IR 05000324/1986032
| ML20215C206 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/26/1986 |
| From: | Blake J, Menning J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215C190 | List: |
| References | |
| 50-324-86-32, 50-325-86-31, IEIN-86-034, IEIN-86-050, IEIN-86-34, IEIN-86-50, NUDOCS 8612150060 | |
| Download: ML20215C206 (8) | |
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UNITED STATES -
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~ of l NUC[ EAR REGULATORY.COMMISSIOP[
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Report Nos.:
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. Licensee:~ Carolina Power'and. Light Company,1 *
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P. 0.-Box 1551'
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Docket ~Nos.: 50-325 and 50-324
~ *i License-Nos.: DPR-71 and DPR-62
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Facility Name: ~ Brunswick 1 and 2 i
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Inspection Cond eted: November 3-7, 1986 '
\\\\\\%\\tL Inspector:\\(
' Approved by-llt S0 J. J Blake, Section Chief.
Ddte Signed Mt fals and Processes Section v ion of_ Reactor Safety:
SUMMARY'
Scope:- -This~ routine, unannounced inspection involved the-areas of inservice
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testing of pumps and valves (617008 and 617258), inservice inspection data review.
- and evaluation (73755), Part 21 report followup (927168), and followup on IE Information Notices -(92701B).
Resul ts: No violations or deviations were identified.
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8612150060 861205~
PDR ADOCK 05000324 G
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- REPORT DETAILS,
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- Perscris' Contacted-
~LicenseeEmhl.oyees-
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- P.: Howe', Vice President, Brunswick Nuclear Project:(BNP) '
=*J. Chase,~ Assistant to' General Manager --BNP
- E. Bish'op, Manageri ' Operations-(*E.;Eckstein,: Manager-Technical Support
- J. O'Sullivan, ManagerH-Maintenance
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- C.'Blackmon, Superintendent - Operations.
n t *K. Enzor, Director'- Regulatory Compliance'
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- L. Jones, Director - Quality Assurance / Quality Control.
- J. Titrington, Project Engineer-(Mechanical)
- L. Wheatley, Project Engineer (ISI)
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0ther? licensee employees contacted included engineers. technicians,' security'
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iforce members, and office personnel.
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- NRC Resident Inspectors
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. *W. Ruland, Senior Resident Inspector
- Attended exit' interview 2.
- Exit Interview l
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- The. inspection scope and findings.were summarized on November 7,1986, with
.those. persons. indicated in paragraph 1 above.
The inspector' described the
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areas inspected and discussed in detail the inspection findings.
No
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-dissenting comments were received from the licensee, b-(0 pen). Inspector Followup Item 325/86-31-01, 324/86-32-01, Review of Test
. Procedures for: Exercising Dual Function' Check Valves - paragraph 5.c.
i (0 pen) Inspector Followup Item 325/86-31-02, 324/86-32-02, Resolution of
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- Test Requirements for NSS Relief Valve Discharge Line Vacuum Breakers -
-paragraph S.c.
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-The licensee did not identify as proprietary any of the materials provided
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to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
I-This subject was not addressed in the inspection.
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,4; Unresolved Items Unresolved items _ were not-identified during the inspection.
'5.
Inservice' Testing of Pumps'and Valves (617008 and 61725B)
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The inspector-reviewed procedures and records, as described below, to =
determine whether applicable _ code, procedure, and regulatory requirements were being met.
The licensee submitted its Interval 2.In-Service Testing _
Program (IST) for pumps and valves for both Brunswick units to'the Office of Nuclear Reactor Regulation (NRR) on October.23, 1986 This program conforms to the ASME Boiler and Pressure Vessel Code,Section XI,- 1980 Edition through the winter-1981 Addenda. The updated IST Program is applicable for-the 120-month interval' which began, for both units, on July 10, 1986.
.a.
The inspector reviewed the following procedures _for; administration and control of the IST. program:
Engineering Procedure:. ENP-16, Rev. '21, " Procedure for Admini-
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strative Control of Inservice Inspection Activities" Engineering Procedure:
ENP-17, Rev. 0, " Pump and Valve Inservice
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Testing (IST)"-
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Maintenance Procedure:
MP-01B. Rev. 5
" Control of Measuring
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Devices and Test Equipment for I&C/ Electrical" The above procedures were reviewed to determine if the licensee has assigned responsibilities for the following:
Preparation, review, and approval of IST procedures
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Scheduling of IST tests, both normal and increased frequency
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Performance of testing per approved procedures
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Performance of post-maintenance and post-modification inservice
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tests Proper certification and calibration of IST instruments
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Training for those personnel responsible for implementing
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inservice testing procedures b.
The inspector reviewed the following IST periodic test procedures focusing on provisions for the testing of pumps:
PT 07.2.4b, Rev. 10, " Core Spray System Operability Test - Loop B"
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PT 08.1.4a, Rev. 15, "RHR Service Water System Operability Test -
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Loop A"
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' PT'09.2, Rey;~47b"HPCISystem.OperabilityTest" PT 24.1-1, L Rev. 0, " Service Water Pump 'and Discharge Valve!
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- Operability-Test"
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-The labove procedures _.were reviewed-to -determine -whether, except as lspecifically addressed by relief requests, all requirements of. the-applicable 1editioniof J the ' ASME' Code,Section XI are ' incorporated-including:
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. Recording of test results per the. approved procedures Eval'uation of test data in accordance with specified time
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constraints and criteria P
Evaluations of. imposing and removing increased frequency testing
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requirements.
' Evaluation and justification of = cha'nges to -test. acceptance
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' Pump vibration ' test data analysis and specification of,loca' tion
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for vibration measurement Requirements that pump tests be conducted at reference conditions,
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including reference speed During this review, the. inspector: noted that the test procedures did
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. not.contain specific provisions to ensure. that the requirements of IWP-4120 of Section XI are met.
IWP-4120' requires the full-scale range
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of each instrument used in. pump testing -to be three times the associ-
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i ated reference value or less. Discussions with a licensee representa-tive revealed that. CP&L had previously identified the need to
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- strengthen the ISI program in this area, and is currently considering
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how best to ensure that the range requi.rement for test instrumentation is always met.
The inspector indicated that this matter would be
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reviewed during a future inspection.
The inspector reviewed the following IST periodic test procedures, c.
focusing on provisions for the testing of valves:
PT.11.1.3, Rev. O, " Nuclear Steam Supply / Relief Valve Discharge
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Line Vacuum Breaker Operability Test"
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PT 06.2.3, Rev. 18, " Standby Liquid Control System Injection Test" L
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- PT 07.1.lb, Rev. 3, " Core Spray Injection Check Valve Operability L
Test - Loop B" l
PT 25.1, Rev.13, " Nuclear Steam Supply System Main Steam and
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Feedwater Isolation Valve Operability Test"
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PT 20.3a.1, Rev. O, " Local Leak Rate _ Test for _ Containment
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Isolation" PT 07.2.4a, Rev.10 " Core Spray System Operability. Test _ Loop A"
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The above procedures were reviewed to determine whether, except as specifically addressed by relief. requests, all requirements for the applicable edition of the ASME Code,Section XI are incorporated
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including:
Recording of test'results per the approved procedures
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Evaluation of test data in 'accordance with specified time constraints and criteria Positive testing of check valves whose safety function is to both
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open and close Observation of valves with remote position indicators at least
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once every two years Setting of limiting valve stroke times commensurate with the
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capabilities of the valve tested Prior to conducting this review, the inspector discussed test require-ments for Category C check valves that are normally closed and have safety functions in both the open and_ closed positions.
IWV-3522(b)of Section XI requires that nomally closed check valves be periodically exercised to the open position, but does not specifically require testing to the closed position for those valves that also have a safety function in the closed position.
Discussions with.a licensee repre-sentative revealed that CP&L was aware of the need to exercise such dual function check valves to both the open and closed positions, and had included related requirements in the IST program for Interval 2.
The licensee representative indicated, however, the CP&L was currently reviewing and modifying, as necessary, the periodic test procedures for dual function check valves to ensure that the procedures fully support the IST program. Pending completion of the licensee's procedure review and followup by the inspector, this matter is identified as Inspector Followup Item 325/86-31-01,324/86-32-01, Review of Test Procedures for Exercising Dual Function Check Valves.
During this review, the inspector noted that the valve exercising method of PT 11.1.3, Rev.0, appeared to be in conflict with Section XI requirements.
The periodic test procedure is used to exercise vacuum breakers for the nuclear steam supply relief valve discharge lines.
The vacuum breakers are designated B21-F037A, B, C, D, E, F, G, H, J, K and L.
The current procedut e specifies that the vacuum breakers are to be exercised by hand or with an extension devic 9 through the full range
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IWV-3522(b)- of Section XI requires, in part, that such
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testing be done with a mechanical exerciser-to measure opening force or torque.
Limits:en opening torque or. force are specified. -A licensee representative agreed with the inspector's observation and indicated thatCP&LwouldeitherseekrelieffromtherequirementsofIWV-3522(b)
or take action to have these vacuum breakers removed from the Lformal Section XI IST program.
In reviewing this matter, the inspector noted that testing of these vacuum breakers was not required for Interval.1.
' Additionally, it was noted that PT 11.1.3, Rev. 0, had not yet been used for testing in Interval 2.
Pending completion of the licensee's actions, this matter is identified as Inspector Followup Item 325/86-31-02, 824/86-32-02, Resolution of Test Requirements for NSS Relief Valve Discharge Line Vacuum Breakers.-
d.
-The test records listed 'below were reviewed to determine whether inservice testing test data were evaluated in accordance with the requirements of Subsections IWP and IWV lof Section XI, and whether appropriate actions were_ taken, i.e., increased frequency of testing, repairs, declaration of component / system as inoperable, etc.
Procedures Date of Testing Unit PT 06.1, " Standby Liquid Control 04/08/86
System Operability Test" 05/10/86 06/10/86 07/13/86 09/10/86 10/12/86 PT 07.2.4a, " Core Spray System 01/07/86-1 Operability - Loop A" 03/29/86 04/09/86 07/09/86 08/28/86 10/26/86 PT 08.2.2b, "LPCI/RHR Operability 11/08/85
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Test - Loop B" 12/29/85 01/10/86
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l 02/12/86 04/17/86 05/17/86 07/02/86 PT 09.2, "HPCI System Operability Test" 06/26/86
08/15/86 11/02/86
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The Work Request / Job :0'rder' packages listed below;were reviewed to-
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_ determine whether required inservice testing of -pumps 1and valves was:
. performed;after maintenance or modification, and whether. test data were
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- evaluated to determine component operability.
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- Work Request / Job Order Numbers Involved Component Unit-
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' 8'62ARTE1 RCIC-Valve E51-F007'
185-AJXE1
'RCIC Valve E51-F007D-2~
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85-AHBA1 Core, Spray Valve E21-F012A 2l
.85-AILK1 RHR Valve E11-V-32 2=
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86-ADAZ1 Core Spray Pump A.
- 1 86-AXLD1 Nuclear Service Water Pump -1B_
85-ADAX1 Standby-Liquid Control Pump BL-1
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Within the areas' examined, no violations or deviations were identified.
6.
Inservice Inspection Data Review and Evaluation (737558)
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CP&L. submitted.a report of the 1986 inservice inspection of Brunswick Unit.2 to NRR on September 15, 1986,~ as required by IWA-6220(b) of Section XI of the ASME code.. The 1977. Edition through Summer 1978 Addenda were.appli-cable for this recent Unit 2 outage. The inspector reviewed.the report and
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determined-that it complied with the applicable ~ reporting requirements
delineated in' IWA-6220(b), (c), and (d).- ilowever, the inspector noted that on page 11 of this report the licensee reported that ultrasonic examination of-eight HPCI main : pump studs was determined not to. be practical during the. outage, that a relief request was submitted to-the NRC to delay examination to the next outage, and that no further corrective-action was required.
Since NRR denied CP&L's - relief request on August 22, 1986
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(subsequent to the preparation of the Unit 2 outage report), the inspector
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questioned the licensee to determine plans for accomplishing the required examinations of the pump studs.
A licensee representative indicated that the ultrasonic ' examinations would likely be performed during the next two l
to three months.
Within the areas examined, no violations or deviations were identified.
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p 7.
Part 21 Report Followup (927168)
By letter dated March 12, 1986, a valve supplier, Valtek, notified CP&L that some bolting material supplied by Cardinal Industrial Products Corporation deviated from ASME Section III, NCA 3800 in that stock materials were improperly qualified.
More specifically, stock materials certified as meeting Section III requirements were purchased from a nonqualified source,
and no subsequent upgrading was performed.
Valtek indicated that the following valves with questionable bolting had been shipped to Brunswick:
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Valve Serial Numbers 35411-1-1 35411-1-2
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In a subsequent letter to CP&L dated April 4,1986,.Valtek stated that Cardinal had performed testing that showed that the bolting material met the requirements of the material specification. - This ' letter also transmitted test reports for the involved heats of material.
The inspector reviewed a report of the licensee's evaluation of this Part 21 report, identified as document number 10 CFR 2186-04.
The bolting in
. question was used to install valves E11-PDV-F068A and F0688 on piping
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flanges in the Unit 1 service water system downstream of the RHR heat-In summary, CP&L determined that the bolting was acceptable exchangers.
after reviewing the chemical and mechanical test data provided by Valtek and -
finding that the material complied with material specifications and system-design requirements.
The inspector concluded that the licensee's review of this matter was appropriate.
8.
Followup on IE Information Notices (IEIN) (927018)
The inspector verified that the IEINs: listed below were received,. reviewed, and appropriate corrective action taken or planned.
IEIN NO.
Title
" Improper Assembly, Material Selection, and Test of
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86-34
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Valves and Their Actuators" 86-50
" Inadequate Testing to Detect Failures of Safety-Related Pneumatic Components or Systems Review of these IEINsis closed.
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