ML20214R472
| ML20214R472 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/03/1987 |
| From: | Obenchain C EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | Carrington M Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-6415, RTR-NUREG-0781, RTR-NUREG-781 OBEN-30-87, NUDOCS 8706080158 | |
| Download: ML20214R472 (17) | |
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/NEA idaho National Engineering Laboratory March 3, 1987 Mr. Mayo Carrington, Project Manager Technical Assistance Management Branch Planning and Program Analysis Staff Office of Nuclear Reactor Regulation Bethesda, MD 20014 TRANSMITTAL OF SER INPUT - AUDIT OF THE PUMP AND VALVE OPERABILITY ASSURANCE DR0 GRAM FOR THE SOUTH TEXAS PROJECT UNIT 1 - Oben-30-87 Ref: G. E. Marx ltr to S. B. Milam, Marx-367-86, Transmittal of Revised NRC Form 189 for Equipment Qualification Case Reviews (A6415),
October 29, 1986
Dear Mr. Carrington:
The enclosed material is transmitted in fulfillment of subtask e of project IV for the referenced 189 for the South Texas Project Unit 1.
This work was conducted under the technical direction of Mr. G. Bagchi of the Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, Engineering Branch.
The enclosed material is a status summary of the audit for South Texas Project Unit 1.
It is intended to be used as input to the Safety Evaluatic1 Report (SER) Section 3.10.2 for the South Texas Project Unit 1.
Several operability issues are still open and_need to be resolved by the applicant prior to fuel load.
Based on the information obtained during the on-site audit, the related discussions with the South Texas Project personnel, and the preliminary acceptance of the applicant's commitment to resolve all operability issues, E6&G Idaho, Inc. concludes that the pump and valve operability program for South Texas Project Unit I has been established and can be implemented in compliance with the applicable codes, standards, and regulations.
Very truly yours, 8706080158 870303 M ):284t PDR ADOCK 05000498 E
PDR C. F. Obenchain, Manager NRR and I&E Support CK:ggo Cnclosure:
As Stated cc:
G. Bagchi, NRC-PAEB A. Masciantonio, NRC-PAEB G. L. Jones, DOE-ID J. O. Zane, EG8G Idaho (w/o Encl.)
[EGrG,o,na. sne.
P.O. Box 1825 Idal o Falls, ID 83415
sk uc.
INPUT FOR SAFETY EVALUATION REPORT PUMP AND VALVE OPERABILITY ASSURANCE SOUTH TEXAS PROJECT UNIT 1 DOCKET NO. 50-498 3.10.2 boerability Oualification of Pumos and Valves 3.10.2.1 Introduction. The staff performs a two-step review of each applicant's pump and valve operability assurance program to determine whether its program can ensure that all pumps and valves important to i
safety will operate when required for the life of the plant under normal and accident conditions.
The first step is a review of Section 3.9.3.2 of
.the applicant's Final Safety Analysis Report (FSAR). However, this information is general in nature and lacks sufficient detail to determine the scope of the overall equipment qualification program as it pertains to pump and valve operability. The results of the FSAR evaluation appear.in Section 3.10.2 of NUREG 0781, " Safety Evaluation Report, Related to the Operation of the South Texas Project Units 1 and 2."
The resolution of any open SER issues is accomplished prior to or concurrently with the on-site audit.
A Pump and Valve Operability Review Team (PVORT),-consisting of engineers from the NRC staff and the Idaho National Engineering Laboratory.
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(INEL-EG&G) conducted the second step of the review; which consisted of an audit-of a-representative sample of installed pump and valve assemblies and their supporting qualification documents at the plant site.
Based upon the results of both the audit and the FSAR review, the PVORT determines whether the applicant's overall program conforms to the current licensing criteria presented in Section 3.10 of the Standard Review Plan (SRP). Conformance with SRP 3.10 criteria is required in order to satisfy the applicable portions of General Design Criteria (GDC) 1,'2, 4, 14,.and 30 of Appendix A to 10 CFR 50'as well as Appendix B to 10 CFR 50.
r The following sections include:
(a) a discussion of the PVORT review l
process, (b) a summary of PVORT findings concerning the applicant's overall j
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l pump and valve operability assurance procam,.(c) a discussion of the confirmatory issues resulting from the PVORT review, and (d) Table 3.10.2.1, which presents a summary of the audit results.
3.10.2.2 Discussion. The PVORT reviewed the pump and valve operability assurance information contained in Section 3.9.3.2 of the South Texas Unit 1-FSAR and later conducted an on-site audit to determine the extent to which the pumps and valves important to safety meet-the criteria listed above. The issues which resulted from the South Texas FSAR evaluation appeared in an SER (NUREG 0781) dated April 1986. Many of these SER issues were resolved by material submitted by the applicant up to and including FSAR Amendment 54.
Additional qualification issues not covered in NUREG 0781 were discussed at a pre-<. adit meeting held September 16, 1986.
Several of these pre-audit issues were adequately resolved by the applicant in a letter dated October 9, 1986.
The remaining SER and pre-audit issues were resolved during the site audit held December 16-19, 1986.
Evaluation of SER Issues: The staff investigated the deep draft pump issue during the audit.
In a letter dated October 9, 1986, the applicant indicated that the South Texas vertical pumps do not fall into the category of " deep draft" pumps.
The program does meet the intent of the NRC and LRG-II guidelines with respect to long term operation, vibration monitoring, maintenance and inspection.
Based on the applicant's response and site verification, the South Texas pump qualification program should be adequate to assure operability of vertical pumps.
The staff requested information regarding operability of containment purge and vent valves in accordance with NUREG-0737, TMI Item II.E.4.2(6).
In a letter dated October 9, 1986, the applicant provided a response to the request. The response indicated that the containment purge and vent system has been revised to incorporate a pneumatic valve on the outboard side of the intake and exhaust lines. The applicant committed to provide documentation demonstrating valve operability prior to fuel load.
The staff's position regarding operability of these valves will be included in future supplement to the SER.
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The following discussion lists the remaining SER issues originally identified in NUREG 0781 and describes the manner by which each issue was addressed.
SER issues 1, 3, and 7 were completely resolved by the applicant in FSAR Amendments 45 through Amendment 54.
The staff has verified that the FSAR includes the appropriate Tables and text description. SER issues 1, 3 and 7 (described below) are closed.
(1) As of Amendment 38, Tables 3.10-1, 3.11-2, 3.11-5, and 3.llN-1 have not been added to the FSAR.
The Pump and Valve Operability Review Team (PVORT) is interested in examining these seismic and environmental qualification tables to evaluate the applicant's overall pump and valve operability assurance program.
(3) Table 3.9-1.2A (Amendment 41) lists active NSSS valves.
- However, several valves are flagged with the footnote "* BOP scope of supply." The applicant must clarify the purpose of the footnote.
(7) The following actions by the applicant would enhance PVORT understanding of the plant:
(b) FSAR Tables 3.9-4 and -4C provide the stress criteria for Class 2 and 3, nonactive, B0P and NSSS pumps, respectively.
The applicant should identify these nonactive pumps.
(c) FSAR Section 3.9.3.2.1.2 describes an NSSS program for testing various valve designs and sizes during a simulated faulted event. The applicant must describe the criteria used to select the valves for testing and specify the range of sizes that are covered.
(d) FSAR Section 3.9.3.2.2 and 3.9.3.2.3 describe the methodology used to demonstrate operability of B0P pumps and 3
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ce, valves, respectively. The applicant must identify the seismic accelerations and describe how they were applied to qualify " rigid" and " flexible" 80P equipment.
i (e) The applicant must specify the range of sizes of~ BOP valves that are covered by program 1 in FSAR Section 3.9.3.2.3.
Also, the applicant must confirm that the evaluation of the 80P check valves will' include " stress analysis of' critical parts, which may affect operability including the faulted condition loads," as'is the case for NSSS check valves.
SER issues 4, 5, 6 and 7 required applicant responses FSAR revisions, I
and/or site verification.
These concerns and resolutions are presented below.
(4) The applicant must clearly show the extent to which RG 1.148, ANSI /ASME N551.1 draft standards, and ANSI B16.41 are met.
Evaluation:
During the site audit, the applicant provided a respons. to this concern. FSAR Table 3.9 -. 23 ( Amendment 154) l describes compliance with Regulatory Guide 1.148. 1The FSAR information was found to be adequate and resolved the concern.
I The applicant did not address' ANSI /ASME'N551.1 and ANSI B16.41.
This was not found to be unacceptable as N551.1 is draft anc a response is not required. ANSI B16.41 is a new standard and the
, applicant has not been required to respond. This issue is' closed.
(5) The applicant must clarify the methods used for qualification.
Specific information should be presented in the FSAR and be available for review at the site. The applicant must demonstrate (a) the extent to which operational testing is performed at design-basis conditions (full flow, pressure, temperature, etc.)
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a-(b) the technical basis for qualifying equipment.by similarity analysis and prototype testing (c) qualification of the equipment as an assembly rather than individual components (d) the extent to which qualification by analysis, as presented in Table 3.9-10, was supplemented by correlated test results and documented operating data Evaluation:
During the FSAR revision from Amendment 39 to Amendment 54, the necessary information was provided. The-information and site verification were found to be adequate and resolved this concern. This issue is closed.
(6) The applicant should clearly show how implementation of the initial test program, maintenance and surveillance, inservice inspection, and quality assu ance programs will maintain equipment operability throughout the 40-year plant life.
Specific criteria should be presented in the FSAR and be l
available for review at the_ site.
Evaluation:
During the FSAR revision from Amendment 39 to Amendment 54, the necessary information was provided. The information and site verification were found to be adequate and resolved this concern. This issue is closed.
4 (7) The following actions by the applicant would enhance PVORT understanding of the plant:
(a) The applicant should identify-any pumps and valves that are considered to be functional accessories for active-safety-related equipment.
(The diesel generator lubrication system described in FSAR Section 9.5.7 is safety related and is designed to seismic Category I, SC3 requirements. The l
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's system includes one engine-driven and two motor-driven pumps, which are not listed in any of the tables in FSAR Section 3.9.)
(f) The PVORT is interested in examining the lists of pumps and valves that are designated for inservice testing per FSAR Section 3.9.6.
Evaluation:
During the site audit, both of these areas were verified. No discrepancies were identified. Based on the site verification both concerns have been adequately addressed.
This issue is closed.
The final concern identified in the SER was item 2 as described below.
(2)
It is not clear that Table 3.9-. 2 (Amendment 44).is a complete list of active balance-of-plant (80P) valves.
(a) B0P check valves have not been included in the table.
(b) Some valves listed in Table 3.9-1.2 no longer appear to be used.
For example, containment purge valves HA002 and HA004, as well as radiation monitoring valves RP002 and RP005, have been deleted from Table 7.3-9 (Amendment 43).
(c) For all active 80P valves, the applicant should list the function, American Nuclear Society (ANS) safety class, and active status in a manner similar to the way Table 3.9-1.2A lists NSSS valves.
Evaluation:
The three concerns originally identified as examples have been adequately resolved in revisions to the FSAR; however, the site audit found other discrepancies. This concern was transferred and combined into generic issue 3 and explained further in section 3.10.2.3.
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Evaluation of On-Site Audit:
The on-site audit, which was conducted December 16 through 19, 1986, consisted of field observations of the equipment configuration and j
installation for a representative sample of plant equipment.
The PVORT evaluated three NSSS and nine 80P pump and valve assemblies, i
Table 3.10.2.1 summarizes the status of each assembly that was audited and inspected. The field observations were followed by a review of the design and purchase specifications, test / analysis documents, and other documents related to equipment operability, which the applicant maintains in its central files.
In addition to reviewing information concerning the selected assemblies, the PVORT also reviewed other information concerning i
i the plant's overall equipment qualification _ program.
Included within this broad evaluation were those programs and procedures necessary to ensure that equipment qualification issues and concerns will continue to be addressed for the life of the plant. One such program, concerning the deep i
draft pump issue (refer to IE Bulletin 79-15), was reviewed in depth.
The PVORT resolved all but 4 of the specific operability concerns that were identified at the close of the audit.
These 4 concerns are:
(1) pre-operational testing was not completed on the auxiliary feedwater turbine driving steam modification, (2) auxiliary feedwater minimum flow recirculation valve maintenance schedule was not completed; therefore, maintenance was not identified per vendor's recommendations, (3) documentation was inconsistent for the b'oric acid transfer pump radiation qualification and (4) the boric acid transfer pump qualification did not address operation at reduced voltages.
In addition, the applicant was informed at the close of the audit of 5 generic issues which must be resolved prior to fuel load. The 5 issues j
are:
(1) all of the pre-service tests required before fuel load have not-
.seen completed, (2) approximately 10 to 15 percent of all pumps and valves important to safety are not yet installed and qualified, (3) the FSAR does j
not provide a complete list of safety-related pumps and valves (BOP and l
NSSS), (4) nonconformancie: issued during the transition of architect engineers from Brown and Ro9t to Bechtel should be reviewed, and (5) a i
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o-i 30 day operating time post-accident is not consistent with nornal practices. These specific and generic issues form the basis for the discussion presented in Section 3.10.2.3.
l Overall Evaluation:
The PVORT believes that the applicant is dealing with the equipment qualification issue in a positive manner.
During the audit, the applicant 2ddressed all questions posed by the PVORT and committed to resolve all audit issues prior to fuel load or provide adequate justification.
Furthermore, the applicant discussed significant aspects of its overall equipment qualification program, aspects such as amplified response spectra reconciliation, equipment modification and reconciliation of original qualification reports, nozzle l'oad verification, and review of non-safety related equipment located in close proximity to safety related equipment.
Consequently, the PV0RT believes that the continuous implementation of the applicant's overall program should provide adequate assurance that the pumps and valves important to safety will operate as required for the life of the plant.
3.10.2.3 Operability Issues.
Based upon the results of the PV0RT site audit, the staff has identified to the applicant the following 4 equipment specific and 5 generic issues.
These issues must be resolved prior to fuel load:
Specific Issues:
1.
Issue:
During the site audit, it was identified that the applicant had developed a design to minimize the impact of moisture in auxiliary feedwater turbine driving steam.
The design had not been tested at the time of the audit.
The applicant committed to confirm when pre-operational testing was satisfactorily completed, to identify all deficiencies discovered during testing, and to describe the disposition of the deficiencies.
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' Issue. During the site audit, the applicant was requested to provide the preventive maintenance schedule for AF-0091 (Auxiliary Feedwater Minimum flow Recirculation Valve).
The maintenance schedule had not been developed. The applicant committed to provide evidence that manufacturer recommended.
maintenance will be performed.
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Issue. The review of the boric acid transfer pump (Tag Number 3R171NPA103A) identified an apparent discrepancy in the level of radiation for which the equipment is qualified. The test sequence described in WCAP 8687 (EQDP-AE-3) indicated 10000 R, but the qualification summary Table I in the same report showed 400 R.
The PVORT questionnaire reported 2100 R.
The applicant shall (1) modify the WCAP 8687 report and PVORT form to correct the apparent discrepancy in the qualified level of 1
radiation and (2) confirm that the equipment qualification file has been supplemented with the appropriate documentation.
4.
Issue: The review of the boric acid transfer pump (Tag Number 3R171NPA103A) identified concerns regarding the qualification document file. The applicant claimed the equipment-was fully qualified, but the documentation file did not reference operability of the motor at reduced voltages. The applicant shall (1) provide a copy of the test report which references operability of canned motors at reduced voltages (2) describe the basis for similarity of the motor test results to the operation of the boric acid transfer pump used at South Texas, and (3) l confirm that the equipment qualification file has been supplemented with the appropriate test data and required analyses.
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Generic Issues:
1.
Issue. At the time of the audit, most construction tests had been completed.
However, the hot functional tests are scheduled i
for January 1987. The applicant shall confirm that all 9
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.w preservice tests for safety-related pumps and. valves'that are required before fuel load have been completed. The applicant shall also provide a-list of all preservice tests to be completed, the schedule for these tests, and the justification for any tests scheduled beyond fuel load.
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2.
Issue..At the time of the audit, approximately 10 to 15 percent of all safety related pumps ~and valves had not been qualified, h
The applicant shall confirm that all safety related pumps and i
valves are properly qualified and installed prior to fuel load.
In addition, the applicant shall provide written confirmation
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that the original loads used in tests or analyses to qualify safety-related pumps and valves are not exceeded by any new loads, such as those imposed by a LOCA (hydrodynamic loads).or as-built conditions.
3.
Issue: At the conclusion of the PVORT audit, it was apparent 4
that a complete list of safety-related pumps and valves had not been provided in the FSAR. The applicant shall confirm that all safety-related NSSS and B0P pumps and valves, including check l
valves, are correctly identified in the FSAR prior to fuel load.
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Issue:
During the site audit, a nonconformance tag was found attached to a component five years after the nonconformance had been cleared. The applicant explained that the nonconformance was cleared during the transition of architect engineers from.
Brown and Root to Bechtel. As a result of the change over, the tag was overlooked. This tag appeared to be an' isolated case and therefore not an indication of a programmatic. problem. However, the staff was concerned that a tag was attached for five years and no action taken. The applicant shall confirm that nonconformances issued for safety related pumps and valves during l
the transition period have been reviewed and assure they have i
been properly picked up by a Bechtel program and dispositioned.
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5.
Issue. At the site audit, it was identified that the applicant was using a 30 day post-accident operating time for qualifying equipment. Typically 100 days or greater post-accident is used.
The applicant shall provide information which demonstrates how a l
100-day minimum post-accident operability time is met.
3.10.2.4 Sununa r y.
Based on the result of:.(a) the component l
walkdown and the review of the qualification document packages, (b) the i
additional explanations and information provided by the applicant throughout the audit, and (c) the resolution of the SER items, the staff concludes that an appropriate pump and valve operability assurance program has been defined and implemented. The continuous implementation of this overall program should provide adequate assurance that all pumps and valves important to safety will perform their safety-related functions as required for the life of the plant. With the exception of the issues identified in Section 3.10.2.3, the staff concludes that South Texas has qualified those pumps and valves important to safety so as to meet the applicable portions of GDC 1, 2, 4, 14 and 30 of Appendix A as well as Appendix B for 10 CFR 50.
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-m TABLE 3.10.2.1.
SUMMARY
OF PVORT AUDIT FOR SOUTH TEXAS PROJECT UNIT 1 Equipment Findings Resolution Status Description Plant I.D.
Function (note)
(note)
(note)
Chemical 81CV-FV-84008 Valve is Closed and Volume (NSSS) normally open.
Flow Control Closes on a Valve boric acid (Grinnell storage tank 2" diaphragm-10-10 level.
valve)
Chemical 2R171X-CV-0112C Valve is Closed and Volume (NSSS) normally Control closed.
Isolation Opens on a Valve safety (Westinghouse injection 6" Gate signal or Valve)
VCT Lo-Lo level signal to provide flow to charging pump suction.
Boric Acid 3R171NPA103A Normally Note,b Notec Opend a
Transfer (NSSS) operates to Pump (Crane provide boric Chempump acid for CVCS 125 gpm) nukeup and boric acid purification.
Emergency function is to provide flow to the charging pump suction for emergency boration.
d Auxiliary 3S141MPA04 Pump normally Note' Note c Open Feedwater (B0P) in standby.
Pump Operates on (Bingham an ESF signal Willamette or manually Co., 600 gpm) to provide emergency feedwater to the steam generators.
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TABLE 3.10.2.1.
(continued)
Equipment Findings Resolution Status Descriotion Plant I.D.
Function (note)
(note)
(note)
Auxiliary 3S141T-AF-0091 Valve is Notef Notec Opend Feedwater (80P) normally lined Minimum up for Flow recirculation Recirculation with its Valve associated (Yarway, 4" Aux Feed Pump Auto in standby.
Recirculation Valve aligns Valve) itself to flow to steam generator or recirc to stcrage tank as required on an ESF signal.
Closed-Component 3R101T-CC-0132 Valve normally Cooling (BOP) open to allow Surge Tank flow from Isolation surge tank.
Valve Valve closes (Rockwell, to isolate 24" surge tank on Butterfly a low surge Valve) tank level.
Closed Essential 3R281NPA1018 Pump normally Cooling (80P) provides flow Water Pump fro:a essential (Hayward cooling pond
- Tyler, to serviced 20610 gpm) components.
In an emergency (Safety Injection Signal, LOOP, or low water header pressure) provides cooling water to essential equipment.
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TABLE 3.10.2.1.
(continued)
Equipment Findings
-Resolution Status Description Plant I.D.
Function (note)
(note)
(note)
Feedwater A1FW-FV-7141 Valve is Closed Isolation (BOP) normally.open.
Valva Va]ve closes-(WKM 38" on a feedwater Gate Valve) isolation signal.
Auxiliary 2S141T-AF-0019 Valve' is Closed Feedwater (BOP) normally Stop-Check closed. Valve Valve opens on an (Rockwell 4" ESF signal Stop-Check) and Auxiliary Feedwater Pump
- 14 operation to feed steam generator 10.
Chilled ClH-TV-9497A Valve is Closed Water (B0P) normally open Isolation acting as a Valve temperature (Valtek 4" regulating Butterfly valve for the Valve)
Electrical Auxiliary Building.
Valve opens completely on a safety injection signal.
Reactor 81RM-FV-7663 Valve is Closed Water (80P) normally open.
Makeup Valve closes Isolation on a safety (WKM 4" injection Globe Valve) signal to isolate nonessential service water.
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- TABLE 3.10.2.1.
(continued)
. Equipment findings Resolution Status Description Plant ILD.
Function (note)
(note)
(note) 2 Main Steam AIMS-FSV-7414 Valve is Closed Isolation.
(BOP) normally open.
Valve Valve closes (Atwood &
on an isolation Morrill 30"_
signal.
Opend ALL' PUMPS Operate as Note 9 Notec AND VALVES required h,1,j,k IMPORTANT during the
.TO. SAFETY life of the-plant under accident conditions.
i a.
(SPECIFIC ISSUE) During the document review, the component appeared to be qualified to three different radiation levels.
The applicant shall (a) modify the WCAP 8687 and PVORT form to correct the apparent discrepancy and (b) confirm that the equipment qualification file has been supplemented j
with 'the appropriate documentation, i
b.
(SPECIFIC ISSUE).During the documentation review, documentation supporting operation at degraded voltages could not be provided. The applicant shall (a) provide a copy of the test report which references operability of canned motors at reduced voltages, (b) describe the basis for siellarity of the test results, and (c) confirm that the equipment qualification file has been. supplemented with the appropriate information.
c.
At the conclusion of the site audit, the staff summarized the open issues. The applicant was informed of the appropriate actions necessary to resolve the specific and generic issues prior to fuel load.
d.
Qualification status will be " closed" upon resolution of specific and generic issues.
e.
(SPECIFIC ISSUE) At the time of the audit, the applicant had not tested the new design to minimize the impact of moisture in the AFW turbine 1
driving steam. The applicant shall confirm when pre-operational testing is i
l satisfactorily completed, identify deficiencies discovered during testing, and describe the disposition of the deficiencies.
f.
(SPECIFIC ISSUE) During the audit, the applicant could not provide a preventive maintenance schedule as it had not been developed.
The applicant shall provide a copy of the maintenance schedule demonstrating-l that the manufacturer's recommended maintenance will be performed.
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TABLE 3.10.2.1.
(continued) g.
(GENERIC ISSUE) At the conclusion of the PVORT audit, it was apparent that a complete list of active pumps and valves had not been provided in the FSAR. At the site audit, the applicant committed to confirm that all active NSSS and 80P pumps and valves are correctly identified in the FSAR.
h.
(GENERIC ISSUE)
Some pre-service tests required to be completed prior to fuel load have not yet been performed. At the site audit, the applicant committed to confirm that all appropriate pre-service tests have been completed prior to fuel load.
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(GENERIC ISSUE) Some pumps and valves important to safety have not been completely qualified and installed._ At the site audit, the applicant committed to confirm that all pumps and valves important to safety are completely qualified and installed prior to fuel load.
Also, the applicant shall confirm that the original loads used in tests and analyses to qualify pumps and valves important to safety,are not exceeded by any new loads (i.e., design load reconciliation).
j.
(GENERIC ISSUE) The applicant shall perform a review to ensure that nonconformances issued for safety related pumps and valves during the transition of architect engineers from Brown and Root to Bechtel were properly picked up by a Bechtel program and dispositioned.
k.
(GENERIC ISSUE) The 30 day post-accident operating time for qualifying equipment is not consistent with post-accident times used at other plants.
Typically 100 days or greater post-accident periods are used. The applicant shall provide information which demonstates how a 100-day minimum post-accident operability time is met.
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