ML20033B652
| ML20033B652 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/13/1981 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20033B644 | List: |
| References | |
| NUDOCS 8112010609 | |
| Download: ML20033B652 (4) | |
Text
f PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHI A. PA.19101 SHIELDS L DALTROFF ELECTRIC PR D CION November 13, 1981 Docket No. 50-278 Insp. No. 50-278/81-21 Mr. R.
R.
Keimig, Chief Projects Branch No. 2 Division of Resident and Project Inspection U.
S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Keimig:
Your letter of October 15, 1981, forwarded Inspection Report No. 50-278/81-21.
Appendix A addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.
This item is classified as a Severity Level IV Violation and is restated below with our response.
10CFR 50, Appendix J, Section IV.A, requires that any modification or replacement of a component which is part of the primary reactor containment boundary be followed by a leakage test as applicable for the area affected.
Administrative Procedure A-26, Procedure for Corrective Maintenance, requires that sufficient post repair tests be performed to assura that the equipment hes been returned to a fully operable condition.
8112010609 811119 PDR ADOCK 05000278 G
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o Mr.
R.
R.
Keimig, Chief Page 2 Contrary to the above, pressure transmitter PT-3 12C, which is a part of the primary reactor containment boundary, was disassembled for maintenance on August 19, 1981 and not leak tested to prove its containment leak-tight integrity function.
Leakage from this instrument subsequently contributed to the failure of the Containment Integrated Leak Rate Test to meet its acceptance criteria on September 4, 1981.
RESPONSE
The leaking drywell pressure transmitter was isolated and disassembled.
The leakage was caused by a missing o-ring.
The instrument was repaired and a documented leak test was performed at 49.1 psig.
Additionally, a review of maintenance requests initiated for instruments which communicate with primary containment indicated that no additional instruments were disassembled during the Unit 3 refuel outage and none bave been dismantled on Unit 2 since the last Integrated Leak Rate Test was conducted.
The surveillance tests for these instruments will be revised by April 30, 1982, to include a pressure test to verify acceptable leakage if maintenance is performed which has the potential to cause leakage.
Until these surveillance tests are revised, the station instrument and control group will specify the required pressure testing on the maintenance request forms.
Failure of the Integrated Leak Rate Test to meet its acceptance criteria on September 4, 1981, was directly attributable to pressure transmitter PT-3-5-12C.
This instrument had been disassembled for repairs during the refueling outage and was tested at 5 psig after repairs were completed.
We have 1
acknowledged that this instrument should be tested at design basis accident pressure and appropriate corrective actions have been taken as described above, however, it does not seem appropriate to perform Integrated Leak Rate Tests at the increased frequency specified in 10CFR 50, Appendix J, baced on the failure of this instrument.
All other aspects of the 'est were successful and final results were well within ace--
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a Mr.
R.
R.
Keimig, Chief Page 3 limits.
Based on this information, we plan to submit a formal request for exemption from the increased testing requirements of 10CFR 50, Appendix J.
If you have any questions, or require additional in formation, please don't hesitate to contact us.
Very truly yours,
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s COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S.
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Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing response to Inspection Report No. 50-278/81-21, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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