ML20204H718

Interim Safety Evaluation Re Pump & Valve Operability Assurance (SER Confirmatory Issue 13).Pages from Pvort Audit Encl

ML20204H718
Person / Time
Site:	Beaver Valley
Issue date:	03/18/1987
From:	NRC
To:
Shared Package
ML20204H633	List: ML20204H629 ML20204H718
References
RTR-NUREG-0737, RTR-NUREG-1057, RTR-NUREG-737, TASK-2.E.4.2, TASK-TM IEB-79-15, NUDOCS 8703270079
Download: ML20204H718 (18)

Text

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Enclosure to

',' meeting notice dated

. 3/18/1987 INTERIM SAFETY EVALUATION PUMP AND VALVE OPERABILITY ASSURANCE (SER confimatory issue 13)

BEAVER VALLEY POWER STATION UNIT 2 3.10.2 Operability Qualification of Pumps and Valves 3.10.2.1 Introduction. The staff performs a two-step review of each ap-plicant's pump and valve operability assurance program to determine whether its program can ensure that all pumps and valves important to 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 purip and valve operability. The results of the FSAR evaluation appear in Section 3.10.2 of NUREG-1057, " Safety Evaluation Report Re -

lated to the Operation of Beaver Valley Power Station, Unit 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 (INEL-EG&G),

conducted the second step of the review which consisted of an audit of a re-presentative 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 detemines 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.

8703270079 870318 PDR ADOCK 05000412 E PDR 3.10-1

. o The following sections include: (a) a discussion of the PVORT review pro-( cess, (b) a summary of PVORT findings concerning the applicant's overall pump and valve operability assurance program, (c) a discussion of the operability 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 Beaver Valley Unit 2 l 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 Beaver Valley FSAR evaluation appeared in an SER (NUREG-1057) dated October 1985 and were discussed at a pre-audit meeting held July 23, 1986. Several of these issues were adequately resolved by the applicant in a letter dated September 23, 1986.

Evaluation of SER Issues: The staff investigated the deep draft pump issue during the audit. In a letter dated September 23, 1986, the applicant provided

, a description of the program for deep draft pumps. The program was verified j during the site audit by reviewing documentation for the service water pump 25WS-P21B. Based on the applicant's response and site verification, the deep draft pump program should be adequate to assure operability.

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 September 23, 1986, the applicant provided a response to the re-quest. The response indicated that the purge and vent valves are considered to be inactive valves and will be closed during normal plant operation. The staff has evaluated the applicant's response and FSAR Section 9.4.7.3 (Amend-ment 6, April 1986). It appears that containment purge valves 2HVR-MOD-23A,

-23B, -25A, and -25B will be sealed closed during operational modes 1, 2, 3, and 4 (power operation, startup, hot standby, and hot shutdown, respectively).

This is an acceptable approach to meeting the requirements of NUREG-0737, Item II.E.4.2 (6). The applicant has committed to provide priar to fuel load documentation which demonstrates containment purge valve operability. The staff's position regarding acceptability of these valves will be included in a

( future supplement to the SER.

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Thefollowingdiscussion,f1'iststheremainingSERissuesasoriginally identified in NUREG-1057 and'/ describes the manner by which each issue was addressed. jp

1. Issue. The environmental qualification of the BOP pump motors is not specifically mentioned in FSAR 3.98.'3.2.1, as compared to the BOP valveoperatordiscussioninFjAR'3.98.3.2.2 Item 5. The applicant shall amend the FSAR as needed to confire that the operability quali-fication of each pump motor considered all environmental conditions over its qualified life (aging, radiation, accident environment, etc.). (See FSAR Section 3.98.3.2.1, page 3.9.10a and NUREG-1057 Section 3.10.2.)

Evaluation. In a letter dated September 23, 1986, the applicant provided a response to this issue. The response indicated how motor environmental qualification was being addressed and that the required information would be included in a future amendment

, to the FSAR. This issue is confirmatory. .-

U 2. Issue. Many of the preoperational tests listed in FSAR Table 3.98-1

, are to be monitored visually rather than by calibrated instrumenta-tion. Visual monitoring alone may not be adequate to detect subtle j system responses that may differ from the responses predicted by qualification analyses. The applicant shall provide justification that the preoperational test results will validate the qualification of the systems, components, and supports. (See FSAR Section 3.98.2, Table 3.9B-1 and NUREG-1057 Section 3.10.2.)

Evaluation. In a letter dated September 23, 1986, the applicant i

responded to this concern. The response indicated that Table 3.98-1 refers to visual monitoring of piping systems only. The applicant also referred to the responses to FSAR Questions 210.2, 210.21, 210.22, 210.23, 210.24 and 210.41 where instrumented monitorjng requirements are more clearly defined. It is evident that testing of pumps will be performed with adequate instrumentation. This issue is closed.

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1 Evaluation of On-Site Audit:

-t The on-site audit, which was conducted September 30, through October 2, 1986, consisted of field observations of the equipment configuration and in-sta11ation for a representative sample of plant equipment. The PVORT evaluated five NSSS and seven BOP pump and valve assemblies. In addition, six items (3 NSSS and 3 BOP) were inspected to verify installation status. 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 speci-fications, 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 the plant's overall equipment qualifica-tion program. Included within this broad evaluation were those programs and procedures necessary to ensure that equipment qualification issues and con-cerns will continue to be addressed for the life of the plant. One such pro-gram, concerning the deep draft pump issue (refer to IE Bulletin 79-15), was reviewed in depth.

O 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) the fuel l pool cooling pump did not meet design flow rate or manufacturer's vibration l

recommendations, (2) the MSIVs were not qualified and a design flaw had been I

identified, (3) the turbine driven auxiliary feedwater pump did not have pre-ventive maintenance identified in accordance with the turbine manufacturer's recommendations, and (4) the steam generator blowdown isolation valve load analysis did not address load effects appropriately.

In addition, the applicant was informed at the close of the audit of generic issues. These issues are: (1) all of the pre-service tests required before fuel load have not been completed, (2) approximately 10 to 15 percent of all pumps and valves important to safety are not yet installed and quali-fled, (3) similarity statements were fnot provided, (4) retrieva,1 of qualifica-tion documents was not adequate, (5) check valve design in accordance with the INPO workshop needs to be confirmed, (6) non-conformances and dispositions did not appear to be effectively controlled, (7) FSAR drawings do not identify Beaver Valley 3.10-4

check valves by identification number, and (8) the FSAR does not provide a

( complete list of safety-related pumps and valves (80P and NSSS). These items form the basis for the discussion presented in Section 3.10.2.3.

Following the site audit the applicant submitted a letter, dated Octo-ber 27, 1986, which completely resolved specific issues 3 and 4. The commit-ments to resolve specific issues 1 and 2 and generic issues 1, 2 and 4 appear to be acceptable pending confirmation by the staff. The responses to generic issues 3, 5, 6, 7, and 8 are not acceptable and need to be resolved prior to fuel load.

Overall Evaluation:

The PVORT believes that the applicant is dealing with the equipment quali-fication issue in a positive manner. During the audit, the applicant addressed all questions posed by the PVORT and committed to resolve all audit issues prior to fuel load or provide adequate justification. Furthermore, the appli-cant discussed significant aspects of its overall equipment qualification pro- 1 gram, aspects such as amplified response spectra reconciliation, equipment modification and reconciliation of original qualification reports, nozzle load verification, and review of non-safety related equipment located in close 1 proximity to safety related equipment. Consequently, the PVORT believes that the continuous implementation of the applicant's overall program should pro-l vide adequate assurance that the pumps and valves important to safety will l operate as required for the life of the plant.

2.10.2.3 Operability Issues. Based upon the PVORT site audit, the staff has identified to the applicant the following 4 equipment specific and 8 generic issues. These issues for which an adequate response has not l been provided are identified below. These issues must be resolved prior to

fuel load.

Specific Issues: .-

1. _Tssue. The review of the fuel pool cooling pump (Tag Number 2FNC-P21A) revealed that during pump testing the applicant had identified

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l l-design flow rate and pump / motor assembly vibration readings as not being within the limits of the acceptance criteria. The vibration problem requires that the pump mounting have additional support added. The applicant shall notify the staff when (a) the installa-tion has been modified and (bl the pump satisfactorily meets the testing of all design parameters and manufacturer's criteria.

Evaluation. In the letter dated October 27, 1986 the applicant com-mitted to notify the staff when the fuel pool cooling pump has been tested and accepted for operation. The applicant has already ex-plained that the testing and modifications will not be completed prior to fuel load. The applicant has detemined that the pump is not reauired until the start of the first refueling outage. The staff finds the applicant's commitment to be acceptable, pending notification by the applicant. This issue is confimatory.

2. Issue. The review of the MSIV (Tag Number 2 MSS-HYV101A) found that operational problems have been identified by the applicant. Also, environmental cualification had not yet been completed. The applicant is considering several options to address operability of this component, including redesign or replacement. The applicant shall notify the staff when (a) a suitable modification and repair has been detemined, (b) the necessary repairs and modifications have been completed, (c) testing has been completed, and (d) when full cualification in-cluding environmental has been established.

Evaluation. In the letter dated October 27, 1986 the applicant indi-cated that the existing MS!Ys will be used. The applicant will notify the staff when all problems associated with the MSIVs have been cor-rected, and the valves are fully qualified and ready for operation.

The staff finds the applicant's commitment to be acceptable, pending confimation of qualification. This issue is confimattory.

Beaver Valley 3.10-6

3. Issue. Theap[licanthastaken'exceptiontothevendorrecom-( mended 5 yearfteardown of the emergency feedwater turbine (Tag Number 2FWE-T2'2). In lieu of the 5 year teardown, the appli-cant intends to evaluate the teardown schedule based on surveil-lance and trending data. The applicant shall (1) contact the vendor to compare the Beaver, Valley surveillance and trending Lnalysis programs with the 4endor's recommendations and (2) reach a consensus for all maintenance activities to be per-formed on the turbine, including teardown.

Evaluation. The applicant has contacted the turbine vendor and has agreed to follow the vendor's 5 year maintenance program.

This issue is closed.

4. Issue. The review of the air operated Masoneilan valve (Tag Number 2BDG-A0V100B1) identified concerns with the structural integrity analysis. The analysis of the flange connection from

p. the operator to the bonnet utilized ASME Code equations for a -

pipe flange and employed the equivalent pressure technique to account for teending moments. This method does not include the effects of the direct vertical seismic load nor torsional moment. The applicant shall provide justification for not including these effects.

Seismic test reports for a 4-inch and 3-inch valve were reviewed.

Both of these reports identified amplification factors at the operator center of gravity at frequencies below 33 Hz. Amplifi-cation of the seismic loads was not included in the structural analysis. The applicant shall provide justification for not including the amplification.

Evaluation. The applicant determined that the effects of the vertical seismic load and amplification factor are a factor of 10 less than the torsional (bending) load applied. The effects due to the vertical seismic load were co.'sidered to be relatively insignificant. The results of the vendor's stress analysis Beaver Valley 3.10-7

identified a calculated stress of 6000 psi compared to the

/ 30000 psi allowable limit. The staff finds that the applicant's explanation justifies the method of qualification. This issue is closed.

Generic Issues:

1. Issue. At the time of the audit, most construction tests had been completed. The hot functional tests are scheduled for late 1986.

The applicant shall confirm that all 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 pre-service tests to be completed, the schedule for these tests, and the justification for any tests scheduled beyond fuel load.

. Evaluation. The applicant responded to this issue in a letter dated October 27, 1986. The Initial Test Program and Pre-Operational Test l . Phase are described in FSAR Section 14.2 and 14.2.1.2. The schedule

} for the Initial Test Program for system operability verification, pre-op test phase, and initial start-up test phase is shown FSAR Figure 14.2-3. The applicant intends to complete the majority of pre-op tests before fuel load. The applicant has committed to per-form sufficient testing prior to fuel loading to provide reasonable assurance that the tests performed after fuel load will be success-ful. The applicant has stated that "all appropriate pre-service tests will be completed prior to fuel load." The staff finds the applicant's response and FSAR descriptions to be acceptable, pending confirmation of completion of the pre-service tests needed before fuel load. This issue is confirmatory.

2. Issue. At the time of the audit, approximately 10 to 15 percent of all safety related pumps and valves had not been qualified. The ap-plicant shall confirm that all safety-related pumps end valves are properly qualified and installed prior to fuel load. In addition, the applicant shall provide written confirmation that the original loads used in tests or analyses to qualify safety-related pumps and j Beaver Valley 3.10-8 i

l 1 1 valves are not excee ed by any new liads, such as those imposed by a LOCA(hydrodynamichoads)oras-builtconditions.

p Evaluation. In the letter dated October 27, 1986 the applicant made '

a commitment that all safety-related equipment will be qualified and properly installed prior to fuel load. The applicant will notify l the staff if any equipment cannot,be qualified before fuel load, or

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if any new loads are imposed that exceed those loads used to orig-inally qualify the equipment. The staff finds the applicant's response acceptable pending confirmation of qualification completion.

This issue is confirmatory.

3. Issue. There were several instances where the tested component is not the same as the installed component. However, no similarity i analysis has been included in the documentation which addresses ac-

, captability. A similarity statement (analysis of form, fit, func-

tion, manufacturing methods, materials, etc.) must be provided in

all cases where the tested unit is not identical to the installed ..

unit. The effect of these differences on component operability J

should be addressed. Attention should also be given to test condi-i tions that are not identical to the expected plant conditions. The applicant shall evaluate its document files to assure that all sini-larity concerns have been addressed.

Evaluation. In the letter dated October 27, 1986 the applicant made j a commitment, which adequately addresses similarity analysis for two l components (2 CHS-MOV 8130A and 2 IAC-MOV 130). The applicant has committed to reverify the similarity evaluations in conjunction with the finalization and turnover of these two equipment qualification packages. This is acceptable.

l The applicant has stated that a complete review of all equipment qualification packages was performed during the pack,4ge assembly

j. stage of the program prior to the PVORT audit. However, the above 5

two concerns identified by the staff during the PVORT audit were considered to be of a generic nature. The staff's concern is that 2

the applicant's pre-audit review of the qualification packages may i

! Beaver Valley 3.10-9 1

nothavebeensuffj[ienttoaddress'similarityanalysisforall safety related punips and valves.

i' In order to resolve this issue the applicant needs to complete the following action items prior to fuel load:

a. Based upon a representative' sampling of NSSS and BOP active safety related pumps and valves, the applicant shall demonstrate that the qualification by similarity can be justified. In each case where the tested unit is not identical to the , installed unit, the applicant shall confirm that a similarity statement (analysis of form, fit, function, manufacturing methods, mate-rials, etc.) has been provided. The statement or analysis shall

include the basis for assessing similarity.

b. Using the same representative samplint,in (a), the applicant shall confirm that any differences between the tested and in-

, stalled units do not adversely affect equipment operability.

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c. The applicant shall submit for staff review examples of similar-ity analyses for one active safety related pump and one active safety related valve.

Until these items are completed this issue remains open.

4. Issue. The audit revealed that errors were made in retrieving the appropriate qualification documents. Although the reports were eventually made available for the audit, the method of retrieval is l

complicated ann lacks consistency. The applicant shall evaluate

( their document control syst6m to (a) determine its effectiveness, (b) reduce the potential fo,r human error, and (c) ensure that all personnel who use the document retrieval system are adequately

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trained. I l

Evaluatien. In the letter dated October 27, 1986 the applicant made it a commitcent to evaluate the equipment qualification documentation Beaver Valley 3.10-10

e packages to improve the documentation retrieval system in conjunction with the finalization and turnover of the packages to Duquesne Light Company. Any improvements will be incorporated into the Final Equip-ment Qualification Documentation Package and will be compl.eted prior to fuel load. The staff finds the applicant's response to be accept-able, pending confirmation of completion of the turnover of packages.

This issue is confirmatory.

5. Issue. In a letter dated September 23, 1986 the applicant committed to evaluate any recommendations that may result from an INP0 workshop held in October 1986 on check valve operability. The applicant needs to (a) describe the extent of its participation in the workshop and (b) indicate any actions (mandatory or voluntary) that will be taken by Beaver Valley to assure check valve operability.

. Evaluation. The letter dated October 27, 1986 did not include a response to this issue. This issue remains open.

6. Issue. There were two instances where the Nonconformance and Dispo-sition (N&D) tags were not accurate, indicating that the tracking system is not as effective as it should be. The applicant shall pro-vide evidence that N&D 16001 and 32817 have been completed and ac-cepted prior to fuel load. In addition, the applicant shall provide written confirmation that the N&D tags and rejection tags for all safety-related pumps and valves have been satisfactorily resolved prior to fuel load.

l Evaluation. The letter dated October 27, 1986 did not include a response to this issue. This issue re.nains open.

7. Issue. The FSAR figures do not identify check valves by label (mark number). Since these valves are active, safety-related components, the applicant shall confirm that all check valves arf correctly identified in the FSAR figures prior to fuel load.

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Evaluation. In the letter dated October 27, 1986 the applicant

(_ stated that the check valves are identified on the Beaver Valley 2 design and operation drawings as required. The applicant considers the FSAR to be a licensing document, which does not require all equip-ment items to be listed. The staff does not find this response to be acceptable. The staff is not aware of any other plant which has failed to identify check valves in the FSAR text, tables, and figures.

The FSAR description should be representative of the plant configura-tion, including the identification of safety-related equipment. The applicant has already committed in the response to Generic Issue 8 to amend the FSAR tables to list all active safety related pumps and valves, including check valves. In order for the content of the Beaver Valley 2 FSAR to be consistent, the applicant shall confirm that all active safety related check valves are correctly identified in the FSAR figures prior to fuel load. This issue is open.

8. Issue: At the conclusion of the PVORT audit, it was apparent that a complete list of safety-related pumps and valves had not i been provided in the FSAR. The applicant shall confim that all safety-related NSSS and B0P pumps and valves including check valves are correctly identified in the FSAR prior to fuel load.

I Evaluation. In the letter dated October 27, 1986 the applicant com-mitted to list all balance-of plant (80P) active pumps and valves in the FSAR Amendment 13 scheduled for' January 1987. This response is acceptable for BOP equipment. The applicant needs to confirm that the FSAR list of Nuclear Steam Supply System (NSSS) active safety related pumps and valves is correct. In addition, the applicant needs to confirm that all active safety related NSSS and 80P check valves are correctly identified in the FSAR tables. This issues is open. -

i 3.10.2.4 Summary. Based on the results of: (a) the component walkdown and the review of the qualification document packages, (b) the additional ex-planations and information provided by the applicant throughout the audit and in the letter dated October 27, 1986, and (c) the resolution of the SER itams,

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• 9 the staff concludes that an appropriate pump and valve operability assurance program has been defined and substantially implemented. The continuous imple-mentation of this overall program should provide adequate assurance that all pumps and valves important to safety will perform their safety related func-tions as required for the life of the plant. With the exception of the open and confirmatory issues identified in Section 3.10.2.3, the staff concludes that Beaver Valley Unit 2 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 to 10 CFR 50.

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.' TABLf 3.10.2.1. SUPPARY OF PVORT AUDIT FOR [EAVER VALLEY UNIT 2 Equipment Plant Findings Resolution Status Description I.D. Functien (Notel (Note) (Notel Joron recovery 2 RCS-v56 Valve normally -- -- Closed system to PRT (NSSS) close:. Valve en:ct valve opens to ft11 (Atwood and Morrel PRT. Valve 3* cnect valve) closes for containment isolation.

Valve normally -- -- C1cseca RwR suction from 2 RHS MCV7018 RCS not leg (N555) closed. Valve isolation valve coens to take (Westingnouse 12" RHR suction from gate valve) RCS. Valve acts as a RCS pressure boundary.

Low head safety 25!S-MOV26a A Valve normally *

-- -- Closed injection to RCS (N555) closed. Valve hot leg or cold leg opens for RCS isolation valve hot leg (Westingnouse 10" recirculation.

gate valve)

Lom head safety 2515-P219 Pump normally -- -- Closed injection pump (N555) snut down. Pump (Could, 3000 gpm) starts for low pressure cociant injec ion.

Emergency beration 2CHS MOV350 Valve normally -- -- Closed

. isolation valve (N555) c1csed. valve

}velan 2" gloce opees for palve)

• emergency beration backup to normal boration patn.

Biron recovery 2RCS-ACv519 Valve normally -- -- Closedb system to PRT (NSSS) closed. valve isolation valve opens for soray (Westingnouse inside of PRT 3' disonragm) and closes for containment isolation.

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s TABLE 3.10.2.1. (continued)

Plant

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findings Resolution Status Equipment (Notel (Note' 'Netet Descriotien f.D. [g' Function thl lyalve normally -- -- Closed Nitrogen sucaly 2SNS-50V853A to safety injection (hSSS) closed. valve ooers to tank 21A isolation pressurire valvo (Target Roca 1" gate valve) injection tank. ~

valve closed for nitrogen .

isolation, y,/

2RHQ-p21A Puf*p normally -- -- Closect Residual hest removal pump (NSSS) in standby.

(Ing;rsoll Rand, Pump started 4000 gpm) for residual heat removal.

Valve normally Noteh Noted Closed Steam generator 2BDG-A0V10081 slowdown isolation (BCP) open to allow val:e (Masonetlan steam generator 3' globe valve) tstowdown. Valve l closes to isolate blow-down.

-- C 1,osed Component cooling 2CCo-v6 valve ooens to --

water pump P21C (BCP )

allow pumo flow discharge check or closes to valve (TRW 20" isolate an idle pump.

Check valve)

• Valve normally -- -- Closed .

25=E-MOV1166 l(.Standbyservice

. tater system succly (BCP ) closed as a Galve (Henry Pratt division valve JC' butterfly valve) cetween Trains A and B. Valve opens on a standoy pump run signal.

Pume operates to Note c Note d Open' Fuel pool cooling 2FNC-P21A pump (Gould. ( BOP ) remove neat buildup in 750 gpm) the spent fuel pool.

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1. 1 ant Findings Resolution Statas

. Eculoment (Nctel ( *.ot e ) (Note)

Descrietien f.0. Function

.[ Two pumps out of -- -- Closec

\ dervice water pump 2 5=S-P21 B (Byron Jactson, three normally 15.000 gam) operating to remove auntliary system heat loads.

One pump out of three recaired for safe shutdown.

valve normally -- -- Closes Containment 2 !HC.MOV130 1:strument air (BCP ) open. Valve isolation valve closes on (Nomox 3" plug containment valve) isolation signal.

2*SS-nVV101A Valve normally Note f Note d Ocen' Main steam isolation valve (BOP) open. Valve (Crosey 32" ball closes to isolate valve) main steam line. -

valve normally -- -- Closecb Hydrogen comoiner 2wCS-50V11aA inlet isolation (BCP) closed. Valve valve (Target opens to provide Rock 2" glace flow from -

valve) containment vacuum pumps.

Valve normally -- -- ClosedD Cooling water to 25=S-MOV1068 primary component open. Valve cooling heat closes to isolate enchanger isolation service water valve (Henry Pratt from Train B.

f0?cutterflyvalve)

Auxiliary feedwater 2FWE 822 Pues normally Note I Note d CloseCD pump (Terry Tureine in standoy. Pump 750 gpm) starts to

• provide water to steam generators.

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Plant Findings Resolution Status Ecuipment Description t.0. r unction (Ncte) 'ictet (hetet

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Ooerate as Note d coene all #Uw 5 aND VALVES Notej'**

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• recuired daring

!!9CiiTANT TO SAFETY the Itfe of tne "'O'D' ot tnt uncer normal ano accident Conditions.

a. This component is a RCS coundary isolation valve: however. leak rate testing is not being performed.

This item is Considered to De Closee sending aCCeDiance of the Tecnnical Specifications anc its testing requirements.

b. This item was visually inspected fer completeness of installation. Qualification documentation was not reviewed except on a limited basis,

c. (SPECIFIC !$$UE) During oualification documentation review, it was found tnat tne pump and motor installation did not meet the design flow or maximum vibration requirements. The applicant was aware of the deficiencies. In the letter dated October 27, 1986 tne applicant committed to notify the staff

• when this pump meets its design and vibration criteria. Tnis is acceptatle, pending notification ey the applicait. This issue is ccnfirmatory.

d. At the conclusion of the site audit, the staff Sumarized the coen issues. Tne apolicant was informed of the appropriate actions necessary to resolve the specific and generic issues pricr to fuel lead.

e. Qualification status will be " closed" upon resolution of specific and generic issues.

f. (Sp!CP !C ISSUE) This component was partially oualified, however, when testing was being performed, a

' #. design flaw was identified. The flaw resulted in failure of toe actuator. At the time of tne site audit the applicant had not determined a repair. The applicant small (a) determine a suitaole 1y) modification and repair. (b) make the necessary repairs. (c) perform testing to e9sure modifications are adeduate, and (d) ensure tnat toe component is cualified. These recairements small tie confirmed 1

' prior to fuel load. In the letter dated Octoner 27, 1886 tne applicant comitted to notify the staff when all problems associated =1tn the PS!Vs have been corrected. This is acceptable pending notification by the aDolicant. This issue is confirmatory.

! g. (GENERIC !$$UE) The potential for flow disrupting conditions that could affect eneck valve operacility has not been assessed. Tne acc11 cant has comitted to participating in tne lhp0 eneck valve worksnco and verifying design against INDO toentified criteria. As of Octooer 27. 1996 the applicant has not specified what actions will be taken to assure check valve operability. This issue is open.

h. (SPECIFIC !$5UE) The review of the structural integrity analysis revealed that justification was not provided for omitting consideration of oirect seismic vertical loads, torsional moments and measured amplification factors. The acclicant sna11 provide justification for not including (a) tne effects and (D) the amplification f actors. In the letter dated Octooer 27, 1966 the applicant determined that tne i

effects of the vertical seismic load ano amplification are insignificant. T*its issue is closed.

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... .e TA 3.10.2.1. (continued)

t. (58ECIFIC !$5UE) Tne frecuency for turbine disassemoly differs from tne vendor's reconenendations. The applicant sna11 provide assurance tnat the tureine vendor's recomunendations for maintenance including disassemely are invoted ny the leaver valley unit 2 maintenance program. In the letter cated

( Octocer 27, 1986 tne appitcant agreed to follow the vencor's maintenance program. Tnis issue is closed.

J. (SENERIC !$ SUE) At tne conclusion of the PVORT audit, it was apparent that a complete list cf active pumps and valves nad not been provided in tne FSAR. At the site audit, tne appiteent corrottee to confirm that all active M555 and 800 pumos ano valves are correctly identified in tne F5AR. Tne response cated Octoeer 27. 1926 is not ccmplete. Tnis issue is open.

k. (GENERIC !55UE) Some pre. service tests reoutred to be completed prior to fuel load have not yet been performed. At the site audit, the applicant comnitted to confirm that all appropriate pre. service tests have been completed prict to fuel load. Tne response dated Octocer 27, 1986 is accentaole, pending notification by tne applicant. This issue is confirmatory.

1. (GENERIC !$5UE) Some pumps and valves important to safety have not been completely cualified and installed. At the site audit, the applicant comitted to confirm that all pumps and valves important to safety are completely cualified and installed prior to fuel load. Also, the applicant shall confirm that the original loads used in tests and analyses to cualify pumps and valves important to safety are not exceeded by any new loads (i.e. design load reconctitation). The response dated Octoeer 27,1986 is acceptable, pending notification by the appittant. This issue is confirmatory.

c. (GENERIC !$5U0) Similarity statements were not provided in all cases where similarity ovalification was utilized. The similarity statement should include a ciscussion about the difference between cualification and installed conditions. The applicant shall evaluate their document files to assure all similarity concerns have been addressed. The response dated October 27, 1986 is not complete.

This issue is open, 3

n. (GENERIC ISSUE) Document retrieval was inconsistent. The appitcant sna11 evaluate their documen't control system to (a) determine its effectiveness. (b) reouce the potential for numan error, and (c) ensure tnat all personnel uno use tne document retrieval system are acecuately trained. In tne letter dated October 27, 1986 the applicant comitted to evaluate the document retrieval system in conjunction with the finalization and turnover of packages to the Duouesne 1.iget Company. This issue is confirmatory.

(f .

(GENERIC ISSUE) Inconsistencies were identified in nonconformance and disposition tag (h&O) controls.

y) o. The applicant sna11 (a) provide evidence that the inconsistencies nave been completed and accepted and (b) confirm that h&D and rejection tags for all safety related pumps and valves nave seen satisfactorily resolved prior to fuel load. As of October 27, 1986 the applicant has not specified wnat actions will be taken to assure adequate control of nonconformances and dispositions. This issue is open.

p. (GENERIC !$5UE) The FSAR figures do not identify check valves tiy an identification lace 1. The applicant shall confirm that all eneck valves are correctly identified in the FSAR figures prior to fuel load. The response dated Octocer 27, 1986 is not acceptable. This issue is open.

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