05000317/LER-1982-022, Updated LER 82-022/01T-1:on 820503,total Type B & C Penetration Leakage Calculations Compared to Wrong Spec. Caused by Incorrectly Revised Local Leak Rate Surveillance Test Procedure.Procedure Revised

Updated LER 82-022/01T-1:on 820503,total Type B & C Penetration Leakage Calculations Compared to Wrong Spec. Caused by Incorrectly Revised Local Leak Rate Surveillance Test Procedure.Procedure Revised

ML20071L277
Person / Time
Site:	Calvert Cliffs
Issue date:	07/22/1982
From:	Sydnor R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20071L273	List: 05000317/LER-1982-022, Updated LER 82-022/01T-1:on 820503,total Type B & C Penetration Leakage Calculations Compared to Wrong Spec. Caused by Incorrectly Revised Local Leak Rate Surveillance Test Procedure.Procedure Revised
References
LER-82-022-01T, LER-82-22-1T, NUDOCS 8208020391
Download: ML20071L277 (3)

LER-2082-022, Updated LER 82-022/01T-1:on 820503,total Type B & C Penetration Leakage Calculations Compared to Wrong Spec. Caused by Incorrectly Revised Local Leak Rate Surveillance Test Procedure.Procedure Revised

Event date:
Report date:
3172082022R00 - NRC Website

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U.S. NUCLEAR REGULATORY COMMISSION

{ NRC (7 77)

FORM 366

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LICENSEE EVENT REPORT Update Report Previous Report Date: 5-17-82 (PLEASE PRINT OR TYPE alt REQUIRED INFORMATION)

CONTROL BLOCK: l 1

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l C l C I N l 141 l@l LICENSEE CODE 15 0 l 0 l - l 0 LICENSE l 0 l 0NUMBER l 0 l 0 l - l 0 l 025l@l264 l 1LICENSE l 1 l 1TYPE l l 1JOl@l $7 CAT 58 l@

CON T I0ltl 7 8 S$RCE 60 d lOl5l0l0l0l3l117 hl0!510l3l8]2Ihl0l7l2l2l8l2lh 61 DOCKET NUMBER 68 69 EVENT DATE 74 75 REPORT DATE 80 EVENT DESCRIPTION AND PROBABLE CONSEQUENCES h I O I 2 l l At 1400, during refueling operations, discovered that on 9-24-82 Unit 1 I

[Ol3l l Local Leak Rate Surveillance Test Procedure was incorrectly revised l l o l 4 l l auch that total type B and C penetration leakage was compared to the l l o I s i l wrong specification (T.S. 3.6.1.2.b) . Unit 2 procedures were found l l 0 l6 l l similarly incorrect. During the time period the incorrect revisions l -

l 0 l 7 l l were in ef fect no Calculated leak rates were above the correct speci- l lOlsl l fication. No similar events have been reported. J80 7 8 9 SYSTEM CAUSE CAUSE COMP. VALVE CODE CODE SUBCODE COMPONENT CODE SUBCODE SUBCODE 1019l l S l A l h (_A_jh l X lh l P l E l N l E lT lR lh W h (_Z_j 20 h

7 8 9 10 11 12 13 18 19

,_ SEQUENTIAL OCCURRENCE REPORT REVISION LER RO EVENT YE AR REPORT NO. CODE TYPE NC.

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33 34 35 M 3 40 41 42 44 CAUSE DESCRIPTION AND CORRECTIVE ACTIONS h l1 10 l l This event was caused by a personnel error during revision of Local Leak l l i 11 l l Rate Surveillance Test Procedures which caused total measured Type B and l

[il2l l C leak rate to be compared to La versus 0.60 La. Procedures have been l l i l 3 l l revised to correct the error. The review process is being upgraded to l l i 14 I I prevent possible recurrence. I 7 8 9 80 ST S  % POWE R OTHER STATUS OlSCO RY DISCOVERY DESCRIPTION 1 5 W h l 0l Ol 0l h ! N/A l (_B_jhl Procedure Review l AC TIVI TY CO TENT RELEASED OF RELE ASE AMOUNT OF ACTIVITY LOCATION OF RELE ASE d W h d@!

7 8 9 10 11 N/A 44 l l 45 N/A 80 l

PERSONNEL EXPOSURES NUMBER TYPE DESCRIPTION 1 7 lOl0l0lh W hl N/A l PERSONNE L INJUI IES NUMBER DE SCRIP TION 7

1 H 8 9 l0l0l0lhl 11 12 N/A 80 l

LOSS OF OR DAMAGE TO FACILITY TYPE DESCRIPTION 7

1 9

" S lZlhl'o N/A 8208020391 820722 l

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PDR ADOCK 05000317 NRC USE ONLY ,

ISSUE M 7 8 9 hl to N/A l 68 69 lllllllllllll{

80 3 NAME OF PREPARER R. Sydnor PHONE: 301-269-4728 {

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LER NO. 82-22/IT, Rev. I p DOCKET NO. 50-317 LICENSE NO. DPR-53 EVENT DATE 05-03-82 REPORT DATE 07-22-82 ATTACHMENT EVENT DESCRIPTION AND PROBABLE CONSEOUENCES At 1400 on 5-3-82, with Unit I shutdown for refueling, it was discovered that Surveillance Test Procedure (STP) M-571-1, Local Leak Rate Tests, completed 12-18-80, incorrectly compared the total measured Type B and C leak rate to La vice the correct specification of 0.60 La (T.S. 3.6.1.2.b). STPs M-471-1, M-571-2, and M-471-2 also contained the same error. All four procedures were incorrectly revised in September 1980. The error was not detected in the review and approval process.

During the time period the incorrect revisions were in effect the majority of the total measured Local Leak Rates for both Units 1 and 2 was due to Type 2E electrical penetrations. The method used to Local Leak Rate Test these Type 2E electrical penetrations produced conservatively high leak rate results. It can be shown that with the containment pressurized, the potential leak paths via the 2E penetratilons differ from, and are more tortuous than, those paths measured during the Local Leak Rate Test. Also, it can be shown that with the containment pressurized the maximum leakage via a penetration of this type would be 50% of the leak rate measured by the Local Leak Rate Test. Thus, for all Local Leak Rate Tests completed during this time period (9/80 -

5/82) the specification of 0.60 La was not exceeded.

Additionally, a special Local Leak Rate Test performed on Unit 2 2E electrical penetrations on 6-10-82, at the request of USNRC the Region 1 Office of Inspection and Enforcement, indicated that leakage rates via these Type 2E penetrations during operation are significantly less than the leak rates measured during plant shutdown by STP-M-571-2.

CAUSE DESCRIPTION AND CORRECTIVE ACTIONS:

This event was caused by personnel error in revising Surveillance Test Proadure (STP)

M-571-1 to list 346,247 SCCM as the maximum allowed total Type B and C penetration leakage. STPs M-471-1, M-571-2, and M-471-2 were also incorrectly revised. Tech Spec 3.6.1.2.b requires total Type B and C leakage to be _0.60 La (207,600 SCCM). The four procedures involved listed the specification in SCCM and did not cross-reference the number to La or 0.60 La. In addition, the independent technical review and Plant Operating Safety Review Committee (POSRC) reviews failed to detect the error.

The Type 2E electrical penetrations which contributed the majority of the total measured leakage have been replaced in Unit I and the replacement penetrations, which are a different type, have reduced leakage via these penetrations to essentially none.

The Unit 2 2E electrical penetrations will be replaced during the scheduled Fall outage.

The special test conducted 6-10-82, on the currently installed Unit 2 penetrations has indicated that the total leakage rate is well within the Technical Specification limits and is not deteriorating any appreciable extent.

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The entire review process associated with this event has been examined to determine appropriate measures to prevent recurrence. These measures taken or to be taken are:

a. establishment of a qualification program for STP coordinators;

b. issuance of a letter by the Plant Superintendent reminding personnel of their responsibilities in conducting technical reviews;

c. change of the Technical Specification to express the limit in Type B and C penetration leakage in equivalent SCCM;

d. revision of the STPs to correctly specify leakage limits; and

e. upgrade of the POSRC procedure review process.

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