IR 05000416/1990018
| ML20058A576 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/12/1990 |
| From: | Belisle G, Scott Sparks NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058A574 | List: |
| References | |
| 50-416-90-18, GL-89-04, GL-89-4, IEB-88-004, IEB-88-4, NUDOCS 9010290024 | |
| Download: ML20058A576 (8) | |
Text
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. UNITED STATES i
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101 MARIETTA STREET,N.W.
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ATLANT A, GEORGt A 30323.
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Report No.:
50-416/90-18 s.-
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Licensee: System Energy Resources,^Inc.
t Jackson, MS 39205
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Docket No.:
50-416'
License No.:
NPF-29-Facility Name: Grand Gulf J
Inspection Conducted: September 17-21, 1990
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Inspector:
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Date 5fghed Approved by:
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G. A. Telisle, ShWf.
Date Signed Test Programs Section j
. Engineering' Branch.
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Div.ision of. Reactor. Safety
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SUMMARY'
Scope:
- This: routine, unannounced, inspection was conducted-in. the areas of-pump and
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ival.ve inservice testing (IST) and followup of previous' inspection findings.
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Results:
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'In th'e areas inspected, vioIations _or deviations:were not identified..
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iThe licensee's Low Pressure Core Sprayi(LPCS) and-Hidh Pressure; Core Spray
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- (HPCS) systems; appeared to be.~ adequately inservice tested to ensure pumps'and?
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valves' were' maintained. in ani operational readiness state.c paragraph.2.
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d Ey However, the licensee's stop check valve reversefflow testingL oes not conform -
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- to" NRC e guidance regarding the-' intent of Section XI:.off the1 ASME ' Code,
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- paragraph 2.c.-
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REPORT DETAILS l
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1.
Persons Contacted Licensee Employees
- M. Dietrich, Quality Programs Director
- W. Eiff, Principal Quality Engineer
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- C Hayes, Quality Programs Manager
- W. Hughey, Nuclear Licensing Supervisor
- C. Hutchinson, General Manager
- W. Justice, Senior Technical Specialist
- S. Lewis, Senior Technical Specialist
- A. Malone, Senior Engineer
- M. Meisner, Nuclear Licensing Director
- M. Renfroe, Inservice Inspection Supervisor
- J. Roberts, Plant and Systems Engineering Manager
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- S. Saunders, Engineering Support Superintendent
- J. Summers, Compliance Coordinator
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- G. Zinke, Plant Licensing Superintendent i
Other licensee employees contacted during this inspection included engineers, technicians, and administrative personnel.
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NRC Resident Inspectors
- H. Christensen Senior Resident Inspector
- J. Mathis, Resident Inspector
- Attended exit interview 2.
.InserviceTesting(73756)
10 CFR 50.55a(g)'and Technical Specification (TS) surveillance requirement 4.0.5 ^ require that ASME Code Class 1, 2, and 3 pumps and valves be inservice tested in accordance with Section XI of the American Society.of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, which specifies testing requirements - to. assess operational readiness.
The licensee's Pump and Valve IST Program,. Specification: No. SERI-M-189.1, Rev. 4, dated May. 17, 1990,- is based on. Subsections IWP and IWV of the requested in accordance with 10 CFR 50.55a(g)(pt for specific reliefs
.1980 Code through Winter 1980 Addenda, exce5)(iii).
The inspector's review of the IST Program consisted of a comparison of
. current testing practices to the guidelines contained in Generic Letter
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(GL) 89-04,. Guidance on Developing Acceptable Inservice Testing Programs, dated April 3,1989.
By letter dated May 18, 1990, the licensee stated their IST-Program conforms to 'the NRC positions contained' in GL 89-04
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The inspector discussed recent revisions to the IST Program for pump and valve testing of components in the LPCS and HPCS systems, and general testing methodology, and concluded the licensee has a proper understanding of the general guidance provided in GL 89-04.
However, additional inspection would be required to verify testing procedures have been properly revised and implemented for other systems.
The inspector reviewed the licensee's implementation of their current IST Program through a review of procedures, plant drawings, and test results that accomplish IST for pumps and valves that are lo.ated in the LPCS and HPCS systems.
The following specific areas were reviewed:
l a.
Pump Testing The inspector reviewed IST of the LPCS and HPCS pumps to determine if testing was performed in accordance with Section XI, Subsection IWP requirements.
The licensee's LPCS system consists of one vertical centrifugal pump, which takes suction from the suppression noci and discharges to the reactor vessel.
The licensee performs dection XI testing using procedure 06-0P-1E21-Q-0006, LPCS Quarterly Functional Test, Rev. 23, dated 8-26-87, which recirculates flow back to the suppression pool.
The licensee's HPCS system consists of one vertical centrifugal pump, w)hich takes suction from the condensate storage tank (injection mode or the suppression pool, and discharges to the reactor vessel.
The licensee performsSection XI testing using procedure 06-0P-1E22-Q-0005, HPCS Quarterly Functional Test, Rev. 28, dated 7-30-90, which takes section and returns flow back to the suppression pool.
Both the LPCS and HPCS systems also contain i
one jockey pump, which performs a keep fill-function to reduce injection time and minimize water hammer.
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Acceptance criteria in procedure 06-0P-1E21-Q-0006 and 06-0P-1E22-Q-0005 for flow rate, ' differential pressure, vibration, and bearing temperature were verified to be in accoroance with Section XI, Table IWV-3100-2.
The licensee tests the two jockey pumps in accordance with relief requests E21-1 and E22-1, in-which
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horizontal and vertical pump vibration, and bearing temperature, are measured.
GL 89-04 approves IST program relief requests that were on the docket-before April 3,1989, for plants that are not on Table 1 or 2 in GL 89-04, and are topics that were not discussed in Attachment 1 of GL 89-04.
Relief requests E21-1 and E22-1_ satisfy these conditions, and as such may be implemented.
The inspect::r reviewed pump testing results from 1988 through 1990 and concluded that testing is performed at the required frequency.
These records also indicate that all data was properly reviewed to
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determine whether-acceptance criteria were satisfied.
The inspector noted through discussions with IST personnel and review of the testing procedures that if test data falls within the required action range, the pump is inmediately declared inoperable, t-
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Subsequently, gages may be recalibrated and the test performed again, or an analysis performed that demonstrates that the condition does
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not impair pump operability and that the pump will still fulfill its function.
The licensee's position on pump inoperability is
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consistent with position 8 of GL 89-04, which states that instrument recalibration is an alternative to replacement or repair, and not an
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additional action that can be taken before declaring the pump inoperable.
The inspector compared recent test results with vendor head curves T-36512-7 and T-36620-2 for the LPCS and HPCS pumps.
Although this comparison is not an ASME Section XI testing requirement, it may provide another source of information on whether the pump has experienced any significant degradation, or whether it can provide sufficient accident flow rate.
The inspector noted that the pumps are operating approximately on the vendor's head curves.
The inspector also discussed possible testing enhancements for pump vibration monitoring.
Section XI, Subsection IWP requires vibration monitoring in peak-to-peak displacement, which the licensee accomplishes per IST.
However, pump vibration velocity measurements are considered to provide a better overall indicator of pump vibration problems.
This is due in part because the overall vibration severity of a component is a function of displacement and frequency, which can also be attained through the measurement of peak velocity.
The NRC is currently considering rulemaking to reference ASME standard OM-6, Inservice Testing of Pumps in Light-Water Reactor Power Plants.
This standard would require pump vibration velocity measurements as part of IST.
The licensee stated that efforts are underway to obtain baseline peak vibration velocity measurements, which will be used to develop reference values for pump IST.
In addition, the licensee stated that a relief request will be' submitted to-perform IST vibration monitoring using the vibration velocity acceptance critaria contained in OM-6.
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Power Operated Valves The inspector reviewed the IST Program SERI-M-189.1 and testing
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procedures for valves contained in the LPCS and HPCS system, which included the following:
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E21-F001 E21-F005 E21-F011 E21-012-E22-F001 E24-F004 E22-F010 E22-011 E22-F012 E22-F015 E22-F023 The review confirmed that the criteria of Section XI, IWV are specified and implemented in the program and procedures, including:
Positionindication(IWV-3300).
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Valve exercising and~ stroke timing (IWV-3411).
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Stroke time at quarterly intervals (IWV-3412).
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Stroke time at cold shutdown ur refueling outages where relief
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requests are established.
Relief requests stating justification for alternate positions are included in the program document dnd are based on the positions of GL 89-04, (IWV-3412).
Fail Safe actuation (IWV-3415).
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Valve failure criteria (IWV-3417).
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Return of components to service (IWV-3416).
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The inspector revit.wed testing results from 1988 through 1990 and concluded that testing is performed at the required frequency.
These records also indicate that subsequent to maintenance or modification.
l valves are tested prior to return to service.
c.
_ Check Valve Testing Requirements for full stroke and reverse flow exercising check valves are contained in Section XI, Subsection IWV-3520 of the Code.
In addition, specific guidance is contained in positions 2 and 3 of GL 89-04, which discuss forward flow and reverse flow testing.
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- following check valves in the LPCS and HPCS system were reviewed:
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E21-F003 C21-F006 E21-F034 E22-F002 E22-F005 E22-F006 E22-F016 E22-F024 E22-F039 j
The inspector questioned the licensee.on specifically how IST of-the testable check salves E21-F006 and E22-F005 was performed.
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check valves are located downstream of the injection valves for the LPCS 'and HPCS sptems, respectively, inside the drywell.
Each valve has an air actuator, which the licensee uses to manually full stroke
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in accordance with IWV-3522(b).
In addition, these valves have an olectrically initiated position indicating device which is directly q
coupled to the disk, which is ' verifie'i to be accurate every two j
years.
The licensee strokes tnese valves every three months and i
observes the position ' indication to verify reverse closure capability.
The inspector concluded check valves ' E21-F006 and s
E22-F005 were tested in accordance with the Code.
The inspector noted that valves E21-F034, E22-F006, and E22-F039 were stop check valves. The licensee accomplishes reverse flow testing of these valves by turning the handwheel to close the valve.- The
Meeting Minutes to Generic Letter 89-04, dated October 25, 1989,
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addressed stop check valve testing.
Specifically, the response to
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question 25 stated the following:
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Verification of closure-capability of stop check valves by using l
the handwheel meets the ASME Code requirements. This, however, is not the preferred method of test.
The NRC staff considers
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reverse flow testing to be a more reliable indication of valve operability.
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The_ licensee also provided the inspector a Summary of Meetings on November 27 and 28, 1984 Regarding Pump and Valve Inservice Testing Program, dated December 12, 1984.
This document provides NRC staff
- questions and coments regarding the IST program and associated relief requests.
Specifically, it is noted that closure of a stop
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check valves' handwheel is a suitable method of demonstrating closure capability of the valve disk.
However, closure of the hand wheel or hand switch may not provide verification that the reverse flow closure capability can be performed, in that the disk could be detacheo from the valve acem.
In addition, closure of the hand wheel does not confirm the disk seats promptly.upon cessation or reversal of flow by visual observation, by an electrical signal initiated by a position indicating devise, or by observation of appropriate pressure indications in the system.
Region II recently received additional clarification from NRC Headquarters regarding stop check valve testing. Specifically, the following clarification was provided from NRR to Region II.
(1) If there is no safety-related function in the closed position of the stop check valves, closure verification is only necessary to ensure repeatable opening stroke time testing.
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(ii)
If the safety-related function of the system is achieved by valve closure using a handwheel or a hand switch, then exercising the valve by.this method meets = the ASME Code
requirements of IWV-3522.
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(iii)
If prompt closure of these valves on cessation or reversal of flow is required to accomplish a safety-related function, closure verification must be performed by reverse flow testing or other positive -means ~ such as acoustic monitoring or radiographic techniques.
(iv): Disassembly and inspection should only be used as a last resort for the purpose of' verifying valve closure because it provides little information onL valve capability to seat promptly on cessation or reversal of flow.
Furthermore, if the method
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involves extensive disassembly, a post-maintenance test would be necessary per. IWV-3200 because disassembly and inspection can i
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reassembled.
Therefore, in cases where closure testing of a check valve using reverse flow and system parameters is not
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. feasible, disassembly and inspection may be used as a last
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resort.
However, the licensee should investigate the use of
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non-intrusive testing techniques and implement them if they are
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demonstrated ~to be effective.
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The inspector provided this information to the licensee, and noted that based on discussions with the licensee, the three stop-check valves in the LPCS and HPCS systems meet the criteria of item (iii)
above, in that they are required to promptly close to perform their intended safety function.
The licensee currently tests these stop check valves by turning the hand wheel, and dots not perform reverse flow testing.
As such, the licensee's current IST for these stop check valves was not in accordance with the above guidance regarding Section XI, IWV-3522 of the ASME Code.
The inspector informed licensee management that no enforcement would be taken in this area due to the apparent confusion regarding Code requirements as they relate to reverse flow testing the prompt closure function of stop check valves.
However, revision of the licensee's current IST Program may be appropriate to conform to ASME Section XI IST requirements.
The above stop check valve testing issue will be reviewed in future NRC inspections, d.
Relief Valve Testing The requirements for relief valve testing are contained in Subsection IWV-3512 of the Code, which states that setpoint testing shall be in accordance with ASME Performance Test Code (PTC) 25.3-1976.
The inspector reviewed IST data and procedures for LPCS and HPCS relief valves E21-F018. E21-F031, E22-F014, and E22-F035, and concluded testing was performed in accordance with PTC-25.3-1976.
Within the areas inspected, no violations or deviations were identified.
3.
ActiononPreviousInspectionFindings(92701)
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(0 pen)InspectorFollowupItem(IFI) 50-416/89-13-02, Verification of the Adequacy of Current Miniflow Capacity by Pump Vendors The inspector reviewed the licensee activities in this area, which was a result of Bulletin 88-04, Potential Safety-Related Pump' Loss, dated May 5, 1988 This Bulletin addressed potential cumulative pump damage which would result due to operation at flow rates less than that recommended by the pump vendor. The licensee's initial response involved a Boiling Water Reactor Owner's Group (BWROG) generic letter, which stated that past oaerating history did not reveal any pump damage as discussed in the 3ulletin. However, the licensee was asked to obtain pump vendor informatkn on miniflow capacity to support the conclusions drawn by the BWROG.
The licensee's activities included discussions with pump vendors to obtain the minimum flow requirements for each safety related pump.
However, s'nformation for the Reactor Core Isolation Cooling pump, as well as a
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rt/.lew of actual minimum flow rates fv other safety related pumps, had not been completed.
Pending completion of these. actions, this IFI will remain open.
Within the areas inspected,_no n1ations or aviations were identified.
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Exit Interview The inspection scope and results were summarized on Septernber 21. 1990, with those persons indicated in paragraph 1, The inspectors described the areas 'nspected and discussed in. detail the inspection results.
Propt!ccary information is not contained in this report. Dissenting-comments were not received from the licensee.
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