Text

LER 89-016-00:on 890719,during Tech Spec Surveillance Test MI-5,leak Identified on MV-1805.Caused by Failure to Test Portions of Piping Associated W/Penetrations 17 & 48 Following 1980 Mod.Procedures developed.W/890818 Ltr
	ML18054A925
Person / Time
Site:	Palisades
Issue date:	08/18/1989
From:	Johnson B, Kozup C; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	LER-89-016, LER-89-16, NUDOCS 8908240345
	Download: ML18054A925 (12)
	v • d • e

consumers Power POWERI Nii MICHIGAN'S PROGRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 August 18, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

LICENSEE EVENT REPORT 89-016 (UNTESTED PIPING ASSOCIATED WITH THE CONTAINMENT BOUNDARY Licensee Event Report (LER)89-016 (Untested Piping Associated with the Containment Boundary) is attached. This event is reportable to the NRG per 10CFR50.73(a)(2)(i) and 10CFR50.73(a)(2)(ii).

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRG Resident Inspector - Palisades Attachments OC0889-0175-NL04

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I I I I I I I I I* I I I I I IUi.LIMINTAL llll'ClllT IXP'ICTID II" T rx, l!XP'ECTED IUIMISllON I Yl!S (If l'W. - - f)(l'fCTID SUllM/$$/ON DA Tf) NO DATE 1151 I I I A~ approximately 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months on July 19, 1989 Technical Specification (TS)

Surveillance Test MI-5, "Containment High Pressure Initiation Circuits for RPS, SIS and CIS" was initiated to test pressure switches [JM;PS] associated with the Containment Building high pressure initiation logic. During the conduct of the test, at approximately 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months , a leak was identified on MV-1805 [JM;RTV] by the Plant Instrumentation anci Control (I&C) Technician performing the t*est. At this time the test was stopped. Subsequently, it was determined that small $ections of piping associated with containment penetraticins 17 and 48 had not been tested during either LLRTs or past ILRTs. At 1500 the Plant -.Review Comlil.ittee directed that tests be developed and immediately performed to verify containment integrity. At 1045 on July 20, 1989 after identifying that testing would not be completed within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time imposed under the intent of Generic Letter 89-07, the NRC Resident Inspector was notified of our intent that Enforcement Discretion be granted to complete.the testing and at approximately 1445 it was granted by the NRC Region III Administrator. The total leakage rate for all eight penetrations was approximately 1,000 cc/min.

The failure to subsequently identify the untested piping under the current LLRT or ILRT program has been attributed to a failure to identify the lack of testing overlap between the ILRT and LLRTs performed.

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lllllCf_ . .18-131

NRC Fot"' 3MA 19-831 FACILITY NAMI 111 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NU . . Ell 121

U.I. NUCLEAll llEOULATOllY COMMl. .ON LEll NUMelll Ill APPROVED OM!I NO. 3150~104 EXPIRES: 8131185 PAOl 131 PALISADES NUCLEAR PLANT TEXT Ill,,_ - ii """"'9d- - _ . Nlft: Fomr JSil'1I 1171 0 IS I 0 I 0 I 0 12 I 51 5 8 19 - 0 I 11 6 - 01 0 0 I2 OF 0 ,s Description At approximately 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months on July 19, 1989 Technical Specification (TS)

Surveillance Test MI-5, "Containment*High Pressure Initiation Circuits for RPS, SIS and CIS" was initiated to test pressure switches [JM;PS] associated with the Containment Building high pressure initiation logic. During the conduct of the test, at approximately 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months , a leak was identified on MV-1805 [JM;RTV] by the Plant Instrumentation and Control (I&C) Technician performing the test. At this time the test was stopped and both System Engineering and Operations personnel were notified. The reactor was critical with the Plant operating at 80 percent of rated power when this condition was identified.

At 1400 the Plant Review Committee (PRC) convened to discuss the identified leakage of MV-.1805. The leakage locations were identified to be the threaded sections of MV-1805, which if closed, would be isolated from the containment atmosphere. MV-1805 is threaded onto the piping associated with

-the containment high pressure initiation circuitry at penetration 48. This penetration has four instrument air pipes which penetrate the Containment Building as indicated on Figure 1 and is one of two nearly identical penetrations. Penetration 17 is the "sister" penetration and is shown on Figure 2.

PRC noted that with the valve closed, the I&C Technician was able to pressurize the valve (the side away from containment) to about 70 psig of the 85 psig needed :for the calibre. .fon of PT-1805, ~.~ut he was unable to maintain the pressure with a _hand pump. Based on the successful calibration last month, it is believed this leakage has only been present for a maximum of one month. PRC concluded th.at since the leakage of MV-1805 has not been quantified, a leakage test on MV-1805 should be expeditiously conducted to determine if the total containment leakage is less than 0.6 L and whether further immediate repairs are needed to re-establish containm~nt integrity.

PRC directed a test to be written to determine leakage.

PRC also discussed whether MV-1805 could be considered a containment isolation valve. Engineering personnel provided verbal information that MV-1805 is equivalent to the other valves which are containment isolation valves. PRC concluded that sufficient justification was present to. classify MV-1805 as a containment isolation valve. However; PRC directed that a safety evaluation per 10CFR50.59 be conducted to determine if that .

reclassification constituted an unreviewed safety question. The* completed evaluation determined that an unreviewed safety question did not exist.

During reviews of the integrated and local leak rate testing (ILRT and .LLRT) it was determined that the portion of the piping between the designated containment isolation valves and the instrument isolation valve*, this section includes the associated pressure switch and/or transmitter, was not.

being tested as part of the routine Technical Specifications Surveillance T ER RQOHi -T.Tnl NfllC FOfllM JN~

19-831

NRC Form lllA 19-131 FACILITY NAMI 111 LICENSEE EVENT REPORT ILERt TEXT CONTINUATION DOCKET NUMIEll 121 U.I. NUCLEAR llEOULATOllV COMMllllON Liii NU...111111 A'PROVEO OMll NO. 3150-0104 EXPIRES: 8/31185

'AOI 131 PALISADES NUCLEAR PLANT TEXT 1/f ,,_. ...... ii,...-, _ __..NffC Foml .-.*111171 Program. Therefore, PRC discussed what actions were necessary to perform LLRT on portions of the penetrations 48 and 17 which were found not to be tested previously by the LLRT or the ILRT. PRC discussed that the monthly calibrations done on .. the pressure switches and transmitters on these sections of piping provided good evidence that these lines were intact and did not leak. During calibration, pressures ranging from 10 -psig to 100 psia were impos_ed but the calibrations did not qualify as LLRT' s. The failure to conduct the required surveillances were analogous to a previous occurrence where a Technical Specification test (R0-32-47, another LLRT) was missed in May 1988, thereby putting the Plant into Technical Specification 3.0.3. This occurrence was reported as Licensee Event Report 88-008, Date Entry Error Results In Failure To Complete Required Containment Leak Rate Test". At that time*, the provisions of Generic Letter 87-09 were used to allow a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period to conduct the required testing. The use of the provisions of Generic Letter 87-09 have been submitted as a formal Technical Specification Change Request on April 3, 1989. Based on the evidence that these sections of piping were leak free from the prior calibrations, PRC considered it prudent not to declare the piping inoperable and to allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the testing to be conducted to demonstrate operability. PRC directed these penetration tests be developed and run within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

At 1545 immediately after the PRC meeting, the Technical Engineer and the .

Plant General Manager met with the NRC Resident Inspector and the Chief, Project Branch No 2 to explain the situation and the direction being pursued by the Plant to expeditiouslv verify that containme~t integrity was being maintained. A conference call was establishad with Palisade;; Project

.Managers at NRR to discuss the containment integrity issue. During the conference call three major issues were discussed in the following .order:

1. MV-1805 was found to be leaking during a calibration of PT-_1805.

Our actions discussed were;

a. MV-1805 was closed and locked,

b. the leakage is isolated from containment by closing the valve,

c. the testing of MV-1805 would be done expeditiously,

d. MV-1805 would be reclassified as.a containment isolation valve.

2. In that only portions of the penetration around the pressure transmitters 1805 and 1812 had been tested during the ILRT and that the piping associated with the remaining pressure transmitters and pressure switches were not tested either in the LLRT or the ILRT further testing is required. The remaining portions of piping would be tested within the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months given as the NRC staff's position in Generic Letter 87-09 and as submitted as a Technical Specification Change Request on April 3, 1989. We noted that this Generic Letter guidance has been used previously by us,

3. The calibration of the pressure switches and pressure transmitters was beini conducted by opening the two containment isolation valves T.RR ~Qnl h-T.Tnl N"C FO .. U 3UA 19-131

NllC Fo1111 JleA 19-331 FACILITY NAMI 111 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMHll 121

U.I. NUCLEAll llEGULATOllY.COMMlalON Liii NUMelll Ill APPROVED OMll NO. 3150-0104 EXPIRES: 8/31185 PALISADES NUCLEAR PLANT o 1s I o I o I o I 2 15 I 5 8 19 - o 11 I 6 - 01 o o I 4 oF o 18 TEXT llf,,,.,,. - 11 ,.,,.,,,., - _ , . NltC Fomt .-.il'al 1171 and closing another valve which was not classified as a containment isolation valve. The calibration of the pressure switches and transmitters would be revised to eliminate that practice which is not allowed by Technical Specifications.

After leaving*the PRC meeting at 1530, a representative of the Plant Nuclear Licensing Department reviewed documentation associated with Systematic Evaluation Program (SEP) Topic VI-4, °Containment Isolation System". This review, conducted with a Plant representative involved with the SEP issue in 1981, was completed at 1630. The review concluded that no discussion regarding compliance with 10CFR50 Appendix J was present even though the penetration in its current configuration was identified. Further review identified that as a result of an NRC Notice of Violation issued in Inspection Report 80-02, these p~netrations were modified to their current configuration. This modification installed the new valves currently classified as the "containment isolation valves". Previously, the containment boundary had been defined as the cap which was directly downstream of the pressure element.

As a result of this revfew, the leakage associated with MV-;1805 and the fact that no information was readily available regarding compliance with 10CFR50 Appendix J for penetrations 17 and 48, the condition was deemed to be reportable.under 10CFR50.72(b)(2)(iii)(B) as a condition that could have prevented the fulfillment of a system needed to control the release of radioactive material. The report was initiated at 1715 and completed at approximately 1800. "

At 0000 on July 20, 1989 a PRC meeting was convened to review the reclassification of MV-1805 to a containment isolation valve and to review the procedure for testing MV-1805 and the portions of penetration 48 and 17 whic~ did not have LLRT's previously conducted on them. At 0215 PRC approved both issues and did not consider an unreviewed safety question existed.

At 1045 on July 20, 1989 PRC met again to discuss the status of testing with respect to end of the 24 .hour time period instituted under Generic Letter 87-09 on July 19, 1989. Based on the present status of testing, it was determined that an additional 12 to 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months past the 1500 hour0.0174 days 0.417 hours 0.00248 weeks 5.7075e-4 months deadline would be required. PRC also reviewed the data collected for the first three tests and concluded that continued testing past 1500 hours0.0174 days 0.417 hours 0.00248 weeks 5.7075e-4 months presented the safest course of action.without imposing a Plant transient (shutdown). At this time PRC developed a list of Plant Safety Considerations and decided to pursue enforcement discretion in accordance with NRC internal memorandum EGM-85-05B dated February 27, 1987. *The Plant NRC Resident Inspector was then notified at approximately 1045 of our intent. At 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months on July 20, 1989, the Resident Inspector and other NRC Staff presently onsite were presented the Plant_Safety Considerations.

LER 8Qnl n *T IOl

NRC For"'

A 19-831 FACILITY NAMI 111 LICENSEE EVENT REPORT ILER) TEXT CONTINUATION

DOCKET NUMelll 121

U.I. NUCLEAll llEOULATOllY CCIMMIDION Liii NUMelll Ill APPROVEO OMI NO. 3150-4104 EXPIRES: 8/31185 PAOl 1:11 PALISADES NU.CLEAR PLANT 0 I5 I 0 I 0 I 0 11 I 51 5 8 19 - 0 I 11 6 - 0I0 0 I5 OF 0 I 8 TlXT ! I f - - II,.,,,.,..., - .--..NltC -.-..*111i7I At. approximately 1445 on July 20, 1989 the requested Enforcement Discretion was granted by the NRC Region III Administrator. All LLRT was completed at 1955 hours0.0226 days 0.543 hours 0.00323 weeks 7.438775e-4 months on July 20, 1989. the total leakage rate for all eight penetrations was app~oximately 1,000 cc/min.

On July 26, 1989, while performing an additional review of ILRT versus LLRT lineups to identify if conditions similar to penetrations 17 and 48 existed for other penetrations, it was noted that a section of piping downstream of MV-CRW647A on penetration 25 was not tested. Subsequent reviews have revealed that a conscious decision was made to isolate this piping during ILRT performance. The decision was made t~ isolate the pressure transmitter to prevent over-ranging and damaging the transmitter. The section of piping isolated was approximately eight inches and contains a tee type fitting *.

The ILRT procedure clearly states our intentions of is9lating the line. In Attachment 3A of this procedure a note states, "The following valve is being closed to prevent over pressurizing PT-1065". ANSI Document N45.4-1972, Sectiqn 4.6, General Preparations for Test Pressurizing states, " ... contents of the containment structure that are sensitive to damage by a pressure differential, or by pressures above atmospheric (such as some instruments) should be removed or otherwise protected". The NRC has recognized this document arid the industry uses it as a guide. Palisades took the position that isolating 'the pressure transmitter to prevent damage falls under the "otherwise_ protected genre" and determined that no other testing of that line was required. At the time of discovery, it was decided to close the two manual isolations for PT-1005 until final rAsolution was determined. In summary, it is felt that this is not a similar case to penetra*... :!.ons 17 and 48 since we knowingly isolated the transmitter and no suitable alternate test existed and that ANSI N45.5-1972 was correctly applied. However, for prudency, an LLRT was written and satisfactorily performed on August 1, 1989 (identified leakage was 209 cc/min) for the previously untested piping.

Cause Of The Event The failure to test portions of the piping associated with penetrations 17 and 48 following the 1980 modification has been attributed to inadequate post modification testing. Testing and installation of the modified penetrations was to be performed under six procedures. Four of the six procedures were completed and documented within the modification package.

The remaining two procedures, however, 'were cancelled. The reason .for cancellation stated on the modification package was that other procedures had been or would be performed which would satisfy the intent of the procedures being cancelled. The cancelled procedures would have tested the untested portions of the piping.

The failure to test the untested portions of penetrations 17 and .48 under the current LLRT or ILRT program has been attributed to a f ailur~ to

~dentify the lack of overlap between the ILRT and the LLRTs performed. The

NRC Fot"' lMA 19-831 FACILITY NAMI 111 LICENSEE EVENT REPORT ILER) TEXT CONTINUATION DOCKET NUMllll 121

U.I. NUCLEAR llEOULATOllY COMMlatON LEll NUMllll Ill APPROVEO OMI! NO. 3150-411M EXPIRES: 8131185 PAOI IJI PALISADES NUCLEAR PLANT TEXT Ill,,.,,. - ii_.,., - _.... NftC Fomt lllSA'1J 1171 0 IS I 0 I 0 I 0 12 15 I 5 8 19 - 0 I lj 6 - 01 ci 0 I 6 OF 0 ,s ILRT tests the portion. of the penetration from the Containment Building to the instrument isolation valves for piping associated with pressure switches. Piping associated with pressure transmitters is tested to the designated containment isolation valves. The LLRT tests from the test tap connection to the second designated containment isolation valve. The piping system between the instrument isolation valves and the designated containment isolation valves was not tested *. This testing practice has been utilized since the firs.t LLRT on these penetrations was performed in 1981 and reflects the post modification testing performed in 1980.

The modification surveillance testing of the associated containment pressure switches has been performed monthly by removing the test tap, opening the manual containment tsolation valves, closing the instrument isolation valve and pressurizing the line. This practice violates Technical Specifications sections 1.4 and 3.6 which requires that all manual containment isolation valves be closed when the ~lant_is above the cold shutdown condition. The failure to identify this condition has been attributed to a lack of understanding of Technical Specification requirements and inadequate procedural ..reviews. During interviews with I&C personnel it was identified that during.calibrations, fittings at isolation valves were disconnected and test equipment connected. Therefore, a direct path from the containment atmosphere existed for short periods of time. This condition has been attributed to a lack of understanding of the system and the purpos~ of the test taps. Additionally, the controlling document for the calibration was a periodic activity control and calibration sheet which did not have formal procedural guidance detailed. ,

In that fittings associated with valves were breached and reconnected and tightening of fittings to eliminate leakage was performed, a maintenance activity occurred on tested components without pre-maintenance testing as ,

required by 10CFR50 Appendix J. This condition has been attributed to a lack of understanding by involved personnel. Engineering personnel drew an analogy between tightening the fittings and adjus.ting valve packing and concluded no testing was required.

Corrective Actions Procedures* were developed and satisfactorily performed to verify the integrity of the previously untested portions of the piping at design containment pressure. Technical Specification Surveillance Procedure MI-5 was revised such that containment high pressure logic would be tested by electronic signal on a monthly basis. The full system logic testing by use of pressure is currently performed on a refueling frequency.

A complete review of the ILRT and LLRT programs are being conducted. This review will include physical walkdowns of.penetrations to verify accuracy of drawings and test boundaries, a review of past modifications to penetrations NJIC FOJIM 368A 19-131

N AC Forlft JllA 19-831 FACILITY NAMI 111 LICENSEE EVENT REPORT (LEA) TEXT CONTINUATION DOCKET NU. .111 IZI

U.S. NUCLEAll llEOULATOllY COMMIDION Liii NUMHll Ill APPROVED OMll NO. 3150-0lCM EXPIRES: 8131185 PAGI 111 PALISADES NUCLEAR PLANT o 1s Io Io Io 12 I 51 5 8 19 - o I ll 6 - 01 o 01 7 OF o 18 TtxT llf - - 11 ....-_ - . - , . , NllC Fotrrl .-.**1117)

to assure required test lineups were made and a* review of ILRT versus LLRT lineups to verify all required lines are tested. The test procedure methodology developed and utilized during testing on July 19 and 20, 1989 will become formal LLRT procedures.

MI-5 testing methodologies will be reviewed to determine the most prudent testing arrangements. If necessary, Technical Specification changes will be proposed to allow opening of manual valves above the cold shutdown condition. A detailed review of all other calibration procedures used to calibrate instruments between containment* isolation valves and the Containment Building is being conducted to ensure all requirements of 10CFR50 Appendix J and Plant Technical Specifications are met.

All applicable I&C Department test procedures are being revised to include guidance.regarding test tap usage only and the importance of maintaining containment isolation boundaries. All instrument calibrations requiring manipulation of manual valves associated with penetrations 17 and'48 are be~ng incorporated in formal Technical Specification surveillance procedures requiring performance.in the cold shutdown condition.

An evaluation is in progress to determine the need to modify piping associated with penetration 25. This evaluation will include removing or relocating PT-1065 and its associated manual valves.

Continuing training sessions will be conducted to specifically address this event. Additional 10CFR50 Appendix J training will be added as a requirement to the ILRT/LLRT and containment isolation engineering training matrices.

Analysis Of The Event As indicated, the total leakage from all previously untested portions of piping was approximately 1000 cc/min which is only a. fraction of the allowed 65,200 cc/min leakage. Therefore, no threat to the health and safety of the public is believed to have existed. Dose consequence analyses are being conducted to determine the impact of breaching piping at valve fittings.

Based on preliminary reviews, the resultant dose is expected to be below 10CFRlOO. 11.

This event is being reported per 10CFR50.73(a)(2)(i)(B) for opening of the manual isolation valves above the cold shutdown condition and per 10CFR50.73(a)(2)(ii) for breaching* the piping associated with penetrations during instrument calibration.

T.'F'R RQ()l i:\-T.Tnl N~C FO~M 388A 19-831

NRC Form lllA 19-831 FACILITY NAMI 111 LICENSEE EVENT REPORT (LERI TEXT CONTINUATION OOCKET NUMIEll 121

U.I. NUCLEAR llEQULATOllY COMMIDION LEll NUMHll Ill APPAOVEO OMll NO. 3150~104 EXPIRES: 8131185 Pl<QI 1:11 PALISADES NUCLEAR PLANT TEXT /If marw - * ~. - . - W NlfC Form :mA'111171 0 IS I 0 I 0 l 0 12 I 51 5 819 - 0 I lj 6 - o, 0 0 I8 OF 0 ,s Additional Information

Reference:

a. Licensee Everit Report 88008; "Data Entry Error Results In Failure To Complete Required Containment Leak Rate Test" dated June 13, 1989.

b. NRC Inspection Report 88014 dated June 17, 1989.

c. Consumers Power Company letter "Request For Enforcement Discretion" dated July 21, 1989.

d. NRC letter "Discretionary Enforcement Regarding Untested Containment Penetration Lines" dated July 21, 1989.

NlllC FOlll"-" J&GA 19-831

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 SCHEMATICS FOR LLRT PENETRATION 17 AND 48 August 18, 1989 2 Pages OC0889-0175-NL04

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