IR 05000458/1997018

Insp Rept 50-458/97-18 on 971208-12.No Violations Noted. Major Areas Inspected:Maint & Engineering

ML20198J424
Person / Time
Site:	River Bend
Issue date:	01/06/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198J380	List: IR 05000458/1997018 ML20198J376
References
50-458-97-18, NUDOCS 9801140129
Download: ML20198J424 (10)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

- Docket No.: 50-458 License No.: NPF-47 Report No.: 50-458/97-18 Licensee: Entergy Operations, In Facility: River Bend Station

_; Location: 5485 U.S. Highway 61 St. Francisville, Louisiana d,;

Dates: December 8-12,1997 Inspectors: Lawrence E. Ellershaw, Senior Reactor inspector Maintenance Branch Yun-Seng Huang, Senior Mechanical Engineer Mechanical Engineering Branch, Office of Nuclear Reactor Regulation Approved By: Dr. Dale A. Powers, Chief, Maintenance Branch Division of Reactor Safety ATTACHMENT: SupplementalInformation

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9801140129 900106 PDR ADOCK 05000458 0 PDR l

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_ m EXECUTIVE SUMMARY

- River Bend Station:

NRC Inspection Report 50458/g7-18 The p"mose of this inspection was to determine whether inservice testing regulatory .

- rguiremants and licensee commitments were being met. -The inspection was performed using ;

the guidanu of NRC inspection Procedure 73756, " Inservice Testing of Pumps and Valves." - -- I Maintenance

- *- The observed inservice testing was performed in'accordance with the applicable

-: procedure and by knowledgeable test personnel (Section M1)/

/ . The material condition of the equipment located e 0,e Residual Haat Removal Pump C room was very good (Section M2).

.- Inservice testing procedures met applicable ASME Code requirements and inservice

- tests were performed at the specified frequencies (Section M3),

Engineering-The licensee had developed a strong inservice testing program and the component-

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scope was found to be appropriate, Development and use of the component information sheets, which constituted the inservice testing data base, was considered excellent - J (Section E1).

. The licensee exercised sound judgement in developing the bases for refueling outage

- . testing and cold shutdown justifications (Section E1).

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A Reoort Details '

1 Summarv of Plant Status  !

The plant was at full power operations during the inspectio '

11. Maintenance M1 Conauct of Maintenanc lDsoection Scone (73756)

On December 11,1997, the inspectors observed inservice testing performed on the following components: Residual Heat Removal Pump (RHR) C, E12 PC002; RHR

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Pump C Test Return to Suppression Pool Valve, E12 MOVF021 (open and close); and -

Check Valves E12-VF031C (open) and E12-VFO46C (open).

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The inspectors also reviewed locked valve administrative controls and the implementation of the control . Observations and Findinas Section 7.3 of Surveillance Test Procedure STP-204-6302, "Div ll LPCI (RHR) Quarterly Pump and Valve Operability Test," Revision 13, was used to test the above-described components. The inspectors observed installation of the ultrasonic flow meter, which had been properly calibrated and placed in a location that had been specifically designated to assure repeatability. Test personnelinstalled the specified . suction pressure test gauge at the designated location. After starting the pump, the reference flow rate of 5100 gpm was established and the required measurements were recorde .

Vibration data was taken at the specified locations and documented. Subsequent to -

comp!stion of the test, the temporarily installed instrumentation was removed. The inservice test results were reviewed and found acceptabl . The inspectors determined that the test personnel demonstrated strong knowledge of the surveillance test procedure, instrumentation installation, and the mechar'ics of the test

. performanc A sample of locked open and locked closed valves was selected from Engineering

. Piping and Instrumentation Drawing (P&lD) PID-00-03A, " Table of Locked Valves."

Further verification of valve normal position status was made by review of each valve's

. Inservice Test Data Base Document. The inspectors verified, by observation, that the conditions of the following valves were in accordance with their pcsitions as shown on the corresponding documents:

. E12-VF029C - Locked open

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. E12 VF102 - Locked closed

. E12-VF029A - Locked open -

- E12-VF0298 - Locked open c. Conclusions The test personnel were knowledgeable and very familiar with the surveillance test procedure, instrumentation installation, and the mechanics of test performanc Administrative controls for the locked valve program had been established. The controls had been appropriately implemented on the four valves that the inspectors sample M2 Maintenance and Material Condition of Facilities and Equipment a. Insoection Scooe (73755)

During observation of the inservice test performed on the RHR pump and associated valves, the inspectors also observed the material condition of the equipment in the pump roo b. Observations and Findings The inspectors observed minor surface rust conditions at several pipe and vc!ve joints; however, none of these conditions affected the operability of equipment. No oil or water leaks wer9 observed, and no evidence of prior leaking conditions was identified. No obvious damage to components was observed by the inspector c. Conclusions The material condition of the equipment located in the RHR Pump C room was very goo M3 Maintenance Procedures and Documentation a. Jnsoection Scoce (73756)

The inspectors reviewed the inservice test procedures identified in the attachment, to assure that steps necessary to comply with ASME Code requirements were include The inspectors verified that acceptance criteria, and actions to take if those criteria were exceeded, were included. In addition, the inspectors reviewed ths :ast three quarterly test result data sheets for each of the identified inservice test procedure ,

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5-b. Observations and Findinas The licensee's current inservice test program, effective December 1,1997, was updated in accordance with the 1989 Edition of the ASME Code. Inservice test personnelwere responsible for assuring that surveillance test procedures were revised to reflect changes in ASME Code requirements. Two of the eight surveillance test procedures reviewed had been used to perform tests after the time of the update, and both procedures had been properly revised. Thus, the inspectors found that the inservice test personnel were implementing their responsibility for assuring procedure revision prior to us The inspectors noted that stroke-time acceptance criteria for motor-operated valves had become more restrictive in the 1989 Edition of the ASME Code. For example, this version of the ASME Code states that motor-operated valves with reference stroke times greater than 10-seconds shall exhibit no more than a 115 percent change in stroke time when compared to the reference values, as opposed to the previously allowed 125 percent change. Also, motor-operated valves with reference stroke times 10 seconds or less shall exhibit no more than 125 percent or 11 second change in stroke time, whichever is greater, when compared to the reference values. The use of the previous Code required the change be within 150 percen If the applicable surveillance test procedures were used without incorporating the new acceptance criteria, it is possible that the test results could be accepted while not meeting current ASME Code requirements. In fact, the inspectors' review of several test results dated November 28,1995, and February 12,1996, identified that certain stroke times determined with Procedure STP-209-6310 would not meet the current ASME Code requirements. However, the inspectors verified that the stroke times were in compliance with the then-existing ASME Code requirements. The inspectors discussed this condition with inservice test personnel to assure their awareness of this potential problem. The inspectors were informed that the operations inservice test coordinator is responsible for developing the inservice test schedule. The test schedule was forwarded to tne inservice test program specialist who is required to perform a review of the applicable surveillance test procedures for compliance to current program and ASME Code requirements. Upon completion of a satisfactory review, the inservice test program specialist authorized performance of the scheduled tes During review of Pressure Isolation Valve Surveillance Test Procedure STP-204-6603, the inspectors noted that two pressure isolation valves (RHR Pump Shutdown Cooling Inboard Isolation Valve E12-MOVF009 and RHR Pump C Shutdown Cooling inlet Check Valve RHS-V240) were tested as a group with a leakrate acceptance criterion identified as 5 gpm or less. The ASME Code states that if water leakage rates are not specified for Category A valves (other than containment isolation valves), then leakage rates, at function pressure differential, shall be the lesser of 5 gpm or the gpm resulting from 0.5 times the diameter in inches. Valve RHS-V240 is a 1-inch diameter valve; therefore, its maximum allowable leak rate is 0.5 gpm. Since the valves were tested as a group, there was no way to determine if Valve RHS-V240 leaked in excess of 0.5 gp ____ _ -_ - - ________

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6-Inservice test personnel showed the inspectors that Valve RHS-V240 was listed in the Updated Safety Analysis Report Pressure Isolation Valve Table, but it was not listed in the Technical Specification / Technical Requirements Manual Pressure Isolation Volve Table. Since it was excluded from the Technical Specifications / Technical Requirements Manual, licensee personnel contended that they met the guidance provided in NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants." The inspectors noted that NRC staff guidanca contained in NUREG-1482, with respect to pressure isolation valves, states that valves defined as pressure isolation valves other than those in

~ echnical Specifications are at least verified closed in accordance with the inservice testing progra The inspectors found that the licenses's inservice testing program appropriately followed the guidance provided in NUREG-1482, and that testing the valves as a group with a 6 gpm leakage limit would adequately verify closure of Valve RHS V24 However, the inspectors questioned licensee personnel regarding the inconsistency of listing Valve RHS V240 in the Updated Safety Analysis Report but not in the Technical Specificatiort' Technical Requirements Manual. This prompted licensee personnel to initiate Condition Report 97-2103 on December 10,1997, to determine if Valve RHS-V240 should be listed in the pressure isolation valve table in the Technical Specification / Technical Requirements Manual. If so, the acceptance criteria for the combination valve test could be limited to 0.5 gpm, which could result in a 4.5 gpm penalty against Valve E12-MOVF009, or the need for a possible license amendment change. The inspectors considered this issue to be an inspection followup item pending review of the licensee's completed evaluation (50-458/9718-01).

t The inspectors' review of the pump and vaive operability data sheets for the identified i

surveillance test procedures revealed that inservice tests were performed at the specified l frequency, and test results were acceptable. The inspectors noted, however, that the

! high pressure core spray pump operability data sheet in Surveillance Test Procedure

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STP-203-6305 showed a small differential pressure margin between the reference value (428.8 psid) and the Technical Specification limit (415.0 psid or greater). With such a

small margin available (approximately 3.2 percent), there was no realistic way to detect

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degradation to the extent the ASME Code intended (i.e., up to 10 percent before the required action range limit was reached). Therefore, if the pump differential pressure i

degraded in excess of 3.2 percent, it would be considered acceptable within ASME Code parameters; however, it would fall below the Technical Specification limit and would be inoperable. The inspectors noted that the inservice test program specialist had recognized this vulnerability, and had included the Technical Specification limit in the l pump and valve operability data sheets as a reference point to preclude that possibility.

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The inspectors reviewed the past four quarterly operability tests for High Pressure Core Spray Pump E22-PC001 and noted 2 hat the differential pressure test results were above the reference value of 428.8 psid.

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The inservice test program specialist appropriately recognized the m'norabilityc associated with the small margin between the high pressure core apw oump's - .

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. reference value (differential pressure) and the Technical Specification inn t. This resulted -

in the Technical Specsfication limit being incorporated into the pump and valve operability -

data sheets as a reference point to preclude the possibility of the pump's performance dropping below the Technical Specification limit without being detecte i inservice testing procedures met applicable ASME Code requirements and inservice -  ;

tests were performed at the specified frequencies, j lit Engineering  ;

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E1 Conduct of Engineering .

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• Inspachon Scope (73756)

The inspectors selected the following four systems for review in order to determine whether inservice. testing regulatory requirements and licensee commitments were being met:

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. High Pressure Core Spray ,

. Low Pressure Core Spray ,

-. - Low Pressure Coolant injection

.' Reactor Core Isolation Cooling (partial)

The 'nspectors also reviewed four cold shutdown testing justifications (CSJ-001, -009,

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-017, and -031), and one refueling outage testing justification (ROJ 03) that were _{

applicable to certain components in the selected system P

Observations and Findings 1 On December 1,1997, the licensee implemented their updated second 10-year inservice -

test plan, which committed to the 1989 Edition of the ASME Code. This edition of.the Code, which is approved for use in 10 CFR 50.55a, constituted a major revision to the

' first 10 year inservice test plan, which had committed to the 1980 Edition through the Winter 1981 Addenda of the ASME Code.-

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The 1989 Edition of the'ASME Code references use of Part 6. " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10, " Inservice Testing of Valves-in Light-Water Reactor Power Plants," in the ASME/ ANSI OMa-1988 Addenda to the OM -

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1987 Edition.

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. The inspectors reviewed the P&lDs (identified in the attachment) for each of the four selected systems to determine if all safety-related ASME Code pumps and valves hao been included in the inservice testing plan. With the appropri@ exception of several administratively controlled manual valves that were used for maintenance purposes, the inspectors did not identify any instance where pumps or valves had been exclude Licensee personnel had developed a component information sheet for each component, regardless of classification. These information sheets, collectively, constituted the licensee's inservice testing data base. The documents clearly identified the component (i.e., name, identification, system, type, size, P&lD, code class, normal position, safety position, fail position, safety function (s), references, related documents, and test requirements). The documents also appropriately provided the basis for excluding a component from the inservice testing progra The inspectors considered the cold shutdown and refueling outage testing justifications for test frequency adjustments proper and appropriat The inspectcrs verified that administrative controls existed for providing information pertaining to physical changes to plant systems (i.e., modifications) to the inservice test engineer for his use in determining any impact to the inservice test program. The controls were delineated in Engineering Procedure EDP-AA-80," Modification Forms,"

Revision c. Conclusions A strong inservice test program had been developed. The reviewed component scope was appropriate. Development and use of the component information sheets, which constituted the inservice testing data base, was an excellent approach to providing inservice testing component control and informatio The licensee had exercised sound judgement in developing the bases for refueling outage testing and cold shutdown justification V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on December 12,1997. The licensee personnel acknowledged the findings presented. The inspectors asked the licensee personnel whether any materials examined during the inspection should be considered proprietar No proprietary information was identifie ,

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licenste M. Bellamy, Director, Site Support P. Bellard, inservice Test Coordinator D. Dormady, Manager, Plant Engineering C. Forpahl, Supervisor, Engineering Programs C. Glass, inservice Test Program Specialist H. Holkamp, Jr., Technical Specialist, Quality Assurance R. King, Director, Nuclear Safety and Regulatory Affairs D. Lorfing, Supervisor, Nuclear Safety and Regulatory Affairs W. Mashburn, Manager, Engineering Support J. McGaha, Vice President, Operations M. McHugh, Engineer, Nuclear Safety and Regulatory Affairs M. Small, Quality Assurance Specialist INSPECTION PROCEDURES USED 73756 Inservice Testing of Pumps and Valves ITEMS OPENED 50-458/9718-01 IFl Review licensee's evaluation to determine if pressure isolation valve RHS-V240 should be listed in the Technical Specification / Technical Requirements Manual LIST OF DOCUMENTS REVIEWED Procedures ENG-3-041, 'ASME Section XI Inservice Testing Program,' Revision 2 OSP-0042, 'ASME Section XI Inservice Testing implementation,' Revision 1 EDP-AA-77, Control of Locked Valve List," Revision 7 EDP-AA-80, ' Modification Forms," Revision 2 ADM 0015,' Station Surveillance Test Program," Revision 18 STP-204-6302, "Div 11 LPCI (RHR) Quarterly Pump and Valve Operability Test,' Revision 13 STP-205-6301, "LPCS Quarterly Pump and Valve Operaoility Test," Revision 6A STP-233-6305, 'HPCS Quarterly Pump and Valve Operability Test," Revision 5 STP-209-6310, 'RCIC Quarterly Pump and Valve Operability Test," Revision 9 STP-204-6304, "Div 11 RHR Quarterly Valve Operability Test," Revision 14 STP-000-6606, "Section XI Safety and Relief Valve Testing," Revision 6 l

STP-204 6301, "Div I LPCI (RHR) Quarterly Pump and Valve Operability Test," Revision 15 STP-204-6603, "RHR System Refuel Pressure Isolation Valve Test," Revision 1 I

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I 2-Drawinos PID-27-04A, High Pressure Core Spray, System 203, Revision 23 PID 2745A, Low Pressure Core Spray, System 205, Revision 20 PID-27-06A, Reactor Core Isolation Cooling, System 209, Revision 34 PID-27-7A, Residual Heat Removal (LPCI), System 204, Revision 31 PID-27-78 Residual Heat Removal (LPCI), System 204, Revision 34 PID-27-7C, Residual Heat Removal (LPCI), System 204, Revision 22 PID40-03A," Table of Locked Valves," Revision 19 1