ML20236B002

Expanded Augmented Sys Review & Test Program (Expanded Asrtp) Evaluation of Auxiliary Feedwater Sys

ML20236B002
Person / Time
Site:	Rancho Seco
Issue date:	10/07/1987
From:	Croley B, Humenansky D, Stock F SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20236A981	List: ML20236A978 ML20236A989 ML20236A992 ML20236A998 ML20236B002 ML20236B005 ML20236B010
References
NUDOCS 8710230289
Download: ML20236B002 (28)

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EXPANDED AUGMENTED' SYSTEM REVIEH AND TEST' PROGRAM (EXPANDED ASRTP) 1 EVALUATION

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0F THE AUXILIARY FEEDHATER SYSTEM ,

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SUBMITTED BY: DATE: 0 6 fi FRANK STOCK TEAM LEADER CONCURRENCE: Y"d N DATE: 10-L-0)-

[ DAVID HUMENANSKY EXPANDED ASRTP PR NAGER j CONCURRENCE: 7 DATE: N7M I-B0B CROLEY /-

DIRECTOR, NUCLEAR TECHNICAL SERVICES i l

t 8710230289 B71021 DR ADOCK0500g2 E

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. . .; e .g .'TdBLE OF CONTENTS '

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1.0. INTRODUCTION- 3 gl: nu 2.0 PURPOSE , r,- '

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.e L4.0 ' OVERALL RESULTS AND CONCi.USIONS- 6

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5.0 . SPECIFIC CONCERNS

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! Acknowledged (Valid) Concern [s.

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5.2 -Open (Potentie.1) Concerns ~ 7 a o it I- /

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6.0 ATTACHMENTS '

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6.1 List of Documents Reviewed 9 6.2 Status of -RIS >

16 6.32 Detailed Observations - Requests for Information. 17

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EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM f

EVALUATION OF THE AUXILIARY FEEDWATER SYSTEM

1.0 INTRODUCTION

1 I The Rancho Seco Expanded Augmented System Review and Test Program

',n (ASRTP) evaluation effort involves an assessment of the

', effectiveness of the System Review and Test Program (SRTP] and an l

L f' analysis'of the adequacy of ongoing programs to ensure that systems will continue to function properly after restart. The Expanded ASRTP is a detailed system by. system review of the SRTP as implemented on 33 selected systems and an in-depth review of the L '

engineering, modification, maintenance, operations, surveillance,

$' inservice testing, and quality programs. It also conducts a review, G

i on a sampling basis, of many of the numerous ongoing verification

, and review programs at Rancho Seco.

s Six multi-disciplined teams composed of knowledgeable and l experienced personnel are tasked with performing the Expanded ASRTP. Each multi-disciplined team consists of dedicated personnel with appropriate backgrounds to evaluate the operations,

, maintenance, engineering, and design functional areas.

Independence, perspective, and industry standards provided by team members with consultants, architect engineer and vendor backgrounds are joined with the specific plant knowledge of SMUD team members.

Each team performs an evaluation on a selected system using the same fundamental evaluation techniques employed by the NRC in the ASRTP inspection. System Status Reports are used as the primary source of leads for the. teams. They are augmented with references to available source and design bases documents as needed. Team

, o synergism and communication is emphasized during the process in order to enhance the evaluation. Each team prepares a report for each completed selected system evaluated. This report is for the auxiliary feedwater system.  ;

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.Thc objectives of the Expanded ASRTP evaluation are to-(1). assess the adequacy of activities and systems in support of restart and'(2) .

evaluate the ' effectiveness of established programs for ensuring 'q gafety during plant operation after restart.

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3.0 SCOPE To accomplish the first objective, the Steam Plant team evaluated' the Auxiliary Feedwater system to determine whether:

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1. The system was capable of performing the safety 1 functions required by its design bases. j

2. Testing was adequate to demonstrate that the system would perform all of the safety functions required. l l

3. System maintenance (with emphasis on pumps and valves) was adequate to ensure system operability under postulated accident conditions. _

4. Operator and maintenance technician training was adequate to ensure proper operations and maintenance of ,

the system. )

5. Human factors relative to the system and the system's j supporting procedures were adequate to ensure proper 1 system operations under normal and accident conditions. I l '

To accomplish the second objective, the team reviewed the programs as implemented for the system in the following functional areas:

1. Systems Design and Change Control

2. Maintenance

3. Operations and Training

4. Surveillance and Inservice Testing

5. Quality Assurance '

6. Engineering Programs The team reviewed a number of documents in preparation for and during the Expanded ASRTP evaluation. This list of documents is found in Attachment 6.1.

The primary source of leads for the team were the problems identified in the Auxiliary Feedwater System Status Report. Various source documents such as the USAR and Technical Specifications and available design bases documents were reviewed as needed to augment  ;

the information needed by the team.  ;

The evaluation of the Auxiliary Feedwater system included a review ,

of pertinent portions of support systems that must be functional in order for the Auxiliary Feedwater system to meet its design objectives.

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l L4.0- OVERALL'RESULTS AND CONCLUSIONS

< 'The more significant. issues identified pertaining to the adequacy of ' i

;the SRTP and the effectiveness of; programs to ensure continued safe:

I- operations after restart are summarized below.- The summary focuses'

, Lon the. weaknesses identifled during. the evaluation.- Attachment 6.3 d provides detailed findings by providing the Request for Information =

(RI) forms that are used by the Expanded ASRTP teams to identify j potential concerns during the evaluation. Section 5.0 lists thei  :!

specific. concerns identified by the teams. The numbers in brackets after each individual. summary or concern refer.to:the corresponding .'i)

RIs'in Attachment 6.3.

4.1. Auxiliary Feedwater. System Operation and Maintenance-

, 4.1.1 The main concern relating to the. auxiliary feedwater sy' stem-operation pertains to the auxiliary feedwater pump area.- l l

. Recent fire protection modifications;in the' area were addressed as concerns with respect to the following:.

Accessibility to specific components in the auxiliary feedwater pump area is severely restricted. In addition, a significant personnel safety hazard exists in the area.

The isolation valve for the auxiliary feedpump-deluge system has a tamper switch installed which-will not provide suitable indication of valve position.

- The IDADS Annunciator Response Procedure does not provide adequate guidance for responding to a common fire alarm in the Control Room.

• Surveillance procedures for the feedwater check valves do not adequately test for system or valve seat integrity. This may have resulted in unidentified or unanalyzed overpressurization conditions.

4.1.2 Concerns relating to system maintenance pertained to the following:

= The testing requirements of ASME Section XI are not being satisfied for the auxiliary feedpump suction side relief valves or the turbine casing relief valve.

. Root cause analysis has not been conducted on multiple failures of pressure gauges on the auxiliary feedpump suction side.

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5.0 SPECIFIC CONCERNS

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' A list'of the specific concerns the' Expanded ASRTP team believes are .

.new concerns not previously identified for resolution follows:-

5.1- Acknowledged-(Valid) Concerns .

l 5.1.1 - Accessibility to the area behind AFH~ Pump P-318 is severely'

' restricted and may result in' inability.to operate or monitor required equjpment, as well as create personnel safety hazard.- [RI 224]-

5.1.2 The IDADS Annunciator, Procedure, Revision ~2, does not provide adequate information nor guidance to properly

. respond to an alarm for the AFH pump area fire system.

[RI 240]

5.1.3 ' The design and installation of the. tamper switch for fire system isolation valve FPH-803 may be inadequate for performing its intended function. [RI 241]

5.1.4 The testing requirements of ASME Section XI, Subsection'IHV are not' being satisfied .for the two auxiliary feedwater pump  ;

suction side relief valves. [RI 243]

5.1.5~ . Quality assurance and quality control procedures were not adequately implemented during the installation, . inspection, and testing of the Quality Class 1 heater controllers.

[RI 231].

5.1.6 The effectiveness of the fire protection system in the-auxiliary feedwater pump area may be compromised by the design and installation of certain' fire system components.

[RI 236]

5.2 Open (Potential) Concerns 5.2.1 Surveillance procedures for AFH check valves do not 1-'

adequately test for physical or seat integrity, possibly resulting in unidentified or unanalyzed overpressurization  !

conditions. [RI 264] l

- l 5.2.2 The USAR contains commitments regarding the Condensate i Storage Tank (CST) level alarms and water levels which are I not consistent with plant conditions nor supporting design calculations. [RI 266] l l

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6.0 ATTACHMENTS 1

6.1 List-of Documents Reviewed ' ,

6.2- ' Status of.RIs 6.3: -Detailed Observations - Requests for Information i

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p LIST OF DOCUMENTS REVIEHED Maintenance and Calibration Procedures M.22, Auxiliary-Feedpumps and Turbines

'I.032, Monthly Auxiliary Feedpump P-318 and.P-319 and Auxiliary Feedwater Flow Indicator Operations: Ventilation Test M.ll4, Maintenance Cleanliness Control-

I.Oll, General Calibration M.103, Valve Inspection and Maintenance Ooeratina Procedures A.51, Auxiliary Feedwater System i A.6, Steam Generator Secondary Side

System Casualty Procedures .

-OP-C.1, Rev'. 1, Load Rejection OP-C.12, Rev. 6, Loss of Decay Heat Removal System OP-C.20, Rev. 9. Loss of CCH Inventory / Flow OP-C.94, Loss.of All AC Power / Station Blackout OP-C.13, Remote Shutdown Emeraency Goeratina Procedures E.02, Rev. 5, Vital System Status Verification E.03, Rev. 3 Loss of Subcooling E.04, Rev. 7,' Loss of Heat Transfer E.05, Rev. 9, Excessive Heat Transfer E.06 Rev. 7 Steam Generator Tube Rupture (SGTR)

E.07, Rev. 5, Inadequate Core Cooling (ICC)

CP.103, Rev. 4, Emergency Operating Procedure CP.104, Rev. 4. Emergency Operating Procedure

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Annunciator Procedures i H2YSB, Rev. 10 10 ADS, Rev. 2  ;

H2PSB, Rev. 15 and Rev. 16 (draft) l Administrative Procedure i

RSAP.0803, Work Requests ,

System Desian Basis NEPH 5427, FHS System Design Bases DB-AFH-5427B, AFH System Design Bases, Rev. A ATTACHMENT 6.1 f

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LIST.OF DOCUMENTS REVIEHED (Continued) l Process Standards 1

AP.100 Rev. 11, Process Standards (Miscellaneous) i AP.150, Rev. 14, Main and Auxiliary Turbine System J AP.151, Rev. 6, OTSG Secondary Side AP.152, Rev. 20, Feedwater and Condensate System Surveillance and Soecial Test Procedures 1

SP.20 (D) Monthly Turbine / Motor Driven Auxiliary Feedwater Pump l P-318 Inservice Test t SP.21 (D) Monthly Motor Driven Auxiliary Feedpump P-319 Surveillance and Inservice Test SP.23 (D) Special Frequency Auxiliary Feedwater Pump Flow Test and Check Valve Full Stroke Test (Cold Shutdown)

SP.24 (D) Special Frequency Auxiliary Feedwater Check Valve Integrity Test j SP.69 (D) Refueling Interval Reactor Building Isolation Trip l Verification  !

SP.74 (D) Quarterly Auxiliary Feedwater System Valve Inspection and Surveillance .

SP.200.01 Instrumentation Surveillance Performed Each Shift I SP.207.01 Inservice Inspection SP.210.01A Monthly Turbine / Motor Driven Auxiliary Feedpump P-318 Surveillance and Inservice Test  :

SP.210.01B Monthly Motor Driven Auxiliary Feedpump P-319 l Surveillance and Inservice Test SP.210.01C Quarterly Steam and Auxiliary Feed System Valve Inspection and Surveillance SP.210.01F Cold Shutdown Auxiliary Feedwater Pump Flow Test and Check Valve Full Stroke Test SP.210.0lH Refueling Interval Auxiliary Feedwater System Auto Start Test for Loss of Four Reactor Coolant Pumps and SFAS Actuation SP.210.01I Auxiliary Feedwater Check Valve Integrity Test SP.210.01J Refueling Outage Main Steam to AFH Turbine Check Valve Integrity Test SP.210.04A Cold Shutdown Feedwater Valves Surveillance Test SP!214.01- Inservice Testing and Inspection of Valves SP.214.02 Inservice Testing of Relief / Safety Valves SP.214.03 Locked Valve List STP.650 Acceptance Test for the Auxiliary Feedwater Freeze Protection STP.651 Auxiliary Feedpump Runout Alarm Test STP.949 Acceptance Test of Auxiliary Feedwater Pump Fire Protection Deluge System

! STP.963 Auxiliary Feedwater System Heat Tracing Functions / Test ATTACHMENT 6.1 l

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LIST 0F DOCUMENTS REVIEHED (Continued)

Surveillance and Soecial Test Procedures (Continued) .

1 STP.1024 Fill NSCH from AFH l STP.1025 Auxiliary Feedwater System Turbine Test with Auxiliary j Steam Supply  ;

STP.1027 Auxiliary Feedwater System SRS to AFH NPSH Flow Test  !

STP.1058A (D) Sudden Loss of the Instrument Air System to an '

Atmospheric Dump Valve STP.1058C (D) Gradual Loss of the Instrument Air System to an .

Auxiliary Feedwater (AFH) Control Valve  !

STP.10580 (D) Gradual and Sudden Loss of IAS to a CCH Containment Isolation Valve i

, STP.1068 AFH Pump Flow Test with Condenser at Atmospheric Pressure STP.1070 AFH Hot Shutdown Test Surveillance Procedure Data Packages SP.210.01A Monthly Turbine / Motor Driven Auxiliary Feedpump P-318 Surveillance and Inservice Test Data Packages performed 01-24-75, 01-31-87, 02-20-87 '

l SP.210.01B Monthly Motor Driven Auxiliary Feedpump P-319 Surveillance and Inservice Test Data Packages performed 11-11-74, 11-12-74, 02-05-75, 05-19-75, 12-14-85, 11-18-86, 02-21-87 SP.210.01F Cold Shutdown Auxiliary Feedwater Pump Flow Test and Check Valve Full Stroke Test Data Packages performed 3 11-17-86, 02-23-87 i SP.210.21B Special Frequency Motor Driven Auxiliary Feedpump l P-319 Surveillance and Inservice Test Data Package )

performed 03-23-87  ;

Soecial Test Procedure Data Packaces STP.650 Acceptance Test fer the Auxiliary Feedwater Freeze I Protection Data Package performed 11-17-84 l STP.651 Auxiliary Feedpump Runout Alarm Test Data Package l performed 04-25-85 l' STP,949 Acceptance Test of Auxiliary Feedwater Pump Fire Protection Deluge System Non-Conformance Reoorts S-4244 S-6825 l S-4244, Rev 1 S-6929 S-5086 S-5373, Rev i S-6188 S-6467 S-6560 ATTACHMENT 6.1 I

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.e! a LIST OF' DOCUMENTS REVIEMED l(Continued)

Vendor Manuals M19.02 Specifications, Drawings and Instructions for Automatic.

Control Valves - Fisher PABCO Log 1826 Heat Insulation Manual M5.06-57 Hayward Tyler Pump Manual

, M5.06-IM01 Hitachi Motor Manual M31.07A-97 Grinnell Deluge Valve Vendor Manual Log #1071 Grinnell Deluge Valve Vendor. Manual Letters SRT 87-216 SGBH 87-154 GVC 87-809 JEM 87-098 RJR-86-086 Response to IE Bulletin 85-01 B&M letter to SMUD - SMUD 82-10 .

Hayward Tyler to SMUD 86-41-04 i CGA 87-492 SMUD Response to NRC on ASRTP Inspection (09-16-87) -)

NL 87-530 l Drawinas 1

31800-8"-HC Rev 5 M-530 Sh 3 of 3 Rev 14 M-533 Sh 3 of 5 Rev 10 i 31890-3/4"-HC Rev 1 M-530 Sh 3 of 3 Rev 18 M-536 Rev 21 31900-8"-HC Rev 14 M-532 Sh 1 Rev 0 M-536 Rev 24 31900-8"-HC Sh-1 Rev 1 M-532 Sh 1 Rev 0 M-536 Rev 24 .

31990-3/4"-HC Rev l' M-532 Sh 1 Rev 0 M-536 Rev 26 I 6292-N21.01-33-S1 M-532 Sh 1 Rev 0 M-536 Rev 26 I 6292-N21.01-94-S1 M-532 Sh 1 Rev 0 M-544 Rev 17 l 6292-M21.05-74-S1 M-532 Sh 1 Rev 1 H-594 Sh 2 Rev 4 l E-228 Sh 1 Rev 0 M-532 Sh 1 Rev 1 N21.01-102 Sh 1 Rev 2 i E-228 Sh 2 Rev 0 M-532 Sh 1 Rev 2 N21.1-33 Rev S1 )

I-203 Sh 99 Rev 0 M-532 Sh 1 Rev 3 N21.1-94 Rev S1 I-205 Sh 3 Rev 6 M-532 Sh 1 Rev 3 E-101 Rev 20 M5.06-8 Rev 1 M-532 Sh 1 Rev 6 E-104 Sh 6 Rev 4 MS.06-59 M-532 Sh 1 Rev 6 E-104 Sh 7 Rev 5 M19.02-338 Rev 0 M-532 Sh 1 Rev 9 E-205 Sh 44 Rev 0 M26.03-10 M-532 Sh 1 Rev 9 E-205 Sh 43 Rev 0 M31.01-194 M-532 Sh 1 Rev 10 E-228 Sh 3 Rev 0 M-530 Sh 2 Rev 0 M-532 Sh 2 Rev 0 E-343 Sh 2 Rev 3 M-530 Sh 2 Rev 10 M-532 Sh 2 Rev 2 E-1011 Sh 125 Rev 0 ATTACHMENT 6.1

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.:S LIST OF DOCUMENTS REVIEHED (Continued).

Drawinas (Continued) i H-530 Sh 2 Rev 10 M-532-Sh 2.Rev 3 E-1011 Sh 128 Rev 1 .l M-530 Sh 2 Rev 12 M-532 Sh 2 Rev 3 .I-203 Sh 99 New  !

M-530 Sh 3 of 3 Rev 10 M-532 Sh 2 Rev-3 I-205 Sh 3 Rev 6 l M-530 Sh 3 of 3 Rev 14 H-533 Sh 3 of 5 Rev 6 M-532 Sh 2 Rev 6 J M-530 Sh 3 of 3 Rev 14- M-533 Sh 3 of 5 Rev 7' l

A-3062 R-0470 f A-4383 R-0859 A-5415 R-1188 ,I A-5530 R-1656 R-0357A R-1672 ,,

R-0914A0 f

Calculations l Z-ZZZ-C0884 Z-FHS-M1798 Z-FPS-E0119 Z-IAS-M2084 Z-IAS-C0773 Z-FHS-C0882 Z-IAS-H2085 Z-IAS-C0810 Z-FPS-M0346 l Z-IAS-M2086 Z-EGS-E0658 Z-FHS-E0643 Z-MCM-IO138 Lesson Plans System Training Manual Chapter 29 Auxiliary Feedwater System 00-21I-4300R1 Auxiliary Feedwater System 00-21I-4300 Preparation Guide 00-210-3200 EFIC - Classroom OD-24K-1000 EFIC - Simulator Scenarios 00-23J-2100 NLO Auxiliary Feedwater System LER1 87-05 ATTACHMENT 6.1 1

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LIST OF DOCUMENTS REVIEHED (Continued).

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Hork-Reauests 23708,:35292,.45516, 69637, 71214, 72996, 78541, 78660, 80831,  !$

91515, 97846, 98546, 98547, 98548, 98549, 101321', 102143, 102978, 104621, 104992, 105981, 107030, 107438, 107597, 107609, 107836,  ;

108687, 109289, 109391, 110027, 110034, 110035, 110036, 110085 "

110086, 110087, 110088, 110508, 110814, 110912, 111024, 111025,1 111026,,111215,.114123, 114490,'115384, 115436, 115460 -115562, 115578, 115579, 115580, 115581, 115724, 115922, 116026, 116027, 116555, 120042, 120181, 120182, 122840, 123192, 126093, 126873, 127349,'127378, 127897, 127898, 129054,'129188,'129189,'129932, 130195,' 130908,1131004,.132543, 132778, 132887, 132888, 133119, 133447, 134515, 134607, 134918, 134918A, 137563  ;

IE Bulletin j 85-01 Steam Binding j Purchase Orders RS 54725 PRH 14486 i RQ 87-01-10032 .'

i RS 84478 Receivina Insnection Data Reterts l

.l QA 2059 1 QA 5022 QA 2915 QA 4628 QA 3075 Other Sources l Auxiliary Feedwater System, System Status Report Rev. O and Rev. 1 EFIC System Description, Rev. 1 Nucleis MIRS Master Equipment List (MEL) j Equipment History for AFH System ASME Section I ASME Section II, Part A ASME Section III, Division 1 ASME Section XI, Article IHV ANSI B31.1 ANSI B31.7 )

ANSI N45.2.11 ATTACHMENT 6.1 l '

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LIST OF DOCUMENTS REVIEHED (Continued)

-Other Sources (Continued)

ASTM Part 1, 4 ..

AISC Manual of. Steel Construction EPRI HS-78-132 NEMA Standard MG 1-1978 (R-1981)

.USAR, Chapter 10 'i Technical Specifications '

Technical Specification . Proposed ~ Amendment No.152 Engineering Action Plan - Inspection Readiness Worksheet-Control' Room Blue Book Crane " Flow of Fluids" I Marks " Standard Handbook for Mechanical Engineers" Piping Design Specification M-870 Rancho Seco Code Application Schedule .

QA Vertical Audit RI #84 i Safety System Functional Inspection Reports for.the following plants:

Palisades Docket No. 50-255 Pilgrim . Docket No. 50-293 Oconee Docket No. 50-269, 50-270, 50-287 l Rancho Seco Docket No. 50-312. l HB Robinson. Docket No. 50-261 THI-1 Docket No. 50-389 Trojan .

Docket No. 50-344  !

Turkey Point Docket No. 50-250 and 50-251 i i

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STATUS OF RIs l

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Attachment 6.2 provides RI status as'of this report date. An RI is considered closed if the Team Leader was convinced a' potential concern  ;

? was not valid or not significant enough to be an RI. An RI would also be closed if requested information was provided. All other RIs are open. 1 Acknowledged RIs are open RIs that have been-accepted as valid by the-responsible organization and have been stated as concerns in Section 5.0. q j

RI NUMBER STATUS i 224 (Acknowledged) 231 (Acknowledged).

236 (Closed) i 240 (Acknowledged) 241 (Acknowledged) l 243 (Acknowledged) ,

264 (0 pen)  !

I 266 (0 pen) i ATTACHMENT 6.2

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DETAILED' OBSERVATIONS -RE00EST FOR INFORMATION During an ' evaluation, all potential concerns are documented on Request for Information sheets (RIs) that are'sent to the responsible organization to ~ receive their input _concerning the potential concern. -

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RIs are also used to request information that the EASRTP team is-having~

difficulty obtaining.-

These RIs are. considered drafts throughout the entire evaluation until J

.they become part_of the rsport._ Responsible organizations can accept the ,

- potential' concern as valid _or they may disagree with the potential  ;

concern.- If _ they disagree, they can submit information that convinces' i the EASRTP team members that the potential concern.is not. valid, or they may' redirect the EASRTP members to better focus.the concern. RIs-developed during the system evaluation comprise this section of the -

report.

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REQUEST.FOR INFORMATION (RI)

,RI NO: , 224 SYSTEM CODE: AFH ISSUE DATE: '09-23-87

SUBJECT:

' ACCESS TO AREA AROUND AUXILIARY FEED PUMP P-318 DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR: T. TELFORD/3849 TEAM LEADER: F. STOCK /3929 l

POTENTIAL CONCERN /00ESTION:

Accessibility to the area behind AFH pump motor P-318 is severely restricted. In addition to limiting operator access to equipment for operation, surveillance, or valve monitoring, a distinct safety hazard has been created.

REASONS:  ;

The installation of cooling air shrouds per ECN A-5530 on the motor for pump P-318 has resulted in an additional problem accessing the area behind the pump. Prior to the installation of the shrouds, personnel  ;

were forced to straddle the motor to pump coupling guard when climbing  !

over pump P-318. The. shroud installation has blocked the access to the area behind the pump. Access to the area behind the pump is required for l surveillance, valve lineups and monitoring of the pump operation. Quick access to the area may be required to manipulate valves HV-30801, steam to terry' turbine and PCH-076 site water supply to auxiliary feed pump P-318. The north access route to the area is extremely difficult and is also a safety hazard since a steam line break or pump motor. fire will trap personnel in the enclosed area. l l

In addition, climbing over the pump is a safety hazard. Personnel could ,

slip and fall, particularly if the area is wet. The thermocouple and  !

seal water lines are vulnerable to being stepped on. Damage to the seal water lines could result in the pump being inoperable.

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' REQUEST FOR INFORMATION (RI)-

p RI-NO: 231 SYSTEM CODE:' AFH ISSUE DATE: 09-21-87 l' 'SUBJECTF CONTROL OF MATERIAL UTILIZED IN'AFH SYSTEM DEPARTMENT: NUCLEAR ENGINEERING LC00RDINATOR: T. TELFORD/3849 N. SAMPSON/4585-TEAM LEADER: F. STOCK /3929

.. i POTENTIAL' CONCERN /00ESTION: i Quality assurance and quality control procedures were not adequately.

implemented during the installation, inspection, and testing of the Quality Class 1 heater controllers.

REVIEH/RESULTS:

During.the performance of the acceptance' test for the Auxiliary.  !

Feedwater Freeze Protection, STP.650, Temperature Controller TCHT-31903B was found to be inoperative. The Class 1 device was replaced from stock and documented by NCR S-4244. -This NCR was later. voided and replaced by NCR S-4244. Revision 1 which states that the replacement item was actually purchased non-class and unaraded to commercial arade.

Disposition of NCR S-4244 Revision 1, states, "QA Class 1 replacement heater controller, when received, should be stored under 3 Stock No. 037485 complete with necessary documentation." It does  !

not require that the new Quality Class 1 device will replace the-  ;

'" upgraded" commercial grade device that was installed as a replacement. The NCR did not address seismic and equipment '

qualification.

. The RIDR # QA 2059 documents the upgrade but lacks QC Review and sign off in the appropriate. space. Per item 2 of RIDR # QA 2059, '

the original Purchase Order was for 8 devices, but only 5 were upgraded to Commercial Grade. )

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. The Certificate of Conformance inspection (a SMUD document) was pefformed on the Purchase Order of the upgraded devices, but was nol inspected to the original purchase order requirements as specified in ECN A-4383 in order to verify "like for like" replacement.

. The DBR to ECN A-4383 requires that the heater controllers be seismically and EQ qualified in accordance with IEEE 344-1975 and IEEE 323-1974. The material used to replace the defective device was only purchased as stock item without any of the required vendor $

supplied certifications. l ATTACHMENT 6.3

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L. REQUEST FOR INFORMATION (RI) i.

j. RI NO: 231 (Continued)

. Work Request 80831 which calibrated the heater.setpoints, did not receive QC Inspection. However, a Quality Class I heater controller was removed and replaced with an upgraded commercial grade heater controller. This is in conflict with 10CFR50_ Appendix 8,.which requires inspection to insure that the new heater controller was installed correctly, was the correct item as specified by  !

Engineering, and satisfies all ECN A-4383 requirements.

. NCR S-4244, Revision 1 specified that retest of the system / unit be l conducted, however, the " closed" NCR (02-25-85) does not indicate i that this was ever accomplished.

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ATTACHMENT 6.3 es , ,

.a REQUEST FOR INFORMATION (RI) p RI.NO

:236 SYSTEM CODE: AFW ISSUE DATE: 09-21-87

SUBJECT:

- EFFECTIVENESS OF THE AUXILIARY FEEDPUMP AREA FIRE PROTECTION SYSTEM DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR: T. TELFORD/3849 1 TEAM LEADER: F. STOCK /3929 POTENTIAL CONCERN /00ESTION:

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-The effectiveness of the fire protection system in the auxiliary feedwater pump area may be compromised by the design and installation of certain fire system components.

l REASONS:

'The air exhaust shroud installed to prevent water intrusion from the fire

' system into Auxiliary Feed Pump Motor P-319, blocks the proper spray pattern from the deluge nozzle adjacent to the shroud. The shroud and nozzle are located on the north side of the motor.. The' nozzle will spray only one third of the motor,'thereby greatly reducing the effectiveness of the nozzle.  !

The heat tracing and insulation installation on the deluge valve,  !

HY-47100, has. resulted in the inability to disassemble the valve. The l insulation covers the entire valve and is of the fab cloth type. The  !

valve must be-disassembled to be reset and to clean the valve internals following a system actuation. 4 The UV flame detectors are overly sensitive. Their sensitivity has interfered with the operability of the fire system, requiring a continuous fire watch posted in the area. Spurious alarms and actuations have occurred from sunlight, incandescent light, welding arcs, and radiation from the BHST. Electrical Maintenance and Fire Protection are addressing this problem, but it is not yet resolved.

l This RI is considered to be closed. The response from ERT has led us to  !

determine that this is not a valid concern.

ATTACHMENT 6.3 l

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REQUEST FOR INFORMATION (RI)

RI NO: 240 SYSTEM CODE: AFH ISSUE DATE: 09-22-87

SUBJECT:

ANNUNCIATOR RESPONSE PROCEDURE FOR' ZONE 110-AFH PUMP AREA DEPARTMENT: OPERATIONS COORDINATOR: R'.'HACIAS/4589 -'

TEAM LEADER: FRANK STOCK /3929 POTENTIAL CONCERN /00ESTION: l The IDADS Annunciator Procedure, Rev. 2, does not provide adequate ,

information nor guidance to properly respond to an alarm for the I Auxiliary Feedwater Pump Area Fire System.

REASONS:

The alarm points for X-8110 are multiple input alarms. The Annunciator ,

Response Procedure does not list all the individual inputs to each point.

IDADS point X-8110 has a total of five inputs. The actuating device is f listed as H4FCP8. The response procedure is to'" Investigate Circuit Trouble," however, this may be inappropriate dependent upon the input which triggered the alarm. The inputs to this point require distinct responses to ensure fire system operability. The alarm point does not indicate which input triggered the alarm.

The lack of information in the procedure could lead to improper responses l or overlooking of a condition that could impair fire system operability. .i

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. l REQUF.ST FOR INFORMATION (RI)

RI NO: 241 SYSTEM CODE: FPH ISSUE DATE: 09-21-87

SUBJECT:

TAMPER SWITCH INSTALLATION ON FPH-803 ISOLATION VALVE FOR ZONE 110 FIRE SYSTEM DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR: T. TELFORD/3849 TEAM LEADER: FRANK STOCK /3929 POTENTIAL CONCERN /00ESTION:

The design and installation of the tamper switch for the fire system isolation valve, FPH-803, may be inadequate for performing its intended function.

REASONS:

A tamper switch was installed under ECN A-5330 in order to provide indication that the isolation valve has been moved from its "open" seat.

Due to the design and installation of the switch, the possibility of closing the isolation valve 50% without receiving an alarm exists.

Partial closure of the valve may cause flow to be reduced below the system design requirements.

The ERT has initiated an NCR in response to this item.

ATTACHMENT 6.3

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p REQUEST FOR INFORMATION (RI)-

.RI NO: ~243 SYSTEM CODE: AFW ISSUE:DATE: '09-22-87

'SU8 JECT:l SECTION XI TESTING REQUIREMENTS

, DEPARTMENT: MAINTENANCE C00RDINATOR': J. DARKE/4817 TEAM LEADER: FRANK STOCK /3929 POTENTIAL CONCERN /00ESTION:

l The t'esting requirements of ASME Section XI, Subsection INV are not being-  ;

' met for the Auxiliary Feed Pump Suction Side Relief Valves,'PSV-31800 and PSV-31900.

RESULTS:

Subsection IHV,' Article INV-3200 requires that a valve which has been

removed for maintenance shall be tested prior to the time it is returned to service.- i Subsection INV, Article IHV-3515, requires similar valves in a system to  ;

be tested when "...any valve in a system fails to function properly during a regular test....".

The following items were noted during'this review:

. -Two work requests have been written and currently released for work for the removal and reinstallation of PSV-31800 and PSV-31900 with no setpoint verification prior to reinstallation.

. No supporting documentation was found for a test of PSV-31900 because of the failure of PSV-31800 in December 1982. '

. No supporting documentation was found for a test of PSV-31800 because of the failure of PSV-31900 in August 1983.

. If the August 1983 test of PSV-31900 was intended as the "similar  ;

valve" test for the December 1982 test of PSV-31800, then the 'I adequacy of the timeliness of proving system functionality under the l requirements of ASME Section XI must be evaluated. -

It has also been noted that the Auxiliary Feed Pump Turbine Casing Relief Valve does not appear as an IST Program valve.

ATTACHMENT 6.3

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REQUEST FOR INFORMATION.(RI)

RI NO: 264 SYSTEM CODE:- AFH ISSUE DATE: 09-25-87

SUBJECT:

SURVEILLANCE PROCEDURES FOR AFH CHECK VALVES FHS-047 AND FHS-048 AND RELATED SETPOINTS DEPARTMENT: SYSTEM ENGINEERING COORDINATOR: J. ITTNER/4701' i TEAM LEADER: FRANK STOCK /3929 POTENTIAL CONCERN /0UESTION: .{

Surveillance procedures for the AFH check valves do not adequately test f for system or. valve seat integrity. This may. result in unidentified or unanalyzed overpressurization conditions.  ;

REVIEN/RESULTS: i

1) SP.210.OlF, Rev. 8 (Cold Shutdown Auxiliary Feedwater Pump Flow Test

.and Check Valve Full Stroke'. Test), Section 5.1 of acceptance criteria states that " full stroke of the check valve is verified by i passing of design flow." '

SP.210.'01A, Rev. 23, and SP'.210.01B, Rev. 23 (Monthly Surveillance and Inservice Test of the Auxiliary Feedwater Pumps), state that "no rotation of the standby pump verifies seating of the check valve" (FHS-047 or FHS-048).

The passing of full flow through the check valve is not considered to be verification of the physical integrity of the valve, it is ,

only a verification that no obstruction exists in or because of the '

valve.

The loss of seat integrity of the check valve would not manifest '

itself as pump rotation on the static system but as a pressure increase in the pump and pump suction piping.

A review of applicable draft procedures indicates that the above  ;

/

items will be resolved unon issuance.

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ATTACHMENT 6.3

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REQUEST FOR INFORMATION (RI)

RI NO: 264 .(Continued). 1 l

2) The failure (due to overpressurization) of the 30# pressure gauges l (PI-31803 and PI-31903) on the suction side of the Auxiliary i Feedwater Pumps indicates that a possible design overpressurization  ;

condition could exist. Root cause of the overpressurization may be l

.the lack of seat' integrity of check valves FHS-047 and FHS-048. '

The setpoint established for the feedpump suction side relief valves, PSV-31800 and PSV-31900, are currently 100 z 3 psig (in ,

Process Standard AP.152).- The suction piping for the Auxiliary-Feedwater Pumps has a design maximum pressure. rating of only 30 psig'.

Review of the calibration records'for PI-31803 and PI-31903 indicate  !

repeated damage and replacement due to overpressurization (4 times  !

for PI-31803 and 5 times for PI-31903). The continued replacement  !

of damaged equipment should initiate a root cause analysis if the 1 proper trending was being dono, l

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ATTACHMENT 6.3

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' REQUEST FOR INFORMATION (RI) l RI NO: 266 SYSTEM CODE:' AFH ISSUE DATE: 09-25-87  ;

SUBJECT:

USAR COMMITHENT AND DESIGN ASSUMPTIONS UTILIZED FOR CST CALCULATIONS DEPARTMENT: LICENSING COORDINATOR: J. DELEZINSKI/3909

. TOM TELFORD/3849 1 TEAM LEADER: FRANK STOCK /3929 l I

j i

POTENTIAL-CONCERN /00ESTION:

1) The USAR contains commitments regarding the condensate storage tank (CST) level' alarms and water levels which are not consistent with 4 plant. conditions nor supporting design calculations and (2) the design calculation and assumptions utilized for establishing the 40 minute-response criteria may be non-conservative.

REVIEH/RESULTS:

4

. With respect to Item (1) above, the following statements are l contained within the USAR: ., l A) Volume V, Page 10.2-5 Amendment #2 states', "The low level I alarm on the CST allows 40 minutes to transfer to alternative water supplies." (This alarm is at the 42' ',

level.)

B) Volume V, Page 10.2-5b Amendment #2 states, "The CST is ,

protected adequately against high winds up to 175 MPH and '

the lower 8 feet of the CST offers protection against missiles generated by these winds. '...The assured 8 feet of i water in the CST, in conjunction with low level and low-low i

level alarms for the CST, provide adequate time for operator action to switch over to an alternate source of water." {'

(Alarms are at 42' and 29' respectively.)

A review and investigation into the commitments referenced above indicates the following:

,e

- Calculation Z-HCH-IO138, dated 02/12/87, initiated in response to .'

NRC ASRTPI finding 3.3.4(7)(d) utilized the low-low-low level alarm (3' level) as the initial alarm setpoint for the 40 minute response  :

time. This is inconsistent with USAR statements referenced in (A) and (B) above.

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- Since the CST sits on a 2 foot concrete pedestal, the concrete

missile barrier only protects the tank to a level of 6'2". This is inconsistent with (B) above. j ATTACHMENT 6.3 1'

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REQUEST-FOR INFORMATION (RI)  ;

RI NO: 266- (Continued) 1 i

. Hith respect to Item (2) above, the referenced design calculation (Z-MCM-IO138) may be non-conservative since a worst case scenario would indicate that a 40 minute response time before a loss'of pump suction (approximately 6" tank level) would need to be initiated  ;

near'the 9' tank level. As noted above, however, the tank is 1 considered to be missile protected to a height of only approximately 6'2".

The portion of the.RI pertaining to the USAR is considered to be valid covered by RI#172. l l

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