ML18005A223
| ML18005A223 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/19/1987 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A224 | List: |
| References | |
| 50-400-87-39, NUDOCS 8712020340 | |
| Download: ML18005A223 (11) | |
See also: IR 05000400/1987039
Text
cate
REgIr
(4
0
.
csO
sI ~*y4
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report No.:
50-400/87-39
Licensee:
Carolina
Power and Light Company
P.
0.
Box 1551
Raleigh,
NC
27602
Docket No.:
50-400
License No.:
Facility Name:
Harris
1
Inspection
C
d c +ed:,
ember 2-6, 1987
,,n
Inspect r:
n
r e
Approv d by:
a e,
>e
M
e ials and Processes
Section
D vi ion of Reactor Safety
SUMMARY
, -6
a
e
cygne
ll ]>
te
>gne
Scope:
This routine,
unannounced
inspection
was
conducted
in the
areas
of'nservice
testing (IST) of pumps
and valves
(73756).
Results:
No violations or deviations
were identified.
87>aOa0340 87'24
ADQCK 05000400
6
REPORT
DETAILS
1.
Persons
Contacted
Licensee
Employees
- H. R. Banks,
Manager Corporate Quality Assurance
- M. M. Pugh, Technical
Support ISI
- S.
M. Pruit, Technical
Support ISI
- M. West, Technical
Support ISI
D. Tibbits, Regulatory Compliance
Other
licensee
employees
contacted
included
engineers,
technicians,
operators,
and office personnel.
NRC Resident
Inspector
- G. F. Maxwell, Senior Resident
Inspector
+Attended exit interview
2.
Exit Interview
The inspection
scope
and findings were
summari'zed
on
November
6,
1987,
with those
persons
indicated in paragraph
above.
The inspector described
the areas
inspected
and discussed
in detail
the inspection findings listed
below.
No dissenting
comments
were received
from the licensee.
(Open)
Inspector
Followup Item 50-400/87-39-01:
"Full Flow Testing
of Check Valves," paragraph 5.g.(1).
The licensee
did not identify as proprietary any of the materials provided
to or reviewed
by the inspector during this inspection.
3.
Licensee Action on Previous
Enforcement Matters
(92701B)(92702B)
Not inspected.
4.
Unresolved
Items
Unresolved
items were not identified during this inspection.
5.
Inservice Testing
(IST) of Pumps
and Valves
(73756)
The inspector
reviewed
procedures,
observed
work activities
and reviewed
pertinent
quality records,
as
indicated
below,
to determine
whether
inservice
testing
regulatory
requirements
and licensee
commitments
are
being met.
The applicable
code for IST pumps
and valves is
ASME Boiler
and Pressure
Vessel
(ASME BSPV)
Code Section
XI 1983 Edition Summer
1983
Addenda
(83S83).
The licensee's
Pump
and
Valve Test
Program
became
effective
.on the date of Commercial Operation,
Nay 2, 1987,
and continues
to May 1,
1997.
a
~
The inspector
interviewed licensee/contractor
personnel
and reviewed
the below listed documents
to verify that the licensee
has
assigned
responsibilities
to
persons
and
organizations
for:
preparation,
review,
and approval of IST procedures;
scheduling of IST for normal
and increased
frequency testing,
performance of testing per approved
procedures;
performance
of post-maintanance
and post-modification
IST; proper certification
and calibration of IST instruments;
and
training for those
personnel
responsible
for implementing
procedures.
Documents
Reviewed
Identification
IST-203,
Rev.
3
Title
"ASNE Section
XI Pump and Valve Program
Plan"
MMM-019, Rev.
0
MMM-006, Rev.
6
ISI-111,
Rev.
1
"Post Maintenance Testing"
"Measuring
and Test Equipment Calibration
Program"
"Personnel
Training for ASME Section
XI Pump
Vibration Measurements"
b.
The inspector
reviewed
the
below identified procedures
for the below
valves
to
ensure
that
procedures
and
data
reflect all
requirements
of the appropriate edition of the
ASNE Code Section XI.
The
review
included
the following:
evaluations
of imposing
and
removing
increased
frequency testing
requirements;
evaluation
and
justification of changes
to test acceptance
criteria; compliance of
test instruments
to
10 CFR 50 and
ASME Code requirements;
performance
of positive testing of Category
whose safety function
is to open
and close; evaluation of Category
A valve leak test data
conducted
in accordance
with ASNE IWV-3426 and -3427 guidelines
and
including
containment
isolation
and
pressure
isolation
valves;
testing of safety
and relief valves in accordance
with ASNE IWV-3510
through
-3513; observation
of remote position indicators,
including
those
on the remote
shutdown panels, at least
once every two years to
verify that, valve operation is accurately
indicated;
and indication
that valve stroke times are
commensurate
with the capabilities of the
valve tested.
Identification
ISI-203, Rev.
3
Documents
Reviewed
Title
"ASME Section
XI Pump and Valve Program-
Plan"
OST-1106,
Rev.
2
OST-1028,
Rev.
3
Ch 3/2
"CVCS/SI System Operability quarterly
Interval
Mode 4-5-6"
"Containment Isolation Valve Operability
Post Maintenance
Interval 1-2-3-4-5-6"
OST-1007,
Rev. 2,
Ch 2/8 "CVCS/SI System Operability quarterly
Interval
Modes 1-2-3-4"
OST-1008,
Rev. 3,
Ch 3/1
"RHR Pump Operability quarterly Interval
Modes 1-2-3"
OST-1108,
Rev. 2,
Ch 2/4
"RHR Pump Operability quarterly Interval
Mode 4"
OST-1804,
Rev.
1,
Ch 1/2
"RHR Remote Position Indication and Timing
Test
18 Month Interval
Modes
5
8 6"
OST-1215,
Rev.
1,
Ch 1/8 "Emergency Service Water System Operability
quarterly Interval 1-2-3-4"
OST-1103,
Rev.
2
"Component Cooling Water ISI Valve Test
18
Month Interval
Modes
5 5 6"
OST-1316,
Rev. 2,
Ch 2/2 "Component Cooling Water System Operability
(Pump
1C-SAB in Service) quarterly
Interval
Modes 1-2-'3-4"
OST-1216,
Rev. 2,
Ch 2/2 "Component Cooling Water System Operability
(1A-SA and
1B-SB Pumps in Service)
quarterly Interval
Modes 1-2-3-4"
EST-211,
Rev. 2,
Ch 2/1
"Auxiliary Relief Valve Testing"
OST-1072,
Rev.
0
"CVCS/SI System
Remote Position Indication
Test Two-Year Interval
Mode 6"
Valve Records
Examined
Valve No.
Valve
Cat.
Valve
Valve
Class
~Size
in
Actuator/
Valve
~Te
~Sstem
1-CS-8
1-SI-263
1-SI-86
1-CC-128
1-RH-30
1-CH-54
1-SC-34
1-FP-357
Actuator T
e
A
2
A/C
3/4 II
10
1xl
Valve T
e
MO/GL
AO/GL
MO/GA
MO/BF
AO/BF
SA/RL
SA/CH
SA/CH
Chemical
8 Volume
Control
Safety
Injection
Safety
Injection
Component
Cooling
Residual
Heat
Removal
Essential
Chil led
Water
Emergency
Screen
Wash
Fire
Protection
MO - Motor Operated
AO - Air Operated
SA - Sel f
GL - Globe Valve
BF - Butter fly Valve
GA - Gate
RL - Relief
CH - Check
The inspector
reviewed all the above indicated procedures,
completed
since
commercial
operations. for the
above listed valve,
to verify
that
these
procedure
are
the latest
ones
approved
and that test
acceptance
criteria used
were valid for the component
being tested.
d.
The inspector
reviewed all the above indicated procedures,
completed
since
commercial
operations
for the
above listed valves, to verify
that inservice test results
were recorded
per the approved
procedures
and that data
was evaluated within the time constraints
delineated
in
the appropriate edition of the
ASME Code Section XI, Subsections
IWP
and
IWV.
e.
The inspector
reviewed data
from all the above indicated procedures,
completed
since commercial
operations for the above listed valves, to
verify that
IST data
was evaluated
per the requirements
of ASME Code
Section XI, Subsection
IWV, and
and
ensured
that
appropriate
followup actions
were taken.
f.
The inspector
examined
selected
records
to verify that
IST records
are
maintained
as
delineated
in
IWV-6000;
and
engineering
evaluations
are sufficient to justify changes
to reference
values
and
removal
of
increased
frequency
testing
requirements
should
be
documented
and reviewed;
g.
Relative to the above,
the inspector
made the following observations.
(1)
Valve No. 1-SC-34
a 3-inch check valve is required
by ISI-203 to
be full flow tested.
This testing
is
accomplished
with
OST-1215,
"Emergency
Service
Water System Operability quarterly
Interval
Modes 1-2-3-4."
OST-215,
Rev.
1, paragraph
1. 1 states
"to verify the operability of 1B-SB
ESW Screen
Wash
Pump
and
that its associated
discharge
check valve (1-SC-34)
passes
flow
in the forward direction."
The procedure
provides
no full flow acceptance criteria for the
pump
and
therefore,
no full flow acceptance
criteria for
1-SC-34.
The
above is the result of the fact that the screen
wash
pump flow is dependent
on system
demand.
In view of the
above, it is evident that the licensee
has not demonstrated
that
valve
1-SC-34 is exercised
to the position required to fulfill
its safety function as required
by IWV-3522.
IWV-3522 has
been
interpreted
by the Office of Nuclear
Reactor
Regulation
(NRR)
letter from D.
G. Eisenhut,
Director, Division of Licensing to
C.
E. Norelius, Director, Division of Engineering
and Technical
Programs,
Region III, dated
January 3,
1983,
which indicated
that
NRR has
found four methods
acceptable
to test check valves
in which the full stroke motion of the disk cannot
be directly
observed
or where there is no position-indicating device are
as
follows:
a.
By demonstrating that the valve can
pass
the full flow
which has
been
taken credit for in FSAR analyses.
b.
By showing that, for the measured
flow, the pressure
loss
through
the valve is
such that the valve could
only be fully open.
c.
By using
a mechanical
exerciser
which can
be observed
to move through
a full stroke.
d.
By partial
disassembly
of the valve
and
manually
moving the disc through
a full stroke.
-The inspector
noted that
a similar condition exists for OST-1315
relative to valve
1-SC-34.
The licensee
indicated that they
would review their
program relative to full flow check valve
tests
to assure
that those
valves are tested
consisted with the
NRR position
as stated
in the January
3,
1983 letter.
Pending
NRC review of the licensee's
actions
relative to the
above
issue, this matter will be identified as inspector followup item
50-400/87-39-01:
"Full Flow Testing of Check Valves."
(2)
Procedure
No. ISI-203,
Rev. 3,
on page
4 of 259 states
in part
that "Valve Stroke Direction:
Valves will be stroked
and timed
in their Safety-Related direction(s)."
Valve 1-SI-86 is stroked
and timed from closed to open in OST-1106
and open to closed in
OST-1028.
The licensee
indicated that they would review the
valve
program to assure
that valves are'tested
in a direction
consistent with the commitment in ISI-203.
(3)
Procedures
OST-1216
and
1106
reference
CPSL
letter
SHH10/14506101
MS-850167
(o)
dated
December
9,
1985,
which
states
in part:
"Increase-Test-Frequency-
This limit on
stroke
time
is
specified
by Section XI.
If a
valve
stroke
time
exceeds
this
value the test
frequency will be
doubled until corrective action is
taken."
The
above is not consistent
with
ASNE
B&PV Code
Section
XI
paragraph
IWV-3417 which requires test frequency,
when required
to be increased,
be increased
to once each
month instead of once
each
month and
a half.
The inspector
was
unable
to identify any examples
where test
frequency
increase
was actually necessitated
because
repairs to
valves
were
made within one
month of the identification of an
unacceptable
increase
in stroke time test results.
The licensee
indicated
that
they
would
review their
program
and
make
necessary
changes
to assure
that increased
frequency testing,
when required,
would be consisted
with the applicable
sections
of the code.
(4)
The inspector
noted that procedure
Nos.
OST-1315
and OST-1215,
produce
records
attesting
to
exercise
testing
of valve
No.
1-SC-34
by inference only.
The
same is true for procedure
No. OST-1103 for the
IWV-3300 testing of valve
No. 1-CC-128.
The licensee
indicated that they would review the valve test
procedures
relative to record clarity and
make
any necessary
changes.
Within the areas
examined,
no violations or deviations
were identified.
It
l
~