ML16341E586
| ML16341E586 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/11/1988 |
| From: | Clark C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341E585 | List: |
| References | |
| 50-275-88-04, 50-275-88-4, 50-323-88-03, 50-323-88-3, NUDOCS 8803290015 | |
| Download: ML16341E586 (18) | |
See also: IR 05000275/1988004
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-275/88-04,
50-323/88-03
Docket Nos.
50-275,
50-323
License
Nos.
Licensee:
Pacific Gas
and Electric Company
77 Beale Street
Room 1451
San Francisco,
94106
Facility Name: Diablo Canyon Units 1 and
2
Inspection at:
Diablo Canyon Site,
San Luis Obispo County, California
Inspection
Conducted:
February 8-22,
1988
Inspector:
C.
rk, Reactor Inspector
Approved by:
S.
Richards,
Chief
Engineering
Section
Date Signed
3
tI
gS
Date Signed
~Summar
Ins ection Durin
the Period of Februar
8-22
1988
Re ort Nos.
50-275/88-04
~/
Areas Ins ected:
This routine,
unannounced
inspection involved the areas
of
inservice testing of pumps
and valves.
The inspection
included review of the
program,
procedures,
records,
and interviews with licensee
personnel.
During this inspection,
Inspection. Procedures
Nos.
30703
and 73756 were used
as guidance for the inspection.
al
Results:
In, the areas
inspected,
two violations were identified for returning
a valve to.,its original stroke time test frequency, with no corrective action
performed (paragraph 2.c.)
and for not establishing
the required reference
flow rate during a pump test (paragraph
2. d).
~ 0~~ SS0311
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0
DETAILS
1.
Persons
Contacted
Pacific Gas
and Electric
Com an
PGEE
G. Burgess,
Senior
Power Production
Engineer
J.
Hjalmarson,
Lead Power Production Engineer
T. Pellisero,
Lead Power Production
Engineer
C. Pendleton,
Lead Power Production
Engineer
0.
Franks,
Supervisor
ISI/NDE
D. Taggart, Director guality Support
R.
Nanninga,
Senior
Power Production
Engineer
"T. Grebel,
Regulatory Compliance Supervisor
"Denotes those personnel
in attendance
at an exit meeting
on February
12,
1988.
The inspector also held discussions
with other licensee
personnel
involved with inservice testing of pumps
and valves.
2.
Inservice Testin
Pro
ram
a.
IST Pro
ram Status
Unit 1 is currently in its first 10-year inspection interval,
May 7,
1985 through
May 7,
1995.
Unit 2 is also currently in its first 10-year inspection interval,
March 13,
1986 through March 13, 1996.
In November of 1987 the licensee
submitted Revision
6 of the Unit 1
ISI/IST Program Plan and Revision
3 of the Unit 2 ISI/IST Program
Plan.
The IST Programs for Units 1 and
2 are identical
and the
licensee
refers to them as the
"DCPP Units 1 and
2 IST Program."
As
of the date. of this inspection the
NRC is in its final review of
these latest revisions to the IST programs,
and is aware that the
licensee
IST program is following these latest revisions.
b.
Procedures'he
licensee
implemented the policies-and
procedures
for inservice
te'sting of pumps
and valves through various site procedures.
During
this inspection the inspector
reviewed the latest revisions of the
following procedures:
Administrative Procedure
AP C-80, Revision 4, "Inservice
Inspection
Program (equality Related)"
Various other Surveillance Test Procedures
and Maintenance
Documents
Related to IST Pump and Valve Testing
During the review of these
IST procedures,
the following was noted:
While these
procedures
assigned responsibilities
to persons
and
organizations for the majority of IST activities, they did not
appear to cover any training for licensee
personnel
implementing
IST surveillance
procedures.
After this concern
was discussed
with the licensee,
they identified they were
aware of the
need to provide training in this area,
and were
working on this item.
The acceptance
criteria in surveillance test procedure
M-77,.Revision 7, "Safety and Relief Valve Testing", stated
"prior to calling a lift an actual lifting test,
1 to 3 lifts
may be
made to determine operability, repeatability
and seat
clean out."
The
NRC considers this statement
unacceptable
for
as-found lifttesting.
This procedure
did not identify if the
above lift acceptance
criteria statement
was applicable to
as-found and/or as-left lifttesting.
The licensee
stated this
statement
was only applicable to as-left testing after valve
adjustment,
and that all test personnel
had been instructed to
record the first as-found lifttest data, without any previous
valve exercising. 'o clarify the licensee position on as-tound
and as-left testing in this area,
the licensee
stated
additional instructions would be added to the applicable
procedures.
This item will be followed as
open item
50-323/88-03-01.
0
'
Surveillance Test Procedures
STP P-1B (Revision 8) "Routine
Surveillance Test of Safety Injection Pumps"
and
P-4B
(Revision 8) "Routine Surveillance Test of Containment
Spray
Pumps" are performed to verify operational
readiness
of the
applicable
pumps.
Both procedures
test the applicable
pumps
by
establishment
of a volume
9 (pump routine surveillance test
acceptance criteria) reference
flow rate, but these flow rates
are not verified in either test procedure
during establishment
of the flow rates at the start of the tests,
or checked
as
acceptance criteria for considering preliminary pump
operability.
Since these
reference
values
are
a fixed set of
baseline
values,
which all subsequent
inservice testing is
performed at, the establishment
of these
values
needs
to be
verified'n test procedures.
The licensee
stated they would
review surveillance test procedures,
and ensure
Volume 9
reference'values
are verified and checked during Section
XI
surveillance testing.
This item will be fol'lowed as
open item
50-323/88-03-02.
The licensee is in the process
of reformatting the IST
surveillance test procedures,
to follow the latest
IMPO
recommended
form.
The licensee
stated that all applicable
procedures
have
been rewritten in the draft form and in excess
of 50K of the drafts
have
been reviewed,
approved
and issued.
IST Records
Various final IST records for pumps
and valves were examined,
and
the following was identified for valve RCV-16, in Unit 2.
Per,the individual valve exercising record;
the Unit 2
Component Cooling Water
(CCW) surge tank vent valve
RCV-16 (a
3
inch electric motor-operated
ball valve)
has
shown
a history of
increasing
valve stroke times.
Subsection
IWV-3417(a) of
Section
XI of the
ASME Boiler and Pressure
Vessel
Code states
in part "if, for power operated
valves,
an increase
in stroke
time of...50K or more for valves with full stroke times less
than or equal to 10 sec is observed,
test frequency shall
be
increased
to once
each
month until corrective action is taken,
at which time the original test frequency shall
be resumed."
The exercising record identified the limiting stroke time for
this valve as
10 seconds.
The initial recorded
valve stroke
time of 1.61 seconds,
has
increased
to the
7 to 8 seconds
range
in six out of twenty five of the latest stroke time tests.
The
same valve in Unit 1,
had
an initial valve stroke time of 1.24
seconds,
which has
increased
to the two second
range in 5 out
of twenty-eight of the latest stroke time tests.
A review of the licensee
actions
taken
on Unit'2, valve RCV-16,
identified that A0011167 was issued
November 12,
1985, to
increase
surveillance
frequency.
This A/R was issued
because
the November 2,
1985 stroke time for RCV-16 valve increased
to
2.01 seconds
from 1. 12 seconds
(a 79X increase
in valve stroke
time).
While this A/R was still open,
a January
3,
1986 stroke
time increase
from 0.9 seconds
to 5.01 seconds
(a 457K increase
in valve stroke time) was investigated.
A solenoid ground
was
found and identified as contributing to the problem of the
January
3, 1986 valve stroke time.
Action Request
Number
A0011167 was closed out with reference
to A/R number A0028976,
which was issued July 8, 1986.
Action Request
Number A0028976
was issued to document alert status,
because
a July 4,
1986
stroke time increased
to 5.46 seconds
from 3.53 seconds
(a 55K
increase
in valve stroke time).
While witnessing
a September
3,
1986 stroke time test of valve RCV-16, flaking paint was
observed
on the valve stem near the point where the valve stem
entered
the valve body.
At this time A/R number A0033066 was
.~j~written on September
4, 1986, to remove paint.
The licensee
~~'+identified that it considered that the flaking paint may have
,',,"'"contributed to the erratic valve stroke times for this valve.
-'.+"'= 'On April 6,
1987 A/R Number A0033066, identified that the
subject paint had
been
removed.
On December
3,
1986 A/R Number
A 0050193
was issued,
since
a
stroke time test of valve RCV-16 on November 29,
1986 (prior to
any paint removal)
showed valve stroke time increased
to 7.70
seconds
from 3. 20 seconds
(143K increase
in valve stroke time).
This A/R increased
the surveillance
frequency to once per 31
days.
On April 22, 1987, this A/R identified "successful
tests
on March 3,
1987 and April 3, 1987; return to 92 day freq."
The March 3, 1987 stroke time was 8. 2 seconds
and the Apri 1 3,
1987 stroke time was 6.25 seconds.
At the time of this inspection,
the stroke times for the next
three surveillance
stroke time tests
were:
May 4,
1987
7.88 seconds
August 4,
1987
7.83 seconds
November 3,
1987
5.35 seconds
The licensee
had
no explanation or analysis
as to why valve
RCV-16 in Unit 1 still has
a stroke time in the 1-2 seconds
range
and the Unit 2 valve stroke time increased
to the
7 to 8
seconds
range.
After reviewing of the above information the inspector requested
identification of the licensee's justification for returning the
Unit 2 valve
RCV-16 to the normal
92 days surveillance
frequency,
after the
May 4,
1987 surveillance stroke time test, without
performance
of the corrective action referenced
in subsection
IN/-3417(a) of Section
XI of the
ASME Code.
On February 22,
1988 the licensee
provided
a response
that stated
in
part "the valve stroke time again'stabilized,
at approximately the
time the paint was cleaned
from the valve stem...and
the valve was
returned to quarterly testing...."
The licensee
also noted that
while subsection
"IN/-3417 Corrective Action, requires that if a
valve's stroke time increases
by a specific amount over the previous
test..., test frequency shall
be increased
to once
each
month until
corrective action is taken, at which time the original test
frequency shall
be resumed.
Unfortunately, subsection
IN/ provides
no other guidance
as to what "corrective action" consists of."
The licensee
stated it had been their practice to use
IMP-3230(c)
for guidance
on what constitutes
corrective action,
and to return
the valve to original test frequency if two subsequent
tests
indicated that the valve's stroke time has stabilized at less
than
90K of the stroke time limit.
The licensee
stated they felt the
above constitutes
"an analysis to demonstrate
that the condition
does not impair (valve) operability and that the (valve) will still
fulfilli.ts function."
-J-
The> above licensee practice
was not documented
in the IST procedures
at .time of the inspection .
The inspector identi fied to the
1icensee
, that if the licensee
expects
to follow the above practice ,
it should
be documented
in the applicable
IST procedures
.
Also if
anal ys i s , eval uati on or investigation of a change in valve stroke
time is performed , the actions
taken should
be documented
along with
any pos itions taken
by the licensee
, to identi fy the reason for the
change .
After revi ewi ng the above licensee
records
and response
, it was
identified to the licensee that failure to take corrective acti on on
valve
RCV-16 , prior to returning it to its origi nal test frequency
(after the May 4,
1987 surveillance
stroke time test) is an apparent
violation (323/88-03-03) for the following reasons:
There were
no documented
licensee
records that corrective
action
had been taken for this valve, prior to resuming the
original test frequency.
That is, there were
no records
documenting valve replacement,
repair actions,
trouble shooting
investigation,
or a detailed engineering
analysis identifying
why this latest
141K increase
in valve stroke time had occurred
and why the licensee
considered it acceptable.
Section
XI testing is required for each valve, to determine its
operational
readiness.
There is no record the licensee
investigated this operational
readiness
concern,
before
resuming the original test frequency.
In followup discussions
the licensee
stated that they would provide
additional
documentation
of the actions
taken
on the past A/R's
associated
with the Unit 2 valve RCV-16.
d.
Work Observations
On February 10, 1988, the inspector
observed
the following Unit 1
surveillance testing:
(1)
STP V-3K5 (Revision 7), exercising valves
8146 normal charging
and 8147 alternate
charging
and check valves
8378A,
B,
C and
8379 A, B.
The performance of STP V-3K5 appeared
to provide
acceptable
results,
and the inspector did not identify any
concerns.
(2)
P-4B (Revision 8) routine surveillance testing of
containment
spray
pump no. 1-1.
The performance
of this
surveillance testing appeared
to be unacceptable,
and the
following observations
were identified.
The volume 9 reference
flow rate of 300 t 5 gpm,
identified in paragraph
C.2 of the procedure
data sheet
was not established
for the test.
The operator
looked at
the flowmeter and recorded
300
gpm in the test procedure
and proceeded. with the test.
After the inspector
questioned
how the operator could identify the actual
flow
rate with the erratic flowmeter FI-929 readings
observed,
the operator
attempted
unsuccessfully
to obtain the
required reference recirculation flow rate by operation of
valve CS-1-8983.
The actual
flowmeter reading appeared
to
hang at 310
GPM,
a majority of the time.
Paragraph
C.2 of
the procedures
states
in part "if necessary,
open or
throttle valves in the recirculation flow path to attain
the reference recirculation flow rate."
This could not be
acccomplished,
and was reported to the control
room via
telephone.
The operator stated
an A/R would be written on
the flowmeter.
The test
was continued,
even though the procedure
required
reference
flow rate of 300 2 5 gpm could not be
established.
All other required test data
was recorded.
The completed test procedure
was reviewed by the shift
foreman
and signed off, verifying the procedure
preliminary acceptance
criteria had been satisfied for
considering the
pump operable.
This preliminary
acceptance
criteria did not include verification that the
required
volume
9 flow rate
was established
for the test.
After the inspector,
operator
and shift foreman discussed
the question of flowmeter FI-929 functioning properly
during this
pump test,
and the
pump operability status,
the shift foreman stated
the operation of the flowmeter
would be investigated
per the A/R and they would send both
the test procedure
and A/R on to the engineering
group for
review.
Action Request
(A/R) Number A0099074 was written on
February ll, 1988.
This A/R identified that the
recirculation flow indication of FI-929 oscillated from
approximately
290
gpm to 320 gpm, but did not indicate
a
steady oscillation.
Per the A/R, flow indication would
hover at the 310 mark then drop to the 300 mark and then
drop to the 290 mark, then spike back
up to 320
gpm and
repeat the cycle.
This A/R also identified that by
shutting the recirculation isolation valve CS-1-8983
approximately 1/2 to 3/4 of a turn, the oscillations
continued,
but in the range of 280-310
gpm.
During observation of this
pump test,
the inspector
determined that the licensee
had obtained
a relief request
from calibration of flowmeter FI-929.
The licensee
had
received relief in paragraph
2.3. 1 "Relief Request (1)" of
attachment
2 of NUREG-0675,
supplement
no.
31, entitled
"Safety Evaluation Report Related to the Operation of
Diablo Canyon Nuclear
Power Plant"
~
As part of the
licensee
basis for requesting relief, paragraph
2.3. 1.2
stated,
"These flowmeters shall
be observed to function
properly during each
pump test."
When this flowmeter was
used during the February
10,
1988
pump test discussed
above, neither the existing test procedure,
test personnel
or I&C personnel
had specific instruction or requirements
to verify the subject flowmeter was functioning properly
during this test.
When licensee
personnel
were asked
how
they observed that this flowmeter was functioning
properly, they had
no answer.
The licensee
stated
they
would investigate this item,
and provide additional
instructions
as required to verify the subject flowmeter
operation
was acceptable
during the performance of future
tests.
The licensee
plans to investigate
replacement
of
the existing flowmeter with a new design that can
be
calibrated at the facility.
The licensee
stated that the accuracy/verification that
flowmeter FI-929 was functioning properly during the
subject test will be investigated
per
A/R number A00990074
and if required,
the subject
pump test will be
reperformed.
The corrective actions
taken to ensure
the
flowmeter is functioning properly during future tests will
be followed as
open item 50-275/88-04-02.
Discussion with operational
personnel
identified that
since flowmeter FI-929 is not required to be calibrated,
and the
STP did not require verification of the actual
flow rate,
the actual
flow rate reading
may not have
received the
same attention
as other data recorded in this
STP.
It was also identified that operating personnel
had
not received
any recent training on section
XI IST
testing, to explain why it is important for subsequent
pump testing to be performed at the
same reference
values.
Discussion with the engineering
group identified that the
licensee
has
had
some problems in the past with personnel
making their own interpretations
of procedure
instructions,
but all recent training has
been emphasizing
procedure
compliance.
This is another
example of plant
personnel failing to follow procedure,
a similar example
was identified as
open item 50-323/87-43-03,
in report
number 50-323/87-43,
dated January
20,
1988.
Evidently
additional
management
attention is required in this area,
as there
has already
been
some past problems
and
additional training provided.
The licensee
stated that
they would review this procedure
along with similar
procedures,
as discussed
in paragraph
2.b of this report,
and change
the procedures
as required to ensure that the
establishment
of volume 9 reference
values is verified and
checked
as part of the test acceptance
criteria.
Along
with the above action, the licensee
stated they were
planning on providing additional training to their
personnel
on Section XI IST surveillance testing
and
procedure
compliance.
Also, during performance of this STP, paragraphs
4.a.3
and
4.a;4 of the data sheet required recording both inboard
and'utboard
pump bearing lube oil (L.O.) temperatures
f'rom TIC-604 and TI-606.
The installed
pump thermometers
were not labeled
on the pump,
nor identified on the
drawing used during performance of the test.
The licensee
stated the subject
thermometers will be labeled or tagged
as required.
This item will be followed as
open item
50-275/88-04"01.
Based
on the above observations
and the fact that Subsection
IWP-3100 of section
XI of the
ASME code states
in part,
"The
resistance
of the system shall
be varied...until
the measured
flow rate equals
the corresponding
reference.",
the failure to
obtain the reference
flow rate of 300 1 5 gpm during the
0
performance of this
STP is an apparent violation
(275/88-04-03).
e.
ualit
Assurance
Involvement with IST Actives
During this inspection,
the licensee identified that the latest
audits of IST activities,
had
been
performed
and reported in the
following audit reports.
Audit 86174T - report date of April 7,
1987
Audit 87230T - report date of October
19,
1987
The inspector
reviewed the applicable sections of these reports,
and
did not identify any areas
of concerns.
Within the areas
inspected,
two violations were identified.
3.
~Ei
N
The inspector
met with a licensee
representative
identified in paragraph
1,
on February
12,
1988.
The scope of the inspection
and findings up to
that date were discussed.
The inspector identified that he had requested
some additional
information from the licensee
and that this would be
reviewed in the region,
and the inspector's
findings identified in this
report.
In subsequent
telephone
discussions,
between
the inspector
and
licensee,
after returning to the region, the licensee
requested
that the
report period
be held open until February 22,
1988 so they could provide
some additional
responses
to the inspector's
questions.
k'