IR 05000348/1989026
| ML19332E485 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/21/1989 |
| From: | Belisle G, Scott Sparks, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19332E479 | List: |
| References | |
| 50-348-89-26, 50-364-89-26, IEB-85-003, NUDOCS 8912070281 | |
| Download: ML19332E485 (12) | |
Text
ll Ri >;.T
'. ;
. .Y. 4 h M . UNITED STATES l . ' j-4 'q, NUCLEAR REGULATORY COMMisslON ] . ,, - REGION ll ~ b +s s 101 MARIETTA STREET.N.W.
- ~
k .- . \\.....y#j ' ' ATLANTA, GEORGI A 30323 - ' ,. . p j < m
.
- Report No.
- t 50-3_48/89-26'and 50-364/89-26-
Licensee:. Alabama Power Company.
i 1600 North-18th Street' Birmingham, AL-35291-0400 . j Docket No.:.:50-348 and 50-364-License No.: NPF-2 and NPF-8 Facility Name:. Farley-1 an'd 2-. k I ' Inspection Conducted:( October 2-6, 1989 and October 16-20, 1989
s w Inspection at Farley site near Dothan,' Alabama .i-Inspectors: ?lCfoL' A - tihi
5. Tingeh.
Date Signed
S. Sd n/mle
'5.
Sparks Ddte Signed s
- Approved by:
W/ (~ E[ ///2 / /b
- G. A. Bdlisle, Chief 4 Date Signed Test Programs Section Engineering' Branch Division of Reactor Safety l.7 r
L SUMMARY ,, Scope: '
- This routino, announced inspection was conducted.in the areas of inservice
' h
- testing, complex. surveillance, Inspection and Enforcement (IE) Bulletin
' '. followup.and action on-previous inspection findings.
Results: ,.. lt p
- Violations were identified for inadequate inservice testing, (paragraphs 3, 4 l
and. 5)~ and-inadequate complex surveillance testing, (paragraph 7). A strength
was identified in the. area-of IE Bulletin 85-03 differential pressure testing, t(paragraph 8).
L pi l . K . 891122 N ~ 8912070281 ADOCK0500g8 DR.
i -.. . .. - -. .- - ...- - -...-. --
G 3:
, .
- <-
, c. , '. s ,. , i' , REPORT DETAILS
i 1.
Persons Contacted Licensee Employees
- R.: Badham, System Performance Engineer
- R. Berryhill, Systems' Performance and Planning Manager
'
- C, Buck, Plant Modification Manager
- L. Enfinger, Administrative Manager
- S. Fulmer, Supervisor.. Safety Audit and Engineering Review
- R. Hill, Assistant General Manager - Plant Operations
- D. Morey, General Manager - Farley Nuclear Plant
- J.. Thomas, Maintenance Manager Other licensee employees contacted during this : inspection included
, craftsmen, engineers, operators, mechanics, technicians, and L administrative personnel.
NRC Resident Inspectors - -G. Maxwell l > L
- W. Miller l
H
- Attended exit. interview
. ! l Acronyms and initialisms used throughout this report are listed in the j 'last paragraph, ' 2. - ISTIntroduction(7S756) 10 CFR_50.55a(g) and Farley Nuclear Plant "TS Surveillance Requirenent 4.0.5 require that ASME Code Class 1, 2 and 3 pumps and valves be 11nservice tested in accordance with Section XI of the ASME Boiler Pressure and Vessel Code.
Section XI specifies rules and requirements for , inservice testing to assess operational readiness of certain Class 1, 2 { and 3 pumps and valves which are required to perform a specific function > in shutting down a reactor to the cold shutdown condition in mitigating the consequences of an accident or in providing over pressure protection, Farley Nuclear Plant is required to follow the requirements of ASME Code, , -Section XI,1983 Edition through the Summer 1983 Addenda.
During this Linspection, the inspectors reviewed the licensee's Inservice Test Program, Inservice Test Plan, implementing procedures, and test results that i accomplish.Section XI pump and valve IST. The results of this review are stated in paragraphs three through six.
Pumps and valves that are in the AFW system or support the operation of the AFW system, pressurizer safety valves, and PORVs were reviewed during this inspection.
. -.. - -- . . . - -.. .. . .
i - , s , v s, ..
.: , . ... ,: g h< , v In = the area of IST, one violat' ion with four examples was identified.
These are discussed in paragraphs three through five.
, _3.
Pump Testing (73756) , 1The inspectors reviewed IST. of MDAFWPs A and B, and the TDAFWP, for each L nit? to determine whether_ testing was performed in accordance with , U s Section XI,. Subsection IWP requirements. The following AFW IST implementing-procedures and test results were reviewed: FNP-1-STP-22.1, Auxiliary Feedwater Pump 1A Quarterly Inservice Test, Rev.-l'
FNP-1-STP-22.2, Auxiliary Feedwater Pump 1B Quarterly Inservice Test,
Rev. 17 ~ FNP-1-STP-22.26, Auxiliary Feedwater_ Pump 1A Cold Shutdown Inservice Test, Rev.41 FNP-1-STP-22.27, Auxiliary Feedwater Pump 1B Cold Shutdown Inservice Test, Rev. 1 FNP-1-STP-22.16, Turbine Driven Auxiliary Feedwater Pump Quarterly Inservice Test, Rev. 14 ! ' Similar IST-procedures were reviewed _for Unit 2.
' In general, inspection results - indicated that Code requirements were j satisfied in the areas of testing frequency, establishing new reference' values,_ post-maintenance testing, and evaluating test results.
However,
reviewc of procedures FNP-1-STP-22.16 and FNP-2-STP-22.16 revealed that .i acceptance criteria for-quarterly IST of the TDAFWP were not in accordance l
with Section XI, Subsection IWP requirements, Specifically, Subsection IWP-31001 requires that each measured test quantity (such as inlet 'l ' pressure, differential pressure, flow rate, and vibration amplitude) be ,
compared with 'the reference value of the same quantity.
Any deviations ' determined shall be_ compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.
The TDAFWP IST procedures did not contain acceptance criteria for a comparison of pump differential pressure ! for. the high - values in the Alert Range (1.02 to 1.03 of differential i
- pressure) and Required Action Range (>1.03 of differential pressure).
- However, comparisons. of other measured test quantities were performed.
The" licensee had initiated correction action to revise the appropriate j procedures during the inspection.
However, this item is a violation of i , Subsection IWP-3100, and is identi fied as Part A to violation 50-348,364/89-26-01, Failure to Provide TDAFWP IST Acceptance Criteria.
~The inspectors also reviewed corporate QA audit FNP-NC-39-89/15(29), which identified a noncompliance in the pump testing area.
GL 89-04, Guidance on Developing Acceptable Inservice Testing Programs, dated April 3,1989, provides NRC staff positions on IST, and states the following:
v tw: ' ' ' ,. ,'
- e
.4 ,. , y; a.; a v -
, c
-When the. data is determined to be within the Required Action Range of ' ~ Table IWP-3100-2 the pump is -inoperable and the TS Action statement time starts.
The - provisions. in IWP-3230(d) to recalibrate.the yM instruments involved.and rerun the. test to show the pump is-still capable of: fulfilling its function are an alternative to replacement
or-repair,' not ~ an ' additional. action that can be taken before
- declaring the pump inoperable.
, , ' ~The corporate QA: audit identified several pump.IST procedures where a i second test may be'run after-instrument recalibration prior to declaring the pump inoperable, which is not consistent with GL 89-04. The, licensee stated that-their policy was. not to declare equipment inoperable-or take - TS action baseduon erroneous data.
If instrument recalibration makes no difference, the pump is. considered inoperable from the time of the first test, which-by the-licensee's interpretation is allowed.by the ASME Code and the Inservice Test Plan. The licensee also stated that their Inservice-Test Plan and implementing-procedures were based on conformance with the ASME Code, and compliance with the NRC staff pcsitions contained in GL ? 89-04 wasLnot a requirement.
-The inspectors 1also witnessed IST for Unit 2 Containment Spray pump 2B.
. Test personnel were knowledgeable of acceptance criteria, procedural . ere familiar with surveillance procedure ' requirements,.and w .FNP-2-STP-16.2. The inspectors noted during the test performance that the _ Containment Spray: pump suction pressure indicator PI-946A was oscillating.
"' Test personnel-recorded a. conservative reading, which subsequently led to - a: differential pressure that was in the Alert Range as required by the . procedure.
PI-946A-was recalibrated which is allowed by Subsection IWP-3230(d) of: the Code;. however, the as-found calibration was satis-factory. During the re-test, test personnel throttled the instrument line isolation valve to reduce instrument fluctuations as permitted by Subsection IWP-4150.
Acceptance criteria were satisfied during the re-test.
The inspectors commented to licensee management that damping hydraulic instruments is addressed by the Code, which may provide more consistent and' accurate test data.
Within the areas inspected, one example. of the IST violation was identified.
4.
Check Valve Full Stroke and Reverse Flow Testing (73756) The inspectors reviewed the full stroke and reverse flow IST methods and results for the following check valves for each unit: NV001 NV005 NV009 NV013 QV002A QV002B QV002C QV002D QV002E QV002F QV002G QV002H QV003 QV006 QV007A QV007B QV011A QV011B QV011C HV3235A HV3235B QV010A QV010B / b' .. .. - -., - -. - - , - . - -, _.. . - - - -. -.... - - -, . -
w-g -
. . . ,
- ..
+, . .,- f ( The inspectors reviewedithe following Unit 1 (corresponding procedures ' - were alsoLreviewed for Unit 2 testing) procedures which performed IST on the previously listed check valves: . FNP-1-STP-21.3r TDAFWP Steam Supply Valve Inservice Test, Rev. 2 - FNP-1-STP-22.16,LTurbine Driven Auxiliary Feedwater Pump Quarterly Inservice Test,- Rev. 14 . FNP-1-STP-22.1, Auxiliary Feedwater Pump 1A Quarterly Inservice Test.
Rev.3 19 FNP-1-STP-22.2, Auxiliary Feedwater Pump 1B Quarterly Inservice Test, .Rev. 17 FNP-1-STP-644.1, Auxiliary Feedwater Pump Check Valve (Q1N23V006, Q1N23V007A, B) Full Stroke Test, Rev. I sFNP-1-STP-22.8, Auxiliary Feedwater Inservice-Valve Exercise Test.
Rev. 9 , FNP-1-STP-22.24 Auxiliary Feedwater System Check Valve Reverse Flow-Closure' Operability Test, Rev. I FNP-1-STP-22.12, Motor Driven Auxiliary Feedwater Check Valves Flow Verification, Rev.-7 . Requirements.for full stroke and reverse flow exercising check valves are contained in Section XI, Subsection IWV-3522 of the Code.
The inspectors reviewed testing frequencies, results, and appropriate relief requests for the above check valves.
In addition, where full
- stroke testing.was performed, the inspectors verified that flow rates were specified by procedure and were greater-than design accident flow rates.
Ie The inspectors also reviewed check valve reverse flow testing, which is required by the Code for check valves which perform.a safety function in the closed position.
Subsection IWV-3522 requires check valve testing in .a manner that verifies the disk travels to the seat on cessation or - reversal of flow.
The inspectors identified the following two examples where the check valve reverse flow function was not verified: TDAFWP steam supply stop check valves HV3235A and HV3235B are reverse flow tested by procedure STP-21.3 on a quarterly basis.
These stop ,o check valves are A0Vs which fail in the open position, and reverse flow closure is -verified by stroking the valve by a manual handswitch to verify reverse flow closure. However, these stop check valves are also required and designed to close on flow reversal. The licensee's testing only verifies stem movement, and does not verify that the .. .. - - . - - . -. -. -- . - ,
em - ,z , .- , ,
.. .
- disk travels to -the seat on flow reversal.
This method does not verify-the. reverse flow function of check valves HV3235A and HV3235B , h.
.in accordance with Subsection IWV-3522 andeis identified as Part B . , of? violation 50-348, 364/89-26-01, failure to Verify Units 1 and 2-Check-Valves HV3235A and HV3235B Reverse Flow function.
MDAFWP. discharge check ~ val.ves V002A and V0028 are reverse flow tested by procedure STP.-22.24 on a quarterly basis.
The procedure records temperature from a temperature element located-upstream of the check' . -valves and downstream of the MDAFWPs. The licensee verifies reverse ' - .' flow closure, :in that, if the check valves do' not travel to the seat .on reversal or cessation of flow, a high temperature reading would be i . . present due.to high temperature steam from the steam generators.
However, check valves YOO2C, D..E, F, G, and H are located downstream o of check valves V002A and.V0028.
These check valves, although not l reverse. flow tested, may isolate the high. temperature steam from the ' , ' steam generators.
This would prevent check valves V002A and V002B from being exposed to a" high temperature source, and thus the temperature-elements upstream of check valves V002A and V002B would .! not:see an4 elevated temperature.
As such, check valves V002A and i V0028.may not be capable.of reverse flow closure, and the licensee's . testing' method-would not detect this.
This method does not verify J . thel reverse-flow function of V002A and V0028 in accordance with , Subsection IWV43522,- and 1s -identified. as-.Part C to violation
50-348,364/89-26-01 Failure to Verify MDAFWP Discharge Check Valves V002A and V002B Reverse Flow-Function.
Within the areas inspected, two examples. of the IST violation were identified.
! 5.. PowerOperatedValveIST(73756) i 'The inspectors reviewed IST for the following MOVs and A0Vs in Units 1 .and 2 AFW, SW, and reactor coolant systems.
i-MOVs A0Vs < M0V3350 A,B,C HV3227 A,B,C L M0V3764 A,B,C,D,E,F HV3228 A,B C ' M0V3209 A,B HV3226
MOV3210 A,B HV3234 A,B . i M0V3216 HV3235 A,B M0V3406 FCV498 L M0V3232 A,B,C FCV488 M0V8000 A,B FCV478 FCV499 l FCV489 - FCV479 ' PCV445A L PCV444B j
. - - ..- .- - - .. -. -. ... .. -
e N '-- ~ -
~
. s i: W tff ?
- _,,
- s , t i f.
... Y
A E 'The11nspectors interviewed l'icensee personnel regarding the general imethods used to stroke time power operated valves and reviewed the ' , .following implementing procedures for IST of the previously listed valves: j, FNP-1-STP-201.28, Revision 4, Pressurizer Power.0perated Relief " '
- Valves Position' Indication Verification
'FNP-0-AP-16, Revision 19, Conduct of Operations - Operations Group' . , s FNP-1-STP-21.3, Revision 2, TDAFWP Steam Supply Valves Inservice . Test . u , ' FNP-2-STP-45-11,. Revision.' 2, Miscellaneous Cold -Shutdown Valves - , Inservice Test [ FNP-1-STP-47.0, Revision 10, Miscellaneous Valves Inservice Test FNP.-1-STP-45.11, Revision 3, Miscellaneous Cold Shutdown Valves . Inservice Test , The. inspectors observe'd the performance of an AFW system valve lineup i = which was' accomplished ' in accordance with FNP-2 STP-22.5, Revision 12, ' Auxiliary. Feed Water System Flow Path Verification.
' The 1nspectors reviewed the stroke times.of Unit 1 Power Operated Valves ~ , contained 11n the Control Room Valve Stroke Time Log.
.The criteria-for IST power operated valve's is contained in. Subsections IWV--3412, 3413, 3415 and 3417 of the ASME code. These subsections specify . stroke timing, fail-safe testing, and corrective action requirements.
Air operated stop check valves HV3235A and B are located in the steam supply. lines to the TDAFWP.
HV3235A is the steam supply ~ valve from the "C" SG.
These-valves open automatically on an automatic TDAFWP start and .their fail-safe position is open.
Review ~of the Inservice Test Plan y
- indicated that these valves were not being stroke timed in the open and closed - positions.
Review of implementing procedure-FNP-2-STP-21.3 indi- ,' cated that, although not required by the valve IST plan, valves HV3235A l.
and B were-'being stroked quarterly and the open direction stroke time was-being measured with a limiting value of ten seconds assigned, however the L valves closed direction stroke-time was not being measured nor was a stroke time closed limiting value assigned. During an accident involving a "B" or "C" SG tube rupture, valves HV3235A or B.would be required to be shut to-isolate the affected SG from the TDAFWP; therefore, the valves are required to be stroke timed in the shut direction.
This item is identified as Part d to violation 50-348, 364/89-26-01, Failure to stroke time Units 1 and 2 Valves HV3235A and HV32358 and assign a limiting stroke time values.
Review of the Inservice Test Plan indicated that the PORVs were being stroked timed in the open direction but not in the closed direction. The . licensee stated that, by design, the block valves are required to be shut .. . _- . .
m ,, - -- - - - ' , , S , . . . . s. w .;o .. . 7- , , f s
if? a PORV; sticks-open; therefore, testing of the PORV.in 'the shut - direction.was not required _ per the ASME code.
However, the-licensee agreed-that it _would be prudent to-stroke test these valves in the closed --directing;and agreed to do so in-the future.. . All other itcms. inspected in the area of PORV: IST were accomplished in s "accordance with Section XI of the ASME Code.
Within the ; areas inspected; one ' example of the -IST violation was ' , identified.- '
- 6.-
^ Safety:andReliefValveIST(73756) ' , w LThe' inspectors reviewed IST for the following safety and relief valves in Units 1 and 2 reactor coolant and AFW systems, s -- 02B13V031 A,B,C Q1813V031 A,B,C PSV2922A' B,C '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: , FNP-1-STP-628.5, Revision 1 Auxiliary Feedwater Pump Suction Line Relief Valve Operational Test
L FNP-1-STP-604.0, Pressurizer Safety Valve Test The inspectors reviewed the results of the pressurizer safety valve test ,. L dating back to 1987.
a The criteria for the IST safety and relief valve is contained in ' t Subsections IWV 3511, 3512,_and 3513 of the ASME Code. These Subsections _specify test methods and frequency.
TS 3/4.4.3 specifies the Pressurizer . Safety Setpoint tolerance of 2485 1 1 percent psig.
All-items inspected in the area of safety and relief valve IST were accomplished in accordance with the ASME Code and TS.
Within the areas inspected, no violations or deviations were identified.
h , Complex Surveillance Testing (61701) 7.
TS Surveillance Requirement 4.4.5.1 requires that each pressurizer PORV be ' demonstrated operable at least once every 18 months by performing a channel calibration and operating the valve through one cycle of full
travel.
The inspectors reviewed the following procedures that accomplished this surveillance requirement: , i . -.. -_ .. .- - - - . - -- .- .
- . , m.
.. .. . ..,
8
,
FNP-1-STP-33.0A, Revision 10, Solid State Protection System Train A ' Operability Test.
, FNP-1-IMP-201.24, Revision 5, Pressurizer Pressure Control, l ' NIB 31PT004 FNP-1-STP-201.3, Revision 3. Pressurizer Pressure, NIB 31PT0444Z Loop , Calibration p L FNP-1-IMP-201.23, Revision 7, Pressurizer Pressure Control h NIB 31PT0445 p FNP-1-STP-33.1A, Revision 2, Safeguards Test Cabinet Train A functional Test , FNP-1-STP-201.28. Revision 4. Pressurizer Power Operated Reitef Valves Position Verification
The pressurizer PORY channel calibration was accomplished by performing a series of overlapping procedures.
Results of the inspector's review of the PORY channel calibration procedures was that the channel function test was not being properly performed.
A channel function test is required to , ' -be performed when a channel calibration is performed.
This requires that , a simulated pressurizer pressure signal be injected to verify automatic ' actuation of the PORVs.
The PORV logic circuitry that ntuates as a i , . result of the channel bistables energizing and/or deenergizing was not L being. verified.
For example, the PORV logic circuitry contains contacts l that make or breu on high or low ' pressurizer pressure in order for the !_ PORVs to automatically open or close.
The automatic operation of these ' contacts were not being verified.
This function has never been verified.
If the condition existed where contacts were. burnt or stuck shut then the PORVs would not automatically open or close as desianed.
Failure to adequately test the PORY logic circuitry in accordance with TS Surveillance Requirement 4.4.5.1 is identified as violation 50-348 364/89-26-02.
. .Within the areas inspected, one violation was identified.
8.
BulletinFollowup(92701) , (Closed) 50-348,364/85-BU-03 TI 2515/73, Motor Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Settings.
- The purpose of this Bulletin is to require licensees to develop and i-implement a program to ensure that switch setting for high pressure
. coolant injection and emergency feedwater system MOVs subject to testing for operational readiness in accordance with 10 CFR 50.55a(g) are properly ' set, selected, and maintained.
,. The licensee's IE Bulletin 85-03 program was previously discussed in NRC Inspection. Report 50-348,364/87-31 and is further discussed in paragraph 9 - _ . . . . . . - __
e y q .. , x
_-
g.
.. .
i < l of this Inspection Report.
The final review of the licensee's program indicated that the licensee had satisfactorily completed all IE Bulletin , 85-03 requirenents.
In accomplishing these requirements, the licensee did a commendable job in thw area of differential pressure testing, in that, a , large number of valve.; were tested.
This testing identified problem ] areas that were aggres:1vely resolved by the licensee.
) Within the areas inspected, no violations were identified.
' 9.. ActiononPreviousInspectionFindings(92701,92702) a.
(Closed)IFI 50-348,364/87-31-02 Valves failing to Operate Under a i Differential Pressure.
l l When differential pressure testing valves in accordance with IE , Bulletin 85-03, five Unit 2 valves failed to fully shut. The failure of valve MOV8133A was attributed to a loose spring pack elastic stop i nut which was reused following overhaul of the actuator. As a result of this failure, procedures were revised to not allow reusing
elastic stop nuts.
Yalves M0V3764C and F failed to close under a dif ferential pressure.
These valves were four inch flex-wedge gate valves manufactured by Velan.
In Units 1 and 2 there are 10 other
valves identical to M0V3764C and F; therefore, all Velan flex-wedge i ? four inch gate valves were grouped in a single group of 12 valves.
All 12 valves in this group were differential pressure tested with only valves M0V3764C and F failing to fully shut.
As a result of - these failures valves MOV3764C and F were disassembled and inspected.
~The inspection of the valve internals did not reveal any causes for the previous failures.
The valve's disks, with carbon steel guice slots, were replaced with new disks with stellite guide slots and ! repacked with a different type of packing.
The volves were
subsequently satisfactorily differential pressure tested.
Valves M0V8803A and B also failed differential pressure testing. These are three inch flex wedge gate valves manufactured by Velan.
The failures were attributed to nonconservative thrust equations, and as a result of the failures Westinghouse revised the thrust equations > by changing the valve factors from.3 to.5.
The torque switch < settings were increased based on the.5 valve factor and the valves
were satisfactorily dif ferential pressure tested. A.5 valve factor was then used to determine the required thrust for all IE Bulletin + l 85-03 three inch Velan flex-wedge gate valves, b.
(Closed) IFI 50-348,364/88-18-01, Determine the Effectiveness of the Licensee's Service Water Chlorination Program.
The inspectors reviewed the licensee's actions for this area, which consisted of a chlorination program for control of Corbicula.
The , licensee uses procedure FNP-0-CCP 708, Rev.
Chemical Addition / Control of the Service Water System, in which sodium hypochlorite is added continuously to the scheduled unit for Corbicula treatment for a period up to eight weeks or until a clam . .
p .. " - q O: .4
.. . [
mortality of greater than 90 percent is achieved in sidestream , aquaria, whichever occurs first.
The inspectors discussed " operational and maintenance problems with licensee personnel, and reviewed Clam Inspection Reports performed during disassembly or maintenance on the Component Cooling Water Heat Exchangers, and did not note any Corbicula problems.
The licensee's actions to address this issue were satisfactory.
c.
(Closed) Violation 50-348,364/87-31-01, Incorrect Procedure and Incomplete Emergency Diesel Generator Test Data Logs.
The Licensee's response dated 12/22/87 was considered acceptable by Region 11. The inspectors reviewed the licensee's corrective actions in this area, which consisted of revising acceptance criteria, proper logging of invalid diesel starts, and elapsed time to reach rated speed and voltage in the diesel Test D6ta Log.
The licensee's actions to address this issue were satisfactory.
Within the areas inspected, no violations or deviations were identified.
10. Exit Interview The inspection scope and results were summarized on October 20, 1989, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed above.
Proprietary information is not contained in this report.
Dissenting comments were received from the licensee in the area of measuring stroke time for the PORVs in the closed direction. The licensee stated that the PORVs do not have a safety function in the closed direction in mitigating the consequences of an accident or shutting down a reactor to the cold shutdown condition. As such, stroke timing was not a section XI Code requirement -and thus did not warrant a violation.
However, licensee management stated that a knowledge of the PORV stroke time in the closed direction would be prudent in determining valve - degradation, and agreed to begin PORY stroke timing in the closed direction.
Subsequent to the inspection, the inspectors agreed that PORY stroke timing in the closed direction was not a Code requirement.
Licensee nanagement was informed via telephone on October 26, 1989, that this item would not be identified as a violation.
Item Number Description and Reference 348,364/89-26-01 Part A Violation - Failure to provide TDAFWP IST acceptance criteria, paragraph 3.
348,364/89-26-01, Part B Violation - Failure to verify Units 1 and 2 check valves HV3235A and HV3235B reverse flow function, paragraph 4.
.
.-p- ' ! - . ' o.
. . ,, .
J Item Number Description and Referenc_e (cont'd) , h F 348,364/89-26-01, Part C Violation - Failure to verify MDAFWP
!- discharge check valves V002A and V0028 - reverse flow function, paragraph 4.
348,364/89-26-01; Part D Violation - Failure to stroke time , ! Units 1 and 2 valves HV3235A and , L HV3235B and assign a limiting stroke
time value, paragraph 5.
348,364/89-26-02 Violation - Failure to adequately test l PORY logic circuitry, paragraph 7.
Licensee management was informed that the following items were closed: IE Bulletin 85-03, paragraph 8.
{ IFI 50-364/87-37-02, paragraph 9.
IFI 50-348,364/88-18-01, paragraph 9.
Violation 50-348,364/87-37-01, paragraph 9, 11. Acronyms and Initialisms AFW Auxiliary Feedwater ADV Air Operated Valve ASME American Society of Mechanical Engineers FNP Farley Nuclear Plant GL Generic letter IFI Inspector Followup Item
IST Inservit.a Testing l-LOCA Loss of Coolant Accident MDAFWP Motor. Driven Auxiliary Feedwater Pump MOV Motor Operated Valve PORY Power Operatid Relief Valve L PSIG.
Pounds per Square Inch, Gage QA Quality Assurance i ! REV Revision SG Steam Generator SW Service Water TDAFWP Turbine Driven Auxiliary Feedwater Pump l TS-Technical Specifications > ,
- 1 W.11/16/e9 ,10:42 H1TE FLINT P: 37 to.303 002 ' m. s ..
A ) ENCLOSURE 3 1~,g Novembee KS, 1989 , NEMORANDIM POR ' O. 8. Matthews. Project Director (14H 25) Pro.fect Directorate !! 3 Division of Reactor Projects - I/!! - PROMt.
Robert C. Jones. Acting Chief Reacter Systems tranch
101 vision of Systems Technology VOSTLt UNIT 1 INTERPRffATION OF TS 3.4.4 LIMITING SutJECT: aCONDITION POR. OPERATION. AtLIEF VALVts L: [ Plant home's Vtstle Unit l' , 72371 TACNe(s)(.', ' -Deckethos) 80-424 L P set Directorate P ett Directorate !!-3 ' oct Manater: J.
ins 'Rev ew Srancht.
SRXB/ ' Review Status: Complete In telephone discussion en November 9. 1989. the NRC Region !! Vogtle Unit 1 muestedanNRRpositionwith)regardtosurveillancerequireesnt4.4.y) SeniorassidentInspector($RI and the licensee (Georgia Power Compan
effropsing PORY testing. The issue is whether or not the automatic function of the PORY need be testes in order to satisfy the requirements of 78 4.4.4 In additten, the licensee stated its intent to pursue the ' automatic" surveillance mede in January 1990 at their next block valve surveillence intervs1.
The licensee performed the ' manual" PORY surveillance testing at the required > interval. However, the $R! interpreted the surveillance requirement to mean that the 'Autcastic" function should also be included. The difference of the two approaches means that a small portion of the circuitry is not tested.
(Thevalveisstrokedinthemanualmode.) However if the surve111snee < requirement ~ 1s intended toxinclude the automatic mode end.the' autensticFor function is not tested, then the PORVs should be declared inoperable.
l _causes of inoperability other than excessive seat leakage, action statement 'b' .opplies end the plant aust shut down.
o The licensee's interpretation is that the manual mode is adequate because: l 1.
Jactionstatement'a'ofthisLC0(iftherewasexcessiveseatleakage) would allow indefinite plant operation with both block velves closed 1.e., without the PORY automatic function.
2.
.the language of the Vogtle FSAR Chapter 15 which does not require (nor use) the PORY automatic actuation, and Contact: L. Lois. SRX8/0$f. xP0000 ' . ^
n - m _. -- .,
- N stessess se 43 HITE FU NT P1-37 NO.883 e03
.,.'+ , . . . .. ' * i rg, . , p. 8. Matthews .t- ' 3.
the fact that under severe accident conditions the PORVs will be used in the senval mode.
l , ' The reasons for.their present avoidence of this test are: (1)toavoidanother i p0RV streking, and (t) because the part of the circuit which has not been > tested is a passive circuit of very high reliability.
. The staff's interpretation f the sveveillance requirements are that the e tie function of the Vs must be assured except fee cases of excessive ! seat leakage. This is because of the following safety considerations associated with the automatic function: (1) assurance that the valves will
not 9 pen at pr below nomel primary system pressurs (thus causing a small break LOCA) and (t) minimiting challenges to the pressuriser code safety valves.. With regard to the licensee's plan to continue operetten until January 1990 l Irior to testing the automatic function, we find this acceptable because: ' L1)theblockvalvesareeimrableandcanbeclosedintheeventofan t . onedvertent p0RV epening licensee's safety analyse 125 She p0RYs are not directly credited in the L s,(33identicalcomponentshavebeenrecently i soccessfullytestedattheotherVogtleUnit,(4)theportionofthe i surveillance test perfomed eevered the major ports of the cirevitry and the i mechanical portion of the valve including the setpoints, and (5) the licensee
plans to include the automatic function in future surveillances.
Robert C. Jones tranchActing Chief ' Reactor Systems , ' ' Division of Systems Technology i ?
i +
k l lu . .. . . . .- . }}