IR 05000275/1985021
| ML16341D268 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/06/1985 |
| From: | Clark C, Dodds R, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341D267 | List: |
| References | |
| 50-275-85-21, NUDOCS 8507010242 | |
| Download: ML16341D268 (14) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-275/85-21 Docket No. 50-275 License No. DPR-76
. Licensee: Pacific Gas and Electric Company 77 Beale Street Room 1451 San Francisco, California 94106 Facility Name:
Diablo Canyon Unit 1 Inspection at:
San Luis Obispo County, California Inspection.'condu ted'
ril 22-26,
Inspector:
Cla
,
eactor Ins ector Da e Signed Approved By:
. You g, hx.ef, Engineering Section Da e
igned R.
odds, C ief, Reactor Projects Section
~Summar:
Ins ection durin the eriod of A ril 22-26 1985 (Re ort No. 50-275/85-21)
review of the program plan, procedures and records pertaining to the Diablo Canyon Unit 1 inservice testing program for pumps and valves.
The inspection involved a total of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> onsite by one NRC inspector and one consultant.
Results:
No violations of NRC requirements or deviations were identified.
85070i0242 850&ii PDR ADOCK 050002
P
~
~
DETAILS Persons Contacted
!.
"-R. Thornberry, Plant Manager
"-D. Miklush, Maintenance Manager
'"L. Womack, Engineering Manager
"-M. Angus, Sr.
Power Production Engineer
)
-"Denotes those attending the exit interview on Apri'l 26, 1985.'nservice Testin (IST) Pro ram Plan Inservice testing is required to be performed'in nuclear power plants in accordance with the ASME Boiler and Pressure Vessel Code by 10 CFR 50.55a(g).
The ASME Code, Section KI, Subsections, IWP and IWV outline the rules for inservice testing of pumps and valves.
For Diablo Canyon Unit 1, a listing of systems, components, and tests types and frequencies are detailed as part of a document titled "Inservice Inspection and Testing Program Plan:
First Ten-Year Interval" (Revision 1).
In May 1983, this program plan was submitted to the NRC Office of Nuclear Reactor Regulation (NRR) for review and approval.
At the time of this inspection, NRR was completing its review but had not issued the SER or other formal comments on the pump and valve testing portion of this program plan.
As approved in 1981 by NRR in NUREG-0675, Supplement 13, the applicable ASME Code edition for this program is the 1977 Edition through the Summer of 1978 Addenda.
A specific request for relief in the submitted Program Plan specified the 1980 Edition, through Minter 1980 Addenda for pump test frequencies.
This program applies to 23 safety related pumps and approximately 350 valves.
The inservice testing program is required to be in place and fully implemented at the time of commercial operation.
However, the implementation of the program at Diablo Canyon has been phased in as systems were accepted by the operations staff.
The IST Program Plan was reviewed for compliance with the applicable edition(s) of Section XI of the ASME Code and the requests for relief detailed in the plan.
The types and frequencies of tests appear to be in compliance with Code requirements.
As noted in NRC Inspection Report 50-275/85-11 the program plan for Unit 1 has not been issued as a formal controlled document with preparer, reviewer and approved signatures or effective page change records.
There were no violations of NRC requirements identified.
IST Pro ram Procedures The Diablo Canyon IST program plan is implemented through various site procedures.
'These procedures were reviewed for one IST program.
AP C-80, Rev.
1, "Inservice Inspection Program"
~
~
1 I I
I 4'
(
II I
"I I
~4 I
I>
I FF lyli Ih,
'1th r I
I r,'
,1, II V
tg
~,
I s,
g'
I'
4 It hy
'tli
.4 '-;
h C'
It I
,)
)Iit, (
1,
V
'c r
I'
t
I'
V II if I
lt I
I
h h
'
4 I'
AP E4 S7, Rev. 0, "ISI and IST Program Plan Control" AP C-750, Rev.
4, "Preventive Maintenance Program" AP C-6S3, Rev.
0, "Post Maintenance Testing" AP C-3S1, Rev. 5, "Surveillance Testing and Inspection" NPAP C-40, Rev. 2, "General Requirements'or Plant Maintenance Programs" In general, the above listed procedures piovided the information and guidance necessary to adequately manage and control IST activities.
Responsibili,ties for maintenance operability determinations required by the Code were detailed.
However, procedu're A'P C-80, 'while appaxently very detailed and thorough with rega'rd,to ISl,requirements," is very weak in defining the specific responsibilities of, the engineering staff controlling the IST effort.
This adminiptrative procedural weakness appears to have contributed to 'some of the problems, noted in lower tier procedures and records as discussed later.
,The above identified weakness was discussed with the licensee, and 'they, agreed to review and clarify as necessary (Follow-up Item No. 50-275/85-21-01).
Plant Manual Volume 9 (Temporary Procedures and Instruction),Section III, (Pump Data), Table IIB-1 Rev ll, entitled
"Pump Routine Surveillance Test Acceptance Criteria," provides the detailed tabulations of reference values and alert/action acceptance criteria for'operability determination on all pumps.
The only deviation from the ASME Code noted was that no
"Alert Range" criteria was specified for pump bearing temperatures as described in sections IWP-3210.
The NRC inspectors consider that the data sheets of this procedure should reference the source of the current reference values, e.g., test procedure and date.
This is desirable to provide more assurance that the most current data is being used to evaluate each pump parameter.
The licensee agreed to review the above identified section of volume 9 and applicable data sheets, and make changes as necessary to meet the applicable requirements (Follow-up Item No. 50-275/85-21-02).
Procedure AC-Pl to 17, Rev.
2, "Acceptance Criteria for Pump Routine Surveillance Test," consisted of summary tables of reference values; action alert values, cross checks to Technical Specification requirements and other source information such as calculations of pressure head values from various tanks.
This procedure provides the "working" information needed to input acceptance criteria to Plant Manual Volume 9.
However, the data in this procedure did not appear to be well organized/catalogued and in fact had not been updated to reflect the current reference values provided in Volume 9 for the Auxiliary Feedwater Pumps.
The licensee agreed to review this procedure and revise it as necessary for clarification, etc.
(Follow-up Item No. 50-275/85-21-03).
Functional data for trending and operability assessments is obtained using Surveillance Test Procedures (STP).
The following test, procedures were reviewed:
STP P-lB, Rev.
6, "Routine Surveillance Test of Safety Injection Pumps"
~
r P
t, rl f 1 h
'i!
lr Hi I
V
Li l
~
~
STP V-2, Rev. 5, "Exercising and Position Verification of Power Operated Valves" STP V-3, Rev. 5, "Exercising Safety Related Valves-General Procedure" STP V-600, Containment Leakage Administrative Procedure STP V-2J, Rev. 2, "Position Indicator Test-Outside Containment Isolation Valves" STP V-43, Rev. 3, "Functional Test of the ECCS Check Valves at Cold Shutdown" STP V-352 and STP V-3R1, "Exercising of Motor Operated Valves" STP M-77, Rev. 3, "Safety and Relief Valve Testing" In general, test procedures appeared'dequate to meet Code and site IST program requirements as to data required, gage calibration, operability determinations, trending of results an'd overall methodology.
Five items of concern were identified.
(a)
No provision is made for a summary of pump corrective actions as required by Section XI, Subsection IWP-"6250.
I t
(b)
The requirements for "scheduling of safety and relief valve tests and evaluations are not established by procedures.
As a result, current published test schedules foz these valves do not meet'requirements of Code Subsection IVV 3510.
The 3,icense'e'-!stated they were writing a procedure to cover these v'alves, and th'at they would, revise the test schedules to meet the identified requirements.
As these valves probably will not be tested again unt:il',the first refueling outage, this error does not present'.
'an immediate concern or an actual violation of Code test frequency requirements.
(c)
Pump test procedures did not specify any tolerance for establishment of system flow rates used to determine and verify acceptable differential pressure values.
Vaziations 'in flow result directly in variations in differential pressure.
(d)
Valve stroke timing procedures did not have a specific precaution/requirement to take data on the first operation of the valve.
Cycling of the valve prior to the test of record would not necessarily result in a stroke time reflective of the emergency condition operation.
(e)
The leakage tests for Reactor Coolant System pressure isolation valves did not determine actual leakage rates and thus leakage rates were not being trended.
As 14 of these 18 valves are at least
inches in diameter, Subsection IWV-3427 requires trending of leakage rates to establish the need for increased testing frequency or corrective action.
These valves are only being tested per Technical Specifications to determine that leakage is less than one gallon per minute.
This question will be referred to NRR for resolutio ~
'I
~
I f
'I I hl I
I fi
)
If Yl lh
il lt ff I
fl I
Ya>
C'l I
II I
I
1; I
I
>I} I I.
Yf '
".
$'
YY i"'J r
r
I h
I I
lt
'i I
I I
I'
f II ll I
~I'rfr Y
ii I
Cl I
ll p'I I
I If r
lf I
I After reviewing items (a) through (d) above with the licensee, the licensee stated he would review its IST program in these areas and make any changes necessary to resolve the a'bove 'items of concern (Follow-up Item No. 50-275/85-21'-04).
i There were no violations of NRC requirements,'.identified.
r 4.
IST Records (
'I a.
~Pum s
I I
The pump inservice testing recor'ds
'and 'selected individual completed test data sheets were examined for, the following pumps for compliance with Section 'XI and site procedural requirements.
Safety Injection (SI) Pumps 1'nd 0" Reciprocating Charging Pump
Component Cooling Water (CCW) Pump
Auxiliary Feedwater (AFW) Pump
A number of discrepancies were noted in the records examined.
Pump Inservice Test Records summarizing all test data for each pump are maintained by the Power Production Engineering group that performs all data review, trending and final determination of operability.
These summary test records did not include reference values nor indicate the person entering the data or the date of encoding.
Reference values are a vital part of the evaluation/tendencies process and should thus be included in the chronological data summary.
Possibly as a result of this omission, engineering evaluations were done erroneously and had to be corrected during subsequent reviews of the data.
Several discrepancies were noted in the test records for CCW pump No.
1.
In tests conducted on 7/84 and 10/84 suction pressure was below the specified action limit yet no change in test frequency was initiated.
In tests conducted 4/10/84 and 5/29/84 flow vs differential pressure results were outside the action line or off scale of the pump performance curve.
These tests were accepted by engineering with no corrective action taken or explanation provided.
For SI Pump No. 2, the bearing temperature was not taken during the first test in 1985 (2/5) as required by site procedure STP P-1B and the Program Plan.
This does not however violate the Code requirement that bearing temperatures shall be measured during at least one inservice test each year.
Several instances were noted where out of calibration or uncalibrated gauges had been used and the test data had been accepted by engineering (CCW 1 on 7/17/84, AWF 1 on 3/7/84).
No explanation or indication of recalibration/evaluation was provided on the documentation.
The licensee stated after the completion of this NRC inspection that records showed those particular gauges had in fact been in calibration on the test dat F pr p ~I p
n L
I HH I
pr H
~
~
The licensee stated they would review the above identified discrepancies and take the necessary actions required to evaluate and resolve the discrepancies (Follow-up Item No. 50-275/85-21-05).
b.
Valves Test record summary sheets were reviewed for various valves tested by STPs V-2J, V-4B, V-3S2, V-600 and V3R1 addressing exercising, position indicating, leakage and stroke timing.
In general, Code, Program Plan and test procedure criteria were met, data was clearly summarized and evaluations properly done.
However several discrepancies in engineering evaluation activities were noted.
For valve PCV-20, the stroke time measured on 2/3/84 exceeded the 125%
of previous test limit of the Code but no operability determination or engineering signature was indicated on the summary sheet.
In a number of cases the words
"new baseline" were simply entered on the logsheet and the operability block changed from "no" to "yes" with no reference to a plant problem report or other technical justification.
The plotting of valve leakage xates for txending as required by Section XI, Subsection IMV-3427 for six inch and larger valves did not appear to be performed in a thorough and controlled manner.
Due to the structure of the forms being used, data was plotted, but no signature or date by the evaluating engineer was indicated.
On some charts as many as nine data entires were made, but only two signatures appeared on the document.
In many cases, tests had been performed in January 1985 that had not yet been plotted.
The licensee stated they would review the above identified discrepancies and take the necessary actions to evaluate and resolve the discrepancies (Follow-up Item No. 50-275/85-21-06).
c ~
~Summa@
Hany of the discrepancies noted above wert isolated cases and of a relatively minor nature.
In addition, the IST program does not become fully effective until. commercial operation.
However, the number and variety of errors and omissions noted in the documentation that has been generated during the last few years under the IST program indicated a 'need for significant improvement.
The adequacy of procedural gui,delines and the implementation of requirements by engineering needs to be evaluated and upgraded.
!'j!
.
At the completion of this inspection the licensee stated this was the first extensive look at their'XST program implementation.
Based on the information and questions generated during this'nspection, the licensee stated he would'eview'its IST program and make any changes necessary to ensure it met all,applicable requirements.
!
W There were no violations of NRC requirements identifi'ed.
!!
!
L!
y!
~
~
I lt
,d II 0'
I t
t V
N t
5.
Hana ement Heetin The inspectors met with licensee paragraph 1 at the conclusion of scope, observations and findings man'agement personnel denoted in the inspection of April 26, 1985.
The of the inspection were discusse ~ qg
~
~
h, C
I I'
~"'t4
~\\
I
~a Il I
I'
I Ir It
, 'I
'I gl
"
I I;
I I"
I i(
'(
I
'I l
rr't (!
I I '"
Iti It I