ML17278A333

Insp Rept 50-397/85-17 on 850506-10.Violation Noted:Failure to Follow ASME Code Requirements for Inservice Testing Program Procedures & Records

ML17278A333
Person / Time
Site:	Columbia
Issue date:	07/19/1985
From:	Clark C, Compton R, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17278A331	List: ML17278A330 ML17278A332 ML17278A333
References
50-397-85-17, NUDOCS 8508090106
Download: ML17278A333 (12)

See also: IR 05000397/1985017

Text

U. S.

NUCIEAR RE'GULATORY COMMISSION

REGION V,,

Report No. 50-397/85-17

Docket No. 50-397

o.

21

License

N

NPF

r

Licensee:

Washington Public Power Supply System

P. 0.

Box 968

3000 George Washington. Way

Richland,

Washington

99352

Inspection at:

WNP-2 Site, Benton County, Washington

Inspection conducted:

May 6-10,

1985

C.

A

ark,

R actor Inspector

Inspector:

~

ompton,

C Co

ultant

Facility Name:

Washington Nuclear Project No.

2

(WNP-2)

H

7/1 ES

Date Signed

7-i7-8>

Date Signed

Approved by:

. Young, Chief

Engineering Sectio

Date Signed

~Summa r

Ins ection on Ma

6-10

1985

(Re ort No. 50-397/85-17)

technical review of the program plan, procedures

and records pertaining to the

WNP-2 inservice testing program for pumps

and valves.

The inspection involved

a total of 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> onsite by one

NRC inspector

and one consultant.

Results:

In the areas

inspected,

one violation of NRC requirements

was

identified (failure to follow Code requirements

- paragraphs

3 and 4) and one

Unresolved Item was identified (adequacy of review of surveillance test

results

paragraph

4).

8508090106

850722

PDR

ADOCK 05000397

8

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DETAILS

Persons

Contacted

'"C.

M. Powers,

Plant Manager

"D. S. Feldman, Plant

gA Manager

M. Bartlett,

QA Supervisor

D. R. Kidder, Plant Engineering Supervisor

A. Wood,

System Engineer

M. Reis,

Sr. Mechanical Engineer

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"Denotes those attending

the exit meeting

on May 10,

1985.

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Xnservice Testin

(IST) 'Pro

ram Plan

f

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Inservice testing is required to 'be performed in nuclear power plants in

accordance

with the

ASME Boiler and Pressure

Vessel

Code by 10 CFR 50.55a(g).

The

ASME Code,Section XI, Subsections

IWP and

IWV outlines

the rules for inservice testing of pumps, and valves.

Revision

2 to the

WNP-2 "Pump and Valve Inservice Test Program Plan,

issued

November 3,

1983," is the document currently "detailing the scope,

implementation

and

administration of the IST program.

Revision

3 i's being prepared

to

substantially revise

and update

the program

and to reflect the results of

a March 1985 meeting between the licensee

and the

NRC Office of Nuclear

Reactor Regulation

(NRR) staff.

Implementation of the IST program requirements

began in December

1983 and

the program

was required to be fully implemented at the

commencement.

of

"commercial operation" in December

1984.

The WNP-2 IST program is

committed to compliance with the

1980 Edition of the

ASME Code with

addenda

through Winter 1981.

This program applies to

18 pumps

and

approximately

475 valves.

The IST Program Plan, including draft changes

for Revision 3,

was

reviewed for compliance with the applicable edition of the

Code

and the

requests

for relief detailed in the plan.

The types

and frequencies

of

tests

appear

to be in compliance with Code requirements.

There were no violations of NRC requirements

identified.

IST Pro ram Procedures

The WNP-2 IST Program Plan is implemented

through various site

procedures.

The following procedures

were reviewed for compliance with

the

ASME code,

the IST Program Plan and

10 CFR 50 Appendix

B

requirements:

Nuclear Operations

Standard,

NOS-34, Rev. 2, "Inservice Testing of

Pumps

and Valves"

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WNP-2 Operating

and Engineering

Test~ Procedure

8.3.1,

Rev. 2, "ISI

and Appendix J, Examination and Testing Program Administration and

Control"

WNP-2 Administrative Procedure

1.5.1,

Rev.

11, "Technical

Specification Surveillance Testing Program"

WNP-2 Administrative Procedure

1.3.7,

Rev.

7, "Maintenance

Work

Request,"

WNP-2 Maintenance

Procedure

10.2.8,

Rev. 4, "Testing and Repair of

Safety

and Relief Valves," J)eviations84-685,

84-1068,85-117,

and

85-377.

Various surveillance

procedures for pump and valve testing.

In general,

the above listed procedures

provided the information and

guidance

necessary

to adequately

manage

and control IST activities.

However, several discrepancies

and weaknesses

were noted.

(a)

(b)

Program Plan pump vibration monitoring details for acceptance

criteria for the type of measurement

(velocity or displacement)

and

location of vibration measurements

(pump or driver bearings)

have

not been properly translated

into the site surveillance

procedure

for the Diesel Oil Transfer

Pumps.

Test. data sheets

provide for

measuring

displacement

only on the pump outboard bearing.

Program

Plan relief request

RP-1 states

that vibration velocity (not

displacement) will be measured

and radial vibration readings will

also be taken at as close

as practical to the inboard

pump bearing.

There is no provision for the System Engineer to signoff for his

review of data sheets

and for documentation of the determination to

increase/decrease

test frequencies.

(c)

The safety

and relief valve test procedure

does not require that two

consecutive

acceptable lifttests

be achieved prior to acceptance

of

the valve.

This verification of repeatability is

a part of the

procedures

detailed in the

ASME Performance

Test

Code for safety and

relief valves.

(d)

(e)

The procedure for operability testing of the Diesel Oil Transfer

Pumps

does

not, provide for recording of storage

tank levels

and tank

correlating levels to pressure

as specified in Note A to the

"WNP-2

Pump Inservice Test Table" in the Program Plan.

Valve stroke timing/exercising'rocedures

did not have specific

precautions/requirements

to take data

on the first operation of the

valves.

Cycling of valves prior to the test of record could result

in stroke times not reflective of emergency condition operation.

Procedure

7.4.0.5.1 actually require,,cycling the

MSRV discharge

vacuum breakers

3 times prior to testing for operability.

This

approach is based

on general maintenance

information provided in a

vendor manual.

However, this does 'not provide all of the

operability assurance

intended, by ASME Section XI.

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The WNP-2 valve program does not provide for evaluation

and

corrective action of valve stroke times based

on the previous test

times

as required by ASME,Section 51, Subsection

IWV-3417.

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Failure to properly establish/implement

Code requirements, regarding the

proper evaluation of stroke times is an apparent violation of paragraph

4.0.5 of Technical Specifications

MPPSS Nuclear Project No.

2

(50-397/85-17-01).

t.

After a review of the findings noted above 'and in discussions

during the

inspection,

the licensee

stated to the senior resident inspector that the

Technical Department staff would review implementing procedures

against

Program Plan commitments

and requirements

and that the Program Plan

and/or procedures will be revised

as required.

This finding will be

carried, as

a Followup Item (50-397/85-17-02)

and will be 'examined

on

future inspections.

4.

IST Records

a

~

Selected

completed inservice test data sheets

were examined for the

following pumps for compliance with Section XI and site procedural

requirements:

RHR Pump

2A

Diesel Oil Transfer

Pump

1A

On RHR Pump 2A, two cases

were noted where tests

were accepted

as-is

when data

was outside of the acceptable

range.

Post-maintenance

testing

on 3/17/84 was accepted without any indication of increased

test frequency,

although

pump flow was in the alert range (high).

The surveillance test performed

on 11/6/84

was also accepted as-is,

but the data point, was in the action range of the attached

pump

curve.

In reviewing this discrepancy

the licensee

subsequently

determined that the curve in the procedure

on 11/6/84 was drawn

using tolerances

more restrictive than the

ASME Code allowed and

appears

also to have been

drawn erroneously.

Accurate drafting,

using

code allowed tolerances,

in a 12/4/84 revision to the

procedure

would place the test data in the acceptable

range.

For the 3/27/84 test

on the Diesel Oil (DO) Transfer

Pump

1A, an NCR

documenting

a discharge

pressure

in the action range

was

dispositioned

as "acceptable,"

because

the amount of specification

was within the accuracy of the pressure

gauge

used; 2.8/.

However,

ASME Section XI, Subsection

IVP-4110 requires pressure

instruments

to have at least

an accuracy +/- 2/ of full scale.

Also during this

test,

no vibration readings

were taken for the east-west

and

vertical directions.

For the 7/30/84,

10/17/84

and 1/14/85 tests of

DO Pump

1A there were no signatures

on the data sheet indicating the

review by the Shift Manager or the ISI Engineer.

On the 10/17/84

test of DO Pump

1A no vibration readings

were taken in the east-west

and north-south directions

and the attached strip chart indicated

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vibration velocity was measured,

'but the data sheet reflected

displacement.

The licensee

stated that the equality Assurance

organization would

perform specific reviews of IST program implementation including

proper evaluation of test results

and corrective actions.

The

question of the adequacy of test result reviews will be considered

an Unresolved Item (50-397/85-17-03)

and will be evaluated

during

a

future inspection.

Valves

A small sample of completed valve test data

sheets

were examined for

compliance with Code

and procedural

requirements.

Valves for which

tests

were reviewed included hydraulic

(HY) valves,

main steam

relief valve

(MSRV) discharge

vacuum breakers,

residual heat

removal

(MS) valves

(Procedure

7.4.5.1.8)

and reactor core isolation

cooling (RCIC) valves

(Procedure

7.4.7.3.3).

Other than the

deficiencies

already noted in paragraph

3 of this report only one

discrepancy

was noted.

For the

HY valves stroke tested per

procedure

7.4.0.5.12

no actual stroke times are recorded,

only an

indication that times were less

than

15 seconds.

This practice

prevents

trending of times

and thus possible early identification of

problems

and is another

example of failure to properly

establish/implement

code requirements

and is an apparent violation

of paragraph 4.0.5.a of technical specifications

WPPSS Nuclear

Project No. 2, which was discussed

in paragraph

3 (50-397-17-04).

General

ASME Section XI, Subsections

IWP-6210,

IWP-6250 and IWV-6210 require

summary listing of pumps

and valves to document the current status

of testing

and the corrective actions

taken with regard to pumps.

The licensee

could not provide any summary listings as required by

Code.

Consolidation

and tabulation of test data is necessary

to

provide, in a practical usable format, the information needed

by

system engineers

to evaluate

component performance.

This is

especially beneficial in meeting

commitments

and requirements for

pump operability, valve stroke timing and relief valve testing.

Due

in part to this lack of required

summaries,

the inspectors

had

difficulty in tracing records

and determining the source

and

accuracy of reference

values.

This failure to implement

Code

requirements

into site procedures

is another

example of an apparent

violation of paragraph

4.0.5.a of Technical Specifications

WPPSS

Nuclear Project No. 2,

as discussed in paragraph

3 (50-397-17-05).

The licensee is developing

a computerized

performance

monitoring

program that will potentially provide very useful trending

information to the engineers

responsible for the pump and valve IST

program.

Based

on a review of preliminary outputs the

NRC

inspectors

consider this program will be an excellent

engineering/management

tool when established.

The inspectors

discussed

the role of the licensee's

(}A organization

in the

XST program with site

gA management.

Only surveillances

(not

audits)

are performed by site

gA personnel.

Surveillances in

January

and July 1984 addressed

the IST program.

A thorough

surveillance of program implementation is listed on the Annual

Surveillance Plan, but had been postponed

pending issuance

of

Revision

3 to the program plan.

No corporate audits of the IST

program had yet been performed.

Other than already indicated,

there

were no violations of NRC

requirements identified.

The inspectors

met with licensee

management

personnel

denoted in

paragraph

1 at the conclusion of the inspection

on Hay 10,

1985.

The

scope,

observations

and findings of the inspection were discussed.

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