IR 05000335/1979013

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IE Insp Rept 50-335/79-13 on 790518-25.No Noncompliance Noted.Major Areas Inspected:Verification,Containment, Integrated Leakage Rate Testing,Snubbers & Previous inspector-identified Findings
ML17206A968
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 06/27/1979
From: Dyer J, Verdery E, Webster E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17206A967 List:
References
50-335-79-13, NUDOCS 7908170545
Download: ML17206A968 (16)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTAST. ~ N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report No. 50-335/79-13 Licensee:

Florida Power and Light Company 9250 West Flagler Street Miami, Florida 33101 Facility Name:

St. Lucie, Unit

Docket No. 50-335 License No.

DPR-67 Inspection at St. Lucie Site near Fort Pierce, Florida Inspectors:

c E.

H.

Web Date Signed J.

A. Dyer H. L.,Whitener BE J.

Yeomans Approved by: K+33 E.

H. Verdery, Acting Chief, RONSB

Da e Si ne I

Date Signed g7

Date Signed Date Signe SUMMARY Inspection on May 18-25, 1979 Areas Ins ected This routine, unannounced inspection involved 207 inspector-hours on-site in the areas of IEB 79-06B verification, containment integrated leakage rate testing, snubbers, and previous inspector-identified findings.

Results Of the areas inspected, no apparent items of noncompliance or deviations vere identifie DETAILS Persons Contacted Licensee Employees-C.

M. Wethy, Plant Manager-J.

H. Barrow, Operations Superintendent

  • J ~ E. Bowers, Maintenance Superintendent-C. A. Wells, Operations Supervisor-R.

R. Jennings, Technical Staff Supervisor

"-G. M. Vaux, QC Supervisor

"A. W. Bailey, QA Supervisor P. L. Fincher, Training Supervisor

""N. G. Roos, QC Engineer P. Shell, ILRT Director K. Simons, Engineer, Corporate D. Sager, Engineer C. Wilson, Maintenance Supervisor C. Smithy, Maintenance (Turkey Point)

Ebasco Services W. Roman, Principal Engineer, ILRT Consultant Other ILRT specialists.

Other licensee employees contacted included technicians.

-Attended exit interview Exit Interview The inspection scope and findings were summarized on May 25, 1979, with those persons indicated in Paragraph 1 above.

Licensee Action on Previous Inspection Findings Not inspected.

Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.

New unresolved items identified during this inspection are discussed in Paragraph 6.

Plant Status At the time of the inspection, St.

Lucie Unit

was in cold shutdown, conducting a Containment Integrated Leak Rate Test (CILRT) of the completion of a refueling outage.

6.

Verification of IEB 79-06 and 79-06B Response The inspectors verified licensee action has been taken as described in their response to IE Bulletins 79-06 and 79-06B dated April 24, 1979 The specific areas reviewed and findings in each area are listed below:

Operator Training (1) The inspectors observed a training session given to nine opera-tors concerning the Three Mile Island 2 incident and recent procedure changes at St.

Lucie.

The presentation lasted about four hours, was adequately presented and appeared technically sufficient.

(2)

One inspector interviewed seven operators from two different operating shifts concerning information on the events at Three Mile Island, recent Emergency Operating Procedure Changes, admin-istrative controls on Emergency Safety Features (ESF) equipment, criteria for operation of reactor coolant pumps and determination of sufficient primary system subcooling.

The inspector had the following comments:

(a)

Operators did not appear to know or indicate use of all administrative controls established to assure ESF opera-bility following maintenance on testing.

(b)

Operators had not been informed of licensee policy on prompt NRC notification in the event of an incident.

Licensee management indicated resolution of this. policy was underway at the time.

Subsequent to the inspection, prior to reactor criticality, licensee management confirmed by phone that NRC notification direction had been given in the Night Orders, with a emergency procedure change to follow.

(c)

Several operators demonstrated limited ability to take corrective actions on multiple casualty scenarios.

Licensee management committed to develop an emergency operating procedure covering void formation with reactor coolant pumps inoperable.

This shall be reviewed in future inspections (335/79-13-01).

Licensee management committed to conduct training in this area.

This training shall be reviewed in future inspections (335/79-13-02).

No items of noncompliance or deviations were identifie be Operating Procedure Review The operating procedures listed below were checked against the applicable systems prints to assure licensee direction for valve, breaker, and switch positions place engineered safeguards systems in an operable status.

~Ss tern Operating Procedure Number Drawing Number Containment Spray 0420020, Rev.

Main Steam Auxiliary Feedwater 0810020, Rev.

0700020, Rev.

Component Cooling Water 0310020, Rev.

8770-G-088, Rev.

8770-G-083, Rev.

8770-G-079, Rev.

8770-G-080, Rev.

Chemical and Volume Control Diesel Generator Fue'l Oil Diesel Generator Cooling Water 0210020, Rev.

2200020, Rev.

2200020, Rev.

E-19367-210-121, Rev.

8770-G-086, Rev.

C-81381-1811, Rev.

G C-81381-1837, Rev.

H C-18381-18198, Rev.

J C"81381-18197, Rev.

J Diesel Generator Air 2200020, Rev.

Start Diesel Generator Lube 2200020, Rev.

Oil C-81381-18692, Rev.

G D-81381-17851, Rev.

C-81381-18112, Rev.

Safety Injection Tanks 0410021, Rev.

Low Pressure Safety 0410020, Rev.

Injection High Pressure Safety 0410020, Rev.

Injection E-19367-210-131, Rev.

E-19367-210-130, Rev.

E-19367-210-130, Rev.

Sodium Hydroxide Service Building Ventilation System 0420020, Rev.

2000024, Rev.

BCS-125-1-303, Rev.

FSAR fig 9.4-2A The inspectors submitted a list of questions and findings to the licensee which will be followed up on in future inspections (335/79-13-03).

Briefly, the comments covered the following problems:

(1)

Procedures did not list required valve positions for several vents or drain valves shown on the applicable prints for the safety injection system, diesel lube oil and diesel cooling water systems.

(2)

Valve V7102 is directed to be locked open in procedure 0410020 step 8.1 and locked shut in procedure 0420020 step 8.1.

(3)

Nomenclature on valve numbers did not agree between print and procedure in three cases.

No items of noncompliance or deviations were identified.

(4)

During the review document control forwarded two copies of drawing D-81381-18692.

One copy was revision G which appeared to be the most recent revision.

The other was revision E which indicated field changes to be made to the diesel generator air start system.

The inspector followed up by checking the licensees drawing index, which was current as of May, 1979.

The index showed both drawings as being effective, one under drawing control number 8770-4478 revision 5 dated 8/13/73 (the revision E drawing), the other under number 877-4432 revision 1 (revision G drawing).

CFR 50, Appendix B, Criterion VI as implemented through the Topical Report for equality Assurance, Requirement 6.0 and equality Procedure 6.4, requires superceded drawings be removed from active files, marked as

"VOID", and filed in separate drawing sets.

Licensee management was informed that the failure to properly mark and separate drawing D-18381-18692 revision E

as one of approximately 43,000 drawings is unresolved pending review of larger sampling of drawings in future inspections (335/79-13-04).

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Surveillance Procedure Review The surveillance procedures listed below were checked using applicable system drawings to assure that ESF systems are returned to operable condition following any maintenance or testing.

Additionally, results of the last completed surveillances were reviewed to verify performance met required acceptance criteria.

Those procedures marked with an asterisk ("") below received this additional review:

OP 0410052, Rev.

OP 0420050, Rev. 9-OP 220050, Rev.

12"-

OP 1900050, Rev.

Check Valve Backleakage Containment Spray Periodic Test Emergency Diesel Periodic Test Control Room Pressure Test

-5-OP 0400050, Rev.

2-"

OP 0700050, Rev. 5-OP 0420051, Rev.

OP 0410050, Rev.

6-OP 0030120, Rev.

OP 0030151, Rev.

Periodic Integrated Test of ESF Auxiliary Feedwater Periodic Test Containment Spray-Nozzle Air Flow Test HPSI/LPSI Periodic Test Prestart Check-off Remote Shutdown Monitoring Instrumentation Channel Check and Switch Position Verification OP 2000053, Rev.

M-0705, Rev.

MP 0210160, Rev.

'P 0210161, Rev.

MP 0210161, Rev.

OP 1900020, Rev.

MP 0420160, Rev.

MP 0420161, Rev.

MP 0920061,, Rev.

MP 2200060, Rev.

MP 2200061, Rev.

M-0012, Rev.

M-0013, Rev.

M-0014, Rev.

Hydrogen Recombiner Main Steam Safety Valve Maintenance lA Charging Pump Maintenance 1B Charging Pump Maintenance 1C Charging Pump Maintenance Auxiliary and Control Building Ventilation System lA Containment Spray Pump Maintenance 18 Containment Spray Pump Maintenance Testing of Class 1E Underground Cables 1A Emergency Diesel Maintenance 1B Emergency Diesel Maintenance Component Cooling Water Pump-Disassembly and Reassembly HPSI Pump - Disassembly and Reassembly LPSI Pump - Disassembly and Reassembly The inspectors submitted questions and comments to the licensee on findings from this review which will be followed up on in future inspections with b., above.

These findings all concerned minor typo-graphical errors and items to clarify procedures.

No items of noncompliance or deviations were identifie d.

Maintenance Controls The inspectors reviewed the following procedures to assure adequate controls to assure retesting of ESF equipment following maintenance and to assure ESF system operability following extended outages:

e.

AP 0010430, Rev.

Maintenance on Seismic Class 1 Systems QI-11 PR/PSL-1, Rev.

Test Control QI-ll PR/PSL-2, Rev.

Mechanical Test Control QI-ll PR/PSL-3, Rev.

Electrical Test Control QI-11 PR/PSL-4, Rev.

Instrumentation and Control Test Control OP 0030121, Rev.

Reactor Plant Heatup-Cold to Hot Standby OP 0030120, Rev.

Prestart Check-off List OP 0030122, Rev.

Reactor Startup The inspectors had no further questions in this area.

Other Items Checked The inspectors looked into the following areas only to gather information for NRC use:

(1)

The licensee does not administratively require independent verifi-cation of valve/switch/breakers positions.

(2)

No operating procedures require partial use of safety injection equipment to assist in pressurizer level control during routine operations.

(3)

Licensee operating and emergency procedures list no precautions concerning when to secure reactor coolant pumps.

The emergency operating procedures recently approved direct continued operation of these pumps during applicable events.

Training in this area has indicated that the pumps should be secured only when indica-tions are that plant integrity is in jeopardy due to immenent damage to the pump.

(4)

The licensee presently has no procedure to feed dry steam generators while hot.

Licensee management agreed to look into this area for possible development of such a procedur (5)

Present tagging practices provide potential for obscuring status indicators, however, operators have been careful to avoid this occurrence.

Licensee management indicated that a

new tagging procedure using small tags is under development for use in the near future.

This will be followed up in future inspections (335/79-13-05).

(6)

Licensee procedures for the following off/normal and emergency conditions have been revised to include primary system subcooling requirements, continued reactor coolant pump operation, and HPSI/LASI pump operation as directed in IEB 79-06B:

EOP 0120041, Rev.

Steam Generator Tube Leak/Failure EOP 0810040, Rev.

Main Steam Line Break EOP 0700040, Rev.

Loss of Feedwater or Steam Generator Level EOP 0120042, Rev.

Loss of Reactor Coolant 0-N OP 0120036, Rev.2 Pressurizer Relief/Safety Valve-Off Normal Operation An inspector reviewed each of the above procedures and attended a

training session on them.

There were no further questions in this area.

7.

Previously Identified Items (Closed)

Open Item (335/78-26-05)

Diesel Generator Air Start Manual Isolation Valve Controls.

As indicated in paragraph 13 of IE Report 335/79-11, the licensees procedure OP 2200050 did not adequately direct restoration of the diesel generators to operable status following testing.

Revision 12 to procedure OP 2200050 has corrected this.

The inspector had no further questions in this area.

b.

(Closed)

Open Item (335/79-09-02)

Change Procedure OP 0700050 to Assure AFW Pump Operability After Test.

Revision 5 to this procedure incorporates this direction.

The inspector had no further questions in this area.

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(Closed)

Open Item (335/79-06-07)

Documentation of Material Used in a Plant Modification Missing.

As indicated in paragraph 3 of IE Report 335/79-11, the documentation for the plate material used in modifying a safety injection tank brace was found but indicated use of ASTM A-36 material vice the A515 Gr.

70 material as called for.

The licensee has since changed the work order to indicate use of A-36 material.

The inspector had no further questions in this are.

Containment Integrated Leak Rate Test The inspector reviewed licensee surveillance activity to determine that the Containment Integrated Leak Rate Test (CILRT) was performed in accordance with the requirements of

CFR 50, Appendix J; Technical Specification 3/4.6; St. Lucie Unit 1, FSAR, Section 6.2; ANSI 45.4; and test procedure 1300050, Revision 1.

Selected sampling of the licensee's activities which were inspected included:

(1) review of the test procedure 1300050, Revision

to verify that the procedure was approved and conformed to regulatory requirements; (2) observation of the test performance to determine that test prerequisites were completed, special equipment was installed and calibrated and that appropriate data were recorded and analyzed; and (3)

preliminary evaluation of leakage rate test results to verify that leak rate limits were met.

Pertinent aspects of the test are discussed in the following paragraphs'.

General Observations The inspector witnessed and/or reviewed portions of the test preparation, containment pressurization, temperature stabilization, leak chasing, and data processing in the period May 18-25, 1979.

The following items were noted:

(2)

The test was conducted in accordance with an approved procedure maintained at the test control center (electrical penetration room).

Changes to the procedure were documented.

A sampling of test prerequisites was reviewed and found to be complete.

(3)

A sampling of plant systems required to maintain safe reactor shutdown and to maintain test control was reviewed and found to be in service.

(4)

A sampling of penetration valve alignments was observed and found to be aligned per procedure.

(5)

A sampling of special test instrumentation was reviewed and found to be installed and calibrated.

Instrument checks were performed just prior to the test.

(6)

Data required for the performance of the containment leak rate calculation was recorded at 15 minute intervals.

Data was assembled and retained for final analysis and evaluation.

(7)

Problems encountered during the test were described in the test event log.

(8)

Final analysis of the leak rate data will be performed by the licensee's consultant, Ebasco Services, Inc., and will be reported in the test report to the Office of Nuclear Reactor Regulation

-9" (NRR).

The inspector's preliminary review indicates that the leakage rate achieved subsequent to isolating the containment spray line "B" header was less than 0.75 Ltm.

Add-on leakage for isolated leakage paths had not been determined at the conclusion of the type "A" test.

These leakages will be included in the final evaluation of containment leak rate.

b.

Procedure Review The inspector reviewed the CILRT test procedure and discussed the findings with the test supervisor and plant management.

Principal points discussed concerned the leakage rate acceptance limit and allowable methods of correcting leakage paths to meet the acceptance limits.

NRC positions were presented to the licensee as follows:

(I)

Leak Rate Acceptance Limit The measured type "A" leakage rate plus the calculated 95/ confi-dence interval plus any add-on leakage resulting from local leakage measurement (at same test pressure)

after repair of isolated leakage paths shall be less than 75/ of the allowable leakage.

(2)

Method of Corrective Action Leakage paths which interfere with meeting the type "A" leakage limits and can be isolated, may be isolated and the type "A" test performed.

"Before" and "after" repair local leakage rate measure-ments will be performed for the leakage paths which were isolated.

The post repair leakage rate will be added to the type "A" 95$

upper confidence limit.

The difference between

"before" and

"after" repair local leakage measurements may not be subtracted from the type "A" leak rate measurement to bring this measurement within the test limits.

Licensee management advised the inspector that the above NRC positions would be observed.

C.

Instrument Calibration The inspector reviewed a sampling of instrument calibrations and found that special sensors used to measure test parameters were calibrated and traceable to National Bureau of Standards (NBS).

Review of instru-ment calibrations included:

'I)

Texas Instrument Pressure Gauges (2)

Wallace and Tiernan Rotometers (3)

EGSG Dew Point Hygrometer (4)

Phys-Chemical Humidity Detector

-10-The inspector had no questions on instrument calibrations.

d.

Test Description and Results Initial pressurization to the reduced test pressure of 19.8 psig was completed at about 3:30 a.m.

on May 24.

The initial measured leak rate exceeded the allowable leakage.

At 1:30 p.m.

a manual valve in the containment spary line "B" header was closed to isolate a leakage path.

The 24-hour test began at 4:00 p.m.

and was concluded at 4:00 p.m.

on May 25, when the supplemental leak rate verification test was initiated.

The leak rate was calculated by the total time and mass point methods using data recorded at 15 minute intervals.

The measured leak rate was 0.05 percent per day (total time method plus error)

and 0.044 percent per day (fitted mass point method).

The inspectors calculation of an 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> data sample yielded a leak rate of 0.052 percent per day upper confidence limit using the mass point technique.

These rates are well below the allowable leakage rate of 0.75 Ltm = 0.24 percent per day.

The inspector will review the licensee's test report when it is available.

The inspector discussed the closure of a manual valve I-V-07165 in the containment spray line with the licensee.

At the exit interview the inspector stated that closure of I-V-07165 would be reviewed further by the NRC.

The licensee was subsequently informed that closure of the valve in a seismic Category I, equality B closed system which would be water filled during a design base LOCA did not invalidate the type

"A" leak rate test results.

9.

Pipe Supports and Restraints The inspector 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 pipe supports and restraints; review of recent surveillance records; and follow up on open items.

Pertinent aspects of this review are discussed below.

Data Review The data for visual inspection (PWO 033611)

and functional testing (PWO 33414) indicate no failed snubbers.

Functional test data was corrected to operating conditions.

b.

Visual Inspection The inspector toured the containment building and inspected installed supports and restraints.

No leakage or abnormal deterioration was observe Open Item Follow Up, (Closed) Inspector Follow Up Item (335/78-22-02):

Procedure Revision.

The inspector reviewed M-0006, Revision 5, dated January ll, 1979, Inspection of Hydraulic Seismic Restraints, and had no further comments'he inspector reviewed M-0007, Revision 1,

dated January 11, 1979, Functional Testing of Hydraulic Seismic Restraints, and had no further comments.

(Closed) Inspector Follow Up Item (78-22-03):

Correction of functional test data to operating conditions.

The licensee had obtained vendor recommended temperature correction factors, had incorporated these factors in the test procedure and had extrapolated test data to operating temperature conditions.