ML20206P728
| ML20206P728 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/15/1986 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8608270298 | |
| Download: ML20206P728 (3) | |
See also: IR 05000277/1985023
Text
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MUG 151%G
Docket Nos. 50-277
50-278
Philadelphia Electric Company
ATTN: Mr. S. L. Daltroff
Vice President
Electric Production
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject: Combined Inspection Nos. 50-277/85-23 and 50-278/85-23
This refers to your letter dated August 28, 1985, in response to our letter
dated July 29, 1985.
In your August 28, 1985 letter,-you requested that the NRC reconsider the
Peach Bottom Atomic Power Station, Unit 2, violation issued in our July 29,
1985 letter. Your reconsideration request is based on your position that the
local leak rate tests in question were conducted in accordance with the Unit 2
technical specifications; valve packing leakage need not be considered in Type
C testing; substantial modification would be required to the valve packing and
that specific exemptions from 10 CFR 50, Appendix J, have been requested and
'
are currently being evaluated by the NRC.
We have completed a detailed review of the information presented in your
August 28, 1985 letter. Our conclusion is that this information does not
supply any change to the regulatory action of nr July 29, 1985 letter.
The
basis for our conclusion is as follows:
This primary reactor containment provides an essentially leak tight
barrier against uncontrolled release of radioactivity to the environ-
ment. As prescribed in 10 CFR 50, Appendix J, Section III, a program
shall be developed for leak testing the primary reactor containment
and components penetrating the primary containment pressure boundary.
The valve stems of valves A0-2502B and A0-2520 are components that
penetrate the primary containment pressure boundary.
The regulations
also indicate that in no case shall the test interval exceed two years
for components, such as valve stems, penetrating the primary containment
pressure boundary. Valve stem test'ing of valves A0-2502B and-A0-2520 did
not meet regulatory requirements for a two year interval. Whereas the
regulation (10 CFR 50.12) permits exemptions from the regulations, your
exemption requests for Appendix J testing for the valves in question did
not address the technical issues identified in the violation.
Therefore,
since your testing of valves A0-25028 and A0-2520 was not in accordance
with 10 CFR 50.54 (o), it still appears that one of your activities was
not in full compliance with the regulations.
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OFFICIAL RECORD COPY
PE612 - 0001.0.0
07/03/86
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8608270298 860015
ADOCK 05000277
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Philadephia Electric Co.
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The attachment to this letter provides additional discussion from our review of
your August 28, 1985 letter. Your letter also identified an additional six
valves on Units 2 and 3 that have the same valve stem packing leakage pathway.
You are requested to include these six valves in your response to this letter as
described below.
We also note that your- August 28, 1985 letter satisfacto;ily resolved our con-
cern in the conflict with your technical specification and 10 CFR Appendix J
regarding actions to be performed if a containment integrated leak rate test
fails.
You are required to respond to this letter and submit your response to this
office within thirty days of the date of this letter.
In preparing your
response, you should follow the instructions in the July 29, 1985 Notice of
Violation.
Sincerely,
OriS nal SignedBY3
i
Stewart D. Ebneter, Director
Division of Reactor Safety
cc w/attchment:
R. S. Fleischmann, Manager, Peach Bottom Atomic Power Station
J. S. Kemper, Vice President, Engineering and Research
W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric
T. B. Conner, Jr. , Esquire
E. J. Bradley, Esquire, Assistant General Counsel
R. L. Hovis, Esquire
T. Magette, Power Plant Siting, Nuclear Evaluations
W. M. Alden, Engineer in Charge, Licensing Section
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
,
Commonwealth of Pennsylvania
i
Region I Docket Room (with concurrences)
DRP Section Chief
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RI:DRS
RI:DRS
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Bettenhausen
Ebneter
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0FFICIAL RECORD COPY
PE612 - 0002.0.0
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Philadephia Electric Co.
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ATTACHMENT 1
NON-CONSERVATIVE LOCAL LEAK RATE TESTING
The Peach Bottom Unit 2 FSAR states, in Section 7.3, that valves A0-2502B and
A0-2520 will be leak rate tested per 10 CFR 50, Appendix J.
The specific ori-
entation and design of valves A0-2502B and A0-2520 is such that the valve pack-
ing is located on the primary containment side of the valve.
The valves them-
selves are located outside'of primary containment in the reactor building.
Failure of the packing during an accident would result in an unisolable leak to
the reactor building. Appendix J requires the test pressure to be applied in
the same direction as that for the safety function to be performed unless it
can be determined that equivalent or conservative results can be obtained in
reverse pressure tests.
If the valve is tested in the accident direction, leak-
age of the valve seat and valve stem through the valve packing is determined.
In the reverse direction testing, the packing is not tested and therefore cannot
yield equivalent or conservative results.
Valve packing for valves A0-2502B and A0-2520 was only tested for contaf ment
integrity on July 28, 1980 and June 10, 1985, during the containment integrated
leak rate test. This interval exceeds the regulatory requirement of two years
for penetrations of the primary containment pressure boundary for either Type B
or C tests.
The Unit 2 technical specifications indicate reverse testing is performed on
valves A0-2502B and A0-2520.
Philadelphia Electric Co. (PECo) letters of
September 12, 1975 and April 19, 1984 discuss exemptions to Appendix J and de-
scribe reverse pressure testing as acceptable. However, the justification pro-
vided does not consider the valve stem packing pathway.
There was a previous occurrence at Peach Bottom, where local leak rate testing
in the reverse direction was not adequate to detect excessive leakage.
In com-
bined inspection report 50-277/83-24 and 50-278/83-24 failure of Peach Bottom
Unit 3 containment integrated leak rate test (CILRT) is described due to a pack-
ing leak on valve M0V-3-10-34A.
This valve was also installed such that per-
formance of a local leak rate test (LLRT) did not test the valve packing.
It
is our understanding that PECo's corrective action included installation of
testing provisions to test this valve packing in accordance with 10 CFR 50,
Appendix J and testing of this packing has been performed.
Conclusion
It was fortunate that in both cases, the reverse pressure LLRT testing was
closely followed by a containment integrated leak rate test which identified
the loss of containment integrity. Had not the CILRT been scheduled to be per-
formed, the plants could have operated until the next CILRT was performed with-
out having containment integrity maintained.
Testing performed at Peach Bottom on valves A0-25028 and A0-2520 did not test
the valve packing at the frequency specified in the regulations, due to non-con-
servative reverse pressure testing. Therefore, the licensee appears to still
be in violation of the regulations.
OFFICIAL RECORD COPY
PE612 - 0003.0.0
07/03/86