ML20133A252
| ML20133A252 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/19/1985 |
| From: | Eselgroth P, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20133A147 | List: |
| References | |
| 50-277-85-23, 50-278-85-23, NUDOCS 8508050390 | |
| Download: ML20133A252 (9) | |
See also: IR 05000277/1985023
Text
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-277/85-23
Report Nos.
50-278/85-23
~
50-277
Docket No.
50-278
License No.
Priority
--
Category
C
Licensee: Philadelphia Electric Company
2301 Market Street
Philad'elphia, Pennsylvania
19101
fFacility'Name:
Peach Bottom Atomic Power Station, Units 2 and 3
{ Inspection At: Delta, Pennsylvania
/ Inspection Conducted: June 4, 9-13, 1985
/
[
78W
Inspectors:
r
.
D."Floreli, Lead R& actor Engineer
/ d/te
Approved by:
,[
7 98[
,
P. Eselgrjffh, Chief, Test Program
' dite
>
Inspection Summary: Inspection on June 4, 9-13, 1985 (Combined Inspection Report
Numbers 50-277/85-23, 50-278/85-23)
- ,;
+1
Areas Inspected:
Routine, unannounced inspection of the Unit 2 Containment
Integrated Leakage Rate Test (CILRT) including test procedures and records
review, test witnessing, local leak rate testing, independent calculations,
followup of the cause of the failed CILRT attempt and its affect on Unit 3,
' '
QA/QC interfaces and tours of the facility. The inspection involved 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br />
onsite and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in office by one region-based inspector.
Results: One violation was identified for not performing local leak rate
tests in accordance with 10 CFR 50 Appendix J.
(see Section 2.9)
y
C
.
1
'
8500000390 850729
ADOCK 05000277
O
mn_____ _._ .
_ _ _ - _ ___ _-_. .__
.
DETAILS
1.0 Persons Contacted
Philadelphia Electric Company
J. Campbell, Engineer, ILRT
- R. Fleischmann, Manager, Peach Bottom Atomic Power Station (PBAPS)
D. Helker, Engineer, ILRT
F. Massatelli, Modifications Coordinator
J. McElwain, Quality Control
J. Morrow, Engineer, Mechanical'
- D. Smith, Superintendent of Operation
A. Wasong, Performance Engineer
T. Wilson, QA Site Supervisor
General Physics Corporation
-
R. Carey, Engineer ILRT
E. Levinson, Engineer ILRT.
U.S. Nuclear Regulatory Commission
- T. Johnson, Senior Resident Inspector
J. Williams, Resident Inspector
The inspector also contacted other licensee personnel during the
inspection including members of the operation and technical staffs.
~ Denotes those present at exit meeting on June 13, 1985.
1
2.0 Containment Integrated Le_ak Rate Test (CILRT)
2.1 General
On June 8-12, 1985, the Peach Bottom Atomic Power Station performed a
CILRT as required by 10 CFR 50 Appendix J and Technical Specification 4.7.A.
The test was performed in accordance with ST-12.5 Revision 3,
The inspector reviewed the test procedure,
reviewed portions of the test preparation and witnessed various portions
of-the test. Other documents reviewed included. the CILRT test log,
calibration records for CILRT instrumentation, ILRT volume fraction
calculations, test data and results, local leak rate test (LLRT) results,
test related process and instrumentation, and valve detail drawings.
2.2 Valve Lineups
The inspector independently verified on a sampling basis the positioning
of valves identified in test procedure ST-12.5.
The valves reviewed were
all found to be in their correct position to perform the CILRT.
__ - _-___ __-_
_ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
c-
~m)
,
.
3
2.3 Instrumentation
The inspector reviewed the calibration records for the resistance
temperature. detectors (12 utilized), dew point hygrometers (6 utilized),
pressure detectors (one utilized plus a backup) and rotometer. The
inspector also reviewed the Instrumentation Selection Guide (ISG) calcu-
lation and verified the proper selection of instrumentation. The instru-
mentation was in calibration with the specified values and the number of
instruments utilized was in accordance with test requirements. No items
of noncompliance were noted.
2.4 Inspection Tours
The inspector conducted inspection tours independently and with licensee
personnel both before and during the CILRT.
The test data collection
system was found to be acceptable. During these tours, test boundaries,
primarily vent paths external to the test volume, were surveyed for evi-
dence of leakage and valve position.
Valves were observed to be in their
correct position. During these tours valve A0-2502B was observed to be
leaking along the valve stem. This is further discussed in section 2.9 of
this report.
2.5 CILRT Chronology
June 8, 1985
0612
Commenced pressurization of
containment
0840
29.6 psia reached, pressurization
stopped
0900
Primary containment exterior .
survey for leaks begun.
0945
Valve A0-2502B in the A and C
core spray triangle room
identified as a large leak.
1030
Pressurization resumed
June 9, 1985
0205
Reached 64.2 psia
0630
Data indicated three times
allowable leakage, temperature
stabilization achieved.
1015
Leak around A0-2502B quantified
to be at least 1.8 scfm (not all
leak-by flow could be diverted
into a rotameter).
Leak search
continues
]
.
.
4
1130
Five other small leaks identified.
1200
Throttled cooling water to
containment coolers to slowdown
temperature changes in primary
containment
1500
A0-2502B packing leak repaired
1730
CILRT failure declared due to
A0-25028 leakage. NRC notified.
1930
Five leaks quantified as < 550
scc / min
2130
Containment repressurized due to
pressure falling below test
-
pressure
2200
Test pressure achieved.
June 10, 1985
0200
CILRT restarted - during
stabilization period, data
indicates potential inleakage
into primary containment. Search
performed on obvious sources but
none identified.
0700
Valve SV-4951A packing leak
identified in leak search.
Quantified at less than 200
scc / min.
Leak was not isolated.
Licensee evaluation of data still
predicts inleakage, which is not
compatible with the plant
conditions.
0800
Leak searches intensify.
1045
Leak rate
.035 weight percent
per day (into containment)
1300
Corrections for reactor and torus
level indicate torus level is
increasing faster than reactor
level is decreasing.
1500
Leakage identified from
>
condensate system through the
core spray torus fill line into
,
the torus at approximately 1 gpm.
,
l.
.
7
,
.
5
1545
Leak isolated. CILRT resumed
2345
CILRT terminated with leakage
calculated as .02978 weight
percent per day at the 95%
upper confidence limit.
June 11, 1985
0100
Verification test begun with a
flow rate established at 4.4 scfm.
0600
Verification test completed with
-
a calculated value of .51989
weight percent per day with an
acceptance band of between .39319
.64319 weight percent per day.
1430
Depressurization begun
2030
Depressurization stopped to
perform bypass leakage area test
of vacuum breakers.
2330
Bypass leakage area test of
vacuum breakers begun.
June 12, 1985
0030
Bypass leakage area test of
vacuum breakers completed.
Calculated leakage area of
.1695ip2 with an allowable value
2
of less than .785 in ,
2.6 CILRT Test Results/NRC Independent Calculations
Licensee preliminary "as left" calculations for the primary containment
leakage uncorrected for reactor and torus water level indicated that the
leak rate was .0573 weight percent per day at the 95% upper confidence
level. The acceptance criteria is .375 weight percent per day. Prelimi-
nary as found primary containment leakage uncorrected for reactor and
torus water level indicated that the leak rate was .2437 weight percent
per day.
See section 2.8 regarding LLRT contribution.
This satisfied the
acceptance criterion. The "as found" results do not reflect the leakage
due to the packing leak in valve A0-25028 that occurred during the CILRT.
Valve A0-25028 was replaced during the recent outage with a valve manu-
factured by CLOW. The previous cycle utilized a Fischer valve and this
valve leakage was utilized for the "as found" calculations.
u.
'3
.
.
6
The inspector performed independent calculations of the test results
using a sample of the raw data to verify mass calculations.
During this
calculation the inspector noted that the computer program was utilizing
volume fractions for temperature sensors that totaled greater than one.
Volume fractions for temperature sensors TE-7 and 8 were input into the
computer as .0540 rather than .0522.
The inspector observed the
reassignment of the correct volume fractions into the program. Using the
test data, the inspector also independently calculated the test results
to determine if the leak rate calculations were appropriately performed.
,
The results were as follows:
Lam (Mass Point)
UCL (Mass point)
weight percent per day
weight percent per day
NRC
.01760
.03006
Licensee
.01769
.02978
The test results are within 5% of the inspector's estimates. The inspec-
tor concluded that the licensee's calculations were appropriately
performed.
2.7 Test Control
The inspector observed that the licensee conducted the test in accordance
with the ST-125
The inspector witnessed turnover operations between test
personnel and observed them to be comprehensive and fully acceptable. The
inspector also noted that the station resources were effectively utilized
to identify and isolate the source of inleakage from the condensate system
into the torus. The inspector also noted that test personnel were know-
ledgeable of the requirements in 10 CFR 50 Appendix J and were observed on
several occasions making sure no adjustments were made to containment once
the CILRT was initiated.
2.8 Local Leak Rate Testing (LLRT)
The inspector reviewed the preliminary LLRT results reflecting the dif-
ference in the "as left" and "as found" Type B & C testing (.0924 weight
percent per day) The licensee indicated that a few cases existed where
the Type C test was not performed immediately before maintenance was
,
performed.
In these cases the licensee provided justification for the
values used based either on the last LLRT performed and valve service was
subjected to since the last LLRT or taking the worst leakage determined
over the history of the containment isolation valve and its operating
service.
In the cases reviewed, the above licensee justifications for the
values used were found to be acceptable.
The inspector pointed out how-
ever, that reliance on this approach to justify "as found"/"as left"
differences is dependent upon the specific valve operating history and may
not always be acceptable.
For example, use of prior LLRT data on a valve
subjected to water hammer or excessive operation would not be acceptable.
_
7
.
.
7
The licensee recognized this and had taken steps to assure the LLRT
differences would be more precise for the upcoming Unit 3 CILRT scheduled
for later this summer.
2.9 Valve A0-2502B Excessive Leakage
The inspector reviewed the following documents to investigate in more
detail the excessive leakage around the stem of valve A0-2502B
Drawing P-77760-03H-18111-E, (Fischer Governor Co.), Revision D,
-
August 28, 1970
-
Drawing P-77760-02H-18112-E (Fischer Governor Co.), Revision D,
August 28, 1970
-
Drawing F-36636, (Fischer Governor Co.), Revision B, March 13, 1974
-
Drawing D-0720-C (CLOW), Revision C, May 4, 1983
-
ST-20.052 "LLRT-D/W Purge Supply," Revision 6 PORC approved
October 29, 1984
-
Safety evaluation for Mod 842C approved March 29, 1983
-
Engineering Work letter for Mod 842C, Revision 6 dated February 1,
1984
-
LLRT records for valve A0-2502B and A0-2520
P&ID-367 Primary Containment Vent and Purge
-
The inspector also contacted personnel at the PBAPS as well as at the
corporate office in Philadelphia, Pa. via the telephone. The inspector
also inspected actual valve orientation of the following Unit 2 and
Unit 3 containment isolation valves: A0-2502A, 25028, 2505, 2506, 2507,
2520, 2521A, 25218, 3502A, 3502B, 3506 and 3521B.
During the CILRT, valve A0-2502B had leakage around the valve stem
sufficient to fail the CILRT leakage acceptance criteria. The licensee
measured leakage of at least 1.8 scfm around the valve stem. Due to the
location of the valve and associated leak, not all of the leakage could be
measured. Valve A0-25028 for this CILRT was a new valve installed during
the recent outage.
The new valve was manufactured by CLOW and was in-
stalled because the old valve (Fischer) A0-2502B could not withstand the
hydrodynamic loads from a LOCA.
Valve A0-2502B is a normally closed valve
located between the reactor building to torus vacuum breaker and the
torus. The valve stem for A0-25028 (CLOW) is located on the torus side of
the valve.
In this orientation the valve stem is subjected to a leak rate
test during a CILRT and not during a LLRT.
LLRT pressurization occurs in
the space between the vacuum breaker and valve A0-25028.
Based on the
7
..
.
.
8
orientation of this CLOW valve the inspector inquired if the valve was
installed as designed.
The licensee evaluation concluded that the CLOW
valve was installed as designed. The inspector inquired if the Fischer
valve was also installed in this orientation. The licensee reviewed
photographs available at the corporate office and indicated via phone that
the orientation of the Fischer valve was the same, namely with the valve
stem located on the torus side, and as such was not subjected to a test
pressure when an LLRT was performed.
Based on the above, the inspector
along with a licensee representative reviewed the valve orientation on
several other Unit 2 and Unit'3 containment ventilation isolation valves
and noted that valves A0-2520, A0-3506, A0-3521B, and A0-3502B were also
oriented such that the valve stem packing was on the primary containment
side of the valve disc and as such is only tested during a CILRT. A CILRT
was performed on Unit 2 on July 28, 1980, and a CILRT performed on Unit 3
on August 23, 1983.
10 CFR 50 Appendix J in Section III.C.1 requires in part that " Type C test
,
pressure be applied in the same direction as that when the valve would be
required to perform its safety function unless it can be determined that
the results from tests for a pressure applied in a different direction
will provide equivalent or more conservative results."Section III.D.3
requires in part that " Type C tests shall be performed at intervals no
greater than 2 years." The inspector notes that satisfactorily completing
a CILRT satisfied the LLRT requirement on these valve packings. However,
two years after the successful CILRT, a LLRT which satisfies Appendix J
must be performed.
Prior LLRTs were performed on valve A0-2502B on July
25, 1980, May 19, 1982, July 14, 1982 and April 26, 1985 and on valve
A0-2520 on July 20, 1980, October 28, 1980, October 31, 1980, February 11,
1981, February 17, 1981, May 28, 1982, June 1, 1982 and June 8, 1982. The
licensee method for performing a LLRT on A0-2502-B and A0-2520 did not
test the packing on the primary containment side of the valve and, there-
fore does not satisfy the 10 CFR 50 Appendix J III.C.1 requirement. The
previous CILRT for Peach Bottom Unit 2 was performed on July 28, 1980.
The previous operating cycle for Peach Bottom Unit 2 ended on April 28,
1984. However, as of July 28, 1982 valves A0-25028 and A0-2520 were no
longer current with regard to the Type C testing requirements of 10 CFR 50
Appendix J III.C.1 in that the valve packing was not subjected to a test
pressure.
It should be noted that compliance with Technical Specification 4.7.A.g " Continuous Leak Rate Monitor" provided information that contain-
ment integrity was maintained in the period July 28, 1980 to April 28,
1984.
Failure to have conducted adequate local leak rate tests consti-
tutes a violation (277/85-23-01)
On Unit 3, three valves (AO-3506, 3521B and 35028) were found to be
-
oriented such that the valve stem is not subjected to LLRT test pressures.
The last CILRT was performed on August 23, 1983.
The requirements of
Appendix J for performing a LLRT on these valves at intervals no greater
than two years must be satisfied by August 23, 1985.
The end of the
operating cycle for Unit 3 is planned for July 1985 and a CILRT is planned
q
m
_
.
e
9
for this outage. Pending licensee action regarding the performance of a
LLRT on these valves, in accordance with Appendix J, this is considered an
unresolved item (278/85-23-01).
3.0 QA/QC Interfaces
The inspector witnessed QC individuals performing surveillance activities
of the in process CILRT and reviewed draft portions of their observations
at the conclusion of the CILRT. The inspector also observed QA personnel
performing an audit of the completed preliminary test package. No
unacceptable conditions were noted.
4.0 Plant Tours
During the inspection, the ' inspector observed an apparently inattentive
operator at the Unit 3 controls.
Special safety inspection 50-278/85-22
discusses this item further.
5.0 Unresolved Items
Unresolved items are matters about which more information is needed to
determine whether they are violations, deviations, or acceptable.
Unresolved items are discussed in paragraph 2.
6.
Exit Interview
An exit meeting was held on June 13, 1985 to discuss the inspection
findings as detailed in this report (see paragraph one for attendees).
At no time during the inspection did the inspector provide written
inspection findings to the licensee.
.
I