IR 05000369/1986026

Insp Repts 50-369/86-26 & 50-370/86-26 on 860825-29. Violation Noted:Inadequate Corrective Actions Re Noncompliance Concerning Checks of Proper Valve Position Indication

ML20214V877
Person / Time
Site:	Mcguire, McGuire
Issue date:	10/16/1986
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214V853	List: IR 05000369/1986026 ML20214V850 ML20214V869
References
50-369-86-26, 50-370-86-26, NUDOCS 8612090885
Download: ML20214V877 (9)

Text

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, UNITED STATES

/p2 KicgDo NUCLEAR REGULATORY COMMISSION 81EGloN 11

[ n 101 MAR;ETTA STREET. $'

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j ATLANTA, GEORGI A 30323

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Report Nos.: 50-369/86-26 and 50-370/86-26'

Licensee: Duke' Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 Facility Name: McGuire 1 and 2 Inspection Conducted: August 25-29, 198 Insoector: -

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E Date Signed Approved by. - -

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.. I v Blake, Section Chief

/0!/6 6 Date Signed n neering Branch t ision of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of inservice inspection, inservice testing, previous enforcement matters and inspector followup item Results: One violation was identified - Inadequate corrective actions, paragraph ~

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B612070885 861128 PDR ADOCK 05000369 G PDR

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REPORT DETAILS

. Persons Contacted Licensee Employees

• T. L. McConnell, Station Manager

• N. McCraw. Complaince Engineer

• Revels, Design Engineer

• R. A. Johansen, Performance Engineer

• N. Atherton, Compliance D. White, Maintenance J. Cavender, Inservice Inspection, Level III Examiner T. Troutman, Inservice Inspection NRC Resident Inspectors

• Order, Senior Resident Inspector

• S. Gunther, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on August 29, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed belo Violation 369, 370/86-26-01, Inadequate Corrective Actions, paragraph Inspector Followup Item 369, 370/86-26-02, Testing of Power Operated Relief Valves and Block Valves, paragraph Inspector Followup Item 369, 370/86-26-03, Basis for Setting Maximum Stroke Times, paragraph Unresolved Item 369, 370/86-26-04, Method of Stroke Timing, paragraph Inspector Followup Item 369, 370/86-26-05, NRC Replies to Relief Requests, paragraph Inspector Followup Item 369, 370/86-26-06, Valve Position Indicator Verifications of Auxilliary Control Locations, paragraph _ - . _

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Inspector Followup Item 369, 370/86-26-07, Large Differences Between Stroke Times of Identical Air Actuated Valves, paragraph Unresolved Item 369, 370/86-26-08, Written Criteria for Evaluation of Erratic Valve Action, paragraph The finding . described by the last inspector followup item above was initially identified to the licensee as part of Violation 86-26-01. During the exit meeting, licensee personnel stated their objections regarding its inclusion in the Violatio Subsequent to the meeting the inspector discussed the matter with knowledgeable Regional personnel and determined that, although the finding required further review, it should not be includ-ed in the Violatio The inspector informed the licensee's compliance engineer that the finding would be addressed thru the Inspector Followup Item during a telephone call on September 4,1986. The matter described in Unresolved Item 369, 370/86-26-08 was originally identified as part of Violation 86-26-01 and was separated from the violation based on discussions with NRC regional managemen The inspector informed the licensee's com-pliance engineer of this change in a telephone call on November 12, 198 The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection. Licensee Action on Previous Enforcement Matters (Closed) Violation (369, 370/86-05-01): Valve Position Indicator Verificatio This violation documented the licensee's failure to verify proper functioning of valve remote position indicators for safety injection system valves 1NI-1848, 1NI-185A, 2NI-184B and 2NI-185A. This verifi-cation is required by Technical Specification (TS) 4.0.5 through reference to ASME Section XI requirement The licensee's letter of response to the violation, dated April 8, 1986, was reviewed and approved by Region I In their response the licensee stated that they would preclude repetition of the violation for the subject valves thru corrections to appropriate procedure The inspector identified and examined the procedures which were to incorporate the position indication verifications for the subject valves to determine that the corrections had been incorporated. These procedures were PT/1/A/4200/22 (Unit 1) and PT/2/A/4200/22 (Unit 2).

The inspector found that the corrections had not been correctly made in that the procedures required, in successive steps, closure of valve NI-1848 and then verification that the indicator showed it to be ope Further, a check of the record for the last performance of the pro-cedure found that test personnel had verified correct completion of both step _ _

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The deficiency in the procedural corrections' and in the licensee's verifications performed using the deficient procedure described above are considered to represent' noncompliance with 10 CFR 50, Appendix B, Criterion XVI requirements for correction of conditions adverse to quali t This noncompliance was identified as Violation .369, 370/86-26-01, Inadequate Corrective Action In relation to the original violations, the inspector asked the licen-see if they performed checks of proper valve position indication for valves with position indications displayed on their auxiliary shutdown panel or in their standby shutdown system. The inspector had not i received a response by the end of his inspection. He indicated that this would be identified for review in a subsequent inspection as Inspector Followup Item 369, 370/86-26-06, Valve Position Indicator Verification at Auxiliary Control Location The original violation is considered closed as remaining concerns will be addressed by the new violation and inspector followup item identi-fied abov (Closed) Violation (369/86-11-01): Failure to Report Erratic Valve Actio This violation documented the licensee's failure recognize that stroke times for certain valves were abnormal or erratic and that these should be reported (for evaluation) as required by ASME Section XI. Stroke

times for Unit i valves ND-34 (residual heat removal system) and i

NI-332A (safety injection system) were measured as 0 seconds although i identical valves in Unit 2 had measured stroke times of 17 and 10 ( seconds respectively.

l The licensee's response to the violation, dated June 17, 1986, was reviewed and determined acceptable by Region II. In their response, the licensee indicated that the violation occurred because the test personnel did not have information readily available to them (such as size and type of values) from which they would recognize abnormal stroke times. To preclude recurrence of the violations, they stated that they would initiate a data base program for valve trending that r would consolidate pertinent valve information and provide data for counterpart (Unit'l versus Unit 2) valves on the same screen. They stated that the involved technicians and engineers had been trained on this data base and that the violation would be reviewed with appropri-ate personnel to assure they realized the importailce of promptly icentifying component problem The inspector checked the performance of the corrective actions stated in the response and found that they had been accomplished. However, the inspector found that the corrections were not supported by any written criteria or guidance as to what conditions should be considered abnormal or erratic or how they should be reported. The safety signifi-cance of the licensee's failure to provide written criteria or guidance

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for determining and reporting abnormal or erratic valve conditions will be examined in a subsequent inspection and the matter is identified as Unresolved Item 369, 370/86-26-08, Written Criteria for Evaluation of Erratic Valve Action In examining valve data included in the licensee's data base, the inspector observed that their apparently identical 8-inch air actuated valves IND-34 and 2ND-34 had been repeatedly exhibiting stroke times of about 6 and 20 seconds, respectively. These were two of the valves whose stroke times were questioned in Violation 369/86-11-01. In the exit meeting licensee personnel offered that the disparity in stroke times should not be considered erratic or abnormal behavior for an air

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actuated valv Based on subsequent discussions with other NRC per-sonnel, the inspector agreed that the stated stroke time differences might not represent abnormal or erratic behavior or have represented inadequate corrective action for Violation 369/86-11-01. The inspector determined that the behavior of these valves would be examined further in a subsequent NRC inspection and identified this planned followup as Inspector Followup Item 369, 370/86-26-07, Large Differences Between Stroke Tines of Identical Air Actuated Valve . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraphs 3.a and 6.a.

4 Inservice Inspection Data Review and Evaluation (Unit 1) (73755)

The inspector selectively reviewed the licensee's records to verify that they had a plan for inservice inspection examinations performed in the current Unit 1 outage and if that plan had been followed such that regula-tory and applicable code requirements were met. The applicable code for the examinations was ASME Section XI (80W80). The inspector performed his review by first selecting six examinations identified to be performed by the plan and then verifying that the licensee either had a report documenting the performance of each examination or an acceptable basis for deletion or deferral of the examinations. The examinations selected were as fo11cws:

Item N Item Description Examinations B07.07.204 Bolting Visual C01.010.005 Steam Generator Weld Ultrasonic B12.040.003C Valve Visual F1.02.880 Spring Hanger Visual B09.011.411A Pipe Weld Penetrant C03.040.011 Support Weld Magnetic Particle l Within the area reviewed, no violations or deviations were identified.

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- Inservice Testing of Pumps on Valves (61700)

The inspector reviewed selected procedures, records and requests for relief from code requirements for inservice testing of pumps and valves. In addition, the inspector reviewed a recent operational event that led to concerns regarding the licensee's inservice testing of their power operated relief valves (PORVs). The review was conducted to verify the licensee's compliance with the inservice testing code, and with regulatory require-

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ments. The applicable code for the licensee's inservice testing is ASME Section XI (80 edition). The inspector's reviews and findings are described below: Procedures The inspector reviewed the test procedures for the valves listed below to verify that they provided proper criteria for stroke timing and checking position indicators for the listed valves:

Valves (Note: First number indicates Unit 1 or 2) Test Procedure

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INC36B, 32B and 34A (PORVs) PT/1/A/4151/03 1NC272AC (reactor vessel vent isolation) PT/1/A/4151/03 2NC368, 32B and 34A (PORVs) PT/2/A/4151/03 2NC272AC and 273AC (reactor vessel vent isolation) PT/2/A/4151/03 4-2NC36B and 54A (Nitrogen to pressurizer PT/2/A/4151/02 relief tank isolation)

2NC563 (pressurizer relief tank isolation) PT/2/A/4151/02

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2NC568 (Pressurizer relief tank isolation) PT/2/A/4151/02 In reviewing the procedures the inspector found that the stroke timing was performed from limit switch to limit switch, thus omitting the portion of the valve stroke cycle between the actuation and the first limit switc This represents nonconformance with the requirements of l ASME Section XI, Subarticle IWV-3413(a), which requires the time to be measured from initiation of the actuating signal to the end of the actuating cycle. The licensee stated that they had requested the NRC to grant them relief from the code requirement and to permit them to measure stroke time from limit switch to limit switch. They stated

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that they had submitted the request three years previously as part of f their pump and valve test program and that, although they had comeini-i cations with NRC reviewers regarding the program, no one had ever t

questioned the requested relief. The NRC inspector noted that the i licensee had already recognized problems with performing the timing between limit switches (see 6.d. below) and questioned why the licensee r

had not changed their procedures. The inspector was informed that the l' need for a change was under evaluation and that test personnel had i recently been requested to perform the stroke timing from actuation to final limit switch whenever a valve underwent maintenance. The inspec-tor informed the licensee the that adequacy of their stroke timing i

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would be reviewed with NRC personnel responsible for evaluation of the i

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1 l - involved relief . request and that the pending ' completion of the review it would be identified as Unresolved Item 369,370/86-26-04, Method of I

Stroke Timing.-

b .~ Records

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The inspector reviewed the records for the below listed valves to

, verify proper testing frequency and analysis of results: <

Valves Test Period Record Source

INC368,32B and 34A' 11/14/83 - 3/26/86 Data Sheet

. 1NC272AC and 273AC 11/14/83 - 3/26/86 Data Sheet 2NC368- 4/27/85 - 6/4/86 Data Base  ;

2NC538,54A and 56B 4/26/85 - 8/6/86 Data Sheet The inspector observed that, while the maximum stroke times specified .

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by the -licensee for valves INC272AC and 273AC was 60 seconds, these

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valves normally stroked in less than one second. The inspector ques-tioned whether such a stroke time was a suitable limit since it failed I to recognize that much smaller stroke times would-be indicative of-

. imminent valve failure. The inspector stated that this matter would be reviewed further by Region II and that pending completion of the review j it would be identified as Inspector Followup Item 369,-370/86-26-03, Basis for Setting Maximum Stroke Time . Relief Requests

! Because .of his concern regarding the licensee's use of the relief request regarding stroke-timing of valves, the inspector examined the

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licensee's other general pump and valve relief requests to determine if ,

any appeared clearly unsatisfactory. The inspector found that the

licensee had requested relief from code requirements on the accuracy of vibration measurements. The licensee's relief request states that their hand held instruments cannot meet code accuracy requirements of

5%, that they are only capable of 111%. Based on his experience the

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inspector believes that, with proper calibration, the licensee's  :

• instruments are capable of meeting the code accuracy requirements. The inspector informed the licensee that he was concerned that this and

other simple relief requests should receive quick NRC action. He '

stated that he would contact the NRC reviewers to determine if prompt replies could be obtained. This matter was identified as Inspector Followup Item 369,370/86-26-05, NRC replies to relief requests..

7 Event Involving Degraded PORV Stroke Time i The inspector reviewed the licensee's analysis and followup actions

with regard to an event in which some of the licensee's Unit 2 PORVs L failed to open as intended. This review was conducted to verify that i the licensee had taken appropriate corrective action and to further evaluate the licensee's testing of their PORVs.

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As understood by the inspector, the event occurred on July 22, 1986, and consisted of a load rejection transient during which two of three PORVs failed to open as intended. Considering the pressure reached and the duration, all~ three PORVs should have opened. One of the valves completely failed to open and another did not fully; open. The third did fully open. The reactor tripped on high pressurizer pressure and there was no further pressure increase beyond the trip setpoint. In examining the event the licensee found that the PORVs were closing ,

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significantly slower than indicated by. their manually actuated stroke i time tests. This was because their limit switch to limit method of i stroke timing omitted two significant portions of the stroke cycle.

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One portion was the time between the test manual actuation and valve

< movement to the first limit switch and the other was an approximate two second time delay included in the automatic actuation circuit to prevent actuations from spurious signals. The licensee's procedure for-stroke timing the PORVs specified a maximum opening stroke time of two seconds. The stroke time of the PORV that completely failed to open i during the transient (valve 2NC328) was measured from manual actuation to final limit switch and was 4.2 seconds. Previous measurements, from limit switch to limit switch, had resulted in stroke times of under two

second Based on the failure of 2NC32B to open during the load rejection transient and on the 4.2 second measured stroke time which

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exceeded the specified two second maximum, the licensee initially declared 2NC32B inoperabl Technical Specification (TS) 3. requires that each PORV be operable in Modes 1 thru 3. If a PORV is inoperable the TS Action statement requires:

f l With one or more PORVs inoperable, within one hour either restore

the PORV(s) to OPERABLE status or close the associated block

! valve (s) and remove power from the block valve (s); otherwise, be

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in at least HOT STANDBY within the next six hours and in COLD j SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

! The licensee's engineers evaluated the valve operability and concluded i that, as no credit was taken for the PORVs in Modes 1 thru 5 at reactor j coolant temperatures above 180 , excessive stroke time did not repre-

, sent PORV inoperability under these conditions.

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The NRC inspector was concerned that the licensee's engineering determi-nation might be incorrect. The TS 3.4.4 bases stated that the func-tions of the PORVs were to " relieve RCS pressure during all design transients" and to " minimize the undesirable opening of the spring

! loaded pressurizer code safety valves". It appeared to the inspector I that the PORVs that exhibited the slow stroke times during the load l reject transient could not perform the stated functions and that they I should be considered inoperable. The inspector also noted, however,

!- that it might be undesirable to determine the PORVs inoperable on the d basis of slow stroke times since, in accordance with the TS Action i statement, their block valves would be closed and any aid they might

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provide in relieving pressure during transients (to avoid safety

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.. f valve's opening or to preclude unnecessary reactor trips) would be negate In reviewing this matter the inspector questioned the test engineer as to whether the PORV block valves were stroke timed in their ASME Section XI pump and valve test program. The engineer stated that they were no The inspector informed the licensee that he would review the matter of the acceptability of the slow PORV stroke times and the omission of block valve stroke timing with NRC management. He informed the licen-see that this would be identified as Inspector Followup Item 369, 370/86-26-02, Testing of Power Operated Relief Valves and Block Valve Within the areas examined, no violations or deviations identified were

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identifie . Inspector Followup Items (IFIs) (92701)

(Closed) IFI (369, 370/86-14-02): Designation of Effective Code for the Nuclear Service Water Syste This item was open to identify an inspector's concern that the licensee had not clearly designated the code to be used for repairs on the Nuclear Service Cooling Water System. During the current inspection the NRC inspec-tor verified that the licensee had revised their specification to specify the code to be used. This matter is considered closed.

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