ML20195C861
| ML20195C861 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 06/07/1988 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20195C836 | List: |
| References | |
| 50-369-88-13, 50-370-88-13, NUDOCS 8806220300 | |
| Download: ML20195C861 (10) | |
See also: IR 05000369/1988013
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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REGION 11
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101 MARIETT A STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.: 50-369/88-13 and 50-370/88-13
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.:
50-369 and 50-370
License Nos.:
Facility Name: McGuire : and 2
Inspection Conducted: May 2-6, 1988
Inspector:
b.
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E. H. Girard~
Date Signed
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Approved by:
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J.
laRs, Chief
D6te' Signed
at ials and Processes Jection
i sion of Reactor Safety
SUNMARY
Scope:
This routine, unannounced inspection was conducted on site and at the
corporate offices in the areas of NRC Diagnostic Evaluation Team Report
findings and action on previous inspection findings.
Results:
The inspector observed that the licensee's Performance Group was
relatively unresponsive to NRC inspector identified concerns.
Repeated
questioning was required to obtain information needed to determine that
procedures and hardware performed properly.
Examples of this unresponsiveness
are described in Paragraphs 3.a, 3.c and 3.d.
One violation was identified involving inadequacies in the licensee's methods
of measuring stroke times, (Paragraph 3.d).
Two new unresolved items were
identified based on information described in a NRC Diagnostic Evaluation
completed early in 1988.
The unresolved items involve apparent deficiencies in
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the licensee's inservice testing program for pumps and valves (Paragraph 2.b)
and their failure to provide testing for many safety-related relief valves
(Paragraph 2.b).
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8806220300 880609
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
- N. Atherton, Production Specialist III, Compliance, McGuire Num.r
Station (MNS)
T. Cook, Mechanical Maintenance, MNS
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D. Gabriel, Technical System Manager, Nuclear Production Department (NPD)
G. Gilbert, Assistant to Station Manager, MNS
- B. Hamilton, Superintendent of Technical Services, MNS
S. Hart, Mechanical Maintenance Engineering, NPD
- T. McConnel, Station Manager, MNS
- S. Morales, Associate Engineer, Performance, MNS
B. Nardoci, Licensing Engineer
J. Oswald, Lead Engineer, Performance, MNS
R. Pierce, General Supervisor - Unit 1. Instrumentation and Electrical,
W. Rixson, Corporate Manager of Project Control
- D. Smith, Test Engineer, Performance, MNS
- J. Snyder, Performance Engineer, Performance, MNS
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NPC Resident Inspector
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- W. Orders, Senior Resident Inspector
- Attended exit interview
2.
NRC Diagnostic Evaluation Team Report Findings (92701) Units 1 and 2
This inspection initiates Region II followup of the NRC diagnostic
evaluation of licensee performance for McGuire Nuclear Station.
The
diagnostic evaluation referred to was conducted between November 1987 and
January 1988 and a report of the evaluation was transmitted to the
iicensee in a letter dated April 8, 1988. The report describes strengths
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and deficiencies identified in the licensee's performance.
The NRC
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transmittal letter requested the licensee to provide a written response to
the report.
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In the current NRC inspection the inspector examined the status of the
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licensee's preparation of a written response and of their corrective
actions for the more important of the reported deficiencies:
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a.
Status of Written Licensee Response
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The inspector ascertained that the licensee had selected a nine-man
corporate team to prepare a written response to the NRC diagnostic
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evaluation report.
The licensee's team was headed by the corporate
Manager of Project Control and the McGuire site was represented by
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the Assistant to the Station Manager. The inspector interviewed both
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of these individuals and obtained the following status information:
Each member of the team had been provided a copy of the
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inspection report.
The NRC had not specified a date for response submittal and, as
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yet, none had been set by the licensee.
It was expected that a
schedule might be determined at the next team meeting, which was.
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scheduled for May 12, 1988
The site was preparing a preliminary response addressing the
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deficiencies described in the NRC report.
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b.
Status of Corrective Actions
An NRC management review of the diagnostic evaluation determined that
two of the areas of deficiency identified recuired partir Sar
attention in Regional inspections.
Those deficiencies involved
inadequacies in the licensee's ASME Section XI inservice testing
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(IST) program for pumps and valves and the licensee's failure to
require periodic testing of any of their safety-related relief valves
other than main steam and pressurizer relief va';ves.
The inspector
discussed these deficiencies with licensee management and was
provided the following information:
Section 3.3.3.1 of the NRC Diagnostic Evaluation Report
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described IST program check valve testing deficiencies.
These
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deficiencies are referred to in Licensee Event Report
369/88-33-01 (4/18/88).
The inspector questioned licensee test
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and engineering personnel regarding specific actions taken
relative to this matter and received the following information:
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Procedures for forward and reverse testing check valves
1SA-5, 2SA-5, 1SA-6 and 2SA-6 had been or were being set up
as described in Problem Investigation Report 0-M87-0301A
(copy reviewed by inspector).
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Licensee engineering personnel had completed an . interim
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review of their IST of check valves as documented in
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Memorandum MBME-88-066 (3/4/88).
Initially, 60 check
valves per unit (120 total) were identified as requiring
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further review to determine whether closure testing was
required.
As described in the memorandum,14 of the 60
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were determined to required closure testing and closure
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testing was recommended (but stated "not required") for
another approximately 30 valves.
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Licensee personnel stated that their IST program had been
corrected to include additional required check valve
testing and that their new program would be mailed to the
'NRC for review on May 6, 1988.
Section 3.3.3.1 of the NRC report also indicated that Auxiliary
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Feedwater System valves CA-1 through CA-6 appeared to have been
erroneously omitted from the licensee's IST program.
Licensee
Performance personnel informed the NRC inspector that these
valves were not required to be in the IST program and that they
thought that the matter of these valves had been resolved to the
satisfaction of the NRC team who performed the diagnostic
inspection.
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Section 3.3.3.2 of the NRC report, in part, noted conflicts
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between manual and Operator Aid Computer methods used by the
licensee in stroke timing valves.
This matter had been
previously identified by Region II and its resolution is
described in Paragraph 3, below.
Section 3.3.3.4 of the NRC report noted that the licensee had
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used an IST program relief request before its approval, which is
contrary to the requirements of Technical Specification 4.0.5.a..
The request provided for a change from quarterly to
cold shutdown testing of two valves.
Licensee personnel noted
that the applicable ASME requirements permitted the use of cold
shutdown testing when valves could not be tested quarterly.
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is the NRC inspector's understanding that NRC reviewers
currently do not require licensee's to submit relief requests to
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change from quarterly testing of valves to cold shutdown testing
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when there is an adequate basis.
Instead, the reviewers require
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that justification for cold shutdown testing be provided in the
licensee's IST program for their review and evaluation.
If this
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is the case, the licensee's failure to submit a relief request
for the cold shutdown testing may not represent a deficiency.
Section 3.3.3.6 of the NRC report stated that the licensee
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testing was deficient in that they required no routine testing
for safety-related relief valves other than main steam and
pressurizer relief valves.
The report also indicated that
during the diagnostic evaluation the licensee had committed to
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develop a testing program for safety-related relief valves.
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On-site licensee management indicated they were unaware of a
commitment.
However, licensee Perfonnance personnel informed
the inspector that it was their understanding that a relief
valve testing program would be developed by October 1988.
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The inspector informed the licensee that the IST program deficiencies
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described in the NRC diagnostic evaluation report represented a
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possible violation of NRC requirements but that, pending an NRC
review of their response and an assessment of the safety
significance, it would ' be identified as unresolved item 369,
370/88-13-01, IST Program Deficiencies.
The matter of relief valve
testing was r,imilarly designated as an unresolved item and was
identified 369, 370/88-13-02, Relief Valve Testing.
The NRC
requirements applicable to testing of safety-related valves will be
reviewed aloag with the licensee's response in determining whether
the matter represents a violation.
The inspector informed the
licensee that, while the perceived deficiencies in their IST program
and relief valve testing were considered of primary importance, other
weaknesses and deficiencies described in the diagnostic report could
represent potential enforcement items and should not be neglected.
These other matters will t,e examined by Region II in subsequent
routine inspections.
3.
Actiun 'on Previous Inspection Findings
a.
(Closed) Unresolved Item (369, 379/86-26-08):
Written Criteria for
Evaluation of Erratic Valve Action
This item identified the inspector's concern that the licensee had no
written criteria covering their evaluation of valve test information
for identification of erratic or abnormal valve action. The licensee
has a compilation of valve stroke time data accessible through
computer, which they state is used to aid in identifying erratic or
abnormal valve operation from stroke time testing.
The identifi-
cation and reporting of erratic or abnormal valve operation is
required by ASME Section XI (80W80), which is the applicable Code for
the licensee's valve testing program.
The licensee's Performance Test Engineer had previously informed the
NRC inspector that written criteria covering the use of the computer
valve data base was in preparation and would be completed by the end
of 1987.
This date was not met and the inspector brought the matter
to the Station Manager's attention or January 8, 1988, As stated in
NRC Inspection Report No. 50-369, 370/88-01, the Station Manager
requested Performance personnel to prepare procedural changes to
resolve the inspector's concern within two months.
In the current inspection the NRC inspector questioned the licensee
Performance Test Engineer regarding their action on this matter. The
inspector was provided an untitled draft Performance Directive which
he understood was to be implemented shortly.
Four months had passed
since Inspection 369,370/88-01 and the licensee still had no approved
criteria ~1 dressing the inspector's concerns.
The inspector reviewed the subject Performance Directive and found
that it appeared to address most of his previourly stated concerns
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with one significant exception - it did not appear to contain
adequately based criteria for establishing when changes in valve
stroke time were deemed large enough to consider abnormal.
The
applicable Code does not define abnormal and the licensee has elected
to use proposed Code limits beyond which increased testing frequency
is specified.
Based on a licensee relief request, the limits would
not apply to valves with stroke times of five seconds of less. The
Performance Test Engineer stated that the limits will be re-evaluated
later this year and changed if determined necessary.
In addition,
other licensee engineering personnel infonned the inspector that they
are participating in an Electric Power Research Institute sponsored
review that will examine stroke timing criteria specified by the
Code.
While the inspector still has concerns regarding the adequacy
of licensee action in this matter, he is satisfied that these will be
addrested in subsequent routine NRC inspection of the licensee's
valve testing program. The original item is considered closed.
b.
(Closed) Unresolved Item (369, 370/87-16-01):
IST Program
Requirements for PORVs and Block Valves.
This item expressed concern that the licensee did not provide for
complete ASME Section XI testing of both power operated relief valves
and block valves in their inservice testing program.
The inspector discussed the matter with responsible licensee
personnel and is satisfied that the required testing is-provided for
in the licensee's IST program.
The program was found to be in
preparation for submittal to the NRC in a May 6,1988 mailing.
On
this basis, the item is considered closed.
c.
(Closed) Unresolved Item (369, 370/87-16-02):
Bases for Setting
Maximum Stroke Times.
This item expressed concern that the licensee had not used adequate
bases in setting maximum stroke times. ASME Section XI requires the
licensee to set valve stroke time limits but does not state how the
limits are to be determined.
The licensee apparently elected to use
TS and system requirements (only) in setting the limits.
As a
consequence, the limits they specify are often greatly in excess of
times representative of valve failure.
Although the inspector
provided the licensee with NRC criteria for determining maximum
stroke times during Inspection Report No. 50-369, 370/87-16, the
Performance Test Engineer indicated that no action had been taken on
this matter as yet.
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The NRC reviewer responsible for evaluation of the licensee's IST
program informed the inspector that this matter would be addressed in
the evaluation.
The inspector understands this evaluation is to
begin shortly.
Therefore, the NRC inspector considers it unnecessary
for him to address this item further. The item is hereby closed.
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d.
(Closed) Unresolved Item (370/87-37-01): Valve Failed to Operate.
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This item identified concerns with regard to the valve stroke timing,
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As of the last NRC inspection of this item, the concerns requiring
resolution were as follows:
(1) Although valve 2RN-231 apparently failed to indicate the correct
movement to open in its first actuation during testing, the
licensee considered that the valve performed acceptably.
The
Performance Test Engineer stated that this type a valve had a
history of not tripping the second limit switch. A Work Request
(WR) was issued to check the valve within two weeks.
The NRC
inspector questioned whether that long a delay in verifying
correct valve operation was acceptable.
The Unit was operating
in Mode 1 at the time of-the test and the valve in question was
the decay heat removal pump 28 cooler isolation valve.
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The inspector has since reviewed the completed WR and found that
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it only states ; hat the valve was cycled five or six times and
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functioned properly.
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(2) TS 4.0.5 requires inservice testing in accordance with ASME
Section XI.
The testing specified by Section XI includes
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periodic stroke timing of power operated valves and comparison
of each time obtained with the previous value. When changes are
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observed that exceed specified limits
Section XI requires
actions, such as increased test frequency, to aid in assuring
valve operability.
For example, test frequency must be
increased or corrective action taken if a valve with a stroke
time over 10 seconds experiences a stroke time increase (from
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the previous test) of 25% or more.
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By implication, stroke time tests must be performed in a manner
which assures that times obtained for comparison are not unduly
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affected by changes in measurenent method or timing device
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inaccuracy.
water system valves)(e.g. , PT/1 or 2/A/4403/02 permitted the use of c
Licensee procedures
for nuclear service
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computer was unavailable) stopwatches for stroke timing.
For
a given valve, computer and stopwatch obtained times may differ
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up to approximately 10% because the computer and stopwatch
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measurements may be terminated at indications from different
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valve limit switches.
According to licensee personnel, the
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locations of these limit switches may differ by up to 10% of
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valve disc travel (or about 10% of stroke time).
The licensee
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did not account for this error in their procedures or practices.
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As a consequence, when timing methods were changed licensee
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determinations of stroke time changes could have been up to 10%
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in error and the need for actions required by Section XI could
have gone unrecognized. It should be noted that (according to
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licensee personnel) the limit switches referred to have a
maximum 10% difference for a given valve and the influence on
stroke time measurement may be significant less than 10% if the
switches are close together.
In an example observed by the
inspector, valve 2RN-279 stroked in 50.0 seconds per 0AC and
54.3 seconds per stopwatch, a 4.3 seconds or 8.6% dif ference.
(3) The licensee did not calibrate or otherwise provide assurance
that the accuracy of the stopwatches used for stroke timing was
maintained.
With regard to (1) above, at the end of NRC Inspection 369,370/87-37,
the licensee agreed to provide the NRC inspector with data supporting
their contention that valves like 2RN-231 had a history of not
trippino the second limit switch.
The inspector requested the data
at the beginning of Inspection Report No. 369, 370/87-40 but it was
never provided.
The NRC inspector again asked for the data during
Inspection 369, 370/88-01 but it was not provided and the inspector
comented adversely on the licensee's responsiveness during the exit
meeting.
When the inspector requested infonnation relative to (1)
during the current inspection, the Performance Test Engineer provided
him a typed statement that indicated there had been problems with
limit switches tripping and properly indicating on the subject type
of valve (the statement neither provided or referenced supporting
records), described valve operation with reference to an attached but
illegible circuit drawing, and stated the valve was scheduled to be
replaced (replacement documentation was referenced).
The data was
inadequate.
Subsequently, the inspector discussed the valve further
with Instrumentation and Electrical Maintenance personnel.
The valve
and a legible copy of the circuit drawing were reviewed during the
discussion and similar hardware was examined.
On the basis of this
information the inspector was satisfied that valve 2RN231 had
operated properly, except for indication, and since it was to be
replaced there was no further need for concern.
With regard to (2) above, the inspe:: tor was informed that tests were
being conducted to establish the difference between 0AC and stopwatch
stroke times for each valve for which both timing methods were
permitted.
With regard to (3), the inspector was informed that requirements to
assure maintenance of stopwatch accurey had been instituted.
(2) and (3) above are considered to represent deficiencies in the
licensee's program for inservice testing valves, in that the licensee
had not assured that changes in valves stroke times exceeding TS or
Code limits could be recognized.
This represents noncompliance with
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TS 4.0.5 requirements for conformance with' ASME Code Section XI and
is identified as Violation 369, 370/88-13-03, Stroke Timing
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Deficiencies.
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The original unresolved item is considered closed.
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e.
(Closed) Inspector Followup Item (369, 370/87-16-03):
Methods of
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Stroke Timing.
This item was identified for followup verification that the licensee
had completed procedural changes to assure that valve stroke timing
would be started with switch actuation.
The inspector discussed this
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matter with responsible licensee personnel and was informed that the
procedural changes were completed.
Further NRC verification will be
accomplished in routine inspections.
This matter is considered
closed,
f.
(Closed) Inspector Followup Item (370/86-14-03):
Verification of '
Snubber Test by Qualified Personnel.
Data relative to this item has been previously reviewed as described
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in NRC Inspection Report No. 369, 370/87-16.
During the current
inspection the inspector discussed the matter with responsible
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licensee personnel and determined that the item should be closed,
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4.
Exit Interview
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The inspection scope and findings were summarized on May 6,1988, with
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those persons indicated in Paragraph I above.
The inspector described the
areas inspected and discussed in detail the inspection findings listed
below. Dissenting comments were not received from the licensee.
Item Number
Status
Title / Reference Paragraph
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369, 370/88-13-01
Open
Unresolved Item - IST program
(Paragraph 2)
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369, 370/88-13-02
Open
Unresolved Item - Relief
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Valve testing (Paragraph 2)
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369, 370/88-13-03
Open
Violation - Stroke timing
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deficiencies (Paragraph 3.d)
369, 370/86-26-08
Closed
Unresolved Item - Written
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criteria for evaluation of
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erratic
valve
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(Paragraph 3.a.)
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369, 370/87-16-01
Closed
Unresolved Item - IST
program
requirements
for
and block valves
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(Farcgraph3.b.)
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369,370/87-16-02
Closed
Unresolved Item - Bases fnr
setting maximum stroke times
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(Paragraph 3.c.)
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369, 370/87-16-03
Closed
Inspector Followup Item -
Methods of str;-
'iming
(Paragraph 3.e)
370/87-37-01
Closed
Unresolved Item - Vu
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failed to operate (Par
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3.d.)
370/86-14-03
Closed
Inspector Followup Itt
Verification of snubber Test
by
qualified
personnel
(Paragraph 3,f.)
Proprietary information is not contained in this report.
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