IR 05000324/1987039

Insp Repts 50-324/87-39 & 50-325/87-38 on 871102-06. Violation Noted.Major Areas Inspected:Failure to Promptly Correct Tech Spec Requirement Re Gages

ML20237A398
Person / Time
Site:	Brunswick
Issue date:	12/04/1987
From:	Blake J, Coley J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237A382	List: IR 05000324/1987039 ML20237A380 ML20237A395
References
50-324-87-39, NUDOCS 8712140451
Download: ML20237A398 (9)

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UNITED ST AT ES l

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i Report Nos.: 50-325/87-38 and 50-324/87-39 f Lic.ensee: Carolina Power and Light Company i P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Fbcility Name: Brunswick 1 and 2 l Inspection Conducted: Nc. Aber 2-6, 1987 Inspectors: . thbkk /7 2 E H. Gi (r Date Signe f

/ /&i 7 j . #61ey Date Signed Acccmp$nyin P6 nn 1- Y. S. Huang, NRC Office of Nuclear Reactor Regulation Approveu by: . ,. /A/1/87 J. J/ Blake, Section Chief Date' Signed E gineering Branch JtisionofReactorSafety SUMMARY Scope: This routine, unannounced inspection was in the area of inservice testing of pumps and valve Results: One violation was identified - Failure to Promptly Correct Technical Specification Requirement Regarding Gages, paragraph 5.f.(1).

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l 8712140451ADOCK 05000324 871210 PDR PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• P. W. Howe, Vice President

• C. R. Dietz, General Manager

• J. G. Tritrington, Principal Engineer, Operations

• E. R. Eckstein, Manager, Technical Support

• L. W. Wheatley, Inservice Inspection (ISI) Project Engineer, Technical Support

• L. E. Jones,. Director, QA/QC

• R. M. Poulk, Senior Specialist - NRC, Regulatory Compliance P. Godsey, ISI Responsible Engineer NRC Resident Inspector

• H. Ruland,' Senior Resident Inspector

• Attended exit interview Exit Interview l The inspection scope and findings were summarized on November 6,1987, i with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee. The following new items were identified during this inspection Violation 325/87-38-01 and 324/87-39-01, Failure to Promptly Correct Nonconformance with Technical Specification Requirement Regarding Gages, paragraph 5.f.(1). I Unresolved Item 325/87-38-02 and 224/87-39-02, Requirements for Use of Teflon Tape, paragraph 5.f.(2).

Inspector Followup Item 325/P7-38-03 and 324/87-39-03, Duplication of Reference Conditions in Pump Tests, paragraph 5.f.(3).

The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio . Licensee Actier, on Previous Enforcement Matters This subject was not addressed in the inspection.

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2 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. An unresolved item identified during this inspection is discussed in paragraph 5.f.(2). Inservice Testing of Pumps and Valves (73756)

The NRC inspectors examined the licensee's inservice testing of pumps and valves to determine whether regulatory requirements and licensee i commitments were being me Brunswick Technical Specification 4.0.5. requires that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

In a letter dated April 9,1987, the NRC granted the licensee relief to permit the use of a common test interval stait date of July 10, 1986, for both units. Based on this interval date, the ASME Section XI Edition and Addenda specified by 10 CFR 50.55a are 80W8 In acccrdance with 10 CFR 50.55a, the Section XI Edition and Addenda applicable to the testing in the previous 40 month period was 77S7 The NRC inspectors performed examinations of the inservice testing activities as follows: Responsibilities i

The. inspectors reviewed licensee instructions and procedures and interviewed cognizant licensee personnel to determine that the licerrsee had assigned responsibilities to persons and organizations for:

(1) preparation, review, and approval of inservice testing (IST)

procedures j (2) scheduling of IST for normal and increased frequency te?, ting

(3) performance of testing per aproved procedures

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l (4) performance of post-maintenance and post-modification IST f I

(5) proper certification and calibration of IST instruments i i (6) training for those personnel responsible for implementing IST 4 l procedures Instructions and procedures reviewed by the inspectors relative to  !

the above were as follows: )

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Document N Revision Titie l

ENP-16 22 Procedure for Adminiu rative Control of Inservice 2nspection ,

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Activities ENP-17 3 PU:"a and Valve Inservice Tecting

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107 Operating Manual, Volume 1, Book 1 01-28 7 (Procedure Preparation and Changes)

MP-01A 5 Control of Measuring Devices for i Mechanical Maintenance MP-01B 7 Control of Measuring Devicas and Test Equipment for I&C/ Electrical ilP-10 28 Preventative Maintenance Program

The licensee's procedures for IST are generally prepared and performed by Operations personnel, whereas, the IST program and i evaluation of IST results are the responsibility of the licensee's Technical Support oersonne The NRC inspectors noted that there was no requirement tnat the Technical Services personnel participate in the review and approval of the IST procedures and thei'r change The inspectors expressed concern regarding this to the Operations Principal Enginee The Principal Engineer stated that the procedures were, in practice, being reviewed by cognizant Technical Services personnel. He 6 greed that a formal requirement for a Technical Services review of IST procedures should be included in the Operations Instruction (01-28) for preparation of the procedures and procedure changes and he stated that he would initiate a change to incorporate such a requiremen The inspectors were informed that the IST was performed by Contre:

and Auxiliary Operators and that their operator training and supplementary training in the use of vibration meters qualified them for the IST. The procedures for the training were identified to the inspectors as tis-104 and 201. The training may be reviewed further by the inspectors in a subsequent inspection, b. Procedure Control The inspectors examined the licensee's procedure controls, as described in the Records Management Procedures (RMP-003, 004, and 005), to verify that the licensee had requirements to assure the use of the latest procedure Proper control was verified for IST procedures 06.2.3-1R2, 06.1-1R6, 06.1-2R2 and 06.2.1R10.

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i l 4 I-I c. Scheduling The inspectors reviewed the licensee's October. 10-30, 1987, schedule for performing procedures, such as pump and valve tests, reviewed the scheduling procedure (Procedure RCI-02.4R8) and di::,ussed the schedule with cogn1 rant personnel. The inspectors conducted the review and discussions to verify that the schedule provided testing at the frequencies specified by ASME Section XI and 'the plant Technical Specifications (TSs).

d. IST Procedure Content The inspectors reviewed a sample of the licensee's IST procedures to verii'y that the prccedures specify (except for items addressed by  :

relief requests): ,

(1) valid test criteria for the components being tested (2) evaluations of imposing and removing increased frequency testing requirements

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(3) pump vibration test data analysis and acceptance criteria justification, including location of vibration measurement (4) requirements that pump tests be conducted at reference conditions, inc?uding reference speed .!

(5) compliance of test instruments to 10 CFR 50 and ASME Code requirements (6) requirements that testing of Category 8, C and D valves include:

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performance of positive testing of Category C check valves whose safety function is to open and close (i.e., full stroke verification in both directions and individual i quantitative leak rate testing where applicable)

- observation of remote position indicators, at least once every 2 years to verify that valve operation is accurately indicated

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indication that valve stroke times are commensurate with j the capabilities of the valve tested The procedures reviewed by the inspectors relative to the above were as follows:

Procedure N Revision Ti tle l 06.1-1 6 Standby Liquid Control System Operability Test (Unit 1)

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l (cont'd) Procedure N Revision Title 06.1-2 2 Standby Liquid Control System Operability Test (Unit 2)'

06.2.3-1 2 Standby Liquid Control System Injection Test (Unit 1)

24.1-1 3 Service Water Pump and Discharge Valve Operability Test (Unit 1)

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24.1-2 2 Service Water Pump and Discharge l Valve Operability Test (Unit 2)

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08.2.2b 17 LPCI/RHR System Operability Test -

Loop B (Units 1 and 2)

08.2.2c 13 LPCI/RHR System Operability Test -

Loop A (Units 1 and 2) IST Records The inspectors reviewed completed procedure 08.2.2b records for IST of the following components to verify conformance with the procedure requirements and to verify proper evaluation in accordance with the requirements of ASME Section XI:

Component Dates Valve 1-E11-F017A 8/11/87 (Developing new stroke time acceptance criteria following limit switch change)

IB RHR Pump 10/16/87, 8/7/87, 7/25/87, 6/29/87 10 RHR Pump 10/16/87, 8/7/87. 7/25/87, 7/26/8't, 6/29/87 28 RHR Pump 10/31/87, 8/8/87, 5/16/87 2D RHR Pump 10/31/87, 8/8/87, 5/16/87 Valve 1-E11-F0078 10/16/87, 8/7/87, 7/25/87 Valve 1-E11-F041B 10/16/87, 8/7/87, 7/25/87 Valve 1-E11-F0158 10/16/87, 8/7/87, 7/25/87 l Valve 1-E11-F017B 10/16/87, 8/7/87, 7/25/87 Valve 1-E11-F016D 10/16/87, 8/7/87, 7/25/87 l

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(cont'd) Component Dates Valve 1-E11-F0278 10/16/87, 8/7/87, 7/25/87 Valve 2-E11-F0078 10/31/87, 8/8/87  ;

Valve 2-E11-F011B 10/31/87, f/8/87 IST Performance Thc licensee did not perform any IST during this NRC inspection. As the inspectors could not directly observe and evaluate performance of IST, they elected to observe the condition of the licensee's RHR, Service Water and Standby Liquid Control pumps and adjacent components and gage The inspectors specifically observed the following for conformance with IST v requirements:

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vibration monitoring locations labeled - all pumps observed

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gage ranges - RHR pumps installed flow and pressure gages

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lubricant levels - RHR pump The inspectors observed the following items of concern:

(1) The RHR pump pressure gages were not in accordance with an ASME Section XI requirement that the full-scale range of each instrument shall be three times the reference value or les Typical suction and discharge pressures for the pumps are about 0 psig and 130 psig, respectively, yielding a reference differential pressure of about 125 psig. The licensee's suction pressure gages have a range of -30 in. Hg to 150 psig and their discharge pressure gages have a range of 0-600 psig. As ASME Section XI instrument accuracy requirements ( 2% for pressure gages) are based on the full-scale gage ranges, the above requirements result in measurement accuracies lower than would be obtained when complying with Section X For example, a gage meeting ASME Section XI requirements would measure the licensee's pump discharge pressure with an accuracy l of 7.5 psi. The licensee specifies the Section XI requirement 1 of ?% of the full-scale for their 0-600 psig discharge gage j and, thus, assures an accuracy of only 12 ps (NOTE: The inspectors verified that the licensee specified only the 12 psi ,

accuracy for discharge pressure gages by examining the records l for the discharge pressure gages for RHR pumps 2A (9/29/87 calibration) and 2B (10/5/87 calibration)). The ISI Project Engineer informed the NRC inspectors that the range deficiency i had been previously identified by the licensee and that corrective action had been identified in a licensee conducted surveillance reported as Quality Assurance Surveillance Report (QASR)85-068, dated October 7, 198 The matter was described I

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for disposition in CP&L Nonconformance Report (NCR) S85-074, dated 10/2/8 The ISI Project Engineer stated that the corrective action had been to obtain and use gages that exceeded the Section XI requirements. The inspectors questioned this as a 8/7/87 completed procedure 08.2.2b for IST of Unit 1 RHR pumps indicated use of gages not conforming to Section XI requirements. -The Project Engineer indicated that the change to acceptable gages for the RHR pumps had nnly recently been provided. The inspectors expressed concern that the licensee had taken so long after identification of the nonconformance to take corrective action to obtain compliance with the TS implemented Section XI requirements (over '.'2 months from the 10/2/85 identification to an 8/7/87 test). Further, the

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inspectors commented that the TS provided for the licensee to obtain relief from the gage requirements if they could show that meeting the requirements was impractical. The in.ipectors were informed that the licensee had not preptred an evaluation to  ;

demonstrate the impracticality of performing the IST with acceptable gages (even for a limited period while obtaining and/or installing proper gages) and that they had not requested relie The inspectors identified the licensee use of the nonconforming gages as violation 325/87-38-01 and 324/87-39-01, Failure to Promptly Correct Nonconformance with Technical Specification Requirements Regarding Gage ( 2 ) In observing the licensee's installed gag?s, the inspectors noted that teflon tape had been used at threaded joint As teflon has a high flouride content and might travei as an undesirable impurity into important safety-related systems, the inspectors questioned its use. The licensee was requested to provide their requirements regarding acceptable or prohibited materials for use in safety-related fluid system The requirements were not determined prior to the end of the inspection and the matter was identified as unresolved item 325/87-38-02 and 324/87-37-02, Requirements for Use of Teflon Tap (3) In discussing the licensee's use of new gages, the inspectors l were informed that the licensee anticipated that the use of more i

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accurate gages might aid in avoiding declaring service water pumps inoperable or avoiding increased frequency testing because of excessive deviations from pump reference values. The licensee stated that tests of these pumps often resulted in devlations requiring the pumps to be declared inoperable or to be tested more frequently although no significant mechanical or hydraulic degradation were present. The inspectors questioned whether the problem might not also be due to the licensee's failure to duplicate the hydraulic circuit that was present when I

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8 the reterence values were established. The ISI Project Engineer stated that this and other possible variables adversely affecting the testing were being examined. The inspectors informed the licensee that this matter would be identified for further NRC review as Inspector Followup Item 325/87-38-03 and 324/87-39-03, Duplication of Reference Conditions in Pump Test Within the areas examined, the inspectors identified one violation as described in 5.f.(1) abov I

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