IR 05000245/1981009
| ML20011A075 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/14/1981 |
| From: | Caphton D, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011A073 | List: |
| References | |
| 50-245-81-09, 50-245-81-9, 50-336-81-09, 50-336-81-9, NUDOCS 8110060531 | |
| Download: ML20011A075 (8) | |
Text
.
,'
-
-
.
.
U.S. NUCLEAR REGULATORY COMNIS5 ION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-245/81-09 Report No. 50-336/81-08 50-245 Docket No. 50-336 DPR-21 License No. DPR-65 Priority
--
Category C
Licensee:
Northeast Nuclear Energy Company P.O. Box '70 Hartford, Connecticut 06101 Facility Name:
Millstone Nuclear Power Station, Units I and 2 Inspection At:
Waterford, Connecticut Inspection Conducted:
May 26-29, 981 Inspectors:
(
9/
W.A, Rek'ito, Reactor Inspector d6te 6igned
date signed
.
Approved By:
I bdNMw---
fc__
9//kif/
0.L. Caphton', Acting, Chief, Test Programs date signed Section, Engineering Inspection Branch Inspection Summary:
Inspection on May 26-29,1981 (Combined Report No.
50-325/81-09 and 50-336/81-08)
Areas Inspected:
Routine, unannounced inspection of the inservice testing program for safety related pumps and valves (Unit 1), and licensee action on i
previous inspection findings. The inspection involved 25 inspector-hours onsite by one region based NRC inspector.
Results: One item of noncompliance was identified at Unit 1 (Failure to meet the ASME B&PV Code requirements for inservice testing of pumps and valves, Paragraph 3).
Regian I Form 12 (Rev. Ap il 77)
.
l
!
i 8110060531 010918 gDRADOCK 05000245 PDR
.-
-
-
-
.
-
- -
- -
-
- -
-
-
- - -
.
-
-
- - - -
-
-
-. -
-
-
.
-
.
.
,
.
OETAILS 1.
Persons Contacted The following is a list of technical and supervisory personnel who were interviewed and provided information to the inspector.
T. Blanchard, ISI Coordinator (Unit 2)
- R. Herbert, Unit 1 Superintendent J. Leason, ISI Technician
'
E. Levinson, Engineer (General Physics Corp.)
- E. Mroczka, Station Superintendent
- K. Thomas, Senior Engineer U.S. Nuclear Regulatory Commission
- D. Lipinski, Resident Inspector
- T. Shediosky, Sei.ior Resident Inspector
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (336/79-20-01):
Corrective Actions required by ASME 6&VP Code IWP 3230(a) not specified. The licensee issued revision 1 to Operability Evaluation Procedure EN 21101 on October 12, 1979 which specified that corrective action include increasing test frequency when test values fall within the " Alert Range" of acceptance criteria. This item is resolved.
(Closed) Unresolved Item (336/79-20-02):
Inadequate procedural guidance for corrective action required when test values fall within the "Re-quired Action Range" of acceptance criteria. The licensee revised Operability Evaluation Procedure EN 21101 to require that any evaluation and determination of corrective action be completed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of test completion. Additionally, e licensee acknowledged the fact that when pump test results are first recognized to fall within the " Required Action" range it is to be declared inoperable per Technical Specifications.
For valve testing, the licensee revised applicable procedures EN 21127, EN 21128, EN 21129, EN 21130, EN 21131, EN 21132, EN 21133, EN 21134, EN 21135, and EN 21136 to include the maximum stroke times allowed for all safety related power operated valves and that any required corrective action be initiated immediately. Additionally, J
'
.
.
the licensee acknowledged the requirement of IWV-3410 and IWV-3520 to declare a valve inoperable if its unacceptable condition cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This item is resolved.
(Closed) Unresolved Item (336/79-20-03):
Pump test procedures did not address minimum run time requirements of IWP-3500. The licensee revised all applicable pump ooerational readiness test procedures to require that a pump be run at least five minutes under stable conditions before the required data be obtained. This item is resolved.
(Closed) Unresolved Item (336/79-20-04): Method of testing check valves which perform a dual safety function.
The licensee has revised applicable check valve testing procedures to include testing in both open and closed directions and that methods verify prompt valve position changes as required by IWV-3520. The inspector reviewed procedure EN 21130, revision 1 "RBCCW System Operational Readiness Tests" and EN 21136, revision 2, " Safety Injection and Containmcat Spray System Valves Operational Readiness Tests" as a sampling of these revised procedures and found them acceptable. This item is considered to be resolved.
(Closed) Unresolved Item (336/79-20-05):
Stroke time testing of valve 2-FW-43A. The licensee notified NRR of their re-evaluation and decision to revise the " Maximum Stroke Time Allowed" for this and other power operated valves in the test program. Tha inspector determined that these actions were acceptable and this item is considered resolved.
(Closed) Unresolved Item (336/79-20-06): Test instrument calibration requirements. The licensee has completed installation of all permanent test gages in accordance with Plant Design Change Notice #2-112-79 in support of the IST program.
In addition, all existing meters and gages used for inservice testing are included in the station I&C periodic calibration program. The inspector determined that this action satisfies the requirements of IWP-4113.
This item is resolved.
(Closed) Unresolved Item (245/79-15-03): No acceptance criteria for snubber piston extension.
The licensee has included the requirement to measure snubber piston rod extension dimensions as step 7.6 of Procedure SP 673.2, revision 3, " Inspection of Hydraulic Snubbers."
The inspector reviewed this procedure and found it and the acceptance criteria for all safety related snubber piston rod settings contained in Table 1 to be acceptable. This item is resolved.
(Closed) Unresolved Item (245/80-19-01): Various inadequacier, identified in the draft procedur prepared for the Containment Integrated Leak Rate Test (CILRT). The licensee addressed these concerns in approved procedure SP 623.13 revision 2, " Primary Containment Integrated Leak Pate Test," which was used to conduct the CILRT on April 11-14, 1981.
The inspector reviewed procedure SF 623.13, revision E, and determined that it satisfied each of the six concerns identified and met the requirements of 10 CFR 50 Appendix J.
This item is resolved.
a
,'
-
.
.
,
(Closed) Unresolved Item (245/80-19-02): The draft CILRT procedure did not provide adequate vent paths outside the containment isolation valves (CIVs) for the Head Spray and Atmospheric Control Systems. The licensee corrected this problem in approved 9rocedure SP 623.13, revision 2, and stated that all other systeu valve line-ups in the procedure were reviewed to ensure that applicable CIVs were subjected to the test differantial pressure. The inspector reviewed the valve line-ups in Appendix D to procedure SP 623.13, revision 2 and verified that the Head Spray and Atmospheric R ntrol Systems were vented outside of the CIVs and no artificial leakage barriers existed. This item is resolved.
(0 pen) Unresolved : tem (245/80-19-03): Containment leak rate testing requirements for the Reactor Building Closed Cooling Water (RBCCW)
System. In a letter to the NRC dated November 6,1980, the liceqsee corrected an error in its earlier correspondence dated September 20, 1978 regarding conformance to 10 CFR 50, Appendix J, which stated that the RBCCW valves (RC-6 and RC-15) were tested during the CILRT. The letter further stated that these isolation valves could not be local leak rate tested with the existing system configuration and described plans to complete necessary modifications and include the isolation valves in the local leak rate test program.
The inspector determined that the proposed local leak rate test method was appropriate and would achieve greater conformance with 10 CFR 50, Appendix J.
This item will remain open pending completion of the licensee's planned actions.
(Closed) Ur. resolved Item (245/80-19-04): The draft CILRT crocedure improperly isolated and vented the drywell atmosphere pres;ure switches.
The licensee recognized this error and corrected the problem in approved procedure SP 623.13, revision 2.
The inspector reviewed che valve line-ups in Appendix 0 to procedure SP 623.13, revision 2 and verified that all instrument isolation valves were required to be in their normal operating position causing the drywell atmosphere pressure switches to become part of the containment test boundary.
This item is resolved.
3.
Inservice Testing of Pumps and Valves a.
Documents Reviewed
--
ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWP and IWV, " Inservice Testing of Pumps and Valves in Nuclear Power Plants" 1977 edition with Summer 1978 Addenda.
--
Millstone Station, Unit 1, Inservice Inspection and Testing Program (Second Ten Year Interval), submitted to NRC.on September 18, 198 *
...
.
.
.
.
.
--
Procedure ACP-QA-9.06, revision 3, Inservice Inspection Program.
Procedure SP 1060, revision 3, ISI Program Pump Vibration
--
and Hydraulic Test (Fump Hydraulic Data Sheets 1-14).
Procedure SP 1061, revision 1, ISI Valve Timing Program.
--
--
Procedure SP 608.2, revision 0, Reactor Feedwater Pump Readiness Test (ISI).
--
Procedure SP 608.5, revision 0, Service Water System Readiness Test (ISI).
Procedure SP 621.10, revision 2, Core Spray System Operability
--
Test.
Procedure SP 621.11, revision 0, Core Spray Remote Valve
--
Indicator Check (ISI).
--
Procedure SP 608.15, revidon 1, Reactor Feedwater Power Operated Valve Readinees Test (ISI).
Procedure SP 608.17, revision 0, Diesel Generator Service
--
Water Inlet Valve Readiness Test (ISI).
--
Form SP 1060-15, revision 0, ISI Fump Test Plan for Core Spray Pumps CS M8-74 A, B.
--
Form SP 1060-2, Core Spray Pump Vibration and Hydraulic Test-Data Sheets from tests dated 7/17/80, 8/12/80, 9/16/80, 5/7/81.
--
Form SP 1060-15, revision 0, ISI Pump Test Plan for Fuel Pool Cooling Pumps M4-11A, B.
--
Form SP 1060-17, Fuel Pool Cooling Pump. 'er+.fon and Hydraulic Test-Data Sheets from tests dated 8/20/80, 1-44/80, 5/7/81.
--
Form SP 1060-15, revision 0, ISI Pump Test Plan for Service Water Pumps M4-7 A, B, C, D.
--
Form SP 1060-8, Service Water Pump Vibration and Hydraulic Test-Date. Sheets from tests dated 8/21/80, 9/16/80, 5/14/81.
--
Form SP 1060-15, revision 0, ISI Pump Test Plan for Feedwater Pumps M2-10 A, B.
--
Form SP 1060-3, Reactor Feedwater Pump Vibration and Hy-draulic Test-Data Sheets from tests dated 9/4/80, 9/30/80.
i
.
-
- --
-.
-
.-
--
.-
-
- --
- _.
_
.
-
--
-=
... -
.'
..
.
.
.
,
b.
Scope The inspector verified that applicable Code Class 1, 2, and 3 pumps and valves, as identified in the Inservice Testing Program Description, were being tested by approved procedures. The inspector also reviewed the documents listed above and interviewed responsible personnel to ascertain the adequacy of the inservice testing program implementation. The acceptance criteria included technical acd administrative requirements in Subsections IWP and IWV of Section XI of ASME B&PV Code, licensee's approved Inservice Test Program Description, Technical Specifications, and inspector
-
Judgement.
.
c.
Findings The inspector identified the following discrepancies between surveillance testing procedures and specific code inservice test requirements for pumps and valves.
Test records reviewed by the inspector indicated that the latest surveillance tests performed on the Feel Pool Cooling Pumps, Service Water Pumps, and Reactor Fcedwater Pumps were May 7, 1981, May 14, 1981, and September 30, 1980 respectively.
(1) Pump Inservice Test Method
The pump operability surveillance test procedure SP 1060, along with the individual Test Plans (Form SP 1060-15) for the Fuel Pool Cooling, Reactor Feedwater, and Service Water Pumps do not specify that the system hydraulic resistance be varied to equal an established fixed reference value for differential pressure or flowrate as required by the code article IWP-3100, Inservice Test Procedures.
The inspector further noted that the provision in procedure SP 1060, permitting certain pumps to be tested at the "As Found" flow condition is not in accordance with the licensee's Inservice Test Program-Flow Measurement Relief Request (Note
,
'
3) which states that an established set of referen::e con-ditions will be utilized for each test.
The inspector discussed with the licensee the importance of performing inservice tests in the prescribed manner for adequately monitoring and detecting changes in the hydraulic operating performance of the pump.
(2) Reference Values Code article IWP-3110 defines reference values as a set of values for certain operating parameters of a point of operation readily duplicated during subsequent 1* service tests and re-
-
-.. ~
,, -
-. _ -. _. _.. -, _
,
J
-.
.
...
.
,,
a
quires that they be established during a single test per-
,
,
formance.
Procedure SP 1060 deviates from this requirement by permitting an optional method of establishing Pump Test Base Line Data (reference values) by analysis of tests over a six month or greater period.
.
'
(3) Differential Pressure Measurement The licensee's Inservice Test Program Differential Pressure Relief Request (Note 5) identified a lack of suction pressure indication for the service water pumps and described an alternate test method of measuring pump discharge pressure and sea level for equivalent suction pressure.
The ISI Pump Test Plan (Form 1060-15) for the service water pumps does not include measuring sea level as required. As part of this review the inspector determined that the requested
-
exemption from evaluating service water pump differential pressure was not justified. The licensee acknow' edged this fact and stated that both the test procedure and the test program description would be revised.
i (4) Allowable Ranges of Test Quantities Table IWP-3100-2 provides test acceptance criteria in the form of allowable ranges of measured test quantities with relation to the comparible reference values. The acceptance criteria of Procedure SP 1060 deviates from this requirement by permitting, as an option, use of a pump characteristic curve in lieu of established reference values for pump flowrate and differential pressure.
(5) Corrective Action for Pumps Article IWP-3230 requires specific corrective actions be taken when test values fall within the " Alert Range" and
" Required Action Range" of the acceptance criteria. The inspector also identified the NRC position that a pump must be declared inoperable as soon as test results are recognized as being within the " Required Action Range." The Technical Specification Action statement time starts when this determination is made. The pump test data analysis section of Procedure SP 1060 does not satisfy these requirements since no corrective action is required when test results fall in the " Alert Range" or " Corrective Action Range" and are considered not to be detrimental to pump operation. Also, there are no provisions to assure prompt recognition of unacceptable test results and initiation of Technical Specification required remedial actions.
_
_
_
.
.
__
_
-
_-
_
-
.
. -.
..
.
.
..
-
,
,,
.
(6) Corrective Action for Valves Article IWV-3410 and IWV-3520 requires that corrective
'
action be initiated immediately if a valve fails to exhibit the required change of disc position during a test and the valve is to be declared inoperable if the unacceptable
condition cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The valve testing implementation procedures do not satisfy the above requirements in that the acceptance criteria of specific valve test procedures SP G08.15 and SP 608.17 only state that "The test shall be considered satisfactory provided the data is recorded on the data sheet." Also general valve test procedure SP 1061 does not provide assurance for:
timely recognition of unacceptable test results, immediate initiation of corrective actions, or initiation of remedial
'
actions required by Technical Specification.
Items (1) thru (6) are examples of the licensee's Inservice Testing Program failure to meet requirements set forth in Section
,
XI of the ASME B&PV Code. The licensee acknowledged this fact
+
'
and committed to reviewing all inservice test procedures and correcting these and any other discovered inadequacies prior to September 1, 1981.
Collectively items (1)_thru (6) constitute an item of noncompliance of 10 CFR 50.55a(g) and Technical Specification 4.13 B. (245/81-09-01)
4.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on Mav 29, 1981. The inspector summarized the scope and findings of the inspection at that time.
With regard to the item of noncompliance described in Paraucaph 3, the Station Superintendent ackr;wledged the various inadequacies of the Inservice Testing Program and committed to correcting the identified problems and to achieve conformance with code requirements by September 1, 1951.
I
,
r
....
, -
-- -
... -,,
-,__._,...,...m...-,m.
mm.,,,....
,.
. ~,,