IR 05000250/1990022
| ML17348A448 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/19/1990 |
| From: | Belisle G, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348A444 | List: |
| References | |
| 50-250-90-22, 50-251-90-22, NUDOCS 9007260172 | |
| Download: ML17348A448 (13) | |
Text
UNITE D STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.: 50-250/90-22 and 50-251/90-22 Licensee:
Florida Power and Light Company Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point Inspection Conducted:
June 18-22, 1990 Inspector:
H. L.
iten r Approved by:
ie Test Programs Section Engineering Branch Division of Reactor Safety License Nos.:
DPR-31 and DPR-41 Date Signed ate signed SUMMARY Scope:
This routine unannounced inspection was conducted in the areas of inservice testing of pressure isolation valves (PIVs)
and review of licensee action on previous inspection findings.
Results:
The licensee has developed and implemented a program of test controls and test procedures which are adequate to meet the Technical Specifications (TS) for pressure isolation valves.
A strength was identified in the pressure isolation valve testing in that the licensee has included five PIVs on each unit not required by current TS, paragraph 2.
In the areas inspected, violations or deviations were not identified.
~0072l'0172 900719 I DR ADOCK 0':-000250 Q
REPORT DETAILS Persons Contacted Licensee Employees J.
Bender, Lead Operations Procedure Writer, Procedures Group V. Edwards, Senior System Performance Engineer, Technical Department
- K. Harris, Senior Vice President, Nuclear Operations P. Jones, System Engineer, Diesels J.
Kenney, Production Supervisor, Mechanical Maintenance
- J. Mack, Inservice Test Coordinator, Technical Department
- L. Pearce, Plant Manager
- D. Powell, Licensing Superintendent W. Raasch, Balance of Plant Lead Engineer
- K. Remington, Supervisor, System Performance Group, Technical Department D. Sisk, Regulatory Compliance Engineer, Licensing NRC Resident Inspectors
- R. Butcher, Senior Resident Inspector
- G. Schnebli, Resident Inspector (RI)
T. McElhinney, RI
- Attended Exit Interview Acroynms and Initialisms used throughout this report are listed in the last paragraph.
Pressure Isolation Valves Inservice and Surveillance Testing (61701)
Pressure isolation valves (PIVs) are defined as two normally closed valves in series that isolate the reactor coolant system (RCS)
from an attached low pressure system.
PIVs are located at all RCS low pressure system interfaces.
Event V PIVs are defined as two valves in series at a low pressure/RCS interface whose failure may result in a LOCA that by-passes containment.
Event V refers to the scenario described for this event in the WASH-1400, Reactor Safety Study.
Event V PIVs are a
subset of PIVs.
On April 20, 1981, the NRC issued an Order requiring Turkey Point to include specific Event V PIVs in the TS and conduct periodic leak rate testing on these valves.
Accordingly, the licensee incorporated Sections 3. 16 and 4. 17 into the TS.
These sections identify the Event V PIVs, specify test frequency, specify leak rate limits, and define the limiting conditions for operation related to the operability of PIVs.
ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWV, Inservice Testing of Valves in Nuclear Plants, 1980 Edition, also requires leak rate testing of PIVs, as Category A or A/C valves, at,a frequency of
e ~
once each two years (IWV-3420).
IWV-3423 specifies how the differential pressure will be applied, which valves can be tested at less than function differential pressure, and the acceptable method to extrapolate test pressure to system function pressure to determine the leak rate..
The purpose of inspection activities in this area was to verify that the licensee developed and implemented procedures and controls to leak rate test PIVs consistent with both the TS and IWV requirements.,
PIVs identified in TS 3 ~ 16, Table 3 ~ 16-1 for both Unit 3 and Unit 4 are as fol 1 ows:
TABLE 3.16-1 PRIMARY COOLANT SYSTEM PRESSURE ISOLATION VALVES
~Sstem Valve No.
Maximum (a)(b)
Allowable Leaka e
High-Head Loop A, Loop 8, Loop C, Safety Injection hot leg cold leg cold leg hot leg cold leg cold leg cold leg cold leg Unit 3 3-874A 3-875A 3-873A 3-8748 3-8758 3-8738 3-875C 3-873C Unit 4 4-874A 4-875A 4-873A 4-8748 4-8758 4-8738 4-875C 4-873C-5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm Residual Heat Removal Loop A, cold leg Loop 8, cold leg Loop C, cold leg 3-876A 3-8768 3-8760 3-876C 3-876E 4-876A 4-876E 4-8768 4-8760 4-876C 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm 5.0 gpm In addition to the above PIVs, the licensee included MOV 750 and MOV 751 for each unit in the proposed revision of the TS.
These are the RHR Loop C Suction Stop Valves on Unit 3 and RHR Loop A Suction Stop Valves on Unit 4.
These valves are currently being tested each refueling outage.
The licensee also performs leak rate tests on accumulator check valves 8750, E,
and F on each unit at each RFO.
The accumulator check valves are PIVs but were not included in the NRC Order as Event V PIVs.
The inspector considered that testing important PIVs beyond the minimum TS requirements was a strength in the licensee's program; PIV leak rate test procedures were reviewed to verify that the above valves were identified and leak rate tested in accordance with TS and Subsection IWV requirements.
Procedures developed by the licensee and reviewed by the inspector during this inspection included:
3/4-OSP-041. 17 RCS Pressure Boundary Valves MOV-3-750 and/or MOV-3-751 Leak Test
l*
3/4-0S P-041. 18 3/4-OSP-041. 19 3/4-OSP-064. 2 OSP-200.2 GOP-503 RCS Pressure Boundary Check Valves Leak Test RCS Pressure Boundary Check Valves 3-874A and B Leak Test Accumulator Outlet Check Valves Leak Test Plant Startup Surveillances Cold shutdown to hot standby Plant system drawings were reviewed in conjunction with the procedure review to verify that adequate test instructions were provided.
Additionally, the inspector verified that the test methods were acceptable, leak rate data was correctly extrapolated to functional pressure leak rates, correct acceptance criteria were specified, and verification of system restoration was required.
Controls to assure that the leak tests were performed as required by plant conditions and TS were incorporated into plant startup procedure OSP-200.2.
A review of test results for a period of approximately one year including plant startups for each unit showed that the leak rate tests were performed at the frequency required by plant conditions and TS.
Based on the review of the licensee's requirements, test procedures, test controls, and test results, the inspector concluded the following:
Pressure isolation valves were correctly identified in the test procedures.
Adequate leak rate test procedures were developed and implemented.
PIV leak rate tests were performed by acceptable methods at the required frequency.
PIV test data was adjusted to the system functional pressure, 2235 psi, in accordance with IWV-3423.
PIV tests were performed within the limits, analysis, and corrective
. action requirements of Technical Specifications 3. 16 and 4.17.
Within these areas, no violations or deviations were identified.
3.
Action on Previous Inspection Findings (92701, 92702)
a.
(Closed)
UNR (250,251/89-07-01):
Investigate Discrepancies Between As-left and As-found MSSV Ring Settings In a letter to the NRC (L-89-302) the licensee addressed the results of their investigation of the discrepancies between as-left and
as-found MSSV ring settings.
Based on a Westinghouse evaluation, a
15 percent MSSV blowdown is acceptable.
The blowdown resulting from, the as-left ring settings is within this range.
The licensee concluded that the MSSVs are operable.
The licensee also traced the activities related to removal, testing, overhaul, and reinstallation of the MSSVs to identify the cause of the discrepancy in ring settings and concluded that the most probable root cause is that the ring setting values for the MSSVs were improperly recorded by the vendor during as-received inspection.
The licensee initiated several actions to prevent recurrence including:
Installation of marker plates on each MSSV showing as-left ring settings after repair and testing.
Revision to Maintenance Procedures 1507. 1, Steam Generator Safety Valve Repair and Setting, and 1507.5, Steam Generator Safety Valve Removal and Replacement.
Review of Dresser Valve Repair and Inspection Procedures to recommend improvements as appropriate.
The inspector reviewed documentation which supports the following:
Installation of marker plates on the MSSVs Revision of maintenance procedures 1507. 1 and 1507.5 Changes in the Dresser Repair and Inspection Procedure to reduce potential error by verifying ring settings by the use of a gauge rather than counting notches, to verify ring pin and cap seals, and to verify proper ring settings prior to MSSV inspection and subsequent to final testing.
The inspector concluded that the licensee has performed the actions identified in letter L-89-302.
b.
(Closed)
Violation (250,251/89-07-02):
Failure to Adjust PSV Ring Settings Following Setpoint Testing and Maintenance in Accordance with Procedures During the 1987 RFO Unit 3 PSVs 551A and B were setpoint tested in accordance with procedure 3-SMM-041. 1 and PSV 551C was repaired and setpoint tested in accordance with procedure 3-CMM-041. 1.
Both of these procedures require that the as-found ring settings be documented and the rings returned to these positions after testing.
The licensee reset the rings according to vendor recommendations which conflicted with the test procedure In response to the violation (letter L-89-175),
the licensee identified the actions taken to correct the failure to follow procedures which included an evaluation of the operability of PSVs with the current nozzle and guide ring settings and training in the'esponsibilities for Conduct of Maintenance for Maintenance and Technical Staff.
The inspector reviewed the documentation of training in the Conduct of Maintenance, NI-700, and the Westinghouse safety evaluation, SECL 89-361, Rev.
1, which concluded that the current nozzle guide ring settings are acceptable.
Procedures 3/4-SNM-041. 1 and 3/4-CMM-041. 1 were revised to reflect the Westinghouse and Crosby recommended nozzle ring settings of -16, Unit 3 guide ring settings of 235 and Unit 4 guide ring settings in the range of 230 to 275 determined to be acceptable in the safety evaluation.
(Closed) Violation (250,251/89-07-03):
Failure to Revise Procedures to Recognize Correct PSV Ring Settings In response to the violation (letter L-89-175),
the licensee identified that the failure to set ring settings on Unit 3 PSVs to the as-shipped values in the 1987 RFO was due to a failure to transmit information dated August 12, 1986, to the Procedure Update Group.
Corrective action involved a
Westinghouse evaluation to verify that the current PSV ring settings were acceptable, revision of procedures 3/4-CMM-041. 1 and 3/4-SMM-041. 1 to reflect as-shipped ring settings values, and implementation of a Technical Department tracking system to ensure actions are tracked to completion.
The licensee identified the failure to use as-shipped ring settings when PSV 551B was replaced on Unit 4 in the 1988 RFO as a procedural deficiency; specifically, procedures 4-CMM-041. 1 and 4-SMM-041. 1 addressed valve repair but did not address the use of as-shipped ring setting values for a replacement valve.
Corrective action involved the Westinghouse safety evaluation that the 551B PSV current ring settings were acceptable and revision to procedures 3/4-CMM-04. 1 and 3/4-SMM-041. 1 to incorporate the proper as-shipped ring settings for PSV 551B and a caution that procedure changes were required if a PSV was replaced.
The inspector reviewed the Westinghouse safety evaluation, SECL 89-361, Rev.
1 and procedure 3/4-CNM-041.1 and 3/4SMM-041.1 to verify that the current nozzle and guide ring settings for PSV 551B are acceptable, that procedures 3/4-CNM-041. 1 and 3/4-SMM-,041. 1 specify, correct as-shipped ring setting values, and that proper action is identified to achieve as-shipped ring settings if a PSV is replace (Cl osed)
IFI (250,251/89-07-04):
Perform Special Testing and Implement Single Element EDG Fuel Oil Filter in EDG Operating Procedures Duplex filters at the pump discharge were being operated as a dual element.
As a result, the EDG must be taken out of service to replace the filters.
The licensee performed testing of the EDG, TP523, and verified acceptable operating characteristics in the single filter element mode.
The inspector verified that the licensee has implemented single filter element operation and has revised procedures to support this operation as follows:
0-OP-023 Emergency Diesel Generator 0-OSP-023/1 Diesel Generator Operability Test (Closed) Violation (250,251/89-07-05):
Failure to Increase Inservice Test Frequency and Take Adequate Corrective Action In the response to the violation (Letter L-89-175)
the licensee identified the root cause of the violation as a
procedural deficiency.
Procedure OP 209. 1, Valve Exercising Procedure, Step 8.3.2 allowed retesting to establish operability if a valve failed to meet the proper stroke time on the initial test.
The corrective action specified a revision to OP 209.1 to require that only the initial stroke time was used to determine surveillance frequency.
The inspector verified that the revision of OP 209. 1 required appropriate action based on the initial stroke test.
Also, interviews with Technical Department personnel indicated that the practice of restroking a valve has been discontinued.
The inspector concluded that the licensee has met the action specified in Letter L-89-175.
(Closed)
IFI (250,251/89-07-06):
Failure to use Abnormally Low Stroke Times to Determine Test Frequency In practice, when a stroke time was initially abnormally low, the licensee used a previous normal value to establish test frequency.
Interviews with Technical Department IST personnel and review of test records show that this practice has been discontinued.
Test frequency is based on the previous measurement even though an abnormally low measurement followed by a
normal measurement may result in increasing the test frequency on a valve.
The licensee considers that the revision of OP 209.1 requires the use of the previous initial measurement to establish test frequenc.
Exit Interview The inspection scope and results were summarized on June 22, 1990, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed above.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Licensee Management was informed that six open items were reviewed and closed during this inspection.
5.
Acronyms and Initialisms ASME EDG IST LOCA MOV MSSV NRC PIV(s)
PSV(s)
American Society Mechanical Engineers Emergency Diesel Generator Inservice Testing Loss of Coolant Accident Motor Operated Valve Main Steam Safety Valves Nuclear Regulatory Commission Pressure Isolation Valve(s)
Pressurizer Safety Valve(s)
Reactor Coolant System Refueling Outage Residual Heat Removal Temporary Procedure Technical Specification(s)