IR 05000335/1978022
| ML17206A564 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/07/1978 |
| From: | Brooks E, Martin R, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17206A561 | List: |
| References | |
| 50-335-78-22, NUDOCS 7812140277 | |
| Download: ML17206A564 (11) | |
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<<<<*d,4 UNITED STATES NUCLEAR REGULATORY COMMISSION REGIDN II 101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30303 Report No.:
50-335/78-22 Docket No.:
50-335 License No.:
DPR-67 Licensee:
Florida Power and Light. Company Facility Name:
St. Lucie
Inspection at:
St. Lucie 1, Hutchinson Island, Florida Inspection conducted:
September 19-22, 1978 Inspectors:
H. L. Whitener E.
H. Brooks Accompanying Personnel:
None Approved by:
fi I (CiiW R.
D. Hartin, Chief Nuclear Support, Sect.ion No.
Reactor Operat,ions and Nuclear Support.
Branch Date Ins ection Summar Ins ection on Se tember 19-22 1978 (Re ort No. 50-335/78-22)
activity for safety relat.ed pipe support, and rest.raint syst,ems including a review of program cont.rois; inspection and test schedules, procedures, and result.s; and a visual examination of select.ed rest.raints and associat.ed hardware.
The inspection involved 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> of on sit.e inspection by two NRC inspect.ors.
Result,s:
Of the area inspected one it.em of noncompliance was ident,ified concerning the frequency of conducting visual inspections of hydraulic shock suppressors (335/78-22-0]).
7 812 14 0 4~'7
RII Rpt.
No. 50-335/78-22 Details I gl7 78 Prepared by:
H. L: Whitener, Reactor Inspector a
e Nuclear Support Section No
~
Reactor Operations and Nuclear Support B anch
~h E.
H. Brooks, Reactor Inspector ate Nuclear Support Section No.
Reactor Operations and Nuclear Support Branch Dates of Inspectio September 19-22, 197S Revieeed by:
R.
D.
artin, Chief Nuclear Support Section No.
Reactor Operations and Nuclear Support Branch D te 1.
Persons Contacted
- C.
M. Wethy, Plant Manager
"R.
R. Jennings, Technical Supervisor
- J. E. Bowers, Maintenance Superintendent T. A. Dillard, Assistant Superintendent, Mechanical Maintenance
"C. L. Wilson, Maintenance Supervisor
- J. H. Barrow, Operations Superintendent-G.
M. Vaux, QC Supervisor
- A. W. Bailey, QA Operations Supervisor
- J.
H. Ruby, Administrative Supervisor
- N. C. Roos, QC Operations
- Denotes those present at the Exit Interview.
2.
Licensee Actions on Previous Ins ection Findin s
Not in the scope of this inspection.
3.
Unresolved Items None identified during this inspectio ~
~
RII Rpt.
No. 50-335/78-22-2-4.
Exit Interview The areas inspected and inspection findings were discussed with Mr. Wethy and members of his staff on September 22, 1978.
These items are delineated in this report.
In discussions during the inspection, the licensee indicated disagree-ment with the Inspector's position that if no inoperable snubbers were identified during the initial inspection at 6 months after initial critical, Technical Specification 4.7.10.1.1 and Table 4.7-3 require that the next visual inspection be performed at 12 months
+
25~ from the previous inspection.
Licensee personnel stated that.
they interpret these specifications to allow an 18 month + 25~
inspection interval if no inoperable snubbers are identified at the initial 6 month inspection.
The inspector identified the failure to perform a visual inspection of snubbers at 12 months
+ 25$ as an apparent item of noncompliance-(see paragraph 5.c)
and informed the licensee that their objection was noted and would be referred to IE, Region 2 management for review.
The licensee was informed by telephone on September 25, 1978, that this matter had been reviewed by the IE Region II office and would stand as a non-response item of noncompliance.
5.
Pi e
Su orts and Restraints The inspectors reviewed the licensee's surveillance program for safety related hydraulic supports and restraints.
This included a
review of procedures for technical adequacy; examination of various installed dynamic and fixed supports and restraints and associated hardware; and, review of recent surveillance records.
Pertinent aspects of this review are discussed below.
Shock Su ressor Ins ection and Test Procedures (1)
Visual Ins ection Procedure The inspectors reviewed Maintenance Procedure 0006 (MP0006),
Revision 4 dated March 6, 1978, for technical adequacy and discussed the findings with the licensee as follows:
(a)
Limits of operable piston rod travel have not been identified in the acceptance criteria and verified for the hot and cold position ~
(
RII Rpt.
No. 50-335/78-22
"3" (b)
Inspection of vent holes to ensure the vents are open is not identified in the procedure nor included in the check off list on the data sheet.
(c)
Procedure instructions and data sheets do not specifi-cally delineate all items to be inspected.
Items to be inspected need to be defined to assure uniform inspection and to document the results'd)
Procedure instructions and data sheets did not provide for recording the as found - as left fluid levels.
(e)
The procedure does not define the minimum operable fluid level for Grinnell Snubbers.
- (f)
The procedure does not require that a functional test be performed on a snubber prior to installation after maintenance.
(g)
The procedure does not specify the use of baseline piston position data as a guideline to determine appropriate piston positions.
(2)
Functional Test Procedure The inspector reviewed Maintenance Procedure 0007 "Functional Testing of Hydraulic Seismic Restraints for technical adequacy and discussed the findings with the licensee as follows:
(a)
The acceptance criteria does not include a correction to the measured lockup velocity and bleed rate to correct for the difference between test temperature and operating temperature.
(b)
(c)
The procedure does not require that free motion of the piston rod be verified.
The procedure does not contain instructions for refilling and bleeding the snubber or provide a
reference to a technical manual for these instructions.
The licensee vill evaluate the items in 5.a.l and 5.a.2 above and address these matters in a revision to Procedure M006 and
O'
REI Rpt.
No. 50-335/78-22 M0007.
Procedure revision will be completed by January 1,
1979, or prior to reuse of the procedure.
Revision to these procedures was identified for followup inspection (335/78-22-02).
Administrative Controls The inspector reviewed Administrative Procedure (AP) No. 0010437,
"Schedule of Maintenance Surveillance Requirements,"
to deter-mine that adequate controls had been established for imple-menting the shock suppressor inspection and test procedures.
The inspector found that AP 0010437 adequately specifies the inspection requirements for visual inspection and functional testing of snubbers but does not specify the method of tracking the variable frequency inspection dates.
Quality Instruction 16.1 (QI-16.1) "Corrective Action," specifies the responsibility for issuing Corrective Action Requests for identified deficient equipment and requires Department Head and QC verification of closeout of deficiencies.
The licensee stated that an increased frequency would be identified and tracked through this correc-tive action log.
Status of corrective action is reviewed weekly by Department Heads.
The inspector concluded that an adequate scheduling and tracking system had been developed.
Ins ection/Test Results and Schedulin The inspectors reviewed recent visual inspection and functional test results for safety related hydraulic snubbers.
Records indicate that visual inspection were performed on October 8, 1976, and April 12, 1978.
Functional testing of 10 snubbers was performed April 14, 1978.
These records indicate that no inoperable snubbers have been identified; however, the visual inspection frequency requirements of Technical Specification Table 4.7-3 were not met.
Technical Specification 4.7.10.1.1 in conjunction with Table 4.7-3 requires that subsequent to the initial inspection, at. six months after initial criticality, the licensee will enter the inspection table (Table 4.7-3)
as if the unit was previously at a six month inspection interval.
This means that the next. inspection interval, assuming no failures, would be at 12 months from the previous inspection.
The licensee scheduled and performed the next inspection at
months (i.e., October 8, 1976, to April 12, 1978).
From discussion with licensee personnel the inspectors concluded
RII Rpt.
No. 50-335/78-22-5-that the missed frequency was not due to a failure in the surveillance tracking system but resulted from an incorrect interpretation of the Technical Specification requirements.
This item was identified as a no response item of noncompliance in that the licensee has performed an inspection at 18 months and determined that there are no inoperable snubbers.
This item is assigned an identification number (335/78-22-01)
and is considered closed.
d.
Acce tance Criteria/NRC Positions (1)
Locku Velocit and Bleed Rate The licensee has established criteria for lockup velocity and bleed rate through an engineering analysis.
However, as discussed in Pargraph 5.a the acceptance criteria for functional testing does not include a correction for temperature difference between test and operating conditions.
The licensee agreed to determine the correction factor and verify that the corrected functional test results meet acceptance criteria.
Any failures should be reported to the NRC.
This matter will be reviewed at a subsequent inspection (335/78-22"03).
(2)
Seal Material The inspector discussed the NRC position that an expected lifetime for seal material other than EP must be established on the basis of an engineering evaluation which considers the effect of hydraulic fluid, operating temperature, moisture and radiation environment on the material, and the compression set characteristics of the material.
Other options available to the licensee were identified as:
(1) install EP material in the suppressors and inspect in accordance with the Technical Specification frequencies; (2) replace the seals with the same non-EP material and establish the material lifetime as that period of time which the suppressors have operated in their environment without adverse effects on the seals and inspect in accordance with the Technical Specification frequencies; and (3) inspect the suppressors with non-EP seal material on a
31 day frequency.
The licensee believed all installed seal material to be ethylene propylene but agreed to perform a record review to confirm this condition.
If non-EP seals are installed, the licensee will replace
RII Rpt.
No. 50-335/78-22
~
~
-6-non-EP material with EP or pursue another option as discussed above.
This item was identified for future inspection (335/78-22-04).
(3)
Re resentative Sam le The inspector advised the licensee that the term,
"Repre-sentative sample,"
as used in the Technical Specification, requires evaluation of the factors affecting shock sup-pressor operation.
The licensee agreed to develop written guidelines for selection of the snubber test sample.
This item was identified for future inspection (335/78-22-05).
(4)
Fluid Level The licensee has not documented the technical basis for the minimum fluid level used in acceptance criteria for Grinnell or Bergen Paterson snubbers.
A review of tech-nical manuals available to the licensee did not yield this information.
The licensee agreed to contact the vendors and determine the minimum fluid level for an operable snubber.
This item was identified for future inspection (335/78-22-06).
Snubber Ins ection Accompanied by licensee personnel, the inspector toured acces-sible areas and examined hydraulic snubbers, fixed supports, adjustable supports and the associated hardware on parts of the main steam, feedwater, component cooling and safety injection systems.
No discrepancies were identified.