IR 05000277/1979019
| ML19294B340 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/11/1979 |
| From: | Caphton D, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19294B325 | List: |
| References | |
| 50-277-79-19, 50-278-79-21, NUDOCS 8002280211 | |
| Download: ML19294B340 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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50-277/79-19 Report No. 50-278/79-21 50-277 Docket No. 50-278 DPR-44 License No. DPR-56 Priority
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Category C
Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3 Inspection at:
Delta, Pennsylvania Inspection conduct d: August 29 979
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/0/5/77
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Inspectors:
W. A. Rekito, Reactor Inspector date / signed date signed
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date signed
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f Approved by:
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D.~ L. Caph'ronf, Chief, Nuclear Support
'dat'e signed Section No. 1, RO&NS Branch
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Inspection Summary:
Inspection on August 29-31, 1979 (Combined Reoort No. 50-277/79-19 and 50-278/79-21)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the inservice test program for pumps and valves, and licensee action on previous inspection findings, The inspection involved 26 inspector-hours on site by one NRC regional based inspector.
Results: One item of noncompliance was identified (Infraction - failure to meet the inservice test requirements for pumps, set forth in Section XI of the ASME Boiler and Pressure Vessel Code - Paragraph 3).
(Rev. April 77)
8002 280%{
Region I Form 12
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DETAILS 1.
Persons Contacted L. Baker, Surveillance Test Coordinator R. Fleichmann, Assistant Station Superintendent J. Mittman, Test Engineer
- S. Roberts, Results Engineer
- W. Ullrich, Station Superintendent NRC Personnel E. Greenman, Resident Inspector The inspector also interviewed other licensee personnel during the course of the inspection. They include members of the engineering and operating staffs.
- denotes those present at the exit interivewi 2.
Licensee Action on Previous Inspection Findings a.
Items Closed (Closed) Unresolved Item (277/78-03-03):
Pump bearing temperature measurements are not required due to relief request number 5.3.4 included in the Inservice Test Program Submittal to NRR, dated November 22, 1978.
As an alternate measure, the licensee will determine the condition of the pump bearings by visual inspectica when disassembled for maintenance purposes. This itemiis therefore closed.
(Closed) Unresolved Item (277/78-03-04):
The inspector verified on a sampling basis that instruments used for tests met the range and accuracy requirements of IWP 4100. Additionally, the licensee's representative stated that all instruments used for the inservice test program are verified for calibration validity on a regular basis.
This item is closed.
(Closed) Unresolved Item (277/78-03-05):
Check of valve position indicators in accordance with IWV-3300 is not required due to relief request number 5.5.6 included in the Inservice Test Program Submittal to NRR, dated November 22, 1978. As an alternate measure, the licensee verifies that remote valve indicat6rs accurately. reflect valve operations each time maintenance is performed on a valve or its operator in accordance with Maintenance Procedure M-9.1.
Thisiitem is close.
(Closed) Unresolved Item (277/78-03-07): The licensee has reviewed and NRR has concurred in the completeness of the licensee's relief valve test program as described in the Inservice Test Program Submittal to NRR, dated November 22, 1978.
This item is closed.
b.
Items Remaining Open (0 pen)UnresolvedItem(277/78-03-02):
The licensee has not yet revised Procedure ST 6.7 (Core Spray 'B' Pump, Valve, Flow Cooler Operability), to measure and evaluate pump differential pressure in accordance with Section XI requirements. See paragraph 3 of this report for expanded details of this and similar deficiencies with other pump test procedures. This item remains open.
(0 pen) Unresolved Item (277/78-03-06): The licensee has submitted a Request for Relief (No. 5.5.5) from comparing valve stroke times to previous test results in accordance with IWV-3410(c)(3). This request is acceptable to the NRC based upon the licensee's proposed alternate measure to evaluate operability by comparing the stroke time with the more conservative of two separate criteria. One of the criteria requires comparing the measured valve stroke time to the " normal" or " expected stroke time". The inspector could not find evidence of this comparison being done in the procedures reviewed. Therefore, this item remains open pending review of licensee's further action on this item.
(0 pen) Item of Noncompliance (277/78-03-08): The inspector reviewed the actions taken by the licensee to correct this item of noncompliance.
Specifically, pump and valve operability test procedures for the five systems identified were revised to include Section XI requirements and were implemented. According to the licensee's reply dated April 24, 1978, part of the reason for not meeting the original implementation date was under estimation of the complexity associated with reviewing and revising these procedures to assure that the ISI program requirements were properly implemented.
The licensee's reply also described actions taken to improve the effectiveness of their quality assurance program. They included expanding the scope of the procedure for OA "Open Items" to include licensing requirements important to nuclear safety. The reply claimed that these actions should assure by means of 0A Division checks, surveillance or audit that occurrences of this nature do not recu.
As detailed in paragraph 3 of this report, several pump operability test procedures do not meet all requirements of Section XI and therefore the licensee is still not in full compliance with 10 CFR 50.55a(g). This item remains open pending review of licensee's further corrective actions.
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Inservice Testing of Pumps and Valves a.
Documents Reviewed AE"E Boiler and Pressure Vessel Code,Section XI,
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Subsections IWP and IWV, " Inservice Testing of Pumps and Valves in Nuclear Power Plants" 1974 edition with Summer 1975 Addenda.
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Peach Bottom Atomic Power Station Inservice Inspection Program Unit 2 and Common Plant, dated August 1977 (Program Submittal to NRC)
Letters from PECO to the NRC concerning revisions to the ISI
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Program, dated November 22, 1978 and July 1979.
Procedure A-43, Revision 13, Surveillance Testing System.
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Procedure ST 6.1, Revision 9, Standby Liquid Control Pump
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Functional Test Procedure ST 6.3, Revision 6, ESW Pump, Valve, Flow, Cooler
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Procedure ST 6.5, Revision 15, HPCI Pump, Valve, Flow,
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Cooler Procedure ST 6.6, Revision 10, Core Spray 'A" Pump, Valve,
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Flow, Cooler
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Procedure a' 6.7, Revision 10, Core Spray 'B" Pump, Valve, Flow, Cooler Procedure ST 6.8, Revision 12, RHR 'A' Pump, Valve, Flow and
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Unit Cooler Functional Procedure ST 6.9, Revision 11, RHR 'B' Pump, Valve, Flow and
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Unit Cooler Functional
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Procedure ST 6.ll-A, Revision 1, RCIC Pump
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Procedure ST 6.10, Revision 10, HPSW Pump and Valve
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Operability and Flow Rate Test Procedure ST 6.11, Revision ll, RCIC Pump, Valve, Flow,
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Cooler Procedure ST 13.19, Revision 6, Standby Liquid Control
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Poison Recirculation and Pump Capacity Procedure ST 13.21, Revision 5, Emergency Cooling Water
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Pump, Bnergency Cooling Water Fans, ESW Booster Pump Operabili ty Procedure ST 12.13, Revision 1, RCIC Vacuum Relief Valve
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VRV-139A-D Functional Procedure ST 12.14, Revision 1, HPCI Vacuum Relief Valve
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Functional
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Procedure ST 13.32, Revision 2, Safety and Relief Valve Replacement Procedure ST 13.33, Revision 0, LLRT-Feedwater Check Valve
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28A, 28B, 96A, 968 ISI Testing Verification Procedure ST 13.36, Revision 0, Head Spray Check Valve
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Functional (ISI)
b.
Scope The inspector verified that all applicable pumps and valves, as identified in the Licensee's ISI Program Submittal to the NRC, were tested by approved procedures. On a sampling basis, the-inspector also reviewed the licensee's implementation program for conformance with Subsections IWP and IWV of Section XI of ASME B&PV Code along with his program submittals to the NRC. This included review of implementaing test procedures, administrative control procedures, test records, and test results evaluation records. With the exceptions noted below and in paragraph 2.b, the inspector found no discrepancies and had no further questions in this are.
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c.
Findings The inspector identi fied the following discrepancies between surveillance test procedures and specific code inservice test requirements for punps and valves.
Test records reviewed by the inspector indicated that the latest surveillance tests perfonned using procedures ST-6.5, 6.7, and 6.11 were July 25,1979, Aug ust 29, 1979, and August 13, 1979 respecti vely.
(1)
Reference Speed The HPCI and RCIC Punps have variable speed drives and Surveillance Test Procedures ST-6.5 and 6.11 do not establish a reference speed as required by IWP-3100.
(2) Variable Resistance Systen System resistance is the hydraulic resistance to flow in a system.
A variable resistance system is one wherein the hydraulic resistance is varied to duplicate a reference flow rate or differential pressure.
The HPCI, RCIC, and Core Spray are tested as variable resistance systens but ST-6.5, 6.11, and 6.7 do not specify that the systen resistance be varied to equal an established reference value for differential pressure or flow rate as required by IWP-3100.
(3)
Inservice Test Ouantities Table IWP-3100-1 identifies the test quantities (operating parameters) required to be measured during inservice tests.
ST-6.5, 6.7, and 6.11 measure punp inlet pressure and discharge pressure but do not convert this data to punp differential pressure as identified in the table.
In addition, the inspector noted that none of the surveillance test procedures reviewed measured inlet pressure before punp startup and during test as identified in the table.
(4) Allowable Ranges of Test Guantities Table IWP-3100-2 provides the acceptance criteria in the fonn of allowable ranges of test quantities with relation to comparible reference values.
ST-6.5, 6.7 and 6.11 do not evaluate punp differential pressure with limits established in Table IWP-3100-2.
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(5)
Duration of Tests Paragraph IWP-3500 requires that a pump be run for at least five minutes under stable conditions, then measure and record the required data.
The following surveillance test procedures did not address this requirement:
ST-6.1, 3, 6, 7, 8, 9, 10, 11 and 13.21.
(6) Valve Leak Rate Tests Paragraph IWV-3420 requires that Category A valves be leak-tested with specific requirements for test methods, seat leakage measure-ments and test results evaluation.
The inspector noted that the licensee had not yet issued procedures or performed these tests and that they were due during the next refueling outage. The licensee stated he would develop procedures and perform these tests during the upcoming refueling outage for Unit No. 3.
Items 1 thru 5 above are examples of the licensee's Inservice Insoection Program not meeting the requirements set forth in Section XI of the ASME B&PV Code. The licensee acknowledged this fact and committed to reviewing and correcting his implementing procedures.
Collectively items 1 thru 5 constitute an item of noncompliance of 10 CFR 50.55 a(g) at the infraction level (277/79-19-01 and 278/79-21-01).
The inspector noted that the discrepancies identified as items 2, 3, and 4 were previously identified as an unresolved item (277/78-03-02),
for procedure ST 6.7.
As of August 31, 1979, the licensee had not revised the procedure to include measurement and evaluation of pump differential pressure in accordance with Section XI requirements.
In addition, the inspector reviewed the actions taken by the licensee to correct the previous item of noncompliance (277/78-03-08) with 10 CFR 50.55 a(g).
Specifically, pump and valve operability test procedures for five systems were stated in the licensee's response letter dated April 24, 1978, addressing the item of noncompliance.(Notice of Violation dated April 3, 1978) that the procedures had been revised to include the Section XI requirements.
Each of the pertinent revised procedures (ST6.3,6.5,6.8,6.10,6.11) covering the subject systems were identified during this inspection to not include all the requirements of Section XI as stated in the licensee's response and as such continue to be an uncorrected item of noncomplianc.
Inservice Test Witness On August 29, the inspector observed a control room operator perform Surveil-lance Test No. ST-6.7 on Unit No. 2.
The inspector verified that the test was conducted in accordance with the approved procedure and that the test results appeared satisfactory.
The inspector noted that the operator appeared to be adequately trained and was knowledgeable of the procedural requirements.
No discrepancies were identified and the inspector had no further questions in this area.
5.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on August 31, 1979.
The inspector summarized the scope and findings of the inspection at that time.