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IE Insp Rept 50-278/81-21 on 810831-0908.Noncompliance Noted:Failure to Perform Leakage Test Following Maint on Containment Boundary
	ML20032B639
Person / Time
Site:	Peach Bottom
Issue date:	10/08/1981
From:	Bettenhausen L, Rekito W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20032B631	List: ML20032B630; ML20032B634; ML20032B639;
References
	50-278-81-21, NUDOCS 8111050744
	Download: ML20032B639 (12)
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U.S. NUCLEAR REGULATORY' COMMISSION'

0FFICE OF INSPECTION AND ENFORCEMENT.

Region ~I

Report No.

50-278/81-21

Docket No.

50-278

License No.

DPR-56

Priority

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Category

C

Licensee:

Philadelphia Electric Company

2301 Market Street

Philadelphia, Pennsylvania ~19101

Facility Name:

Peach Bottom Atomic Power Station, Unit 3

Inspection at:

Delta, Pennsylvania

Inspection' conducted: August 31, 1981

- September 8, 1981

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/O/6[/P/

Inspectors:

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W.'A. Rekito,-Reactor Inspector

date s1gned-

Approved by:

,_ M M N ha---

/d/F/g/ -

. H. Bettenhausen, Chief, Test Programs,Section,

date sigried.

Engineering Inspection Branch, DE&TI

Inspection Summary:

Inspection on August 31 - September 8,1981(Report No. 50-278/81-21)

Areas Inspected:

Routine unannounced i.7 ea. tion of containment integrated

leakage rate test activities; outage maintenance activities; shutdown plant-

activities; and licensee action on previous inspection findings. The inspection

involved 42 inspector-hours onsite by one region-based NRC inspector.

Results: One item of noncompliance was identified in one area.

(Failure to

perform leakage test following maintenance on containment boundary, paragraph

4.g).

Region I Form 12

Aa.41 m

(Rev. 8111050744 811015

PDR ADOCK 05000278

G

PDR

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. DETAILS

1.

Persons Contacted

E. Black, Assistant Foreman, Mobile Turbine Group

J. Davenport, Engineer-Maintenance

J. Doering, Results Engineer

R. . Fleischmann,' Assistant Station Superintendent -

A. Fulvio, Results Engineer

K. Mandl, Quality Assurance Auditor-

C. Mengers, Quality Assurance Site Supervisor

W. Ullrich, Station Superintendent

.

-* A. Wasong, Test Engineer

H. Wilkerson, Bechtel Corporation.

USNRC

rc Blough, Resident Reactor Inspector

C. Cowgill, Senior Resident Inspector

The inspector also interviewed.other. licensee employees-during the inspection

- including reactor operators, technical support, and maintenance personnel.

denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings

(0 pen) ' Unresolved Item (278/77-28-05)i

Site records of-Type B and C

local-leak rate test dates for penetrations N-231A and B did not agree

with the dates reported to the NRC in the 1977 Unit 3 Reactor Containment

. Building Integrated Leakage Rate Test Report.

The licensee determined

' that the report was in error and committed to correct this discrepancy by

submitting *a am ended version of the subject report to the NRC by October

21, 1981.

(0 pen) Unresolved Item (278/77-28-07): Apparent inaccurate reporting cf

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MSIV 80B local leak rate test .results ir. the 1977 Unit 3 Reactor Containment

Building Integrated Leakage Rate Test Report. The licensee determined

that the identified report error had not yet been corrected.and committed.

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to submitting an amended version of the subject report to the NRC by

October 21, 1981.

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3.

Containment Integrated Leakage Rate Test (CILRT) Procedure Review

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a.

Documents Reviewed

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Procedure ST 12.5-1, Revision 2, " Integrated Leak Rate Test".

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Peach Bottom Technical Specification Section 4.7, Containment

Systems.

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Dwg. No. M-351, Revision'.18, fluclear Boiler.

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Dwg. No.' M-332, Revision -8, Primary Containment Leak Testing.

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Dwg. No. M-308, Revision ~ 16, Feedwater and Feed Pumps.

.Dwg.~ No. M-362, Revision 19, Core Spray Cooling System.

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Dwg.'No. M-365, Revision 19, High Pressure Coolant Injection

System.

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Dwg. No. M-367,' Revision 17, Containment Atmospheric Control

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System.

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Procedure-RT 8.0, Revision 0, Safety. Instrument Valving Che'ck

Off List.

b.

Scope

The inspector reviewed Procedure ST 12.5-1, " Integrated Leak Rate

' Test," for technical adequacy and compliance with 10 CFR 50, Appendix

J, ANSI /ANS-N56-8-1981, and Peach Bottom Technical Specifications.

.

The following are.some of the key aspects of the CILRT requirements

verified by the inspector:

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Containment Interior Inspection specified;

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Special Instrumentation requirements specified and instrument

error analysis performed;

Isolation valve closing mode specified to be normal;

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Valve lineups specified venting and draining of lines as required

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to prevent the creation of artificial leakage barriers that

could not be expected to exist following a Design Basis Accident

(DCA);

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Use of Test Events-Log specified;

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Method of pressurization, minimum test pressure, and depressuriza-

tion properly specified;

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Minimum test data requirements specified;

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Results evaluation techn'ique properly specified;

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Systems required to remain in operation to support the test and

assure re ator safety were pr'operly specified;

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Appropriate corrections to test results specified for sys"..ms-

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not properly vented or drained and changes to the containment

free air volume; and

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Acceptance criteria properly speciffed.

c.

_ Findings

With the exception of the one item below, the inspector found no

problems with the test procedure and had no further questions'in

this area.

The inspector noted that Procedure ST 12.5-1, Revision 2, contained

valve lineups to verify that the ' root valves forLinstrumentation

were in the proper position, but individual instrument isolation,

vent, and drain valves were not addressed in_the procedure. The

licensee representative was aware of'this fact and stated that the-

pre-startup surveillance RT 8.0, " Safety Instrumentation Valving

Check Off List" would be performed coincident with the CILRT valve

lineup to verify that all instruments are inLtheir proper normal

alignment and this would be documented in the Events Logs.

Review-

of this procedure along with general guidance for system valve

lineup requirements contained in the CILRT procedure' satisfied the

inspector's concern.

'4.

Containment Integrated Leakage Rate Test (CILRT)

a.

General

On' September 2-6, 1981, the Peach Bottom Atomic Power Station, Unit

3, performed a CILRT as required by 10 CCR 50, Appendix J and_ Technical Specification 4.7. A.

The test was performed in accordance with

Procedure ST 12.5-1, Revision 2, " Integrated Leak Rate Test". . The

inspector witnessed preparations for and various portions of the

test, verified qualifications of test personnel and independently

verified calculations of the test results. Details of the test are

discussed below.

b.

Instrumentation

The inspector reviewed the calibration records for the resista. ice

temperature detectors, dew point hygrometers, precision pressure

indicators, and.the verification test flowmeter. Their calibration

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prior to the CILRT met applicable accuracy requirements and were

traceable tu the National Bureau of Standards.

No noncompliances were identified.

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c.

Tours

The inspector conducted'several inspection. tours independently and

with licensee personnel both before and during the CILRT. 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 positions. These selected valves included test boundary

isolation ~ valves and vant-paths external to the test volume. -No;

valve misalignment were identified and no discrepancies were noted.

d.

Chronology

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Date

. Time

Description,

P/2

2000

Drywell internal inspection complete.

9/3

Complete valve lineup verifications.

0645

Drywell ' sumps pumped down.

1605

Commence pressurization of containment.

System inspections for external leakage conducted.

Various small liquid leaks discovered at valve

stem packing were quantified and documented as

required in Appendix L of. test procedure.

Significant air leakage discovered at flange on

one drywell pressure transmitter, PT-3-5-12C.

9/4

0400

Containment reached test pressure of 64.130

psia. Secured pressurization.

0415

Began initial dat- recording at 15 minute intervals.

0700

Noted unstable drywell temperature changes and

corresponding pressure drop.

0730

Repressurized due to reaching minimum test

pressure.

0745

Secured two drywell cooling fans.

0940

Added water via Shutdown Cooling Keep Full

System to raise reactor water level.

1030

Adjusted the Chilled Wa'.er Cooling System flow

and number of drywell cooling fans in service to

stabilize temperatures.

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Date

Time

Description

1430

Temperature stabilization' requirements satisfied.

Continued data! recording.

Continued leakage' surveys.

2200

Calculated leakage rate of approximately 0.391

percent per day recognized to exceed acceptance

criterion of 0.375.

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2305-

Isolated leaking PT-3-5-12C and conducted local

leakage' rate test with results:being approximately

.9 SCFM.

9/5

0200'

Decision made to declare the initial CILRT

attempt a failure and rerun-the test-with.

PT-3-5-12C isolated.

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0300

Drywell Equipment Drain Sump pumped down.

Continued data. recording and leakfrate calculations.

1345

Completed 8 hocr. leakage rate test with a calculated

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leakage rate at the upper;95% confidence limit

of-0.151 percent per. day.

1445

Commenced test data-verification' test with.

imposed leakage rate of .5 %/ day (4.41 SCFM).

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Completed'5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months test data. verification. test.

~2230

Commenced depressurization.

9/6

0830

Depressurization complettd and: system restoration

begun.

9/7

1000-

Completed post repair local leakage rate test of -

PT-3-5-12C with zero leakage.

No items of noncompliance were identified with the conduct of the

CILRT.

e.

CILRT Results

-(1) Initial Attempt

The initial attempt of the CILRT, from 1600 hours0.0185 days 0.444 hours 0.00265 weeks 6.088e-4 months on September

3 to 2200 hours0.0255 days 0.611 hours 0.00364 weeks 8.371e-4 months on September 4 revealed a significant air leak

at,a flange on one drywell pressure sensing . instrument (PT-3-5-12C).

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The licensee's evaluation of leakage rate including required

corrections for systems in service indicated the overall contain-

ment leak rate at the 95% confidence interval to be 0.391

percent per day which exceeded the test acceptance criterion of

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nitial attempt at this

0.375 percent per day. Therefore the i

1981 CILRT was considered to be a failed test.

(2) Successful Test

After isolating PT-3-5-12C, a successful eight hour leakage

rate test was run from 0545 hours0.00631 days 0.151 hours 9.011243e-4 weeks 2.073725e-4 months to 1345 hours0.0156 days 0.374 hours 0.00222 weeks 5.117725e-4 months on September 5,

1981. The calculated leakage rate including required corrections

for systems in service and changes in the test volume at the

95% confidence interval was 0.179 percent per day.

The inspector noted that the above leakage rate represented the

final total leakage rate because PT-3-5-12C which was isolated

during the test was local leak rate tested on September 8,

after being repaired, and found to have zero leakage.

The inspector observed data recording, transcription and calcula-

tions during the test.

In addition, the inspector independently

calculated several mass values and the leakage rate, using raw

data from the test to verify the accuracy of the licensee's

leakage rate calculations.

No items of noncompliance were identified in this area.

f.

Future Test Schedule

Paragraph III.A.6.(b) of 10 'r9 50, Appendix J, states that if two

consecutive periodic Type A tests (CILRT) f ail to meet the acceptance

criteria then tests shall be performed at each shutdown for refueling

or approximately every 18 months, whichever occurs first, until two

consecutive periodic tests meet the acceptance criteria

The inspector

noted that the initial attempt of the 1977 and 1981 periodic Type A

test at Peach Bottom Unit 3 failed ta meet the acceptance criteria

and that the licensee was therefore subject to the increased frequency

of tests as described above. The licensee acknowledged this fact

and stated that the 1981 CILRT Technical Summary Report to the NRC

would include an evaluation for the cause of test failure with

generic corrective action plans and a request for exemption from the

increased test frequency requirement.

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Leak Repairs and Special Testing Requirements

Paragraph IV.A of 10 CFR 50, Appendix-J, require's that any modification

or replacement of a component which is part of the primary containment

boundary be followed by a leakage test, as applicable for the area

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affe;ted.

Administrative Procedure A-26, Revision 23, " Procedure for Corrective

Maintenance," requires that a " Maintenance Request-Form" (MRF) be

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used to: (1) specify sufficient rsst repair testing to assure that

the equirment has been returned to a fully operable condition and

(2) document the performance of post repair testing and accentance

for operations.

Following the isolation of.PT-3-5-12C during the CILRT,-this instrument

was disassembled, repaired and leak tested at 50 psig as documented

on MRF 3-60-L-1-95.

During disassembly-the cause of leakage was'

determined to be an "0" ring seal missing from the process flange

(instrument sensing line connection).

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The inspector requested the previous maintenance and test records

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for PT-3-5-12C.

Review of MRF 3-94-L-1-51, dated July 30, 1981,

revealed that t.._ instrument was disassembled for repairs and was

recalibrated on August 19, 1981 in accordance with Procedure ST

2.6.02C-which was specified to be-the applicable post repair test

requirement.

The purpose of Procedure ST 2.6.02C, Revision 4, is stated to verify'

the operability and set point of PT/PIS 3-5-12C.

However, the..

inspector noted that the maximum pressure specified in the procedure

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is 138.7 inches of water (5 psig) which does not prove the functional

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capability of the instrument to act as a primary containment barrier

at the design basis accident pressure of 49.1 psig. The licensee

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acknowledged this discrepancy and identified that the problem is

applicable to nine other primary contlinment instruments calibrated

to normal operating pressure and not design basis accident pressure.

The Station Superintendent stated that the stan'trd practice for

post repair testing of'all instruments was to perform.the normal

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calibration check.

He also stated that due to an oversight, this

amount of . testing is not sufficient for certain primary containment

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instrumentation and final corrective actions would be generic.

The inspector stated that corrective actions taken for PT-3-5-12C

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were acceptable but questioned what assurance was the*e that adequate

post maintenance testing would be performed on primary containment

boundaries prior to implementation of final generic corrective

action. The Station Superintendent stated that the instrument

departmant: personnel would be advised of this requirement and a

review of primary containment instrument work would be conducted

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prior to the next reactor start y .

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Failure to perform a local leakage test' of PT-3-5-12C, which is part

of the primary reactor containment boundary, following maintenance

on August-19, 1981-constitutes an item of noncompliance with 10 CFR 50,. Appendix J and Procedure A-26.

(278/81-21-01)

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Outage Maintenance' Activities

a.

Documents Reviewed

The inspector selected three' major maintenance activities, being-

completed during the current refueling outage, for review.

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(1) Torus to Drywell Vacuum Breaker Modification.

(2) Main Steam Isolation Valve Maintenance.

(3) High Pressure Coolant Injection (HPCI) Turbine Maintenance.

The following procedures and associated Maintenance Request Forms

(MRFs) were reviewed:

Procedure MS-7.2, Revision 0, Torus /Drywell Vacuum Breaker -

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Hinge Arm No. 1 Fabrication.

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Procedure MS-7.3, RLvision C, Torus /Drywell Vacuum Breaker -

Hinge Arm No. 2 Fabrication.

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Procedure MS-7.4, Revision 0, Torus /Drywell Vacuum Breaker -

Hinge Pin Fabrication.

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Procedure M-7.10, Revision 0, Replacement of Torus /Drywell

Vacuum Breaker Hinge Arms, Hinge Pins, Hinge Pin Bushings,

Pallet seal and 24 inch "0" Ring.

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MRS , 3-37-M-1-15,16,17 and 18, Torus Drywell Vacuum Breakers,

Janetry 20, 1981.

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Procedure M-1.3, Revision 6, Main Steam Isolation Valve Maintenance.

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Procedure MS-1.4, Revision 2, Main Steam Isolation Valve -

Fabrication of "0"-Ring Retainer.

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Procedure M-1.5, Revision 6, Main Steam Isolation Valve Pneumatic

Control Manifold Ma'ntenance.

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Procedure M-1.28, Revision 0, MSIV Pneumatic Control Valve

Rework.

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-- :MRF.3-31-M-1-16,fMSIV A0 80A, completed July 17,'1981.

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MRF 3-31-M-1-17, MSIV A0 80B, comp.leted March. 19, 1981.

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.MRF 3-31-M-1-18, MSIV A0 80C, completed May 8, 1981.

MRF 3-31-M-1-19,.MSIV A0 80D, completed June'25, 1981.

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MRF 3-31-M-1-20, MSIV A0 86A, completed May" 12,~ 1981

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MRF 3-31-M-1-22, MSIV A0 86C, completed May 22, 1961.

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MRF:3-31-M-1-23, MSIV A0.86D, completed June 15, 1981.

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Procedure M-23.1, Revision 0, High Pressure Coolant Injection

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(HPCI) Pump Drive Turbine Maintenance.

-- - ' Procedure M-23.4, Revision 2, HPCI Lube Oil Flush.

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Procedure M-23.10, Revision 1, HPCI Woodward Governor Remate

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Servo Maintenance.

Procedure M-23-11, Revision 0, HPCI. Turbine Stop. Valve / Hydraulic

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Cylinder. Maintenance.

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Procedure M-23-13, Revision 1, HPCI' Pump Drive Turbine Casing

Disassembly and Reassembly.

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Procedure M-23-15, Revision 1, HPCI Overspeed Trip Device.

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MRF 3-23-M-1-18, January 26, 1981, Perform 5 year Inspection,

~ Perform 011 Flush, Install new Governor.

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MRF 3-23-M-1-20, January 26, 1981, Replace HPCI Rupture Disc.

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MRF 3-23-M-1-134, July 23, 1981, Repair _and Set Overspeed Trip

Device.

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b.

Scope

.

The inspector reviewed the above documents to ascertain that maintenance

activities were being conducted in accordance with approved procedures

' which met applicable regulatory guidance. . The following are key

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aspects of maintenance procedure requirements verified by the: inspection.

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Administrative controls established for. system / equipment prior;

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to and during maintenance activities.

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'QA inspection / audit requirements.identifled.

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'Special_ process'and personnel' qualification requirements identified.

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Equipment classification =and special material certification

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requirements identified.

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General Housekeeping.and system / component cleanliness requirements

identified.

--- Post maintenance test requirements specified.

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. Administrated approval for return of system / equipment to~ service.

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No items of noncompliance were identified during this review.

c.

Work Activity Witnessing

On September 1, 1981, the inspector observed maintenance technicians

performing work on the.HPCI turbine.

They were installing the

Woodward Governor and restoring the lube oil piping to normal following

the lube oil system-flush. The work was being performed.in accordance

with Procedure M-23.4 and the Turbine Instruction Manual.

The

inspector _ interviewed the technicians and foreman who were turbine

repair specialists and determined that they were knowledgeable of

procedural requirements and were suitably qualified for the_ work

being done.

No' items of noncompliance were identified and the inspector had no

further questions in this area.

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6.

Facility Tours

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The inspector made 'several tours of the f acility including the Reactor

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Building, Relay Room, and Control Room.

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During-these tours, the inspector observed operations and activities in

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progress, implementation of radiological controls, general condition of

safety related equipment, component tagging and system operations to

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support the CILRT.

No items of noncompliance were identified.

7.

Exit Interview

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The inspector met with licensee representatives (see detail 1 for attendees)'

at the conclusion of the inspection on September 8, 1981. The inspector

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summarized the scope and findings of'the ' nspe: tion at that time.

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Regarding the future CILRT schedule described in paragraph 4.f, the

Station Superintendent acknowledged the requirement for increased frequency

of tests.

Regarding the item

noncompliance in paragraph 4.g, the Stulon Superin-

tendent stated

.. che post maintenance calibrations had erroneously

been conside

,atisfactory for assurir.g containment leak-tight integrity

and that e

ective actions would be generic to all primary containment

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instrum- . tion.

In addition, he stated that prior to the next reactor

start

a review would be conducted to assure that all containment

ins'

...ientation work was adequately leak tested following maintenance.

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ML20032B639

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