IR 05000213/1989023
| ML20042D332 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 12/28/1989 |
| From: | Joe Golla NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042D331 | List: |
| References | |
| 50-213-89-23, GL-89-04, GL-89-4, NUDOCS 9001090003 | |
| Download: ML20042D332 (8) | |
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U.S', NUCLEAR REGULATORY COMMISSION l
REGION I
Report No. 50-213/89-23-
Docket No.
50-213.
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,. License No. :DPR-61-
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Licensee: Connecticut Yankee Atomic Power Company
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P.O. Box 270
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Hartford, Connecticut 06141
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-Facility Name: Haddain Neck Nuclear Power Plant
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Inspection At: Haddam Neck, Connecticut
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Inspection Conducted:
November 27 - December 1, 1989 i
Inspector -
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Joseph A. Golla, Rehetor Engineer
' date Approved by:
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/J A S/MJ Dr.-P. K. Eapen, Chief, Special Test dite
Programs Section
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. Inspection Summary:. Inspection on November'27 - December 1, 1989 (Inspection Report No. 50-213/89-23)
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' Areas Inspected:. Routine unannounced inspection of pump and valve Inservice
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Test (IST) program implementation and review of the IST Program with respect to NRC Generic Letter 89-04 dealing with exemptions to ASME Code Section XI requirements for IST. Also,.the lice.nsee's corrective action program for evaluating and correcting leakage problems with local leakage barriers was -
reviewed.-
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Results: No violations or deviations were identified. The licensee's IST
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Program was found to be in compliance with applicable codes. including Generic Letter 89-04 dealing with exemptions.
IST implementation procedures were very wel1~ written. The licensee's corrective action program for evaluating and
preparing local leakage barriers was adequate. One unresolved item (50-213/89-23-01) was identified. A need for the licensee to more clearly
- defin.e the role of procedure writer, originator, and independent review for the
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-. newly developed procedures was identified by the inspector. Also, unresolved item 50-213/88-01-01 was closed.
f 9001opo003 891229
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DETAILS c
- 1.0 Persons Contacted 1.1 Connecticut Yankee Atomic power Company
- G. Bouchard, Unit Superintendent J. Calderone, IST Engineer
- J. Delawrence, Supervisor ISI
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- C. Gladding, Engineering Supervisor
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- D. Miller, Station Superintendent M. Smith, IST Engineer
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p 1.2 U.S. Nuclear Regulatory Commission
- "T. Shediosky, Senior Resident Inspector
- Denotes those present at the exit meeting held December 1, 1989.
2.0 -Inspection Purpose and Scope This inspection was conducted to review and assess the licensee's implementation of their pump and valve Inservice Test Program commitments and:other activities associated with IST implementation.
It also verified adherence to regulatory requirements, ASME Section XI Code requirements, the licensee's commitments regarding Generic Letter 89-04 dealing with exemptions to Code requirements, and safety considerations.
Also, the. licensee's' corrective action program for evaluating and repairing valves with a history of repetitive leakage problems as identified by Inservice Testing per-ASME Code Section XI and 10 CFR 50, Appendix J local' leak rate testing was reviewed.
Additionally, the licensee's IST Procedure Enhancement Program was reviewed for closure of Unresolved Item 50-213/88-01-01.
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3.0 IST Program Implementation (73756)
The inspector reviewed-the licensee's latest IST pump and valve program submittal and its background history.
The licensee is committed to the 1983 version of the ASME Code Section XI up to and including Summer 1983 Addenda. The current submittal is Revision 1 to the third ten year IST
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In a letter dated April 3, 1989, the NRC staff issued Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs." Connecticut Yankee Atomic Power Company (CYAPCO) has reviewed the generic letter and compared the positions outlined therein with the Haddam Neck Plant third ten year interval IST Program. The following changes.will be incorporated in the third ten year IST program by March 30, 1990.
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' Limiting values of full stroke _ time will be defined as discussed in Position 5 of the generic letter and valve operability will be judged based on these limiting values of stroke time.
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.The proposed acceptance criteria in Position 6 for " Rapid-Acting
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Valves".will be adopted.
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' Pump tests will be performed under full or substantial _ flow as outlined in Position 9.
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The frequency of check valve disassembly and inspection will be
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specified for consistency with Position 2.
Upon completion of these_ revisions, the Haddam Neck Plant IST Program will fully meet ASME Section XI, with previously submitted relief requests, and will be consistent with the staff positions outlined in Generic Letter 89-04.
The licensee is presently reviewing and revising IST implementing
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i procedures for consistency with Generic Letter 89-04 as verified by the j
inspector. Although another Program revision will be documented and
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submitted to the NRC staff by March 30, 1990, the licensee is currently conducting inservice testing according to positions described in the
above generic letter.
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It was verified that the licensee's IST Program was maintained as a
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controlled document and meets-10 CFR 50 Appendix B requirements of control.of documents that affect safety related equipment.
4.0~ Administrative Control
4.1 Test' Scheduling
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l The inspector verified that the licensee has an administrative system in place to schedule normal and increased frequency ISTs adequately.
The system also ensures that functional verification
tests of quality related components which were removed from service
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for maintenance, repairs, rework, or replacement are conducted to
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verify that they will function satisfactorily when returned to
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operation.
The inspector reviewed the following licensee documents
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which control scheduling:
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Procedure No. ACP 1.2-11.3, Rev. 13, " Retests / Functional Verifi-cation." This procedure applies to the retest / functional verif-ication of quality-related systems, structures, and components subsequent to the performance of maintenance, repair / rework, or replacement.
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Procedure No. ACP 1.2-11.7, Rev. 2, "Special Testing." This procedure applies to tests performed on installed plant systems or components for troubleshooting, performance analysis, securing data or determining operating characteristics. This procedure also applies to tests performed to satisfy
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preoperational testing requirements on plant modifications.
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Connecticut Yankee Engineering Department Instruction 3.19, Rev. I, " Inservice Inspection / Inservice Testing PDCR Review."
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The purpose.of this Engineering Department 2nstruction is to provide the means by which the Engineering Department evaluates Plant Design Change Records (PDCRs) to identify impact on any ISI or IST requirement.
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Procedure No. ACP 1.0-59, original rev., " Technical Specification Surveillance Tracking." This procedure defines responsibilities for surveillance tracking.
It applies to all Connecticut Yankee (CY) departments which are responsible for surveillance tests required by CY Technical Specifications.
This-procedures requires that on an annual basis a review / audit be done by supervisors of departments that perform surveillance procedures to implement Technical Specification surveillance requirements under their jurisdiction.
Inservice testing is included in this audit by the ISI engineering supervisor.
5, Connecticut Yankee Engineering Department Instruction 3.21, original rev., " Schedules for Inservice Testing of Valves."
This Engineering Department Instruction applies to all valves
.which are required to be inservice tested once every three months, cold shutdown, and refueling outages.
Its purpose is to identify to other departments, the tests, procedures and test frequencies required to be performed in support of the
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inservice testing program for valves.
From the above review, the inspector concluded that there is adequate administrative controls to schedule inservice testing.
4.2 Status of Inservice Testing Procedure Enhancement Program
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Connecticut Yankee surveillance test procedures (SUR's) have been undergoing revision and enhancement for approximately the last 18 months. All SUR's for inservice testing have been upgraded. A number of them are under additional review for the programmatic changes described in Section 3.0 of this report as a result of Generic Letter 89-04. The inspector noted that the reviewed IST procedures were very well writtan.
They typically included detailed steps in the body of the procedure, purpose, applicability, frequency, license or administrative requirements, references,
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prerequisites, precautions, and excellent graphics to illusttate system configurations for the procedure. Within the procedures j
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i human factors considerations such as white space, bold face type for
special notes'and warning statements to the user, and adequate space l
for sign-offs are provided.
The inspector noted that strict
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compliance with the requirements for the indepedence of the persons serving as technical reviews for the procedures was not readily apparent.
The licensee's station administrative procedure i
ACP 1.2-6.5, Rev, 23, entitled " Station Procedures" (which applies to the IST procedures discussed above) states under Section 6.7.4 i
for Administrative, Technical and Nuclear Safety Review:
" Procedure Reviewers -- The-reviewer is a person who reviews a procedure or L
revision and is not directly involved in the process of writing the procedure or_ change.
This person performs an independent review of the procedure including changes and evaluates the document for compliance with station Administrative, Technical and Nuclear Safety requirements." Upon discussing this requirement with the licensee
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and upon reviewing backup review materials, the inspector verified
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that meaningful technical reviews of the new procedure revisions i
were being conducted by competent persons in the ISI Engineering Department. The licensee indicated that due to the small number of l
people responsible for upgrading IST procedures, responsibilities
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for origination, writing, and independent review sometimes overlapped.
The inspector stated that the above overlapping
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condition is not consistent with the strict definition of Procedure
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Reviewer as stated in paragraph 6.7.4 of ACP 1,2-6.5.
The licensee then committed to review the procedure writing and review process i
and establish department guidelines which ensure that verifiable and meaningful independent reviews are conducted by persons t
knowledgeable in inservice testing. These department guidelines will more clearly define the degree of independence necessary for IST procedure writing and the role of procedure originator, writer
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and reviewer.
The licensee also stated that the procedure writing l
and review processes in other departments would be evaluated against i
ACP 1.2-6.5 for compliance.
The issue of compliance with Section 6.7.4 of administrative control procedure ACP 1.2-6.5 will remain unresolved pending the licensee's evaluation and establishment of department guidelines to ensure its compliance.
This is unresolved item number (50-213/89-23-01),
5.0 Test Metho' dology and Acceptance Criteria The inspector reviewed a sample of the licensee's upgraded procedures for technical content and compliance with the ASME Code Section XI require-ments.
The procedures reviewed include:
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SUR 5.7-66, Rev. 5, February 17, 1989, " Safety Injection Recirculation, P-24."
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SVR 5.7-116', Rev. 2, December 4, 1989, "RCP Seal Water Supply, P-74,
75, 76, 77 Local Leak Rate Test."
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SUR 5.7-169, original, October 13, 1989, " Inservice Testing by Disassembly of Service Water Check Valves SW-NRV-276A, B, C and D."
4; SUR 5.5-28, Rev. 4, July 6,1989, " Pressure Relief Valve
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Surveillance Testing."
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SUR 5.7-67, Rev. 9, March 23, 1989, " Inservice Testing of Service I
Water Isolation Valves, SW-A0V-8 and 9, SW-FCV-129 and 130, SW-MOV-5 i
and 6."
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SUR 5.7-5, Rev. 6, August 29, 1989, " Inservice Testing of Containment Sump Check Valves RH-CV-783 and RH-CV-808A".
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ENG 1.7-55, Rev.1, March 22,1989, " Documentation and Evaluation of Inservice Valves Testing".
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SUR 5.7-148, Original, March 1, 1989, " Inservice Testing of A, B, C, and D Service Water Pumps Surveillance".
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SUR 5.7-106, Rev. 3, (review pending), " Full Flow Test of HPCI and
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LPCI Systems"
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SUR 5.7-144, Rev. 1, May 4, 1989, " Inservice Testing of A and B Charging Pumps Surveillance".
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ENG 1.7-85, Original,-March 1, 1989, " Inservice Testing Pump Analysis and Documentation".
All of the above procedures have been recently upgraded as part of the IST procedure enhancement program. The inspector noted that they are all of consistently good quality as described in Section 4.2.
Also notable are the licensee's Engineering procedure numbers 7 and 11 listed above for test evaluation and acceptability. These procedures incorporated test evaluation methodologies from the latest industry standards; ANSI /ASME OM-10, July-1987, " Inservice Testing of Valves" and ANSI /ASME OM-6, July 1987, " Inservice Testing of Pumps" and meet ASME Section XI Code requirements.
For example, the establishment of reference values based on
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previous test data and degraded acceptance criteria for valves was in accordance with the new "0M-10" methodology.
This meets ASME Section XI requirements, and is consistent with position 5 in Generic Letter 89-04 for: limiting values of full-stroke times for power operated valves.
For pumps, the licensee is developing full and substantial flow test procedures which will be consistent with position No.' 9 of Generic Letter 89-04.
Position No. 9 allows the quarterly testing of pumps using minimum flow return line and full or substantial flow testing at cold shutdown or refueling outages.
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-The inspector verified that the licensee is performing prudent engineering evaluations of pump and valve testing and is maintaining proper test records in accordance with IWP-6000 and IWV-6000 for pumps and valves, respectively.
The licensee is also trending pump and valve performance and performing spectrum frequency analysis for pump vibration. The inspector also evaluated
c the licensee's methods for establishing pump baseline or reference values and found this to be in compliance wit ASME Section XI requirements. No unacceptable conditions were identified.
6.0- Corrective Action Program for Valves
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The inspector reviewed information documenting the licensee's efforts in evaluating and implementing corrective action for valves in the IST Program which seat leakage is limited to a specific amount (Category A valves) with a history of leakage problems.
It was found that the
. licensee does trend and evaluate these valves for repair or replacement and that there is evidence that their corrective action program for this has been effective, local leak rate tecting of containment isolation valves conducted during this outage indicates the total local leakage is within that allowed.per 10 CFR 50, Appendix J, that is.6La.
Credit is r
taken in the IST Program for valves tested under 10 CFR 50, Appendix J with individual leakage limits imposed on the valves per IWV-3425,
" Analysis of Leakage Rates." In this way Appendix J testing and inservice testing are related. This is also consistent with position number 10 of Generic Letter 89-04.
.The licensee has an effective corrective action program in place for trending, evaluating, and making repairs or replacing problem valves. No unacceptable conditions were identified.
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7.0 Followup of Previously Identified Open Items (Closed) UNR 50-213/88-01-01:
Implementation of Surveillance Procedure Improvement program
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This item was opened because of identified weaknesses with surveillance-procedures.
Examples cited were mislabeled valves and confusing termin-ology for the user.
Since this unresolved item was written the licensee has-implemented an utensive surveillance procedure upgrade program. The program includes both Technical Specification surveillances and those conducted to fulfill the inservice testing requirements of ASME Code Section XI.
Those surveillance procedures upgraded by the current procedure improvement program and reviewed by the inspector during this inspection were found to be of good quality as stated in Sections 4.2 and 5.0 of this report. This item is closed.
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8.0 Exit Meeting Licensee management was informed of-the purpose and scope of the
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inspection at the entrance interview. The findings of the inspection were periodically discussed and were summarized at the exit meeting on
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December 1, 1989. Attendees at the exit meeting are listed in
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Section 1.0 of this report. At no time during the inspection was written material provided to the licensee by the inspectors.
The licensee did not indicate that the inspection involved any proprietary information.
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