ML20203D474

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Insp Rept 50-302/86-04 on 860103-07.Violation Noted:Failure to Follow Written & Approved Abnormal Procedure (AP) 580, Reactor Protection Sys,Actuation, During Recovery from Reactor Trip
ML20203D474
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 04/14/1986
From: Arildsen J, Debs B, Kleinsorge W, Mccoy F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203D468 List:
References
50-302-86-04, 50-302-86-4, NUDOCS 8604220120
Download: ML20203D474 (11)


See also: IR 05000302/1986004

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Report No.

50-302/86-04

Licensee:

Florida Power Corocration

3201 34th Street, South

St. Petersburg, FL 33733

Docket No.:

50-302

License No..

OPR-72

Facility Name:

Crystal River 3

Inspection Concucted: January 3-7 1986

V[M[%

Inspectors:

F. R. McCo

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Date Signed

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W. Kleinsorge

Ddte'IS i gn ed

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p J. A. Arildsen

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Ddte/ Signed

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Approved by

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Brian I. Debs. Acting Section Chief

Oate Signed

Operational Programs Section

Division of Reactor Safety

SUMMARY

Scope: This soecial, unannounced inspection entailed 139 inspector-hours on site

in the area of event followup. The event under assessment was the failure of

Reactor Coolant Pumo (RCP) 1A and the suosecuent reactor trip on January 1, 1986.

Areas under review included: an inspector review of recorded values of selected

plant parameters associated with the event; an inspector review of the licensee's

Post Trip Review; an inspector review of selected plant enemistry data for

indication of fuel element failure; and an inspector review of RCP 1A's

surveillance, preventative naintenance, corrective maintenance and predictive

maintenance programs.

Results:

One violation was ic3ntified - three examples of failure to follow

written and approvec acnormal procedure (AP) 580, Reactor Protection System

Actuation during recover from a reactor trip.

(see paragraph 5.c.)

8604220120 860416

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

  • P. F. McKee, Plant Manager

R. Wittman, Operations Superintendent

"C. F. Bennett, Operations Planning Supervis:-

  • B. J. Hickle, Operations Manager
  • J.

A. Frijouf, Compliance Specialist

  • R. L. Thompson, Nuclear Plant Engineering Supt.
  • V. R. Roppel, Plant Engineering anc Technical Services Mgr.
  • D. B. Eggleston, Nuclear Safety Suoervisor
  • L. W. Moffatt, Nuclear Safety Supervisor
  • P. D. Breedlove, Recoras Management Supervisor
  • K. F. Lancaster, Site QA Manager
  • S. C. Powell, Senior Nuclear Licensing Engineer
  • A. E. Friend, Nuclear Staff Engineer

G. Halnen, Nuclear Staff Engineer

Other licensee employees contacted included engineers,

technicians,

operators, mechanics, and office personnel.

Other Organizations

Precision Mechanical Analysis, Inc.

Babcock & Wilcox

NRC Resident Inspectors

  • T.

K. Setka, Senior Resident

. J. E. Tedrow, Resident

  • Attended exit interview

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2.

Exit Interview

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The inspection scope and findings were summarized on January 10, 1986, with

those persons indicated in paragraph 1 above. The inspectors described the

areas inspected and discussed in detail the inspection findings listed

below.

The licensee acknowledged ~the findings.

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The licensee did identify as proprietary various materials and information

provided to the inspectors during this inspection, however, no proprietary

information is included in this report.

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3.

Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4.

Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or devia-

tions. One unresolved item was identified in the area of reactor coolant

system pump vibration surveillance during this inspection, and is discussed

in paragraph 5.b.

5.

Failure of RCP 1A and the Subsequent Reactor Trip on Power to Flow Channels

"B" and "D".

On January 1, 1986, an event was reported at Crystal River Unit 3, under 10 CFR 50.72. The event included the failure -of RCP 1A and the subsequent

reactor trip. On January 3-7, 1986, an inspection team composed of three

individuals from Region II visited the Crystal River Nuclear Plant in order

to evaluated this event.

a.

Sequence of Events

Crystal River Unit 3 was operating at approximately 93P. power with no

special

operational

evolutions

in progress.

Shift relief had

commenced, and the oncoming shift supervisor and assistant shift

supervisor had assumed the shift.

At approximately 11:37 p.m.

the

control room operators noted the sound of " clicking" relays.

The

assistant shift supervisor noted a loose parts monitor alarm and a

RCP vibration alarm.

He tnen observed an RC low flow alarm, RC low

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pressure alarm, and low amperage indication (approximately the

no-load value) on RCP 1A.

The operators noted control rods going

in and cbserved proper indications for a reactor trip.

The operators

commenced the Immediate Actions of AP 580, Reactor Protection System

Actuation, from memory.

During the event, pressurizer level decreased to 46 inches and was

restored to greater than 50 inches by opening, more fully, charging

injection valve MUV-24.

Additionally, Reactor Protection System low

pressure channel B tripped at 47 seconds into the event. There was no

obvious indication for this occurrence.

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Approximately 2 minutes into the event, the Shif t Supervisor, having

noted the failure of RCP 1A's first seal and a degradation of the

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second seal, was concerned about a possible LOCA on RCP 1A's seal

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packing failure.

He directed the securing of RCP 1A. This action was

noted to be in compliance with AP 502, Annunciator Response, which

requires securing an RCP upon verifying high vibration annunciation.

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During the transient, Emergency Feedwater actuated automatically due to

steam generator pressure perturbations associated with the turbine trip

that accompanies the reactor trip. As steam generator level increased,

Emergency Feedwater Injection valve EFV-57 did not give complete

indication of closure.

Consequently, the operator placed the valve

controller in the " Hand" position in order to manually close the valve.

When the valve controller was placed in the " Hand" position, the valve

malfunctioned and opened fully.

The operator then manually _ shut the'

valve.

Also during the transient, one secondary safety valve, MSV-41, stuck

partially open and did not reseat; and two secondary safety valves,

MSV-35 and MSV-36, chattered upon reseating.

Valve MSV-41 was

subsecuently reseated afte- lowering of steam header pressure and

manually cycling the valve, and valves MSV-35 and MSV-36 ceased

chattering upon lowering of steam header pressure.

During the conduct of this . inspection, actions were initiated by the

licensee to depressuri:e, cooldown and lower reactor water level

consistent with required plant conditions for pump repair operations.

Additionally, actions were initiated to troubleshoot pump damage

and repair the damaged pump.

The inspectors consider that the

licensee's current and planned recovery operations reflected a

controlled avolution with adequate management attention and direction.

Actions taken appeared to be properly planned and deliberately imple-

mented.

The licensee's engineering ef fort associated with recovery

from this event is considered noteworthy.

b.

Review of Transient Data, Chemistry Data, and Licensee Post Trip

Review.

A review of SPDS recall data associated with this transient did not

reflect any conditions outside of safety limits or safety analysis.

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Additionally, there was no indication of loss of subcooling during the

transient.

A review of the licensee's Post Trio Review and Plant Review Committee

Restart Review reflected that the licensee's assessment of the event

was accurate.

The licensee's Post Trip Review and Plant Review Committee Restart

Review indicated that the following malfunctions occurred which would

require corrective action prior to restart:

RCP-1A motor and impellor separated which initiated the transient.

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RCP-1A will be repaired and cause determined prior to restart.

EFV-57 opened when placed in manual control mode. Operators then

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successfully shut the valve. This deficiency should be corrected

prior to restart.

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MSIV's -35, 36, and 41 did not fully reseat following the reactor

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trip until main steam header pressure was lowered, and MSV-41 was

cycled manually.

These valves should be reset prior to restart.

Additionally, the licensee's review indicated that the following

malfunctions occurred which do not require correction prior to restart:

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Condensate Pump (CDP)-1A, 18 tripped following the reactor trip

(apparently on the spiking Dearator level transient that was

identified on 12/3/85 reactor trip).

One condensate pump was

-successfully restarted. This deficiency is the subject of further

engineering study and does not need to be resolved prior to

restart.

Reactor coolant pump 1A suction's narrow range temperature

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indication, RC-5A-TT1, spiked high following the reactor trip.

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Redundant instrumentation is available as wide range indication,

RC-5A-TT2.

Licensee investigation has revealed an inadequate

connection at the RTD which is under a work request for repair.

Although the licensee's initial evaluation determined that

correction of this malfunction was not equired prior to restart,

subsecuent investigation has led the licensee to list this item

for repair prior to restart.

The licensee also indicated t m the Qaactor Protection System a flux to

flux to flow set point needs to be verified with detailed calculations

based on data derived from this event, and that Surveillance Procedure

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(Sp) 110, Reactor Protection System Functional Testing, be performed

for this trip function prior to restart.

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The insoectors noted that Reactor Protection System low pressure

channel B tripped at approximately 45 seconds into the event. The Post

Trip Review recognized the trip; yet, did not address the lack of

obvious indication that the plant pressure attained a point which would

have perpetuated the low pressure trip.

The inspectors were unable

to find any licensee evaluation to determine the specific cause of this

occurrence, and their review of selected documentation including the

Reactor Trip Report and Plant Review Committee Restart Review failed

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to indicate that such an evaluation is to be performed. The licensee

stated that Reactor Protection System calibration of the low pressure

trip instrumentation and other trip functions is scheduled for

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accomplishment during this outage.

The inspectors consider such

action to be warranted as a result this occurrence, and also consider

that a detailed licensee evaluation should be conducted to determine the

specific cause of this occurrence.

Resolution of this concern is

identified as an inspector followup item (302-86-04-01).

The inspectors also noted that the cause of failure of RCP-1A may

necessitate the performance of further evaluation of the other RCP's.

During interviews with licensee personnel, it was apparent that this

issue has been recognized; but it was not specifically addressed in the

documentation reviewed by the inspectors.

Resolution of this ' concern

is identified as an inspector followup item (302-86-04-02).

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A review of selected chemistry data associated with this event

indicates an increase in Dose Equivalent I 281 Activity of approximately

346% over pretrip levels and an increase in the I */I

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Ratio by a

factor of 38.5 to a level of 5.89 (as of last sample January 4,1986).

This ratio is in excess of the criteria 0-0.6 specified in Enclosure 2

of the Chemrad Report, CH-409, Rev. 05. Interviews with the licensee's

chemistry staff indicated that a licensee evaluation of this and other

chemistry data for the event had been conducted, and that fuel failure,

as a result of the event, is not evident from this data. A review of

selected past trip data confirmed that, though higher, this data is not

significantly out of proportion with that from past react Jr trips.

Further review of this data by the NRC Region II Radiologic,1 Effluents

and Chemistry Section confirms the licensee's conclusions that fuel

failure is not evident from this data.

c.

Failure to Follow Written Approved Procedures

The inspectors interviewed onshif t operaters in evaluation of the

event.

In the performance of AP-530, Reactor Protection System

Actuation. Immediate Actions and some Followup Actions were performed

from memory.

However, during the course of this performance, three

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examples of failure to follow written and approved procedures were

noted:

(1)

Immediate Action 1 of AP-580 requires the operators to ensure

group 1-7 rods are inserted by depressing the reactor trip push

button and by observing that the " TRIP CONF" light is lit on the

diamond panel. The operators failed to depress the reactor trip

push button.

(2)

Immediate Action 6 of AP-580 requires the operators to ensure

pressurizer level greater than 50 inches and specifies four

remedial actions to be taken in the event level is less than 50

incnes.

These actions are in order of 1 to 4 as follows:

1.

open suction from BWST

2.

start 2nd MVP

3.

open MOV-24

4.

close MUV-51

The operators only performed remedial action 3, open MUV-24. This

action was sufficient to recover pressurizer level, however, it

was not fully in accordance with the procedure since the other

three actions were not performed.

(3)

Followup Action 2 of AP-580 recuires that makeup tank level be

maintained between 55 inches and 86 inches with a detailed action

to be performed if makeup tank level is less than or equal to 55

inches. This detailed action is to open suction from the Borated

Water Storage Tank (BWST) to the running makeup pump (s). When

makeup tank level decreased to less than 55 inches, the operators

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did not perform this detailed action, but instead, restored makeup

tank level by filling the makeup tank from the reactor coolant

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bleed tank.

The inspectors questioned the operators about the

boron concentration of water in the RC bleed tank and were

informed by the operators that the concentration was approximately

200 parts per million greater than the concentration which was in

the reactor coolant system at that time.

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It was noted that, programmatically, the licensee's operators and

operations management consider that Remedial Actions associated

with fulfilling Immediate Actions and Details associated with

accomplishing Followup Actions are not required to be followed

vercatim as prescribed in the Abnormal Procedure provided that

actions taken ca- restore the requisite parameters.

Inspector

review of administrative procedures in this regard indicate that

authority for operators to deviate from prescribed Remedial or

Detail Actions does not exist.

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These examples of failure to follow procedure constitute a viola-

tion (302-86-04-03).

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Inspector evaluation of ooerator actions during the transient of

this event noted that in responding to acnormal events, operators

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take all tne Immediate Actions and some of the Followup Actions

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based on operator training and experience.

The procedure is

referred to af ter accomplishment of these actions to verify that

all requisite actions were properly taken.

This practice, in

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general, is considered acceptable if the operators are properly

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trained to respond in this fashion.

If it is intended that all

Immediate and some Followup Actions taken in the early phases of

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an actual event be performed without use of open procedure to

facilitate a timely response, and if it is intended that the

orocedure is to be subsecuently used to verify all requisite

actions were properly taken, the operators should respond in a

similar manner during simulator examinations conducted by either

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the licensee or the NRC. Resolution of this concern is identified

as an inspector followup item (302-86-04-04).

d.

Review of RCP Operational and Maintenance Data for Prior Indication of

Impending Pump Failure

An inspector review of selected portions of machinery history, opera-

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tional data, and pump vibration data associated with RCP 1A; and

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interviews with staff from Precision Mechanical Analysis, Inc. (PMA)

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indicated that, with regard to the data reviewed, there was no prior

indication of RCP 1A's degradation.

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The below listed documents were reviewed to evaluate surveillance,

corrective maintenance,

preventative maintenance,

and predictive

maintenance for RCP No. lA.

FPC-SP-300, Rev. 82

" Operating Daily Surveillance Log"

FPC-PM-101, Rev. 11

"4.16kV and 6.9 kV Switchgear"

FPC-FM-103, Rev. 10

" Maintenance of the Reactor Coolant Pump

Motor Oil Reservoir"

FPC-PM-105, Rev. 9

" Insulation Resistance, High Potential

Testing, Inspection, Cleaning and Drying

Windings of Electric Motors"

FPC-PM-133, Rev. 22

" Equipment Lubrication Procedure"

Prever*.ative Maintenance Control Sheet (PMCS) No. 139

PMCS No. 846

PMCS No. 1102

PMCS No. 1468

FPC

" Machine History Trending Program" Printout for Tag No RCP-001A

Westinghouse Oil Analysis Report dated 6/14/85.

The licensee's documented preventative maintenance program for Reactor

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Coolant Pumps consists cf the following:

PM-133 (Section 7 and 10)

Frequency 180 days

PM-102 (Calibrate 1elays)

Frequency 547 days

PM-101 (Clean and nspect)

Frequency 547 days

PM-105 (sections 8 nd 9)

Frequency 365 days

The licensee replacts pump seals at each refueling outage, not as part

of a documented pro ram, but at the direction of the reactor pump

engineering section based on the engineer's experience and engineering

judgement.

Under contract to the licensee, PMA performs real time

vibration spectrum analysis monthly on the reactor coolant pumps. This

analysis measures and trends the ten frequencies of largest amplitude

in the vibration spectrum from data taken in the control room.

The

PMA . reports, since the last seal change (summer 1985 outage), and

discussions with PMA personnel indicate that the 1A pump vibration was

normal, lower than the other pumps, and the trend was flat.

During

the summer 1985 outage, the oil in all four pumps was filtered and

analyzed by Westinghouse for: insoluble metals, as additives, contami-

nants and wear metals; solid content by volume; water content by

volume; viscosity at 40 and 100 degrees centigrade; neutralization

number, acid or base indexes; and particle size by scanning electron

microscopy. The licensee determined that the oil was acceptable. The

licensee used the acceptable analysis to satisfy the requirements of

preventative maintenance control sheet (PMCS) 139 (sections 7.0 and

10.0 of PM-133).

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During this area of review, several problems with the accumulation and

evaluation of RCP vibration data were noted.

Specifically, SP-300

requires personnel, reporting to the shift supervisor, to record

Reactor Coolant Pump data including but not limited to the following:

pump seal pressures; seal leak flow data; seal water flow; control

bleed-off flow; component cooling water temperature; control bleed off

temperature; and radial vibration daily.

SP-300 paragraph 2.1.1

requires that a cualitative assessment of each data channel's behavior

be performed to determine if that channel is exhibiting normal charac-

teristics fo,r the system's current configuration based on previous

operating experience and sound engineering judgement.

SP-300,

paragraph 2.1.2 requires that if a data channel is determined to be

exhibiting other than normal characteristics for the systems current

configuration, the eff-standard values shall be circled and immediate

reference be made to the " Action Statement" of the applicable Stanoard

Technical Specification paragraph referenced.

No circles were noted

on the RC Pump Seal Data Sheets from the start up, after the summer

1985 outage, to January 1,

1986.

Conversely, the inspectors noted

the following apparent off-standard data: the Radial Vibration (mils)

ranged from 2 to 7 mils in the X direction and ranged from 1 to 6 mils

in the Y direction except on the following dates 9/28, 9/30, 10/2,

10/4, 10/25, 11/11-14, 12/28 and 12/31, 1985, when the X direction

vibration was 15 mils and the Y direction vibration was 13 to 14 mils.

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There was no evidence that the personnel, reporting to the Shift

Supervisor, identified the elevated vibration data as off-standard,

and hence, no evaluation was made.

The inspectors made an inspection in the control room of the Reactor

Coolant Pump 1A Radial Vibration Indicator, the instrument used to take

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the vibration readings discussed above, and conducted interviews with

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licensee's engineering personnel. The licensee's engineering personnel

indicated that they expected vibration data to be less than 10 mils for

normal operation.

In fact, the " Alert" and " Danger" set points for

these instruments were set on the order of 20 mils and were nominally

within 2 mils of each other.

In one case, the inspectors noted the

" Alert" and " Danger" set points were the same.

Insufficient time was

available for a comprehensive inspector review of calibration

procedures and cata associated with the setting of RCP vibration

instrumentation, however, it appears that the instrumentation may be

improperly set and inconsistent with engineering analysis.

Although

these concerns are not considered to have been of any impact with

regard to this specific event, the inspectors noted that this equipment

has the potential for early warning of erratic RCP operation which

could preclude a pump failure from a progressive degradation.

The

inspectors discussed the above with both the licensee's operations and

engineering personnel.

The following appear to be areas of concern:

The off-standard values were not identified as such because the

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RCP seal data sheet did not contain acceptance criteria for

comparison.

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The off-standard values were,'most likely, the result of improper

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operation and reading of the Reactor Coolant Pump Radial Vibration

Indicators by personnel reporting to the shift supervisor.

The " Alert" and " Danger" set points on the Reactor Coolant Pump

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Radial Vibration Indicators appear to be too high to be an

effective harbinger of excessive pump vibration. At the time of

this inspection the basis for the selection of set point levels

was not available.

Disscussions with control room personnel indicated that they were

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only collecting data on the Reactor Coolant Pump vibration fer

others to evaluate because the data sheet contained no acceptance

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criteria.

Discussions with the responsible engineer indicated

that he assumed that the control room staff would make a qualita-

tive assessment of the data to determine whether the data was

exhibiting normal characteristics for the current configuration

based on previous operating experience and . sound engineering

judgement consistent with paragraph 2.1.1

of SP-300.

The

responsible engineer also stated that he assumed if off-standard

data was encountered, he would be notified.

This is indicative

that confusion exists with regard to which licensee organization

is responsible for pump operational data evaluation.

Resolution of this concern is identified as an unresolved item

pending further NRC review of calibration procedures and data

associated with this equipment.

(302-86-04-05)

e.

Review of Past Machinery History Associated with the Secondary Relief

Valve Problems

The inspectors also reviewed the below listed procedures and their

associated records for technical adequacy ard c'mpliance with applic-

able codes, procedures and regulatory reo Ji remen 's .

The applicable

code for Inservice Testing (IST) of pumps and valves is ASME Boiler and

Pressure Vessel (B&PV) Code Section XI, 1974 Edition eith Addenda

through Summer 1975. Specific attention was directed in tne following

areas:

number of valves to be tested and test frequency; set point

test procedure in accordance with ASME requirements; and provisions

for increased testing if valves fail to function properly.

Procedure No.

Title

SP-600, Rev. 12

" Pressurizer Code Safety Valves Test"

SP-602, Rev. 11

"ASME Section XI Relief Valve Testing"

SP-650, Rev. 12

" Main Steam Code Safety Valve Test"

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(1) With regard to the inspection above, the inspectors noted that

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procedure PS-602, Rev. 11 directs the reinstallation of piping and

supports af ter relief valve testing with no reference to post

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installation inspection for safety related supports. At the time

of this inspection it could not be determined whether safety-

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related -ipe supports had been removed or disassembled and

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reinstalled or reassembled without required quality control

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inspections. Pending further NRC review in this area, this matter

will be identified as an inspector followup item (302-86-04-06).

(2) During the course of this inspection, the licensee informed the

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inspectors that a non-related valve, EFV-14, was included in a

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fire resistant sealed enclosure pursuant to 10 CFR 50 Appendix R.

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Valve EFV-14 is required to be inspected once every two years to

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verify that valve operation is accurately indicated, pursuant to

ASME Section XI paragraph IWV-3300. Pending NRC inspection of the

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valve for testability and Inservice Test Program assurance that

the valve is adequately addressed, this matter will be identified

as inspector followup item (302/86-04-07).

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The inspectcrs reviewed the valve test records indicated below to

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verify adequate implementation of procedure SP-650.

Valve No.

Insoection Date

MSV-35

3/8/85

MSV-36

8/12/85

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MSV-41

8/12/85

Within this area examined, no deviations or violations were identified.

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