IR 05000289/1988006

Insp Rept 50-289/88-06 on 880222-26.No Violations or Deviations Noted.Major Areas Inspected:Pump & Valve Inservice Test Program Implementation & Review of Procedures & Test Results

ML20151G602
Person / Time
Site:	Three Mile Island
Issue date:	03/31/1988
From:	Eapen P, Joe Golla, Gregg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151G597	List: IR 05000289/1988006 ML20151G593
References
50-289-88-06, 50-289-88-6, NUDOCS 8804200064
Download: ML20151G602 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-06 Docket N License No. OPR-50 Licensee: GPU Nuclear P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted: February 22-26, 1988

Inspectors: , .

7- 5/- SS yseph . a, Re tor Engineer date ndM yaroldGregg, Senior y ctor Engineer a date-at-sL Approved -

t 5 4fp 3-3/~U Vb P . K . D pe'n , C h t'gf Special Test date Programs Section, EEr, RS Inspection _ Summary: Inspection on February 22-26, 1988 (Inspection Report No. 50-289/88-06)

Areas Inspected: Routine unannounced inspettion of pump and valve inservice test program implementation and review of procedures and test result Results: No violations or deviations were identified. Four open items pertaining to inservice testing were closed. One unresclved item involving the close-out of Information Notice 86-05, Main Steam Safety Valve ring settings was identifie (89 PDR O

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OETAILS 1.0 Persons Contacted 1.1 GPU Nuclear D. Atherholt, Operations Engine 3r (IST)

"R. Barley, Manager, TMI-1 Plant Engineering

• J. Bashista, Plart Engineer (IST)

• J. Colitz, Plant Engineering Director

• J. Herman, QA Lead /uditor

• C. Smyth, TMI-1 Licensing Manager U.S. Nuclear Regulatory Commission

"R. Conte, Senior Resident Inspector

• Denotes thuse present at the exit meeting held February 26, 198 .0 Inspection Purpose and Scope This inspectior. was conducted to review and assess the licensee's implementation of their pump and valve inservice testing (IST) program commitments and other activities associated with IST implementatio Verification of adherence to regulatory requirements, ASME Section XI requirements and licensee's commitments as well as consideration of safe;s consequences, and organizational structure were reviewe Also, four unresolved items pre /iously identified by the NRC pertaining to IST were close .0 IST Program History and Organization The inspector reviewed the licensee's last IST pump and valve program submittal and background history. Discussions were held with cognizant IST personnel concerning the program, relief requests and resolutions of review concerns. The following inspector determinations were made:

• The IST program is a separate and distinct program and not a subdivision of Inservice Inspectio * The licensee's second ten year interval IST submittal was nade to NRC on March 3, 198 ,_ ._

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• A meeting between the Office of Nuclear Reactor Regulations (NRR)

and their consultant and the licensee was held in Bethesda, Maryland on October 27, 1986 to discuss the licensee's second ten year submitta * The licensee submitted a revised submittal on December 24, 198 + NRR issued a Safety Evaluation (SE) for the licensee's second ten year program on March 19, 198 * The licensee submitted supplemental IST information on February 19, 1987. A supplement to the SE was requested by the license * The licensee submitted additional information concerning several diesel generator air start valves on September 17, 198 * The licensee's second ten year interval is from September 1984 to September 199 * The IST program is committed to ASME Section XI 1980 Edition through winter 1980 Addend The inspector also reviewed the IST organizational status and determined that implementation of the IST effort is defined and controlled through Administrative Procedure 1041, titled IST Program Requirements. This procedure defines responsibilities of personnel and provides an overview on the types of testing and retesting to be performed and the conditions for testin Each pump and valve in the program is listed together with the test procedure number (s) of the IST required test. This procedure contains the IST program implementation requirements and is maintained as a controlled documen Within the organizational structure, the IST coordinator develops test procedures and verifies that all IST components are included, and reviews all unsatisf actory result The IST Coordinator reporting chain is through the Plant Engineering Department. Operations performs the testing, and an operations engineer reviews the results to assist with the evaluation. The overall scheduling for all Technical Specification surveillances is handled through a computerized program under Plant Materie The personnel involved with IST were knowledgeable and dedicated to the IST of pump and valves. Test result records were noted to be properly recorded and readily availabl Management was also cognizant and responsive to the IST implementation effort No violations were identifie , _ _ _ .

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. 4 4.0 Review of Surveillance Procedures and Test Resul y 4.1 Procedure 1300-3B A/B, Oecay Heat Removal System Pump and Valve Operability Test The inspector reviewed the Control room copies of the completed results of the testing performed on 3/14/87, 6/19/87, 9/20/87, and 12/21/87. This procedure covered the testing of both the pumps and valves on a 92 day surveillance frequency when the system is in service. The inspector's review of these test records concentrated on the valve stroke testing requirements and the test results. The 3/14/87 records showed the stroke times for valve DH-VSA of 1 seconds and for valve OH-V5B of 21.5 seconds to have increased greater than 25*. and the test deficiency sheet noted these valves as inoper-able even though the limiting stroke time was 24 seconds. The test results also discussed that the observed stroke time was due to replacements of 1/2 speed motors on the valve operators. The licensee redefined the stroke time acceptance limits based on actual recorded stroke times of 19.8 seconds for valve OH-VSA and 21.5 seconds for valve DH-V5 The surveillance test results of 9/20/87 and 12/21/87 were reviewed by the inspector and found to be acceptabl .2 Functional Testing of Pumps The inspector reviewed the following completed procedures for pump testing from the most recent and two prior surveillances:

• 1300-35 Boric Acid Injection System Functional Test

+ 1300-38 A/B Decay Heat Removal System Pump and Valve Operability Test

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1303-11.42 EFW Flow Test from CST The procedures included test acceptance criteria, prerequisites and precautions, and step by step instructions to perform the test The procedures also required test instrumentation calibration due dates to be filled i The inspector verified that the required parameters for pumps (flow, vibration amplitude, etc.) are being monitored and recorded per ASME Code Section XI requirement The inspector noted that all sign-offs and supporting documentation for maintenance anci retest work were completed properly. Adrai ni stra tive control, t W efora, appeared adequat ,_ ._____

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. 5 4.3 Test Schedule Adherence The inspectors verified that test surveillance intervals wern adhered to for the inservice testing of pumps and valves described t the surveillance procedures in sections 4.1 and 4.2. This was accomplished by an audit of recorded test results which demonstrated adherence to the ASME Code Section XI requirements for the inservice testing surveillance frequency of pumps and valve No violations were identifie .0 Main Steam Safety Valves The inspector reviewed the licensee's activities related to NRC's Information Notice (IEN) 86-05. This notice described potential problems with Main Steam Safety Valves (MSSVs), where improper ring settings adjustments could result in insufficient lift and insufficient capacit The inspector determined that the licensee has 18 Dresser MSSVs, 9 for each of two steam generators (S/G). Sixteen of the valves, (8 on each S/G) are 6" x 10" model 3707-RA ano two are 3" x 6" model 3747-A (one on each S/G). The licensee had considerable documentation regarding the ring settings of their MSSVs which included: internsi memoranda, (memos 3310-86-0132 of June 17, 1986; 3310-87-0052 of April 6, 1987; 3310-87-0038 of March 13, 1987), Drester letter dated March 27, 1986, phone conversa-tion record with Dresser on October 31, 1985, Inspection and Repair Reports dated 3/13/87 and 2/11/87, a safety evaluation SE 000411-001 of November 18, 1985, and GPU General Maintenance Procedure 1404-4 Repair of Main Steam Safety Valves. The licensee's ring settings are known and are recorded. Based on information from the vendor and licensee evaluation followed by some ring setting changes, the licensee considered their action to be sufficient to close IEN 86-0 While the licensee has maintained extensive documentation and was knowledgeable of the issues, the inspector expressed a concern that the acceptance of the current as left ring settings was somewhat judgmental since there is no available test result data to correlate with the actual settings. Additionally, the settings of the 18 valves vary to a great degree and are not the Dresser generic recommended setting The licensee's as left ring settings from the 6R outage varied from -3 to -9 on the lower ring and from +104 to +248 on the upper ring (number of notches from the seat plane reference).

The inspector reviewed the Dresser letter of 3/27/86 which stated that Dresser 3707 RA valves have been full flow tested at Wyle Laboratories, and that full lift was obtained at virtually all ring setting Ring settings of -8 rotches (lower ring) and +160 notches (upper ring) were rer.ommended for model 3707 RA valves. In an earlier phone conversation

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, record _of 10/31/85, Dresser recommended -5 to -6 on the lower ring and

+200 on the upper r,ing for 3707-RA valves, and -8 for the lower ring and

+160.for the "Q" or "No. 4" 3747-A valve The licensee had refurbished 15 valves during the 6R outage. There was a full power trip in September 1987 af ter two months of operation and the licensee's representative viewed the stack discharges and described the

, following MSSV operational aspects. All 18 valves appeared to nave a sharp' opening and reseated without relift. On trips prior to this refurbishment, they had to open steam dumps to lower the pressure to enable reseatin During the exit meeting the licensee mentioned that they may have full flow tested an MSSV and would try to locate the data. Subsequently, the licensee determined that a full flow test was not performed. This item is unresolved pending the licensee obtaining test result data or other data that can be correlated to their MSSV ring settings (50-289/88-06-01).

6.0 QA Involvement The inspector reviewed the audit report for the 1987 QA audit of the TMI-1 IST program. This audit verified that procedures to properly implement the program were prepared and that testing was conducted per the procedures. The audit also verified that pump testing procedures

.would include the measurement of pump parameters required by the IST program and the ASME cod The audit concluded that, for the procedures sampled, testing was being done at the frecuencies committed to in the IST program. The audit identified two anomalies which were resolved by the license Overall, the QA audit results showed improvement over previous audits of the IST progra Based on the inspectors review of this audit it is

oncluded-that the quality assurance department is giving adequate .

. attention to the IST program. No unacceptable conditions were identifie .0 Follow-up of Previously Identified Open Items

.{ Closed) Unresolved Item 50-289/87-09-17: Inservice Testing Program 3elief Request "

NRR Required the licensee to procedurally incorporate the testing of some spent fuel pool cooling system valves into the IST program. Relief war granted until the end of August 1987. Also, the licensee was required to incorporate the testing of diesel generator air start valves EG-V-17A/B arior to September 19, 1987, or provide justification for not testing the :

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e With'regato to_the spent fuel pool cooling system valves, the inspector reviewed revised table B-1 page 36 of 38 of the' Periodic Inservice Inspection Program which lists valves in the program. The spent fuel ,

pool cooling system valves in question, have been incorporated into the IST program. The inspector verified this was done prior to August 198 With_ regard to diesel-generator air start valvos EG-V-17A/B, the inspector reviewed the licensees documentation dated August 24. 1987, whi-S de-scribed their justification for not including these valves in the IST progra The documentation provided reasoning that these valves do not perform a required safety function and therefore should not be required to be it..iuded in the IST program. The inspector found the licensee's reasoning to be acceptable. This item is close (Closed) Unresolved Item 50-289/86-12-09: Testing Two Hour Back-up Supply System and Valves An NRC inspe: tion identified the need for periodic testing of the two hour backup air supply system and associated valve The inspector verified that the licensee had written a draft procedure to *

test the two hour backup supply air syste The system line up was changed to resolve the single active failure concern that failure of one check valve could cause loss of the syste Additionally, valves EF-V30A/B have been replaced with valves l EF-V30A/B/C/D cf a different design and the procedure incorporates stroking and fail safe position verification for these valve The inspector verified in the Control Room that operating procedure 1104-25 was formally revised to include the draft revision This item is close (Closed) Unresolved Item 50-289/86-21-04: Engineering Evaluation of Walworth Check Valves The item pertained to the licensee's IST as-found condition of 6" Walworth check valve MS-V9A. The valve was found with its disc still

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attached to the disc arm out the washer, nut and cotter pin were missin This item was tnresolved pending NRC review of the licensee's engineering

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evaluation of this matter.

l The inspector reviewed the licensee's engineering evaluation memorandum

3310-87-0131 dated August 5, 1987. The licensee utilized a conservative approach and reviewed histories of all size Walworth check valves in their. safety systems. A resolution describing actions to be takea to l

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. 8 prevent similar problems as made for each of.the valves. Actions in-

. cluded tack welding of the nut to the stud on valves MS-V9A/B, recom-mendations for disassembly and inspection for several valves, and installation of bonnet stops on other valve The inspector verified that valves MS-V9A/B are part stroked on a quarterly basis and disassembled and inspected each refueling outage in

.accordance with IST commitment This item is close (Closed) Unresolved Item 50-289/86-17-03: IST Testing Requirements for Make-up System Check Valves This item involved the type of testing to be performed and the frequency of tests for valves MU-V68A/B, MU-V94, MU-V95, MU-V107A/B/C/0 and MU-V22 The inspector reviewed the NRC Safety Evaluation (SE) dated March 19, 1987:

of tha licensee's second ten year IST program. The SE granted the licenee's relief request to full stroke exercise check valves MU-V86A/B, MU-V95, MU-V107A/B/C/0, and MU-V220 during refueling outage For check valve MU-V94 the SE granted quarterly partial stroking of normal make up flows and full stroke exercising during refueling outage. This relief was granted to avoid additional thermal cycling of the injection nozzl The inspector verified that the licensee's admir.istrative procedure 1041, IST Program Requirements, and surveillance procedures reflected the SE granted alternative test This item is close .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. A new unresolved item is discussed in paragraph 5.0 of this repor Four unresolved items were resolved as stated in paragraph .0 Exit Meeting Licensee management was informed of the purpose and scope of the inspec-tion at the entrance intervie The findings of the inspection were periodically discussed and were summarized at the exit meeting on February 26, 1988. Attendees at the exit meeting are listed in section 1.0 of this repor At no time during the inspection was written material provided to the licensee by the inspectors. The licensee did not indicate that the inspection involved any proprietary informatio ._ .