IR 05000250/1987040

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Insp Repts 50-250/87-40 & 50-251/87-40 on 870908-11.No Violations or Deviations Noted.Insp Conducted to Verify Compliance W/Order for Mod of License.Major Areas Inspected: Primary Coolant Sys Pressure Isolation Valves
ML17342A931
Person / Time
Site: Turkey Point  
Issue date: 09/22/1987
From: Blake J, Kleinsorge W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17342A930 List:
References
50-250-87-40, 50-251-87-40, NUDOCS 8709300432
Download: ML17342A931 (13)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MAR I ETTA ST R E ET, N.W.

ATLANTA,GEORGIA 30323 Report Nos.:

50-250/87-40 and 50-251/87-40 Licensee:

Florida Power and Light Company 9250 Hest Flagler Street Miami, FL 33102 Docket Nos.:

50-250 and 50-251 Facility Name:

Turkey Point 3 and 4 Inspection Co ddt

, -11, 1987 Inspector:

so Approved by a e,

>e Materials and Processes Section Division of Reactor Safety License Nos.:

DPR-31 and DPR-41 ate cygne ate gne e

SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of verification of compliance with order for modification of license:

Primary Coolant System pressure isolation (Event V) valves (TI 2515/84)

and inservice testing of pumps and valves (73756).

Results:

No violations or deviations were identified.

8709300432 870925 PDR ADDCK 05000250 G

PDR

REPORT DETAILS 1.

Persons Contacted Licensee Employees

"C. J.

Baker, Plant Manager

"D.

W. Haase, SEG Chairman

"J.

A. Labarraque, Technical Department Supervisor

"B. A. Abrishami, System Performance Supervisor J. Arias, Regulatory Compliance Supervisor

"R. Hart, Licensing Engineer Other licensee employees contacted included engineers, technicians, and office personnel.

NRC Resident Inspectors

"D.

R. Brewer, Senior Resident Inspector

"J.

B. MacDonald

"Attended exit interview

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2.

Exit Interview The inspection scope and findings were summarized on September 11, 1987, with those persons indicated in paragraph

above.

The inspector described the areas inspected.

No dissenting comments were received from the licensee.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

3.

Licensee Action on Previous Enforcement Matters (92701B)

(92702B)

This subject was not addressed in the inspection.

4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

Verification of Compliance with Order for Modification of License:

Primary Coolant System Pressure Isolation (Event V) Valves.

(T1 2515/84)

a.

Background The Reactor Safety Study (RSS),

WASH-1400, identified in a PWR an intersystem loss of coolant accident (LOCA) that is a significant contributor to risk of core melt accidents (Event V).

The design examined in the RSS contained in-series check valves isolating the

high pressure primary coolant system (PCS)

from the low pressure injection system (LPIS) piping.

The scenario which leads to the Event V accident is initiated by the failure of these check valves to function as a pressure isolation barrier against reactor coolant system (RCS) pressure.

This causes an overpressurization and rupture of the LPIS low pressure piping which results in a LOCA outside of the containment.

To better define the Event V, all light water reactor licensees were requested by letter, dated February 23, 1980, to provide system design information in accordance with 10 CFR 50.54(f).

Based on licensee responses, it was concluded that a

valve configuration of concern existed at 36 plants.

On April 20, 1981, an order requiring Event V valve testing was sent to

PWR plants and two BWR plants.

This order included a

Safety Evaluation Report (SER)

and Technical Specification inserted pages to require leak rate testing of Event V pressure isolation valves.

The two additional plants had previously been issued a

licensee amendment.

Inspection (1)

The inspector reviewed the plant's technical specifications (TS)

to ensure the modification was entered as required by the Event V Order.

(2)

The inspector reviewed the below listed test proc'edures to determine whether those test procedures reflected all requirements of the TS including:

an acceptable test method is used (this would include a direct volumetric leakage rate measurement or other equivalent means capable of demonstrating that leakage rate limits given in the TS are not exceeded);

test procedure requirements which ensure that leakage rates obtained are for individual valves rather than for combined components; procedural requirements that leakage rates measures at test pressures less than-the maximum potential pressure differential across the valve be adjusted by assuming leakage to be directly proportional to the pressure differential to the one-half power (as noted in the SER which accompanies the Order);

and procedural acceptance criteria stated in accordance with the TS.

In additidn, the inspector reviewed the licensee's procedures to verify that it identified corrective actions required in the event unacceptable leakage rate results.

b.

The inspector reviewed documentation associated with the implementation of the Event V order from 1980 to present to evaluate compliance.

The specific areas examined are indicated belo Procedures Reviewed Procedure Number Title FP8 L-3-OSP-041. 18-8/4/87 FP8 L-4-OSP-041. 18-8/4/87 FP8 L-3-OSP-041. 19-8/4/87

"RCS Pressure Boundary Check Valves Leak Test"

"RCS Pressure Boundary Check Valves 3-874A and B Leak Test" FP8 L-4-OSP-41. 19-8/4/87

"RCS Pressure Boundary Check Valves 4-874A and B Leak Test" Within the areas examined, no violations or deviations were identified.

6.

Inservice Testing (IST) of Pumps and Valves (73756)

The inspector reviewed procedures, observed work activities and reviewed pertinent quality records, as indicated below, to determine whether inservice testing regulatory requirements and licensee commitments are being met.

The applicable code for IST of pumps and valves is ASME Boiler and Pressure (ASME B8PV) Code Section XI 1980 Edition Winter 1981 Addenda (SOWS1)

a.

The inspector interviewed Licensee/Contractor personnel and reviewed the below listed documents to verify that the licensee has assigned responsibilities to persons and organizations for: preparation, review, and approval of IST procedures; scheduling of IST for normal and increased frequency testing; performance of testing per approved procedures; performance of post-maintenance and post-modification IST; proper certification and calibration of IST instruments; and training for those personnel responsible for implementing IST procedures.

Documents Reviewed Procedure ID FPAL-0-ADM-100 of 7/18/87 FP8(L-AP-0109 e 1 of 6/2/87 FP8(L-0-OPS-200. 1 of 8/27/87 Title

"Procedure Preparation, Review and Approval"

"Preparation Revision, Approval, and Use of Procedures"

"Schedule of Plant Checks and Surveillances"

(cont'd)

Procedure ID Documents Reviewed Title FP8(L-AP-190. 16 of 8/27/87 FP8(L-AP-0190. 28 of 5/29/87 FPRL-AP-0190. 9 of 6/9/87

"Scheduling and Surveillance of Periodic Test and Checks Required by Technical Specification"

"Post-maintenance Testing"

"Control of Measuring and Test Equipment" b.

The inspector reviewed the below listed completed procedures to verify that these procedures are the latest ones approved and that test acceptance criteria used were valid for the component being tested.

Procedures Reviewed Procedure ID FP8(L-3-0SP-068.2-8/4/87 FP8(L-4-OSP-068. 2-2/13/87 FP8(L-0-OSP-062. 2-7/1/87 FP8 L-3-OSP-050. 2-5/28/87 FPAL-4-OSP-050. 2-3/24/87 FP8 L"OP-2104. 1 of 2/5/87 FPAL-OP-4304. 4 of 1/21/86 FP8 L-0-OSP-075. 11-8/27/87 FP8(L-3-SMM-041. 1-8/26/86 Title

"Containment Spray Pump Inservi'ce Test"

"Safety Injection Pumps Inservice Test

"Residual Heat Removal Pump Inservice Test"

"Chemical and Volume Control System-Periodic Test of Charging Pumps" Diesel'Oil Transfer System Periodic Tests of Pumps

"Auxiliary Feedwater Inservice Test"

"Pressurizer Safety Valve Set Point Testing"

Procedure ID FPSL-OP-0209m

of 8/6/87 FPgtL-OP-13404 e 1 of 7/2/87 Procedures Reviewed Title

"Valve Exercising Procedure"

"Local Leak Rate Tests"

~Pum No.

3-P201A 4-P201C P2A P2C 3-P210A 4-P210B 3-P214B 4-P214A 3-P10 4-P10 3-P215A 4-P215D

~Pum Test Procedure Reviewed Chemical and Volume Control System Charging Pump A

Chemical and Volume Control System Charging Pump C

Auxiliary Feed Pump "A" Auxiliary Feed Pump

"C" Residual Heat Removal Pump

"A" Residual Heat Removal Pump "B" Containment Spray Pump "B" Containment Spray Pump

"A" Diesel Oil Transfer Pump Diesel Oil Transfer Pump High Head Safety Injection Pump "A" High Head Safety Injection Pump

"D" Valves Examined Valve Number SV-3-6385 CV-4-522C CV-3-200C CV-4-204 NOV-3-749A Valve Cate or Valve T e

Solenoid AOV AOV AOV MOV

~Ss tern Reactor Coolant Reactor Coolant Chemical and Volume Control Chemical and Volume Control Auxi 1 iary Cooling/

'Component Coolant

(cont'd)

.

Valve Number FCY-4-626 MOV-3-843B MOV-4-869 AFS-3-005 AFS---003C RV-3-551A RV-4-1407 Val ve Test Procedure Reviewed

~Y1 B

C C

Valve T e

M V

MOV MOV Check Check Relief Relief S stem uxi iary Cooling/

Component Coolant Safety Injection Safety Injecti on Steam Steam Reactor Coolant Steam c ~

AOV-Air Operated Valve MOV-Motor Operated Valve The inspector reviewed the last six completed procedures for the above listed pumps and valves to verify that the licensee performed IST per an approved schedule within the limitations described in the IST program, including increased frequency testing.

d.

The inspector reviewed the last six comp'feted procedures for the above indicated pumps/valves to verify that inservice test results were recorded per the approved procedures and that data was evaluated within the time constraints delineated in the appropriate edition of the ASME Code Section XI, Subsections IWP and IWV.

e.

The inspector reviewed the above identified procedures for the above indicated pumps and valves to ensure that IST procedures and data reflect all requirements of the appropriate edition of the ASME Code Section XI, including: evaluations of imposing and removing increased frequency testing requirements; evaluation and justification of changes to test acceptance criteria; pump vibration test data analysis and acceptance criteria justification, including locations of vibration measurement; requirements that pump tests be conducted at reference conditions, including reference speed; compliance of test instruments to 10 CFR 50 and ASME Code requirements; performance of positive testing of Category C check valves whose safety function is to open and close; evaluation of Category A valve leak test data conducted in accordance with ASME IWV-3426 and -3427 guidelines and including containment isolation and pressure isolation valves; testing of safety and.relief valves in accordance with ASME'WV-3510 through-3513; observation of remote position indicators, including those on the remote shutdown panels, at least once every two years to verify that valve operation is accurately indicated; and indication that valve stroke times are commensurate with the capabilities of the valve teste f.

The insp'ector reviewed the data for the above indicated pumps and valves for the last six intervals to verify that IST data was evaluated per the requirements of ASME Code Section XI, Subsections IWP and IWV, and

CFR 50.55a(g)

and ensured that appropriate follow-up actions were taken.

g.

The inspector examined selected records to verify that IST records are maintained as delineated in ASME IWP-6000 and IN-6000; and engineering evaluations are sufficient to justify changes to reference values and removal of increased frequency testing requirements should be documented and revi.ewed.

h.

Relative to the above the inspector made the following observations.

(1)

Valve MOV-3-843B exhibited at last test a stroke time of 8. 3 seconds.

The licensee assigned an ultimate stroke time maximum of

seconds.

Valve MOV-3-869 exhibited, at last test, a

stroke time of 9.8 seconds.

The licensee, for reasons that the licensee could not explain during this inspection, assigned an ultimate stroke time maximum of

seconds.

The licensee indicated that they would look into this matter further and provide an answer, to this inspection, during his next visit, to the question:

Why is the ratio of Actual Stroke Time to Ultimate Maximum Stroke Time approximately one to two for valve MOV-3-843B and one to six for valve MOV-3-869.

(2)

The licensee has found that the test quantity, flow rate, for the Diesel Oil Transfer Pumps are not consistent from test to test, with the variations drifting into both the Alert and the Action-Required Ranges.

The flow rate is determined, for these pumps, by calculations, based on Physical Measurements of the fluid level in the Diesel Oil Day Tank.

It appears to this inspector that the irregularity of flow rate results are caused by lack of precision in the measurements of the fluid level in

. the Diesel Oil Day Tank.

.The licensee indicated that they are in the process of procurement of flow instrumentation that will provide the necessary precision to accurately evaluate flow rate.

The inspector wi 11 inspect in this area in future inspections.

(3)

The licensee had only informal, undocumented on-the-job training (OJT) program for personnel from the technical department who are responsible for the implementation of IST program.

The inspector discussed the above with the licensee, indicating the inherent dangers in informal undocumented programs.

The licensee indicated that they would look further into the matter, and consider the benefits of.documenting minimum OJT require-ments and the benefits of letters in personnel files attesting to the ability of an individual to perform IST unsupervised.

Within the areas examined, no violations or deviations were identifie !

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