ML18101A363
| ML18101A363 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/30/1994 |
| From: | Dempsey D, Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18101A360 | List: |
| References | |
| 50-272-94-21, 50-311-94-21, NUDOCS 9412060151 | |
| Download: ML18101A363 (12) | |
See also: IR 05000272/1994021
Text
DOCKET/REPORT NOS:
LICENSEE:
FACILITY:
DATES:
INSPECTORS:
APPROVED BY:
SCOPE AND FINDINGS:
9412060151 941130
ADOCK 05000272
G
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/94-21
50-311/94-21
Public Service Electric and Gas Company
Salem Nuclear Generating Station, Units 1 & 2
Hancocks Bridge, New Jersey 08038
September 12-16, 1994, & October 19-21, 1994
Douglas Dempsey, Reactor Engineer
Oou~~i'3tor"'"tngi neer
Systems Section
Division of Reactor Safety
Systems Section .
Division of Reactor Safety
This inspection evaluated compliance with NRC
regulations, American Society of Mechanical Engineers
(ASME) Code requirements, and commitments made in the
licensee's approved inservice testing program.
The
licensee's resolution of anomalies identified in
previous NRC Safety Evaluations also was reviewed.
Two violations of NRC requirements were identified
involving failure to test certain safety system check
valves within the periodicity specified by the ASME
Code, and failure to assure that conditions adverse to
quality are identified and corrected promptly.
Two
unresolved items were opened involving technical
review of changes to pump and valve test acceptance
criteria, and inadequate or incomplete cold shutdown
justifications. Two previous unresolved items were
closed. The executive summary provides additional
assessment .
EXECUTIVE SUMMARY
SALEM IST INSPECTION
The IST program at Salem Units 1 and 2 was reviewed to verify conformance with
the American Society of Mechanical Engineers Boiler and Pressure Vessel Code
and NRC requirements. Overall, the program satisfied the requirements, in
that the pumps and valves in the systems selected for review generally were
being tested properly, and the test results were evaluated and trended
appropriately.
An initiative to use spectrum analysis to assess the condition
of pump bearings exceeded Code requirements and contributed to safe operation
of the facility.
However, several program shortcomings indicative of weak management oversight
were identified during the inspection.
For example,* certain safety system
check valves were not tested in accordance with the Code or program
commitments (VIO 50-272 and 50-311/94-21-03); several requests for relief from
Code test requirements were not updated to reflect the responses to program
anomalies which were identified in an NRC safety evaluation; and cold shutdown
justifications often were documented incompletely.
In addition,
clarifications to some cold shutdown justifications, provided during the
inspection, did not adequately justify postponement of the tests specified by
the Code.
(URI 50-272 and 50-311/94-21-02)
Although the Quality Assurance organization performed comprehensive and
critical program audits, followup of audit findings by the line organization
were not always effective in assuring that conditions adverse to quality were
corrected. The failure to reconfirm pump vibration reference data following
corrective maintenance was cited because remedial action for two previous
similar audit findings was not adequate to prevent recurrence. A second
example of inadequate corrective action was identified during review of an
unresolved item (URI 50-311/94-13-01) involving recurring unexpected
actuations of a safety injection pump discharge relief valve during
surveillance testing (VIO 50-311/94-21-04).
An unresolved item (50-272 and 50-311/94-21-01) was opened regarding review of
changes to the baseline data sheets for safety-related pumps.
The data sheets
contain the acceptance criteria for IST surveillances. While the levels of
review appeared to be adequate from a technical standpoint, it was not
apparent to the inspectors that the administrative review requirements of the
technical specifications were being met.
The corrective actions implemented in response to a violation (50-272 and
50-311/93-27-01) involving leakage of residual heat removal system hot leg
injection check valves were reviewed, and the item was closed .
ii
DETAILS
1.0
BACKGROUND
Through 10 CFR 50.55a, "Codes and Standards," the NRC requires certain pumps
and valves designed and constructed according to the American Society of
Mechanical Engineers (ASME) Boiler and Pressure Vessel Code to be designed to
enable inservice testing (IST).Section XI, Subsections IWP and IWV, of the
Code provide requirements for testing to assess the operational readiness of
pumps and valves. These requirements are included as surveillance
requirements in plant Technical Specification (TS) 4.0.5, which requires
testing of pumps and valves per ASME Section XI, except where specific written
relief is granted by the Commission.
The purpose of IST is to assess the
operational readiness of pumps and valves, to detect degradation that might
affect component operability, and to maintain safety margins with provisions
for increased surveillance and corrective action.
NRC Generic Letter (GL) 89-
04 provides guidance on meeting the requirements of 10 CFR 50.55a(f),
"Inservice Testing Requirements."
The licensee currently is implementing the second 10-year interval of the IST
program as described in Revision 2 (October 3, 1989) of its program submittal
to the NRC.
The submittal included requests for relief from several Code
requirements, and Public Service Electric and Gas Company's (PSE&G) response
to the regulatory positions contained in GL 89-04, "Guidance On Developing
Acceptable Inservice Test Programs," dated April 3, 1989.
NRC review of the
program entailed verification that the program was based on the applicable
Code edition and addenda, that all appropriate pumps and valves were tested,
and that requests for relief from the provisions of Section XI, Subsections
IWP and IWV were acceptable.
An NRC letter, dated October 9, 1992, forwarded
the safety evaluation (SE) which provided the results of the NRC staff's
review of the Salem IST program.
The SE discussed program anomalies which
were identified during the review and requested additional information
regarding certain relief requests.
PSE&G's response to the items in the SE
was submitted to the NRC on October 12, 1993.
In another SE, dated
April 15, 1994, the NRC staff approved the revised relief requests and
concluded that PSE&G had addressed the program anomalies appropriately.
2.0
INSPECTION DETAILS (TI 2515/114)
The inspectors used NRC Temporary Instruction 2515/114, "Inspection
Requirements for Generic Letter 89-04, Acceptable Inservice Testing Program,"
to assess the current IST programs at Salem Units 1 and 2.
Primarily,
components in the auxiliary feedwater, safety injection, and containment spray
systems were selected for review.
Plant risk and the number of relief
requests and program anomalies identified in the NRc' Safety Evaluation Reports
were considered in the selection of these systems.
2.1
General IST Program Review
IST program documents were reviewed and licensee personnel were interviewed to
verify that program responsibilities were assigned and that requirements were
being implemented effectively.
2
The licensee currently is implementing the second IO-year IST program, which
began on June 30, 1987, and is described in the "Salem Generating Station IST
Program Manual."
The manual specifies program organization and *
responsibilities; the pump and valve testing to be performed pursuant to
Section XI, Subsections IWP and IWV of the Code (1983 Edition through Summer
1983 Addenda), frequency of testing; and requests for relief from Code
requirements. Administrative procedure NC.NA-AP.ZZ-0070(Q), "lnservice
Testing And MOV Testing Programs," Revision 2, establishes personnel
responsibilities and specifies the general requirements for implementing the
IST program.
The program at both units is administered primarily by one full-time IST
Engineer who coordinates the efforts of various implementing departments
(Operations, Maintenance, Planning).
The inspector found that the roles and
responsibilities defined in the two program documents were inconsistent, in
part, and did not always depict current practices accurately.
For example,
the program manual was not updated along with the administrative procedure to
show the change in responsibility for planning and scheduling from the
maintenance manager to the station planning and outage managers; and neither
document reflected the IST Engineer functions have been assumed by the systems
engineers.
With some exceptions, the inspector found that adequate administrative
controls were in place to schedule and track the performance of tests; to
ensure that reference values and acceptance criteria were met; to assure that
reference values were verified or reestablished following component
maintenance or replacement; to perform post-maintenance testing prior to
restoring a component to service; and to analyze and trend test data.
However, the inspector observed, and confirmed through discussions with the
Technical Support Manager and the IST Engineer, that the latter is constrained
by the day-to-day demands of program administration from performing more
programmatic tasks such as general program reviews, updates, and self-
assessments.
As a result, the program deficiencies listed below had been
identified to the licensee during QA audits and NRC program reviews, but
remained uncorrected.
Relief requests were not uniquely identified, and did not
distinguish between relief requests and cold shutdbwn test
frequency justifications, for which no NRC relief is required
Some components were tested as required by the Code, but were not
listed in the program
Component Requirement Review Sheets were not updated to identify
upgraded surveillance procedures
Relief requests were not updated to reflect the licensee's
responses to the anomalies identified in NRC safety evaluations
Cold shutdown justifications frequently were not detailed or
documented adequately
3
The Technical Support Manager acknowledged a need to reduce the IST Engineer's
administrative burden to facilitate the performance of program reviews and
self-assessments.
However, plans to ameliorate the condition were inchoate,
and no specific schedule or action plan was presented during the inspection.
2.2
IST Procedures
IST procedures were reviewed to confirm that instructions were sound
technically, and that components were tested in accordance with the
requirements of ASME Code Section XI and the regulatory positions of GL 89-04;
that appropriate quantitative or qualitative acceptance criteria were
established; and that procedures were reviewed and approved per license
requirements.
IST procedures were revised during the licensee's procedure upgrade program
and uniformly were found to be of high quality. Particularly noteworthy were
the clear, step-by-step processes outlined for performance of post-maintenance
retests, establishment or reverification of baseline values, required actions
for components in the alert and required action ranges, and disposition of
nonconforming conditions or unacceptable test results. Overall, acceptance
criteria were appropriately quantitative and unambiguous.
However, in pump
test procedure Sl-OP-ST.SJ-OOOl(Q), "Inservice Testing - 11 Safety Injection
Pump," Revision 2, safety injection pump discharge check valves ll,12SJ34 and
minimum flow check valves ll,12SJ64 were confirmed closed by verifying that
the safety injection pump discharge pressure gage in the idle loop was
"significantly lower" than the discharge pressure of the pump being tested.
ASME Section XI, Subarticle IWV-3522(a) allows the use of pressure indication
as a means to verify that check valves perform their closure safety function.
The licensee's test did not provide sufficiently definitive assurance (viz.
vague acceptance criteria) that the check valves were closed. The licensee
promptly revised the safety injection pump procedures to provide more
quantitative acceptance criteria.
The acceptance criteria for pumps in the IST program are maintained in a Pump
Test Baseline Data Manual located in the Shift Supervisor's office, rather
than in individual surveillance procedures.
Pump test baseline data sheets
are based directly on the quantities and allowable ranges specified in
Section XI, Tables IWP-3100-1 and IWP-3100-2.
The sheets are prepared by the
IST Engineer, reviewed by a system engineer, and approved by an engineering
supervisor in accordance with procedure SC.TE-TI.ZZ-0028(Q), "Pump Inservice
Testing Results Analysis." Deviations between new and previous pump reference
values are documented either by an engineering memorandum, an engineering
evaluation, or a safety evaluation pursuant to 10 CFR 50.59.
Technical Specifications (TS) 6.8.2 and 6.5.3.2 require procedure changes to
be reviewed independently by a designated Station Qualified Reviewer (SQR) and
approved by the appropriate department head, or, if an "on the spot change",
by two members of the management staff, at least one of whom holds a Senior
Reactor Operator license. The inspector questioned whether review and
approval of changes to the pump test baseline data sheets were consistent with
TS requirements.
The licensee stated that preparation of the data sheets did
not constitute a change in technical content when changed in accordance with
4
procedure SC.TE-TI.ZZ-0028(Q), and that review by an SQR was not required.
This item is unresolved pending further NRC review of the pump test baseline
data sheet approval process.
(URI 50-272 and 50-311/94-21-01)
2.3
Pump Testing
Surveillance procedures and performance records were reviewed for the safety
injection, containment spray, and auxiliary feedwater pumps against ASME
Section XI requirements for IST of pumps.
The test frequencies, quantities
measured, and allowable ranges were consistent with those specified in Article
IWP-3000.
Test instruments were verified to meet th~ accuracy requirements of
Table IWP-4110-1 of the Code.
The licensee properly dispositioned test
results which entered "alert" or "required action" ranges and maintained a
computerized database to trend pump performance.
The inspector noted that following replacement of the #22 auxiliary feedwater
pump impeller in May 1993, the licensee validated pump performance by
comparing differential pressure versus flow rate at only a single point along
the original (1970) pump curve.
The data was taken with the pump operating in
minimum flow recirculation (400*gallons per minute).
Notwithstanding that the
comparison satisfied the minimum requirement of Section XI, Subarticle IWP-
3111, the inspector considered that additional measurements taken at
progressively higher flow rates would have provided a greater level of
confidence in pump performance.
The licensee consulted the pump manufacturer,
who stated that the new impeller differed from the original only in material,
and that the original performance curve remained valid for the refurbished
pump.
The inspector discussed this with the Technical Support Manager, who
stated that pump performance would be validated at higher flow rates when a
suitable opportunity occurred.
In reviewing test data for the safety injection pumps, the inspector found
that the licensee uses spectrum analysis to assess the condition of the pumps
in the IST program.
The licensee also trends vibration levels for drivers as
well as pumps.
The inspector concluded that the licensee was utilizing
vibration data effectively, and that the monitoring program exceeded Code
requirements.
2.4
Valve Testing
Test frequency, methods, acceptance criteria, and corrective actions for
several types of valves in the selected systems were reviewed and found to be
satisfactory with the exceptions noted below.
The appropriate containment
isolation valves listed in TS Table 3.6-1 for both units were included in the
IST program as Category A or A/C valves.
As documented in the IST program,
these valves are leak rate tested pursuant to 10 CFR 50, Appendix J, in lieu
of Subarticles IWV-3421 through 3425 of the Code.
The inspector identified
several Unit 1 pressure isolation which are not listed in TS Table 4.4-4.
However, all pressure isolation valves at Unit 1 were verified to be included
in the IST program as Category A or A/C valves and tested per procedure
Sl.OP-ST.SJ-0020(Q), "Periodic Leakage Test - RCS Pressure Isolation Valves,"
Revision 3.
The licensee stated that a revision to the TS table which adds
5
the missing valves currently is being reviewed.
The inspector reviewed
completed work order packages for valves 11-14SJ139 and 11-14SJ144, verified
that the valves were tested individually, and concluded that the test results
were satisfactory.
Procedures and maintenance records for power-operated valves were assessed
against the stroke time criteria of Section XI, Subarticles IWV-3413(b} and
3417, and Position 6 (rapid-acting valves} of Generic Letter 89-04, as
applicable. Subarticles IWV-3411 and 3412(a} require Category A and B valves
to be exercised at least once every three months unless operation is not
practical during power operation. Valves which cannot be exercised during
power operation are to be specifically identified by the licensee and full-
stroke exercised during cold shutdowns.
The inspector evaluated several cold
shutdown justifications and verified on the basis of the program
documentation, that most of the valves could not practically be exercised
during power operation. However, several examples of inadequate cold shutdown
justifications were identified.
Accumulator outlet isolation valves ll-14SJ54 and 21-24SJ54 were
exercised on a cold shutdown frequency.
However, the valves were
not listed, and no cold shutdown justification was included, in
the IST program beyond a simple statement in a Component
Requirement Review sheet that the valves are required by TS to be
open.
The justifications in the program documents for RHR heat exchanger
outlet valves 11SJ45 and 12SJ45 were inconsistent. The basis
stated in the relief request was that opening the valves during
power operation would allow the refueling water storage tank to
backflow into the containment sump, while the Component
Requirement Review Sheet stated that the valves could not be
exercised'because they were interlocked with the SJ44 valves.
RHR supply to containment spray header valves 11CS36 and 12CS36
were tested during cold shutdown to avoid spraying down the
containment.
The inspector was unable to conclude from the program documents that the
licensee was justified in not testing the valves listed above at the frequency
prescribed by the Code. This issue is unresolved pending review of additional
information from the licensee.
{URI 50-272 and 50-311/94-21-02)
The inspector identified that charging pump suction check valves ISJ3 and 2SJ3
were partial-stroke exercised during cold shutdowns and full-stroke exercised
during refueling outages.
The safety function of the valves is to open to
permit the flow of borated water from the refueling water storage tanks to the
10 CFR 50.55a{f) requires IST of certain ASME Code 1,
2, and 3 valves per Section XI of ASME Code except where specific written
relief has been granted by the Commission.
The tests performed by the
licensee deviate from the requirements of Section XI, Subarticles IWV-3521 and
3522, which state that check valves are to be exercised at least once every
three months unless such operation is impractical during power operation. If
6
only limited operation is practical during power operation, the valve shall be
partial-stroke exercised during power operation and full-stroke exercised
during cold shutdowns.
In a SE dated October 2, 1992, the NRC denied a relief
request to full-stroke exercise the valves during refueling outages, but
granted interim relief to permit the licensee to evaluate the practicality of
testing the valves during cold shutdown.
The licensee responded to the SE on
October 12, 1993 by withdrawing the relief request and stating that the valves
would be tested during cold shutdowns.
The inspector concluded that since
October 12, 1993, valves 1SJ3 and 2SJ3 were not tested in accordance with ASME
Code Section XI during cold shutdowns. This is the first example of a
violation of 10 CFR 50.55a(f}.
On being informed of the discrepancy described above, the licensee determined
on October 17, 1994, that check valves 1PR25 and 2PR25 also were not being
tested in accordance with the Code or as committed to the NRC in its SE
response.
The valves are located in the common discharge line of the
emergency core cooling system relief valves and function to permit flow from
the relief valves to the pressurizer relief tank.
Per Position 2 of GL 89-04,
the NRC SE granted relief from the test frequency and method requirements
Subarticles IWV-3521 and 3522, and authorized the licensee t9 partial-stroke
exercise the valves quarterly, and disassemble and inspect the valve internals
each refueling outage.
However, since October 9, 1992, the licensee has not
disassembled and inspected the valves. This is the second example of a
violation of 10 CFR 50.55a(f}. In support of an interim determination of
operability, the licensee relied, in part, on records of successful partial
flow tests which were performed per procedure Sl.OP-ST.ZZ-0003(Q}, "In Service
Testing - Miscellaneous Valves." The inspector verified through review of
test data that the partial-stroke exercise tests had been performed
satisfactorily. The inspector concluded that these deviations from the Code
test requirements were significant in that, in combination with the other
program deficiencies described above, they indicated poor licensee followup of
program commitments and weak management oversight of the IST program.
Consequently, the violations of 10 CFR 50.55a(f} will be cited.
(VIO 50-272
and 50-311/94-21-03}
Generic Letter 89-04, Position 2, states that check valves which are
disassembled and inspected in lieu of full-stroke exercising must be partial-
stroke exercised, if possible, after reassembly.
Several relief requests to
disassemble and inspect check valves were granted by the NRC in the IST
program SE with this proviso.
The inspector reviewed procedure NC.NA-AP.ZZ-
0050(Q}, "Station Testing Procedure," Revision 2, and observed that it
contained detailed retest instructions which are correlated explicitly with
ASME Code,Section XI requirements.
The inspector also verified throug~
review of work order packages, that the licensee partial-stroke exercised the
check valves following reassembly.
However, the inspector noted that the
quality of documentation for the retests varied considerably.
In most cases,
retest documentation consisted of a "sat" notation in the work order, while in
a few instances the original disassembly work order and test procedure were
referenced.
The licensee acknowledged the inconsistencies and agreed that
improved documentation of retests was warranted .
7
Test records and work order packages of pressurizer and steam generator Code
safety valves were reviewed and setpoints were verified to have been adjusted
within a tolerance of plus or minus 1.0 percent in accordance with the TS.
The inspector noted that for scheduling convenience, the licensee tests all of
its Code safety valves one time every five years. This practice takes
advantage of an ambiguity in the requirements in the 1983 Edition of Section
XI, Table IWV-3510-1, which provides a testing schedule for groups of valves
that should be tested every refueling outage.
The inspector determined that
Section XI Interpretation XI-1-89-25 of Subarticle IWV-3511 does not require a
minimum number of safety valves to be tested each refueling outage, and
concluded that the licensee's schedule was acceptable.
2.5
Evaluation of Anomaly Responses
The NRC SE for the Salem IST program contained a list of 19 anomalies where
inconsistencies and omissions in the program were noted.
The inspector
evaluated the anomaly responses contained in the licensee's submittal dated
October 12, 1993, and found, with two exceptions, that the responses had been
implemented satisfactorily. Anomaly No. 9 involved testing of check valves
1SJ3 and 2SJ3, which is discussed in Section 3.4 above.
Anomaly No. 15 stated
that some relief requests that were granted to permit full-stroke exercising
of check valves during refueling outages did not document adequately the
justification for not performing the tests during cold shutdowns, and that the
relief requests should be revised to provide this information.
In response,
the licensee stated that justification would be provided where valves were not
being tested per the ASME Code.
The inspector noted that the relief requests
for valves 11-14SJ139 and ll-14SJ144 were not updated to reflect the
licensee's statement, but verified that the valves were being tested as
required.
The inspector concluded that this was another example of lack of
followup and weak program oversight by licensee management.
3.0
IST PROGRAM AUDITS AND SELF-ASSESSMENTS
The licensee's quality assurance organization performs audits of the IST
program approximately every other year.
The reports of audit numbers90-011
(October 1990);91-012 (September 1991); and 93-012 (December 1993) were
reviewed.
The 1990 and 1993 audits were performed with the assistance of a
technical specialist from outside of the company, and focused on compliance
with license requirements (Section XI of the ASME Code), and broader
performance factors such as interdepartmental coordination and communication,
training, management support, and self-assessments. The inspector found the
audits to be comprehensive and self-critical. Audit findings (as opposed to
recommendations) were tracked via the licensee's action request system, and
the quality assurance organization was aggressive in insisting on timely
closeout of items.
Notwithstanding the above, the inspector found several recurring indications
of weakness in IST program implementation involving pump vibration reference
values following corrective maintenance.
ASME Code Section XI, Subarticle
IWP-3111 requires that when a reference value or set of values may have been
affected by repair of a pump, a new reference value or set of values must be
determined, or the previous values reconfirmed, by an IST run prior to, or
8
within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of returning the pump to normal service.
In audit 90-011, the
licensee identified that this requirement had not been met following repair of
an auxiliary feedwater pump in November, 1989. This was recognized as a
repeat of a similar finding in a 1988 program audit.
In spite of actions
taken in 1991 to prevent recurrence, the 1993 auditors found that new
reference values were not taken (or previous values reconfirmed) following
replacement of thrust bearings in the #21 component cooling water pump in July
1993.
The inspector considered two common elements detailed in the audit
reports to be significant.
Audit 93-012 stated that the operations department had no specific
direction for a method of transmitting completed IST data to the
technical department.
The IST Engineer stated that in 1993 he did
not routinely receive test data. Audit 90-11 noted a lack of
procedure controls to ensure that pump and valve test data is
transmitted to the IST Engineer.
Audit 93-012 stated that the knowledge level of IST program
requirements was not consistent among personnel with program
responsibilities, and that operators lacked specific training on
the IST program and administrative procedures.
Corrective actions
recommended in the auxiliary feedwater pump action request in
audit 90-011 included training and indoctrination of operations
personnel on IST program requirements. This item was closed in
audit 91-011 .
The inspector noted that the actions implemented in response to the 1993 audit
finding did not include consideration of why the previous corrective actions
had not been effective in preventing recurrence of the event.
The licensee failed to establish new vibration reference values, or to
reconfirm old reference values following corrective maintenance on the #21
component cooling water pump on July 6, 1993, despite identification of and
corrective action for similar occurrences identified in quality assurance
department audits in 1988 and 1990. This is the first example of a violation
of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," which requires
measures to be established to assure that the cause of a significant condition
adverse to quality are taken to preclude repetition.
The inspector observed that the licensee has not performed any self-
assessments of the IST program, and learned in discussions with the IST
Engineer and the Station Technical Support Manager that, despite a strong
recommendation from the technical specialist in the 1993 audit, there are no
plans to do so at this time. In addition, the inspector learned that the
licensee does not plan to implement a new (Summer, 1994) requirement in
administrative procedure NC.NA-AP.ZZ-0070(Q) to perform a biannual review of
IST program submittals to evaluate the need for updated submittals to the NRC.
Finally, the inspector was informed that in anticipation of the resources
which will be required, the licensee does not intend to update or revise
extensively the present IST program prior to the third ten-year test interval
which is scheduled for June 30, 1997.
9
4.0
PREVIOUSLY-IDENTIFIED ITEMS
4.1
(Closed)
URI 50-311/94-13-01 Safety Injection Pump Discharge Relief
Valve Leakage
This item involved recurring leakage through safety injection pump discharge
relief valve 22SJ39 during surveillance testing of safety injection pumps on
March 31 and June 22, 1994. This relief valve is one of three whose safety
function is to protect the safety injection system from overpressure due to
reactor coolant system {RCS) backleakage through the injection line check
valves.
The leakage was significant because of the potential for reduced and
delayed injection flow to the RCS during a loss of coolant accident, and
depletion of refueling water storage tank inventory via the diverted flow.
Operators first noticed the leakage while testing the No. 21 safety injection
pump on March 31, 1994.
The system engineer was informed verbally of the
condition, but no formal request for engineering assistance was initiated.
When the pump was operated again on April 3, with no apparent valve leakage,
the operators concluded that the safety injection system was operable, and no
further evaluations regarding possible causes or safety impact were performed
until the problem recurred on June 22.
At this time, a formal request for
engineering assistance was made and a troubleshooting plan was implemented.
Ultimately, the leakage was determined to have been caused by relaxation of
the valve operating spring.
The valve was refurbished, satisfactorily bench-
tested, and installed in the system on June 28, and remained seated during
subsequent pump operation.
In Engineering Memorandum 94-117, dated
July 13, 1994, the licensee addressed the safety concerns mentioned above, and
concluded that the safety injection system had been operable while the relief
valve was lifted.
The inspector found the operability evaluation to be technically acceptable,
and this unresolved item is closed. Notwithstanding the outcome, the
inspector also concluded that the final operability determination and action
to prevent recurrence had not been performed in a timely fashion, commensurate
with the potential safety significance of the problem. This is the second
example of a violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective
Action," which requires conditions adverse to quality to be identified and
corrected promptly.
{VIO 50-311/94-21-04)
4.2
(Closed)
VIO 50-272&311/93-27-01 Corrective Action For Check Valve
Leakage
This violation involved a routine practice of manipulating certain safety-
related valves without an approved procedure.
During the startup of Unit 2 on
December 30, 1993, the NRC noted that valves RH19 and SJSO were positioned
during reactor coolant system {RCS)*pressurization to establish a differential
pressure sufficient to seat the residual heat removal {RHR) system injection
header check valves and to stop backleakage from the RCS to the RHR system.
Other concerns included the licensee's failure to develop a troubleshooting
procedure or to initiate a work order for the activity in accordance with
'
10
administrative directive SC.OP-DD.ZZ-AD46(Q), "Troubleshooting Abnormal Plant
Conditions," (AD-46). Also, the resulting lack of historical data on the
check valves with which to assess potential repetitive failures or the need
for corrective action to precluded recurrence.
The licensee responded to the violation in a letter, dated March 10, 1994, in
which it committed to revising the operations department standing orders to
clarify the application of Directive AD-46 and to issue a procedure for coping
with safety injection and RHR system check valve leakage. The standing orders
and draft Procedure Sl/S2.0P-SO.SJ-0003(Q}, "RCS Pressure Isolation Valves
Check Valve Reseating," were reviewed and found to be acceptable and
consistent with the commitments made in the violation response.
The inspector
also noted that both documents require a work order to be generated, thus
creating a historical trending record of check valve leakage.
Based on these
actions, this violation is closed.
5.0
MANAGEMENT MEETINGS
The inspector met with those principals denoted below on September 16 and
October 21, 1994, to discuss the preliminary inspection findings.
The
licensee acknowledged the findings and conclusions contained in this report
with no exceptions taken.
No proprietary information was reviewed during this
inspection.
J. Fest
s. La Bruna
J. Morrison
M. Morroni
H. Onorato
M. Pastra
M. Pike
F. Thomson
E. Villar
s. Faulkner
F. Kaminski
E. Karpe
H. Onorato
K. Pike
c. Bajwa
c. Marschall
T. Fish
J. White
Assistant to General Manager - Salem Operations
Vice President - Nuclear Engineering
Manager -
Technical Support
Manager - Maintenance Controls
Licensing Engineer
Lead Engineer - General Manager - Salem Operations
Technical Engineer - Reactor and Plant Performance
Manager - Licensing
Licensing Engineer
Senior Staff Engineer
IST Coordinator
Principal Engineer - QA Audits
Licensing Engineer
Technical Engineer - Reactor and Plant Performance
Region I
Senior Resident Inspector
Resident Inspector
Section Chief, Region I, Division of Reactor Projects