IR 05000416/1989013

Insp Rept 50-416/89-13 on 890417-21.No Violations or Deviations Noted.Major Areas Inspected:Pump & Valve Inservice Testing,Ie Bulletin Followup & Followup on Previous Insp Findings

ML20244E087
Person / Time
Site:	Grand Gulf
Issue date:	06/05/1989
From:	Belisle G, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20244E080	List: IR 05000416/1989013 ML20244E079
References
50-416-89-13, IEB-85-003, IEB-85-3, IEB-88-004, IEB-88-4, NUDOCS 8906200140
Download: ML20244E087 (9)

Text

_ - _ _ _ _ _ _ ___ -. . , . - .- - - _ -

_

.

'

'

' ~

,1 c

, >

_

• '

,,  ;

, .

p r<sh ' UNITED STATES - t- 3

• b;o.- NUCLEAR REGULATORY COMMISSION

..'

f' 1

,

& - 'd REGION ll -

i

'gh 101 MARIETTA STREET, <

j* 4

/ ATLANTA, GEORGIA 30323 y

1%,e....g

,

.

p Report No.:. .50-416/89-13 Licensee: System Energy Resources, In Jackson, MS 39205~

~ Docket No.: '50-416 License No.'.: :NPF-29:

W

" Facility Name: Grand Gulf

[ Inspection Conducte : A ril 17-21, 1989

'

-

. Inspector: ,

.zes LY _a 4M M

- 5.' tin' gen ~

~~

' Date Signed

/ /

.e ' Approved' ty: - ////w #' CSD w

~

'

C.W.- BeTisle, C'hief ' Date Signed-Test Programs Section -

' Engineering Branch Division of Reactor Safety

.e SUMMARY Scope:

This routinec. unannounced inspection was conducted in the areas of pump and-valve inservice testing, IE Bulletin ' follow-up, and follow-up on previous inspection finding Results:

An unresolved item.was identified that involved licensee justification for not exercis.ing and stroke time testing valves quarterly, paragraph 2.a. A weakness

.was identified that involved staffing in the area of motor operated valve

' diagnostic testing, paragraphs 3.b. and 4.a.

r Within the areas inspected, no violations or deviations were identified.

ll

a

[,. ,

- G

.

_ - _ - - _ _ _ _ _ _ -

, - - - - - . - _

.

. _ _ _ - - _ - - _ _ .

.

-

v ,

*

.

REPORT DETAILS i Persons Contacted Licensee Employees

• W. Cade, Operations Coordinator

• L. Daughtery, Supervisor, Compliance

• Eiff, Principal Quality Engineer

• J. Reaves, Manager, Quality Systems

• J. Roberts, Manager, Performan:e and Systems Engineering

• J. Summers, Compliance Coordinator

• M. Wright, Manager, Plant Support

• J. Yelverton, Manager, Plant Operations Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, technicians, and administrative personne NRC Resident Inspectors

• H. Christensen, Senior Resident Inspector

• J. Mathis, Resident Inspector

• Attended exit interview Pump and Valve Inservice Testing (73756)

Power operated valve stroke time testing, pump testing, and safety relief valve (SRV) setpoint testing requirements are contained in the licensee's Inservice Test Program for pumps and valves. This program invokes requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Subsections IWP, Inservice Testing of Pumps in Nuclear Power Plants, and IWV, Inservice Testing of Valves in Nuclear Power Plant Power Operated Valve Stroke Time Testing The inspector reviewed stroke times obtained during quarterly or cold shutdown testing for the following motor operated valves (MOVs) from 1986 that were in the licensee's IE Bulletin 85-03, Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings program:

E22-F001 E22-F015 E51-F031 E51-F064 E22-F004 E22-F023 E51-F045 E51-F068 E22-F010 E51-F013 E51-F046 E51-F077 E22-F011 E51-F019 E51-F059 E51-F078 E22-F012 E51-F022 E51-F063 E51-C002-N

j

- . _ _ _ - _ _ . _ - _ _ _ _ - _ _ - _ - - _ _

mm a s N. MY ,

. (

,

', ,

,

,

r

, s

+ a .- 3

,

q'. ,

-

,'

3 l $ l W * ' y' \;

,

y ,

a'

' '

-

y 2 g

p% '

' The inspector reviu.ed stroke times obtained quarterly or'during cold

. shutdowns ' from .1986 for the - following air operated containment ,

isolation valves that were identified in. the Grand Gulf Technical l Specifications (TSs), Table 3.6.4-1:

,,

M41'-F011-(A) G36-F106-(B E61-F056-(B) E61-F020- B)

M41-F012-(B)- -G36-F101-(A =E61-F057-(A) M41-F015-A)

-M41-F034-(B) P45-F067-(B P11-F130- A)- M41-F013- B)

+ M41-F035-(A) P45-F068- A) - P11-F131- B)- M41-F016-(A).

P71-F150-(A) P45-F061- B)' P45-F098- B) M41-F017-(B)-

P71-F148-(A)- P45-F062- A) P45-F099- A) P45-F009-(A)

P71-F149-(B) P11-F075- A) P60-F009-A' P45-F010-(B)'. -

P52-F105-(A) E61-F009- A) P60-F010-B P45-F003-(A).

P53-F001-( A) - E61-F010- B) E61-F007-(A) P45-F004-(B);

Reviewing the MOV.and air operated valve stroke times ~ revealed the following:

~ Article IWV-3000 requires valves to be exercised and stroke timed at_least every three months. Where it is not practical to operate certain valves during plant operation, these valves are required to be exercised and stroke time tested during cold shutdowns. This article does not provide specific guidance for

'

determining when 'it is not practical to operate valves during plant operation other than they be' identified by the owner. The licensee's justification for not exercising and stroke time-testing certain valves during plant operation was that if a valve was located in an inaccessible area and failed during the test, than the system would have to be declared inoperabl This would ' require entry into a TS Limited Condition for Operation or create other conditions that would require a reactor shutdown to repair. Inaccessible areas were identified

<

by the licensee as the drywell and steam tunnel. Examples of licensee justifications for testing valves during cold shutdown in lieu of quarterly are as follows:

MOV E51-F064 is a normally open steam supply valve to the reactor core isolation cooiing (RCIC) turbine that is required to automatically shut on a containment isolation signal. The licensee justification for testing the valve during cold shutdown was that the valve is located in the steam tunnel which is inaccessible during power operatio Failure of the valve in the closed position would isolate the steam supply to the RCIC turbine and result in an inoperable RCIC syste Shutdown of the plant would be

/ required to repair the valv Valves F113 and F114 are normally open air operated gate valves that are required to shut in order to isolate the secondary containmen The licensee justification for testing these valves during cold shutdown, in lieu of p

L

_ - _ - - -- - _ ___

_

- - _

,

-

ll .

.

-

l 3 quarterly, was that the valves are located in the steam tunnel in the condensate drain line for the main steam header Failure of either valve in the closed position would decrease the condensate removal capacity, and valve repair would require a plant shutdow Reviewing the Itcensee's Inservice Test Program revealed at least 40 additional examples where primary and secondary containment isolation valves, located in the steam tunnel or drywell, were - being tested during cold shutdowns, in lieu of quarterly, with the justifications previously discussed. The licensee's position for testing valves during cold shutdown instead of quarterly is identified as Unresc1ved Item 50-416/

89-13-0 This will be referred to the Office of Nuclear Reactor Regulations (NRR).

Reviewing' valve stroke times indicated that velves were stroke tested per the licensee Inservice Test Program frequencie Failures were corrected and stroke time frequencies increased when require The inspector reviewed work orders and engineering evaluations generated in response to valve failures and increased stroke times and determined that adequate correction action was performe Reviewing the work histories associated with IE Bulletin 85-03 MOVs indicated that post-maintenance testing was being accomplished in accordance with Section XI postmaintenance test requirements. IE Bulletin 85-03, post maintenance testing is further discussed in paragraph b. Pump Testing The inspector reviewed the Inservice Test results of the low pressure core spray (LPCS) jockey pumps and standby service water (SSW) pumps A and B from 1986. LPCS jockey pump testing was performed quarterl This testing measured bearing shaft temperatures, vibration, and proper lubricatio Since instrumentation is not installed to measure pump inlet pressure, differential pressure, or flow, the licensee has submitted a Section XI relief request omitting these measurement SSW pumps A and B testing was performed quarterly, and measured inlet pressure before and after pump start, outlet pressure, differential pressure, flow rate, and vibratio The SSW pumps are water cooled therefore, bearing temperature was not verified. The licensee has submitted a Section XI relief request omitting bearing temperature measurements. The test data review indicated that pump failures had not occurred, nor were pump alert or action ranges exceede The inspector reviewed the applicable portions of Surveillance Procecures 06-0P-1E21-Q-006, Revision 21 LPCS Quarterly Functional Test; 06-0P-IP41-0-004, Pevision 27, SSW Loop A Pump Operability Test; and 06-0P-1P41-Q-005, Revision 27, SSW Loop B Pump Operability Test. These procedures clearly stated pump references, alert ranges

. . - _ - _ _ _ _ _ -

9 .,  !

.

-

i

.

and required action values. . These procedures also contained sign-offs that the test data was acceptabl Main Steam SRV Setpoint Testing The inspector reviewed Wyle Laboratories SRV setpoint test results, and verified licensee compliance with TS 4.0.5 which requires that SRVs be setpoint tested in accordance with Section XI of the ASME-Boiler and Pressure Vessel Code. Each refueling outage (RFO) all 20 SRVs are removed and sent to Wyle Laboratories to be setpoint teste The licensee has a complete set of spare SRVs that are installed each RF0. The SRVs removed during the present RF03 have not been setpoint tested. The inspector reviewed the following as-found results of th SRVs removed during RF02 in December 1987, and subsequently installed during the present RF0 Percent Fxceed Valve Serial TS Required As-Found Set Set Pressure Number Set Pressure (PSIG) Pressure (PSIG) Tolerance 160795 1165 1% ;.172 0 160801 1165 1% 1178 + t 1% 1174 0 160796 1165 1% 1172 0 160815 1165 1% 1157 0 160818 1165 i 1% 1190 + i 1% 1166 0 160838 1165 1% 1151 - % 1171 0 160808 1180 1% 1199 + % 1206 + i 1% 1191 0 160841 1180 1% 1187 0 160804 1180 1% 1160 - m 1% 1163 - .1% 1195 0 160813 1190 1% 1181 0 160829 1190 1% 1175 - % 1192 0 l 160844 1190 1% 1192 0 Within the areas inspected, no violations or deviations were identifie . IE Bulletin Follow-up (92703) (25573) IE Bulletin No. 88-04, Potential Safety-Related Pump Loss The inspector reviewed the licensee's response letter dated June 29, 1988, and determined that one of the IE Bulletin No. 88-04 required actions was not acceptably addressed. With the exception of SSW, the licensee did not obtain pump vendor approval of minimum flow rate _________ _-_-__- _ _ _ _ -

- - - - _ . _ _ _ _

.

..

.

~

This matter remains open pending verification from applicable pump suppliers that_ current miniflow rates are sufficient to ensure that there will be no pump damage from low flow operation or until clarification is obtained from NRR regarding requirement of vendo approva The licensee's reasons for not obtaining adequate verification of the current miniflow capacity by _the pump manufacturer is based on the Boiling Water Reactor (BWR) Owner's Group response to IE Bulletin 88-04 in that:

BWR operating experience does not indicate any excessive wear to pumps when operating under the current specified flow condition The total expected time in the minimum flow mode over the plant life is lo Past BWR operating history indicates no occurrences of system unavailability upon demand due to pump wear incurred in minimum flow operatio Recent inspection of some BWR residual heat removal pumps had indicated no pump impeller damage due to minimum flew that could potentially degrade pump performance over the inspection perio ASME Boiler and Pressure Vessel Code,Section XI, testing and Technical Specification surveillance requirements will detect changes in pump perfor:aance BWR safety-related pumps are supplied by different pump vendors. The responses contained in the BWR's Owners Group and the utility's June 29, 1988, letter to the NRC address pumps in general in regards to adequate minimum flow to preclude pump damage at low flow '

operation but does not address the utility's specific pumps. This matter is identified as inspector follow-up item (IFI) 89-13-0 IE Bulletin 85-03, Motor Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Setting (Closed) 85-90-03, T2515/73. The purpose of IE Bulletin 85-03 is to require licensees to develop and implement a program to ensure that switch settings for High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling system motor operated valves (MOVs)

subject to testing for operational readiness in accordance with 10 CFR 50.55a(g) are properly set, selected, and maintaine This Inspection Report supplements additional information contained in NRR Inspection Report Nos. 50-416/87-36 and 50-416/88-2 In order to further evaluate the licensee's IE Bulletin 85-03 program, the inspector held discussions with the appropriate licensee personnel and reviewed the following:

_ - - - _ _ _ _ _ _ - - _ __

_ _ _ _ _ _ _ _ -

.

- 6 l

. Procedure 07-S-12-62, Revision 6, Inspect and Clean Limitorque Valve Operators Procedure 07-S-12-81, Revision 6, Setting of Limitorque' Valve Operators Procedure 07-5-12-118, Revision 0, M0 VATS Testing of Limitorque MOVs Machinery history and material non-conformance reports from 1986 '

Letter from System Energy Resources, Inc. to NRC dated February 27, 1988, Grand Gulf. Nuclear Station IE Bulletin 85-03 Response Letter from System Energy Resources, Inc. to NRC dated June 1, 1988, Grand Gulf Nuclear Station IE Bulletin 85-03, Supplement 1 Response In letters -from System Energy Resources, Inc. to the NRC dated February 27, 1988, and June 1, 1988, the licensee reported that IE Bulletin 85-03 and Supplement I actions items were completed. . Review of the licensee's program indicated that instructions were adequate to set switches, maintain switch settings, and ensure MOVs are properly retested following maintenance. A requirement ~-of IE Bulletin 85-03 is to monitor valve performance to ensure switch settings are adequate throughout the life of the plant. The licensee plans to accomplish ' this requirement by accomplishing diagnostic testing on all IE Bulletin 85-03 valves in three year intervals but has not developed a program to do so. Until the licensee develops and implements a program to routinely monitor IE Bulletin' 85-03 valve performance, this will be followed as Inspector Follow-up Item 50-416/89-13-0 The licensee IE Bulletin 85-03 program is coordinated by one person who is responsible for determining all IE Bulletin 85-03 M0V post-maintenance test requirements and performing all diagnostic testin Since there are only 23 MOVs in the program, relying on one individual appears to be adequate to satisfy IE Bulletin 85-03 requirement However, the licensee has not expanded the IE Bulletin 85-03 scope to include other safety-related valve Recently, MOV RHR-E12-F003B, Residual Heat Removal Heat Exchanger Outlet Valve, stem to disk connection failed, resulting in damage that required the entire 18-inch valve to be replaced. This is a safety-related valve, but the ;icensee did not perfonn any type of diagnostic testing to ensure switch settings were correct or to verify that the actuator was not overthrusting following valve replacement. It appeared that the licensee MOV program is staffed only to diagnostic test IE Bulletin 85-03 MOVs. As a result, overall M0V program in general was different for bulletin and non-bulletin valves, yet all were safety-related.

-_ _ _ _ _ _

__ ._ ___ ._ - -- - ---_ _ _- -

.~

. .

Within the areas inspected, no violations or deviations were identifie ~ Follow-uponPreviousInspectionFinding(92701) In April 1989 the licensee ' identified that . valve RHR-E12-F003B, RHR B heat exchanger outlet valve, was damaged and required a complete replacemen This item is being followed by the resident inspector, however, the inspector also investigated the failure. While-stroke

. timing the valve in accordance with ASME Section XI valve exercising-

. requirements, local valve mechanical position indication ' indicated that the valve was not fully. closed. :The stroke time was-norma Because of this abnormality,. the . valve was disassembled and inspected. . The valve disassembly revealed that the stem was

~

separated from the disk, the disk was laying cocked in the valve seat, the valve seating area had several cracks,.and that tne valv stem was bent. The-stem is secured to the disk.with a nut which.was found' laying in the valve body. The valve is.at 18-inch globe valv In lieu of attempting to weld repair the seating area cracks, the valve body was replaced. One of the functions of this valve is to throttle RHR. flow during the shutdown cooling mode.- Because the valve is throttled to achieve low flow rates, the licensee considered that vibration at low flow caused the nut that secured the stem to the disk to come loose. The nut is locked.in place with a lock tab; however, :the lock tab was bent upwards and not able to' perform its function. The actuator's logic was to utilize the torque switch in the closed direction to secure the actuator motor. The closed torque switch was .not bypassed.- When damaged and the valve was closed, the stem would hit ~ the disk body and actuate the torque switch which

- secured the moto The new valve stem nut lock tab was welded into place to prevent it from flattening ou Valve RHR-F12-003A was inspected and 'tas not damaged; however, the . stem nut lock tab was

. welded into piace. As previously discussed, valve RHR-F12-0038 was

- not diagnostically tested because the licensee policy. is not .to diagnostic test non-bulletin valves. Diagnostic testing would have provided additional assurance that .the valve and actuator were operating correctly following replacemen (Closed) Inspector Follow-tp Valve Item 416/86-36-01, Establish Criteria for Determining When to Clean Engineered Safeguards (ESF)

Switchgear Rnom Coolers Pipin The inspector reviewed Procedures 04-1-03-T46-1, "A" ESF Switchgear Room Coolers Flow Test, Revision 7, dated March 11, 1988, and 04-1-03-T46-2, "B" ESF Switchgear Room Coolers Flow Test, Revision 7 dated March 11, 1988, and determined that' flow cooler criteria had been acceptably addressed. The procedures provided acceptable cooler flow rate criteri Within the areas inspected, no violations or deviations were identifie ._--_ __- ___ _-________________ _ ________ _ _ _ _ -

_ _

,

s

,

.

,.

l 8 l 5. Exit Interview The inspection scope and results were summarized on April 21, 1989, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed above.

i Proprietary information is not contained .in -this report. Licensee

'

management was informed that IE Bulletin 85-03 discussed in paragraph and the Inspector Follow-up Item discussed in paragraph 4.b. were considered closed. Dissenting comments were not received from the license Ite6n N Description and Reference 416/89-13-01 Unresolved Item - Questionable justification for not exercising and stroke testing valves quarterly, paragraph /89-13-02 Inspector Follow-up Item - Verification of the adequacy of current miniflow capacity by the pump vendor, paragraph /89-13-03 Inspector Follow-up Item - Develop and Implement a progarm to routinely monitor valve performance, paragraph 3.b.

- - _ _ _ _ _ _ _ -