IR 05000348/1987031

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Insp Repts 50-348/87-31 & 50-364/87-31 on 871102-06. Violation Noted.Major Areas Inspected:Emergency Diesel Generator Surveillance Testing & Reliability Reporting & IE Bulletin 85-003
ML20236X842
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 12/03/1987
From: Jape F, Tingen S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236X820 List:
References
50-348-87-31, 50-364-87-31, IEB-85-003, IEB-85-3, NUDOCS 8712100310
Download: ML20236X842 (7)


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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-348/87-31 and 50-364/87-31 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291-0400 Decket Nos.:

50-348 and 50-364 License Nos.:

NPF-2 and NPF-8 Facility Name:

Farley 1 and 2 Inspection Conducted:

November 2-6, 1987

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Inspector:

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S. G' Tirigen

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de S F. Jape, Chief

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Date Signed

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Test Programs Section Division of Reactor Safety SUMMARY Scope:

This routine, unannounced inspection was in the areas of Emergency Diesel Generator Surveillance Testing and Reliability Reporting, and IE Bulletin 85-03, " Motor-operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Settings."

Results:

One violation was identified - Incorrect Procedure and Incomplete Emergency Diesel Test Data Log, paragraph 5.b.

8712100310 871204 PDR ADOCK 05000348 G

PDR

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l REPORT DETAILS l

1.

Persons Contacted Licensee Employees -

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  • l.. Ward, Maintenance Manager L
  • W. Shipman, Assistant Plant Manager
  • R. Berryhill, System Performance Manager
  • W. Ware, Quality Control Engineer
  • B. VanLandingham, Unit Supervisor

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  • R. Hill, Operations Manager
  • L. Williams, Training Manager
  • C. Buck, Discipline Engineer Supervisor
  • B. Moore, Training Technical Support
  • L. Stinson, Plant Modification and Support Manager
  • J. Thomas, Maintenance Manager M. Eidson, Engineer J. Brantley, Technical Support NRC Rasident Inspectors
  • W.

Bradford, Senior Resident Inspector

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W. Miller, i,asident Inspector l

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  • Attended exit interview l

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Exit Interview l

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The inspaction scope and findings were summarized on November 6,1987, l

with those persons indicated in paragraph 1 above.

The inspector described the areas inspected and discussed in detail the inspection findings.

No dissenting comments were received from the licensee.

The following new items were identified during this inspection:

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Violation 50-348, 364/87-31-01, Incorrect Procedure and Incomplete i

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EDG Test Data Logs, paragraph 5.b.

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Inspector Followup Item 50-348, 364/87-31-02, Valves Failing to

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Operate Under a Differential Pressure, paragraph 7.

The licensee did not identify as proprietary any of the materials provided t

to or reviewed by the inspector during this inspection.

3.

Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

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Unresolved Items Unresolved items were not identified during this inspection.

5.

Emergency Diesel Generator Surveillance (61701)

a.

The inspector reviewed Farley Nuclear Plant (FNP) Unit 2 surveillance test procedure FNP'2-STP-40.0, " Safety Injection with Loss of Off-S4,e Power Test." This test is performed in 18 month intervals for the purpose of determining the operability of the following:

on-site emergency power system during a Safety Injection (SI) in conjunction with a loss of off-site power, containment phase A isolation valves, and emergency core cooling system check valves.

The licensee was in the process of evaluating test data and restoring from the test.

FNP-2-STP-40.0 accomplishes a number of Technical Specification (TS)

requirements. The inspector chose Surveillance Requirement 4.7.3.b, Verification that Phase A Component Cooling Water Valves Close on a SI Test Signal, and by reviewing the component cooling water diagrams

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and discussion with the Unit Supervisor verified that Surveillance

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Requirement 4.7.3.b was satisfactorily accomplished by FNP-2-STP-40.0.

The inspector reviewed test deficiencies recorded by the FNP-2-STP-40.0 Test Director and through discussion with the Unit Supervisor verified that an adequate system exists to accomplish corrective action and subsequent retests.

The acceptance criteria against which the test will-be judged was clearly identified, restoration valve lineups required double verification, all pre-requisite steps completed and the appropriate revisions of the test procedure-were utilized by test personnel, b.

The inspector reviewed the Emergency Diesel Generator (EDG) Test Data Log from 1985 to present. NRC Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units used as Onsite Electric Power Supplies at Nuclear Plants," requires that the licensee maintain accountability of all EDG starts in order to determine EDG reliability to perform their intended safety functions.

The Log J

should describe each occurrence in sufficient detail to permit

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independent determination of statistical validity in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108.

FNP has five EDGs and maintains a EDG Test Data Log for all five EDG start and start attempts.

Operations Intra Department Memorandum dated September 9, 1985, was issued by the licensee to provide written instructions for filling out the EDG Test Data Log.

The licensee was not complying with the Intra Department Memorandum for completing EDG Test Data Log; examples include not recording EDG l

start or start attempt time, not recording explanation for invalid i

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start or start attempts, not recording reason for EDG start or start attempt, and not recording time for EDG to reach speed and voltage

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i for satisfactory starts. The EDG Test Data Log did not contain the

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information necessary to determine if EDG invalid tests and failures were correctly classified in accordance with NRC Regulatory Guide 1.108.

In addition to lacking important details, the EDG Test Data Log was not neat and orderly.

TS 4.8.1.12 requires that each EDG be demonstrated operable at least once per 14 days if there are two or less failures in the past 100 valid tests or at least once per seven days if there are three or more EDG failures in the last 100 valid tests.

An EDG is demonstrated operable by:

(1) Verifying the fuel level in the day tank.

(2) Verifying the fuel level in the fuel storage tanks.

(3) Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the da; tank.

(4) Verifying the diesel starts and accelerates to at least 900 rpm for the 2850 kw generator and 514 rpm for the 4075 kw generators in less than or equal to 12 seconds. The generator voltage and frequency shall be > 3952 volts and > 57 Hz within 12 seconds after the start signal and operates for 5 minutes.

(5) Verifying the generator is synchronized, loaded to 2700-2850 kw for the 2850 kw generator and 3875-4075 kw for the 4075 kw generator and operates for greater than or equal to 60 minutes.

(6) Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

i The inspector reviewed EDG 2C Test Data Log and verified that items (4) and (5) have been accomplished as required by TS 4.8.1.12.

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Intra Department Memorandum issued by the licensee to provide instructions for completing EDG Test Data Logs provides criteria for i

determining if a EDG start or start attempt is an invalid test or failure. The inspector compared this criteria ageinst the guidelines in NRC Regulatory Guide 1.108 for determining invalid tests and failures. Statement B(b) of the Intra Department Memorandum states l

that a failure for the EDG to start automatically is not a valid test or failure provided the EDG can be manually started from the Control Room.

This statement is not in accordance with NRC Regulatory Guide (

1.108 criteria for determining an invalid test or failure, j

i The inspector findings conclude that (1) the Intra Department

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Memorandum for maintaining the EDG Test Data Log is technically l

incorrect because statement B(b) of the Memorandum does not comply with NRC Regulatory Guide 1.108 and (2) the EDG Test Data Log did not describe invalid tests and f ailures in sufficient detail to permit

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independent determination of validity of EDG reliability.

These findings are identified as violation 50-348, 364/87"37-01, Incorrect Procedure and Incomplete EDG Test Data Logs.

6.

Annual Diesel Generator Reliability Report (Units 1 and 2)

FNP TS 6.9.1.12 requires the number of tests (valid or invalid) and the (

number of failures to start on demand for each diesel generator be submitted to the NRC annually, and that the report contain the information identified in Regulatory Position C.3.b. of NRC Regulatory Guide 1.108, Revision 1, 1977.

The inspector reviewed the 1936 FNP Annual Diesel Reliability Report.

The report contained the following information.

Diesel Generator 1-2A IB 2B IC 2C Total (

Valid Successful Tests

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167 Invalid Tests

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21

104 Failures

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1 At 1350 on May 5,1986, tne 2C FDG was started to perform an operability test.

Upon starting, the plant operator noticed that no frequency or voltage was indicated.

However, speed indication and DG status lights functioned correctly.

The control power fuses and control circuits were checked and no problem was found.

The EDG was restarted and it tripped due to overspeed. No cause for the trip was discovered.

The overspeed trip switch was reset. The field flashing circuit was checked and the K1 field flashing relay was manually operated.

The EDG was restarted and proper indications were received locally and on the emergency power board. The EDG wa< returned to service at 1955 on May 12, 1986.

The K1 relay was check.: again later in the shift and was verified to be operating pror.rly.

No correlation between the overspeed trip and loss of in' cation could be found.

.his was the first failure in the last 100 starts for this type of EDG.

No change in the surveillance schedule was necessary.

The surveillance interval remained at 14 days in accordance with TS Table 4.8-1.

The 1986 FNP Annual Diesel Generator Reliability Report did not identify invalid failures for each EDG, describe the cause of invalid failures or describe corrective measure taken.

The licensee stated that invalid EDG f ailures were not reported because TS 6.9.1.12 was interpreted as act requiring invalid failure reporting.

Per NRC Regulatory Guide 1.108 invalid failures are required to be reported in order to analyze and examire failure trends.

The inspector verified with NRR that invalid i

i failures are required to be reported.

The licensee has committed to I

provide information required by Regulatory Guide 1.108 on Invalid EDG failures in future Diesel Generator Reliability Reports and to issue a revision to the 1986 report to provide this additional information.

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No violations or deviations were identified.

7.

Inspector Followup on IE Bulletin 85-BU-03: Motor Operated Valve Common Mode Failures During Plant Transients Due to improper Switch Settings (50-348, 364/85-BU-03) (Modules 25573)

The inspector held discussions with responsible licensee and Motor Operated Valve Analysis and Test Systems (M0 VATS) engineers and maintenance personnel concerning the progress of their program to meet the

requirements of this Bulletin.

The licensee is in the process of completing testing on Unit 2 Bulletin valves (a total of 37) and in parallel is evaluating the data obtained while testing. Testing of Unit 1 Bulletin Valves (total of 37) is scheduled to commence and be completed during the 1988 Spring refueling outage.

The licensee's program consists of reviewing each valve design basis, testing each valve to identify the as found condition, refurbish each valve actuator, test each valve under no load condition, and then test selected valves with the system pressurized. The inspector verified through discussions with the licensee that valve operation during degra led voltage conditions and operation with valve packing at maximum torque were considered during the valve's design review. The licensee has a dedicated program to determine correct valve thermal overloads.

One phase of the program is to determine adequacy of the previously installed thermal overload by performing a boroscope inspection on each valve motor during actuator refurbishment. The licensee feels that the visual condition of the motor is helpful in determining adequacy of the existing thermal overload along with identifying other motor problems.

Boroscope inspections have revealed cracked motor internal components, charred marks on stator and windings, metal beads on rotors and dry and cracked stator and insulation.

Although during testing, motor running current, motor load, winding resistance and megger checks were within specification, the licensee has replaced valve motors based only on the boroscope inspection. During the as found testing the following deficiencies were identified and subsequently corrected or evaluated: too high valve thrust, worn motor bearings, valves being backseated, corroded torque switches, and loose spring packs. Of the 37 unit 2 bulletin valves, approximately 25 will be tested under a D/P. Fourteen Unit 2 Bulletin valves have so far completed D/P testing, of these, three ve.lves have failed to operate under a D/P or which could indicate a serious problem in the FND Program. The suspected cause of one of these valves failing to operate may have been caused by the spring pack preload nut backing off which was removed and reinstalled during actuator refurbishment.

This failure and the other two valve failures are being investigated by the licensee.

Valves failing to operate under a differential pressure will be followed up on a future Inspector inspection.

This is idntified as IFI 50-364/87-37-02, Valves Failing to Operate Under a differential pressure.

The inspector reviewed Maintenance Procedure FNP-0-MP-89.0, "Limitorque l

Motor Operated Valve Testing Using MOVATS 2150 Analysis and Testing l

System." This is a generic procedure utilized for testing Bulletin valves l

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l and provides detailed instructions for periodic testing and maintenance of limitorque motor operated valves.

This procedure does not provide instructions for ad]usting spring packs or limit switches, other procedures-referenced these items.

FNP-0-MP-89.0 contained clear-instructions as to specific torque switch settings. The procedure did not specify that torque ' switches are to be set with the valve in'the mid-stroke position and the Belleville spring in the relaxed condition, however, a subsequent step in the procedure performs MOVATS testing that would identify a torque switch incorrect setting. The inspector reviewed Procedure FNP-0-MP-28.137, "Limitorque-Type. SMB MOV Inspection and Adjustment," which is referenced by FNP-0-MP-89.0 to adjust limit j

switches.

The procedure did not specify setting limit switches based on stem movement, instead it set limit switches based on number of handwheel turns. Current industry practice is to utilize stem movement in lieu of counting hardwheel turns to set limit switches.

FNP-0-MP-89.0 and FNP-0-MP-28.137 inspector findings were discussed with the licensee.

The inspector witnessed Bulletin valve testing per FNP-0-MP-89.0.

The procedure worked well while the inspector witnessed its use. Maintenance and testing personnel followed the procedure in a step-by-step manner without experiencing any difficulties.

MOVATS test personnel were directing the testing and were knowledgeable on motor operated. valve specifics and the test equipment.

No violations or deviations were identified.

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