ML20135A968
| ML20135A968 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/28/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8509100334 | |
| Download: ML20135A968 (7) | |
Text
_
o
.i o
o PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 sHistos t. oALTnorr alc70"'.U'"Jio August 28, 1985 Docket No. 50-277 50-278 Inspection Report Nos. 50-277/85-23 50-278/85-23 Mr. Stewart D. Ebneter, Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Ebneter:
Your letter dated July 29, 1985 forwarded combined Inspection Report Nos. 50-277/85-23 and 50-278/85-23 for Peach Bottom Atomic Power Station.
Appendix A of your letter addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission Requirements.
This item is restated below followed by our response.
Restatement of Violation 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."
10 CFR 50 Appendix J Section III.D.3 and Technical Specification 4.7.A.2.f. require in part that, " Type C tests shall be performed at intervals no greater than two years."
' Contrary to the above, Type C testing performed on Torus Vacuum Relief Valve A0-2502B and Drywell air and nitrogen purge valve A0-2520 did not test the leakage boundary of the valve stem during reverse pressure testing performed on July 20, 1980, July 25, 1980, May 19, 1982, May 28, 1982, June 1, 1982, June 8, 1982, and July 14, 1982.
The valve stem is subjected to accident pressure and is required to perform a h.
DOC D
%>[ 6 I n Q\\.
E
- E
- o Mr. Stewart D. Ebneter August 28, 1985 Page 2
- sa fety function.
The reverse pressure testing performed did not test' the valve stem due to the specific valve orientation.
The containment integrated leak rate test was conducted satisfactorily on July 28, 1980.
Peach Bottom E
Unit 2 is considered to be in violation of this requirement i
only-for the period July; 28, 1982 to April 28, 1984, When
],
the Unit 2 refueling outage was begun, since the containment integrated leak' rate test satisfied the Type C testing requirement for the period July 28, 1980 to July 28, 1982.
This-is a Severity Level IV violation (Supplement I).
1 4
t-
Response
{
hDenial/ Evaluation of Alleged Violation inue Pea'ch' Bottom primary -containment 1.eakage rate testing
}
program is conducted in accordance wi2h Section 4.7.A.2 and i
Tables 3.7.2, 3.7.3, and 3.7.4 of_the plant Technical i
Specifications.
The stated basis for the proposed violation is non-compliance with an interpretation of 10 CFR 50, Appendix J, Section.III.C.l.
The Technical Specifications, l
as currently written, are not-intended to be in full compliance with Appendix J.
The Atomic Energy Commission recognized that many plants were in the final stages of construction at the time of issuance of Appendix.J and could
- not immediately comply _with the letter of that regulation without extensive modifications.
Accordingly, in August of 1975, 'the Commission requested Philadelphia Electric Company 3
(PECo) to provide a. submittal on the degree of. Peach Bottom Atomic Power' Station (PBAPS) compliance with Appendix J and to request any necessary exemptions in ~ accordance-with 10 :
1 CFR 50.12.; -In submittals dated September 1975 and August 1976,-PECo-submitted a revised-leakage rate testing program l
and requested appropriate exemptions.
This material has 3
1 beenf under: NRC staf f review -since ~ that time..Our latest I
submittal on this topic wasJmade;on April 19, 1984.
Each of the valves cited in the proposed violation has been tested in full compliance with the existing 'PBAPS Technical
];, _ '
Specifications and all proposed revisions.
Technical Specifihation Tables' 3.7.2 and 3.7.3 list those seals and bellows.-Which'are " Type B" local' leak rate tested as defined.in Appendix J, While ' Table 3.7.4 lists those isolation. valves which are " Type C" local. leak. rate tested.
2
. The subject, valves'.( AO-2502B and AO-2520 ) are -listed on the
'latter table with a. note indicating that they are tested in the reverse direction, which is conservative-for-the particular~ valve design.
More precisely; stated,-testing of AO-2502B in the reverse-direction isLconservative relative
~
p m
4 g,(
y-t7 y
w h
--g-+
-.g
- ymew
-we e9
-ep 9-am y w
-r--+= eye 7
r---r><
er
FI m
g Mr.1Stcwart-D. Ebneter:
August 28, 1985 Page 3 to valve seat leakage, and testing of AO-2520 in the reverse direction provides equivalent results relative to valve seat leakage.
The interpretation of the Appendix J Paragraph III.C.1
' discussion of reverse direction. testing preferred by the violation notice z implies that the valve -packing gland must
~be subject to' Type C test pressure in order to effect corpliance.
It;has always been recognized by PECo and previous-NRC reviewers that this discussion pertains only to valve seat leakage.
Arrangements for proper reverse direction' testing have on occasion required. that the packing glands of inboard containment isolation valves be exposed to
-containment pressure, and thus'. leak tested only as part of the Type A Integrated Leakage Rate Test.. ' The. ILRT measures the overall containment leakage rate,. which includes those penetrations and isolation valves subject to local leakage rate testing, as well as additional potential leakage paths such as - instrument lines, non-testable pipe flanges, and non-testable valve packings.
1 Rue valve packings for valves
=AO-2502B and AO-2520 fall into _the latter category.. This
. aspect of the PBAPS leak rate testing program has-been specifically discussed with the NRC staff. and found to be acceptable durin'g earlier reviews.
If ' additional testing of these~ packing glands were-required, alternate design provisions would have-been made'and the glands.would be included.on Technical Specification ~. Table 3.7.2.
The packing leakage on valve AO-2502B experienced during the last ILRT, performed during the 1985. Unit 2 outage, was on a new valve Which had been installed during.the same Unit 2 outage.
Thus, it had never zbeen' subjected to ILRT pressure in its installed-condition and could be expected to require c
l packing adjustment.
Detection of this type of leakage represents. the inherent basis for performing an ILRT.
following containment modifications,Las mandated by-Paragraph IV. A of Appendix J..
We, note that none of the previous ILRT L failures which have occurred at the -two-unit
' Peach Bottom plant have been-due,to-packing = leakage on any of the ' inboard purge and' vent valves Which have their packing glands exposed to the containment. atmosphere.
The PBAPSL LLRT program. is further discussed in Paragraph
'4.7. A.2. f ? of the Technical Specifications, which states:
2 " Local leak rate test's (LLRTs) : shall be : performed on the primary. containment. testable penetrations and '
isolation valves at a pressure of 49.1 psig... in no case at intervals greater than two years. "
F
'.m Mr. Stewart D. Ebneter August 28, 1985 Page 4
(
This statement pertains to only those penetrations and l
isolation valves Which are_ identified as being testable on l
Technical Specification Tables 3.7.2, 3.7.3, and 3.7.4.
To l
assert otherwise would imply that all areas where the PBAPS Technical Specifications do not explicitly conform with
[
current interpretations of Appendix J represented l
violations, even though justifications for specific j
exemptions have been timely provided.
i Based _ upon the fact that the local leak rate tests for l
valves AO-2502B and AO-2520 and the integrated leak rate l
tests were conducted in. full conformance with the plant Technical Specifications, that substantial backfit modifications would be required to allow local leakage rate testability of the packing glands on certain valves, and that justifications for specific exemptions from Appendix J i
requirements have been provided, Philadelphia Electric Company respectfully requests that the NRC reconsider the classification of this item as a violation.
Reason for Apparent Violation i
l The apparent violation occurred because of a failed i
Integrated Leakage Rate. Test due to excessive leakage around the packing gland of valve AO-2502B.
This valve was replaced 'during the Unit 2 outage with a model which would withstand higher identified' hydrodynamic loade.
Evidently the valve packing gland was not adjusted properly _ prior to performance of the ILRT.
Extent of Significance of Apparent Violation l
Philadelphia Electric Company-has conducted a review of all containment purge and vent valves and has determined that the following valves currently have-packing glands exposed l
to containment' atmosphere and tested only during the ILRT:
Unit 2 Unit 3 i
AO-2502B AO-3502B AO-2511 AO-3506 j.
AO-2520 AO-3511 AO-3520 AO-3521B i
l We note that an Integra,ted Leakage Rate Test on Unit 3 is currently scheduled for the present refueling outage.:
~
T
~~'
Mr.; Stewart D. Ebneter August 28, 1985 Page 5
_ Corrective Action Taken and Results Achieved The immediate corrective action taken was to adjust the packing gland of valve AO-2502B to allow successful passage of the containment ILRT..The ILRT was successully completed and. verified on June ll, 1985, with a preliminary leakage rate determined to be 0.01769 wt. %/ day with a 95% UCL of 0.0298xwt. %/ day.
This is well'within the Technical Specification acceptance criteria of 0.375 wt. %/ day.
' Corrective Action Taken to Avoid Recurrence
- Continuation of. the current program of periodic local and integrated leak rate tests will ensure containment integrity.
Performance of ~ the ILRT will ensure integrity of tdue stem. packing of the _ subject valves.
Following modifications or repairs that may impact containment integrity, the appropriate leak rate - tests -will be performed as in the past.
One additional NRC concern.is identified in the cover letter that' accompanied the subject ' Inspection Report.
This
- concern is restated below along with our response.
Concern "During the-course of this. inspection,.a' conflict was noted with your Technical Specifications andfl0 CFR 50 Appendix J.
Technical Specification 4.7'.A.2.e indicates that a failed containment integrated leakirate tes't-(ILRT) measured value may be reduced by local ' leak rate data', taken before and after repairs,- in' order to meet the acceptance criteria.
It further< states that the containment ILRT' need not be repeated if tthe above actions; satisfy ~ acceptance criteria.
10 CFR-50 Appendix J:does not allow these reductions to meet acceptance criteria and furthermore - requires. successfully
-conducting a: Type A containment ILRT.
It.is requested that you respond to the above conflict and submit-Technical.
Specification _ changes to resolve this' conflict."
- Response 1 A Peach. Bottom Technical SpecificationfAmendment Request was submitted"tosthe Office of Nuclear Reactor Regulation via letter,;E.;J. Bradley-.to H.-R..Denton,. dated April. 19, 1984.
Item 1 of this Amendment Request concerns performance of integratedEleak' rate-tests.- Our proposed revision to Technical Specification ' 4.7. A.2.e, as identified in-the
Mr. Stewart D. Ebnater August 28, 1985 Page 6 April 19, 1984 submittal, is written in accordance with 10 CFR 50 Appendix J requirements.
Approval of this Amendment Request will resolve the concern identified above.
Should you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, fo -$Ll
./\\
/
cc:
T. P. Johnson, Site Inspector i