IR 05000456/1993011
| ML20045B563 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/08/1993 |
| From: | Dunlop A, Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045B559 | List: |
| References | |
| 50-456-93-11, 50-457-93-11, GL-89-04, GL-89-4, NUDOCS 9306180073 | |
| Download: ML20045B563 (7) | |
Text
.
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/93011(DRS); No. 50-457/930ll(DRS)
Docket Hos. 50-456; 50-457 Licenses No. NPF-72; No. HPF-77 Licensee: Commonwealth Edison Company Executive Towers West III 1400 Opus Place - Suite 300 Downers Grove, IL 60515 Facility Name: Braidwood Nuclear Power Station - Units 1 and 2 Inspection At: Braceville, IL Inspection Conducted: May 17-28, 1993 Inspector:
r/[
h-043 A. Dunlop
/
Date Accompanied By:
L. Sage, Illinois Department of Nuclear Safety May 18- 0, 24-26, and 28, 1993 Approved By:
' M/M S-I-V J.,M Jydbson, Chief ~
Date Mate ia
& Pr cesses Section Inspection Summarv
.
Inspection conducted May 17-28.1993 (Reports No. 50-456/930ll(DRS):
No. 50-457/930ll(DRS))
Areas Inspected: Announced safety issues inspection of the licensee's incorporation of Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Test Programs" into the Inservice Testing (IST) Program (TI 2515/114) and licensee's self-assessment in this area.
'
Results: No violations or deviations were identified. The inspection disclosed one unresolved item (Paragraph 2.b.(2)) concerning stroke timing of power operated valves. Based on this inspection, TI 2515/114 is considered closed.
.
i i
9306180073 930610 PDR ADDCK 05000456 l
O PDR
.
-
-
-
,
.
-
_ _
-
. _.
._.
--
..
,
..
,
!
TABLE OF CONTENTS
,
l-i
.
Pace
1.
Persons Contacted...................................
........
2.
Inservice Testing (IST) of Pumps and Valves......................
-
a.
Scope......................................................
,
b.
Pump Testing...............................................
l c.
Val v e Te s t i ng..............................................
l d.
Rel i e f Va l v e Te s t i n g.......................................
,
'
e.
Trending...................................................
'4
!
3.
Li cen s ee Sel f As s e s sment.........................................
-4
'
4.
U n re s ol v ed I t em s................................................
i 5.
Exit Meeting.....................................................
'
,
?
t
4
?
I i
>
,
i J
b l
!
i:
,
,
'
t l-I
- - !
i
!
- l l-
.
-.
-
,
....
,
r q
.
.
DETAILS 1.
Persons Contacted
'
Commonwealth Edison Company (Ceco)
,
- K. Kofron, Station Manager G. Vanderheyden, System Engineering Supervisor
- M. Prosperv, System Engineering
- H. Pentious, Licensing Supervisor
- E. Juricic, Engineering Assistant-Operations
- D. Zebrauskas, Corporate Inservice Testing
- R. Sagmoe, Inservice Testing / Check Valve Coordinator
- G. Holloway, Inservice Testing / Check Valve Coordinator
- J. Lewand, Regulatory Assurance
- F. LeSage, Site Quality Verification D. Ibrahim, Auxiliary feedwater System Engineer Illinois Department of Nuclear Safety (IDNS1
- L. Sage, Head, Code Compliance Section U. S. Nuclear Reaulatory Commission (NRC)
- S. DuPont, Senior Resident Inspector J. Roton, Resident Inspector
- Denotes those personnel attending the exit meeting on May 28, 1993.
2.
Inservice Testino (IST) of Pumos and Valves The inspectors reviewed IST procedures ~and completed IST surveillances.
Generally, the methods used for the testing of pumps and valves were
adequate. The test frequencies and acceptance criteria were specified and provisions were made for prompt operability determinations. Areas reviewed are discussed below.
a.
Scone Selected plant systems were reviewed to ensure adequate program scope.
Technical Specifications (TS), Updated Final Safety Analysis Report (UFSAR), and Emergency Operating Procedures _(EOPs)
were also reviewed to evaluate the program scope.
The following valves were identified with safety related functions but were not included in the IST program.
(1)
The residual heat removal (RHR) system cross connect valves, 1(2)RH8716A/B, were identified in the.UFSAR with a close safety function during cold leg recirculation and an open safety function during hot leg recirculation.
I r
i-
.
(2)
The discharge check valves for the refueling water storage tank (RWST) to the RHR pumps, I(2)SI8958A/B, had an
additional safety function in the closed direction during the injection phase.
If one RHR pump did not operate, flow
'
from the running RHR pump could be diverted from the reactor core through the RHR cross connect valves, the open mini
flow valve on the idle pump, and challenge the RWST check valve. The operator would assume all flow from the running pump would be entering the reactor since the flow instrument
,
,
was upstream of the cross connect valves.
(3)
The RWST to charging pump suction isolation valves, 1(2)CV112D/E, were identified in the UFSAR with an additional safety function in the closed direction during
!
cold leg recirculation.
(4)
The volume control tank (VCT) outlet check valves, I(2)CV8440, had a safety function in the closed direction as
!
stated in an industry information notice. The unit 2 valve was tested satisfactorily during the last outage and the valves will be incorporated during the next program
'
revision.
,
Although the above safety functions for the valves were not identified in the IST program, these valves were exercised on a
'
periodic basis or included in the check valve program.
Based on this testing there was no operability concern. The adequacy of the program valve scope, however, was questioned based on the number of valve safety functions identified that were not included in the IST program during this limited sample. The licensee stated the intent to submit a combined Braidwood/ Byron IST
..
program. The program would be submitted after a thorough review
of both plants IST programs and UFSAR.
The new program would be reviewed during a future inspection to ensure all valves with a required safety related function, as defined by ASME Section XI,
'
are included in the IST program and properly tested.
b.
Pomo Testina The IST procedures for pumps included tolerance bands of
approximately 2% on the flow reference value. _ The tolerance band relaxed the requirement to obtain a fixed reference value for each.
_
s test, which can be difficult-to accomplish in some cases. The Code, however, does not allow for a tolerance band on the fixed i
reference value.
'
Discussions with NRR indicated this was a generic-issue and f
guidance addressing acceptable tolerance bands would be issued in the near future. Upon issuance the licensee should review and incorporate this guidance into the IST program as required.
t
,
f
,
\\
,
-5 L
,
.
c.
Valve Testina In most cases the guidance of GL 89-04 was incorporated into the IST program for valves. Areas reviewed are discussed below.
(1)
The licensee's interpretation of IWV-3413 for stroke timing power operated valves indicated that stroke timing was only required in one direction, even if the valve had a safety function in both directions. The NRC interpreted this Code
,
section to require stroke timing in both direction.
This
'
was based on the clarification of the Code section in OM-10,
" Inservice Testing of Valves in Light-Water Reactor Power
!
Plants," and the NRC's response to question 41 in the meeting minutes for GL 89-04, dated October 25, 1989.
The licensee had not committed to agree with the NRC's interpretation prior to the exit. No specific examples were
identified in the inspection sample where compliance with
'
this issue was questioned, although several valves
'
identified in paragraph 2.A have safety functions in both directions. This will be considered an unresolved item (20-
!
456/457-930ll-01(DRS)) pending licensee review and response to compliance with the Code requirement.
.
(2)
The test procedures to verify the 1(2)AF014A-F check valves closed on cessation of flow, were not adequate. Temperature measurements were taken at the auxiliary feedwater (AFW)
.
pumps 30 minutes after flow was stopped to verify hot fluid
.
was not leaking back to the pumps. This was not acceptable since two additional check valves in the system could prevent backflow before the temperature monitor.
The test procedures were being revised to monitor the temperature at the 1(2)AF005A-F valves located immediately downstream of the 1(2)AF014A-F valves. Although the
,
previous IST tests did not specifically verify closure, temperature monitoring was performed each shift to verify _
seat tightness in the same manner as stated in the procedure revision, although credit for this action was.not taken in the IST program.
This issue is not a safety concern based
"
on the revised test procedures and temperature monitoring each shift.
B)
The test procedures to verify the open function of 1(2)AF014A-F, 1(2)AF029A-B, 1(2)AF0001A-8, and 1(2)AF003A-B were unclear as to what the acceptable flow rate was for-
>
each valve. A procedure revision was already in progress to specify the required flow rate acceptance criteria. The revised procedure was reviewed and considered acceptable.
Additional procedures reviewed contained clear acceptance criteria for verifying check valves were full open.
^
.
.
(4)
Relief request VR-19 for the AFW pump suction check valves from the RWST, 1(2)AF001A-B), requested relief from the Code from quarterly testing in'the closed direction to a sampling frequency every other refueling outage. Based on the preliminary relief request review by NRR, the justification for not performing the testing quarterly and at a cold shutdown frequency appeared acceptable, however, testing should be performed on each valve on a refueling outage basis. The licensee committed to test on a refueling outage basis and revise the relief request as necessary upon issuance of the SER.
(5)
The position indication testing (PIT) method for the RHR valves was acceptable, however, the procedure identified only one position indication verification as required for acceptance criteria. The licensee agreed to revise PIT procedures to include both the open and close directions as acceptance criteria.
.
d.
Relief Valve Testina The IDNS inspector identified the relief valves in the safety injection (SI) discharge lines were not included in the IST program. The valves provided overpressure protection for the SI system if the pressure isolation valves leak. The licensee committed to the 1983 revision of ASME Section XI that did not require relief valves to be included in the program if they do not perform a specific function in shutting down the reactor or in mitigating the consequences of an accident.
Based on this Code
,
revision, the relief valves do not need to be included in the program, although later revisions to the Code may warrant their inclusion.
.
e.
Trendina
'
The IST coordinator maintained a computer database to trend performance of all pumps and valves in the IST program. Graphic representation allowed easy interpretation and comparison of test results to the appropriate alert and required action ranges. The trending program allowed the IST coordinator to monitor component performance and initiate necessary administrative processes and
plan corrective actions before components became inoperable.
4.
Licensee Self-Assessment
Periodic field monitoring was performed on inservice test performance to
!
verify procedure adherence. The audit scope conducted'in 1991 was j
sufficiently detailed to determine compliance with the Code in the reviewed areas. Deficiencies. identified during these processes were adequately addressed.
-l
__
._
.
.
.
.'
.
5.
Unresolved Items
,
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of
-
noncompliance, or deviations. An unresolved item disclosed during this
>
inspection is discussed in Paragraph 2.c.(1) of this report.
6.
Exit Meetino The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on May 28, 1993..The inspectors
,
summarized the purpose, scope and findings of the inspection and discussed the likely informational content of the inspection report.
The licensee identified none of the documents or processes reviewed by the inspectors during the inspection to be proprietary.
,
.
.
l l
j i