85-71; Containment Integrated Leak Rate Tests j

2.3 Documents Reviewed ) Current outage LLRT results s Maintenance Request Forms (MRF's) for "B" MSIV inboard, "0" MSIV outboard, and RHR containment spray valve 16 l j Suspected Licensee Event Report (SLER) for MSIV's exceeding LLRT limit and other Appendix J testable valves exceeding .6La criteri . SLER for tip purge and spare containment penetrations identified as not LLRT'ad per technical specificatio . LLRT history for containment airlocks - TL-12-07047, Implementing procedure for certification of gas  !

flow and flow rate meters, Rev. 0

• ST-1-LLR-001-1, the LLRT program and accountabilhy test, Rev. 4 8. QA monitoring reports and related auditing documentation j

• 0ther LLRT procedures specific to selected penetrations were reviewe .4 LLRT Procedure Review The inspector reviewed the LLRT procedures to determine their adequacy of content and adherence to accepted testing methodolog The LLRT program is structured such that every mechanical penetration has a specific procedure covering system lineup and leak testin These penetration specific procedures are governed by a more general procedure which covers test methodology and LLRT p record keeping. The procedures were found to be technically correct to perform local leak rate testing utilizing the mass flow-in method. This method is acceptable per 10 CFR 50, Appendix J and current industry practice. The inspector verified that the LLRT .

procedures contained the following pertinent information: Response l for combined LLRT failure, criterion utilized to determine the maximum pathway leakage through a valve / piping network, and test precautions and initial condition ?

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Nounacceptableconditionswereidentifiedwithinthescopeofichi review)

2.5 Test Witnessing'and Instrumentation

.The inspector witnessed.the.p'erformance'of test activities to. verif that qualified. test equipment and tools were used and that:the test -

technicians follewed the procedure. -The following-mass flow-in tests were witnested:

' Pressure-safety valve pSV-51-IF0,30b at'RHR pump "D" suction

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on June 16, 198 '"y 4 l

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l Valv'e No. HV-52-IF005 at "A" core s' pray pump discharge on , 1

% June 17, 198 The inspector' reviewed the system lineups for the tests,. witnessed' "q and determined that they'were.in an effective test configuratio The test technicians followed approved procedures, utilized '

qualified test equipment, and wdre competent to perform the tests'.

The inspector reviewed calbration records for the following lea rate raonitors (LRM's) beirig u' sed this' outage to conduct local . leak rate testing: serial nos.; 21-1106, 21-1107, 21-1108,'21-1109 -

21-1120,21-112 '

The standards used to' cal'brate the in'struments contained within'the LRMs (Pressure Gages and Flow Meters) were certified to be trace '

able to the National Bureau 'of ' Standards (NBS). The LRM's are re-

calibrated on a monthly. frequency when in use,and receive a' flow range check as a prerequisite to= everyi LLRT performed.' No deficien-

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cies were identified within'the scope of this revie .6 Administrative Control a

The inspector reviewed documenta. Men relevant to the overall admini-strative control of the local lehk rate test program. Informatio which documented the following status of activities and criteria wer reviewed: Recording of test'results, determination of maximum pathway leakage, LLRT equipment. calibration requirements, acceptance criterion for pneumatic, hydrostatic, and MSIV': testing and mainte-

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nance request forms'(MRF's) for containment isolation valves receiv--

ing maintenance work. The information reviewed was foun'u current (LLRT running total' was being maintained and records were prganized l well) and.. appeared adequate to provide proper administrative cont'r ol of the overt. 1 LLRT program. No unacceptable conditions were identified.

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. 27 Failure of "As-Found" Criterion 9 As iof:the time of th.e inspection, approximately.78 of 92 "as-found" ' : local leak rate tests have been performed.. The acceptance criterion' 4 '

for total-maximum pathway leakage through alliisolation barriers: p (except MSIV's) subject to pneumatic testing is .6La. This maximum i . .j' .

-allowable..LLRT; total-is a requirement per 10'CFR 50, Appendix J and t

)J N Limeric:k Technical Specifications. For Limerick Unit I where La is 't q#'

O.5%/ day, .6La is=0.3%/ day. This corresponds to 94,964 sec/ min. As' d

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of June- 19, 1987, the LLRT- running total: was'- 135,119.7 sec/ min. .This

isLin; excess.of the allowable limit. MSIV's at' Limerick have..a '

leakage control system'and are not included in the :.6La criterion, d, The~ allowable leakage'for MSIV's is'11.5 scfh/line or 46.sef .s total. .Three'of four main steam lines tested showed "As-Found"

'offscale= leakage through their-MSIV's. The'other line showed a leakage of '16,000 sccm or 33.9 scfh. The table below identifies the steam. lines'and valves with.their leakages, y  :;

Penetration- Valves Leakage X-7A'(main. steam HV-40.1F0018, 33.9 scfh line A) HVS-41-1F022A, i<

1F028A

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X-7B (main steam HV-40-1F001F, Offscale line B) HVS-41-1F022B, 1F028B

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X-70.(main steam HV-40-1F001K, Offscal s, line C) . HVS-41-1F022C', IF028C

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X-70 (main steam HV-40-1F001P, Offscale F line D) HVS-41-1F0220, IF0280 1

,3 MSIV "As-Found" leakages are in excess of allowable limits per mijn steam.line and per total allowabl .

The inspector reviewed a  !

" suspected license. event report" addressing the LLRT criteria failure Repairs to theTheappropriate licensee stated thatvalves isolation the formal LEReffected must.be is forthcomin such ,A that LLRT criteria is met prior to unit startu [. v 2.8- Identification of Untested Primary Containment Isolation Boundaries '

a The licensee has identified two penetrations which have not~ received h1 local leak rate testing per technical specification require dnt !

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They are at X-35A (spare) and X-35B (TIP purge). The circesstances

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which led to their identification are as follows: while performing

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ST-1-LLR-281-1 (LLRT for TIP purge), it was observed that penetration J X-358 included a testable "0" ring assembly which had not;bd n ,'

included in the procedure for this penetratio Investigatici fo.und that this should have been tested (TS Table 3.6.3) and had not * .

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been previously tested by the local leak rate tett program. While performing this investigation, it was further-fouad t'p penetration e' i X-35A, listed as a spare in FSAR Table 6.2.25 and not induded in TS Table 3.6.3, is provided with a testable "0" ring assembly. Due

. . . s to these two oversights, primary containment integrity was not proved

L)- 'A as required by Technical Specification 3.6.1.1 pride to cycle 1

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criticalit Thetwo"0"ringassembl9shavenobNtentestedwith the following results: Penetration X j and "0" ring assembly at penetration N355(TIPpurib)m@ured .5A (spare)'meciscred 0.Y sccm t'

sccm. These leakages are small and indicate leak GghtyM. The inspectordiscussedcorrdctiveactionwiththelicenseeandreviewed i the " suspected license event report" on the subject. ST-1-LLRl231-1 "

, received a temporary procedure change (TPC) to test the "0" rings a y,(

X-35i( The inspector reviewed the TPC and found it acceptabid AC/

permanst revision will be inade.i Penetration X-35A will be capped 'andd'

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'j q a 4 10 CFR 50, Appendix J but since it was identified, reported and

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1 y" corrected by the licensee it may be considered to meet the five

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criteria of 10 CFR 2, Appendix C for self identified violations, . .t i

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(1) it was identified by the licensee'

(2) it fits severity level IV or V r/ s J (3) it was reported s 4 j it was or will be corrected,' including measures to prevent

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recurrence

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(5) it was not a violation that could reasonably be havebeenpreventedbythelicensee'scorrectivfexpecMedto'he j ,

'y previous violatio ,g 1 q

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This will remain an unresolved item (UNR No. 87-17-31) unt 6 the NRC l receive:, the formal LER on the subject, permanent procedtze change to ST-1-LLR-281-1 has been approved, and spare penetration X-35A has been verified capped and welded. The.' inspector had no further

question ( l 3.0 Followup of Previously Identified Open id h4 (0 pen) (50-352/86-23-01) LER 85-102: E ssi Ne Leakage of Containment Spray Valve HV-51-1F016A As previously discussed (in inspdtYon reports 86-03 and 86-23), a LLRT y ,, was performed in December 1985 on' penetration 39A for the "A"-Loop

O drywell spray header. That penetration failed to hold pressure with the  !

. . outboard isolation valve (HV-51-!FM6A) tightened by normal means (motor

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, ' \ ' operator). As-found leakage was W excess of 68,000 sce IsoMtior 1

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l valve HV-51-1F016A was manually tign'tened shut, the ipst was ,

re performed, and penetration leakage was reduced to 372.4 sccm. Al,

i,e supervisory block was applied to thei,hand switch for the 163(v

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control room, its' motor control center was de-energized, and the man ~al- u handwheel .for. the valve was secured in; the full l closed positio Although technical specifications do.not require operability of drywell sprays, closingLthe 16A' valve rendered the "A". loop of: containment. spray

' inoperable for the~ subsequent.five months of plant operation. . During the-

6-week outage in.'May-June:1986, maintenance-was performed on the 16A:

valve! operator,which.ircluded. cutting a s1C n the.. torque 11mitJsleeve of the spring' pack used to sense motor torque. This' was done to allow the release of-excess grease that-may have accumulated and was suspected as a'cause of the valves failuro to hold LLRT. pressure. However,_on Jun'e 4,.1986, the' penetration was-re-tested by normal means:(closure of isolation' valve-by motor operator) and failed to achieve test pressur Hc ~

' The ' valve was again . manually closed and the "A" loop of containment spray

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' remained: inoperable since the The: inspector' discussed with the licensee the planned corrective action for the valve 'and ! reviewed a . maintenance request form (MRF) for the' valv .

The. licensee' indicated that the valve wil1~ receive thorough corrective maintenance this outage and.that the containment spray "A" loop will be operable prior to startup 'for' the next cycle. The MRF indicated the'

following planned corrective actions:

Remove limitorque operator, disassemble'and investigate problem

• . Lap / repair the valve seat

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Check and; adjust limitorque operator a' Lubricate parts as needed

• Repack the valve The MRF also indicated that OPS /QC is to perform QC functions for this work. This item will remain open until, resolution of the proble .0 Personnel Training and Qualifications

'The Qualification and training of selected test personnel were discussed with a licensee representative. In addition, the-inspector evaluated the performance of test technicians during the test witnessing. It was-determined that new LLRT technicians and other interest 2d parties attended a training class given by experienced LLRT personnel. Class material and' attendance records were reviewed by the inspecto 'The inspector determined that the test technician's qualifications met the requirements specified in ANSI N 18.1-1971 " Selection and training o nuclear power plant personnel". They were knowledgeable of their responsibilities and technical aspects of leak testin No unacceptable j

. conditions were' identifie ;

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5.0 Plant Tour The inspector made several tours of the plant facilities including the reactor building, turbine building, control room, and plant exterior to monitor outage activities and housekeeping. All areas inspected were generally clean and free from debris not affiliated with ongoing maintenance activitie No unacceptable conditions were identifie .0 Quality Assurance and Quality Control The inspector discussed coverage of local leak rate testing with representatives from the QA and QC organizations and reviewed LLRT QA monitoring reports and supporting documentation. It was determined that both QA and QC are providing direct coverage of local leak rate tests this outage and that QA is doing a program effectiveness audit. The LLRT program effectiveness audit includes QA evaluation of both technical and administrative aspects of the LLRT program. QA monitoring reports and findings were well documented. The QA and QC representatives interviewed j were knowledgeable of local leak rate testing and their duties as QA/QC auditors. No unacceptable conditions were identified.

l 7.0 Exit Meeting Licensee management was informed of the purpose and scope of the inspection at the entrance intervie The findings of the inspection were periodically discussed and were summarized at the exit meeting on June 19, 198 Attendees at the exit meeting are listed in section 1.0 of this report.

l At no time during the inspection was written material provided to the licensee by the 'nspector.

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