IR 05000369/1987016

Insp Repts 50-369/87-16 & 50-370/87-16 on 870511-15.No Violations or Deviations Noted.Major Areas Inspected: Inservice Insp,Including Licensee Action on Previous Enforcement Matters & Nonroutine Event Repts

ML20215M102
Person / Time
Site:	Mcguire, McGuire
Issue date:	06/05/1987
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215M080	List: IR 05000369/1987016 ML20215M077
References
50-369-87-16, 50-370-87-16, NUDOCS 8706260275
Download: ML20215M102 (13)

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T n i D UMITED SVATES

[a Ric 'o NkfCLE'dR REGULATORY COMMISSION l

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e REGION lt

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• '- ,'s j 101 MARIETT A STREET, ATLANTA. GEORGI A 30323

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i Report Nos.: 50-369/87-16 and 50-370/87-16 '

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Licensee: Duke Power Company 1

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422 South Church Street Charlotte, NC 28242 ,

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50 369 and 50-370 License Nos.: NPF-9 and NPF-17 fi Facility Name: McGuire 1 and 2 '

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Inspection nd ed 1 -15, 1987 ,

Inspectort

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h[O Date Signed

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Approved by: ,e L-

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J. J. Elake, Section Chief g Date Signed E gipdering Branch t,

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iv2sion of Reactor Safety ,

I SUMMARY j i

Scope: This routine, announced inspection conducted was] in the areas of inservice inspection. licensee action on previous enforcement matters,

nonroutine event reports and inspector fot'lowup item

Results: No violations or deviations were identifie , '

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REPORT DETAILS i l

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i i Persons Contacted Licensee Employees i

• D. J. Rains, Acting Plant Manager l

• B. Hamilton, Superintendent of Technical Service i

• R. P. Ruth, Senior QA Engineer

• A. F. Batts, QA Technical Support Supervisor

• E. O. McCraw, Compliance Engineer l T. Troutman, Inservice Inspection (ISI) Coordinator '

• R. A Johansen, Performance Engineer

• N. Atherton,' Compliance

• W. H. Taylor, Civil Supervisor of Design Engineering D. N. Smith, Performance Test Engineer P. McHale, Maintenance Training Director W. E. Smith, Production Specialist, Mechanical Maintenance ,

D. Stump, Production Specialist, Mechanical Technical Support  !

T. Love, Design Engineer - Valve Group S. Lanning, Senior QA Specialist Other Organizations R. Patterson, ISI Coordination, Babcock and Wilcox R. Rawlings, Quality Control Specialist, Babcock and Wilcox NRC Resident Inspectors '!

• Orders, Senior Resident Inspector

• Gunther, Resident Inspector i

• Attended exit interview ' Exit Interview The inspection scope and findings were summarized on May 15, 1987, with i those persons indicated in paragraph 1 above. The insaector described the areas inspected and discussed in detail the inspection finding He expressed concern that the licensee had not provided information needed to resolve four previously identified ~ items, even though the inspector's

)lans to ins,pect the items had been announced to the licensee the week 3efore the inspection began. (Items 2.d '~ thru g celow identify this concer No dissenting comments were received from the license The

.following new items were identified during this inspectio '

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I Unresolved Item 369, 370/87-16-01-. ISI Program Requirements for PORVs and Block Valves, paragraph Unresolved Item 369, 370/87-16-02, Bases for Setting Maximum Stroke Times, paragraph Inspector Followup Item 369, 570/87-16-03, Method of Stroke Timing, paragraph Unresolved Item 369/87-16-04, Records for Improper Structural Restraints per LOCA Load Mismatch, paragraph 6.b(1). ) Unresolved Item Records for Incorrect Design of Bellows 369/87-16-05,ints Penetration Structural Restra and LOCA Restraints on Small Piping Inside Containment, paragraph 6.b(2). Unresolved Item 369/87-16-06, Records for RVLIS Penetrations Not I Installed to Safety Related QA nor Traceable Materials, paragraph ' Unresolved Item 370/87-16-07, Records for Piping Dynamic Response Following Loss of Electrical Load Test paragraph The licensee did not identify as pr,oprietary any of the material provided I to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters (Closed) Violation (369, 370/86-14-01): Instruments and material used for the qualification of special process shot peening procedure and personnel not identifie This violation involved the licensee's failure to identify the instruments and material used in qualifying a special process (shot peening) and in qualifying personnel to perform the special proces The licensee's letter of response to the violation dated Janaury 16, 1987, has been reviewed and determined acceptchle by Region I The inspector held discussions with the licensee's representatives and examined' the corrective actions as stated in the letter of respons The inspector concluded that the licensee had determined the full extent of the subject' violation, performed the necessary followup actions to correct the conditions present, and developed the necessary corrective actions to preclude recurrence of similar 4 circumstances. The corrective actiora identified in the letter of response have been implemente I

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a 3 s I (Closed) Violation (369, 370/66-26-01): Inadequate Corrective I Action This violation involved the licensee's failure to assure that corrective actions for previously omitted valve test requirements were properly implemented. The licensee's letter of response to the violation dated December 26, 1986, has been reviewed and determined I acceptable by Region I l l

The inspector held discussions with the responsible licensee Performance Test Engineer and examined the corrective actions stated in the letter of response. The insp'ector concluded that the licensee l had determined the full extent of the subject violation, performed I the necessary followup actions to correct the conditions present, and 4 developed the necessary corrective actions to preclude recurrence of i similar circumstances. The corrective actions identified in the l letter of response have been implemente j (Closed) Unresolved Item (369, 370/86-26-04): Method of Stroke 4 Timin l This unresolved item identified a NRC inspector's concern that the licensee was not stroke timing valves in accordance with the requirements of the applicable code, ASME Section XI (80W80). The licensee was using an alternate method which omitted the start of the ;

stroke and they had requested NRC approval of the alternate. This i request had not been acted on by the NRC and the inspector noted that ,

in the case of power operated relief valves (PORVs) the licensee had ;

found that their alternate testing method had resulted in 'a failure to detect excessive stroke time The inspector reviewed this item with the licensee's cognizant Performance Test Engineer during the current inspection and found-that the licensee was in the process of correcting their procedures to revert to a timing method meeting the code requirements. The revised method appeared to provide very accurate and technically superior timing. The inspector considers that these changes will resolve the original concern. The unresolved item is considered closed. The licensee's completion of their . implementation of the,-

revised stroke timing method will be identified as inspector followup item 369, 370/87-16-03; Revised Method of Stroke Timin (0 pen) Unresolved Item (369, 370/86-26-08): Written criteria for evaluation of erratic valve actio This unresolved item identified the NRC inspector.'s concern that the licensee's procedures for determining the acceptability of valve stroke times did not include written criteria or guidance for determining when a valve was performing erratically or abnormally or

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I how such conditions should be reported. ASME Section XI (80W80),

IWV-3417, requires reporting of erratic or abnormal stroke times and, in response to a previous NRC violationi the licensee had prepared and placed in use a computerized comparison of valve stroke times- J that facilitates detection of abnormal or erratic stroke time However, the licensee did not pre)are any written description of by whom or how the computerized data aase would be use In the current inspection, the NRC inspector questioned the cognizant Performance Test Engineer as to what had been done to resolve this j matter. The inspector was informed that the matter was still under !

consideration, but that they had not as yet determined an appropriate j means of incorporating such requirements and of defining " erratic or j abnormal" stroke time behavior. The inspector noted that licensee-personnel were using the computerized stroke time comparison and-it 4 appeared that the individuals were knowledgeable enough to identify i erratic or abnormal behavior. Thus, there did not appear to be any immediate safety concern. This item will remain open for further licensee and NRC review and actio ] (Closed) Unresolved Item (369/86-11-01): RVLIS penetrations not installed to safety-related QA nor traceable material This item 4 expressed concern with regard to apparently unsatisfactory conditions i that had been identified by the license A licensee Quality I Assurance (QA) review had revealed that the Reactor Vessel Level i Indication System (RVLIS) was not installed under the pro)er QA program in that tubing connecting to the containment pene; ration fitting was not ASME Code material and had no traceability. The above problems were reported on Incident Investigation Report No.1-84-13 and 2-84-13 and Licensee Event Report (LER) No. 84-0 The system drawings for above tubing indicated that the entire' system was QA condition one, which required that the tubing material should be safety-related with traceabilit Unresolved item 86-11-01 was identified because of concerns

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re arding the adequacy of the licensee corrective action for these de iciencie The licensee was contacted by the NRC inspector prior to the current inspection and was requested to assemble the information needed to resolve this item. The licensee provided Licensee Event Report (LER)

84-09 and indicated that the corrective action was included in the LE The LER. stated that ASME material was not required for above tubing based on ASME NA-1130, paragraph c. NA-1130, paragraph c states that the rules of this section do not-apply to instruments or permanently sealed fluid-filled tubing systems furnished with instruments as temparature pressure responsive device The tubing used for RVLIS is not the permanently sealed fluid-filled tubing furnished with

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l instruments. Therefore, the inspector finds that the tubing can not be exempted from the ASME Code requirements. Although the licensee had been informed of the inspcctor's intention to inspect this item i prior to the inspection, no significant records or information l related to the corrective action for the item were provided other than the LE The inspector informed the licensee that their failure to provide more adequate su,paorting records or information for their corrective action would be 1centified as unresolved item 369/87-16-06, Records for RVLIS Penetrations Not Installed to Safety-Related QA Nor- 3 Traceable Materials. The original unresolved item 84-11-01 is considered closed. The licensee's failure to provide additional data {q supportinc their corrective action.and the adeguacy of the corrective j action wi'l be addressed in Region II inspection of unresolved item j 369/87-16-06.

4. Unresolved Items Unresolved items are matter.s about which more information is required to determine whether they are acceptable or may involve violations or deviations. Six unresolved items identified during this inspection are j discussed in paragraphs 3.e, 6.b, 7.b, 7.c and I 5. InserviceInspection(Unit 2) J The NRC inspector examined selected aspects of the licensee's inservice inspection (ISI) to determine its compliance with licensee commitments and i NRC requirements including ISI code requirements. The ISI code applicable i

to the licensee s current examinations is ASME Section XI (80W80).

Details of the inspector's examinations are described belo ReviewofProcedures(73052)

In a letter to the NRC dated November 5, 1984 the licensee committed to perform special augmented ISI examinations, of special accumulator injection line welds. The licensee stated that they would perform ultrasonic (UT)andpenetrant(PT).examinationsonthespecifiedwelds with the accumulator injection system depressurized and that the examination techniques used would be " modern inspection techniques developed in recent years for detection of intergranular stress Corr 0Slon Cracking."

During the current inspection the licensee performed examinations on two of the welds involved in the liunsee's commitment, ' welds-2NCFW-16-1 and 16- The NRC inspector reviewed the licensee s UT

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procedure ISI-125R5, which was used for the examinations. The inspector reviewed the procedure to determine that it was properly ,

approved and tha (1) Requirements were in accordance with the licensee's commitment (2) Examiner qualification requirements were correctly sprifie ,

(3) Recording, evaluating and reporting requirements were correctly specifie (4) The technical content was adequat l l Observation of Work and Work Activities (73753)

The inspector observed the UT examinations of welds 2NCFW-16-1 and 16-3-(referred to in 5.a above) and reviewed the qualifications of the examination personnel to determine that:

I (1) Qualification and certification records contained all l information necessary to verify that the examiners were properly '

qualified for the examinations performe (2) Approved procedure was available during the ' examinations, was being followed and the specified equipment was being use l (3) The examination personnel were knowledgeable of the examination method and the operation of the UT equipmen (4) Examination results were being properly recorded and evaluate l In addition, the inspector observed that calibration performed prior to UT examination of the accumulator 2A outlet nozzle weld to verify j that the calibration was being performed and recorded by properly qualified personnel, in accordance with the approved procedure and i the applicable code, Data Review and Evaluation (73755)  ;

The NRC inspector reviewed the records for the recently completed UT and PT examinations of welds 2NCFW-16-1 and 16-3 to determine that '

the contained or provided reference to:

(1) Examination results and data she.et (2) ' Examination equipment dat (3) Calibration data sheet (4) Examination evaluation dat (5) Records on extent of examinatio (6) Identification of NDE material such as penetrant, penetrant cleaner, couplant, et .

Within the areas examined, no violations or deviations were identifie . Nonroutine Event Reports (92700)

The NRC inspector reviewed four deficiencies reported for the McGuire site j in accordance with the requirements of 10 CFR 50.55e' and 10 CFR 21 and examined the adequacy of the licensee's corrective action 'i CFR 21 Deficiency Reports (1) (Closed) Item (369/P2185-05): Valve actuators on pressurizer PWR operated relief valves discovered with only one of two springs installed - valve will not fail closed on loss of air suppl This item was reported to the NRC by the manufacturer in a letter dated December 10, 1985. The title of the item (above)

describes the deficiency, which was detected on a valve supplied for the licensee's Catawba site. The licensee's corrective action for the McGuire site consisted of examinations that verified that their power operated relief valves contained both of the required springs. The NRC inspector reviewed the records (Maintenance Requests 57452 and 3 and 57174) of the licensee's examinations with cognizant maintenance personnel and determined 1 that the corrective actions had been complete (2) (Closed) Item (369/P2186-01): Atwood and Morrill main steam isolation valves spring failure - caused by quench crack '

This item was reported to the NRC by the valve manufacturer in a

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i letter dated June 6, 1986. The title of the item describes the -

deficiency, which was detected on valves provided for Detroit Edison's Enrico Fermi Unit 2. The licensee's corrective actions consisted of magnetic particle examinations of their valve springs to verify that they did not contain quench cracks. The inspector verified the licensee's completion of the examinations on Unit 1 valves thru separate discussions with the licensee'.s cognizant Valve Group Design Engineer and cognizant maintenance personnel. The examinations had not been conducted on the licensee's Unit 2 valve springs. However, the NRC inspector visually examined the Unit 2 springs and saw no evidence of cracking. This item is considered closed, CFR 50.55e Deficiency Reports (1) (Closed) Item (369/81-03-09): Improper Structural Restraints per LOCA Load Mismatc This concern came from the licensee's SD Sig/80-20 369 and 370/80-15nificant stated theDeficiency problems of(SD) Reports LOCA 369/80-20 not used in and 3 piping analysis, valve discharge load used improperly and

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support / restraint loads shown on design drawings mismatching

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8 piping analysis loads. The Significant Deficiency Reports indicated the total number of supports / restraints that required analytical review and possible revision was 1591 and the estimated number that might require some hardware change was 45 The inspector who conducted Inspection 81-03 reviewed the installation package for structural restraints which were '

installed on Mode 6 systems and affected by the reanalysi The i matter was left open for NRC review of other example I i

Prior to the current inspection the licensee was contacted and I requested to assemble the information needed for NRC completion ]

of review of this item. However, the licensee failed to provide 1 analysis packages or other significant data to the inspector J during the insaection. The inspector informed the licensee l rovide these . records would be l that their as identified fai'ure to promptly unresolved p/87-16-04, Records for Improper item 369  !

Structural Restraints per LOCA Load Mismatch. The original item ;

will be considered closed. The licensee's ability promptly-retrieve ana provide the records (analysis packages and other ,

data) associated with the original item and the adequacy of the l packages will be addressed by Region'II in subsequent review of i unresolved item 369/87-16-0 (2) (Closed) Item (369/81-03-10): Incorrect Design of Bellows i Penetration Structural Restraints and LOCA Restraints on Small l Piping Inside Containmen This matter concerns LOCA pressure effects that were not considered in piping analyses of lines penetrating containment through bellows-type cold penetrations. This was documented in the licensee's Significant Deficiency Reports 369/80-21 and 370/80-16. An evaluation of the pipe stresses, support / restrain locations and loads, and higher loads on penetration structures was required. Twenty six (26) piping analysis -math models required licensee reanalysis. An estimated eighty-two (82)

support / restraints required revision and hardware changes. -The licensee did not provide documents or information needed by the inspector for review of this ite ,

As with regard to Item 81-03-09 above, the licensee had been contacted prior to the inspection and requested to assemble the information needed for NRC review of the item. The inspector informed the licensee that their failure to promptly provide these records would be identified as unresolved' item 369/87-16-05, Records for Incorrect Design of Bellows Penetration Structural Restraints and LOCA Restraints on Small Piping Inside Containmen The original item will be considered closed. The licensee's ability to promptly. retrieve and provide the related

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records and the adequacy of those records in demonstrating their corrective action for their Significant Deficiency will be addressed by Region II in subsequent review of unresolved item 369/87-16-0 . ' Inspector Followup Items (IFIs) (92701) (Closed) IFI (369/86-14-03): Verification of snubber ' test by

qualified personne This item was opened to followup on a concern that (1) snubber test rocedure MP/0/A/7700/01 record sheets had no signature block'for a p' qualified" individual even though the procedure required the . test to

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be performed by qualified personnel and (2) snubber test procedure MP/0/A/7650/50 had no requirements -for personnel._ qualification During the. current inspection tne ' NRC inspector reviewed the .

procedures involved and discussed this matter with the Mechanical-Maintenance Technical Support Supervisor responsible for the testin The inspector found thatl test personnel. meeting the licensee's qualification requirements' had been and .were performing the test The inspector also checked 'that the individual responsible for recording the data on the test record had initialed the previous

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records and.could be identified as qualified. The inspector specifi-cally reviewed the latest revisions of the' test procedures (both approved May 6,1987) and verified that the test individual- who initialed the records for the following snubbers tests was qualified:

Snubber Test Date i

2MCR-S-NI-150-09-N-A 04/28/86-2MCR-S-NI-150-09-N-B 04/28/86 2MCH-S-KC-512-01-0 04/28/86-2MCH-RN-3002-A 04/28/86 2MCA-RN-3022-B 04/28/86 2MCA-CF-204A '04/16/86 2MCA-CF-2048 04/16/86 This matter is considered close (Closed) IFI (369, 370/86-26-02): Testing of power operated relief valves and block valve This item was opended to follow up on concerns as to-(1) whether the licensee had acted properly in not declaring-a power operated reliefo valve (PORV) inoperable' based on itsislow- . stroke time and (2) the licensee's failure'to include'their PORVs and block valves in the IST-progra In discussions with NRC : personnel ^ involved-in resolving generic issues, the inspector found that requirements regarding the'.

operability of PORVs are under review and may change and that the licensee's decision not to declare the slow PORV inoperable aapeared correct. On this basis, ' the concern 'in (1) abo've;is consicered close *

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With regard to the concern in (2), the inspector informed the licensee that it is the NRCs position that PORVs and block valves must be included in ISI programs. This position is stated on page 62 of the NRC Safety Evaluation Report issued for the licensee's Catawba facility in a letter dated January 8,1987. The inspector stat;d that the licensee should either implement the referenced position or otherwise resolve the position with responsible NRC management within six months. The original followup item is considered close Pending final resolution satisfactory to the NRC, the matter of inclusion of the PORVs and block valves in the IST program is now identified as unresolved item 369, 370/87-16-01, IST Program Requirement for PORVs and Block Valve c. (Closed) IFI (369, 370/86-26-03): Basis for setting maximum stroke !

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This item was opened for further review of the licensee's practices in setting maximum allowable stroke times for power operated valve The inspector had previously observed that the licensee set stroke timo maximums so high for some valves as to be meaningless. Valves that stroked in less than one second were assigned 60 second maximum stroke time The inspector discussed this matter with the licensees Performance Test Engineer, who informed the inspector that an Institute for Nuclear Power Operations (INP0) group that had since reviewed the IST program made a similar comment. The inspector informed the licensee of the NRC position on setting stroke times. A copy of the position is included as an attachment to this inspection report. The inspector stated that the licensee should either implement the referenced position or otherwise resolve the position with responsible NRC management within six month The original followup item is considered close Pending final to the NRC, this is now resolution identified asofunresolved the matter satisfactory item 369, 370 /87-16-02, Bases for Setting Stroke Time d. (Closed) IFI (369, 370/86-26-05): NRC replies to relief request This item was opened for the NRC inspector to followup on the status of the NRC review of the licensee's ISI program relief requests for McGuire. In informal discussions with the NRC reviewer responsible for the McGuire ISI program relief requests, the inspector was told that the review had not begun and that the review probably would not be completed in the near future. The inspector apprised the licensee of this status. This item is considered close l J

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11 (0 pen) IFI (369, 370/86-26-07): Large differences between stroke times of identical air actuated valve This item was opened to followup on . concerns that the disparity in stroke times between two apparently identical air operated valves appeared excessive. The NRC inspector discussed this matter with the licensee's cognizant Performance Test Engineer and was informed that maintenance requests had been issued-(but: not yet performed) for. the

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valves to be checked. A review of the requests found that they contained apparent errors that might result in the valves'being improperly checke The Performance Test Engineer ~ indicated that the'

requests would be corrected. This item will remain open pending NRC review of the licensee's actions in a subsequent inspection, (Closed). IFI (370/84-26-02): Piping dynamic response following loss of. electrical 1oad tes This matter concerns the licensee's retest of nine hangers found !

deficient in previous dynamic response testing conducted under '

procedure TP/2/A/1200/27A, Reinspection of Piping Dynamic Response Following Reactor Trip. This testing is required by. McGuire _FSAR

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Section 3.9.1.2, and was performed after a 95% or greater reactor ;

trip to verify that the piping system design for the Main Feedwater !

(CF) and Main Steam (SM) systems take into account dynamic effects

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due to rapid changes in temperature and' pressure. The. transient response of the piping is required to be within specified design limit The NRC followup item addressed 'herein was opened- for. NRC verification that TP/2/A/1200/27A testing was properly complete The inspector discussed the above testing with licensee's test engineer. He stated that test was completed with' deletion of support 2CF-H44 from test proc.edure TP/2/A/1200/27A (Revision 1). Support 2CF-H44 was excluded' from the test because this . support deformed and failed. The Design and Construction Departments tried to redesign and repair it unsuccessfully. The deformed support was allowed to remain in place to take some load during the last 17 months. This <

support was removed during this outage about two days before' this inspection. It will' be replaced with new' support at same locatio In a letter dated December 17, 1985,'the licensee notified Region II ;

of the completion of the test with an explanation of reasons for

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excluding . support 2CF-H44 from the test. ~ The reasons stated. were that the. support was not safety-related' no damage occurred' to

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adjacent hangers (adjacent spring can hangers safely absorbed the 1 additional loads), no damage occurred to feedwater heaters, downstream:

of the hanger, the hanger was included in the test' only to-force an ;

inspection of all the CF and SM pipe hangers 'and it:is-not required ~

for p~rocedure completion. Since the licensee'~s design engineer ,

provided neither the support calculations to justify the adequacy, o !

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the deformed support and adjacent supports nor the piping stress calculations to show that the exact location of this overlap of the safety-related area, the inspector could not accept the explanatio ;

Per FSAR Table 3.2.1-1 (sheet 1 of 2), Summary of Criteria - Structure all of the main steam and feedwater supports are safety-related supports with QA required. Therefore, the inspector considered it '

necessary that the licensee either justify the support calculations I or provide documentation demonstrating that the support is outside and r:ot within the overlap of the safety related area. If the letter is correct the licensee needs to revise FSAR to exclude-this support for the safety-related area. IFI 370/84-26-02 will be closed and an unresolved item will be opened to identify the licensee's failure of provide adequate documents or information to support their contentio The new unresolved item is identified as 370/87-16-07, Records for Piping Dynamic Response Following Loss of Electrical Load Test. The licensee s ability to promptly provide the required documents and information and the adequacy of the documents and information will be examined by the NRC in inspection of the unresolved ite )

ATTACHMENT:

NRC Correspondence dated April 11, 1985 from H. L. Thompson to R. L. Spessard i

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Ag UNITED STATES NUCLEAR REGULATORY COMMISSION '

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APR1$ 1985'

j Docket No.: 50-341 ATTACHMENT

i MEMORANDUM FOR: Richard L. Spessard, Director Division of Reactor Safety Region III FROM: Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation SUBJECT:

RESPONSE TO REQUEST FOR TECHNICAL ASSISTANCE REGARDING I MAXIMUM STROKE TIME TESTING FOR IST OF VALVES We have reviewed the information submitted in your request for technical ,

assistance dated November 14, 1984 testing of the maximum stroke

time as part of the in-service testing (ISTregarding) program at the Fenni-2(

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i Our basic position on this request is that the applicant has committed to comply with the requirements of the ASME Code and has'not requestod specific relief from the applicable portion of the ASME Code. Our response is directed ,

towards the third concern outlined in your letter (i.e., the acceptability of- 'j baseline-data established for valve testing in accordance with Section XI of (

the ASME Code) since the first two concerns were previously resolve l 1 Acceptability of Baseline Data Established for Valve Testing per Section XI i With respect to-the applicant's procedures for measuring valve stroke times, k

as described in your letter dated November 14, 1984, the staff' agrees that these procedures are not in accordance.with the requirements of Section XI, ,

Subsection IWV-3417 of the ASME Code (the Code). The use of such procedures would require prior written relief by the staff from.the specific requirements of the Cod The specific applicable Code requirements are:  !

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IWV-3417 Corrective Action

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(a) If, for power nperated valves, an increase in' stroke _ time of 25% or more from the previous test for valves with full-stroke times creater than 10 sec or 50% or more for valves with full-stroke times less than or equal to 10 see is observed, test frequency shall be increased to once each month until corrective action is taker., at which. time the original test' frequency shall be resumed. In any case, any abnormality or erratic action shall be reporte (Emphasis added).

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Contact: M. Lynch, 492-7050 ~

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.dTTACHhENT -2 R. t.. Spessard, Director - 2.-

APR l l 1965 (b) If a valve fails to exhibit the required change of valve stem or disk position or exceeds its specified. limiting value of full-stroke time by this. testing, then corrective action shall be initiated imediately. If the condition is not, or cannot be,. corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared inoperative. When corrective action is' requfred as a result of tests made during cold shutdown, the condition shall be corrected before startup. A retest showing acceptable operation shall be run following any required corrective action before the valve is returned to servic As cited above, each in-service test valve. stroke time is reqeired to be com-pared to the previous'in-service test valve stroke time and.is not related in-any way to.the design or purchase specification for a valve. Additionally, the staff does 'not . interpret a corrective action to be the acceptance of.the new stroke time measured on the first monthly test. .When a valve has exceeded this criterion on one in-service test, the monthly frequency must be maintained until maintenance is performed on the valve so that it will. not become . inoperabl It appears that the applicant's practice for' establishing maximum limitin stroke times for valves is also inconsistent with the staff's interpretation of.the Cod Subsection IWV is specifically a " component" test code and, therefore, requires that the owner specify the maximum limiting stroke' times for each power operated valve.(IWV-3413). It is the staff's position.that these limiting values of full stroke time are required to be based on reason-able engineering judgement of comoonent (valve) operabilify, not minimum system requirements. ~ System (or component) response time limitations, as stated'in

'Ufe'ajip'11 cant's FSAR or in the plant Technical Specifications, are also time limitations placed on each subcomponent of that system (or component).. How-ever, the staff's position is that these response. time limitations,should rarely take precedence over a component-oriented limiting valve stroke. tim Inasmuch as the IST program requirements become. applicable when Detroit Edison declares that the Fermi-2 facility has gone " commercial," you. should ~ bring this matter to its attention so that it can be properly resolve MI # d-Q Hugh L. Tho'mpson, 'Jr., Director y Division of Licensing i Office of Nuclear Reactor Regulation

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