05000263/LER-1992-012, :on 920824,six RHR Svc Water Valves,Two ESW Valves & Two EDG Emergency Svc Water Valves,Noted During NRC Insp,Not Included in ASME Section XI Program.Caused by Code Misinterpretation.All Components Will Be Tested
| ML20127L383 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/19/1992 |
| From: | Hammer S NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20127L381 | List:
|
| References | |
| LER-92-012, LER-92-12, NUDOCS 9211240073 | |
| Download: ML20127L383 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(1) |
| 2631992012R00 - NRC Website | |
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AssTR AC, m to,so -e,, e e-am u-,4, -e,;-,,ema,, o i On August 24, 1992, six Residual Heat Removal Service Water valves, two Emergency Service Water valves, and two Emergency Diesel Generator Emergency Service Water valves not in the ASME Section XI program were identified by an NRC inspection taam as appearing to meet the criteria to be included in the program.
On October 20, 1992, it was determined that five additional valves were not being tested as required by the ASME Section XI program, and on October 27, 1992, three concerns from an NRC inspection were determined to be reportable. The cause was misinterpretation of the ASME Section XI Code, and inadequate review by plant engineering staff.
All components have been tested or will be tested during the next refueling outage.
The ASME Section XI Testing program will be revised as required.
The lessons learned will bc presented in Engineering and Technical Staff Continuing Training.
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"MR" M'in v:aa Monticello Naclear Generating Plant 0 lb l 010 l 0 l 2 l 6 l 3 912 l- 0 l1 l 2 0l 1 0l2 0F 0l6 TLKT W more spece e reewes. one eMaone! NRC fewm JtRL4 % l1h DIS _CAlPTI03 G
On Augt sc 24, 1992, with the plant operating at 100% of rated thermal power, an NRC inspection team identified six manual valves (EIIS Cc >onent: V) in the Residual lleat Remova: Service Water (EIIS System: B11 system, two manual valves in the Emergancy Service Water (EIIS System: BI) system and two manual valves in the Emerbency Di-1 Generator Emergency Service Water (EIIS System:
BI) systen. which appeared te meet the requireinents for ASME Section XI testing i
but weto not included in the ASME Section XI progtam.
Subsequent evaluation I
by plant engineering staff confirmed that the valves meet the criteria to be included in the Section X1 Testing Program.
The valves identified in the Residual llent Removal Service Water system were RilRSW-21-1 (#11 Residual llent Removal Service Water Pump Motor Cooling Outlet), RilRSW-21 2 (#12 Residual lleat Removal Service Water Pump Motor Ccoling Outlet), RilRSW 21-3 (#13 Residual lleat Removc1 Service Water Pump Motor Cooling Outlet), RilRSW-21-4
(#14 Residual Heat Removal Service Water Pump Motor Cooling Cutlet), R11RSW-3-1
(#11 and #13 Residual }{ eat Removal Service Water Pump Strainer Bypass), and RilRSW-3-2 (#12 and #14 Residual lleat Removal Service Water Pump Strainer Bypass). The valves icentified in the Emergency Service Water system were ESW-3-1 (#11 Emergency Diesel Generator Emergency Service Water Pump Strainer g
Bypass), ESW-3-2 (#12 Emergency Diesel Generator Emergency Service Water Pump Strainer Bypass), ESW-19 (#14 ESW Pum;. Strainer Bypass), and ESW-20 (#13 Emergency Service Water Pump atrainer Bypass).
The Residual Heat Removal Service Water motor cooler valves are normally closed and are opened by operations personnel during pump operations. These valves would be required to operate during an event to insure operability of the Residual llent Removal Service Wa er pumps (EIIS Component: P) and containment cooling. Although not incl'ided in the Section XI Program, the valves were baing exercised each quarter during Residual lleat Removal Service Water pur
' veillance testing.
The Emerges:
xvice Water, Emergency Diese1 Generator Emergent:y Service kater, and msidual llent Removal Service Wate.? strainer bypass valves would need to be opened to insure adequate flow if the stra.iners (EIIS Component:
STR) were to become clogged. On August 24, 1992, these valves were exercised to demonstrate they meet Section XI requirements.
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- eperating at 100% of rated thermal power, and during the performante of systems review for the ASME Section XI program by syntem enginters, it was determined that five check valves which could be used to mitigate c. postulated accident condition were not being tested as required by the ASME Section XI Program.
This review was prompted by the corrective actions taken for revision 0 of this Licensee Event Report.
The five check valves (Ells Component: V) are PAS-59 5 and PAS 59-6 (Residual lloat nemoval Loop Sample Supply Excess Flow Check Valves) in the Post Accident Sample System (EIIS System: IP), Al-629 (Torus Vacuum Breaker Air Supply Check Valve) (E!!S Syntem: LD), Al 598 ("F" SRV Alternate N2 Supply Check Valve)
(Ells System: LR), and Al-599 ("h' SRV Alternate N2 Supply Check Valve).
Al-629, Al 598, and Al-599 have been tested in the open position quarterly, but the closed position has only b'ren tested as part of Appendix J requirements once each cycle.
PAS 59 5 and PAS-59-6 had not been routinely tested.
On October 27, 1992 it was determined by plant management during a review of an NRC Not. ice of Violation associated with Inspection Report 50-263/92010 that three ASME Section XI concerns identified during the NRC inspection may be reportable The three concerns involved:
The use of reference curves instead of n ecific reference values for testing of Emergency Service Water Pumps all, u12, #13, and #14 as required by ASME Code Section XI.
Failure to conduct full flow testing of four Emergency Service Water check valves, ESV $/ (#14 Emergency Service Water Pump Discharge Check Valve), ESW-18 ( - s Emergency Service Water Pump Discharge Check Valve),
ESW-2: inl4 Emergency Service Water Pump Discharge Obeck Valve), and ESW-24 gal 3 Emergency Service Water Disenarge Check Valve).
Failure t o verify the closed position of Residual lleat Removal Service Water pump Sek valves Pl!RSW-1-1 (all Residual licat Removal Service Water Pump i.ischerge Chcck Valve), RHRSW 1 2 (#12 Residual lleat Removal Service Water Pump Discharge Check Valve), RilRSW-1 3 (#13 Residual lleat Removal Serv ko Water Pump Discharge Check Valve), and RllRSW 1-4 (#14 Residual llent Removal Service Water Pump D.scharge Check Valve).
4 On November 10, 1992, it was determined by the plant engineering staff during 3
a further review of the Section XI program that portions of two systems were not included in the Section XI Pressure testing program.
The components not 1.cluded were Code Class 2 piping less than 4 inches in diameter in the Standby Liquid Control (EIIS: System BR) and Combustible Gas Control (Ells System: VB) systems.
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Technical Specification 4.J5.B states in part, " Inservice Testing of Quality Group A, B, and C pumps and valves shall be performed in accordance wit.h the requirements for ASME Code Class 1,2, and 3 pumps and valves, respectively, contained in Section XI of the ASME Boller and pressure Vessel Code".
Article IWV 1000 states, " Valves... which are required to perform a specific function in shutting down a reactor to cold shutdown condition in mit.1 gating the consequences of an accident", should be included in the Section XI testing program. The valves associated with this event should have been included in the ASME Section XI testing prog, ram and tested in accordance with Inservice Testing requirements.
This is a condition prohibited by Technical Specifications and is report able by 10 CPR 50.73(a)(2)(1).
l DbMEL The cause of these events was failure to properly interpret and impicment ASME Section XI requirement s by plant engineering staf f.
The events of August 24 and October 27, 1992, were not cognitive errors.
The events of October 20, and November 10, 1992, were cognitive errors.
There were no unusual characteristics of the work location. Tnis was not contrary to any approved procedure.
tdiALLSIS The use of reference curves instead of reference values did not result in any undetected pump degradation.
All valves wera tested and shown to be operabic.
Since all components were operabic there were no consequences to the henith and safety of the public from this event.
[DIU1ECTIVE ACTION The following actions have been completed:
1.
All the identified Residual lleat Remova'. Service Water, Emergency Service Water and Emergoney Diesel Generator Emergency Service Water valves have been exercised to verify they meet Section XI requirements.
2.
Emergency Service Vater, Emergency Diesel Generator Emergency Service Water, and Residual lleat Removal Service Water-ASME Section XI surveillance procedures have been revised to include testing of Emergency Service Water valves ESW-19 and ESW 20, Emergency Diesc1 Cenerator Emergency Service Wator valves ESW 3-1 and ESW-3-2, and Residual lleat Removal Service Water valves RilRSW-3-1 and RilRSW-3 2.
Residual lleat Removal Service Watar valves RHRSW 21 1, RllRSW-21-2, RilRSW 21-3 and dilRSW 21-4 will be left in the normally open position and may therefore be excluded from the ASME Section XI program.
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A review of all systems contained in the ASME Section XI program has been completed to identify any manual valves which are used to mitigate the consequences of a design or license bases accident.
4.
All pump reference curves have been deleted from ASME Section XI testing procedures.
5.
The inservice test procedure for full flow testing of four Emergency Service Water pump discharge check valves (ESW 17, ESW 18 ESW 23 and ESW 24) has been revised and the test. performed satisfactorily.
6.
The test procedure for Residual lleat Removal Service Water pump dfscharge check valves Rl!RSW 1 1, RilRSW-1 2, Ri!RSW-1 3 and RilRSW 1 4 has been revised and the test r'rformed satisfactorily, 7.
Check valves PAS-59 5, PAS-59-6, Al 629, Al 598 and AI 599 have been ratisfactorily tested, 8.
All systems included its the Section XI testing program have been reviewed for Code Class 2 piping less than 4 inches diameter, The following actions will be completed:
1.
With the exception of the four Rl!RSW valves noted_in corrective action (2.) above, all previously unidentified valves and piping will be added to the ASME Section XI Testing Program, 2.
The pressure tests for Standby Liquid Control and Combustible Gas control systems will be prepared and performed prior to the end of the 1993 refueling outage.
l 3.
The modification process will be revised to provido an additional review l'
by the section XI program coordinator, as needed, to assure program requirements are met, 4.
This event will presented at Engineering Technical-Staff Continuing j
Training.
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ADDITIONAL INFORMATION
Failed Components identification None
Previous Similar Events
f 1,1censee Event Report 92-010 identified two manual valves in abnormal procedures, which had not been identified as performing a function to mitigate the consequences of a license bases event and therefore should have been evaluated for inclusion in ASME Section XI Testing Program.
The corrective actions for that c'/ent (review of-all abnormal procedures and revision of administrative controls associated with abnormal procedure development) would not have resulted in identification of the valves associated with this event.
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