IR 05000245/1987009

Insp Rept 50-245/87-09 on 870420-24.Potential Enforcement Findings Noted:Failure to Make Repts to NRC Per 10CFR50.72 & 50.73,to Take Corrective Action Per 10CFR50,App B,Xvi & to Control Testing Procedures Per 10CFR50,App B,Vi

ML20234D299
Person / Time
Site:	Millstone
Issue date:	06/22/1987
From:	Baker E, Paul Prescott, Stone J Office of Nuclear Reactor Regulation
To:
Shared Package
ML20234D185	List: IR 05000245/1987009 ML20234D181
References
50-245-87-09, 50-245-87-9, NUDOCS 8707070164
Download: ML20234D299 (11)

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UNITED STATES NUCLEAR REGULATORY COMMISSION

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'0FFICE OF NUCLEAR REACTOR REGULATION

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Report No.: 50-245/87-09 Docket ho.: 50-245/87-09 License No.: DPR-21 Licensee: Northeast Nuclear Energy Company Facility: Millstone Nuclear Power Station, Waterford, Connecticut Inspection At: Millstone Unit 1

. Dates: April 20 through 24, 1987 Inspectors: %M L/ 7 Edward T. Baker, Team Leader, Program Development Da'te and Reactive Inspection Section (PDRIS)

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Peter J. Prescott, PDRIS

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l Consultant: Paul Farron, Nuclear Engineers and Consultants, In ;

Approved By: h 4/22/p James C. Stone, Chief PDRIS, Vendor Inspection Date Branch .,

t Inspection Summary: Inspection on April 20-24, 1987 (Report No. 245/87-09).

Areas Inspected: This was a special, announced inspection which was conducted at Millstone Unit 1 to determine to what extent the ASME Boiler and Pressure  ;

Vessel Code,Section XI, and 10 CFR 50, Appendix J, valve testing programs verified check valve disk integrity. The inspectors also reviewed the licensee's response to INP0's SOER 86-3, concerning check valves. The arehs inspected included maintenance and testing records, inspection and testing procedures,valvelocationwithrespecttoflowdisturbances(e.g.,elbowsand pump discharges), and system drawing Resul ts': Three potential enforcement findings (PEFs) and four open items were identified auring the inspection. The PEFs involved failure to make reports to the NRC as required by 10 CFR 50.72 and 50.73, failure to take corrective action to prevent recurrence as required by Criterion XVI of Appendix B to 10 CFR 50 and failure to control testing procedures to assure adequacy as required by Criterion VI of Appendix-B to 10 CFR 5 a70701

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PDR ADOCK 05000245 G PDR l

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l DETAILS

. Persons Contacted 1 John Barnett, Unit 1 Engineer -

l Robert Eppinger, NUSCO Richard Hykys, NUSCO John Leason, Unit 1 Engineer Dave Odland, Unit 1 Engineer John Quinn, Unit 1 Engineer Stephen Scace, Station Superintendent John Stetz, Unit 1 Superintendent Trudy Thull, Unit 1 Engineer Charles Wargo, Unit 1 Maintenance Geoffrey Grant, NRC Resident Inspector Monte Conner, NRC Project Engineer The inspector also held discussions with other licensee employees during the inspectio All those listed above were present at the exit meeting on April 24, 1987. Scope The licensee's programs for testing, inspecting, and performing maintenance on check valves were reviewed to determine the adequacy of the programs to i ensure disk and seat integrity. The licensee's response to INPO's SOER I 86-3, concerning check valves, also was reviewe . Licensee Action on Previously Identified Problems This subject was not addressed in this inspectio . Review of Check Valves Using the Millstone Unit 1 trobabilistic risk assessment and failure data from licensee event reports (LERs) and other sources, the inspectors selected 54 check valves in 16 different systems for inspection. The 54 check valves consisted of 21 pump discharge and 33 in-line valves. The inspectors physically examired 23 of these valves for location with regard to proximity to flow disturbances (e.g., elbows, pump discharges) and reviewed testing procedures and maintenance / failure history for all 54 valves. A description of the results of this review for each check valve application follow .1 Automatic Pressure Relief / Automatic Depressurization System.(APR/ ADS)

System testing of redundant check valves 1-AC-164/165 A, 1-AC-164/165 B, 1-AC-164/165 C, 1-AC-164/165 D 1-AC-164/165 E, 1-AC-164/165 F is performed during refueling outages in accordance with Station Procedure SP1091 and Engineering Form 1091-1. Discussions with the licensee and a review of past test results revealed that the ADS has repeatedly failed the leak testing performed during each refueling outage. The licensee has replaced the hard-seated check valves in the lines with redundant NUPRO soft-seated,

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spring-loaded check valves and switched.from an air to a nitrogen operating

, system to improve reliability. However, the November 2, 1985 leak test of the ADS with the soft-seated check valves installed also was unsuccessfu Maintenance records on these check valves are minimal. The valves were inaccessible for viewing during the plant walkdown, but the licensee f was able to show the NRC. inspectors pictures of the valve and accumulator '

locations as well as providing a representative spring valve for inspectio During further discussions with licensee representatives, it became apparent that the NRC had not been notified, via 10 CFR 50.72 reporting or other means, of the leakage test failures occurring on Ncvember 2, 1985 (8 of 12 soft-seat check valves that could render the ADS inoperable). Four of the six accumulators failed the leak. test due to leakage through the check valves (8 valves) and one accumulator failed due to rupture of flexible piping. The licensee identified the cause of the check valve failures as rust particles on the seat of the valves; but apparently took no action to prevent recurrence of the proble The latest correspondence to the NRC [W. B. Council (Nortneast Utilities (NU)) to W. A. Paulson (NRC), dated August 13, 1984, " Qualification of ADS Accumulators"] states that the supply header to the accumulators is not seismically qualified. Therefore, in the event of a seismic event the check valves must isolate the accumulators from the supply heade The licensee's failure to report to the NRC that 4 of 6 ".DS accumulators ;

failed to pass the leak rate test due to 8 of 12 check valves leaking is )

considered a potential enforcement finding (PEF 50-245/87-09-01). The j licensee's failure to take corrective action to prevent recurrence also 1 is considered a potential enforcement finding (PEF 50-245/S7-09-02).

4.2 Emergency Core Cooling System (ECCS) Condensate Fill System The ECCS condensate fill system, check valves 1-CS-19/20A and B, are not tested under the plant's inservice testing (IST) or Appendix J, test programs and a review of the system maintenance records showed that no work has been performed on the valves. The 1-CS-19/20A valves were inspected during the plant walkdown. The two valves are located in series approximately 2 inches apart, adjacent to 90 elbows on both ends, approximately 4 inches from the inlet and outlet of the respective valve The system is included in the plant Technical Specifications and is required to maintain operability of the low-pressure ECC including isolating the low pressure piping when the ECCS actuates. However, in the absence of testing or inspection, it is not clear how the operability of these check valves can be ensured. The failure to include these valves in the IST program is considered an open item (50-245/87-09-03) and is pending hRC's Region I review of the September 26, 1985 version of the IST progra .3 Core Spray Systeni The NRC inspectors reviewed the Millstone Ur it 1 Final Safety Analysis Report (FSAR) Table 6.2-4, which listed the principal penetrations of primary containment and associated isolation valves. .During.this review, it was noted that two check valves (1-CS-6A and 1-05-6B) associated with the core spray system were listed as primary containment isolation valve . ,' -

Therefore, according to the requirements of 10 CFR 50, Appendix J valves

. 1-CS-6A and 1-CS-6B should receive a test intended to measure the isolation valve leakage rate because these valves are relied on to perform a con-tainment isolation function. To ensure that these check valves received the' required leak rate testing, the inspectors reviewed the licensee's core spray system inservice test (IST) procedure and the Appendix J testing program. The NRC inspectors also reviewed Drawing No. 25202-26008, Sheet 1, Rev. 1, issued August 14, 1986, entitled, " Piping and Instrumen-tation Diagram Core Spray System." The review was performed to determine i if the present piping configuration allows for adequate leak rate testing !

I to be performed for the seal integrity of the subject check valves. During the review, it was noted that the present piping configuration has test !

taps that would allow leak rate testing of the check valves. In addition, the system has a high-pressure indicator that would alarm if the check valves passed excessive flow in the reverse direction, indicating that major damage had occurred to the check valves. However, Station Procedure SP-621.2 only required testing the valve to pass flow. Licensee personnel stated that valves CS-6A and B have not been leak tested under either the Section XI, or the Appendix J, test program In a letter from the licensee to the NRC, dated November 19, 1980, updating Millstone Unit 1 compliance with Appendix J, check valves CS-6A and B are neither listed as exempted or requiring testin In a letter from the NRC to the licensee, dated May 22, 1985, a draft SER was issued to the licensee concerning the Millstone Unit 1 Section XI, IST program. The SER stated that check valves CS-6A and B were considered pressure isnlation valves and were to be leak teste On September 26, 1985, the licensee responded to the NRC concerning the draft SER by sending a revised IST program; however, the licensee did not indicate that CS-6A and B would be leak tested and no exemption was requeste NRC Region I currently has the September 26, 1985 revision of the IST program for review and approval. The lack of testing on check valves CS-6A and B is considered an open item (50-245/87-09-04) pending Region I's neview of the IST progra ;

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As a result of the interviews and a review of the maintenance records, the NRC in'spectors determined that no corrective or preventive maintenance had been performed on these check valves since initial l installation. NU maintenance personnel also stated that formal preventive !

maintenance is not scheduled unless the valves exhibit a history of high-failure rate .4 Emergency Service Water System testing is performed in accordance with Station Procedure SP623.1 Gross flow testing of check valves 1-LPC-1A, B, C, and D is performed in the forward and reverse direction. There is no maintenance history on the check valves and no Appendix J testing is required or performe The check valves were inspected during the plant walkdown. The check valves are 'nstalled at the discharge of the emergency service water l system's pumps. Ninety degree elbows are attached to the outlet of each of the check valve *

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4.5 Feedwater Pump Discharge Check Valves i Feedwater pump discharge check valves IFW-2A, B, and C were selected for review because of their failure history at other plants, including. San Onofre, as described in INP0's SOER 86-3. The system testing of these check valves is performed in accordance with Station Procedures SP608.13 and SP608.26. This testing is perfonned quarterly and during normal pump startup while increasing plant power output. Testing is performed for forward and reverse flow. The check valves are reverse-flow tested by j observing one or more of the following: i (1) The valve is heard to clos (2) i;o reverse rotation of an idle pump shaft is observe (3) The pump discharge pressure of the standby pump approximately equals pump suction pressur l These are the standard means for ISI reverse-flow testing of all pump i

discharge check valves at Hillstone Unit 1. The licensee had not estab-lished how high a leak rate was needed to cause reverse rotation of the pump or cause pump discharge pressure on the idle pump to exceed suction pressur l The review of the maintenance history on these valves revealed that the valves had been damaged and repaired on several occasions. Most notsble was the damage discovered during the 1984 refueling outage. At that time the B feedwater regulating valve just downstream of the check valves was inspected because of valve operating problems. When the regulating valve was disassembled, bolting and locking devices from the pump discharge check valves were found lodged in the feedwater regulating valve. Since this discovery, at least one of the three check valves (1-FW 2A, B, C)

is inspected each refueling outag The feedwater system pump discharge check valves have a history of degradation at Millstone Unit 1. This may be partially caused by high system operating pressures and flow disturbances in the proximity of the check valves. It is unclear that the reverse flow testing would adequately detect degradation of the check valves because leakage through the check valves could be diverted through the feedwater mimimum flow recirculation valves to the main condenser. The feedwater minimum flow recirculation valves 1-FW-14A, B, and C also have had a history of valve degradation. During each outage, the mimimum flow recirculation valves were disassembled. The valve seats and disks were inspected and found to be severely eroded, allowing leakage to the main condenser. During the 1984 outage, valves 1-FW-14A, B, and C were replaced with valves from a different manufacturer. The new recirculation valves will be disassembled and inspected during the next refueling outag An inspection of the 1-FW 2A, B, and C check valves was performed during the plant walkdown. The check valves were located approximately 7 feet downstream of the pump discharge with a 90 elbow attached to the valve inlet. The pump discharge manual isolation valve was also approxiniately 2 feet downstream of the pump discharge check valves. Adcitionally, other-4-

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I turbulence generators were within a few feet of the valves. No Appendix J testing is required or performed on these valves.

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4.6 Feedwater Isolation Valves l

Feedwater Isolation check valves FW-9A, 9B,10A, and 10B are soft-seated !

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valves that are local leak rate tested under the Appendix 0 test progra As such, disk and seat integrity is verified each refueling outag I 4.7 Isolation Condenser

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System check valve testing is provided in Station Procedure SP608.2 l Check valve 1-IC-11 in the common supply line to the condenser is tested for

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gross forward flow each refueling outage. The normal water supply is from the fire protection system through check valve Fire-48, which also is forward-flow tested. Neither valve is tested for reverse flow. A i failure of check valve 1-10-11, and to a lesser extent valve Fire-48, could adversely affect system operability. The system is configured such that valve 1-1C-11 can be reverse-flow tested, if desired. As viewed 1 in the plant walkdown, the check valves are in close proximity to manual l and flow control valves; but, cecause of their infrequent use, it would i not be expected that the valves would be damaged from flow turbulenc l Check valve Fire-48 is directly downstream of a 90 elbo There was no maintenance history on these check valves nor was there any )

Appendix J testing required or performe .8 Low-Pressure Coolant Injection (LPCI) (In-line Valves)

l The NRC inspectors reviewed Millstone Unit 1 FSAR Table 6.2-4, which listed the principal penetrations of primary containment and associated isolation valves. During this review, it was noted that two check valves (1-LP-11A and l 1-LP-11B) associated with the LPCI system were listed as primary containment i isolation valves. Therefore, according to the requirements of 10 CFR 50, Appendix J, these valves (1-LP-11A and 1-LP-118), which are relied on to i perform a containment isolation function, should receive a test intended to measure the isolation valve leakage rate. To ensure that these check valves had received the required leak rate testing, a review of NU's IST procedure and the Appcndix J testing program was performed. The NRC inspectors also reviewed Drawing No. 25202-26008, Sheet. 2, Rev. 1, issued August 14, 1986, entitled " Piping and Instrumentation Diagram LPCI System." The review was performed to determine if the present piping configuration allows for adequate leak rate testing to be performed for the seal integrity of the subject check valves. During

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the review, it was noted that the piping configuration allows for leak rate testing of the check valves by utilizing the four 3/4-inch

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vented test connections (No. 1-LP-71 A/B and No. 1-LP-80 A/B) installed on either side of valves 1-LP-11A and 1-LP-11B. However, as a result of the IST records reviewed, the NRC inspectors determined the licensee had not performed the required leak tes s Under Station Procedure SP608.23, both valves are tested to pass flo . ," .-

The NRC inspectors reviewed maintenance from January 1980 through April

- 1987 for the subject valves. Maintenance History Documents JO #8225625098 and JO #8213925529 revealed that check valve 1-LP-11B had been disassembled ano visually inspected on two occasions (11/12/80 and 03/27/81) per Maintenance Procedure No. MP716.1, Rev. 2, entitled " Overhaul of Globe, Gate and Check Valves." The NRC inspectors also reviewed Maintenance History Document JD iMI-85-11206, which modified valves 1-LP-11A and 1-LP-116 by installing drain valves to facilitate seat leak rate testin However, as a result of the maintenance history provided, the NRC inspectors determined that check valve 1-LP-11A had not been visually inspected since its original installatio In a-letter from the NRC to the licensee dated May 22, 1985, the NRC sent a draft SER to the licensee concerning the Section XI, IST program for Millstone Unit 1. The draft SER stated that 1-LP-11A and 11B were con-sidered pressure isolation valves and were to be leak tested. On September 26, 1985, the licensee responded to the NRC concerning the draft SER with a revised IST program; however, the licensee did not indicate that 1-LP-11A and 11B would be leak tested. NRC Region I currently has the September 26, 1985 revision of the IST program for review and approva In a letter from the licensee to the NRC dated November 19, 1986, updating Millstone Unit I compliance with Appendix J, check valves 1-LP-11A and 11B are neither listed as exempted or requiring test. The lack of testing on 1-LP-11A and 11B is considered an open item (50-245/87-09-05) pending Region I's review of the IST progra .9 Low-Pressure Coolant Injection Pump Discharge Check Valves Pump discharge check valves 1-LP-3A, B, C, and D are tested in accordance with Station Procedure SP622.7. This procedure was written to perform check valve gross flow testing in the forward and reverse direction Because of the sequence of running the pumps, only two of the four pump discharge check valves can be reverse-flow tested using the test criteria established in SP623.7. The failure to test all four valves is one of the examples on which Potential Enforcement Finding 50-245/87-09-06 is base An in-plant inspection of the 1-LP-3A and 3B check valves and piping (typical of all four) revealed that the valves were in close proximity to several turbulence generators. A piping tee (T) was located 2-3 feet upstream of the check valves while an isolation valve and elbow were located just downstream of the check valves. The valves are 12-inch check valves, Model No. 323A, manufactured by Chapman. The 1-LP-3C check valve is suspected of having reverse-flow leakage and is scheduled for maintenance during the next refueling outage. The high system operating pressure and location of flow disturbances may have contributed to the degradation of this valv There is no current maintenance history on these check valves. No 10 CFR 50, Appendix J, testing is required or performed on these valve ._ ,.

. 4.10 Reactor Building Closed Cooling Water (Inline)

Check valve 1-RC-6 is the containment isolation valve inside containment I on the inlet piping. The valve is tested for passing flow only (and not reverse flow or leak tested) under Station Procedure 1094. Maintenance records, available back to 1980, indicated that the valve had received no maintenance in that time frame nor had any failures been detecte The licensee indicated that manual isolation valves had been purchased to be installed on either side of 1-RC-6 so that leak testing could be i performed. However, the November 19, 1986 submittal concerning Appendix I J modifications states that an exemption will be requested based on the RBCCW being a closed syste .11 Reactor Building Closed Cooling Water (Pump Discharge)

Station Procedure SP-1087 requires both forward- and reverse-flow testing of check valves 1-RC-2A and 28. Maintenance records, available back to 1980, indicated that no maintenance had been perfcrmed on the valves !

and that the valves had experienced no failures in that time fram During the plant tour these valves were inspected. The valves are located directly between two 90 elbows, with the upstream elbow attached to the pump discharge and a throttle valve attached to the outlet of the downstream elbow. Pump 25 was running and a banging noise was heard in the vicinity of the check valve. On closer inspection, the noise did not appear to be originating from the valve. However, as evidenced by San Onofre's experience in troubleshooting a banging noise in the vicinity of a check valve, it is extremely difficult to accurately pinpoint the origin of the nois Following the San Onofre water-hammer event, the banging noise in the general vicir,ity of a check valve was found to be caused by the check valve disk being hammered to failure on the bonnet sto .12 Reactor Vessel Head Coolitig Station Procedure SP608.21 provides for flow testing of the 1-HS-5 check valve in the forward direction each refueling outage. Since check valve 1-HS-2 is in this same line, it also is flow tested in the forward direction. Additionally, check valve 1-HS-5 is the inboard isolation .

valve for head cooling and is leak tested in accordance with Appendix J !

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No maintenance history was available on either valve 1-HS-5 or 1-HS- Both valves were inaccessible during the in -plant inspectio .13 Reactor Water Cleanup ]

Valve 1-C0-29 was chosen because the licensee had indicated to the i NRC Project Manager that it would receive "special treatment" because it !

is a containment isolation valve inside containment and the normally open motor-operated valve outside containment was not environmentally ;

qualified and may not close when called upon if it is exposed to a steam environmen !

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. The NRC inspectors reviewed FSAR Table 6.2-4, which listed the principal penetrations of primary containment and associated isolation valve During this review, it was noted that check valve 1-00-29, associated with the reactor water cleanup system, was listed as a primary contain-ment isolation valve. Therefore, per the requirements of 10 CFR 50, Appendix J, this valve, which is relied on to perform a containment isolation function, should receive a test intended to measure the isolation valve leakage rat The NRC inspectors also reviewed NU Drawing No. 25202-26008, Sheet 2, ;

Rev. 1, issued November 25, 1986, entitled " Piping and Instrumentation Diagram Reactor Water Cleanup System." This review was performed to determine if the present piping configuration allows for adequate leak testing to be performed for the seal integrity of check valve 1-C0-2 Because of inconsistencies between two drawings showing adjacent portions of the system, the NRC inspectors were unable to determine if the present piping configuration includes the necessary test taps for leak testing of the check valve. The licensee informed the inspectors that a procedure covering the testing of valve 1-CU-29 did not exist and that the valve was not tested under the Appendix J or the IST progra The NRC inspectors also reviewed maintenance records from January 1980 through April 1987 for the subject valve. Maintenance History Document ,

R-342-80 revealed that the valve had been disassembled on November 12, 1980 to replace the valve's seal ring and was visually inspected per Maintenance Procedure MF716.1, Rev. 2, entitled " Overhaul of Globe Gate and Check Valves."

The inspectors did not see any testing or inspection requirements which would indicate that the valve was receiving "special attention." This lack of testing for isolation function is considered an open item (50-245/87-09-07) pending NRC's Region I review of the September 26, 1985 version of the IST progra .14 Service Water Station Procedure SP-1086 requires that pump discharge check valves i V4-11A, 11B, 11C; and 110 be tested in the forward- and reverse-flow {

direction. A review of maintenance records indicated that valve 11C l received a new disk on February 18, 1981; valve 11D was inspected and reassembled (nonewparts)onFebruary 25, 1981; and 11A was rebuilt on July 31, 198 All four valves were inspected during the plant walkdown. The valves are attached directly to the pump discharge with a 90 elbow attached to the valve outle .15 Shutdown Cooling

System testing is performed in accordance with Station Procedure !

SP623.20 and Engineering Procedure (EP) 1060-38. In reviewing these l documents, it was discovered that the procedures did not contain provisions for testing pump discharge check valves 1-SD-3A and B I

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as required by the IST program. Further research with the licensee revealed that the check valve testing was deleted with Revision 5 to

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SP623.20 on August 28, 1986. The testing of check valves 1-SD-3A and 3B was supposed to be transferred to EP 1060-38. However, the valve test requirements were never added to EP 1060-38. During this inspec-tion the licensee immediately started a procedure change to correct the NRC-identified deficiency. Since August 1986, the plant has been in cold shutdown cnce and the plant operator had noted on the operations data form that the check valves operated properly. The operator verified this operation even though the procedure did not require it. This failure to adequately control test procedures is one of the examples on which Potential Enforcement Finding 50-245/87-09-06 is base !

Review of past operations forms and procedures (SP623.20) indicated that the check valves were required to be tested for gross forward flow but not reverse flo There was no maintenance history on check valves 1-SD-3A and 3B nor was there any Appendix J testing required or performe .16 Standby Liquid Control FSAR Table 6.2-4 lists check valves SL-7 end SL-8 as the containment isolation valves for this system. Station Procedure SP-661.2 requires these valves be tested to pass flow at each refueling outage. Addi-tionally, valve SL-7 (outside containment) is local leak rate tested under the Appendix J test progra During the plant walkdown, check valve SL-7 was inspected and was not located in proximity to any flow disturbance A review of maintenance records indicates that valve SL-7 was rebuilt on October 18, 1982, and the seat and disk were lapped on May 22, 1984, after the valve fat'.:d the local leak rate test. A review of the records also indicates that check valve SL-8 (inside containment) has never been tested, other than to pass flow, and has received no maintenanc .17 Turbine Building Secondary Closed Cooling Water Station Procedure SP-1088 requires that check valves SC-2A and 2B be 1 forward- and reverse-flow tested. These valves were inspected during the plant walkdown. The valves are attached to 90 elbows on both the valve inlet and outlet, with the upstream elbow attached to the pump discharg A review of maintenance records, available back to 1979, indicated no failures and no maintenance performed on the valve ,

I ER Response At the time of the inspection, the licensee had not developed a formal

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response to the 50ER. The inspectors discussed with a licensee represen- I tative the status and content of the response. The licensee indicated that information had been collected from all nuclear sites and a corporate-9-

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response was being prepared and that preventive maintenance would be

. initiated on an unspecified number of valves.. The discussions did not 3 elicit any indications that significant changes would be made to the Mi11 stone Unit 1 inspection and testing programs for check valve ,

6. Exit Meeting

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The inspectors met with the licensee representatives denoted in Section 1 on April 24, 1987, and presented the findings of the inspection.

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DISTRIBl' TION:

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Docket File 50-245 .

VIB Reading DRIS Reading j JPartlow BGrimes EMerschoff ,

JStone l EBaker PPrescott j DCrutchfield FSchroeder CThomas MBoyle I

TMarsch RBaer GGrant, Region I TRebelowski, Senior Resident Inspector

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