IR 05000335/1988013
| ML17222A339 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/23/1988 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17222A338 | List: |
| References | |
| 50-335-88-13, 50-389-88-13, IEB-87-002, IEB-87-2, NUDOCS 8807130225 | |
| Download: ML17222A339 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323 Report Nos.:
50-335/88-13 and 50-389/88-13 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33i02 Docket Nos.:
50-335 and 50-389 Facility Name:
St.
Lucie 1 and
Inspection Conducted:
May 31 - June 3, 1988 Inspector:
ey Approved by:
a e, ec
>on
)e aerials and Processes Section ivision of Reactor Safety License Nos.:
>
e a
e cygne Scope:
SUMMARY This routine, unannounced inspection was conducted in the areas of IST of pumps and valves including selected procedure reviews, observation of work activities, surveillance test results, and equipment calibration records; activities associated with NRC Bulletin 87-02 (TI 2500/26);
and action on previous inspection findings.
Results:
In the areas inspected, violations or deviations were not identified.
807i30225 880624 PDR ADDCK 05000335
PNU
REPORT DETAILS Persons Contacted Licensee Employees
~J.
Barrow, Operations Superintendent G. Boissy, Plant Manager
- C. Burton, Operations Supervisor J.
Dyer, QC Inspector R.
Rhodes, QC Inspector
~N.
Roos, QC Supervisor
~D, Stewart, Test and Performance Lead Engineer Other licensee employees contacted during this inspection included engineers, operators, QA/QC personnel, security force members, techni-cians, and administrative personnel.
"Attended exit interview 2.
Inservice Testing of Pumps and Valves (73756)
The inspector examined the IST activities described below to determine whether regulatory and code requirements were being met.
The current IST programs and applicable codes are as follows:
Unit 1
-
St.
Lucie Unit 1 Inservice Test Program - Submitted by FP8L letter L-87-370 dated September 4,
1987 ASME B8PV Code,Section XI, 1983 Edition, S83 Addenda Unit 2
-
St.
Lucie Unit 2 Pump and Valve Inservice Test Program, RO submitted by FP&L letter L-88-158 dated'April 4, 1988 ASME R8PV Code,Section XI 1980 Edition, W81'ddenda See RII Reports 50-335/86-25, 50-389/86-24, 50-335/87-23, and 50-389/87-22 for documentation. of previous inspections in this area.
The IST Programs are implemented and controlled by the following Adminis-trative and QC Procedures:
0010132, R9, ASME Code Testing of Pumps and Valves 1-0010125, R72, Schedule of Periodic Tests, Checks and Calibrations 1-0010125A, R8, Surveillance Data Sheets 2-0010125, R23, Schedule of Periodic Tests, Checks and Calibrations
2-0010125A, R5, Surveillance Data Sheets QI 5-PR/PSL-l, R32, Preparation, Revision, Review and Approval of Procedures QI 6-PR/PSL-1, R13, Document Control QI 11-PR/PSL-7, R2, Control of Code Safety and Relief Valves Pump Testing The inspector witnessed the monthly pump runs and surveillances for CS Pump 2A and Hydrazine Pump 2A.
All documentation associated with the pump runs and surveillances was reviewed and compared with pump baseline data.
In addition, operating Procedure No. 2-0420050, R15, Containment Spray and Iodine Removal System - Periodic Test, was reviewed.
In addition to witnessing the above pump surveillances, the inspector reviewed the following records associated with pump survei llances:
Control Room Routine Pump Testing Summary for 1988 - Units 1 and 2:
Monthly Pump Code Run Surveillance Data, January
-
May 1988, for the following pumps was reviewed and compared with baseline data:
2A HPSI 2A CS 2A'CM 2A CHG 1A AFM 1A LPSI As part of this review, Operating Procedure No. 2-0410050, R12, HPSI/LPSI Periodic Test, was reviewed.
Calibration records for the following instrumentation used for the above pump survei llances were reviewed:
P rometers Pressure Leve'1 3~au es Instrumentation Dis lacement e ers E 378 E 377 PI"07" 1A PIA-2212 PI-3314 PI-12-18A PI"09."7A PI "14-1A PI-3316 LIS-07-2 LIT-07-2A E 301 E 223 E 314 E 346 E 236 E 229'
b.
Valve Testing The inspector reviewed the following surveillance records relative to valve testing:
Unit 1
-
May 1988, Data Sheets 8A and 8B - Valve Cycle Test
-'on Check Valves May 1988, Control Room Quarterly Valve Cycle Test Summary - Data Sheets 8A and 8B Unit 2
-
May 1988, Data Sheets 8A and 8B - Valve Cycle Test-Non Check Valves May 1988, Control Room Quarterly Valve Cycle Test Summary - Data Sheets 8A and 8B c.
The above implementing documents, in-process pump survei llances, and pump and valve test records were reviewed to verify that:
Licensee had assigned responsibilities for:
preparation, review, and approval of IST procedures; scheduling of IST; performance of testing; performance of post-maintenance and post-modification IST; and proper certification and calibration of IST instruments.
Test procedures used are the latest approved and acceptance criteria are valid.
The licensee performs IST per an approved schedule within the limitations described in the IST program, including increased frequency testing.
IST results are recorded per the approved procedures and that data are evaluated within time constraints of the ASME Code.
IST procedures and data reflect requirements of the ASME Code including:
increased frequency testing requirements;
'pump vibration test data analysis and acceptance criteria justif>ca-tion, including location of vibration measurements; requirements that pump tests be conducted at reference conditions; and compliance of test instruments to ASME Cdde requirements.
Test procedures are adequate and complete and that test conditions specified in Section XI of the ASME Code are met.
.IST data are evaluated per requirements of the ASME Code,'ection X IST records are maintained as required be the ASME Code,Section XI.
d.
Relative to the above examinations, the inspector identified certain weaknesses in the licensee'-s documentation of IST of pumps and valves.
It should be noted that a prior inspection had identified weaknesses in the valve IST program (See IFI 335, 389/88-07-02).
At the time of the current inspection, the licensee had completed most of the improvements resulting from the weaknesses noted in the previous inspection.
However, some improvements, e. g.
computer program to more effectively trend valve stroke times and improved evaluation of trends, were still in the process of being implemented.
Some of the documentation weaknesses identified by the current inspection were similar to those identified by the previous inspection and will be resolved when improvements that are in process are fully implemented.
The following summarizes the inspector's findings:
The inspector noted inconsistencies in recording stroke times for rapid-acting power operated valves.
The NRC's position has
, been that rapid-acting valves (stroke times of two seconds or less)
do not require trending in accordance with ASME Section XI, IMV-3417(a).
Based on this position, the licensee has changed their procedures for rapid-acting valves to require that, if the valve strokes in less than two seconds, a stoke time of
"< 2 seconds" be recorded rather than the actual time.
In review of the May 1988, Data Sheets 8A and 8B the inspector noted that in some cases
"1 second",
"<
1 second ', or an exact time such as
".78 seconds" was being recorded.
The inspector also noted inconsistencies in the way stroke times for three second and five second valves were being recorded.
In some cases
"<
seconds" was being recorded.
In other cases, the time to the nearest second (as required by ASME Code)
was being recorded.
Most of the times were recorded as the exact time measured, such as
"1.37 seconds."
These inconsistencies in the way stroke times are recorded, complicate meaninqful trending of stroke times.
The licensee had recognized this problem and had issued instructions'o clarify recording.requirements.
Additional instructions were issued to clearly indicate the following requirements for recording valves stroke times:
2 second valves All other valves Record "< 2 seconds" if stroke-time less than 2 seconds; record actual time if greater that
seconds Record actual stroke time unless time is less than 1 second; if time is less than 1 second, record time as "1 second"
Based on NRC's position of not requirinq trending for rapid-acting valves, no code violations were identified.
For the March 1988 Code Run of the 1A AFW pump<
the Vibration Instrument No.
was recorded as
"E-29. 'he licensee did not have an instrument identified as
"E29."
The number probably should have been "E-229" based on the fact that '-229" was used for the April Surveillance.
For the May 1988 Surveillance, the vibration measurements were a factor of ten less than that recorded for the previous month.
It appears that the wrong scale on the meter was used, Both problems do not appear to be significant, but are other examples of documentation weaknesses.
For the 2A CCW pump, the inspector noted that the data did not include the identification of the gauge used to measure the suction pressure to the pump.
Further inves-tigation revealed that the gauge used was a permanently installed qauge in a temporary location (TX) identified on the drawing, was in the NOTTE program, and was calibrated.
The licensee indicated that a drawing change was being made to identify the gauge as a permanent location (PI) gauge and that the test procedure would be changed to identify the permanent location gauge.
In order to review the licensee's improvements in documentation of IST data, the above documentation problems are identified as IFI 335, 389/88-13-01, Discrepancies in Documenting IST Data.
Violations or deviations were not identified in review of this program area.
3.
Temporary Instruction (TI) 2500/26, Inspection Requirements for NRC Compliance Bulletin 87-02, Fastener Testing to Determine Conformance With Applicable Material Specifications.
Over the past year, some NRC procurement inspections have included the collection and testing of a
small sample of fasteners.
This limited program was initiated in response to a concern by Industrial Fastener Institute over the potential use of inferior fasteners in milit'ary and industrial applications, including Nuclear Power Plants.
The results indicate that ll out of 32 fasteners tested do not meet specification requirements for mechanical and/or chemical properties.
In a -separate effort, one utility tested 1539 fasteners following discovery that commercial grade fasteners
.had been used in safety-related applications, The test results indicated that 399 failed to meet specification require-ments for mechanical and/or chemical properties.
Based on evaluations performed by the utility, the fasteners which did not meet specification would have fulfilled their safety functio Based on the testing described above, the NRC issued NRC Bulletin 87-02 on November 6, 1987.
The Bulletin requested that licensees perform independent testing on a
sample of fasteners and provide information to the NRC as follows Describe characteristic examined during Receipt Inspection (RI) of fasteners and controls for storage and issue Select ten safety-related and ten non safety-related fastener from current stock and perform mechanical and chemical testing in accordance with specification requirements
-
The NRC is to participate in selection of the fasteners for test.
Forward test results and supporting information to the NRC For any fastener found out specification, provide an evaluation of the safety significance Based on the results of the testing and review of current procedures, describe any further actions being taken to assure fasteners meet specification requirements.
The licensee's response (Letter L-88-73) providing the requested informa-tion is dated February 12, 1988.
Based on discussions with the resident inspector and the licensee, the resident inspector participated in selecting the sample of fasteners to be tested.
The purpose of this inspection was to review the licensee's procedur'es for control of fasteners and compare the procedures with descriptions in the licensee's response.
The following summarizes the inspector's review:
a.
Receipt Inspection Relative to receipt inspection, the inspector reviewed the licensee s
response to Bulletin 87-02 and the following procedures:
gP 4. 1, R19, Control of Procurement Originated By Operating Plant Personnel gP 4.4, R20, Control of Procurement Originated By Non-Operating Plant Personnel gP 7. 1, R9, Receipt Inspection of Materials, Parts and Components at the Plant Site
The above procedures define equality Levels as identified in Attach-ment 3 to FP8 L's response.
In general, safety-related fasteners are gL-1 or gL-2.
gL-1 and gL-2 items are procured from a vendor that has had a licensee gA review and approval of their program.
(L-l, 2 and 3 items require receipt inspection to gP 4. 1.
Receiving inspec-tion verifies that materials meet purchase order requirements including verification that vendor furnished documents such as CMTR's meet requirements.
The purchase order refers to licensee S(AD's (Attachment 4 to licensee response),
which identify testing and documentation requirements for the material or equipment ordered.
Generally, safety-related fasteners wi 11 require chemical and physical tests with a CMTR, Receipt inspection is not required for non safety-related fasteners.
b.
Storage, Issue and Control Relative to storage, issue and control of fasteners, the inspector reviewed the licensee's response and the following procedures:
gP 8. 1, RS, Identification and Control of Materials, Parts, and Components at the Plant Site gP 13. 1, R5, Handling, Storage, and Shipping of Material, Parts, and Components gI 7-PR/PSL-1, RII, Control of Purchased Materials, Equipment and Services gI 8-PR/PSL-1, R10, Identification and Control of Materials, Parts and Components gI 13-PR/PSL-1, R10, Handling, Storage and Shipping Administrative Procedure 0010433, R33, Nuclear Plant Work Orders As stated in the licensee's.
response, materials are controlled using Material and Supply (M8S) numbers.
The control of safety-related fasteners is controlled by specification of replacement fasteners through the M8S number and the Nuclear Plant Work Order System.
gL-1 and gL-2 fasteners are tagged with equality Identification Tags which list the P.O.
Number, M8S number, RI number, and environmental qualification identifier.
C.
The inspector reviewed the revision history or Procedure gP 7.1 to determine the significance and/or reasons for recent procedure changes.
No significant revisions have been made in'he last two year d.
The inspector reviewed the licensee's description of further action being taken as required by Bulletin 87-02.
For the safety-related fasteners tested, three were identified that were marginally rejectable as follows:
Heavy Hex Nut 4"-13 (A-194, Gr. 8) -
Hardness slightly low (Rockwell A-66,65,66 versus cross referenced value of Rockwell A
64.5 maximum)
Heavy Hex Nut <"-13 Galvanized (A 194, Gr. 2H) - carbon content slightly low (.362K versus required
.40 minimum)
Bolt 5/8"-llx12" (A 193, Gr.B7) - Reduction in Area Slightly low (48K versus 50K minimum)
The above conditions were evaluated on a case by case basis and found individually insignificant and not indicative of a general problem when considered in total.
The licensee also determined that plant operability of safety-related components was not affected by the results obtained.
The licensee determined that non safety-related fasteners that did not pass testing, were only marginally out of specification (with the exception of one bolt), were small diameter (less than 5/8"), and that no further evaluation was necessary.
No further action in. planned for installed plant fasteners or
.existing stock.
The 1>censee is contacting the manufactures of the three above listed safety-related fasteners.
In addition requirements for non-safety-related fasteners are being upgraded to better define requirements.
Yiolations or deviations were not identified in review of this program area.
4.
Action on Previous Inspection Findings (92701)
a.
(Closed)
IFI 50-335/87-23-02 and 50-389/87-22-02, IST Program Inconsistencies.
This item pertained to the fact that the licensee's valve testing practices did not agree with the IST program in effect at the time the items was identified.
The discrepancies existed because the program, through relief requests, specified stroke timing only during cold shutdown for a
number of valves.
However, the valves were being stroked, without timing, quarterly to meet TS requirements.
The licensee concluded that -if the valves were being stroked quarterly to meet TS requirements, the stoke should be timed and recorded to meet Section XI.
In the current program, the relief requests have been dropped, the valves are being tested to meet Section XI, and testing practices agree with the progra b.
(Closed)
Unresolved Item 335/86-02-01, 389/86-01-02, Removing Air Mhile Testing "Fail Safe" Valves.
While reviewing IEIN 85-84 and its application to St.
Lucie, questions were raised relative to testing air operated fail safe valves to ASME Section XI.
In addition, it was questioned whether the air operated MSIVs should be considered as fail safe and tested without instrument air.
Paragraph IN-3415 requires
"when practical, valves with fail safe actuators shall be tested by observing the operation of the valves upon loss of actuator power."
Durinq the current inspection, the above questions were reviewed and d>scussed with the licensee.
The following summarizes the results of the review:
"Fail Safe" applies to the application the valve is used in and not the particular design of the valve.
Fail safe means that the component will fail to a safe position because its applica-tion requires that it fail to the position based on assumptions made in different accident analysis in the FSAR.
Mhere a valve is required to position itself to a certain position in an accident situation and the control and motive forces cannot be relied upon (non safety-related),
the valve must be designed to fail to the required position upon loss of the the unreliable power sources.
At St.
Lucie, the valves in question, i. e. air actuated fail safe valves, are designed to be positioned to the safe position by spring force upon loss of non safety-related instrument air.
The valves are tested to the fai 1 safe position by removal of actuator air.
The air operated MSIVs are controlled by electrically operated solenoid valves.
The air supply is safety related accumulators with an eight hour supply of air.
Check valves between the non safety-related air supply (Instrument air, air bottles, and
.
compressors)
and the accumulators are periodically tested for seat tiqhtness to ensure the air supply.
The MSIVs are designed to fall closed upon loss of actuator air and fail open upon loss of power to the solenoid control valves.
The motive force (accumulator air). and the control force (electrical power to solenoid valves)
are both safety-related reliable sources.
The valves do not depend on a
non reliable source of power to operate and the FSAR does not indicate the valves are fail safe.
Therefore, the valves do not fit the "fail safe" category of ASME Section XI.
5.
Exit Interview The inspection scope and results were summarized on June 3, 1988, wi'th those persons indicated in Paragraph 1.
The inspectors 'described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dis-senting comments were not received from the licensee.
(Open) IFI 335, 389/88-13-01, Discrepancies in Documenting IST Data.