IR 05000354/1988008

Insp Rept 50-354/88-08 on 880314-18.No Violations or Deviations Noted.Major Areas Inspected:Local Leak Rate Testing of Containment Isolation Boundaries & Implementation of Inservice Test Program for Pumps & Valves

ML20153D993
Person / Time
Site:	Hope Creek
Issue date:	04/20/1988
From:	Eapen P, Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153D986	List: IR 05000354/1988008 ML20153D982
References
50-354-88-08, 50-354-88-8, NUDOCS 8805090349
Download: ML20153D993 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

Report N /88-08 Docket N License No. NPF-57 Licensee: Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: March 14 - 18, 1988 Inspectors: m# V-Jo-SS eph K. Golla, Reac~ tor Engineer date Approved by: .

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fAfL Dr. P. K. Eapen, Chief, She'cial Test M th P !

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Programs Section, EB, DRS Inspection Summary: Inspection on March 14 - 18, 1988, (Inspection Report No. 50-354/88-08)

Areas Inspected: Routine unannounced inspection of Local Leak Rate Testing of Containment Isolation Boundaries and implementation of the provisions of the Inservice Test Program for pumps and valves. The inspection included a review of test procedures and recoras of test results and test witnessin Results: No violations or deviations were identified, However, Technical Specification maximum leakage criteria was exceeded for MSIVS and for other containment isolation valves pneumatically tested, and QA attention to inservice testing was found to be lacking. Administrative control of Local Leak Rate Testing and Inservice Testing was found adequat PDR ADOCK 05000354 Q DCD

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DETAILS 1.0 Persons Contacted 1.1 Public Service Electric and Gas Company A. Barnabet, QC Group Head

• Beckwith, Station Licensing Engineer B. Binz, Systems Engineer E. Ciemiewicz, LLRT Supervisor, ISI G. Devoy, Lead Mechanical Systems Engineer

"A. Giardino, Manager - Station QA

• R. Griffith, Princi 1 Engineer - QA

• J. Hagan. Maintenar e Manager - HC0

• S. LaBruna, General Manager - HC0 L. Lake, ISI Engineer B. Lemberger, LLRT Supervisor, ISI

• E. Maloney, ISI Supervisor

• J. Nichols, Technical Manager B. O'M41ey, Operations Shift Supervisor E. Parker, Control Room Operator C. Serata, LIRT Supervisor, ISI J. Wicks, Control Room Operator 1.7 Nuclear Regulatory Commission

• 0. Allsopp, Resident Inspector, Hope Creek

• Indicates those pres 6nt at the exit meeting held on March 18, 198 .0 Local Leak Rate Testing 2.1 General The purpose of the inspection in this area was to ascertain that local leak rate testing is being administered adequately and conducted in compliance with the requirements and commitments referenced in the following section. The LLRT procedures were reviewed for technical adequacy to perform the intended activit Other record keeping and LLRT relatad documer.tation was reviewed to determine adequacy of the overall administr;tive control of the local leak rate test progra .2 References

10 CFR Part 50, Appendix J; Primary Reactor Containment Leakage Testing for Water Cooled Power Reactor * Hope Creek Generating Station (HCGS) Technical Specifications Section 3/4. . ;

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HCGS Final Safety Analysis Report (FSAR)

• ANSI /ANS 56.8 - 1987, Containment Systems Leakage Testing Requirement .3 LLRT Procedure Review The inspector reviewed the LLRT procedures to determine their technical adequacy and adherence to accepted testing methodology. The Local Leak Rate Test procedures are structured such that each primary containment penetration has a specific procedure covering its system lineup, and recommended venting and draining instructions, The penetration specific portion of the procedures are governed by a more general portion which covers test methodology, prerequisites, responsibilities, and limits and precautions. The procedures were found to be technically correct to perform Local Leak Rate Testing utilizing the mass flow-in metho This method is acceptable per 10 CFR 50, Appendix J and current industry practic .4 Test Witnessing The inspector witnessed the performance of test activities to verify that qualified test equipment and tools were used and that the test technicians followed the procedure. The following mass flow-in tests were witnessed: Informational LLRT of outboard feedwater check valve HV-F074A (AE-V006) on March 16, 1988: the valve had a temporary bonnet cover installed for this "informational" test so that it could be determined if further maintenance on the valve was necessary. The valve had failed its "as-found" LLRT and was being repaired. This retest was successful in that the demonstrated leakage of 780 sccm was within its administrative leakage limit of 2400 sccm. A final "as-left" LLRT will be performed on the valve af ter it is completely reassemble . As-found LLRT of containment-side flange on March 5, 1983 at penetration P-220, valve nut.ber GS-HV4958 (V022): this is at the inboard side of the 24" torus purge Butterfly Valv The test demonstrated acceptable results (1 sccm) leakag . As-left LLRT of torus purge (24" Butterfly Valve) GS-HV4958 (V022) on March 16, 1938: This valve was tested with a newly installed seat. The test volume was unable to maintain the test pressure of 48,1 psig. After troubleshooting the test boundary by soap bubble testing it was determined that the leakage was occurring through the valve disc / seat interface. The licensee is required to take necessary action to assure leak tightness of this valve prior to startup from the current outag ,

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The inspector reviewed the system lineups for the tests witnessed and determined that the associated boundary and vent valves were in an effective test configuration. The test technicians followed approved procedures, utilized qualified test equipment, and were competent to perform the tests. The inspector determined that test technicians were qualified as a minimum to Level I of ANSI 45. and that as a minimum, LLRT supervisors were qualified to level I The licensee pressurizes the larger test volumes with station air by manually operating a valve from a station air source. This is done until the test technician observes that the test volume is very close to test pressure. At this point, bottled nitrogen gas admitted through the LLRT test box is used to fully pressurize the volume and to measure the makeup required to maintain test pressure. The in-spector observed that this practice has a potential for initially overpressurizing the test volume since no pressure regulator is used when utilizing the station air suppl The licensee acknowledged the inspector's observation and agreed to utilize a pressure regulator or relief valve in the future when utilizing the station air supply to pressurize test volume It was noted that a QC inspector was present at all three of the above surveillance .5 Administrative Control The inspector reviewed documentation relevant to the overall administrative control of the local leak rate test progra Information which documented the following status of activities and criteria were reviewed: Recording of test results; LLRT equipment

! calibration requirements; acceptance criterion for pneumatic, hydrostatic, and MSIV testing; and deficiency reports and work

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l activity planning sheets for containment isolation valves receiving maintenance wor The information reviewed was found current (LLRT computerized running total was being maintained and current records were well organized) and appeared adequate to prw ide proper administrative control of the overall LLRT program. The inspector determined that the licensee is utilizing maximum pathway leaksge determination methodology for valves in the "as-left" condition.

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This is the accepted method of determining leakage through a valve / piping network. No unacceptable conditions were identified.

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2.6 Failure of Penetration Leakage Criterion

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At the tine of the inspection, approximately 80% of all local leak rate testing for the outage was con'plete. The acceptance criterion

! for total local leakage through all isolation barriers (except i M51Vs) subject to pneumatic testing is .6La. This maximum allowable LLRT total is a requirement of 10 CFR 50, Appendix J and i

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Hope Creek Generating Station Technical Specifications. For Hope Creek, .6La corresponds to 76,803 secm. As of the time of the inspection two containment penetrations have demonstrated maximum pathway leakages which are in excess of the .6La acceptable criterion, These were Feedwater Check Valves AE-V003 and AE-V002 at penetration P2A, and Core Spray Injection Valve BE-V006 at penetration P58. In both cases the test volumes did not maintain the test pressur Additionally, on February 18, 1988, local Leak Rate Testing of Main Steam Isolation Valves AB-V031 and AB-V035 at penetration P-10-3 indicated a penetration leakage of 51,300 secm. The acceptance criterion for the Main Steam Isolation Valves per Technical Specifications is that the combined leakage through all !

four Main Steam Lines when tested at 5 psig (seal system delta p) be !

less then or equal to 46.0 scfh (21,693 secm). Leakage through penetration P-1D-3 therefore exceeds the limit for combined leakage through all four MSIV lines. Leakage values at the remaining MSIV lines were acceptable. The licensee has generated Deficiency Reports on the test failures and will also report these occurrences i under the provisions of 10 CFR 50.73, Licensee Event Report (LER)

! Syste The licensee has initiated necessary actions to restore '

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leaktight integrity in accordance with the facility technical specificatio '

3.0 Inservice Testing of pumps and valves 3.1 General The inspection in this area was conducted to review and assess the licensee's implementation of their Inservice Test (IST) pump and valve test program ccmmitments and other activities associated with IST implementation. Verification of adherence to regulatory requirements, ASME Section XI requirements and licensee's commitments as well as consideration of safety consequences, organizational structure and interfacing of other departmental groups were addressed as part of the inspectio The licensee's Inservice Testing of Pumps and Valves was implemented adequately. Testing of components was performed in accordance with commitments and regulatory requirements. An IST organization is in place with designated responsibilities assigned. Personnel were knowledgeable of the issues, Test records and other recorded information were maintained and were readily available. Test schedule adherence of selected pumps and valves were found acceptabl .2 IST Program Background The inspector reviewed the licensee's current IST pump and valve program and held discussions concerning the program with cognizant IST personnel. It was determined that revision 1 to the IST Program is currently under review by NRR and that the licensee has received

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. 6 interim approval of the first revision for implementation '

purpose Revision 1 was written to address program management and {

implementation improvements, update specific testing, revise the

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format and incorporate various miscellaneous changes. The revision incorporates the requirements of ASME Code,Section XI, 1983 Edition ,

with Addenda up to and including the Summer of 1983. This is a code update from revision 0 of the IST Program and was made in order for the IST Program and the Inservice Inspection (ISI) Programs to adhere to the same requirement :

It was determined by the inspector that within the Hope Creek Generating Station organization, development of the IST Program and i it's revisions is the responsibility of the Site Services

} Departmen The Site Services Department receives input and l

expertise from the Technical Department (systems engineers) with <

regard to the safety function of components. The Operations Department is responsible for scheduling and conducting Inservice Testing, and reviewing and accepting test result .2 Surveillance Procedures and Results Review The inspector reviewed the following test procedures and results for the most recent and three previous surveillances:  ; Residual Heat Removal Pump - BP202 - Inservice Test, ,

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OP-IS-BC-003(Q) - Rev. 5.

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s C ECCS Jockey Pump - CP228 - Inservice Test, OP-IS.BC-005(Q) -

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] Residual Heal Removal Subsystem 0 Valves - Inservice Test, j OP-IS-BC-104(Q) - Rev. 1.

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j Main Steam System Valves - Inservice Test, OP-IS.AB-101(Q) -

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The inspector noted that in all cases the tests had been completed a

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with satisfactory results and that all procedural sign-offs were complete where necessar The procedures included test acceptance

criteria, prerequisites, precautions and limitations, and step by ,

step instructions to perform the test The procedures also i required test equipment tag number and calibration due dates to be !

filled i The inspector noted that for pumps and valves the '

required parameters per ASME Section XI (valve stroke times, pump

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vibration readings, and differential pressure for flow '

determination) were being measured, recorded and evaluated, i The inspector determined through an audit of records that the test surveillance frequencies committed to the IST Program (and those of

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l ASME Section XI) are being adhered to. Test records and results

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were well documented. All records reviewed were orderly and up to date. The inspector verified that new baseline data (reference values) are generated por ASME Section XI requirements, for pumps which have been repaired or replace The inspector determined, based on reviewing procedure content and test records, that the provisions of ASME Code Section XI and the licensee's commitments in their IST Program were me .4 Test Witnessing The inspector witnessed on March 17, 1988, portions of the following Inservice and Technical Specification Surveillance Tests: Integrated Emergency Diesel Generator IBG400 Test - 18 months, OP-ST.KJ-006(Q) - Revision . Service Water Subsystem B Valves - Inservice Test, OP-IS.EA-102(Q) - Revision . Service Water Flow Path Verification - Monthly, OP-ST.EA-001(Q)

- Revision The inspector observed from the control room the performance of the operations personnel conducting the tests. The inspector discussed with the operators the provisions and requirements of the above tests with respect to test methodology and schedular adherence. The operators were found to be knowledgeable and competent to perform their duties. All procedural sign-of f s were completed properly and timely. No unacceptable conditions were identifie .5 Trending of Test Results The inspector discussed performance trending with the licensee's representative The licensee indicated that this is presently not done but a program is being developed as a result of an October 1987 audit by the Institute of Nuclear Power Operators (INPO). A commitment was made by the licensee to institute and install a performance trending program by mid 1988. The inspector reviewed newly developed cocumentation regarding this program. A new procedure SA-AP.ZZ-048, "Station Performance Monitoring", has been written which provides for the identification and trending of parameters that are indicative of equipment, system and station performanc Procedure TE-PR.ZZ-002 has been prepared to implement the performance trending program by collecting and analyzing selected analog data from the plant computer. Additionally, procedure SE-PR.ZZ.048,

"System Engineering Station Performance Monitoring", provides for the routine monitoring, trending, and analysis of all systems and components that have the potential to cause plant downtime, power reductions, or undesirable plant transient The in3pector had no further question i I

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3.6. Engineering Interface The inspector reviewed the interface between the IST and Engineering Group The inspector determined there is interaction. When a pump within the IST program is replaced or repaired, it is a systems engineer who generates the new reference values for the pump per ASME Section X The systems engineers were consulted during the development of the current revision to the IST Program and will be in charge of the new performance trending program discussed in Section 3.5 of this repor .0 QA Involvement The inspector discussed involvement of the QA and QC organization in the Local Leak Rate and Inservice Testing areas with representatives from both QA and QC, It was determined that the QC department has made significant efforts monitoring Local Leak Rate Testin It is noted that a QC monitor was present at the LLRT's witnessed by the inspector, see Section 2.4 The inspector reviewed numerous Station QA Surveillance Reports covering LLRT's witnessed by QC monitors. The reports were well writte It was determined, however, that QA/QC attention has not been directed in the IST area. The inspector discussed the apparent lack of QA coverage with the Station QA Manager. The Station QA Manager acknowledged the inspector's concern and stated that QA will in the future provide coverage of Inservice Testing activitie .0 Exit Meeting Licensee management was informed of the purpose and scope of the inspection at the entrance interview. The findings of the inspection were periodically discussed and were summarized at the exit meeting on March 18, 1938. Attendees at the exit meeting are listed in Section 1.0 of this repor At no time during the inspection was written material provided to the licensee by the inspector The licensee did not indicate that the inspection involved any proprietary information.