IR 05000338/1990002
| ML20012C174 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/02/1990 |
| From: | Julian C, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20012C167 | List: |
| References | |
| 50-338-90-02, 50-338-90-2, 50-339-90-02, 50-339-90-2, NUDOCS 9003200231 | |
| Download: ML20012C174 (20) | |
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UNITED STATES g.
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NUCLEAR REGULATORY COMMisslON i
p REGION ll
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O 101 MARIETTA STREET,N.W.
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I ATL ANTA, GEORGI A 30323
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.i Report Nos.:' 50-338/90-02 and 50-339/90-02
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- Licensee: Virginia Electric and Power Company
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Glen Allen, VA 23060 Docket Nos.: '50-338 and 50-339 License Nos.: NPF-4 and NPF-7
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Facility Name: No.rth Anna 1 and 2
Inspection Conducted: January 8-12 and January 22-26, 1990
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t Inspector:
b. k Q
2/9o S. Tingen,.~eam Leadtr>
Dated Signed Team Members:
S. Sparks P.. Taylor H. Whitener
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Accompanying Personnel:
A. Belisle
Approved by:
C. Julian, Chief O
Date' Signed Engineering Branch Division of Reactor Safety
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SUMMARY Scope:
This routine, announced inspection was conducted in the areas of inservice
testing, complex surveillance, containment. integrity and action on previous
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inspection findings.
Results:
L In the areas inspected, deviations were not identified.
A violation with two examples was identified for inadequate inservice testing,
-paragraph 3.
An unresolved item was identified concerning pressurizer power l
operated relief valve channel calibration, paragraph 8.
A weakness was identified concerning containment local leak rate test methods, paragraph 9.
A strength was identified concerning pump testing, paragraph 4.
A weakness was identified concerning implementation of an inservice testing relief request without_ approval, paragraph 5.
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REPORT DETAILS 1.
Persons Contacted
- Licensee Employees j
C. Conner, Engineer, Inservice Inspector
- R. Driscoll, Manager, Quality Service
. G. Flowers, Manager, Site Engineering Programs i
- G.'Kane, Station Manager
- L. Hartz, Manager, Inservice Inspection /Non-Destructive Examination
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Engineering Program
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- D. Heacock, Superintendent, Station Engineering
- J. Kin, Corporate Inservice Inspection
- J. Leberstien, Engineer
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- J. Stall Superintendent, Operations Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, technicians, and administra-tive personnel.
NRC Resident Inspectors
- J. Caldwell L. King
- Attended exit interview 2.
ISTIntroduction(73756)
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10 CFR50.55a(g) and TS Surveillance Requirement 4.0.5 require that ASME Code Classes 1, 2, and 3 pumps and valves be inservice tested in
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accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
Section XI specifies requirements for IST to assess operational readiness of certain Classes 1, 2, and 3 pumps and valves.
The licensee is committed to the requirements of ASME Code,Section XI,1974 Edition through the Summer 1974 Addenda for valve testing, and the 1980 Edition through Winter 1980 Addenda for pump testing. During this inspection, the-inspectors reviewed the licensee's Inservice Test Program, implementing procedures, and test results that accomplish Section XI pump and valve
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IST.
The results of this review are stated in paragraphs 3 through 7.
Pumps and valves that.are in the SI system, SW system, charging system, or interface with these systems, and PORVs were reviewed during this inspection.
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I 3.
CheckValveFullStrokeandReverseFlowTesting(73756)
The inspectors reviewed the full stroke and reverse flow IST methods and results for the following check valves located in the $1 system, charging system, and SW system:
1-CH-8 1-CH-102 1-CH-238 1-CH-242 1-CH-252 1-CH-254 1-CH-264 1-CH-277 I-CH-279 1-CH-322 1-CH-330 1-CH-336 1-CH-358 1-CH-380 1-CH-402 1-SI-213 1-51-1 1-SI.04 1-51-9 1-SI-12 1-51-16 1-SI-18 1-SI-021 1-51-26 1-51-29 1-SI-47 1-SI-66 1-S1-79 1-51-83 1-SI-86 1-51-89 1-S1-90 1-SI-95 1-SI-99 1-SI-103 1-SI-106 1-51-110 1-51-125 1-SI-127 1-S1-142 1-SI-144 1-51-159 1-51-161 1-51-185 1-SI-190 1-SI-192 1-51-194 1-51-195 1-SI-197 1-51-199 1-SI-201 1-51-206 1-SI-207 1-51-209 1-51-211 1-SW-3 1-SW-386 1-SW-648 2-SW-627 1-SW-10 1-SW-420 1-SW-647 2-SW-616 1-SW-22 1-SW-252 1-SW-641 2-SW-615 1-SW-114 1-SW-255 1-SW-644 2-SW-609 1-SW-116 1-SW-686 1-SW-631 2-SW-608 1-SW-120 1-SW-689 1-SW-630 2-SW-598 1-SW-130 1-SW-665 2-SW-24 2-SW-597 1-SW-140 1-SW-664 2-SW-10 2-SW-591 1-SW-150 1-SW-661 2-SW-3 2-SW-592 1-SW-364 1-SW-658 2-SW-626 2-SW-580 2-SW-581 The inspectors reviewed the following procedures which performed IST en the above check valves:
1-PT-212.2, Rev. 5, Valve Inservice Inspection CVCSSystem)
1-PT-212.3, Rev. 3, Valve Inservice Inspection CVCSSystem)
1-PT-213.9, Rev. 3 Valve Inservice Inspection Safety Injection System)
1-PT-15.1, Rev. 11, Boric Acid Transfer Pump (1-CH-P-2A) Test 1-PT-15.2, Rev. 11, Boric Acid Transfer Pump (1-CH-P-2B) Test 1-PT-213.26, Rev.0, Valve Inservice Inspection (Charging Pump Check Valves)
1-PT-14.1, Rev. 15 Charging Pump 1-CH-P-1A 1-PT-14.2, Rev. 15, Charging Pump 1-CH-P-1B 1-PT-14.3, Rev. 17, Charging Pump 1-CH-P-1C 1-PT-14.4, Rev. 3, Charging Pump Head Curve Verification 1-PT-138. Rev. 6 Valve Inservice Inspection - SI Functional l
Verification
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1-PT-57.1A, Rev. 17, ECCS Subsystem - Low Head SI Pump (1-SI-P-1A)
1-PT-57.1B, Rev. 17 ECCSSubsystem-LowHeadSIPump(1-AI-P-1B)
1-PT-213.22. Rev. 1 Valve Inservice Inspection (Safety Injection i
System)
2-PT-75.2A.1, Rev. O.
ServiceWaterPump(2-SW-P-1A)
HEAD Curve Verification 1-PT-75.2A, Rev. 12, Service Water Pump 1-SW-P-1A Test 1-PT-77.11A, Rev. O, Main Control Room and Relay Room Air
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. Conditioning Pump and Valve Test, Train A
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2-PT-75.5, Rev. los, AuxiliaryServiceWaterPump(2-SW-P-4) Test 2-PT-75.6, Rev. O.
Service Water System Flow Dalance Requirements for full stroke and reverse flow exercising check valves are contained in Section XI. Subsection IWV-3520 of the Code, i
r The licensee's ASME Section XI Inservice Testing Program for Pumps and Valves had been revised (Rev. 5, dated October 3,1989) to more closely incorporate the technical positions presented in GL 89-04, Guidance on Developing Acceptable Inservice Testing Programs, dated April 3,1989.
The licensee had completed the revisions of quarterly test procedures, and committed to a completion of revisions for procedures required to perform
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IST on a cold shutdown or refueling frequency prior to the next refueling
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outages (Units 1and2).
The inspector's review of quarterly testing procedures for check valves located in the SI system and charging system indicated that partial stroke testing was performed at the required frequency. Many check valves in the SI system and charging system were full stroke and reverse flow tested
during cold shutdown or refueling outages, and thus these procedures were under revision at the time of inspection.
However, the inspectors verified that testing frequency and methods were in accordance with
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Revision 4 to the licensee's IST program.
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The inspectors noted that in lieu of reverse flow testing, the following check valves were local leak rate tested in accordance with 10 CFR 50
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Appendix J:
1-51-106 1-51-110 1-SI-185 1-51-79 1-SI-201 1-SI-90 1-SI-206 1-SI-207 1-CH-330 1-CH-322 1-CH-402 The inspectors reviewed procedure 1-PT-61.3, Containment Type 'C' Test, Rev.10 associated results, and verified that analysis of leakage rates and corrective actions were in conformance with the requirements of IWV-3426 and IWV-3427 or appropriate relief requests.
Review of SW Check Valve IST resulted in the following deficiencies:
There are three charging pump lube oil coolers in each unit.
Each charging pump lube oil cooler is supplied SW from Train A and/or B through individual supply lines with check valves.
Normally, both
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trains of SW are aligned to the charging pump lube oil coolers; however TS allow operation on one train of SW for limited time periods.
The check valves that provide SW to the charging pump lube oil coolers were not in the licensee's IST program.
The licensee agreed with the inspectors, in that these check valves are required I
to be exercised full stroked open.
The licensee stated that these
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check valves art not rout;nely verified to full stroke open per other procedures.
The licensee stated that these check valves are not
recuired to be verified to shut on flow reversal because SW Trains A anc B were not designed to isolate from one another automatically.
Isolation of the trains from one another would be done manually with manual isolation valves if required.
Failure to full stroke open charging pump lube oil cooler check valves 1-SW-665,1-SW-664, 1-SW-648, 1-SW-647, 1-SW-630, 1-SW-631, 2-SW-615, 2-$W-616, 2-SW-598,
2-SW-597, 2-SW-580, and 2-SW-581 was identified as Part A to violation 50-338, 339/ % -02-01.
IWV-6000 requires licensees to develop and maintain a system to document and define all procedures and valves required to accomplish IST.
Review of SW IST revealed that the check valves in the supply
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lines to the charging pump gear coolers and seal coolers were routinely exercised but were not incorporated into the IST program, and that the manual isolation valves in the charging pump lube oil coolers,-gear cooler, and seal coolers SW supply and discharge lines required to isolate the SW trains from one another were also not incorporated into the IST program, but were routinely tested per
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other non-ISI procedures. Failure to incorporate SW valves 1-SW-694, 1-SW-695, 1-SW-678, 1-SW-679, 1-SW-251, 1-SW-285, 1-SW-254, 1-SW-286, 1-SW-686, 1-SW-689, 1-SW-661, 1-SW-658, 1-SW-641, 1-SW-644, 2-SW-626,
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2-SW-627, 2-SW-609, 2-SW-608, 2-SW-591, and 2-SW-592 into the IST program was identified as Part B to Violation 50-338,339/90-02-01.
Within the areas inspected, two examples of the IST violation and no i
deviations were identified.
4.
PumpTesting(73756)
The inspectors reviewed IST for the CVCS/high head safety injections pumps, low head safety injection pumps, boric acid transfer pumps and service water pumps to determine if periodic testing was performed in accordance with Section XI, Subsection IWP requirements, 1980 Edition with Addenda through the Winter 1980.
The following implementing procedures and completed pump test results for the previous year was reviewed:
151-2.0 Rev. O, ISI Administrative Procedure ASME Section XI Pump Program PT-14.1 Rev.15,14.2 Rev.15,14.3 Rev.17, Quarterl; Operability Test Charging /Si Nmps CH-P-1A, CH-P-10 PT-57.1A Rev. 17, 57.1B Rev. 17, ECCS Subsystem - Low Head SI Pump Quarterly Operability Test SI-P-1A, SI-P-18 i
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PT-15.1 Rev.11,15.2 Rev.11,15.3 Rev.11. Quarterly Operability Test
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Boric Acid Transfer Pumps CH-P-2A, CH-P-28, CH-P-2C PT-14.4A Rev._3. Charging /SI Pumps Head Curve Verification Test - Each Refueling i
PT-138 Rev. 6, Valve ISI - SI functional Verification l
PT-75.2A Rev.12, 75.2B Rev.16, Quarterly Operability Test Service Water Pumps 1-SW-P-1A, 1-SW-P-10, 2-SW-P-1A,
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2-SW-P-1B PT-75.5 Rev.13, Quarterly Operability Test Auxiliary Service Water Pumps 1-SW-P-4, 2-SW-P-4
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PT-75.2A.1 Rev. O Service Water Pumps Head Curve Verification Test - Each Refueling
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The inspectors verified that the above implementing procedures incorporated ASME Code requirements regarding IWP acceptance criteria, test frequency and test duration, calibration of instrumentation, time allowed for analysis of test results and action to be taken if the J
measured pump test quantities fell within the alert or required action range.
In addition the inspectors reviewed completed test results for the ECCS pumps and service water system pumps and also sampled post-l maintenance testing following pump maintenance. The activities were found i
to be thorough and appropriate tests were prescribed based on the extent
of the pump repairs.
The inspectors noted that the licensee's IST procedures, as required per Section XI of the ASME Code, set limits on pump operability of 90 percent l
to 103 percent of the reference value for pump differential pressure and flow rate. The purpose of these limits is to detect pump degradation from
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the reference value, and does not consider if design requirements can be
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met.
The inspectors discussed with the licensee a condition in which a p(e.g.could degrade per quarterly IST and still be considered operable 91 perce I
ump requirements (a design margin of less than 10 percent).
Although the inspector's review of the SW pump IST data did not identify any pumps in this condition, the licensee agreed that this condition could potentially exist, and consideration would be given to evaluating system design parameters against the quarterly IST results.
In addition, the licensee stated that a head curve is performed on each SW pump, and the system flow is then balanced every 18 months with an acceptance criteria for flow and
differential pressure based on system design requirements.
The licensre
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I also conducts pump head curve verification test for the charging /SI pumps i
and the low hcad SI pumps each refueling. The flow data from these tests.
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which includes design flow, is compared with the manufacturer's data as well as the ECCS flow basis from the UFSAR.
The inspectors witnessed the performance of the following pump tests:
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1-PT-57.18,Rev.17,ECCSSubsystem-LowHeadSIPump(1-SI-P-1B)
1-PT-97.1B, Rev. 7, Spent Fuel Pit Cooling Pump (1-FC-P-10)
I 2-PT-71.3, Rev.18, Auxiliary Feedwater Pump (2-FW-P-38)
The inspectors verified that the test procedures used during the tests were the latest revisions.
Prior to the testing the inspectors observed that initial conditions, prerequisites and test equipment calibration for the tests had been met.
During the conduct of the tests, plant personnel
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in charge were observed to be following procedural steps, observing i
procedure precautions, recording test data and assessing the data for acceptability based on the provided acceptance criteria. Test objectives and acceptance criteria appeared to be met for the low-head SI pump test and the spent fuel pit cooling pump test.
The periodic test for the i
auxiliary feedwater pump was in progress when the pump had to be secured
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because the pump packing was overheating (smoke indications.)
The pump was declared inoperable and appropriate TS LCO was entered. The licensee indicated that a new type packing was being used and this new packing required a higher than originally anticipated leak rate.
The inspector was later informed by the licensee that the pump was repacked and tested satisfactory.
Within the area inspected, no violations or deviations were identified.
5.
PowerOperatedValveIST(73756)
The inspectors reviewed IST for the following MOVs and A0Vs in the SI, SW and charging systems:
1-CH-MOV-1115B 1-CH-MOV-1115C 1-CH-MOV-1115D 1-CH-MOV-1115E 1-CH-MOV-1267A 1-CH-MOV-12678 1-CH-MOV-1269A 1-CH-MOV-12698 i
1-CH-M0V-1270A 1-CH-MOV-12708 1-CH-MOV-1275A 1-CH-MOV-1275B 1-CH-MOV-1350 1-CH-MOV-1373 1-CH-MOV-1380 1-CH-M0V-1381 1-SI-MOV-1836 1-SI-MOV-1860A 1-SI-MOV-1860B 1-SI-MOV-1862A 1-SI-MOV-1862B 1-SI-MOV-1863A 1-SI-MOV-18638 1-SI-M0V-1864A l
1-SI-M0V-1864B 1-SI-MOV-1865A 1-SI-MOV-1865B 1-SI-MOV-1865C 1-SI-MOV-1867A 1-SI-MOV-18678 1-SI-MOV-1867C 1-SI-MOV-1867D l
1-SI-MOV-1869A 1-SI-MOV-1869B 1-SI-M0V-1885A 1-SI-MOV-18858
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1-SI-MOV-18850 1-SI-MOV-1885D 1-SI-MOV-1890A 1-SI-M0V-1890B 1-SI-M0V-1890C 1-SI-MOV-1890D 1-SI-TV-100 1-SI-TV-101 1-SI-TV-1842 1-SI-TV-1859 1-SI-TV-1884A 1-SI-TV-18848 1-SW-MOV-101A 1-SW-MOV-104A 1-SW-MOV-108A 1-SW-M0V-123A 1-SW-MOV-1018 1-SW-MOV-104B 1-SW-1088 1-PORV-1456 1-SW-MOV-1010 1-SW-MOV-104C 1-SW-MOV-113A 1-PORV-1455C 1-SW-MOV-101D 1-SW-M0V-104D 1-SW-MOV-133B 1-SW-MOV-123B l
1-SW-MOV-102A 1-SW-MOV-105A 1-SW-MOV-115A 2-PORV-1456
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1-SW-MOV-102B 1-SW-MOV-1050 1-SW-MOV-117 2-PORV-1455C 1-SW-MOV-103A 1-SW-M0V-105C 1-SW-MOV-121A 1-SW-MOV-103B 1-SW-MOV-105D 1-SW-MOV-121B 1-SW-MOV-103C 1-SW-MOV-106A 1-SW-MOV-122A i
1-SW-MOV-103D 1-SW-MOV-106B 1-SW-MOV-122B The inspectors interviewed licensee personnel regarding the general
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methods used to stroke time power operated valves.
The inspectors also i
reviewed appropriate relief requests, and reviewed the following implementing procedures for IST of the previously listed valves:
1-PT-212.3, Rev. 3 ValveInserviceInspection(CVCSSystem)
1-PT-213.9, Rev. 3 Valve Inservice Inspection (Safety Injection System)
1-PT-213.22,Rev.1,ValveInserviceInspection(SafetyInjection
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System)
1-PT-213.2A, Rev. O, Valve Inservice Inspection (Charging Pump 1-CH-P-1A MOVs)
1-PT-213.2B, Rev. O Valve Inservice Inspection (Charging Pump
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1-CH-P-1B MOVs)
1-PT-213.20, Rev. O, Valve Inservice Inspection (Charging Pump
1-CH-P-1CMOVs)
1-PT-212.7, Rev. 1 Valve Inservice Inspection (Safety Injection System)
1-PT-212.10, Rev. 2 Valve Inservice Inspection (PORV-1456)
1-PT-212.11, Rev. 2 Valve Inservice Inspection (PORV-14550)
Criteria for IST power operated valves is contained in Subsection IWV-3400 of the Code, which specifies stroke timing, fail-safe testing, and corrective action requirements.
Subsection IWV-3300 addresses valve position indicator verification which checks remote position indicators
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once every two years to verify that valve operation is accurately indicated.
The inspectors also reviewed the stroke time testing results for the selected valves, as well as maximum, alert, and increased test frequency values.
Maintenance work requests were reviewed for selected valves, including post-maintenance testing requirements and acceptance criteria.
The inspectors noted during their review that the licensee had implemented
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relief request V-66. V-66 requested stroke time testing of power operated valves to be performed to the guidelines presented in OM-10 Inservice Testing of Valves in Light Water Cooled Systems, sections 4.2.1.8 and 4,2.1.9.
OM-10 acceptance criteria permit a change in MOV stroke time not
to exceed plus or minus 15 percent before increased test frequency is required.
On two consecutive tests, testing could result in the first stroke time 15 percent less than the reference value, and the second stroke could be 15 percent greater than reference value, resulting in a total change of 30 percent.Section XI, IWV states that MOV stroke times may increase by 25 percent from the previous test before increased test frequency is reouired.
Therefore, OM-10 stroke timing acceptance criteria are less restrictive than IWV.
Relief request V-66 had been implemented for quarterly valve stroke timing, and procedures were currently being revised for cold shutdown and refueling outage valves.
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management stated that the initial interpretation of GL 89-04, Guidance on Developing Acceptable Inservice Testing Programs, dated April 3,1989, allowed the incorporation of OM-10 guidelines for stroke timing valves.
The NRC staff addressed the use of OM-10 in the Minutes of the Public
Meetings on Generic Letter 89-04, dated October 25, 1989.
This document was issued after the licensee's IST program submittal (Rev. 5).
Specifically, the response to Question 92 in the Minutes states:
The staff has not completed its assessment of the interrelationship of Generic Letter 89-04 and OM-6 and OM-10.
When appropriate references to OM-6 and 10 are incorporated in the regulations, these standards may be used by the licensee as tM regulations permit the use of more recent referenced standards.
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Since relief request V-66 was submitted after issuance of GL 89-04, the l
licensee must receive approval before implementation as stated in the Minutes of the Public Meeting on Generic Letter 89-04.
Although the licensee's quarterly implementing procedures had already been revised to use OM-10, valve stroke times were being informally tracked (no procedural requirements) using ASME Section XI. Subsection IWV requirements.
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licensee initiated corrective action to verify through their informal
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tracking system that no valves in their IST program exceeded IWV
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requirements.
In addition, a procedure deviation was generated for
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ISI-2.1, ISI ASME Section XI Valve Program, such that the stroke time
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limits of ASME Section XI, Subsection IWV would be used in a formal procedure.
The inspectors consider implementation of a relief request prior to approval to be a weakness.
However, the licensee's actions to formally track MOV stroke times using IWV acceptance criteria were satisfactory.
The inspectors also noted that the licensee IST program required stroke timing sever 1 MOVs in the direction required during the injection phase, but did not require stroke timing (although exercising was performed) in the other direction, i.e. during the recirculation phase-or during
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cold-leg to hot-leg recirculation.
The licensee stated valve stroke timing wet required in the direction required to fulfill their function, which per their IST program was being accomplished.
In addition, AC
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powered MOVs typically do not exhibit appreciable differences in stroke time between the open and closed direction, and thus degradation could be determined by stroke timing in one direction.
In addition, the licensee l
performs MOVATS testing on many of the MOVs, which would provide a better l
indication of-valve degradation.
The inspectors concluded that the l
licensee's method of stroke timing AC powered MOVs was satisfactory.
l Within the area inspected, no violations or deviations were identified.
6.
ReliefValveIST(73756)
l The inspectors reviewed IST for the following safety and relief valves in l
Units 1 and 2 SI and charging systems:
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1-CH-RV-1203 1-CH-RV-1209 1-CH-RV-1257 1-CH RV-1382A 1-CH-RV-13828 1-SI-RV-1845A 1-SI-RV-1845B 1-SI-RV-1845C 1-SI-RV-1857 1-SI-RV-1858A 1-SI-RV-18588 1-SI-RV-1858C The inspectors interviewed licensee personnel regarding the methods used to test relief valves and reviewed the following implementing procedures for IST of the previously listed valves:
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1-PT-147.1, Rev. 7 Valve Inservice Inspection, (Relief Valves)
MMP-C-GV-2, Rev. 15, Mechanical Maintenance Procedure for Safety and Relief Valves in General The criteria for IST of relief valves and safety valves are contained in Subsection 1WV-3510, and in Performance and Test Code ASME/PTC 25.2-1966, Safety and Relief Valves with Atmospheric or Superimposed Back Pressure Before Discharging, which specify testing methods and frequency.
Review of relief valve testing indicated that IST was accomplished in accordance with the ASME Code. The licensee stated that the next revision of the IST program would include incorporation of more recent relief valve testing codes, which would impose additional testing requirements such as multiple lifts to verify setpoint, and consideration of temperature differences between actual and testing conditions.
Within the area inspected, no violations or deviations were identified.
7.
QualityAssuranceInvolvementinISTProgram(73756)
The - inspectors reviewed the following QA activities related to Section XI, IST programs / testing:
Surveillance: AR-N-88-130, Conformance to IWV Testing Requirements
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AR-N-88-131. Conformance to IWV Testing Requirements N-89-580, IWP Testing Program Assessment:
AR-N-89-624 IWP/IWV Program Audit:
N-88-18 Inservice Inspection N-89-90, Concurrent Audit of the Inservice Inspection Program
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N-88-18A, Inservice Inspection Program (Followup in i
L FindingfromAuditN-88-18)
These activities led to identifying roblem areas in a variety of areas i
including: findings and observations audits); and findings, concerns, and items (surveillances and assessments.
Findings and observations had l
existing administrative controls for their closure.
Concerns and items did not have such controls. Audit N-89-04 identified, as a finding, this lack of control.
To resolve this finding activity, the inspectors
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I reviewed the Engineering Quality Plan which outlines the direction site and corporate engineering personnel will be taking in the near future.
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This plan outlines the engineering mission and states ten specific objectives.
Each objective is clearly stated and includes a strategy to obtain the objective.
Also included, is an implementation plan which delineates what is to be accomplished for 1990.
Each objective includes various assessment methods and accomplishments.
Reports since January 1, 1989, were reviewed to identify minor discrepancies which were adverse to plant safety to which corrective action was not verified as being complete.
Those discrepancies were entered in the QA Tracking and Trending Program and followed up to verify that corrective action was taken.
Instances where corrective action was not taken will require further evaluation to determine the appropriate disposition.
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ComplexSurveillance(61701)
TS Surveillance Requirements 4.4.3.2.1.b and 4.4.9.3.1.b require that each pressurizer PORV be demonstrated operable at least once every 18 months by
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performing a channel calibration.
The inspectors reviewed the following
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ICP-RC-1-T-1410 Rev. O, Instrument Calibration Procedure Wide Range Temperature (Coldleg)
Protection Channel I ICP-P-1-P-444. Rev. O, Instrument Calibration Procedure Pressurizer Pressure Control 1-PT-44.9, Rev. 5. PORV Instrumentation Functional Test ICP-RC-1-P-1402, Rev. O, Instrument Calibration Procedure P-1402 Reactor Coolant System Pressure (WideRange)ProtectionChannel1 1-PT-44.4.1, Rev. 12, Overpressure Protection Instrwnentation Function Test With PORV Operability Not Required ICP-RC-1-P-1402-1, Rev. O, Instrument Calibration Procedure P-1402-1, Reactor Coolant System NDT Overpressurization Protection The pressurizer PORV channel calibration was accomplished by performing a series of overlapping procedures.
Results of the inspectors' review of the PORV channel calibration procedures were that not all contacts and associated wiring were tested.
For the PORY low temperature automatic mode of operation switch contacts 1, 7, and 9 and connecting wiring in the circuits that align electrical power to the number three solenoids were not tested.
For the PORY normal automatic mode of operation, the two PORV
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channels were tested differently.
The licensee did not know why the channels were tested differently.
In one channel all components were i
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tested with the exception of the relay K628 contact 7, 8 and associated wiring in the circuit that aligns electrical power to the one and two solenoids.
In the other PORY channel, relay K628 contact 7, 8, switch contacts 3 and 7, relay contact 3, 4 and associated wiring that align electrical power to the one and two solenoids were not tested.
Failure of any of these contacts to shut or a broken wire would result in the PORY failing to open on a pressurizer pressure signal. The fact that the PORY was inoperable would not be detected unless a high pressurizer pressure signal occurred and the PORV failed to open.
The licensee agreed with the inspectors that these contacts and associated wiring need to be tested and initiated action to fully test the circuits.
The licensee disagreed with the inspectors in that it was a requirement of TS Surveillance Requirements 4.4.3.2.1.b and 4.4.9.3.1.b channel calibrations to test these components.
In order to resolve the issue as TS requirement to test the contacts and associated wiring, Region II will request NRR assistance.
This item was identified as URI 50-338,339/90-02-02, Testing of PORY channel.
Within the areas inspected, no violations or deviations were identified.
9.
Containment Leak Rate Testing and Integrity (61720 and 61715)
Inspection in this area was performed to verify the development and implementation of programs, controls, procedures, and test activities which ensure that containment integrity is established, monitored and maintained consistent with the requirements of the TSs and Code of Federal Regulations.
a.
LocalLeakRateTesting(61720)
An important part of monitoring and maintaining containment integrity is performance of periodic local leak rate testing to verify leak l
tightness of containment leakage barriers.
The purpose of the inspection activities in this area was to ascertain that the licensee's LLRT program was being conducted in compliance with NRC requirements.
The inspectors reviewed LLRT procedures, evaluated test results, reviewed maintenance records and witnessed local leak l
rate testing of the containment personnel airlock seals.
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(1) Procedure Review i
Fifteen PT procedures related to local leak rate testing of the l
containment leakage barriers were reviewed.
These tests
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included the following:
Type B Tests: CPBS such as the equipment hatch, personnel airlock, and emergency escape local seals; electrical penetrations; and, the fuel
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transfer tube.
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i Type C Tests: CIVs as defined in Section 6 of the UFSAR
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and Section 3/4.6 of the TSs.
Although every leak rate test procedure for the above leakage i
boundaries was not necessarily reviewed for total valve
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alignment in step by step detail, the inspectors verified that the following attributes were included in the procedures to
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ensure adequate leak rate testing of contairunent isolation boundaries:
(a) LLRTs were performed at test (CILRT) peak accident
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pressure, (b) The LLRT program utilized approved methods for testing containment penetration boundaries and CIVs.
l (c) Penetration leakage rates were determined using the maximum
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pathway leakage.
(d) The criteria and response for LLRTs and combined leakage
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rate failure were incorporated in the test program procedures.
(e) Repairs or modifications to containment isolation boundaries and CIVs were preceded and followed by LLRTs, and (f) LLRTs were performed at the correct frequency.
A detailed review was performed for valves in fifteen penetrations to verify adequate alignment for venting, drainirg, and adequate boundary alignment for leak rate testing.
With the exception of one concern, these reviews identified no
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problems relative to penetration venting, draining, valve identification, valve alignment, or system restoration.
A concern was identified in the review of 1-PT-61.3, Revision 10, Containment Type C Test.
For a number of penetrations the licensee is using a " leak thru" method rather than the " makeup flow" method.
The " leak thru" method consists of pressurizing an isolation valve in the accident direction, establishing an isolated volume on the low pressure side of the isolation valve, and determining leakage through the isolation valve by channeling the leakage from the isolated volume through a flow meter.
This method introduces uncertainties in the accuracy of the measured leak rate and can result in non-conservative measurement *
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Licensee management recognized the weakness in this method.and at the exit interview agreed to evaluate the use of the " leak thru" method with the goal of reducing the number of penetrations tested in this manner or possible devising a method i
of qualifying the integrity and pressure stability of the low
pressure volume.
This matter was identified as a weaknesses in the Type C test procedure and will be reviewed during future routine leak rate inspections.
(2)
Implementation of the Leak Rate Program Implementation of the LLRT program to establish and maintain containment leak tight barriers was reviewed.
Records of i
performance, identification of problems, corrective actions, retests, and test acceptance were reviewed.
A detailed review
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of Type B and Type C leak rate testing was performed for the
previous RF0 on Unit 1 (March - July,1989).
$91ected Unit 2
RF0 testing (February - May,1989) was also reviewed; however.
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since the procedures, requirements, and personnel involved are essentially the same, the inspectors reviewed principally the Unit I records.
Records reviewed included the following:
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Airlock and escape lock full pressure tests Airlock, escape lock and equipment hatch seals Electrical penetrations Fuel transfer tube Isolation valves Total local leak rate calculation (running summation of TypeBandTypeCleakrates)
Leak rate log (updates total Type B and Type C leakage when a component is retested).
Integrated Leak Rate Test Reports for 1989 (portions which summarize Type B and Type C leak rate history)
In the review the inspectors determined:
Data sheets were complete and test results were within the specified acceptance limits.
Data was tabulated and transferred to PT-16.3.4, controlling procedure for verification that the total local
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i leakage does not exceed the 0.6 La limit.
i Identified problems were corrected and retesting performed.
i Tests were performed at the f requency required by NRC regulations.
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Pre-and post-maintenance leak rate testing was adequately controlled through the maintenance work order system.
Responsibility for verification of these tests is centered
with the operations and maintenance coordinators and the
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shift supervisor.
i In addition to the record review the inspectors also witnessed
the LLRT of the containment personnel airlock seals. This test
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was performed to fulfill the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirement following containment entry.
The inspectors found that test personnel
were knowledgeable of the test requirements and familiar with
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the test sequence.
The test procedure was present at the job site and completed as the steps were performed.
No problems
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were identified.
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Based on discussion with licensee personnel, observations by the inspectors and records reviewed, the inspectors concluded that the licensee has developed and implemented the procedures and controls necessary to establish and maintain the leak tight integrity of the containmer,t.
b.
VerificationofContainmentIntegrity(61715)
The purpose of the inspection activities in this area was to verify the adequacy and implementation of procedures and controls designed to maintain containment integrity and to mitigate contamination releases in the event containment integrity is lost following a LOCA.
(1)' Primary Containment Integrity Controls The inspectors reviewed Operations Procc:'ure 1-0P-1E, Containment Integrity Check List Procedure ior Unit Startup, which ensures all necessary plant conditions are established for reactor startup.
It was verified that the procedure included the following minimum provisions that ensure primary containment integrity exists before the plant enters operational modes which require containment integrity:
(a) All penetrations not capable of being closed by automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves,
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(b) All equipment hatches are closed and sealed.
(c) Each containment air lock is operable.
(d) Containment leakage rates are within TS limits, (e) Sealing mechanisms associated with each penetration are operable.
Procedures OP-1E Containment Integrity Checklist, 1-MISC-46, LMC Valves Inside Containment and 1-PT-60.1, Containment Integrity, collectively specify the requirements for establishing containment integrity prior to the entering Mode 4 during plant startup and provide for maintaining integrity during operations by visual verification of leakage barriers at 31 day intervals outside containment and at 92 day intervals during cold shutdown inside containment.
The inspectors verified that these procedures included applicable containment isolation barriers necessary to meet the requirements of TSs 4.5.1.1.b, 4.6.1.1.c, 4.6.1.1.d. 3.6.1.3 4.6.1.3.b and 4.6.1.1.c.
The inspectors reviewed the completed surveillance records for procedures 1-0P-1E, 1-MISC-46, and 1-PT-60.1 for the year 1989.
This time period was selected because it allowed the inspectors to assess performance of surveillance testing prior to two plant
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startups (July and December), a 15 day cold shutdown (December),
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a RF0 (March to July) and an extended period of operation (July
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to December).
These surveillances were performed at the I
required frequency and condition.
(2) Containment Systems Designed to Mitigate The Consequences of an Accident Portions of the following containment related systems designed to mitigate the consequence of a LOCA were inspected for compliance with the plant TSs;
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Containment Air Temperature Containment Airlocks Containment Purge Supply and Exhaust Equipment Hatch Quench Spray Systems Recirculation Spray and Casing Cooling Systems Hydrogen Gas Analyzer i
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Hydrogen Recombiner
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For selected TS requirements on these systems, the inspectors reviewed surveillance test procedures and records for 1989 (except for daily or weekly tests which were reviewed for one month) to verify that:
Surveillance test procedures are established which address the TS requirements.
The test procedures contain instructions, acceptance criteria and limits appropriate to the TS requirements,
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The surveillance tests were performed at the frequency required by the TSs, and Corrective action and retest was performed when problems were identified.
The sample of surveillance records reviewed by the inspector included the following:
1-PT-60.2 Containment Air Temperature
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1-PT-S8.4 Casing Cooling Tank Chemistry 1-PT-213.7 Casing Cooling and _ Recirculation Spray Systems (Valve Strose Time and Exercise
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Test)
Quench Spray ) System (Valve Stroke Time and l
1-PT-213.S Exercise Test i
1-PT-63.4 Quench Spray and Chemical Addition System Valve Line-up Verification and RWST Water
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l Temperature Determination 1-PT-66.1 Weight - Loaded Check Valve Test (QS & RS
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Cycle and Verify Differential Pressure
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Function)
u l-PT-66.3 Containment Depressurization Actuation l
Functional Test (Verify Operation of ESF on CDA/ Phase B Signal)
1-PT-68.1.1 Hydrogen Recombiner Functional Test 1-HC-HC-1 1-PT-67A Post DBA Hydrogen Analyzer (H A - HC-101)
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1-PT-62.5 Personnel Airlock Escape Door Seals 1-PT-62.4 Personnel Airlock Seal Leakage (72 hr test)
1-PT-62.3 Equipment Hatch Escape Lock Door Seals 1-PT-62.2 Containment Airlock Interlocks 1-PT-62.1 Containment Airlock Leakage Rate (6 month test)
1-PT-61.2.3 Containment Type B - Equipment Hatch 1-PT-61.3.3 Purge Valve Type C - As Left Based on this sample review, the inspectors concluded that the licensee has established and implemented periodic test procedures to ensure that the operability requirements specified in - the TSs for containment systems designed to mitigate the consequences of an accident are maintained.
Within areas inspected, no violations or deviations were identified.
10. ActiononPreviousInspectionfindings(92701,92702)
a.
(Closed) IFI (338, 339/88-10-01):
Institute Statistical Tests to Confirm Operability of Source Range Neutron Monitors Prior To loading Fuel And Prior To Pulling Rods For the First Post-Refueling Startup.
A telephone' conference call was conducted between licensee personnel (E.Hendrixson, A. Main T. Snow, and J. Leberstien) and NRC personnel (A. Belisle, on site, and P. Burnett, Region II) on January 24, 1990.
Four specific areas in 1-PT-92.0, Chi-Square Test.
were discussed, the licensee agreed to clarify the wording in l
paragraph 4.5 for selecting 30 contiguous data points.
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b.
(Closed) IFI (339/88-08-01):
Effect of Steam Versus Hot Water as System Medium on Pressurizer Safety Valve Setpoint Pressure.
On October 19, 1989 Westinghouse notified the licensee of the Generic j'
Issue concerning-effect of system temperature on pressurizer safety valve setpoint.
As a result, the licensee prepared a Justification for Continued Operation (C-89-27) which states that no safety limits will be violated with present pressurizer safety valves setpoints.
The licensee will operate under the Justification for Continued Operation until permanent correct action can be completed, c.
(Closed) IFI 50-338,339/88-12-03, Review Calculations Accepting Snubber Functional Test Results Which Exceed Licensee's Established Limits.
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The snubber calculations referenced by Engineering Work Request 87-401 and Engineering Mechanics Technical Report 87-MFW-005 were reviewed by the inspectors and were satisfactory.
d.
(Closed) UNR Item 338, 339/89-12-02:
Verify That The Licensee
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Submits His Justification for The Position That Pressure In The Secondary System Will Prevent Leakage From Containment At Accident Pressure to NRR For Evaluation.
The inspectors verified that the licensee is working on this submittal and has a target date of June identified in their tracking
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system. The item is closed based on the licensee tracking this item.
Within the areas inspected, no violations or deviations were identified.
11. Exit Interview The inspection scope and results were summarized on January 26, 1990, with those persons indicated in paragraph 1.
The inspectors described the
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areas inspected and discussed in detail the inspection results listed above.
Proprietary information is not contained in this report.
No dissenting comments were received from the licensee.
Item Number Oescription and Reference 50-338,339/90-02-01 Part A Violation - Failure to full Stroke Open Charging Pump Lube Oil Cooler Inlet Check Valves 50-338,339/90-02-01 Part 8 Violation - Failure to Incorporate
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Service Water Valves into IST Program
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50-338,339/90-02-02 URI Item - Testing of PORY Channel l
Licensee management was informed that the following items were closed:
l IFI 50-338,339/88-10-01, paragraph 10.
IFI 50-339/88-08-01, paragraph 10.
IFI 50-338,339/88-12-03, paragraph 10.
URI 50-338,339/89-12-02, paragraph 10.
On January 31, 1990 per telecon with J. Leberstien, the licensee was informed that the testing of the PORV channel issue would be an UNR in lieu of a violation.
On February 28, 1990 per telecon with J. Leberstien, the licensee was informed that implementation of OM-10 without an approved relief request would not be a violation, due to satisfactory completion of corrective action '
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12. Acronyms and Abbreviations A0V Air Operated Valve ASME American Society of Mechanical Engineers
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CDA Containment Depressurization Activation CVCS Chemical and Volume Control System DBA Design Base Accident
ECCS Emergency Core Cooling Systems ES Engineered Safety Features
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GL Generic Letter HHSI High Head Safety Injection
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IFI Inspector followup Item ISI Inservice Inspection IST Inservice Testing CILRT Containment Integrated Leak Rate Test CIV Containment Iso lation Valves CPB Containment Penetration Boundary La Leakage Allowable LHSI Low Head Safety Injection LLRT Local Leak Rate Test
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LOCA Loss of Coolant Accident
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LC0 Limiting Condition for Operation LMC Locked. Manual Closed MOV Motor Operated Valve NDT Nil Ductility Temperature
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NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation PORY Power Operated Relief Valve
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PSIG Pounds per Square Inch, Gage
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PT Periodic Test
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-QA Quality Assurance QS Quench Spray Rev.
Revision
RF0 Refueling Outage RHR Residual Heat Removal RS Recirculation Spray RR Relief Request RWST Refueling Water Storage Tank SI Safety Injection TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved Item
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