IR 05000317/1992031
| ML20035A425 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/09/1993 |
| From: | Eapen P, Gregg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035A424 | List: |
| References | |
| 50-317-92-31, 50-318-92-31, GL-89-04, GL-89-4, IEB-88-004, IEB-88-4, NUDOCS 9303260044 | |
| Download: ML20035A425 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
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REGION I
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REPORT / DOCKET NOS. 50-317/92-31 50-318/92-31
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LICENSE NOS.
DPR-53 j
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DPR-69 i
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l LICENSEE:
Baltimore Gas and Electric Company 1650 Calvert Cliffs Parkway
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Lusby, Maryland 20657-4702
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FACILITY NAME:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2
i INSPECTION AT:
Lusby, Maryland l
i TEAM MEMBERS:
J. Colaccino, Mechanical Engineer
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J. D' Antonio, Operations Engineer
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LEAD INSPECTOR:
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. Harold I. Gregg, Sr. Reactor Engineer, Date
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Systems Section, EB, DRS
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APPROVED BY:
Dr. P. K. Eapen, Chief, Systems Section, Date l
Engineering Branch, DRS
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9303260044 930309
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PDR ADGCK 05000317 l
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Areas insoected: Inservice Testing of Pumps and Valves l
Inspection Results: The licensee's Inservice Testing program and implementation of the l
l program were good. The surveillance test group was structured, effectively staffed, and well
managed. Two isolated instances of non-adherence to ASME requirements were identified.
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One was the use of inappropriate pressure gauges and the other was inadequate leakage
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measurements. Because of the immediate remedial actions taken by the licensee and the l
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minimal safety implication, these items were classified as noncited violations. One unresolved item involving the response to NRC Bulletin 88-04, " Pump minimum flow," was i
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also identified.
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DETAILS j
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1.0 REVIEW OF LICENSEE'S INSERVICE TESTING OF PUMPS AND VALVES j
PROGRAM IMPLEMENTATION
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The NRC Generic Letter (GL) 89-04, issued April 3,1989, addressed several generic
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inservice testing (IST) program deficiencies and provided specific guidance on meeting the
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Code of Federal Regulations 10 CFR 50.55.a(g) provisions that required adherence to the l
American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI, " Inservice Testing of Pumps and Valves." The NRC Temporary Instruction (TI)
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2515/114, " Inspection Requirements for Generic Letter 89-04, Acceptable Inservice Testing
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Programs," January 15,1992, was issued to provide guidance to the inspectors.
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This inspection was conducted to review and assess the licensee's IST of pumps and valves program and program implementation using the guidance of TI 2515/114. The inspection
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included verification of adherence to the Code of Federal Regulation requirements, conformance to the ASME Section XI requirements, and review of the IST program and its implementation to assure the NRC safety evaluation recommended actions were addressed and there is consistency with the provisions of GL 89-04.
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Several systems (Auxiliary Feedwater, Safety Inspection and Containment Spray) and specific i
components (Pressurizer and Main Steam Safety Valves) were selected for in depth reviews.
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Observations ofin-process testing, assessment of the test conduct, and review of the observed and prior test results were also performed by the inspectors.
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1.1 IST Program
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The licensee's current IST program for pumps and valves applies to the second ten year
interval, beginning April 1,1987, through March 31,1997, for both Calvert Cliffs Nuclear Power Plants (Units 1 and 2).
The inspectors reviewed the NRC safety evaluation issued on September 20,1990, to
Baltimore Gas and Electric Company (BG&E) for their second ten-year interval IST program
submittal. This evaluation provisionally granted six relief requests that required additional
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licensee action and one relief request that was granted on an interim basis that also required
licensee action. The licensee's current IST program (Revision 1, Change 13), dated
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January 30,1992, was reviewed and the inspectors verified that the NRC recommended
actions had been incorporated into the licensee's IST program.
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1.2 Program Administration The Surveillance Test Group is responsible for implementing the IST program. The group
includes a supervisory principal engineer who reports directly to the superintendent technical support. Specific IST staffing includes one IST engineer accountable for control of the ASME Section XI IST pump and valve testing program and individual functional surveillance
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test coordinators in the operations, mechanical, electrical, arid relief valve groups support
each of the surveillance tests.
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Calvert Cliffs Instruction CCI-104, Surveillance Test Program, documents the surveillance requirements and responsibilities of the Surveillance Test Group personnel. Based on discussions with cognizant IST Surveillance Test Group personnel during the inspection, the l
witnessing of testing and review of surveillance test procedures (STPs), the inspectors
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verified that CCI-104 adequately controlled the IST program implementation.
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The inspectors concluded that the ST group was effectively organized and staffed with competent personnel and leadership and there was high level management support.
j 1.3 Valve Stroke Time Acceptance Criteria / Wip Acceptance Criteria
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In response to a prior NRC inspection finding (50-317 and 50-318/92-18), regarding inadequate acceptance criteria for pump performance and power operated valve stroke times,
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the licensee developed Surveillance Testing and Administrative Guidelines (STAG)-6. The l
licensee's implementation of STAG-6 was completed in December 1992.
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The inspectors noted that the STPs contained the action required limiting stroke time acceptance criteria, but did not include the increased test frequency provisions of IWV-3417(a) of the ASME Section XI Code. Further review by the inspectors verified that the l
IST engineer reviewed each test result and made appropriate determinations for increased
surveillances when an action limit was exceeded, in accordance with the Section XI l
requirements.
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The licensee identified rapid acting valves as valves that stroh in 2 seconds or less. The l
licensee declares these valves inoperable if stroke time exceeds 2 seconds, as recommended
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in Position 6 of GL 89-04. The licensee also appropriately identified this position in their
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IST program relief request A-1.
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Pump reference alert and action values were reviewed during the system evaluations f
conducted by the inspectors. The licensee's reference, action, and alert limits for pumps in i
the IST program were in accordance with ASME Section XI requirements.
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5 1.4 Test Scheduling The licensee's system of IST scheduling was computerized. The computer generated schedule lists the STP, test frequency, last completed date, scheduled date, and last permissible date. The schedule is issued twice a month (prior to the 1st and the 15th) and has an authorized distribution. The schedule also lists the STP contingency testing that can be performed in each mode other than power operation. Cold shutdown testing was performed in a systematic manner and the IST engineer was responsible to ensure that all components were tested over a period of time.
Based on this review, the inspectors concluded that the licensee has an effective system for scheduling and implementing testing in accordance with the ASME Code requirements.
2.0 IST PROGRAM IMPLEMENTATION f
The inspectors selected IST components in the auxiliary feedwater (AFW), safety l
injection (SI) and containment spray (CS) systems to assess the effectiveness of the licensee's
IST program implementation as detailed below.
l 2.1 Auxiliary Feedwater System Components i
Piping and instrument drawing 60-583-E, " Auxiliary Feedwater System, Unit 1, OM-800,"
was reviewed to verify that components identified on the drawing were incorporated in the
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IST program and appropriate testing was specified. The inspector observed that check valves
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l-AFW-129 and 1-AFW-130 were only required to be tested in the open direction. The licensee had not documented the basis for not requiring tests for clostre.
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t During a phone conversation with the licensee on December 17, 1992, the licensee stated i
that these valves were installed for protection of the AFW system as described in the UFSAR and not to mitigate the consequences of an accident in the closed direction as required by ASME Section XI, Paragraph IWV-1100. In addition, the licensee verified these valves to
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be closed through monitoring of a pressure indicator located upstream of the check valves
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once per shift. Based on the review of this additional information, the inspectors concluded the licensee has provided adequate justification for not including testing of these valves in the
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closed position. The licensee stated that this justification would be incorporated into the basis document that was being prepared.
The components in the AFW system were tested to demonstrate IST program requirements
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using procedures ETP 88-22R, Rev. 3, STP 0-5A-1, and STP 0-67-1. The valve testing for
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i full-stroke open, closure, and stroke time corresponded to the valve testing listed in the IST
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program. The inspectors reviewed AFW testing records from the previous cycle and found these test results were all in the acceptable range. The inspectors noted that the testing procedures had recently been completely revised to clearly identify valves being tested, the j
acceptance criteria, and the basis for additional testing, if required.
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i A number of components in the AFW system are tested at cold shutdown and the IST
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program included cold shutdown justifications for each of these valves. The inspectors
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verified on a sampling basis that the AFW valves and the main steam valves associated with the AFW steam turbines were adequately tested during cold shutdown.
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2.2 Safety Injection and Containment Spray Systems Components The inspectors reviewed the last surveillances performed for the IST program check valves in
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the SI and CS systems. The majority of these check valves are tested in individual procedures. Others are tested as part of the pump surveillance procedures. These procedures adequately verified the safety functions of the components as specified in the IST program. The results of testing were satisfactory and in accordance with the' acceptance criteria specified in the procedures.
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The ASME XI Code, Paragraphs IWV-3420 to 3427, requires leak testing to determine an
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actual volume of leakage, and that measured leakage be multiplied by a correction factor based on the difference between test differential pressure and maximum service differential pressure. Test procedures STP-65J-1&2, " Safety Injection System Check Valve Quarterly
Operability Test," used to leak test these valves did not require the leakage measurements of j
safety injection tank (SIT) outlet check valves (l&2 SI 215,215,235, and 245) to be i
corrected for maximum service versus test differential pressure. Also, quantitative leakage
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measurements were not required for the high pressure safety injection (HPSI) check i
I valves (l&2 SI 118,128,138, and 148).
The licensee immediately performed the updated surveillance on the HPSI and SI valves to l
i quantify leakage and the results were acceptable. The licensee's corrective actions were appropriate and the inspectors concluded the safety significance of these testing discrepancies
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was minor since the leak testing that was performed was adequate to detect gross valve.
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failure. The licensee's testing was also performed quarterly whereas the ASME code only
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requires leak testing once every two years, therefore, this nonadherence to the ASME Code j
leak testing requirements was not cited per the enforcement discretion provisions of i
10 CFR 50, Part 2, Appendix C,Section VII.B.
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2.3 Check Valve Disassembly Inspections i
l Certain check valves, including the HPSI and SIT check valves discussed above, cannot be I
full flow tested. These valves are disassembled and inspected with a frequency of one valve j
of each type per refueling outage, as approved by the NRC. The inspectors reviewed the last disassembly inspection procedure performed for each valve group covered by a relief
request. The procedures contained adequate instructions, notes on ASME testing provisions,
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dates for the remaining valves in each group were reviewed and the inspector verified that all l
valves were inspected over a period of time.
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3.0 WITNESSING OF TESTS The inspectors witnessed several tests of the IST components as described in the following paragraphs.
3.1 Boric Acid Pump Performance Test On Tuesday, December 8, the inspector witnessed STP 0-73F-2, " Boric Acid Pump Performance Test," being performed on the two Unit 2 boric acid pumps to satisfy the test requirements of ASME Section XI, Paragraph IWP-3100. A briefing, that included all personnel involved in the test, preceded the test. This briefing involved review of the STP, discussion of possible events that could occur during the test, and the appropriate operator responses. Overall, this briefing was well conducted.
The test involved establishing a flow loop through the pump minimum flow line back to the
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boric acid tank. Prior to pump start, the pump suction pressure was verified to be above the
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minimum required value. A reference flow rate was set in the control room and the pump t
was run for 5 minutes before discharge pressure and vibration measurements were recorded.
The process was then repeated for the other boric acid pump. A review of the test results verified that all measured pressure and vibration parameters on both pumps were within the STP acceptable limits.
During the first pump test, the inspector noted that the value of suction pressure, a function of the fluid level in the boric acid tank, was approximately 5.6 psig. The suction pressure
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was being recorded on a 0-30 psig analog pressure gauge. The other pump had an identical pressure gauge. The inspector concluded that the pressure gauge did not comply with
Paragraph IWP-4120 of the Code, which requires full-scale range of each instrument to be three times the reference value or less. In addition, the licensee examined the Unit 1 boric
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acid pump suction test gauges and discovered that 0-60 psig analog gauges were installed on these pumps.
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l The licensee initiated action to change the installed gauges to instruments that meet the Code requirements. The Unit 1 pumps were retested satisfactorily with a 0-15 psig gauge and the
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results were similar to the prior gauge readings. The licensee prepared issue report (IRO)
002-089, in response to this finding and conducted a review of the other pump suction and discharge test gauges in their IST program. No other gauges with incorrect ranges were
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discovered. The licenze also immediately revised the STPs to use a 0-15 psig replacement gauge for testing. The licensee verified there were no safety concerns due to the use of improper gauges by retesting and verification that recorded pressures were similar to the i
earlier tests, therefore, this noncompliance to the ASME Code gauge range requirement was
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not cited per the enforcement discretion provisions of 10 CFR 50, Part 2, Appendix C,
Section VII.B.
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3.2 Service Water Air-Operated Valve Stroke Tests
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The inspectors witnessed the Quarterly Operability Test of 12 Service Water (SRW)
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Subsystem air operated valves performed on December 8,1992, in accordance with the l
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licensee's STP 0-65C-1. During the witnessing of the test, it was noted that the STP limiting
stroke time of the spent fuel pool (SFP) cooler isolation valves 1-SRW-1596-CV was
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25 seconds and for 1-SRW-1597-CV was 23 seconds. For both valves, a Technical l
Specification (TS) surveillance reference relating to engmeered safety features response time j
was also listed. The TS maximum response time was 35 seconds for diesel generator start i
that included a load sequencing delay and 10 seconds when offsite power was available for j
the containment fan coolers (CFC). The inspector also noted that the STP applicability / scope
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statement includes the SFP cooler valves within the CFC valve category. Therefore, there l
was an apparent discrepancy between the TS more limiting 10 second stroke time and the
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As a result of the stroke time discrepancy, the licensee identified a concern in the load.
l sequencing signals and Issue Report IRO 002-071 and program deficiency report (PDR)
j 92536 were written. The IRO and PDR required actions to: perform a design evaluation to
confirm operability, verify accuracy of affected drawings, review other engineered safety j
features actuation systems valves for similar problems, evaluate modification to change
sequencing of affected valves, and revise the STP to reflect the proper stroke time basis. In f
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response to the PDR, the licensee immediately performed operability evaluation M92-13,
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utilizing the computer program service water system model (KYPIPE 2, University of j
Kentucky Hydraulic Analysis Program,1000 Pipe Version 1.10 of 8/25/92) that is calibrated
to actual plant data. The evaluation quantified flow to the CFCs during worst case peak i
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pressure and temperature loads, with the SFP valves open and with the valves closed.
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Adequate CFC flow was shown to be available with the valves open throughout the event.
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The IRO and PDR required actions are the licensee's mechanism for documenting and j
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closing all issues pertaining to the SFP required closing time, including corrections to the l
STP, UFSAR, and drawings, and the inspectors had no further questions.
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3.3 Quarterly Surveillance of Service Water Check Valves and LPSI Pumps
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The inspectors witnessed the performance of STP 0-65V-1, a quarterly surveillance to verify the ability of the service water pump discharge check valves to close, and STP-073-1, a
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quarterly operability surveillance of the No. I1 and No.12 low pressure safety injection l
pumps. The check valve test acceptance criteria were adequate to determine valve closure as l
well as minimal leakage and the pump test performance and results were satisfactory.
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4.0 PRESSURIZER SAFETY VALVES AND MAIN STEAM SAFETY VALVES The pressurizer safety valves (PZR/SV) and the main steam safety valves (MSSV) are in the licensee's IST program. ASME Section XI, Subsection IWV-3500, and Table IWV-3510-1, require setpoint testing of all valves of each type (PZR/SV and MSSV) within a five-year period. Each of the Calvert Cliffs Nuclear Power Plant Units has 2 PZR/SV and 16 MSSV (eight on each steam generator outlet header). The PZR/SV and MSSV are manufactured by Dresser Industries.
The inspectors reviewed the licensee's new reformatted surveillance test procedures (STP)
STP-M-2-1/STP-M-2-2 for setpoint testing and adjustment of PZR/SVs. The STP requires documented as-found and as-left values. The as-left setpoint averaged two consecutive within acceptance simmers. The STP setpoint range of 25 psi was clearly defined and corresponds to the Technical Specification (TS) range.
The inspectors reviewed the licensee's STP-M-3-l/STP-M-3-2 for setpoint testing and adjustment of MSSVs that were also recently reformatted. The as-left setpoint averaged two consecutive within acceptance and within 10 psig of each other simmers. The STP setpoint range of 10 psi or 20 psig total for all MSSVs was based on the licensee's setpoint log.
The 10 p;i STP range to which the MSSVs were set was more stringent than the TS setpoint range of 60 psi to 130 psi depending on the valve. The inspector verified that the more stringent setpoint range of 10 psi was used in determining both as-found and as-left setpoints. The inspector also determined that an approved TS amendment provided the authorization for the TS MSSV allowable setpoints.
The STP narration of PZR/SV as-found setpoints called the first simmer the as-found setpoint. This value was recorded. The STP also required recording of three consecutive simmers, ignoring the first simmer, to be an averaged as-found lift pressure. The MSSV STP determination of as-found setpoints called for the recording of the first and subsequent simmers and the averaging of three consecutive-simmers within 10 psig of each other. The inspector discussed the use of two as-found termed conditions in each of the STPs, with the principal engineer.
The licensee provided P7R-SV STP change information (Change Report No. 93-11) on March 1,1993, that clarified the first simmer to be the "TS as-found setpoint" and the subsequent simmers were termed a "Setpoint averaging test." The licensee also provided MSSV STP change information (Change Report No.93-054) on March 4,1993, that clarified the first simmer as the "TS as-found setpoint" and the subsequent simmers as a
"Setpoint averaging test." The inspectors concluded that the STP revisions more clearly defined the as-found condition and had no further questions.
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5.0 REVIEW OF BULLETIN 88-04, POTENTIAL SAFETY RELATED PUMP LOSS
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The inspector evaluated the licensee's actions taken to investigate and correct as applicable,
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two minimum flow design concerns discussed in NRC Bulletin 88-04, " Potential Safety
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Related Pump loss." The first concern was the potential for dead heading one or more centrifugal pumps in safety-related systems if the pumps have a common minimum flow line
or if the system configuration allows for pump interaction during operation in minimum flow
mode. The second concern was the adequacy of the installed minimum flow line capacity.
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The licensee's engineering evaluations of the systems addressed by the bulletin were technically adequate and documentation was generally good. The licensee concluded that the design, operation, maintenance, and surveillance practices associated with the safety related pumps preclude occurrence of the minimum flow problems discussed in Bulletin 88-04.
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However, one minimum flow issue involving the High Pressure Safety Injection System,
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Low Pressure Safety Injection System, and Containment Spray System, requires followup as discussed below.
The Emergency Core Cooling System (ECCS) of each unit at Calvert Cliffs Nuclear Plant (CCNP) has three High Pressure Safety Injection (HPSI) pumps, two Low Pressure Safety Injection (LPSI) pumps, and two Containment Spray (CS) pumps. Each pump has a
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t minimum flow line and all of the pump minimum flow recirculation lines tie together into a common header back to the Refueling Water Tank (RWT). Each of the individual minimum flow lines has a restriction orifice. Each HPSI pump was rated for 345 gpm at 2500 ft, Total Dynamic Head (TDH). The minimum flow provided for each HPSI pump was 32
gpm. Each LPSI pump was rated for 3,000 gpm at 350 ft TDH. The minimum flow
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provided for each LPSI pump was 42 gpm. Each CS pump was rated for 1,400 gpm at 370 i
ft TDH. The minimum flow provided for each CS pump was 53 gpm. The flows measured during surveillance testing of these safety related pumps were slightly higher than minimum.
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i Each unit at CCNP has two Steam-driven Auxiliary Feedwater Pumps (SDAFWP) and one Motor-driven Auxiliary Feedwater Pump (MDAFWP). Each pump was equipped with a j
minimum flow recirculation line. The individual minimum flow lines tie together into one header for each unit and the common header for each unit then ties with that of the other unit to form a common run to the Condensate Storage Tank (CST). Each SDAFWP was ratal at l
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700 gpm and has an installed minimum flow line capacity of 80 gpm. The MDAMVP was rated at 450 gpm and has an installed minimum flow line capacity of 150 gpm and each of j
the recirculation lines has a flow restriction orifice located between the pump and the l
common return header.
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The licensee performed good engineering evaluations of all required systems in response to
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the bulletin, pump suppliers were consulted to ascertain the adequacy of miniraum flows,
and the quality and timeliness of the licensee's actions were noteworthy. Based on past i
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performances, surveillance test results, past pump overhaul results, and dircussions with the pump vendors, the licensee concluded that the pumps are not susceptible to the concerns of Bulletin 88-04. While the inspector found no discrepancy with this determination, the inspector noted that the licensee had no documented evidence to show that all possible modes of the ECCS systems pumps operation in minimum flow had been considered and discussed with the pump vendors. Specifically, the estimated times of pumps operating in the minimum flow mode following a postulated small break LOCA had not been determined.
r This item is unresolved pending completion of the licensee's evaluation to demonstrate that the HPSI, LPSI, and CS pumps can operate satisfactorily in minimum flow mode during all
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analyzed plant conditions including a small break LOCA (Unresolved Item 50-317/92-31-01
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and 50-318/92-31-01).
6.0 REVIEW OF PREVIOUSLY IDENTIFIED ITEMS (Closed) Violation 50-317/92-18-01 and 50-318/92-1841 This violation concerned repetitive full stroke failures of a service water air operated butterfly valve 2-SW-5173-CV. The licensee placed the valve in an open (required) position under temporary controls and later inappropriately changed the valve position prior to completion of outstanding maintenance orders to identify and correct the problem.
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The licensee's corrective actions included: supervisory discussion with operating personnel on the importance of verifying that components are fully operational prior to removing i
temporary controls, maintaining a temporary note on the valve switch that states, "this note cannot be removed until unit maintenance and post maintenance test is complete," a change
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to CCI-140 to address equipment maintained outside normal position to meet design requirements and how equipment can be made operational, attachment of a temporary note on the valve (or other equipment) with a description of why the valve must be left in its
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accident position, and the issuing of maintenance order (MO) 29108092 for the order of l
spare parts and repair of the valve that is scheduled for the 1993 outage.
t The inspectors reviewed CCI-140 and verified change 6 issued on December 17, 1992, i
incorporated the licensee's committed changes. The inspectors also verified that temporary
note 0-92-043 at the control room valve switch was in place and stated, " Leave 2-SW-5173
open for 22 ECCS operability and do not remove the note until maintenance and post
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maintenance testing is completed, (needs STP-0-65P-2 completed prior to operable)."
Inspector observations of valve 2-SW-5173-CV noted appropriate deficiency tags were in place on the valve.
The inspectors considered the licensee's actions to be appropriate. This item is closed.
i 7.0 UNRESOLVED ITEMS Unresolved items are matters about which more information is required in order to ascertain
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T whether they are acceptable items, violations, or deviations. An unresolved item is discussed
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in Paragraph 5.0 of this report.
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8.0 EXIT MEETING
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The inspector met with the licensee's representatives on December 15,1992 and January 15,1993, at the conclusion of the inspection to summarize the findings of this inspection. Attendees at the exit meeting and person contacted during the inspection are listed in Attachment 1. Titis inspection was extended to March 5,1993, to enable resolution
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of the additional information provided by the licensee.
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t ATTAClIMENT 1 i
t Persons Contacted
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Calvert Cliffs Nuclear Power Plant M. Arcaro, Engineer
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P. Chabot, Superintendent Technical Support
- + S. Davis, Surveillance Test Group - Principal Engineer l
G. Detter, Director - Nuclear Regulatory Matters
D. Dobson, IST Engineer -
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- + R. Franke, NRM T. Lupold, Principal Engineer - PEP &SU
W. Rummel, FSTC - ST Group
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L. Tucker, G.S. Plant Engineering
l L. Wenger, Principal Engineer - Compliance
E. Wilson, Compliance Engineer
J. Wood, Senior Engineer - Quality Audits
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U.S. Nuclear Reculatory Commission
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J. Yerokun, Project Engineer / Acting Senior Resident Inspector I
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i Denotes those present at exit meeting held December 11, 1992.
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+ Denotes those at January 15,1993 exit.
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