ML19354D616
| ML19354D616 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/11/1989 |
| From: | Belisle G, Scott Sparks, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19354D617 | List: |
| References | |
| 50-424-89-31, 50-425-89-36, NUDOCS 8912280244 | |
| Download: ML19354D616 (15) | |
See also: IR 05000424/1989031
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UNITED si ATES
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NUCLEAR REGULATORY COMMIS$10N
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101 MARIETTA STREET.N.W.
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ATLANT A, CEORGI A 30323
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Report Nos.:
50-424/89-31 and 50-425/R9-36
Licensee:
Georgia Power Company
P. O. Box 1295
Birmingham, AL 35201
Docket Nos.:
50-424 and 50-425
License Nos.:
Facility Name:
Vogtle 1 and 2
Inspection Conducted:
October 30 - November 3, 1989 and November 13-17, 1989
Inspectors:
Mali
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11hlM
5. Tihgen
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Date Signed
Ae e .2 L
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5. Sparks
Date Sig'ned
Approved by:
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G. A. Belisler Chief
Date Signed
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Test Programs Section
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of inservice
testing, complex surveillance, and action on previous inspection findings.
Results:
The licensee's RHR system IST program appeared to be adequate to ensure that
the system's components are maintained in an operational readiness state,
paragraphs 2 through 7.
A weakness was identified in the area of check valve
full stroke testing, which indicated the licensee's review of Generic Letter 89-04 was not thorough, paragraph 4.
An unresolved item was identified in the
area of pressurizer safety valve setpoint testing, paragraph 6.
A violation
was identified for inadequate complex surveillance testing, paragraph 8.
8912280244 891219
ADOCK 05000424
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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- J. Aufdenkampe, Technical Support Manager
- G. Bockhold, Jr., General Manager. Vogtle Nuclear Operations
- J. Churchwell, Senior Engineer
- G. Frederick, Quality Assurance Site Manager
- H. Handfinger, Maintenance Manager
- M. Hickox, Senior Plant Engineer
- M. Hobbs, Instrument and Control Superintendent
- S. Kitchens, Assistant General Manager, Operations
- A. Mosbaugh, Assistant General Manager, Plant Support
- L. Noblett,
Instrument and Control foreman
- J. Swartzwelder, Operations Manager
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- J. Williams, Plant Engineering Supervisor
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Other licensee employees contacted during this inspection included
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craftsmen,
engineers,
operators,
mechanics,
technicians,
and
administrative personnel.
NRC Resident Inspectors
R. Aiello, Resident Inspector
- J. Rogge. Senior Resident Inspector
D. Starkey, Resident Inspector
- Attended exit interview
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Inservice Testing Introduction (73756)
10 CFR S0.55a(g) and TS Surveillance Requirement 4.0.5 require that ASME
Code Classes 1, 2, and 3 pumps and valves be inservice tested in
accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
Section XI specifies rules and requirements for IST to assess operational
readiness of certain Classes 1, 2, and 3 pumps and valves which are
required to perform a specific function in shutting down a reactor to the
cold shutdown condition, in mitigating the consequences of an accident or
in providing over pressure protection.
Plant Vogtle is required to follow
the requirements of ASME Code,Section XI, 1983 Edition through the Summer
1983 Addenda.
During this inspection, the inspectors reviewed the
licensee's Inservice Test Program, implementing procedures, and test
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results that accomplish Section XI pump and valve IST.
The results of
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this review are stated in paragraphs 3 through 7.
Pumps and valves that
are in the RHR system or interface with the RHR system, pressurizer safety
valves, and PORVs were reviewed during this inspection.
3.
PumpTesting(73756)
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The inspectors reviewed IST of RHR pumps A and B for each Unit to
determine whether testing was performed in accordance with Section XI,
Subsection IWP requirements.
The following RHR IST implementing
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procedures and test results for the previous two year period were
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reviewed:
14805-1, Rev. 8. Residual Heat Removal Pump and Check Valve IST
14805-2, Rev. 3. Residual Heat Removal Pump and Check Valve IST
In general, inspection results indicated that Code requirements were
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satisfied in the areas of testing frequency, establishing new reference
values, post-maintenance testing, and evaluation of test results.
In
addition, the inspectors verified that testing was performed with
calibrated instrumentation.
The inspectors also reviewed and witnessed the performance of the
following pump IST procedures:
14801-2, Rev. 1
NSCW Transfer Pump Inservice Test
14808-2, Rev. 4,
Centrifugal Charging Pump and Check Valve
Inservice Test
14807-2, Rev. 2,
Motor Driven Auxiliary Feedwater Pump Inservice
Test
14804-1, Rev. 7
Safety Injection Pump Inservice Test
The inspectors verified that the above procedures accomplished testing in
accordance with Code requirements.
Test personnel were observed to be
knowledgeable of Section XI Code requirements, acceptance criteria,
precautions and limitations, and adhered to the appropriate procedure
during performance of the test.
Test data was measured with calibrated
instrumentation, and results were properly evaluated.
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Within the areas inspected, no violations or deviations were identified.
4.
Check Valve Full Stroke and Reverse Flow Testing (73756)
The inspectors reviewed the full stroke and reverse flow IST methods and
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results obtained during the previous two year period for the following
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check valves for each unit:
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1-1205-U4-122
1-1205-U4-123
1-1205-U6-001
1-1206-U6-002
1-1205-06-009
1-1205-U6-010
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l-1204-U4-143
1-1204-U4-144
1-1204-U4-145
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,1-1204-U4-146
1-1204-U6-079
1-1204-U6-080
1-1204-U6-081
1-1204-U6-082
1-1204-U6-128
1-1204-U6-129
1-1204-06-147
1-1204-U6-148
1-1204-06-149
1-1204-06-150
The inspectors reviewed the following Unit 1 (corresponding procedures
were reviewed for Unit 2 testing) procedures which performed IST on the
above check valves:
14896-1, Rev. 2,
ECCS Check Valve Cold Shutdown Inservice Test
14895-2, Rev. 3
ECCS Check Valve Refueling Inservice Test
14805-1, Rev. 8,
Residual Heat Removal Pump and Check Valve IST
28716-C, Rev. 5,
Westinghouse Style
"B"
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Surveillance
Requirements for full stroke and reverse flow exercising check valves are
contained in Section XI, Subsection IWV-3522 of the Code.
The inspectors reviewed testing frequencies, results, and appropriate
relief requests for the above check valves.
In addition, where full
stroke testing was performed, the inspectors verified that flow rates were
specified by procedure and were greater than design accident flow rates.
GL 89-04, Guidance on Developing Acceptable Inservice Testing Programs,
dated April 3,1989, provides NRC staff positions on IST.
The licensee
stated that a review of the GL 89-04 positions had been performed, and
that current IST was in accordance with these positions.
In addition,
since an SER, dated March 1987 (and approvals of subsequent revisions to
the IST Program), had been received, current testing was considered
acceptable.
However, the inspectors identified an area where current IST
wus not consistent with the potential generic deficiencies related to IST
programs and procedures as identified in GL 89-04.
GL 89-04 addresses
full-stroking check valves, and states:
A valid check valve full-stroke exercise by flow requires that the
flow through the valve be known.
Knowledge of only the total flow
through multiple parallel lines does not provide verification of flow
rates through the individual valves and is not a valid full-stroke
exercise.
The following items were identified where check valve full stroke
exercising was not in accordance with GL 89-04:
Check valves 1204-04-143, 144, 145, and 146. The licensee describes
the alternate testing for these check valves in Relief Request RR-6,
which has been approved.
Discussions with licensee personnel
indicated that the purpose of RR-6 was to perform full stroke
exercising during refueling.
Alternate testing is performed
by procedures 14892-1 and 14892-2, in which a total flow from one
safety injection pump is compared to the system flow balance
requirements of TS to verify that these valves open to perform their
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function. The licensee stated that failure of a single check valve to
full-stroke would be detected by a decrease in pump flow rate or an
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increase in discharge pressure.
However, the licensee could not
provide data to support the assumption that a check valve which only
partially strokes open would result in a detectable change in pump
discharge flow or pressure.
Check valves 1204-U6-147, 148, 149, and 150. The licensee describes
testing these c.eck valves in Cold Shutdown Justification CS-7.
CS-7
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states that total flow from one RHR pump will be compared to the
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system flow balance requirements of TS to verify that these valves
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open to perform their function, and that inoperability of these check
valves to pass their required flow would be seen as reduced total
flow.
However, the licensee could not provide data to support the
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assumption that a check valve which only partially strokes open would
result in a detectable change in pump discharge flow or pressure.
Based on the above two examples, the inspectors concluded that the
licensee's review of the positions and generic deficiencies related to IST
programs and procedures stated in GL 89-04 was not thorough in the area of
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check valve full stroke exercising.
Licensee management orally committed
to perform an additinnal review of GL 89-04 and revise any implementing
procedures, as necessary, to comply with the GL 89-04 positions.
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The inspectors also reviewed calibration of instrumentation used to verify
check valve full stroking in which the design accident flow rate is used.
The inspectors questioned licensee personnel on the use and accuracy of a
clamp-on acoustic flow meter, used during procedures 14896-1 and 14896-2
to verify the flow rate through check valves 1204-06-128 and 1204-U6-129.
Review of the vendor manual for the acoustic flow meter indicated that the
instrument error is less than or equal to one percent.
The inspectors
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consider the stated accuracy of the acoustic flow meter to be satisfactory
for verifying check valve full stroking.
The inspectors also reviewed check valve reverse flow testing, which is
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required by the Code for check valves which perform a safety function in
the closed position.
Subsection IWV-3522 requires check valve testing in
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a manner that verifies the disk travels to the seat on cessation or
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reversal of flow.
Check valves 1204-06-079, 080. 081, and 082 are
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disassembled and manually stroked each RF0 (one each refueling) on a
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staggered test basis as stated in relief request RR-7.
The remaining
check valves are either PIVs, which are leak rate tested, or are
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satisfactorily reverse flow tested in accordance with. Code requirements.
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Within the areas inspected, no violations or deviations were identified,
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-PowerOperatedValveIST(73756)
The inspectors reviewed IST for the following MOVs and A0Vs in the Units 1
HV8804A
HV8804B
HV8716A
HV8717B
FV0610
FV0611
HV8812A
HV8812B
HV8811A
HV8811B
HV8840
HV8809A
HV8809B
HV0606
HV0607
FV0618
FV0619
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The inspectors interviewed licensee personnel regarding the general
methods used ~ to stroke time power operated valves.
The inspectors
also reviewed appropriate relief requests, and reviewed the following
implementing procedures for IST of the previously listed valves:
14850-1, Rev. 11,
Cold Shutdown Valve Inservice Test
14825-1, Rev. 11,
Quarterly Inservice Valve Test
Criteria for IST power operated valves is contained in Subsections IWV
3412, 3413, 3415
and 3417 of the ASME Code.
These Subsections specify
stroke timing, fail-safe testing, and corrective action requirements.
The
inspectors verified that testing was performed in accordance with Code
requirements, and that testing data and subsequent corrective action was
satisfactory.
The inusctors also questioned che licensee on the need to fail-safe test
valve.
70606, HV0607, FV0618, and FV0619.
These valves are A0Vs which
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a e RHR heat exchanger discharge flow and bypass flow, and have a
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fail-seit position.
Subsection IWV-3415 provides the requirements for
testing valves with fail-safe actuators.
The licensee stated that the
normal position of these valves is the failed position and, as such,
consider these valves to be passive valves.
There are no exercising
requirements for passive valves and thus the inspectors had no further
questions.
Within the areas inspected, no violations or deviations were identified.
6.
Safety and Relief Valve IST (73756)
The. inspectors reviewed IST for the following safety and relief valves in
-Units 1 and 2 RHR system and reactor coolant system:
PSV8708A
PSV8708B
PSV8708C
PSV8010A
PSV8010B
PSV8010C
The inspectors interviewed licensee personnel regarding the methods used
to test relief valves and reviewed the following implementing procedures
for IST of the previously listed valves:
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28211-C, Rev. 2, RHR Suction Relief Valve Test
28215-C, Rev.1. Pressurizer Code Safety Valve Setpoint Verification
WYLE Laboratories Test Procedure No. 1032, Rev. A, Testing of Crosby
Model HB and HB-BP Safety Valves at Non-elevated Temperature
WYLE Certification Test Report 48136-01
The criteria for IST of relief valves and safety valves are contained in
-Subsections IWV 3511, 3512, and 3513 of the ASME Code, and in Performance
and Test Code ANSI /ASME-PTC 25.3-1976, Safety and Relief Valves, which
specify testing methods and frequency. TS 3/4.4.2 specifies a PSV setpoint
tolerance of 2485 plus/minus one percent psig.
Section .01 of ANSI /ASME-PTC 25.3-1976 states that if the temperature of
the medium used to test the valve differs substantially from the
temperature to which the valve is subjected while in service, the opening
and closing pressures as well as the blowdown will be different fro.n the
test pressures, and it is necessary to develop appropriate corrections for
the valve under test to account for these differences which are outside the
scope of the code.
Vogtle PSVs are installed on uninsulated loop seals. The exact
temperature of the loop seals is unknown.
Discussions with the licensee
indicated that loop seal temperatures are somewhere between 120 and 200'F,
and that ambient temperature was approximately 140*F.
Prior to Units 1
and 2 respective startups, all six PSVs were setpoint tested at WYLE
Laborat,ories.
The valves were tested with steam at approximately 650 F.
During the WYLE tests, the PSV bonnet temperature was maintained at
approximately 140 F.
The PSV body temperature was also measured with a
lower limit of 200"F required to commence testing; no upper limit for body
temperature was established.
Review of the WYLE setpoint test results
indicated that the valve's body temperature was never allowed to stabilize.
Once body temperature reached 200 F, WYLE coninenced setpoint testing.
In
all cases body temperature increased as setpoint testing progressed.
For
the six PSVs tested, body temperatures ranged from a low of 218*F to a
high of 385 F when satisfactory setpoints were obtained.
During the previous Unit 1 RF0, PSV8010A was setpoint tested in place
utilizing a pressure assist device.
In order to perform this testing the
loop seal was drained by opening the loop seal drain / fill valve for
approximately one minute.
Within two to five minutes after draining the
loop seal, the valve was setpoint tested. During the following 15 minutes,
the valve was setpoint tested a total of eight times.
During the inplace
testing, the valve and loop seal temperatures were not monitored.
The
inplace setpoint results wandered somewhat and required two adjustments to
obtain two consecutive setpoints in the middle of the tolerance band. The
initial setpoint obtained during the inplace testing (2507 psig) was close
to the WYLE as-left setpoint (2506 psig) obtained prior to Unit 1
Etartup.
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The inspectors had the following questions regarding Vogtle PSV setpoint
test methods:
During WYLE testing, body temperatures were not allowed to stabilize.
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During normal plant operation, the PSV's body temperature is stable.
Does WYLE testing at unstabilized body temperatures provide accurate
setpoints?
What effect does valve lower body temperature have on setpoint?
During the WYLE testing, body temperature was as high as 385'F. The
exact body temperature at normal operation is unknown, but could be
as low as 120-140 F.
During the inplace testing conducted on Unit 1 valve PSV8010A, was
the valve body temperature stable, and did the valve heat up after
draining the loop seal?
During the inplace testing conducted on Unit 1 valve PSV8010A, did
.the loop seal remain filled with steam in lieu of being partially
filled with water?
During the inplace testing conducted on Unit 1 valve PSV8010A, the
valve was setpoint tested eight times in approximately 15 minutes.
Was valve temperature stable during these consecutive lifts?
In response to these questions the licensee and inspectors disagreed with
the validity of the present PSV setpoints being in the TS allowed
tolerance range. The licensee considers that (1) based on discussion with
Crosby, valve bonnet temperature and not valve body temperature has the
major effect on valve setpoint, therefore WYLE setpoint testing was valid,
and (2) during the inplace testing conducted on valve PSV8010A, the valve
was at normal operating temperature; therefore, because the WYLE and
inplace test results were identical,-no temperature correction factors were
required. During the upcoming Unit 2 RF0 the licensee will be required to
perform PSV setpoint testing.
The licensee agreed to verify that no
temperature correction is required uue to the differences in temperature
between test mediums and normal service medium during this testing. This
issue was identified as URI 50-424/89-31-02 and 50-425/89-36-02.
WYLE test results contained graphs of valve inlet pressure and
corresponding disc lift versus time for each setpoint test. The inspectors
had the following questions pertaining to these graphs:
Why did set pressure occur prior to disc lift?
In some instances, prior to the full gagged disc lift, there was a
disc lift of a much smaller magnitude. What was cause of the smaller
magnitude disc lift?
How does WYLE setpoint testing and the pressure assist device
setpoint test method utilized during the previous Unit 1 RF0
differentiate between opening pressure and simmer?
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The licensee agreed to review this matter further to obtain answers to these
questions.
These questions were identified as IFIs 50-424/89-31-03 and
50-425/89-36-03, and will be followed up on during a future inspection.
Review of RHR relief valve testing indicated that IST was accomplished in
accordance with the ASME Code.
Within the areas inspected, one unresolved item and one inspector
followup item were identified.
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7.
LeakRateTesting(73756)
The inspectors reviewed local leak rate testing for the following PIVs in
the Units 1 and 2 SI system:
1-1204-U4-143
1-1204-U4-144
1-1204-04-145
1-1204-U4-146
1-1204-U6-079
1-1204-U6-080
1-1204-U6-081
1-1204-U6-082
1-1204-U6-128
1-1204-U6-129
1-1204-U6-147
1-1204-U6-148
1-1204-U6-149
1-1204-U6-150
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The inspectors reviewed the following implementing procedures for IST of
the above valves:
14450-1, Rev. 7, RCS Pressure Isolation Valve Leak Test
14450-2, Rev. 2, RCS Pressure Isolation Valve Leak Test
Based on a review of procedures and results, the inspectors concluded the
fcilowing:
Adequate leak rate test procedures were developed and implemented,
and PIVs were correctly identified in the IST Program.
PIV leak rate tests were performed by acceptable methods at the
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required frequency.
Leak rates were satisfactory and were in agreement with the limits
established by TS 4.4.6.2.2 for PIVs.
PIV test data, taken at pressures below system functional pressure,
were adjusted properly in accordance with Section XI, Subsection
IWV-3423.
The inspectors identified a concern regarding procedures 14450-1 and
14450-2.
Specifically, these procedures contain a figure which is used to
correlate an indicated flow with an observed leak rate.
The inspectors
questioned the basis of the correlation,
i.e., why an indicated flow
needed to be adjusted to an observed leak rate. The licensee stated that
the leak rate is measured from flow elements 1FE-928 and 2FE-928.
An
Operations Deficiency Report, T-1-86-3320, was issued during Unit 1 pre-op
because the installation of IFE-928 did not meet ASME guidelines for
recommended minimum pipe lengths upstream and downstream of the orifice.
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Interim resolution consisted of a special test of passing known flow rates
of water through 1FE-928 and observing the indicated flow. Data collected
would be used to develop a correction curve of actual versus indicated
flow rate.
The inspectors reviewed the results of the special test
and verified that the correction was incorporated into procedure 14450-1.
The licensee properly installed 2FE-928 (Unit 2); however, the same
correction was incorrectly used in procedure 14450-2.
The correction
factor was in the conservative direction, which added a maximum amount of
approximately 1.5 gpm to the indicated leak rate.
The correction for
small leak rates (less than 1 gpm) was less than 0.5 gpm.
The licensee
agreed to revise the Unit 2 procedure to remove the correction factor due
to the fact that no correction in the indicated flow rate as provided by
2FE-928 is needed.
Request for Engineering Review 87-0287 recommended
long term corrective action to rework flow element 1FE-928 to conform to
ASME guidelines, which the licensee will follow under Design Change
Request 90-047.
Within the areas inspected, no violations or deviations were identified.
8.
Complex Surveillance (61701)
TS Surveillance Requirement 4.4.4.1 required that each pressurizer PORV be
demonstrated oper ble at least once every 18 months by perfonning a
channel calibration and operating the valve through one cycle of full
travel.
The inspectors reviewed the following procedures that
accomplished this surveillance requirement:
VEGP 14861-1, Rev. 1,
PORV Cold Shutdown Inservice Test
VEGP 14600-2, Rev. 2,
ESFAS Slave Relay and Final Device Train A
Block Test
VEGP 24526-2, Rev. 1
Pressure Protection Channel II 2P-456 Analog
Channel Operational Test and Channel
Calibration
VEGP 24518-2, Rev. 1,
Reactor Coolant Pressure (Wide Range)
Protection
II
2P-403 Analog Channel
Operational Test and Channel Calibration
VEGP 24539-2, Rev. 2,
Pressurizer Pressure Control 2P-455 Channel
Calibration
The pressurizer PORV channel calibration was accomplished by performing a
series of overlapping procedures.
Results of the inspectors' review of
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.the PORV channel calibration procedures was that the channel calibration
was not being properly performed, in that not all components in the
channels were tested.
NAS card 0936, K713 relay, and the contacts and
wiring that actuate when the K713 relay is energized were not tested.
These components are required to actuate to automatically open and close
the PORVs on high pressurizer pressure.
Failure to adequately test the
PORV circuitry in accordance with TS Surveillance Requirement 4.4.4.1 was
identified as Violations 50-424/89-31-01 and 50-425/89-36-01.
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November 17, 1989, the licensee had satisfactorily tested the PORV channel
components that had previously been omitted.
The inspectors also reviewed procedure 24524-1, Rev. 10, RCS Wide Range
Pressure IP-418 Channel Calibration, which the licensee uses to satisfy TS
surveillance requirement 4.5.2.d.1.
This procedure verifies automatic
isolation and interlock action of the RHR system from the RCS.
The
inspectors verified that the procedure adequately tests and calibrates
each component in the loop such that with a pressure signal greater than
or equal to 377 psig, the interlocks prevent RHR valve HV8702A from being
opened, and with a pressure signal less than or equal to 750 psig, the
interlocks will cause HV8702A to automatically close.
Within the areas inspected, one violation was identified.
9.
Action on Previous Inspection Findings (92701, 92702)
a.
(Closed) Inspector Followup Item 50-424/88-51-01, The Effect of
Temperature and Steam in Lieu of Water on PSV Setpoint.
This' item was discussed in paragraph 6 of this Inspection Report and
upgraded to an URI.
b.
(Closed) Inspector Followup Item 50-424/88-10-01, Torque Switch
Replacement.Due to Potential Roll Pin Failure.
During a previous inspection, the licensee committed to replace the
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torque switch on the Unit 1 RER cold leg isolation valve 1HV8716B.
The commitment to replace the torque switch was primarily based on a
torque switch roll pin failure that occurred on 1HV8716B in October
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1987 and a. subsequent failure of 1HV8716A in February 1988. The pin
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failures were attributed to high unseating thrusts discovered during
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the February outage, due to thermal binding.
The torque switch for
1HV8716A was replaced, holes drilled in the discs of valves 1HV8716A
and B to alleviate thermal binding, and 1HV8716B torque switch was
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proven operable through diagnostic testing.
The most recent
diagnostic test again showed 1HV8716B torque switch to be operable;
therefore, the licensee does not intend to replace the torque switch
as previously committed,
c.
(Closed) Inspector Followup Item 50-425/89-11-01, M0V Fasteners with
less Than Full Thread Engagement.
This item identified M0V adapter to actuator and motor to actuator
fasteners that did not have full thread engagement.
The licensee
reviewed the valves identified with a thread engagement problem on
the adapter to actuator fasteners and actuator to valve fasteners and
determined that the bolting configurations were installed correctly.
The bolt lengths were verified based on vendor part numbers and field
walkdowns. The bolts that were threaded into the actuator housing or
adapter flanges did not utilize nuts.
The bolts had thread
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engagement equal to or greater than the thread engagement when using
a nut.
The licensee also reviewed the motor to actuator fasteners
using studs and nuts and determined that full thread engagement had
not been achieved.
To correct the situation the licensee added a
step to the maintenance checklist to check for full thread engagement
on Limitorque operators during the next maintenance cycle.
Within the areas inspected, no viciations or deviations were identified.
10. Exit Interview
The inspection scope and results were summarized on November 17, 1989,
with those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection results listed
above.
Proprietary information is not contained in this report.
Dissenting comments were received from the licensee in the area of PORV
logic circuitry testing, and PSV setpoint temperature correction factor.
The licensee stated that TS 4.4.4.1 did not require the PORV automatic
function to be verified as part of the performance of a channel
calibration, therefore, they were not in violation of TS 4.4.4.1.
In
addition, the licensee stated that based on inplant testing data for
their PSVs, the PSV setpoint temperature correction factor was a one to
one relationship, therefore, their setpoint test method was not a code
violation.
Subsequent to the inspection, the inspectors informed licer.see management
via telephone on November 29, 1989, that the issue of the PSV setpoint
temperature correction factor would be identified as an unresolved item in
lieu of a code violation.
The licensee management committed to an additional review of GL 89-04 and
revision of any implementing procedures, as necessary, to comply with the
GL 89-04 positions regarding IST.
Item Number
Description and Reference
424/89-31-01
Violation - Failure to Adequately Test
425/89-36-01
PORV Circuitry in Accordance with
424/89-31-02
Unresolved Item - PSV Setpoint
425/89-36-02
Temperature Correction Factor
424/89-31-03
Inspector Followup Item - Questions
425/89-36-03
regarding WYLE Test Results
Licensee management was informed that the following items were closed:
IFI 50-424/88-51-01, paragraph 9.
IFI 50-424/88-10-01, paragraph 9.
IFI 50-425/89-11-01, paragraph 9.
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11. Acronyms and Initialisms
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ANSI
American National Standards Institute
A0V
Air Operated Valve
American Society of Mechanical Engineers
CFR
Code of Federal Regulations
'F
Degrees Fahrenheit
i
Engineered Safety Features Actuation Signal
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GL
Generic Letter
i
GPM
Gallons per Minute
IFI
Inspector Followup Item
Inservice Inspection
Inservice Testing
Loss of Coolant Accident
MOV-
Motor Operated Valve
NRC
Nuclear Regulatory Commission
Nuclear Service Cooling Water
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Pressure Isolation Valve
PORY
Power Operated Relief Valve
4
Pounds per Square Inch, Gage
PSV
Pressurizer Safety Valve
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REV
Revision
RF0
Refueling Outage
Relief Request
Safety Evaluation Report
Safety Injection
TS
Technical Specifications
Unresolved Item
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Vogtle Electric Generating Plant
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ENCLOSURE 3
'. ., 4
Novembec 15, 1989
MEMORANDUM FOR: D. 8. Matthews. Project Director (14H 25)
Pro'ett Ofrectorate 81 8
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Div sten of Reacter Projects - t/!!
l
Robert C. Jones.BranchActing Chief
PROM:
Reactor Systems
Division of Systems Technology
V00118 UNIT 1 INTERPRITATION OF 78 3.4.4 LINITIN8
SUBJECT:
ett!0N FOR. OPERATION. AtLIEF VALVES
Plant Name
Vogtle Unit !
TACNe(s).:
728?1
DocketNe(s):
80-42d
Pro,4ect Directorate
ProjectDirectorate!!3
4ect Nanager:
J. NeDkins
Revlow Bronch:
SRX8/D87
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Review Status:
Complete
In tele $one discussion en November 9.1989 the NRC Region !! Vogtle Unit 1
Senior tesident Inspector ($RI) and the licensee (Georgia Power Company)
requested an NRR position with regard to surveillance requirement 4.4.4
eddressing PORV testing. The issue is whether or not the automatic function of
the PORY need be testes in order to satisfy the requirements of TS 4.4.4.
In addition, the licensee stated its intent to pursue the ' automatic *
surveillance mode in January 1990 et their next block valve surveillance
intervs1.
PORY surveillance testing at the required
The licensee performed the 'menua18
interval. Nowever, the SRI interpreted the surveillance requirement to mean
The difference of the
that the ' Automatic" function should also be included.
two approaches means that a small portion of the circuitry is not tested.
(The valve is stroked in the manual mode.) However. if tne surveillance
requirement is intended to include the automatic sode and the estomatic
function is not tested then the PORVs should be declared inoperable. For
causes of inoperability other than excessive seat leekage, action statement "b'
epplies and the plant must shut down.
The licensee's interpretation is that the manual mode is adequate because:
action statement 'e' of this LC0 (if there was excessive seat leakage)
1.
would allow indefinite plant operation with both block valves closed
1.e.. without the PORY automatic function.
the langvege of the Vogtle FSAR Chapter 15 which does not require (nor
2.
use) the PO.RY automatie actuation and
Contact:
L. Lois. SRXB/ DST. x20890
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the fact that under severe accident conditions the p0RVs will be used in
the manual mode.
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The reasons for their present avoidance of this test are:
(1)toavoidanother
PORV. streking, and (t) because the part of the circuit which has not been
tested is a passive circuit of very high reliability.
The staff's interpretation of the surveillance requirements are that the
eetonatic function of the PORVs must be assured oncept for esses of excessive
PORY seat leakage. This is because of the following safety considerations
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associated with the automatic function:
(1)assurancethatthevalveswill
not open at er below normal primary system pressure (thus causing a small break
LOCA) and (t) sinialaing challenges to the pressuriser code safety valves.
With regard to the licensee's plan to continue operation satil January 1990
prior to testing the automatic function, we find this acceptable because:
11) the block valves are operable and can be closed in the event of an
onadvertentPORVepening.lt5thePORVsarenotdirectlycreditedinthe
..
licensee's safety analyses. (3) identical components have been recently
successfullytestedattheotherVogtleUnit,(4)theportionofthe
surveillance test performed covered the major parts of the cirevitry and the
mechanteel portion of the valve including the setpoints,llances.and(6)theItcensee
plans to include the automatic function in future survei
/s
Robert C. Jones.BranchActing Chief
Reactor Systems
Division of Systems Technology
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