ML18152A590
| ML18152A590 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/20/1987 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A588 | List: |
| References | |
| 50-280-87-30, 50-281-87-30, IEB-83-06, IEB-83-6, NUDOCS 8711130264 | |
| Download: ML18152A590 (17) | |
See also: IR 05000280/1987030
Text
\\
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
50-280/87-30 and 50-281/87-30
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
License Nos.: DPR-32 and DPR-37
Facility Name:
Surry 1 and 2
1987
Inspeclo : w.
Approv
by:1.--1;-,~~~~---:11~~:=.=:..--~~~~~~~~
SUMMARY
Mte,gned
- Scope:
This routine, unannounced inspection was conducted in the areas of
licensee action on previous enforcement matters (927018), inservice testing of
pumps and valves (73576), verification of compliance .with order for
modification of license:
Primary Coolant System Isolation (Event V) Valves
(TI 2515/84), Inspector Followup Items, and IE Bulletins.
Results:
Two violations were identified: Failure to Perform Inservice Test as
Required by the ASME code; and Failure to Follow Document Control Procedure.
REPORT DETAILS
1.
Persons Contacted
2.
Licensee Employees
- D. Benson, Station Manager
- E. S. Grecheck, Assistant Station Manager
- H. C. Miller, Assistant Station Manager
- J. Kin, Corporate ISI
- R. H. Blount, Superintendent, Technical Services
- C. T. Dung, Associate Engineer
- G. 0. Miller, Licensing
Other 1 i censee emp 1 oyees contacted included engi nee.rs, technicians, and
office personnel.
NRC Resident Inspectors
- W. E. Holland, Senior Resident Inspector
L. Nicholson, Resident Inspector
- Attended exit interview
Exit Interview
The inspection scope and findings were summarized on October 2, 1987, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
a.
(Open) Vi o 1 at ion 50-280, 281/87-30-01:
11 Failure to Perform Inservi ce
Test as Required by the ASME Code
11
- paragraph 5.h.(1)
b.
(Open) Violation 50-280, 281/87-30-02:
11 Failure to Follow Document
Control procedure
11
- paragraph 5.h.(2).
c.
(Open) Unresolved Item 50-280, 281/87-30-03:
11 ISI Pump Instrument.
Range
11
- paragraph 5.h.(3).
d.
(Open) Inspector Followup Item 50-280, 281/87-30-04:
11Specification
of Maximum Limiting Valve Stroke Time
11
- paragraph 5.h.(4).
e.
(Open) Inspector Foll owup Item 50-280, 281/87-30-05:
11Unavai 1 able
Valve Records
11
- paragraph 5.h.(5).
f.
(Open) Inspector Followup Item 50-280, 281/87-30-06:
11Verification
of Check Valve Exercising to Open Position
11
- paragraph 3.a.
-.
' ......... , ., ~, ....... ,,~* ... , ........... -~ ...... -;., ... .;__,., __ ,.. ______ -..~ -*
.. -* ... -
.. , . -~-*-* ... .
2
g.
(Open) Inspector Followup Item 50-280, 281/87-30-07:
"Specification
of Containment Isolation Valve Leakage Rates" - paragraph 3.b.
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 (927018)
a.
(Closed) Unresolved Item 50-280, 281/83-06-01:
"Verification of
Check Valve Exercising to Open Position.
11
This matter concerns the licensee's understanding that their
procedures were adequate in that check valves were "tested by proving*
that the disk moves promptly away from the seat when closing pressure
differential is removed and flow through the valve is initiated
11 , as
stated in the Code.
The inspectors of record for report 50-280,
281/83-06 informed the licensee that they would obtain and provide to
the licensee a formal position on this testing and disposition of the
matter would be based on the interpretation obtained and on
Region II' s further review of the 1 i censee' s re 1 ated actions, as
. evaluated in future inspections.
This was _identified as an
unresolved item .
The NRC position concerning this matter is presented in a January 3,
1983 letter to D. G. Eisenhut, Director, Division of Licensing,
Office of Nuclear Reactor Regulation (NRR) to C. E. Norelius,
Director, Division of Engineering and Technical Program, Region III.
This letter states in part:
11 *** the fo 11 owing 1 i sting of . . . test methods which are
acceptable for any check valve in which the full stroke motion
of the disc cannot be directly observed or where there is no
position-indicating device.
These four methods are currently
being accepted in IST program reviews.
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 .
3
We believe these stroking tests assure that the valve is
exercised at least to the position required to fulfill its
function and, therefore, the intent of ASME Section XI
requirements are met. 11
The licensee indicated that they would review the NRC position and
make the necessary changes to their program to bring it (the program)
into line with the NRC position.
This matter will be the subject of future inspections.
Therefore,
this item will be closed as an unresolved item and opened as
inspector followup item 50-280, 281/87-30-06:
11Verification of Check
Valve Exercising to Open Position.
11
b.
(Closed) Unresolved Item 50-280, 281/83-06-03:
11Specification of
Containment Isolation Valve Leakage Rates.
11
This matter concerns the licensee 1s understanding that only the
Appendix J testing is required on containment isolation valves, that
Code
required specification of individual maximum leakage rates,
analysis of leakage rates, and corrective action are not necessary.
The inspectors of record for report 50-280, 281/83-06 informed the
licensee that they would obtain and provide to the licensee a formal
position on this testing and disposition of the matter would be based
on the interpretation obtained and on Region II 1s further review of
the licensee 1s related actions, as evaluated in future inspections.
This was identified as an unresolved item.
The
NRC position concerning this matter is presented in an
October 19, 1984 letter from n. G. Eisenhut, Director, Division of
Licensing, Office of Nuclear Reactor Regulation (NRR) to
R. L. Spessard, Director, Division of Reactor Safety, Region III.
This letter states in part:
11 *** Section XI of the ASME Code requires individual testing for
each component in the* IST program, including individual
acceptance criteria.
Containment Isolation Valves (CIVs) are
required to be individually included in the IST program because
of their accident mitigation service requirements.
However,
since licensees are required to perform leak rate testing of
CIVs in accordance with 10 CFR Part 50, Appendix J, NRR has
routinely granted relief from the leak rate test requirements of
the ASME Code for these components.
For cases where this relief
is granted the staff requires that the licensee still meet the
Analysis of Leak Rates and Corrective Action requirements of the
Code, paragraphs IWV-3426 and IWV-3427 of the 1980 Edition,
respectively .
The staff believes that a
11weighted 11 approach is the most
appropriate method of assigning allowable leak rates.
This
method is based on the existence of a linear relationship
- 4.
' ... ~ ~ *- :* ..
. . .. : / . -
4
between valve sizes with respect to allowable leakage (i.e., a
6
11 valve would be allowed twice the leakage of a 3" valve).
Additionally, where the allowable leak rates are added up for
all type C tested CIVs, the total should not exceed 0.6 L ._
This allows a certain amount of flexibility since the 0.6>'lA
value specified by Appendix J is the maximum allowed for the
combined cumulative leak rates of type C tested CIVs and
containment penetrations as determined by Type B testing."
The licensee indicated that they would review the NRC position and
make the necessary changes to their program to bring -it (the program)
into line with the NRC position.
This matter will be the subject of future inspections.
Therefore,
this item will be closed as an unresolved item and opened as
inspector followup item 50-280, 281/87-30-07:
"Specification of
Containment Isolation Valve Leakage Rates."
c.
(Open) Unreso 1 ved Item (UNR) 50-280, 281/85-06-01:
"Techni ca 1
Specification Requirements for Photographs as ISI Records."
The inspector discussed this matter with the 1 i censee and was
informed that the status of this item is unchanged from that reported
in NRC Report 50-280, 281/87-20.
This item remains open.
Unresolved Items
Unresolved Items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations.
New unresolved items identified during this inspection are
discussed in paragraph 5.h.(3).
5.
Inservice Testing (IST) of Pumps and Valves (73756)
The inspector reviewed procedures, observed work activities and reviewed
pertinent qua 1 i ty records, as indicated be 1 ow, 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 B&PV) Code Section XI 1980 Edition Winter 1980
Addenda (80W81).
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 te*sti ng per approved
procedures; performance of post-maintenance and post-modification
IST; proper certification and calibration of IST instruments; and
training for those personnel responsible for implementing IST
procedures.
5
Identification No.
Documents Reviewed
Title
SUADM-M-21, of 8/27/87
SUADM-M-22, of 2/6/86
SUADM-M-18, of 10/22/86
ENG-63.0, of 5/6/86
ENG-64, of 5/20/86
SUADM-M-23, of 6/5/86
SUADM-M-24, of 3/20/87
SUADM-M-29, of 6/23/87
SUADM-0-23, of 7/13/87
SUADM-ADM-01, of 6/18/87
SUADM-0-21, of 8/21/86
1-PT-40, of 3/20/87
2-PT-40, of 5/7/87
11Valve Program
11
11 Pump Program
11
11Safety and Relief Valve Program
11
11 Review and Record of IS! Pump PTs 11
11 Review and Record of !SI Valve PTs"
11Surry Units 1 Inservice Inspection
Program" dtd 6/22/87
"Disposition of ASME Section XI
Inspection and Testing Discrepancies"
11Test Equipment
11
11 Inservice Inspection Program -
Organization and Responsibilities 11
11Administrative Procedure
11
11Station Organization and
Responsibilities
11
11Control of Measuring and Test
Equipment"
"Periodic Test Instrumentation
Calibration"
11Periodic Test Instrumentation
Calibration"
b.
The inspector reviewed the below listed completed procedures to
verify that these procedure are the latest ones approved and that
test acceptance criteria used were valid for the component being
tested.
7
Valve Data Examined
Unit
Valve No.
Class Category
Size
~
System
1
MOV-1535
1
A
3
2
MOV-2536
1
A
3
1
MOV-1890A
2
A
10
Safety Injection
(Passive)
2
MOV-2890
2
A
10
MDV
Safety Injection
(Passive)
1
MOV-SW-102A
3
B
42
MDV
2
MOV-SW-202B
3
B
42.
MDV
1
TV-CC-109A
3
B
18
BF
Component Cooling
2
TV-CC-209B
3
B
18
BF
Component Cooling
1
l-IA-938
2
2
CK
Compressed Air
2
2-IA-864
2
2
CK
Compressed Air
1
RV-1257
2
C
3
RV
Chemical & Volume
Control
2
RV-2209
2
C
3
RV
Chemical & Volume
Control
RV - Relief Valve
CK - Check Valve
MOV - Motor Operated Valve
Valve No.
Procedure No.
MOV-1535
l-PT-2.26 (P-1-458)
l-PT-18.IOC
MOV-2536
2-PT-2.26 (P-1-458)
2-PT-18.lOC
MOV-1890A
l-PT-18.6A
l-PT-18.lOJ
MOV-2890B
2-PT-18.6A
l-PT-18.lOJ
Identification No.
l-PT-2.26
1&2-PT-18:lOC
2-PT-2.26
1&2-PT-18.6A
1&2-PT-18.lOJ
1&2-PT-25.l
1&2-PT-18.10
1&2-PT-18.613
1&2-PT-18.lOF
1&2-PT-12.2
1&2-PT-16.4
6
Procedures Reviewed
Title
"Reactor Coolant System Pressure
(P-1-458)"
"Verification of Local and Remote
Valve Position Indications of PORV
Inside Containment"
"Reactor Coolant System (P-2-403) 11
"Quarterly Testing of Safety Injection
"Verification of .Local and Remote
Valve Position Indications of Safety
Related Valves. in Safeguards Valve Pit
Area"
11Quarterly Testing of Circulating
Water and Service Water System Valves"
"Verification of Local and Remote
Valve Position Indications of Safety
Related Valves in Turbine Building"
"Quarterly Testing of Miscellaneous
Containment Trip Valves"
"Verification of Local and Remote
Valve Position Indications of
Containment Trip Valves in Auxiliary
Building"
"Testing of Miscellaneous Safety and
Relief Valve Settings in Accordance
with ASME Section XI"
"Containment Isolation Valve Leakage"
- - - - - ~
-
OOo
.._J~ ......... *-*+**o6.
0 JO ->-*-'--**~***'<*
o,*A-J, .. *
,.,* **
8
MOV-SW-102A
l-PT-25.1
1-PT-25.1
MOV-SW-2028
2-PT-25.1
2-PT-18.lQ
TV-CC-109A
1-PT-18.68
1-PT-18. lOF
TV-CC-2098
2-PT-18.68
2-PT-18.lOF
1-IA-938
1-PT-16.4
2-IA-864
2-PT-16.4
1-RV-1257
1-PT-12.2
2-RV-2209
2-PT-12.2
c.
The inspector reviewed the last six complete<;! procedures for the
above listed valves to verify that the licensee performed IST per an
approved schedule within the limitations described in the IST
program, including increased frequency testing.
d.
The inspector reviewed the last six completed procedures for the
above indicated 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 insp~ctor reviewed the above identified procedures for the above
indicated valves to ensure that IST procedures and data reflect all
requirements of the ~ppropriate edition of the ASME Code Section XI,
including:
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 C
check valves whose safety function is to open and close; evaluation
of Category A valve leak test data conducted in accordance with ASME
IWV-3426 and -3427 guidelines and including containment isolation and
pressure isolation valves; testing of safety and relief valves in
accordance with ASME 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.
9
f.
The inspector reviewed the data for the above indicated valves for
the last six intervals to verify that IST data was evaluated per the
requirements of ASME Code Section XI, Subsection IWV, and 10 CFR
50.55a(g) and ensured that appropriate followup actions were taken.
g.
The inspector examined selected records to verify that IST records
are maintained as delineated in ASME IWV-6000; and engineering
evaluations are sufficient to justify changes to reference values and
remova 1 of increased frequency testing requirements should be
documented and reviewed.
h.
Relative to the above, the inspector made the following observations.
(1) Procedure SUADM-M-21, of August 27, 1987, "Va 1 ve Program", _
paragraph 3.1 states in part:
"3.1 Active Category A, 8, and C valves should be exercised
to the position required to fulfill their function
unless such operations is not practical during elant
operation, the valve shall be part-stroke exerc1sed
during plant operation and full stroke exercised
durin? cold shutdown.
These valves shall be
speci ically identified by the VEPCO in relief request
to NRC and shall specifically denote when full-stroke
exercise is possible."
(EMPHASIS ADDED)
ASME B&PV CODE SECTION XI, aowao, PARAGRAPH
IWV-3411 states in part:.
"IWV-3411 Test Frequency
Category A and 8 va 1 ves sha 11 be exercised at
least once every 3 months, except as provided by
IWV-3412(a) ...
IWV-3412 Exercising Procedures
(a) Valves shall be exercised to the point
required to fulfill their function unless
such operation is not practical during plant
operation.
If only limited operation is
practical during plant ope~ation, the valve
shall be part-stroke exercised durina plant
operation and full-stroke exercised uring
cold shutdowns.
Valves that cannot be
exerc, sed during p 1 ant ope rat ion sha 11 be
specifically identified by the Owner and_
shall be full-stroke exercised during cold
shutdowns ... "
J
~ .*** , .'. .* ..:.. ...; **.* ,, 5* *. *~.;, *.,. -..~:~*._.",t. .* r'. ;_~-* ---~ *****..
10
(EMPHASIS ADDED)
Contrary to the above, the licensee has issued relief requests
identifying the below listed Category A and B valves, requesting
relief from the full-stroke exercise test which ASME B&PV Code
Section XI requires to be performed every three months.
A
full-stroke test performed every cold shutdown or refueling
outage is indicated as the alternative test.
No relief for
partial-stroke exercise test for the below indicated valves was
requested.
No partial-stroke exercise tests have been performed
on these valves.
Unit No.
Reguest No.
Valve No.
1
12
MOV-1700(1)
2
12
MOV-2700(1)
1
13
MOV-1720A&B
2
13
MOV-2720A&B
1
15
LCV-1115C&E
2
15
LCV-2115C&E
1
16
MOV-1373
2
16
MOV-2373
1
17
MOV-1381
2
17
MOV-2381
1
18
TV-:1204
2
18
TV-2204
1
19
MOV-1289A&B
2
19
MOV-2289A&B
1
22
MOV-1890C
2
22
MOV-2890C
1
23
MOV-1869A&B
1
23
MOV-1842
2
23
MOV-2869A&B
2
23
MOV-2842
1
24
MOV-1867C&D
2
24
MOV-2867C&D
1
29
TVBD-lOOA-F
2
29
TVBD-200A-F
1
31
SOV-RC-lOO(l)A(B)-1(2)
2
31
SOV-RC-200(1)A(B)-1(2)
The above clearly indicates that the licensee failed to perform
inservice tests on valves as required by their procedures and
the ASME B&PV Code Section XI, to verify operational readiness.
Failure to perform inservice tests to veri_fy operational
readiness of pumps and valves, whose function is required for
safety, in accordance with ASME B&PV Code Sect ion XI is a
violation of the requirements of 10 CFR 50.55a(g)(4)(ii). This
violation will be identified as 50-280, 281/87-30-01:
11Failure
to Perform Inservice Tests as Required by the ASME Code".
--
- -
--- .' ~*,~, .. \\,
- __ ,~_-;- ....
- ...
, ... ,:.:...,.. ..... ~*4_.:-~~- ... ~ *.
..
-*----*-*****-*****
11
(2) Procedure No. SUADM-ADM-18 of July 17, 1987, "Document Control
11
paragraph 5.1.l(l)(b) states in part:
11 *** New and revised procedures wi 11 be imp 1 emented
not later than seven days after approval by the
Station Nuclear Safety and Operating Committee
(SNSOC). 11
Contrary to the above, procedures were not followed in that the
following examples were noted:
(a) Procedure l-PT-25.1 of November 29, 1984,
11Quarterly
Testing of CW and SW System Valves
11 was revised and
approved by the SNSOC on July 22, 1986~
This would mandate
July 30, 1986, as the mandatory implementation date for
Procedure l-PT-25.1 of July 22, 1987.
Procedure l-PT-25.1
of November 29, 1984, was performed on August 21, 1986, 22
days after the mandatory implementation date of the next
revision of the procedure.
(b) Procedure 2-PT-18. 6A of December 20, 1985,
11Quarterly
Testing of Safety Injection MOVs and HCVs" was revised and
approved by the SNSOC on November 6, 1986.
This would
mandate November 13, 1986, as the mandatory implementation
date for procedure 2-PT-18.6A of November 6, 1986.
Procedure 2-PT-18.6A of December 20, 1985, was performed-on
,November 29,
1986,
16
days after the mandatory
implementatioA date of the next revision of the procedure.
Failure to follow procedures, for activities affecting quality
is a v.iolation of the requirements of 10 CFR 50, Appendix
118
11 ,
Criterion V.
This violation will be identified as 50-280,
281/87-30-02:
11Failure to Follow Document Control Procedure
11 *
(3) Currently, the licensee 1s documented program for pump testing
has no procedural provisions to assure compliance with the
requirements of ASME B&PV Code Section XI paragraph IWP-4200
Range,
11Full scale of each instrument shall be three times the
reference va 1 ue or 1 ess. 11
The 1 i censee indicated that this
omission would be corrected and that they would verify that all
instruments used for pump inservice testing are in compliance
with ASME B&PV Code Section XI.
Pending NRC review of the
licensee I s corrective actions and verification of. compliance
with the Code, this matter will be identified as unresolved item
50-280, 281/87-30-03:
11IST Pump Instrument Range
11 *
(4)
ASME Code Section XI paragraph IWV-3417, Correction Action,
states:
12
(a) If, for power operated valves, an increase in stroke
time
of
25% or more from the previous test for
valves with full-stroke times greater than 10 sec or
50% or more for valves with full-stroke times less
than or equal to 10 sec 1s 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.
In any case, any abnormality or erratic action
shall be reported.
(Emphasis added.)
(b) If a *valve fails to exhibit the required change of
valve stem or disk position or exceeds its specified
limiting value of full-stroke time by this testing, then
corrective action shall be initiated immediately.
If the
condition is not, or cannot be, corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,
the valve shall be declared inoperative.
When corrective
action is required as a result of tests made during cold
shutdown, the condition shall be corrected before startup.
A retest showing acceptable operation shall be run
following any required corrective action before the valve
is returned to service.
This requirement is implemented by Procedure SUADM-M-21 of
August 27, 1987, paragraph 3.9, which states in part:
113.9 If a valve fails to exhibit the required change of
valve stem or stem or disk position or exceeds its
maximum stroke time, then corrective action shall be
initiated immediately and the. valve declared
When corrective action is required as a
result of tests made during cold shutdown,. the
condition shall be corrected before startup. A retest
showing acceptable ope rat ion sha 11 be run f<:> 11 owing
any required corrective act ion before the va 1 ve is
returned to service.
11
SUADM-M-21 paragraph 3.11 states in part:
113.11 The administrative stroke time
is only for
trending purposes to detect a gradual change of stroke
time.
If a valve exceeded its administrative stroke
time, engineering will evaluate the valve operability
and recommend corrective action if needed.
11
The maximum stroke time, nominal stroke time, and administrative
stroke times for the valves examined by this inspector are
listed below.
The licensee informed this inspector that the
maximum stroke times is based on the system (or component)
response time limitation, as st~ted in the plant's technical
specifications or FSAR.
The administrative stroke time for
which there is no programmatical or procedural corrective action
13
required, is based on engineering evaluation of vendor
recommendations and performance histories of the valves
concerned.
It appears that the licensee*s practice for*establishing maximum
limiting stroke times for valves is inconsistent with the
staff 1s interpretation of the Code, as stated in NRR letter from
Mr H. L. Thompson, Jr., Director, Division of Licensing, Office
of Nuclear Reactor Regulation to Mr. R. L. Spessard, Director,
Division of Reactor Safety, Region III, dated April 11, 1985.
11Subsection IWV is specifically a
11component
11 test code
and, therefore, requires that the owner specify the maximum
limiting stroke times for each power operated valve
(IWV-3413).
It is the staff 1s position that these limiting
values of full . stroke time are required to be based on
reasonab 1 e engineering judgement of. component (va 1 ve)
operability, not minimum system requirements.
System (or
component) response ti me 1 i mi tat ions, as stated in the
applicant's FSAR or in the plant Technical Specifications,
are also time limitations placed on each subcomponent of
that system (or component).
However, the staff 1s position
is that these response time limitations should rarely take
precedence over a component-oriented limiting valve stroke
- time. 11
Maximum
Normal
Administrative
Valve No.
Stroke Time Stroke Time
MOV-1535
120
46
50
MOV-2536
120
36
NAY
MOV-1890A
30
10
15
MOV-28908
30
12
NAY
MOV-SW-102A
120
19
30
MOV-SW-2028
120
26
NAY
TV-CC-109A
60
8
20
TV-CC-2098
60
9
NAY
NAY - Not Assigned Yet
In discussions with the licensee, the inspector was
informed that their intent was to use the same
administrative values for Units 1 and 2 valves (e.g.,
MOV-1535 and MOV-2535 would have the same administrative
stroke time); however, due to an oversight this was not
documented.
The licensee indicated that they would review the NRC position
and make the necessary changes to their program to bring it (the
program) into line with the NRC position.
-.
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- . *-*
- . **- *****-*** ..... -* .. ~ .*. *.~*r,.*_.;;_ ***-*
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14
This matter will be the subject of future inspections and is
identified as inspector followup item 50-280, 281/87-30-04:
11Specification of Maximum Limiting Valve Stroke Time 11 *
(5) Most of the records for the testing of valves 1-IA-983,
2-IA-864, 1-RV-1257, and 2-RV-2209 are microfilm.
The licensee
was unable to find the last six tests for the above valves
during this inspection.
The licensee indicated that the records
would be available for the inspector's review at his next
inspect ion.
This matter wi 11 be i dent i fi ed as inspector
followup item 50-280, 281/87-30-05:
11Unavailable Valve Test
Records
11 *.
(6) Procedure Nos. 1&2-PT-12.2, in paragraph 5.5, specifies the
accuracy of the pressure gauge used, for testing relief valves,
to be 2% of full scale, but does not specify any setpoint
pressure for the valve under test, and the full scale valve of
the gauge used for the test.
If the difference is too great,
the accuracy of the setpoint verification would be in question.
The licensee indicated that they would look further into the
matter and make necessary changes to the appropriate procedures.
(7) Procedure Nos. 1&2-PT-18.6A, 1&2-PT-25.1, and 1&2-PT-18.68 state
that
11 full stroke time is the time interval from initiation of
the actuating signal to the end of the actuating eye le.
11
The
inspector noted that the procedures do not clearly specify what
constitutes initiation of the actuation signal
11 (actuation of
control panel switch), and what constitutes
11the end of the
actuating cycl e
11
( i 11 umi nation of the fi na 1 contra 1 pane 1
1 i ght).
The licensee indicated that they would review the
matter and make appropriate changes to the applicable
procedures.
(8) Relief Request Unit 1 No. 27 Table G and Relief Request Unit 2
No. 27 Table G identify valves l-SI-79, 82, 85 and 2-SI-79, 82,
85 as Category A, when in fact they are Category AC.
(9) Relief Request Unit 1 No. 35, Unit 2 No. 35 and Units 1 and 2
i nservi ce inspect ion program, i nservi ce test tab 1 e page 4-61
(Unit 1) and G-57 (Unit 2) identify valves PCV-1456, PCV-1455C,
PCV-2456, and PCV-2455C as Category A, when in fact they are
Category AC.
Within the areas examined, no violations or deviations were identified
except as noted in paragraph nos. 5.h.(1) and 5.h.(2).
15
6.
Verification of Compliance with Order for Modification of Licensee:
Primary Coolant System Pressure Isolation (Event V) Valves (TI 2515/84)
a.
Background
The Reactor Safety Study (RSS), WASH-1400, identified in a PWR an
intersystem loss of coolant accident (LOCA) that is a significant
contributor to risk of core melt accidents (Event V).
The design
examined in the RSS contained fn-series check valves isolating the
high pressure primary coolant system (PCS) from the low pressure
injection system (LPIS) piping.
The scenario which leads to the
Event V accident is initiated by the failure of these check valves to
function as a pressure isolation barrier against reactor coolant
system (RCS) pressure. This causes an overpressurization and rupture
of the LPIS low pressure piping which results in a LOCA outside of
the containment.
To better define the Event V, all light water reactor licensees were
requested by letter, dat~d February 23, 1980, to provide the
information in accordance with 10 CFR 50.54(f).
Based on licensee responses, it was concluded that a valve
configuration of concern existed at 36 plants.
On April 20, 1981, an order requiring the above described testing was
sent to 32 PWR plants and two BWR plants.
This order included a
Safety Evaluation Report (SER) and Technical Specification inserted
pages to re qui re leak rate testing of Event V pressure i sol at ion
valves.
The two additional plants had previously been issued a
license amendment.
b.
Inspection
The
inspector reviewed documentation associated with the
implementation of the Event V order from 1980 to present to evaluate
compliance.
The specific areas examined are indicated below.
(1)
The inspector examined records for the below listed valves from
the date of the order to the present to determine whether test
data:
was properly maintained; that data reflect all the
requirements specified in the Technical Specifications test
records contain major test data including upstream and
downstream pressures, leak volume per unit time (or equivalent),
leakage rate adjustment calculations when required, and leakage
rate acceptance criteria based on trending from previous tests
where applicable; recorded test frequency is in accordance with
TS; as found leakage (i.e., prior to valve stroking,
modification, adjustments, etc.) is recorded; leakage rate
trending has been documented and adequately evaluated by the
licensee in accordance with the TS requirement; no test data
anomalies exist which indicate improper or inaccurate testing;
16
adequate corrective actions were taken for valves not meeting
the acceptance criteria; determine in the event of a va 1 ve
modification or replacement, adequate post-maintenance leakage
rate testing was accomplished; determine that valve anomalies
were properly investigated and resolved.
Include those
identified during testing or in the interval between tests that
indicated the possibility of internal valve defects.
Valve Records Examined
1-SI-82
1-SI-242
2-SI-85
2-SI-243
Within the areas examined, no violations or deviations were identified.
7.
Inspector Followup Items (IF!s)
a.
(Closed) Item 50-280, 281/86-35-01:
"Liquid Penetrant Examination
Procedure Discrepancies.
11
The licensee has issued NDE-PT-1, Revision 5, which has corrected all
the discrepancies noted.
This item is considered closed.
The
inspector has no further questions.
b.
(Closed) Item 50-280, 281/86-35-02:
"Magnetic Particle Examination
Procedure Discrepancies.
11
The licensee has issued NDE-MT-1, Revision 4, which has corrected all
the discrepancies noted.
This item is considered closed.
The
inspector has no further questions.
c.
(Closed) Item 50-280, 281/86-35-03:
11Radiographic Procedure
Discrepancies"
The licensee has issued NDE-RT-1, Revision b, which has corrected all
the discrepancies noted.
This item is considered closed.
The
inspector has no further questions.
Within the areas examined, no violations or deviations were identified.
8.
IE Bulletins (IEBs) (92703)
(Open) !EB No. 83-06:
11Nonconforming Materials Suppli_ed by Tube-Line
Corporation Faciliti.es at Long Island City, New York; Houston, Texas; and
Carol Stream, Illinois, 11 Units 1 and 2.
-
The inspector discussed this matter with the licensee and was informed
that the status of this item is unchanged from that reported in NRC Report
50-280, 281/87-20.
This item remains open.