ML20011D504

Responds to Violations Noted in Insp Repts 50-348/89-26 & 50-364/89-26.Corrective Actions:Personnel Involved in Preparation of Inservice Test Procedures Counseled. Violation B Re Opening of Pressurizer PORV Denied

ML20011D504
Person / Time
Site:	Farley
Issue date:	12/22/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912270333
Download: ML20011D504 (6)

Text

w c v-Alabama Power Company

• 40 invernecs Center Partwry

, . Post Office Box 1295

• Dirmingham, Alabama 35201 lelephone r05 668,5501 W. G Hairston,Ill Senior Vice President Nuclear Operation. Alabamafbwer

!!e sanhwn &ectnc $ystem December 22, 1989 Docket Nos. 50-348 ,

50-364 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Nashington, D. C. 20555 j

SUBJECT:

Reply to a Notice of Violation i J. M. Farley Nuclear Plant NRC Inspection of October 2-6 and October 16-20, 1989  !

s RE: Report Number 50-348/89-26-01, 02 ,

50-364/89-26-01, 02 -

Gentlemen:

'Ihis letter refers to the violations cited in the subject inspection reports '

which state:

"During the Nuclear Regulatory Commission (NRC) inspection conducted on October 2-6, 1989 and October 16-20, 1989, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure i for NRC Enforcement Actions," 10 CrR Part 2, Appendix C (1989), the violations  ;

are listed below:

A. hchnical Specification 4.0.5 requires inservice testing of ASME Code i Classes 1, 2, and 3 pumps and valves in accordance with Section XI of the '

ASME Boiler and Pressure Vessel Code and applicable Addenda. The licensee is comitted to inservice testing in accordance with the 1983 Edition of  ;

-the Code and Summer 1983 Addenda  ;

a. Section XI, subsection IWP-3100 requires that each measured test quantity be compared with the reference value of the same quantity.

Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

Contrary to the above, Unit 1 and Unit 2 turbine driven auxiliary feedwater pump inservice testing procedures rNP-1-STP-22.16 and 4 FNP-2-STP-22.16 did not contain acceptance criteria for a comparison of pump differential pressure for the Table IWP-3100-2 High Values in the Alert Range and Required Action Range. As such, differential i pressure comparisons were not made with the limits given in Table IWP-3100-2.

b. Section XI, subsection IWV-3522 requires valves whose function is to prevent reversed flow to be tested in a manner that proves that the

-disk travels to the seat promptly on cessation or reversal of flow.

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Contrary to the above, the Unit 1 and Unit 2 turbine driven auxiliary feedwater pump steam supply stop check valves W3235A and W3235B were not reverse flow tested in a manner that proves the disk travels to i the seat on cessation or reversal of flow,

c.Section XI, subsection IW-3522 requires valves whose function is to prevent reversed flow to be tested in a manner that proves that the e

disk travels to the seat promptly on cessation or reversal of flow.

Contrary to the above, the Unit 1 and Unit 2 motor driven auxiliary  ;

feedwatar pump discharge check valves V002h and V0025 were not reverse flow tested in a manner that proves the disk travels to the seot on I

cessation or reversal of flow.

Section XI, Subsection IW-3412 requires valves to be exercised to the j d.

position required to fulfill their function. Subsection IW-3413(b) l requires the stroke time of all power operated valves to be measured.

Contrary to the above, Unit 1 and Unit 2 turbine driven auxiliary feedwater pump steam supply stop check valves W3235A and W32358 are  ;

l power operated 7sives which perform a function in the closed direction, and stroke times were not measured. i This is a Severity Level IV violation (Supplement I).

B. Technical Specification 4.4.5.1 requires each Power Operated Relief Valve (PORV) to be demonstrated operable at least once per 18 months by performance of a channel calibration and operating the valve through one cycle of full travel. A channel calibration requires that the entire .

channel be calibrated, and shall include a channel functional test, in which an injection of a simulated signal into the sensor verifies operability, including alarm and/or trip functions.

contrary to the above, PORV channel calibration did not fully test the l automatic function contact and associated wiring and circuitry. As such, l

the entire PORV channel was not calibrated.  !

This is a Severity Level IV violation (Supplement I)." q l

Admission or Denial l Violation A Violations a, c, and d occurred as described in the subject reports, l Alabama Power Company denies violation b.

Section XI, subsection IW-3522 states the following for normally open check )

valves:

l i Valves that are normally open during plant operation and whose function '

is to prevent reversed flow shall be tested in a manner that proves that the disk travels to the seat promptly on cessation or reversal of flow. .

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'Ihe Subsection continues to state the following for normally closed check valves Valves that are normally closed during plant operation and whose function is to open on reversal of pressure differential shall be tested by proving that the disk moves promptly away from tho seat when the closing pressure differential is removed and flow through the valve is initiated....

Concerning the exercising of check valves, the Subsection states Check valves shall be exercised to the position required to fulfill their function....

In the minutes of the public meetings on Generic Letter 89-04 dated October 25, 1989, question 2.5 asks Previous to this iG.L. 89-04), it was permissible to verify closure of stop-check valves simply by operation of the stem (shaft). Is this acceptable instead of reverse flow testing?

In response, the NRC stated:

Verification of cle'sure capability of stop check valves by using the handwheel meets the ASME Code requirements. This, however, is not the preferred method of test. The NRC staff considers reverse flow testing to be a more reliable indication of valve operability.

The currently approved Farley Nuclear Plant IST Plan identifies valves W3235A and W3235B as normally closed valves and requires forward and reverse flow testing. Alalema Power Company procedures at the time of the inspection implemented this Plan requirement.

Alabama Power Company also considers the verification of closure capability by use of stem operation at rarley Nuclear Plant to be an acceptable method of Code testing, although it is not the NRC's preferred method of test.

To address the additional NRC issue of valve closure, Alabama Power Company will disassemble check valves V010A and B which are downstream of valves HV 3235 A and B.

Although reverse flow testing is the preferred method of test by the NRC, system configuration will not allow reverse flow testing. A relief request will be submitted for disassembly and inspection of V010A and B on an alternating basis at each refueling outage.

Violation B Alabama Power Company denies this violation.

Alabama Power Company does not agree that automatic opening of the pressurizer PORV is required to be tested for the following reasons:

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a. Automatic PORV operation is not assumed in the safety analyses. Thus, l PORV operability is not dependent on the automatic opening of the PORV.

PORVs are not required for overpressure protection. Consequently, automatic operation of the PORVs is not required and surveillance testing of the manual portion of the PORV control circuit is sufficient to meet Technical Specification requirements.

b. Furthermore, action statement A of Technical Specification 3.4.5 allows ,

indefinite operation with both PORV block valves closed. Closing of the block valves precludes automatic operation of the PORVs. l Consequently, the Technical Specifications acknowledge reactor l operation without the automatic portion of the PORV control circuit. ]

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c. Moreover, fot several acci& nt conditions the FORV2 ere operated in the  :

manual mode. Emergency piocc3 ares provida direction to the operators  !

for operStion of the PORVs. Consequently, the manual control circuit .

for the PORVs is telled on to ensure safe operation.

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d. Finally, the procedures listed in the subject Inspection Report as accomplishing the surveillance requirement are organized to reflect the philosophy of (a!-(c) above. Two of the procedures are designated

" IMPS", instrument maintenaace proceddres. IMPS are not utilized to meet "schnical Specification requirement % Technical Specification

• requirements are met with "STPs", surveillance test procedures.

In summary, Alabama Power Company does not consider the automatic portion of the PORV control circuit to be covered by the surveillance requirement.

The manual portion of the PORV actuation circuit is covered by the Technical Specification and is addressed in surveillance test procedures.

However, after discuscion with the NRC, Alabama Power Company agrees to test the automatic opening portion for these valves at least once per 18 months. Although testing will be performed, it is not considered a i

requirement to meet Technical Specification requirement 4.4.5.1. .

i Reason for Violation .

Violation A

a. Personnel error in that the Inservice Testing (IST) Plan criteria for high pump differential pressure was not included in the procedure,

b. Not applicable

c. Personnel error in that the IST test procedure did not ensure that IST l

L Plan requirements were met,

d. Personnel error in that the IST Program and Plan did not specify verification of valve stroke time in the close direction and that the procedure did not include an acceptance criteria to verify closure of the valve.

j Violation B Not applicable

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Corrective Action Taken and Results Achieved Violation A i

a. FNP-1/2-STP-22.16 have been revised to provide acceptance criteria for high pump differential pressures. A review of surveillance test data  ;

• sults from both units indicates that at no tine did the differential '

pressurs for the turbine driven auxiliary feedwater pumps on either unit reach a value that would have resulted in the pumps' differential j pressure being in the " Alert" or " Required Action Range",

b. No corrective action is required. Current precedures test HV3235A T and HV3235B in a code acceptable manner.  !

c. The motor driveo auxiliary feedaster pump dischargo check valves have  ;

been reverse flow tested for both units and will be reverne flow  ;

tested quarterly in accordance with the IST plan. i

d. The IST procedure for testing valves HV3235A and HV3235B has been j

revised to tine stroke the valves in the closed directico. These valves have been tested.

Violation B '

Based upon discussions with the NRC, the surveillance test which strokes the PORVs has been revised to include functional testing of the automatic ,

function contacts and asr.*ciated wiring and circuitry. The functf.onal test ,

has been satisfactorily perform d on both the Unit 1 and Unit 2 PORVs.

Corrective Steps To Avoid rurther Violations Violation A

a. Personnel involved in preparation of inservice test procedures have been counseled.

b. To further address NRC concerns of verification of closure capability, relief requests will be submitted to require disassembly and inspection of check valves V010A and V010B on an alternating basis for each refueling outage,

c. An itein by item review of the ISI plans and implementing procedures will be performed to ensure all items are proceduralized and no similar problems exist.

Violation B

a. As a result of the NRC concern, the functional test will be performed every 18 months during the performance of the surveillance test which i strokes the PORVs. The surveillance test for stroking the PORVs is required by the Master List of Surveillance Requirements,

b. Channel calibration procedures will be changed from Instrument Maintenance Procedures to Surveillance Test Procedures. The calibrations will be performed as required by the Master List _of Surveillance Requirements.

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Date of rull compliance  ;

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Violation A l

! 3eptember 1, 1990 Violation B December 31. 1989 l Affirmation i I affirm that this response is true and complete to the best of ry knowledge, I '

infonetion, and belief. 7hs information contained in this letter is not conf,idered to be of a proprietary nature.

Respectfully sutaitted, (1 / p$. /lh' W. G. Hairston, III ,

WGHiemb-5.7 ces Mr. S. D. Ebneter >

Mr. E. A. Reeves Mr. G. F. Maxwell- i t

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