IR 05000416/1986029

Insp Rept 50-416/86-29 on 860915-19.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Actions & Inservice Insp & Testing of Pumps & Valves

ML20197A779
Person / Time
Site:	Grand Gulf
Issue date:	10/17/1986
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20197A751	List: IR 05000416/1986029 ML20197A746
References
50-416-86-29, NUDOCS 8610270390
Download: ML20197A779 (9)

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p reto UNITE 3 STATES '

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,, NUCLEAR REGULATORY COMMISSION

[ REGION 88 . . , ,

g j < 101 MARIETTA STREET, * 2 ATLANTA, GEORGI A 30323 i

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• . ** s Report No.: 50-416/86-29-

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l Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted: September 15-19, 1986 Inspector: .

. / ([N Date Signed Approved by: .

/O 7 6 d. aRe, Section Chief Dite' Signed gi ering Branch iv ion of Reactor Safety

SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of licensee action on previous enforcement matters, inservice inspection, inservice testing of pumps and valves, license condition 2.c(20), and inspector followup item Results: No violations or deviations were identified.

8610270390 861021

{DR ADOCK 05000416 PDR

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REPORT DETAILS Persons Contacted

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Licensee Employees I

• E. Cross, Site Director

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• C. R. Hutchinson, General Manager c *R. F. Rogers,. Unit 1 Project Manager

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• L. F. Daughtery, Compliance Superintendent

• W. C. Eiff, Principal Quality Engineer

, *J. D. Bailey, Compliance Coordinator R. A. Courtney, QA Supervisor, Inservice Inspection C. M. Renfroe, Inservice Inspection Coordinator R. S. Lewis, Senior Quality Representative M. Meier, Engineer C. Abbott, QA Supervisor, Inspections A. J. Malone, Inservice Testing Coordinator-D. G. Cupstid, Technical Support Superintendent

• A. Toney, Technical Support Engineer Other Organizations J. Marshall, Standby Service Water Project Coordinator, Bechtel i NRC Resident Inspectors

• R. C. Butcher, Senior Resident Inspector

• F. Smith, Resident Inspector

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• Attended exit interview Exit Interview l The inspection scope and findings were summarized on September 19, 1986,

' with those persons indicated in paragraph- above. The inspector oescribed t

the areas . inspected and discussed in detail the inspection findings. No

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dissenting comments were received from the licensee. The following new items were identified during this inspection.

I Unresolved Item 416/86-29-01, Pump and Valve Testing Criteria, l paragraph 6.b(5). r

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! Inspector Followup Item 416/86-29-02, Standby Service Water System i Loop-A Modifications, paragraph 7.

The licensee did not identify as proprietary any of the materials provided l to or reviewed by the inspector during this inspection.

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2 Licensee Action on Previous Enforcement Matters (Closed) Violation (416/85-38-01): Individuals Performing Inspection Same as Those Performing Activities Being Inspecte The licensee's letter of response, dated December 10, 1985, has been reviewed and determined to be acceptable by Region II. The inspector held discussions with the licensee's representatives and examined the corrective actions stated in the letter of response. The inspector concluded that the licensee had determined the full extent of the subject violation, performed the aecessary survey and followup actions to correct the present conditions and taken the corrective action necessary to prevent recurrence of similar circumstances. The corrective actions identified in the letter of response have been implemente . Unresolved Items Unresolved items are matters about which more information is required to determine whether they tre acceptable or may involve violations or deviations. An unresolved item identified during this inspection is discussed in paragraph 6.b.(5). Inservice Inspection (73051, 73052)

The inspector examined selected aspects of the licensee's inservice inspec-tion (ISI) program and procedures to identify responsible personnel and controlling documentation and to assess the licensee's compliance with regulatory requirements and the applicable code. The applicable code, based on the licensee's commercial operation date (July 1,1985) and their NRC reviewed Ten-Year Inservice Inspection Program, is ASME Section XI (77S79). Program (1) The inspector determined the licensee's assignment of personnel responsibilities to be as follows:

(a) Preparation of ISI program - Nuclear Plant Engineering, Material Science, Senior Quality Representative (b) Preparation of ISI plan for outage - Plant Maintenance and Construction, ISI Coordinator (c) Performance or Supervision of ISI Nondestructive Examinations - Quality Assurance, ISI/NDE QA Supervisor Visual Examinations - Quality Assurance, Inspections QA Supervisor

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(d) Performance of audits - Middle South Utilities

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(2) The inspector determined that the licensee's 10-Year ISI Program (including associated relief requests) had been evaluated by the NR The evaluation is described in a letter from W. R. Butler (NRC) to 0. D. Kingsley (Mississippi Power ~ and Light Company),

dated July 22, 198 Procedures (1) The inspector reviewed the following ISI visual examination procedures:

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Procedure QAP 10.81, VT-1, Visual Examination (RI) (with interim changes, dated 8/22/86)

- Procedure QAP 10.82, VT-3, Visual Examination (R2)

The above procedures were reviewed relative to the following:

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Requirements specified in accordance with ISI program commit-ments

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Personnel qualification requirements

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Evaluation and recording requirements

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Technical content including method application how performed type of surface condition

~* surface preparation type of viewing -

examination sequence acceptance criteria report form (2) The inspector identified the procedures through which the Outage ISI plan is implemented:

- Administrative Procedure 01-S-07-01, Control of Work j -

Administrative Procedure 01-S-01-226, Preparation, Control i and Use of Work Instructions and Inspection Records

The ISI coordinator informed'the inspector that the above proce-dures described the process that was used to transmit requests for i performance of ISI and to receive confirmation of ISI performance.

! Within the areas examined, no violations or deviations were identified.

> Inservice Testing of Pumps and Valves (61700, 61725)

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The inspector examined selected aspects of the-licensee's inservice testing (IST) program and procedures for pumps and valves to identify responsible personnel and controlling documentation and to assess the licensee's

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i- compliance with regulatory requirements and the applicable code. The appli-

,' cable code, based on the licensee's commercial operation date and their

Inservice Testing Program, is ASME Section XI (80W80).  ; Program (1) The inspector determined the licensee's ' assignment of personnel responsibilities to be as follows

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l (a) Preparation of ISI Program - Nuclear Plant Engineering,

Mechanical Systems, Engineer

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(b) Preparation and Performance of Procedures

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Leak testing by Plant Maintenance, Mechanical Mainte-nance Section

- Other tests by Plant Operations Staff (c) Engineering Evaluation of Results - Plant Maintenance, Mechanical Engineering Section, ISI Coordinator (d) Scheduling Tests - Technical Support, Technical Engineering

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(2) The inspector examined the licensee's relief requests to determine

if any appeared clearly inadequately justified. The licensee had submitted the requests for NRC evaluation (as part of their ISI j program) but had not received a NRC safety evaluation of the

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submittal as ye !

l Procedures

! (1) Based on discussions with the ISI coordinator, the inspector

! identified the following procedures which implement general

program requirements:

(a) Preparation and review of test procedures - 01-S-06-012 (b) Scheduling - 01-S-06-012, 01-S-07-01 and Technical Section Procedure 09-S-05-8 (c) Calibration of test equipment - 01-S-07-003 (d) Nonconformance - 01-S-03-003 (e) Discrepancies in procedure - 01-S-03-002

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(2) The inspector identified and reviewed the test procedures for the valves listed below to verify that they provided proper criteria for exercising and verifying the functioning of position indicators:

Valves Test Procedure E21F006 (Low Pressure Core Spray 06-0P-1E-21--0004 (LPCS) pressure isolation testable checkvalve)

E22F015 (High Pressure Core Spray -06-0P-1E22-Q-0002 (HPCS) suction isolation valve from suppression pool)

E22F001(HPCSsuctionisolationvalve 06-0P-1E22-Q-0002 from condensate storage tank)

E21F011 (LPCS discharge minimum flow 06-0P-1E21-Q-0002 valve)

(3) The inspector verified that the licensee had specified proper leak testing and leakage acceptance criteria for valve E21F006. The testing was verified in procedure 06-ME-1M61-V-00 (4) The inspector identified and reviewed the test procedures for the pumps listed below to verify that they provided proper test frequency, test parameters, and limits:

Pumps Test Procedure HPCS pump 06-0P-1E22-Q-0005 Standby Liquid Control pumps 06-0P-1C41-M-0001 (5) In reviewing the above, the inspector identified the following concerns with regard to the licensee's program and procedures:

(a) ASME Section XI required periodic inservice testing of pump For the testing, ' reference values of specified test para-meters, such as flow and differential pressure, are deter-mined when a pump and its associated equipment are known to be functioning acceptably. Using these reference valuu and multiplication factors given in ASME Section XI Table IkP-3100-2, allowable ranges of test values are determined and used to assess the results of the subsequent perirdic tests on the pum Table IWP-3100-2 specifies high anu low alert and required action ranges for the tests result If test results fall in the alert range the test frequency is required to be doubled. If they fall in the required action range, the associated pump must be declared inoperable until the cause is determined and the condition correcte .

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The high alert ranges for flow and differential pressure are specified as 1.02 to 1.03 times their respective reference value The high required action ranges for flow and differential pressure are specified as greater than 1.03 times their respective reference values. The licensee has modified these range limits for flow and differential pressure results determined for their pumps. In place of 1.02, they use 1.05 and in place of 1.03, they use 1.0 They have requested these changes in a relief request to the NRC and give as their basis:

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" Pump testing is performed with 2% accurate instrumentation, but the high valve Alert Range is only 102 to 103% and the Required r Action Range is greater than 103%. As pump

. failures that include increasing flow or discharge pressure as part of their indi-cations are very rare, the very narrow ranges allowed are unrealistic."

ASME Section XI, IWP-3210, permits the licensee to alter the ranges specified in Table IWP-3100-2 provided that the

specified ranges cannot be met and the revised ranges are such that the pumps may still fulfill their function. Based on his discussions with the licensee, the inspector believes that the IWP-3100-2 ranges can readily be met by many of the licensee's pumps and increased range limits may not be fully justifie The inspector is concerned that permitting increased limits would allow abnormal test results to 90 unrecognize (b) The inspector noted that the licensee's IST program did not include exercise tests for Residual Heat Removal system valves F094, 69 and 98. These valves are used to flood the containment from the Standby Service Water system for long term accident recovery. ASME Section XI requires exercising of valves that are required to change position to perform a specific function in shutting down the reactor to the cold shutdown condition or in mitigating the consequences of an accident. The inspector was concerned that these valves appeared to be intended to mitigate the consequences of an accident but that they were not being exercised as require (c) The inspector was unable to determine if the licensee had implemented procedures to verify proper functioning of valve position indicators on their remote shutdown pane The

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inspector asked the licensee to provide information to show that this verification was performed as required by ASME Section XI, IWV-330 (d) The inspector was unable to determine if the licensee's exercising of testable check valves full-stroked the valves as required by ASME Section XI, IWV-352 The inspector asked the licensee to provide information justifying the adequacy of their exercising of these valves in a subsequent inspectio The inapector's concerns with regard to the licensee's inservice testu g described in (a) thru (d)~ above was identified as Unresolved Item 416/86-29-01: Pump and Valve Testing Criteri Within the areas examined, no violations or deviations were identifie . LicenseCondition2.c(20)

Operating License Section 2.c(20), addressing concerns described in the Safety Evaluation Report, required modification of the Standby Service Water (SSW) system to assure the adequacy of its cooling capabilities. The inspector examined the licensee's modification work on the system to verify that the required modifications were being completed in accordance with the license condition and other regulatory requirements. The planned changes are described in the licensee's Design Change Package (DCP) 82/5020-1, approved 03/01/8 During the inspection covered in this NRC Report, the licensee's work on the SSW system was still in progress. To assess the licensee's work the inspec-j tor observed selected in-process work and records to verify the following: Personnel installing pump column bolting were knowledgeable of require-ments and were working to approved instructions complying with DCP 82/5020- The grade of bolting specified by the DCP was being installed in the pump columns (verified from observation of the manufacturer's identifi-cation on the bolts being installed). Torque values specified in the instructions for the above bolting were in accordance with DCP 82/5020-1 (verified from examination of the installationinstruction). Proper documentation and quality of welding performed for weld 501 150 AQS-P41-6010C11, SSW pipe support to pipe weld (verified by observing the welding and documentation). Relief valve installed at SSW pump in accordance with DCP 82/5020-1 (verified by observing installed valve).

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- ASME Section III, Class 2 globe valve installed as replacement for '

butterfly valve QAP41-F002A (verified by observing valve).

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The licensee's completion of this license condition will be verified in subsequent inspection and is identified as Inspector Followup Item 416/86-29-02, Standby Service Water System Loop A Modification Within the areas examined, no violations or deviations were identifie . Inspector Followup Items (IFIs) (55050) (0 pen) IFI (416/85-05-01): Clarification of Responsibilities for Coordination of Closing of Open Item The licensee informed the inspector that they were unable to provide information needed to close this ite (Closed) IFI (416/85-32-01): Issue of WPS Qualification Procedur This item was opened for inspector verification that the licensee had issued a procedure covering details of WPS qualification. During the current inspection, the inspector examined issued procedures covering the WPS qualification. The matter is considered closed, i

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