ML20133A252

Insp Repts 50-277/85-23 & 50-278/85-23 on 850604 & 09-13. Violation Noted:Failure to Perform Local Leak Rate Tests, Per 10CFR50,App J

ML20133A252
Person / Time
Site:	Peach Bottom
Issue date:	07/19/1985
From:	Eselgroth P, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133A147	List: ML20133A144 ML20133A152 ML20133A252
References
50-277-85-23, 50-278-85-23, NUDOCS 8508050390
Download: ML20133A252 (9)

See also: IR 05000277/1985023

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-277/85-23

Report Nos. 50-278/85-23

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50-277

Docket No. 50-278

DPR-44

License No. DPR-56 Priority --

Category C

Licensee: Philadelphia Electric Company

2301 Market Street

Philad'elphia, Pennsylvania 19101

fFacility'Name: Peach Bottom Atomic Power Station, Units 2 and 3

{ Inspection At: Delta, Pennsylvania

/ Inspection Conducted: June 4, 9-13, 1985

Inspectors: / . r [

D."Floreli, Lead R& actor Engineer

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, Approved by: ,[ 7 98[

P. Eselgrjffh, Chief, Test Program ' dite

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.SectiYn, OPS, DRS

Inspection Summary: Inspection on June 4, 9-13, 1985 (Combined Inspection Report

,; Numbers 50-277/85-23, 50-278/85-23)

+1

Areas Inspected: Routine, unannounced inspection of the Unit 2 Containment

Integrated Leakage Rate Test (CILRT) including test procedures and records

review, test witnessing, local leak rate testing, independent calculations,

followup of the cause of the failed CILRT attempt and its affect on Unit 3,

' '

QA/QC interfaces and tours of the facility. The inspection involved 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br />

onsite and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in office by one region-based inspector.

Results: One violation was identified for not performing local leak rate

tests in accordance with 10 CFR 50 Appendix J. (see Section 2.9)

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8500000390 850729

PDR ADOCK 05000277

O PDR

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DETAILS

1.0 Persons Contacted

Philadelphia Electric Company

J. Campbell, Engineer, ILRT

• R. Fleischmann, Manager, Peach Bottom Atomic Power Station (PBAPS)

D. Helker, Engineer, ILRT

F. Massatelli, Modifications Coordinator

J. McElwain, Quality Control

J. Morrow, Engineer, Mechanical'

• D. Smith, Superintendent of Operation

A. Wasong, Performance Engineer

T. Wilson, QA Site Supervisor

General Physics Corporation

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R. Carey, Engineer ILRT

E. Levinson, Engineer ILRT.

U.S. Nuclear Regulatory Commission

• T. Johnson, Senior Resident Inspector

J. Williams, Resident Inspector

The inspector also contacted other licensee personnel during the

inspection including members of the operation and technical staffs.

~* Denotes those present at exit meeting on June 13, 1985.

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2.0 Containment Integrated Le_ak Rate Test (CILRT)

2.1 General

On June 8-12, 1985, the Peach Bottom Atomic Power Station performed a

CILRT as required by 10 CFR 50 Appendix J and Technical Specification 4.7.A. The test was performed in accordance with ST-12.5 Revision 3,

" Integrated Leak Rate Test". The inspector reviewed the test procedure,

reviewed portions of the test preparation and witnessed various portions

of-the test. Other documents reviewed included. the CILRT test log,

calibration records for CILRT instrumentation, ILRT volume fraction

calculations, test data and results, local leak rate test (LLRT) results,

test related process and instrumentation, and valve detail drawings.

2.2 Valve Lineups

The inspector independently verified on a sampling basis the positioning

of valves identified in test procedure ST-12.5. The valves reviewed were

all found to be in their correct position to perform the CILRT.

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2.3 Instrumentation

The inspector reviewed the calibration records for the resistance

temperature. detectors (12 utilized), dew point hygrometers (6 utilized),

pressure detectors (one utilized plus a backup) and rotometer. The

inspector also reviewed the Instrumentation Selection Guide (ISG) calcu-

lation and verified the proper selection of instrumentation. The instru-

mentation was in calibration with the specified values and the number of

instruments utilized was in accordance with test requirements. No items

of noncompliance were noted.

2.4 Inspection Tours

The inspector conducted inspection tours independently and with licensee

personnel both before and during the CILRT. The test data collection

system was found to be acceptable. During these tours, test boundaries,

primarily vent paths external to the test volume, were surveyed for evi-

dence of leakage and valve position. Valves were observed to be in their

correct position. During these tours valve A0-2502B was observed to be

leaking along the valve stem. This is further discussed in section 2.9 of

this report.

2.5 CILRT Chronology

June 8, 1985 0612 Commenced pressurization of

containment

0840 29.6 psia reached, pressurization

stopped

0900 Primary containment exterior .

survey for leaks begun.

0945 Valve A0-2502B in the A and C

core spray triangle room

identified as a large leak.

1030 Pressurization resumed

June 9, 1985 0205 Reached 64.2 psia

0630 Data indicated three times

allowable leakage, temperature

stabilization achieved.

1015 Leak around A0-2502B quantified

to be at least 1.8 scfm (not all

leak-by flow could be diverted

into a rotameter). Leak search

continues

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1130 Five other small leaks identified.

1200 Throttled cooling water to

containment coolers to slowdown

temperature changes in primary

containment

1500 A0-2502B packing leak repaired

1730 CILRT failure declared due to

A0-25028 leakage. NRC notified.

1930 Five leaks quantified as < 550

scc / min

2130 Containment repressurized due to

pressure falling below test

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pressure

2200 Test pressure achieved.

June 10, 1985 0200 CILRT restarted - during

stabilization period, data

indicates potential inleakage

into primary containment. Search

performed on obvious sources but

none identified.

0700 Valve SV-4951A packing leak

identified in leak search.

Quantified at less than 200

scc / min. Leak was not isolated.

Licensee evaluation of data still

predicts inleakage, which is not

compatible with the plant

conditions.

0800 Leak searches intensify.

1045 Leak rate .035 weight percent

per day (into containment)

1300 Corrections for reactor and torus

level indicate torus level is

increasing faster than reactor

level is decreasing.

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1500 Leakage identified from

condensate system through the

, core spray torus fill line into

the torus at approximately 1 gpm.

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1545 Leak isolated. CILRT resumed

2345 CILRT terminated with leakage

calculated as .02978 weight

percent per day at the 95%

upper confidence limit.

June 11, 1985 0100 Verification test begun with a

flow rate established at 4.4 scfm.

0600 Verification test completed with

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a calculated value of .51989

weight percent per day with an

acceptance band of between .39319

.64319 weight percent per day.

1430 Depressurization begun

2030 Depressurization stopped to

perform bypass leakage area test

of vacuum breakers.

2330 Bypass leakage area test of

vacuum breakers begun.

June 12, 1985 0030 Bypass leakage area test of

vacuum breakers completed.

Calculated leakage area of

.1695ip2 with an allowable value

of less than .785 in 2,

2.6 CILRT Test Results/NRC Independent Calculations

Licensee preliminary "as left" calculations for the primary containment

leakage uncorrected for reactor and torus water level indicated that the

leak rate was .0573 weight percent per day at the 95% upper confidence

level. The acceptance criteria is .375 weight percent per day. Prelimi-

nary as found primary containment leakage uncorrected for reactor and

torus water level indicated that the leak rate was .2437 weight percent

per day. See section 2.8 regarding LLRT contribution. This satisfied the

acceptance criterion. The "as found" results do not reflect the leakage

due to the packing leak in valve A0-25028 that occurred during the CILRT.

Valve A0-25028 was replaced during the recent outage with a valve manu-

factured by CLOW. The previous cycle utilized a Fischer valve and this

valve leakage was utilized for the "as found" calculations.

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The inspector performed independent calculations of the test results

using a sample of the raw data to verify mass calculations. During this

calculation the inspector noted that the computer program was utilizing

volume fractions for temperature sensors that totaled greater than one.

Volume fractions for temperature sensors TE-7 and 8 were input into the

computer as .0540 rather than .0522. The inspector observed the

reassignment of the correct volume fractions into the program. Using the

test data, the inspector also independently calculated the test results

, to determine if the leak rate calculations were appropriately performed.

The results were as follows:

Lam (Mass Point) UCL (Mass point)

weight percent per day weight percent per day

NRC .01760 .03006

Licensee .01769 .02978

The test results are within 5% of the inspector's estimates. The inspec-

tor concluded that the licensee's calculations were appropriately

performed.

2.7 Test Control

The inspector observed that the licensee conducted the test in accordance

with the ST-125 The inspector witnessed turnover operations between test

personnel and observed them to be comprehensive and fully acceptable. The

inspector also noted that the station resources were effectively utilized

to identify and isolate the source of inleakage from the condensate system

into the torus. The inspector also noted that test personnel were know-

ledgeable of the requirements in 10 CFR 50 Appendix J and were observed on

several occasions making sure no adjustments were made to containment once

the CILRT was initiated.

2.8 Local Leak Rate Testing (LLRT)

The inspector reviewed the preliminary LLRT results reflecting the dif-

ference in the "as left" and "as found" Type B & C testing (.0924 weight

percent per day) The licensee indicated that a few cases existed where

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the Type C test was not performed immediately before maintenance was

performed. In these cases the licensee provided justification for the

values used based either on the last LLRT performed and valve service was

subjected to since the last LLRT or taking the worst leakage determined

over the history of the containment isolation valve and its operating

service. In the cases reviewed, the above licensee justifications for the

values used were found to be acceptable. The inspector pointed out how-

ever, that reliance on this approach to justify "as found"/"as left"

differences is dependent upon the specific valve operating history and may

not always be acceptable. For example, use of prior LLRT data on a valve

subjected to water hammer or excessive operation would not be acceptable.

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The licensee recognized this and had taken steps to assure the LLRT

differences would be more precise for the upcoming Unit 3 CILRT scheduled

for later this summer.

2.9 Valve A0-2502B Excessive Leakage

The inspector reviewed the following documents to investigate in more

detail the excessive leakage around the stem of valve A0-2502B

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Drawing P-77760-03H-18111-E, (Fischer Governor Co.), Revision D,

August 28, 1970

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Drawing P-77760-02H-18112-E (Fischer Governor Co.), Revision D,

August 28, 1970

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Drawing F-36636, (Fischer Governor Co.), Revision B, March 13, 1974

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Drawing D-0720-C (CLOW), Revision C, May 4, 1983

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ST-20.052 "LLRT-D/W Purge Supply," Revision 6 PORC approved

October 29, 1984

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Safety evaluation for Mod 842C approved March 29, 1983

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Engineering Work letter for Mod 842C, Revision 6 dated February 1,

1984

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LLRT records for valve A0-2502B and A0-2520

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P&ID-367 Primary Containment Vent and Purge

The inspector also contacted personnel at the PBAPS as well as at the

corporate office in Philadelphia, Pa. via the telephone. The inspector

also inspected actual valve orientation of the following Unit 2 and

Unit 3 containment isolation valves: A0-2502A, 25028, 2505, 2506, 2507,

2520, 2521A, 25218, 3502A, 3502B, 3506 and 3521B.

During the CILRT, valve A0-2502B had leakage around the valve stem

sufficient to fail the CILRT leakage acceptance criteria. The licensee

measured leakage of at least 1.8 scfm around the valve stem. Due to the

location of the valve and associated leak, not all of the leakage could be

measured. Valve A0-25028 for this CILRT was a new valve installed during

the recent outage. The new valve was manufactured by CLOW and was in-

stalled because the old valve (Fischer) A0-2502B could not withstand the

hydrodynamic loads from a LOCA. Valve A0-2502B is a normally closed valve

located between the reactor building to torus vacuum breaker and the

torus. The valve stem for A0-25028 (CLOW) is located on the torus side of

the valve. In this orientation the valve stem is subjected to a leak rate

test during a CILRT and not during a LLRT. LLRT pressurization occurs in

the space between the vacuum breaker and valve A0-25028. Based on the

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orientation of this CLOW valve the inspector inquired if the valve was

installed as designed. The licensee evaluation concluded that the CLOW

valve was installed as designed. The inspector inquired if the Fischer

valve was also installed in this orientation. The licensee reviewed

photographs available at the corporate office and indicated via phone that

the orientation of the Fischer valve was the same, namely with the valve

stem located on the torus side, and as such was not subjected to a test

pressure when an LLRT was performed. Based on the above, the inspector

along with a licensee representative reviewed the valve orientation on

several other Unit 2 and Unit'3 containment ventilation isolation valves

and noted that valves A0-2520, A0-3506, A0-3521B, and A0-3502B were also

oriented such that the valve stem packing was on the primary containment

side of the valve disc and as such is only tested during a CILRT. A CILRT

was performed on Unit 2 on July 28, 1980, and a CILRT performed on Unit 3

on August 23, 1983.

, 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."Section III.D.3

requires in part that " Type C tests shall be performed at intervals no

greater than 2 years." The inspector notes that satisfactorily completing

a CILRT satisfied the LLRT requirement on these valve packings. However,

two years after the successful CILRT, a LLRT which satisfies Appendix J

must be performed. Prior LLRTs were performed on valve A0-2502B on July

25, 1980, May 19, 1982, July 14, 1982 and April 26, 1985 and on valve

A0-2520 on July 20, 1980, October 28, 1980, October 31, 1980, February 11,

1981, February 17, 1981, May 28, 1982, June 1, 1982 and June 8, 1982. The

licensee method for performing a LLRT on A0-2502-B and A0-2520 did not

test the packing on the primary containment side of the valve and, there-

fore does not satisfy the 10 CFR 50 Appendix J III.C.1 requirement. The

previous CILRT for Peach Bottom Unit 2 was performed on July 28, 1980.

The previous operating cycle for Peach Bottom Unit 2 ended on April 28,

1984. However, as of July 28, 1982 valves A0-25028 and A0-2520 were no

longer current with regard to the Type C testing requirements of 10 CFR 50

Appendix J III.C.1 in that the valve packing was not subjected to a test

pressure. It should be noted that compliance with Technical Specification 4.7.A.g " Continuous Leak Rate Monitor" provided information that contain-

ment integrity was maintained in the period July 28, 1980 to April 28,

1984. Failure to have conducted adequate local leak rate tests consti-

tutes a violation (277/85-23-01)

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On Unit 3, three valves (AO-3506, 3521B and 35028) were found to be

oriented such that the valve stem is not subjected to LLRT test pressures.

The last CILRT was performed on August 23, 1983. The requirements of

Appendix J for performing a LLRT on these valves at intervals no greater

than two years must be satisfied by August 23, 1985. The end of the

operating cycle for Unit 3 is planned for July 1985 and a CILRT is planned

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for this outage. Pending licensee action regarding the performance of a

LLRT on these valves, in accordance with Appendix J, this is considered an

unresolved item (278/85-23-01).

3.0 QA/QC Interfaces

The inspector witnessed QC individuals performing surveillance activities

of the in process CILRT and reviewed draft portions of their observations

at the conclusion of the CILRT. The inspector also observed QA personnel

performing an audit of the completed preliminary test package. No

unacceptable conditions were noted.

4.0 Plant Tours

During the inspection, the ' inspector observed an apparently inattentive

operator at the Unit 3 controls. Special safety inspection 50-278/85-22

discusses this item further.

5.0 Unresolved Items

Unresolved items are matters about which more information is needed to

determine whether they are violations, deviations, or acceptable.

Unresolved items are discussed in paragraph 2.

6. Exit Interview

An exit meeting was held on June 13, 1985 to discuss the inspection

findings as detailed in this report (see paragraph one for attendees).

At no time during the inspection did the inspector provide written

inspection findings to the licensee.

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