View source for 05000265/LER-1985-007, Responds to NRC Re Violations Noted in Insp Rept 50-265/85-18.Corrective Actions:Four Pressure Transmitters Will Be Returned to Original Configuration by 851031 & Work Request Sys Revised.Rev 1 to LER 85-007 Encl

{{Adams
| number = ML20134B701
| issue date = 08/02/1985
| title = Responds to NRC Re Violations Noted in Insp Rept 50-265/85-18.Corrective Actions:Four Pressure Transmitters Will Be Returned to Original Configuration by 851031 & Work Request Sys Revised.Rev 1 to LER 85-007 Encl
| author name = Delgeorge L
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = Keppler J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION III)
| docket = 05000265
| license number = 
| contact person = 
| document report number = 0448K, 448K, NUDOCS 8508160042
| title reference date = 07-05-1985
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}
{{LER
| Title = Responds to NRC Re Violations Noted in Insp Rept 50-265/85-18.Corrective Actions:Four Pressure Transmitters Will Be Returned to Original Configuration by 851031 & Work Request Sys Revised.Rev 1 to LER 85-007 Encl
| Plant = 
| Reporting criterion = 
| Power level = 
| Mode = 
| Docket = 05000265
| LER year = 2085
| LER number = 7
| LER revision = 
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

=text=
{{#Wiki_filter:l P~(
4               Commonwealth Edison One First N:tioncsl Pirza, Chicrgo. Illinotjs Address Reply to. Post Office Box 767 Checago. filinois 60690 August 2, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137                                                                          [
                                                                                                      \

==Subject:==
Quad Cities Station Unit 2 Response to Items of Noncompliance in I.E. Inspection Report No. 50-265/85018

==Reference:==
R. L. Spessard letter to Cordell Reed dated July 5, 1985.

==Dear Mr. Keppler:==

The reference provided results of a routine safety inspection                       g conducted by Messrs. D. S. Butler and S. M. Hare of your office during the                    \
period of May 25 through June 24, 1985 of activities at Quad Cities Nuclear Power Station Unit 2.
During the course of that inspection, certain activities appeared to be in noncompliance with tEC requirements. Attachment I to this letter contains our response to the Item of Noncompliance.
In addition, your letter requested a response to Unresolved Item No.
265/85018-04 regarding leaking containment isolation valves. Attachment 2 provides a copy of Revision 1 to Licensee Event Report 85-007 which contains the information requested in your letter.
Very truly yours,
                                                                     /
L. O. DelGeorge u
Assistant Vice President im cc: NRC Resident Inspector - Quad Cities Attachments 8508160042 850802                                          51985 PDR           ADOCK 05000265 G                               PDR                               ,
I 0448K                                                                             ,l
                                                                                        /N      t

9
    ,        5
     .?
                               ,-s
         .+,
* ATTACHENT 1                       '
RESPONSE TO NOTICE OF VIOLATION s
T g
4 i,
W            3     ,          .    . _ _ ,            - - - - - ----   - -

l
  ,     <                                                                                    l 1
COMMONWEALTH EDISON COMPANY                        l l
RESPONSE TO NOTICE OF VIOLATION As a result of an inspection conducted during May and June of 1985, the following violation was identified:
10 CFR 50, Appendix B, Criterion XVIII requires in part that sufficient recoros shall be maintained to furnish evloence of activities affecting quality and that they be identified and retrievable. 10 CFR 50, Appendix B, Criteria III requires in part that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and approved by the responsible organization.
Contrary to the above, six safety-related pressure transmitters were modified between April and May, 1979, without adequate documentation and approval. In addition, external calibration Jacks and a calibration test resistor were installeo without implementing required design controls.
DISCUSSION Test Jacks with one ohm precision resistors were installed at Quad-Cities in instruments in the late 1970's to facilitate normal calibration checks and recalibrations. Most instrument models at that time came from the manufacturer with resistors already installed for calioration purposes.
This allowed calibration without removing the instrument cover and breaking the internal current loop to install a test resistor in the internal wiring. Pressure transmitters, supplied by Rosemount Inc., were delivered with a diode installed in series with the current loop that could be used to measure the current in the loop with an ampere meter.
Testing equipment used by the Instrument Maintenance Department during the late 1970's did not include an ampere meter function. Since it was not possible to use the diode in the loop to measure the current, and since the installation of a resistor in a current loop in no way affects the design intent of a current loop, a precision resistor was installed in series in the current loop. This allowed the ability to measure the voltage drop across the resistor and the calculation of the current in the loop. The actual voltage drop around the entire loop in no way affects the function or cesign of the pressure transmitter. All failure modes of the resistor will have no affect on the safe operation of the pressure transmitter. A short across the resistor will not change the value of the current in the current loop. An open circuit failure of the resistor will cause a zero value for current and cause a trip of the pressure transmitter trip unit. The addition of the test jacks and resistor poses no problems with respect to overall reliability or safety. Twenty-two of these units have been in service for many years and none have ever failed or caused any problems associated with calibration. Table I lists all the applications where these resistors have been installed. Only four of the installations are used in safety-related applications.

The interpretation of the threshold of routine maintenance which constitutes a design change is always subject to change. During the late 1970's when these installations were performed, it was determined that this work did not constitute a design change. As the interpretation of the design change threshold has evolved over the years, the Station finds itself accountable for decisions maoe without post TMI hindsignr.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Since the date of the occurrence, the Commonwealth Edison Nuclear Work Request System has evolved to match the pace of changing interpretations.
Currently each work request is scrutinized to preclude the classification of design changes as routine maintenance. We therefore feel that changes in practice to resolve this concern have already been implemented. In order to assure continuing compliance, the following step will be taken:
: 1) The four safety-related classified pressure transmitters in which test facilities were added, will be returned to their original configuration by the removal of the test jacks and precision resistors. This will be accomplished by October 31, 1985.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE As described above, enhancements in the Work Request System implemented since 1979 are sufficient to prevent further noncompliances.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED As stated previously, full compliance will be achieved by October 31, 1985 when the four safety-related classified pressure transmitters will be returned to their original configuration.
0448K

         ^&
TABLE I
                             . Instrument' Test Jack List
           ~EPN           SYSTEM                  USE          CLASSIFICATION 2-261-5 A/B   Recirc          Pump DP              Non-safety Related 1-1602-8 8    Press Sup       Torus Level          Non-safety Related 1-1602-9 B    Press Sup        Torus Press         Non-safety Related s
           '2-1602-8 B    Press Sup       Torus Level          Non-safety Related 1-5441-31 AA  Off Gas         Condenser Level    . Non-safety Related 1-8941-418    HRSS            Waste Tank Level     Non-safety Related 1-8941-419    HRSS            Waste Tank Level     Non-safety Related 2-8941-418    HRSS            Waste Tank Level     Non-safety Related 2-8941-419'   HRSS            Waste Tank Level     Non-safety Related 1-645 D       Feed Water      Steam Flow           Non-safety Related 1-646 B       Feed Water      Rx Level             Non-safety Related 2-645 A/D     Feed Water      Steam Flow           Non-safety Related 2-2541-11 A/B ACAD            D.W. Press           Safety Related 2-2541-12 A/B ACAD            D.W. Press           Safety Related 2-2541-8 A/B  ACAD            Dllution Alr Press   Non-safety Related
=
45rven

cf--
e g
ATTACHENT 2 RESPONSE TO UNRESOLVED ITEM 265/85018-04(DRS) l- --   m

Commonwealth Edison ound Cition Nuclear Power Station 22710 206 Avenue North Cordova, ll!!nois 61242 Telephone 309/654-2241 NJK-85-193 July 15, 1985 U.S. Nuclear Regulatory Commission Document Control Desk Hashington, D.C. 20555

==Reference:==
Quad Cities Nuclear Power Station Docket Number 50-265, DPR-30, Unit Two Enclosed please find Licensee Event Report (LER) 85-007, Revision 01, for Quad Cities Nuclear Power Station.
This report is submitted to you in accordance with the requirements of the Code of Federal Regulations, Title 10, Part 50.73 (a)(2)(ll), which requires reporting of any event or condition that resulted in the condition of the nuclear power plant, including its principle safety barrier, being seriously degraded.
The original Licensee Event Report (LER) 85-007 stated that the Local Leak ,
Rate Testing (LLRT) program had found leakage in excess of Technical           l Specification limits, but did not provide a complete summary pending completion of the testing program and corrective actions. This report addresses all valves and penetrations that had repairs performed to reduce the leakage total to within the Technical Specification limit.
Respectfully,                                                                  l l
COMMONNEALTH EDISON COMP Y Quad Cities Nuclear P e Station N. J. Kallvianakis I
Station Manager NJK/eem/e                                       ,
Encl.
cc:     J. Hojnarowski                                 # j'~/ * ] ; % M A. Madison INPO Records Center                                     c)//y.
NRC Region III 0257H/0136Z

4 ,
EVENT DESCRIPTION During the Unit Two end of cycle seven refueling outage, the following valves required repairs or adjustments (RA's).               Note that some of the RA's were not due to excessive leakage, but were the result of preventative maintenance or modifications.       The valve leakage before and after the RA's and an explanation of the work performed is provided in Table 1.                         For valves where the RA's were initiated due to local leak rate test (LLRT) results, notes are shown in the comment section with details provided in the corrective action section of this report.
I
_1_
0257H/0136Z

LEAKAGE (SCFH)                                        .
;       DESCRIPi10N            VALVE NO.           COMPONENT DESCRIP..ON   AS FOU W   AS LEFT                  CORAENTS t                                                                                                                                        e 1  Main Steam Line Drain M0 2-220-1                Crane 3" Gate Valve       75.50     6.42(c)        Note 1, Table 2 as Left     ,
Leakage (7830)                                              is Total for 220-1,2 Main Steam Line Drain M0 2-220-2                Limitorque Type She       40.20                    Note 2, Table 2 "A" Reactor Feedwater CV 220-58A                Crane Tilting Disc CV   1921.66    16.00           Note 3, Table 2 "B" Reactor Feedwater CV 220-62B                Same as Above            789.50     5.42           Note 4, Table 2
 ; "A" Drywell Spray        M0 2-1001-23A                                     0.63(c) 0.84(c)         New EQ Limitorque
 ;                          and 26A                                                                   Operators installed
(
l  "A" RHR Return           M0 2-1001-29A                                     4.50     9.00           New EQ Limitorque Operators Installed i
!  "B" Drywell Spray        M0 2-1001-23B                                    15.12(c) 15.67(c)        l'ew EQ Limitorque l
and 268                                                                   Operators installed 1
i "B" RHR Return           MD 2-1001-29B                                     4.14     4.14           New EO Limitorque Operators Installed
. RCIC Steam Supply       MO 2-1301-16,17                                    4.10(c) 2.00(c)         New EQ Limitorque l
Operators Installed
!  Dry =oll/ Torus Purge    A0 1601-23             Pratt 18" Butterfly      342.00(c) 0.00(c)         Note 5, A0-1601-23, j  Exhiust                                         (D 1200G)                                          24,60,61,62,63 valves Test as one Volume i  Drywell/ Torus Purge    A0 1601-24              Same as Above                                      Note 5, Table 2 Exh:ust i  Dry ell / Purge         A0 1601-60              Same as Above                                      Note 5, Table 2 j  Exhrust                                         (D 1200G)
!  Dry =oll/ Purge         A0 1601-63              Pratt 6" Butterfly                                 Note 5 j  Exhaust                                         (D 1200G) t J
0258H

TABLE 1 (Cor*inu'ed)                                            LEAKAGE (SCFH)
DESCRif    JN       VALVE NO. COW 0hENT DESCRIP-   N_
AS FOUW      AS LEFT          CO M NTS          .'
  "B" Terus Vent       A0 1601-20B    Prctt 20" Buttcrfly        13.99(c)   13.99(c) Noto 6, Tabla 2               .
CV 1601-31B                                                                            ,
HPCI Steam Exhaust   CV 2301-45     24" Mission Duo Check      33.80       0.00    Note 7, Table 2 HPCI Drain Pot Exh. CV 2301-34     2" Kerotest Lift Check     14.20      12.50    Note 8, Table 2 0xygen Analyzer      A0 8801C       Blaw Knox 3/4" Globe       36.50      13.00    Note 9, Table 2 Valve Oxygen Analyzer      A0 8802C       Same As Above               9.70       6.50    Note 10, Table 2 0xygen Analyzer      A0 8804        Same as Above               6.50       3.50    Note 11, Table 2 TIP Ball Valve       737-1          General Pneumatics Corp     0.25       0.80    Retested after 608 KWJ06-3                                    Preventative Maintenance TIP Ball Valve       737-2          Same as Above               0.40       0.80    Retested After Preventative Maintenance TIP Ball Valve       737-3          Same as Above               0.10       1.30    Retested After Preventative Maintenance TIP Ball Valve       737-4          Same as Above               0.00       0.30    Retested After Preventative Maintenance TIP Ball Valve       737-5          Same as Above               1.70       0.50    Note 12, Table 2 ACAD System          A0 2599-2A     1" A0 Gate Valve            7.80       2.30    Note 13, Table 2 WKM Valve Div., ACF Ind.
ACAD System          A0 2599-4B     Same as Above               6.50       0.90    Note 14, Table 2 CAM System           SO 2499-1A     Target Rock 1/2-SMS-S       0.00       0.00    EO Valve Modification j CAM System           SO 2490-2A     Same as Above               0.00       0.00    EO Valve Modification CAM System           SO 2499-18     Same as Above               0.00       0.00    EO Valve Modification CAM System           SO 2499-28     Same as Above               0.00       0.00    EQ Valve Modification Core Spray           X-16B          Metal Bellows               0.00       0.00    Outer Test Bellows Added i
P;natration                                                                        (Inner Bellows Replaced Last Outage) 0258H                                                                                .

i CAUSE The first step to a good corrective action or maintenance program is to determine why the valve in question leaked. The answer to that question is not always obvious when dealing with valves that are sometimes quite large or when the air leakages are small but require repair due to regulatory limitations. At Quad Cities, we believe that we have a good program for diagnosing valve problems and facilitating repairs through the use of Station Procedure QhP 800-18 and the checklist QMP 800-S15.      When any safety related and/or primary containment isolation valve is disassembled, a Quality Control inspector performs a thorough inspection of the valve in order to determine the root cause of the valve leakage (or any other problems mandating the repair). An additional inspection is performed during re-assembly of the valve. A copy of the procedure and checklist is included in Appendix A. He believe that this method of diagnostics and control on these types of repairs meet or exceed any prevailing standard within the industry.
In addition, Quad Cities maintains on file the LLRT results for every primary containment isolation valve and penetration dating back to plant startup and trends those results. The station's willingness to repair valves or penetrations that exhibit low, but equipment specific high or increasing leakages over past LLRT results, demonstrates a sincere effort to meet the requirements of 10 CFR 50, Appendix J.
Because of the stringent testing requirements of the above regulation and problems encountered industry-wide in meeting those requirements, the corrective action portion of this report has been prepared to identify
          " chronic" problems experienced at Quad-Cities. Actions taken in the past and future plans are discussed.
The specific action taken this refuel outage on all valves with RA's due to LLRT leakage is given below in Table 2.      The note numbers can be referenced back to Table I to identify the valves.
0257H/0136Z

Notn No.                                                                  Div.JSSION                                             -
1        Work Request No. 041003. Repairs to this valve included cleaning the internals of rust-like dirt and lap-              ~
ping the seat.
Leakage History:
07/26/71                  0.00 SCFH(c) 01/18/75                  0.00 (c) 10/17/75                 1.70 (c) 09/11/76                  5.42 (c) 01/15/78                  6.55 (c) 11/26/79                 1.72 01/23/80                  8.45 (c) 09/07/81                 66.30 12/23/81                8.63 (c) 09/05/83                 39.27 (c) 01/12/84                07.46 (c) 03/17/85                 75.50 05/21/85                  6.42 (c)
Note:                              (c) = combined leakage of both 220-1 valve and the 220-2 valve.

== Conclusion:==
While this valve performed well for the first 10 years of plant operation, chronic problems with valve leakage have been experienced recently. Reference the corrective action section of this report.
2        Work Requests No. 039984 and 041911. During operation, this valve had a small steam leak from the bonnet seal ring that only leaked when the MD 2-220-1 was open. After the as found LLRT, this valve was disassembled, inspected, and cleaned with no observed defects that would explain the through leakage.
Subsequent LLRT showed little improvement in leakage. Subsequent investigation determined that Limitorque operator was not closing the valve completely and that torque switch setting could be increased. This corrective action eliminated most of the valve leakage.

== Conclusion:==
Valve inspection and corrective action required do not indicate that this valve has a chronic problem requiring further corrective action at this time.
0258H

l Noto No.                                                       DISCUSSION
* 3      Work Request No. 041492. No problems were found with seat or seals. Valve was disassembled and put back        .
together with new o-rings on disc / seat assembly and seal ring. One of the hold down clamp set screws had 4
a cracked tack weld but no probable affect on valve leakage.
Leakage History:
l                                   07/13/71               4.60 SCFH 12/30/74              97.00
!                                   02/08/75               8.80 l                                   10/12/76               1.70 10/19/76               0.00 02/03/78               1.56
;                                   12/26/79                Could Not Pressurize
,                                   01/16/80               7.80 j                                   09/21/81               1.03 j                                   10/05/83             267.30 1                                   01/09/84               0.52
!                                   04/10/85            1921.66 2                                   05/04/85              16.00 l            

== Conclusion:==
The feedwater check valves are large, 18" check valves on the feedwater lincs and
!                                   have an erratic test history. The main reason for this is that the valve does not seat when tested with 48 PSIG of air. All feedwater check valves are considered a chronic problem. Reference the corrective action section of this report.
0258H

             . . . ..ued )
Notq No.                                                    Dis,,sSS10N                                            -
4   Work Request No. 041492. This valve was found to have a hinge pin missing even though the set screw, lock  '
nut, and tack weld to hold the hinge pin were still in place. Future valve repairs will include modifications to better secure the hinge pins. This is the first failure of this kind at Quad Cities.
Subsequent repairs to the valve to make it leak tight included machining a slight valley out of the valve body where the seat ring is clamped down.
Leakage History:
08/21/71               7.50 SCFH 12/30/74            2647.00 02/18/75               1.36 09/14/76             811.00 10/11/76               6.78 01/17/78                 Unable to Pressurize
 ;                                03/02/78              16.50 11/27/79             406.80 01/28/80              14.90 09/17/81            1018.00 l                                11/13/81              13.60
 !                                09/14/83             362.00                                                                '
1                                 12/30/83              23.50
.                                 03/22/85             789.50 05/31/85               5.42 i

== Conclusions:==
Same as for CV 220-58A i
i i
0258H

~ lflilflTIMETUT555]D                                                                                                          ,
Noto No.                                                         u.oCUSSION                                            -
                                                                                                                                  ~
5     Work Request No. 041926 Replaced A0 1601-23
* Work Request No. 042341 Replaced A0 1601-24 Work Request No. 041927 Replaced A0 1601-60 Work Request No. 042345 Replaced A0 1601-63 Leakage History:     Volume Boundary - A0 1601-23, 24, 60, 61, 62, 63 08/24/71                 3.20 SCFH 08/22/72                 0.70 04/16/73               11.25 10/18/73                 4.55 10/03/76                 0.00 02/25/78               12.52 12/05/79               27.00 02/12/80               18.00 10/18/81               17.99 09/30/83                 9.00 04/29/85              342.00 05/24/85                0.00

== Conclusions:==
The above valves all have vulcanized rubber seats and are Pratt butterfly valves.
Inspections on disassembly revealed that all of the valves were dirty and the seats were hard and non-resilient. These valves were original equipment from when the plant was built (1971).
The 23-valve was disassembled and cleaned in February, 1980. The 24-valve was disassembled and cleaned in April, 1981. This is the only maintenance performed on the internal seating surfaces of these valves since plant startup. While the valves 9 ave little warning of impending failure (excessive leakage), the inspections showed that the seating surfaces were at the end of their useful life. The valves were replaced with new valves and the old ones will be decontaminated and sent out for-seat replacement (re-vulcanizing).
The leak rate history shows that these valves do not constitute a chronic problem.
The fact that so many valves (4) failed simultaneously is, however, reason for concern. Reference the corrective action section of this report.
0258H

TAtsLE 2 (Continued)                                                                                                               .
Noto No.                                                              o  AUSSION 6       Work Request No. 41665. CV 1601-318 was disassembled and cleaned. Was found to be dirty. A0 1601-208                 ~
had packing on shaft replaced.
Leakage History:
08/19/71               0.08 SCFH 04/16/73               1.91 10/17/73               0.00 01/28/75               0.00 09/12/76               2.29 01/18/78            110.74 02/15/78               0.73 12/03/79               0.76 09/23/81              19.90 09/30/81              10.70 09/12/83             07.10 03/23/85              13.99 05/30/85              13 99

== Conclusions:==
Repairs performed did not reduce leakage from the volume. Probable source of leakage is through A0 1601-208. This is a rubber seated Pratt butterfly valve. While no chronic problem has been experienced with this valve, reference the corrective action section of this report.
0258H

                                    .                                       -        _.        _~            -   . - _ .
          ' TABLE 2 (Continued)
Nota No.                                                                 b.dCUSSION 7        Work Request No. 042118 and Modification M-4-2-85-27.                                                                .
This valve is a TRW Mission Duo Chek on the HPCI turbine exhaust. The inspection on this valve showed damage to tho rubber seat and a bent stop pin. The valve was new in October, 1981. The valve was replaced this outage with a nearly identical valve.
Leakage History:
i 07/21/71                  2.20 SCFH 01/30/75                  0.40 09/13/76                 57.23 10/13/76                0.00 01/16/78                  1.56 i                                                    11/26/79              16.90
!                                                 09/08/81                165.00 10/06/81               12.04 09/05/83                  0.00 03/18/85                 33.80 05/23/85                  0.00 I                     

== Conclusions:==
The life expectancy of this valve appears to be approximately 3 cycles. Because of the severe damage found during valve inspections and problems encountered in the industry with these valves used for this application, this is considered a chronic problem. Reference the corrective action section of this report.
i 1
i                                                                              1 l
0258H
{

                             ~'                                                        ^'          ~                  - -- "
TABLE'2 (Continued)
Noto No.                                             DISCUSS 16.
* 8      Work Request No. 041548. Modification M-4-2-85-19.                                                             ,
While this valve has not had a bad LLRT performance, maintenance records showed that the valve did not have much stelIite left on its seat from previous seat lapping repairs. Since the valve leakage did increase over previous values, the decision was made to replace the valve.               ,
Leakage History:
12/31/70               0.19 SCFH
!                                     04/15/74               0.41 01/04/76               0.26 03/22/77               0.00 01/19/79                1.90 08/31/80               4.50 09/09/82               0.00 03/08/84               0.00 03/18/85              14.20 06/02/85              12.50

== Conclusions:==
The leakage history of this valve does not indicate a chronic problem with leakage.
The new valve, a Kerotest lift check valve, exhibited some leakage when installed.
The performance of this new valve will be carefully trended.
l 0258H

TABLE 2 (C<   inued)                                                                                                                                ,
Note No.                                                          DISCUSS 10N                                                                           ,-
9        Work Requests No. 041308 and 042167.
The valve was originally found to have very dirty (rusty) internals with a piece of paper or gasket-material across the seat. Cleaning the valve and seat surfaces reduced the leakage from 36.5 to 17.0 SCFH. The valve was disassembled again and the seat surface lapped reducing the leakage to its final value.
l               Leakage History:
i 01/02/75                  1.49 SCFH (c) 09/16/76                  1.20 01/18/78                10.50 12/06/79                11.00 09/29/81                 4.40 10/03/83                 6.00 03/29/85                36.50 05/21/85                11.00

== Conclusions:==
These oxygen analyzer valves do not represent a serious source of containment leakage because the lines go to a sample rack and are manually isolated at this point.                                  In fact, recent changes to the containment monitoring systems (CAM and HRSS) have made the lines with A0 8801-1, 2A and A0 8801-1, 28 and A0 8801-1,20, obsolete and no longer used. A modification will be started to remove these valves and cap the lines.
i 0258H

                                ~                      '                   ~           ~                                             '
TABLE 2 (' Continued) ~                                                                                                                                     .
Note No.                                                       L. A SSION Work Request No. 041309 10                                                                                                                                                 ,
This valve was found to have dirty internals with a rust-like build up. It was cleaned and re-assembled.
1 Leakage History:
01/02/75               1.49 SCFH (c) 09/16/76              13.00 01/18/78             >30 (limit of fIowmeter)
;                                   02/09/78               0.05 12/06/79               0.60 09/29/81               0.40
!                                   10/03/83              16.00 11/29/83               1.40 03/29/85               9.70 05/03/85               6.50

== Conclusions:==
Same as for Note 9 above.
l 11       Work Requests No. 041307 and 042167.
i On the first Work Request, the valve was cleaned of dirty, rust-like material. Subsequent to reassembly, the leakage rate increased slightly. On re-inspection, small scratches on the valve seat were observed.
The seat was lapped and the leakage was reduced to its final value.
;              Leakage History:
01/28/75               3.87 SCFH
!                                   09/27/76               4.00 01/30/78               3.90 12/06/79               2.90 10/01/81               9.50 10/14/83              10.00 03/29/85               6.50 j                                   05/22/85               3.50

== Conclusions:==
This valve does not have a chronic problem. No further action is required.
i i
j                                                           :
l
] 0258H

TABLE 2 (Continued)
Nota No.                                                       L.oCUSSION 12     After preventative maintenance, consisting of cleaning valve internals and replacing / lubricating valve     .
seals and 0-rings, the leakage of this valve increased from 1.70 to 4.00 SCFH. Since this is an unusually large leakage for these valves, it was replaced with a new valve.
Leakage History:
01/26/78               0.80 SCFH 12/05/79               0.10 09/25/81               0.00 02/02/83               0.00 i
11/07/83               4.50 03/21/85               1.70 i                                   06/02/85               0.50

== Conclusions:==
No chronic problems, no further action required.
l     13     Work Request No. 041662 On disassembly, the bonnet to body gasket was discovered to be improperly installed allowing some slight leakage. Valves had not been worked on since their original installation in 1980.
Leakage History:
02/29/80               0.00 SCFH (c) 09/28/81               0.20 (c) 10/07/83               5.00 04/01/85               7.80 05/03/85               2.30 l

== Conclusions:==
This is not a chronic problem and no further action is required.
l 1
14     Work Request No. 041663 1
Rust and dirt was cleaned from the internals of this valve. In addition, the body-to-bonnet gasket was found to be improperly installed (same as 13 above)
I
 )
l                                                               4 1 0258H I

Notn No.                                                                        L. M ION                                             .~
4 Leakage History:
02/29/80                 0.00 SCFH (c) 09/28/81                  Unable to Pressurize 12/18/81                9.50 09/23/83                 6.50 04/02/85                 6.50 05/03/85                  0.90

== Conclusions:==
The leakage from this valve had been nearly constant since 1981. Valve would appear to be tight now. No further action would seem required at this time.
0258H

     ' CORRECTIVE ACTION The immediate action taken for many of the RA's is sufficient corrective action because the leakages involved were small and no pattern of chronic failure exists. The items of special concern, however, are valves that have a history of excessive leakage and/or large leakage rates. These problems are identified as follows:
: 1)  Main steam line drain valve 220-1;
: 2) All feedwater check valves 220-58A, B; 220-62A,8;
: 3)  Drywell purge butterfly valves 1601-23, 24, 60, 61, 62, 63;
: 4)   HPCI Steam exhaust 2301-45.
The above problems will be discussed in detail here concerning future corrective actions required to prevent further re-occurrences.
MAIN STEAM LINE DRAIN VALVE (220-1)
As noted from the leakage history of this valve, the valve performed reasonably well for the first 10 years of plant operation. Since 1981, however, this valve has caused problems requiring repair each refuel outage.
During the 1983 refuel outage, fairly extensive repairs were performed by replacing the valve disc and disc guide, as well as lapping the seat. The following additional actions are warranted at this time:
: 1)   Replace the valve during the next refuel outage;
: 2)   Investigate a better valve for this application (e.g. a globe type valve instead of a gate valve);
: 3)   Investigate the possibility of relocating this valve in the drywell (under the steam lines) to a location that would make future repairs easier to perform and possible result in less dirt or rust being deposited on valve internals.
ALL FEEDWATER CHECK VALVES (220-58A, B: 220-62A, 8)
The failure of these valves to give good LLRT results is well documented at Quad Cities and at other stations throughout the industry. While modifications have been performed to reduce the potential of valve leakaga (e.g. modifications to the disc / seat assembly seals and hold down clamps),
the primary problem continues to be that these valves are intended to isolate a high pressure water line and we are testing them with low pressure air. The test method does not include a way to firmly seat the disc prior to testing.
The testing does not simulate either normal operating or accident conditions that would act to seat these valves, and normally the feedwater lines would not act as a leakage path because they are water filled.
0257H/0136Z

    . . While other stations, with NRC approval, have attempted to use water and/or water / air oixtures to seat the valves prior to testing with air, Quad Cities has not found this technique to be effective. The quantity of water that can be introduced into an 18-inch line through a 1-inch test tap does not seem to affect closure of the valve, and at times can be counter-productive by washing rust and dirt into the seat.      The water velocity that can be developed seems inadequate to either move the disc or keep the surface free of crud.
While the station continues in its efforts to develop a better maintenance program and test procedure for this valve, we believe that the problem is to a great extent generic with these particular valves. Unfortunately, recent industry experience with a newly designed dual seat valve offered by Anchor Darling Corp. has not been totally successful as documented in NRC IE Bulletins.
The station has initiated an Action Item Request (AIR NO. 85-12) to Station Nuclear Engineering Department (SNED) to investigate this problem and determine a solution.
DRYWELL PURGE BUTTERFLY VALVES As stated in the previous section, the vai.'es that developed excessive leakage have a history of good performance.      The concern of the station, however, is that these valves, because of their soft rubber seats, might be reaching the end of their useful life in terms of the vulcanized seat material. There are a number of other containment valves with this same valve manufacturer and design. The additional valves are listed below and they will be disassembled during the next refuel outage for seat inspection, maintenance, and/or replacement:
A0 1601-20A A0 1601-20B A0 1601-21 A0 1601-22 A0 1601-56 A similar inspection maintenance / replacement program will be established on Unit One.
HPCI STEAM EXHAUST VALVE There is an existing AIR to SNED to investigate a replacement for this valve. The station does not feel that the Mission Duo Check valve, while it does give adequate service for more than one cycle, is the best choice for this application. Further engineering will be performed to determine if a more suitable valve is available, or if modifications to the existing valves will make them more reliable.
0257H/0136Z

S e
    #  6 G
APPENDIX A 0257H/0136Z

l
;     -.                                                                              QMF 800-18 Revision 3                         l July 1984 1                                            USPECTION OF SAFETY.M LATEN VALVES i                                                 DURDG DISAS N Y, REPAIR, AND RI-AMNRLY OF VALVIS ID/10
!               A. PURP0gE                                    .
1 j                   The purpose of this procedure is t.o outline the requirements for. the i
inspection of safety-related valves, including primary containment isolation valves, during disassembly, repair, and re-assembly for" maintenance. This procedure also is intended to verify that foreign materials are not introduced into the valve which may affect future valve performance or testing, j               s. RarzassCas
: 1. ANSI 18.7 (1972 Edition).                    FOR REERENCE ONLY C. PasmsgarsITas
: 1. lihan valve or valve components such as pilots or bonnet, stam, and disc assemblies are to be removed from the system area for repair, obtain a hold tas(s) 1.f needed from Quality Control and place the hold tag (s) on the valve and/or parts.
: 2. Infer to meanfacturer's repair maanal or instructions, etc., if available la system file for recommendation for replacements parts, bolt torque                      ;
procedare orders and for cleanias solvents and lubricants (Ceco approved                    i prodnets). This is to achieve optimum valve operation and perforssace
  .                         se that Technical Specification operability and timing requirements are met.         ,
: 3. Primary containment isolation valve disassembly during a refueling outage must not be undertaken until an "as-found" Local Leak Rate Test (LLRT) is performed first by the Technical Staff.
D. PRECAUTIONS
: 1. Use extra precautions when hanging rigging.        Some climbing may be required to rig in some areas.
E. LIMITATIONS AND ACTIONS
: 1. This procedure is intended to be used in conjunction with a develeped work package for the proposed maintenance on safety-related valves.
l
                 . 2. The maintenance foreman responsible for the repair shall discuss with the mechanics the proper techniques for the disassembly, inspection, repair, and reassembly of safety-related valves. This discussion shall include the specific cleaning solvents and lubricants to be p                        utilized during the repair and the application and amounts to be used.
h                                                                                               ARRROVED AU601884
                                                              -1                                   M 0.,1 R.

      ~'                                                                                           '
                                                                               @tP 800-18
    .'*                                                                        Revir, ion 3
: 3. Quality Control shall inspect every safety-related valve upon disassembly and prior to reassembly to verify that foreign materials are not present on valve seating surfaces.
: 4. The checklist QtiP 800-815 shall be reviewed by QC and QA prior to use to include hold points as deemed necessary to verify maintenance performance.                                                 -
F. PROCED13tE                                           -
: 1. Before disassembly of the valve, survey the entire exterior of the valve for corrosion, cracks, wear and pits etc. (Remove valve insulation only if there is evidence of valve leakage.) Record specific data such as loose bolting, fittings, packing, condition of the stem and the above inspection information on @lP 800-815.
: 2. Contact Quality control for inspection of valve int;rvals (seating surfaces, etc.) immediately upon disassembly.
: 3. When disassembly is complete, briefly describe the condition of.the valve internal parts (including surfaces, stem, disc, seat,' etc.).
Also note the valve leakage source on QtiP 800-815.
: 4. Repair and replace parts as identified in the accompanying work package.
If changes are required to the approved work package, the package revision anst be approved prior to work proceeding.. Note all repair and replacement parts en the checklist.. Also,. list the spacific masafecturer's product name for lubricants and cleaning solvents used on valve componaat surfaces (i.e., o-rings, gaskets, sealing surfaces, stems,etc.). The product used shall be in accordance with the valve manufacturer's recommendations and/or good maintenance practices; for, purposes of assuring smooth and res.istance-free valve operation.
Describe the type application used for cleaning solvents, lubricants and the, proper amounts.
t              5. Contact Quality Control ismisdiately prior to valve closure to inspect the internal seating surfaces for cleanliness and to verify that foreign material is not on the seating areas.
l              6. Complete the reassembly of the valve in accordance with maanfacturers reca===adations and good maintenance practices. Add the bolt torquing ragairements and rotational and sequential orders on the checklist.
G. CHECKLISTS
: 1. QldP 800-S15, Safety-Related Valve Inspection Checklist (Includes Primary Containment Isolation Valves).
i        H. TECIDIICAL SPECIFICATION REFERENCES l
    -          I*
l                                             --
APPROVED
                                            -       1HdIE DAr                             AU601984 Q.C.O.S.R.
!                                                (flaal)                     .
l                                                -.

     . i .                                                               .
HOLD POINTS INCLUDED O         QC QA INITIAL /DATE SAFETY-RELATED VALVE INSPECTION CEECELIST (INCLUDES PRIMARY QMP 800-815 Revision 1 July 1983 CONTATEMENT ISOLATION VALVES)
ID/IP UNIT                      EPN                     WORE REQUEST No.                           <
l VALVE DESCRIPTION (I.E., MAEE, MODEL, SIZE, ETC.)
A. VALVE EETERNAL INSPECTION:              QC/QA BOLD POINTS fX IF REQUIRED)
(NOTE CONDITIONS FOUND)             _  QC QA YES      NO                  SIGN            DATE CORROSION CRACES M
PITS h
* OTHER                                                  ,
IF TES, DESCRIBE CONDITIONS FOUND:
l I
: 8. VALVE DISASSEMBLY                      QA NOLD POINT (I 17 REQuuu.u) i QUALITY CONTROL INSPECT VALVE       l lQAl                                     l l                ON DISASSEMBLY. NOTE ANT                         SIGN            DATE
,                FOREIGN MATERIAL ON SEATING l
SURFACES.                                                             /
l                                                          QUALITY CONTROL INSPECTOR        DATE DESCRIBE ANY DISCREPANCIES BELOW:
i l
l f
l i
i-                                                                                   APPROVED            !
AJG 0 51053 1                                  Q.C. O. S. H.
l

QMP 800-S15
         , ,.                                                                         Rwision 1 C. IDENTIFT VALVE LEAEAG SOUR G           QC/QA HOLD POINTS (I IF REQUIRED)
.                                                             .C                         -
QA l                                                                          SIGN         DATE TES       N0   4
                                                                                                                         ~
;                     MAIN SEAT / POPPET                                                                              -
PILOT SEAT / POPPET STEM PAGING S= una/>0Dr->0N=T GAS =T                                  FOR REFERENCE ONLY                           .
OTHER                                                   -                                              '
IF TES, DESCRIBE CONDITIONS FOUND:
         '       IF UNINOWN AFTER INSPECTION INCLUDE OBSERTATIONS AND POSSIBILITIES OF LEAKAGE SOURG:
D. VALVE INTERNAL INSPECTION                QC/QA BOLD POINTS (I IF REQUIRED)
NOTE ENERAL CONDITION OF:
QC GA INTERNAL VALVE BODY SURFAGS VALVI SEAT GUIDE DISC                   i GASKET AND SURFAGS1 PACKING / FOLLOWER STEM BOLTING LUBRICATION (I.E., DRT, NORMAL ETC.)
OTHER CONDITIONS NOTED E. REPAIRS,IF NECESSART, SHALL BE IDENTIFIED ON A WORK PACKAGE (I.E., MAINTENANG / MODIFICATION PROCEDURE AND STATION TRAVELER).
4 p p g g.,, g .'.
NOTE: NO DATA REQUIRED ON THIS FORM.
             "                                                                                                        ~
                                                                                                                        ~
C: 0 5 E23 Q.c a s. a.

    .**         *                                                                     @lF S00*S15 Revision 1 F. REPLACEIENT DATA:                       QC/QA 502 PO UTS G U ''0UIRED)
QC
    .                                                     QA J                                                                    SIGN             DAR PART NO. (IF AFFLICAME)
VALVE ASSEHRLT Snu                   i-               ,
i                                          -
MA N DISC APPROVED AUG 0 51983 PILOT DISC y a ggar                                                                           - Q. C. O. & R.
OIEER       -
                                                                                         ${&{fff O           G. LUBRICANT AND SOLVINTS                  QC/QA EOLD PO UTS 3 U 52 *T**n)
QC CA SIGN              DATI HFG NAtB                          TYPE LUERICANT AFFLICATION                                 At900NT*
MFG MARIE      -
TTFE SOLVENT                           AFFLICATION                                 ARIOUNT*
          .*AN00NT:    DESam COATUG OF LUERICANT OR SOLVENT (I.E., LIGNT FII2, EEAVT USE ETC).
DESCRIM ANT ADDITIONAL USES OR POTENTIAL PROBLEHS WITE LUBRICANT OR, SOLVENTS:
E. VALVE REASSIMBLY                        .QA 30 2 PO UT CI IF IdQUIRED)
QUALITY CONTROL INSMCT               I IQAl                      1                     l                  1 VALVE PRIOR TO CIASURE                                 SIGN             DATE (VALVE REASSEISLT). NOTE ANT EEGSSIVE OR UNAUIBORIZED FOMIGN MATERIAL ON SEATING SURFAGS.
MCLEANUG IS MQUDED FRIOR'TO PROCIEDDG WITE TM CLOSURE, IF F0MIGN HATERIALS AIE NOTED.
C0ADITION                                                                       /
QUALITT CONTROL INSPECTOR              DATE               -
3

r                                                              -
(       . . ,                      .
      ~
s.,,                                                                QMP S00-515 Revicion 1 1
I. VALVE CLOSUM                       QC/QA HOLD POINTS (E IF REQUIRG)
QC SIGN          DATE BOLTING:       SEQUENTIAL ORDER ROTATIONAL ORDH TORQUE VALIE                                                           l TORQUE WRENG NUMMR CALIBRATION DATE
                                         , a SETG:
O s
V                                      FOR REFERENCE ONJ FINAL SIGNATURES:
4 MECHANIC                                              /
SIGNAruus              DATE FOREMAN REVIEW                                        /
SIGNATURE              DATE MASTER MEC.teNIC REVIEW                               /
SIGNATURE               DATE QUALITY,, CONTROL REVIEW                             /
SIGNATURE              DATE NOTE:    TR ABOVE SIGNATURES MUST E COMPLETE PRIOR TO RETURNING THE VALVE TO SERVICE (REEASE FOR TEST).
APPROVED AUG 0 51053 J                                                                                    '
Q.C.O.S.R   -
                                                     -4.(final)
    ,
}}

{{LER-Nav}}