ML20148S911

Insp Repts 50-277/87-32 & 50-278/87-32 on 871102-06. Violations Noted.Major Areas Inspected:Implementation of Inservice Testing Activities to Assess Adequacy & Verify Adherence to Regulatory Requirements & Licensee Commitments

ML20148S911
Person / Time
Site:	Peach Bottom
Issue date:	01/23/1988
From:	Eapen P, Gregg H, Prividy L, Sullivan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
References
50-277-87-32, 50-278-87-32, NUDOCS 8802030172
Download: ML20148S911 (21)

See also: IR 05000277/1987032

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-277/87-32; 50-278/57-32

Docket No.

50-277; 50-27_8

License No.

OPR-44; DPR-56

Licensee:

Philadelphia Electric Company

~RIl Marb E $treet

2

1. KIlaceiphia, fennsylvania

1)@

facility Name:

Peach Bottem Atomic Power Station, Units 2 and 3

Inspection At: Delta, Pennsylvania

Inspection Conducted:

Nove-ber 2 - 6, 1937

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Inspector #

H. I. Gregg, 5erfor R

oTEngineer

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E. J. Sullivan, Chief,' Inservice Testing

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Assessment Section

NRC Contract Personnel:

H. C. Rockhold,

EG'.G Idaho, Inc.

if.97rividy.2m

n/ vin

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, keactor Engineer

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Approved by:

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P. 46 pe ., Ch{ef,[pecial Test Prograts

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Section

Iny ection Su. mary:

Inspection on November 2-6 l937 (Co-bined Report Nos.

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50-277/37-32 ana 50-273/e7-32)

Areas Inspected:

Inspection of licensee's implementation of Inservice Testing

[ISTFactivitiestoassessadequacyandtoverifyadnerencetoregulatory

requirements and licensee cc mitments.

Inspection included organization

review, discussiens with cognizant personnel, review of documentation, test

witnessing, and observaticn of ccmponents.

8002030172 000

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PDR

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PDR

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Results: Two violations (improper document control and failure to implement

X$NE Code Section XI) were identified.

Severn1 other problem areas were

identified as unresolved items or weaknesses.

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CONTENTS

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reach Bottom 2 and 3 IST Inspection

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1.0 Sumary

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2,0 IST Inspection Purpose and Scope

3.0 Organ uation

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4.0 Plant Tour

5.0 IST Program Overview

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5.1

IST Program Comments

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6.0 Administrative Procedures for Surveillance Testing

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6.1 Procedure A-43, Rev. 19 Surveillance Testing System

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6.2 Procedure A-47 Rev. 8. Generation of Surveillance Tests 6.3 Procedure A-7, Rev. 23, Shift Operations

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7.0 Verification of Valve Test Schedule Adherence

8.0 Review of Test Procedures

8.1 HPSW Procedure ST 6.10-2 and 3

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8.2 ESW Procedure ST 6.3

8.3 HPCI Procedure ST 6.5, Rev 42

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8.4 HPCI Torus Suction Check Valve ST 6.58, Rev. 5

8.5 RHR Procedure ST 6.9F, Rev. 8

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9.0 Test Results

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9.1 HPSW ST 6.10-3

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9.2 Leak Testing for Containment Isolation Valves

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10.0 Review of Vendor Information

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11.0 Post Maintenance and Post Modification Testing

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12.0 High Pressure Service Water Pump Test Witnessing

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13.0 QA/QC Interface

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14.0 Unresolved Items

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15.0 Persons Contacted

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16.0 Reference Docurents

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17.0 Exit Meeting

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DETAILS

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1.0 Symmary

Table 1 provides a summary of the inspection findings.

TheJe include

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weaknesses in test procedures and test result acceptance criteria,

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several unresolved items and nonconformances witn 10 CFR 50 Appendix B

and ASME Section XI Code.

Notwithstanding these finding;. the licensees

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IdT program was assessed as adequate with no indications that safety

significant problems having occurred due to any of the IST program

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findings.

The licensee was receptive to correcting the concerns

identified by the NRC curing this inspection,

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During the inspection, specific problem findings were divided into the

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three following categories.

1)

Weakness - when the IST implementation was carried out but there was

some difficulty in determining details.

2)

Unresolved item - when the IST implementation was not in accordance

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with requirements but the issue requires further evaluation.

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Violation - when the IST implementation was not in accordance with

clear requirements.

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TABLE 1 - SUMMARY OF FINDINGS

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Preblem Tyyo and Designation

Description

Paragraph

Violations

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1.

50-277/87-32-01(a) and

Non conformance to 10 CFR 3.0

50-278/07-32-01(4)

50 Appendix B.

IST program

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maintained uncontrolled

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50-278/d7-32-01(b)

Non conformance to 10 CFR 9.1.1

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50 Appendix B and licensee's

procedure.

Failure to record

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information and signature

2.

50-277/87-32-02(a) and

Nonconformance to ASME Section

8.1.3

50-278/67-32/02(a)

XI pump action range

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requirements

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50-277/87-32-02(b) and

Nonconformance to ASME Section

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50-273/87-32-02(b)

XI purp bearing temperature

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requirements

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TABLE 1 - SUMMARY OF FINDINGS (Cont'd.)

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Problem Type and Designation

Description

Paragraph

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Onresolved Items

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1.

50-277/87-32-03 and

lack of procedural verification

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50-278/87-32-03

of check valve back flow

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50-277/87-32-04 and

Deficiency in sstisfying full

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50-278/87-32-04

stroke requirements

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3.

50-277/87-32-05 and

Lack of full flow / full stroke

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50-278/87-32-05

of torus suction cneck valve

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50-277/87-32-06 and

Contradictory Inoperability

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50-278/87-32-06

statement

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5.

50-277/87-32-07 and

Void in-lerkage rate and

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50-278/87-32-07

corrective action for containment

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isolation valves

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6.

50-277/87-32-08 and

Inability to full stroke

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50-278/87-32-03

testabla check valves

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50-277/87-32-09 and

HF3W pump packing problem

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50-278/87-32-09

and crosstie valve repair

Weaknesses

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Lack of Iden*.ification of

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valve position

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2.

Lack of capability to verify

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test schedule adherence by

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component

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Lack of specifying corrective

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a;tions and inoperability

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Confusion with dual stroke

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time limits

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Delay in correcting procedure

8.4.2

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Inability to verify proper post

9.1.2

maintenance test

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Limited QA/QC overview cf !$T

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2.0 IST Inspection Purpose and Scope

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This special team inspection was conducted to review and assess the

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licensee's Inservice Testing (IST) activities and to verify adherence to

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regulatory requirements and licensee's commitments.

The inspection effort

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included organization review, discussions with cognizant personnel, review

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of documentation, witnessing testing, and observations of components.

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3.0 Organizatig

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The IST program is a part of the Inservice Inspection (ISI) Program.

The

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licensee's Second ten year IST program for Pu'rps and Valves was developed

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by the Philadelphia Electric Ccmpany's maintenance division and submitted

to the NAC in 1984 through the licensee's licensing organization. Copies

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of this ten year IST program have been distributed to different Site

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organizations. However, these copies are not maintained as controlled

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documents.

Changes are made locsily by the users without formal review or

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approval.

Criterion VI of 10 CFR 50 Appendix B and the licensee's Quality

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assurance program require measures to assure that documents such as the

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IST program which affect quality, including changes, are reviewed for

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adequacy, approved for release by authorized personnel and distributed to

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and used at the location where the prescribed activity is performed. Not

having measures to establish and maintain the IST progran,as a controlled

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document is a violation.

At the time of this inspection, the licensee had

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just completed a corporate reorganization and the responsibility for

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establishing and maintaining the IST program was not clearly defined.

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effectiveness of maintaining the IST program as a controlled document

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under the new organization will be reviewed during a future NRC

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inspection,

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The primary responsibility for implementing the IST program for pumps &

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valves at the time of this inspection was with the project engineering

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group under the cognizance of the Technical Engineer. The Project Group

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IST Lead Engineer (a graduate engineer with five years of experience) has

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respcnsibility for the impitmentation of the program and reports to the

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Technical Engineer.

This individual has taken a special training program

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for ISI engineers, participates in Industry Conferences on IST,

and has

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also completed the licenste's technical Staff and management training

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including extensive plant system training.

This IST Lead Engineer is

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supported by a full time contractor employee with an asseciate degree and

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14 y)ars of industry experience. Both individuals were observeo to be

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knowledgeable in the ASME 5 action XI testing requirements and Nuclear

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System performance requirements.

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The valves in the IST program that have implications for Local Leak rate

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testing under 10 CFR 50 Appendix J are testea under the cognizance of

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engineers in the Perfarmance Section,

The pumps and valves under the

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licensee's Technical Specifications are tested by licensed operators under

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the cogaizance of operations engineers.

A detailed review of the test

program and, selected records, and test observations by the inspector

indicated that the personnel involved in the IST testing, conducted the

tests in a professional manner and were attentive to safety and procedural

requirements.

Findings

The implementation of the IST program is adequate as evidenced by the

level of knowledge of the lead engineers directly involved in the program.

However, management oversigh; of the program is required to assure

continued support to the IST program implementation unu ' the new site

organization and to maintain the IST program as a controlled document.

The licensee has adequate staff and management attention to tmplement the

IST program without any noticeable significant safety problems or back

log.

The effectiveness of the IST program implementation under the new

site organization will be reviewed during a future NRC inspection.

The licensee's failure to maintain the IST program as a controlled

document is a violation of 10 CFR 50 Appendix B document control requi*e-

ments.

(50-277/87-32-01(a) and 50-278/87-32-01(a)

4.0 P_lant Tour

The inspectors toured several areas, for the most part in Unit 3, and made

observations of safety related components that are in t.he IST program.

During the tour, component information was collected and specific observa-

tiens were made with the intent of reviewing the procedures, test results

and problems asseciated with some of these particular components, The

areas toured and some observed component information are described in the

following piragraphs.

"B" Core Spray Pump ~ Bingham,

Room - Elevation 91.6' in the Reector Building.

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Putp mas.ufacturer -

Pump discharge check valve - 12"-300#

Crane swing check No. 3-14-108.

WpCI Room - Elevation SS' in the Radwaste Butiding. HPCI pump

manuf acturer - Byron Jackson.

The booster pump 30P033 and high

pressure (HP) pump 30P038 tre coupled together.

The HP pump is

rated at 5000 gpm. Valves on the pump suction line observed at this

location were:

the 16" - 15C# Walworth motor operated gate u,1ve

No. 2 23R-17, the 16" - 150# Atwood and Morrill check valve

No. 3-23R-32, and the Crosby relief valve No. 30P33.

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RCIC Room - Elevation 88' in the Radwaste Building.

RCIC pump

manufacturer - Bingham.

The pump is rated 600 gpm.

HCU South Bank - Scram discharge valves in the reactor building at

elivation f35T.

The air acting valves 126 and 127 and the check

valves 114, 115 and 138 were observed.

SLC Pump Area - in the reactor building at elevation 195'.

The two

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SLC pumps, Ris. 3AP040 and 3BPO40 are positive displacement pumps

rated at 50 gpm and are manufactured by Union Pump Company.

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No. 14 squib valves, the two in series check valves Nos. 16 and 17

and the two relief valves were observed.

Some boren crystals we<.e

evident on the adjusting screw of the reliet valves.

Service Water Building, Unit 3

HP Service Water - The 4 model 13FXH Verti-line pumps are

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manufactured by Layne and Bower pump company and are rated at

4500 gpm at 700 ft. hydraulic head.

The inspector noted that

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two of these pumps were removed for repair and that thes e pumps

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would be goed candidates for further review during the

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inspection.

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ESW - There is a single pump (for each unit).

It is rated at

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5000 gpm at 96 ft. hydraulic head and is also manufactured by

Layne and Bower cump company and is a Verti-line model.

Firdings

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The areas toured were generally clean.

No violations were identified.

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5.0 !$T Program Oservies

Inforeation obtained during the inspectien regarding the licensee's IST

program submittal is outlined below.

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Licensee is implementing the second ten year interval program.

The se:end ten year interval start date is July 5,1934 for Unit 2

and December 12, 1984 for Unit 3.

The program cornits to A5ME Section XI, 1950 Edition through Winter

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1931 Adcenda.

The se:ord ten year interval program for both units was submitted to

NRC on 5/24/84.

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Revision 1 for both units was submitted to NRC on 6/28/84,

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The current program is being reviewed by NRR.

An SER has not been written for the second ten year interval program

(An SER dated 3/30/84 was issued fer the first ten year program.)

5.1

IST Program Comments

5.1.1

During the inspector's overview of the IST program the

inspector determined that the program does not indicate the

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position or positions required for safety-related functioning of

any of the valves. Therefore, it was not possible to co.vlude

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whether this has been identified for each valve and whether the

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procedures call for appropriate valve testing.

Findings

The lack of identification of the safety related valve position

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(open, closed, or both) in the program listing is considered a

weakness.

5.1.2

NRR has reviewed the licensee's 2nd ten year program and has

requested additional information (RAI) from the licensee. A

meeting between NRR and the licensee will be held when the RAI

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response is received.

Findings

1. The discussions of the forthcoming meeting between NRR and the

licensee will be beneficial in resolving IST issues.

6.0 Admintstrative Procedures for Surveillance Testing

Several of the licensee's administrative procedures pertaining to

surveillance testing were reviewed. At this plant the Inservice Testing

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(IST) is folded into the Technical Specification (TS) surveillance testing

activity.

Specific procedures reviewed and the inspector assessments are

described in the following paragraphs.

6.1 Procedure A-C. Dau

10 %rveillance Testing System

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This procedure defines the surveillance test program required by TS

and ASME Sect 4 q XI.

The inspector verified that responsibilities are defined for the

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administration, scheduling, performing, documenting, and reviewing the

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tests.

The inspector's review also verified there were provisions

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for cognizant supervisory engineering review of the completed tests,

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specific sign-off requirements, and further actions including shift

supervisory notification in the case of an unsatisfactory test.

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was noted that in the case of an unsatisfactory test a maintecance

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request form (MRF) must be initiated for corrective action.

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Accitionally, there is PORC overview, and disposition for testing that

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can't be performed prior to the test's grace period expiration.

6.2 Procedure A-47, Rev. 8, Generation of Surveillance Tests

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This procedure describes the responsibilities for writing, reviewing,

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and approving the surveillance test and outlines the content and

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format of the procedure.

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The inspector verified.that there are requirements for cognizant

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engineering review and approval, PORC review and approval and

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ultimately there is plant management approval.

The inspector also

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verified that thr. procedure contains appropriate notification of

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supervisory personnel for testing which can affect plant operations,

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requirements for test equipment are defined, and the procedure steps

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include requirements for acceptance criteria.

It was also noted that

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surveillance tests are controlled copy documents.

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6.3 Procedure A-7, Rev. 23, Shift Operations

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The inspection reviewed this procedure to verify there were shif t

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supervisor actions that correlated with provisions of Procedure A-43.

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The inspector verified that Procedure A-7 defines shift supervisor

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reporting requirements for comparent inoperability. The inspector

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also determined that shift supervisory action also included

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notification to higher level plant management.

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Findings

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The administrative proceduras discussed in the three above paragraphs

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were found to be acceptable.

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7.0 Verific_a_ tion of Valve Test Schedule Adherence

The inspector determined that the licensee's Surveillance Test (ST)

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program is basically a TS surveillance originated system and ASME Section

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XI Inservice Tests are folded into the ST program.

Control of the test

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schedule is performed by the plant ST Coordinator.

(the same person is

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the coordinator for 'Jnits 2 and 3).

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The inspector also determined that the ST program is system oriented and

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not component oriented. Most STs are for a specific system test

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(Example-ST 6.5, HPCI Pump, Valve, Flow and Unit Cooler Test) and includes

the tests for the pump and many valves in that specific system.

For a

small number of valves, there is a specific ST that applies to one

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specific valve (Example-ST 6.58, Torus Suction Check Valve). Also, some

STs are written for a monthly test as required by TS and a separate ST is

written for a quarterly test as required by IST.

In other cases the

monthly ST is used to satisfy both the TS and IST requirements.

Verification of test schedule adherence by component ccnnot be readily done

since the components are ';ithin the system oriented program.

To determine

when tests were performed the ST for that system has to be reviewed to see

what valves are included.

Then the results for the individual valves can

be extracted from the test data results.

The tracking system does not cross reference by component.

This could

lead to occasions where a component test is missed. The licensee's per-

sonnel do know their system oriented program and in the inspectors review

of ST 6.11 RCIC components and ST 6,5 HPCI components the IST schedule

adherence was met.

(The inspector noted that the ANII does maintain a

manual system to track component testing.)

Findings

Difficulty to verify test schedule adherence on a component basis is

considered a weakness.

8.0 Review of Test Procedures

A representative sample of surveillance test procedures were reviewed.

The review details and the inspector's findings and assessment of the

findings are discussed in the following paragraphs.

8.1 HPSW Procedure ST 6.10-2 and 3

8.1.1

This procedure requires that valve stroke times be recorded.

Limiting stroke times are specified for each valve.

If the

limiting stroke time for any valve is exceeded, the test results

are considered unsatisfactory and indicated as such on the ST

cover sheet. However, the ST does not specify the corrective

actions that should be taken or when the valve ,1us; be declared

inoperable in accordance with IWV-3417.

Findings

Lack of specifying corrective actions and declaration of

inoperability is considered a weakness.

8.1.2

ST 6.10-2 and 3 require the full stroke opening of the HPSW

discharge check valves 502 A, B, C, and D.

However, these

valves also have a safety-related function tc prevent back-flow

from the other pumps.

ST 6.10-2 and 3 do not contain any

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explicit provisions to verify that backflow through the pump

discharge valves will not occur.

Findings

Lack of procedural requirements to verify the check valve

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clocure capability is unresolved pending licensee's further

evaluation, procedural corrective actions, and NRC review of the

licensee's actions regarding this issue (50-277/87-32-03 and

50-278/87-32-03)

8.1.3

ST 6.10-3 contains criteria for pump parameters that are in the

acceptable, alert, and actions ranges.

This criteria is in the

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form of windows that perrr.it simultaneous plus or minus deviation

of pressure and flow from the reference values. However, the

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window developed by the licensee is not in conformance with the

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ASME Section XI Code.

IWP-3100 requires that the system

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resistance be varied until either the measured pressure or flow

rate equals the corresponding reference value. The ranges in

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table IWP-3100-2 are then applied to the other parameters.

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The licensee's method accepts alert and action ranges outside

the' code allowed limits.

Findings

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Non conformance to ASME Section XI code requirements is

considered a violation (50-277/87-32-02(a) and

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50/278/87-32-02(a)).

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8.2 ESW Procedure ST 6.3

The flow test under ST 6.3 is a partial flow test.

Exercising of the

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discharge check valves 515A and B is by ficw and the procedure re-

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quires that valve opening be verified by observing the balance arm

on the side of the check valve.

This test does not verify full

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stroke exercising of check valve 515 A and B as required by ASME

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Section XI, IW-3522.

In addition, the IST program listed in the

reference section of this report indicates that these two valves are

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mechanically exercised.

This is inconsistent with the exercising

under flew called for in the procedure.

Findings

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The deficiency in satisfying the ASME Section XI full stroke

requirement and the inconsistency between the licensee's program

commitment to mechanically full stroke and the procedure is

considered an ur. resolved item pending licensee's further evaluation

and corrective actions and NRCs review (Unresolved item

50-277/87-32-04 and 50-278/87-32-04).

_ __ _ _ - ___

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______

._ ___________ __ _ -_____-__

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8.3 HPCI procedure ST 6.5, Rev. 42

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8.3.1

Review of surveillance procedure ST-6.5, rev. 42, identified two

stroke time limits for valves MO-4(5)-245. A Technical

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Specification limit of 15 seconds and IST limit of 19 seconds

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indicated that the IST limit will never be a controlling value

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since exceeding the Technical Specification limit would require

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corrective action.

Identification of ar, IST limit higher than

the Technical Specification limit is inappropriate.

Findings

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Two stroke time limits for the same valve are confusing, this

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is considered a procedural weakness. The licensee acknowledged

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the inspector's concerns and committed to review and corrections

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relating to acceptance criteria in this and other procedures by

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March 31, 1988.

1

8.3.2-

This surveillance procedure also provides for the inservice

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testing of the HPCI pump and includes data pages to be filled

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out during the tests. ASME Section XI, IWP-3500(b) requires

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that when bearing temperatures are taken (annually), the

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"temperatures shall be considered stable when three successive

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readings taken at 10 minute intervals do not vary by more than

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4

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3 percent".

The data pages provided in the procedure do not

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specify this requirement or provide the space for recording

these minimum of 3 readings. Also, acceptance criteria for

,

bearing temperature is not specified.

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Findings

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Non adherence to ASME Section XI requirement is considered a

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violation (50-277/87-32-02(b) and 50-278/87-32-02(b)).

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8.4 HPCI Torus Svetion Check Valve ST 6.5 B, Rev. 5

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8.4.1

Review of surveillance procedure ST-6.58, rev. 5, which includes

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steps for exercising the HPCI pump suction check valve from the

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torus, VV-23-61, specifically states in step 14 that "full flow

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qa/ not be possible through MO-31", the flowpath established for

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axercising VV-23-61, indicating that a full-flow / full-stroke

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exercise of this check valve is not performed by this test.

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ASME Section XI, IWV-3522 requires full stroke exercising but

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the licensee's IST program does not include a relief request for

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not full-stroke exorcising this check valve.

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Findings

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This item is unresolved pending the licensee's evaluation, and

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forthcoming meeting with NRR, and NRC review of the licensee's

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disposition of this matter (50-277/87-32-05 and 50-278/87-32-05).

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8.4.2

During the inspector's review of the ST-6.5B, rev. 4, test

performed in March,1986, a note was made on the procedure that

,

step 11 included a typographical error by referencing valve

M0-23-21 twice rather than M0-23-21 once and MO-23-31 once.

This typographical error still exists in revision 57-

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Findings

The delay in correcting procedure is considered a weakness.

8.5 RHR Procedure ST 6.9F, Rev. S

Review of surveillance procedure ST-6.9F, rev. 8, data sheet

specifically states that exceeding the IST stroke time criteria does

,

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not result in a valve being inoperable.

This is contrary to ASME

Section XI, IWV-3417(b) which requires that corrective action be

initiated immediately, and if the condition is not or cannot be

!

corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared iroperative.

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Findings

a

This item is unresolved pending the licensee's review and corrections

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to this procedure (which the licensee stated was in process), and

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NRCs review of the licensee's corrective action (50-277/87-32-06 and

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50-278/87-32-06).

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9.0 Test Results

The inspector reviewed the actual test results of several of the ST

procedures discussed in paragraph 8.0..

Specific test results reviewed

and findings of the test results are described in the following

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paragraphs.

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9.1 HPSW ST 6.10-3

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9.1.1

The HPSW ST 6.10-3 test records from 6/19/87 and 7/17/87

indicated that the A pump differential pressure and flow from

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both of these tests were 255 psi and 4700 gpm. The A pump

reference differential pressure and flow values are 276 psi and

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4574 gpm.

The June and July test results fell in the alert

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range.

ST 6.10-3 requires that the Additional Action section of

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the test records cover sheet be filled out when toit results

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fall in the alert range.

The Additional Action section of the

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June and July ST 6.10-3 records were not filled in for the IST

in the Alert range.

(Also, the action section was not signed on

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the June 19, 1987 test record.)

It could not be verified

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through official records that corrective action had been taken

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as required by IWP-3230.

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_ _ _ _ _ _ _ _ _

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Findings

Absence of recording alert range information is considered a

violation of 10 CFR 50 Appendix B documentation requirement and

the licensee's procedure requirements (50-278/87-32-01(b)).

9.1.2

ST 6.10-3 was performed on 6/19/87.

The records indicated that

maintenance request forms (MRF) were submitted as a result of

this test.

The MRFs required repair of the 502 A and B dis-

charge check which had to be closed with an external stroking

arm for successful testing.

The closed out MRF for the 502 A

valve indicated that the valve was repaired and that post-main-

tenance testing was performed on 8/21/87 by pump start and stop.

The system engineer indicated that the post-maintenance test he

performed included full stroke opening and verification of disk

backseating. However, it could not be verified throuch official

records that the testing verified the proper functioning of the

valve in both the fully open and fully closed positions.

This

procedure is not appropriate for post maintenance testing as it

does not require backflow testing explicitly.

Findings

The inability to verify proper post maintenance valve functional

,

testing from the MRF is considered a weakness in record keeping.

Improved procedure requirement would be useful in resolving this type

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problem.

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9.2 Leak Testing for Containment Isolation Valves

The inspector reviewed the leak rate testing records for containment

isolation valves at penetration N-9A, N-214, and 52F.

These records

appeared to indicate that the requirements of Section XI, IWV-3426

and 3427, for the establishment of leak rate and trending criteria

and corrective action, are not met.

The SER for the first ten year

interval inservice testing program specifically denied relief from

these Code requirements.

This apparent violation of Section XI was

discussed with a licensee representative who stated that criteria do

exist.

However, the criteria could not be located before the inspec-

tion exit meeting.

Findings

This item is unresolved pending further information from the

licensee. The licensee has stated that the LLRT program was in

process of being changed which will require further NRC review.

(50-277/87-32-07 and 50-278/87-32-07)

10.0 Review of Vendor Information

The inspector reviewed the vendor instruction manuals, valve detail

drawings, and purchase specifications of the testable check valves

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manufactured by Atwood & Morrill and Rockwell. These check valves

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are utilized in the injection flowpaths for core spray, RHR, HPCI, and

,

RCIC system.

The IST program identifies these valves as being full-stroke

,

exercised by utilizing the test operator on the valve.

The Atwood &

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Morrill design does appear to perform a full-stroke of the valve disk,

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however, the Rockwell design appears to only stroke the valve 30 degr -

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cf disk swing. This does not satisfy the full-stroke requirement of

Section XI, IWV-3522(b) for the testable check valves of the Rockwell

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design (core spray injection checks).

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Findings

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This item is unresolved pending the licensee's evaluation and disposition

and NRC's review of the licensee, action (50-277/87-32-08 and

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50-278/98-32-08).

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11.0 post Maintenance and Post Modification Testing

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The inspector reviewed the documentation concerning the post modification

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testing that was performed as a result of Modification #1117. Replacement

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of Main Steam Drain Valves M074 & 77.

The inspector determined that the

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new valves and associated piping welds received an operational hydrostatic

test and that seat leakage tests were satisfactorily completed prior to

,

startup per ST 20.029 for Unit 2 and ST 30.029 for Unit 3.

The licensee's

modification acceptance test documents recorded these satisfactory results

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which provided a final turnover of the modification to operations.

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Findings

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The inspector considered this post modification testing to be acceptable.

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12.0 High pressure Service Water (HPSW) Pump Test Witnessing

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Due to the inspector's plant tour observation that two of these pumps were

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out for repair a HPSW pump test (ST 6.10-3) was requested and was

!

4

performed. The test was witnessed by the inspector.

The test was

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performed from the control room and prior to its start the instrument

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accuracy was verified to meet ASME Section XI, IWP-4110.

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The test of pump 3C was started and early in the procedure (at step 8),

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the pump could not provide the required flow of 4500 gpm.

Step 8 requires

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a discharge minimum flow of 4500 gpm and a minimum discharge pressure of

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233 psig.

The discharge pressure was 235 but the flow was only 4400-4450

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gpm and the test was stopped as unsatisfactory.

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Prior to stopping the pump, AC to BC header crosstie valve (MO-3344)

leakage was indicated by control room indication of flow through the "3B"

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RHR heat exchanger. Also, prior to stopping the pump the inspector went

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to the service water building to observe the running pump.

Service water

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was spraying f,'om the packing box of this recently repaired pump.

The

cognizant engineer said the prior leakage was far worse. The inspector

also observed some leakage at the "30" pump packing gland, which indicated

that the motor operated crosstie valve M0-3344 and the "30" pump discharge

check valve were leaking through.

However, the pressure gage between the

crosstie valve and the "30" discharge check valve did not indicate

pressure.

Because of the unsatisfactory test MRF 8709754 was written to determine

the problem cause and corrective action.

The inspector determined that

the M0-3344 leakage had not been quantified previously.

The control room

operator was aware of this valve leakage by his acknowledgement that

MO-3344 was a known "leaker". MRF 8407631 was originated on Dec mber 9,

1984, to effect repairs on MO-3344 but this could not be accomplished

unwil the core was offloaded.

The inspector noted that under the current

plant conditions with the 3A and 3C pumps out of service a safety concern

might be present if the core were loaded and the MO-3344 leakage was

significant to cause flow through the operational RHR heat exchanger to be

less than the required 4500 gpm. A retest of the 3C pump was accomplished

later in the day to resolve MRF 8709754 and this retest confirmed that the

problem was due to valve leakage and wasn't a 3C pump deficiency. Also,

it quantified the MO-3344 leakage to be 250 gpm.

This test was performed

by temporarily closing several normally open valves to the 3B and 30 RHR

heat exchangers and also closing the 3D pump discharge valve. With this

temporary valve alignment 3C pump flow and AP were determined to be 4700

gpm and 270 psi, respectively.

Findings

There appears to be a generic packing problem associated with these pumps

that requires correction and the licensee is actively involved in

developing a packing fix.

While the crosstie valve is not an IST valve,

it does affect the IST system and component performance and testing,

therefore, this valve requires repair.

The licensee (plant manager)

committed to repair MO-3344 at the exit meeting while the core is off-

loaded prior to restart.

This item is unresolved pending licensee's

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actions on the packing problem and the crosstie valve repair.

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(50-277/87-32-09 and 50-278/87-32-09).

13.0 QA/QC Interface

The inspector reviewed QA Audit No. AP 86-106 IST of December 10, 1986,

titled PBAPS ISI Program.

Audit No. AP 86-106 ISI, was primarily an ISI audit which combined

functional testing, NDE and visual inspection.

_

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16

.

The inspector's review of this audit focused on IST related findings.

It was noted by the inspector that out of the 19 acceptable findings

only the first two related to IST program implementation.

These

findings were primarily general administrative overview.

There were

three unacceptable findings and these were also administrative in

nature and related to qualification of visual inspection examiners,

maintenance personnel qualification and NDE work experience

certification.

The audit did not contain any findings related to techr.ical issues of

completed tests or any concerns of procedure acceptance criteria, or

not meeting ASME Section XI criteria that were identified during this

inspection.

In discussions with cognizant QA personnel, the

inspector also determined there was no consideration given to the IST

program being a controlled document that was also identified during

this inspection.

'

The inspector discussed the conduct of the audit with the lead

auditor and determined that his technical strengths were in NDE and

that another auditor from the corporate office performed the audit of

,

the IST activities. Although this auditor had operational

experience, it was gained at the licensee's fossil plants.

The

audits were not detailed enough to assess the effectiveness of the

IST program and did not appear to have the IST expertise to determine

adherence to ASME Section XI requirements.

Also the inspector discussed with the Site QC Supervisor the extent

of QC involvement in IST activities.

The QC organization performs

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<

Surveillances of various site activities in the form of detailed

,"

monitoring checklists (DMCs).

These DMCs provide a list of

attributes / check items against which the QC inspector verifies

compliance. DMC 1.1, 1.2 and 1.4 involve local leak rate testing of

3

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valves which are in the IST program.

However, November, 1985, was

the last time for the performance for any of these DMCs.

This

'

)

indicates that the licensee allocated its QC Surveillance Manpower to

activities other than IST.

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Findings

QA overview of IST is limited and is considered a weakness.

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14.0 Unresolved _ Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations or

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deviations. Unresolved item are discussed in paragraphs 8.1.2, 8.2,

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8.4.1, 8.5, 9.2, 10.0, and 12.0 of this report.

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15.0 Persons Contacted

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Peach Bottom Atomic Power Station (PBAPS)

A. Cipola, Project Group Engineer

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• J. Cotton, Superintendent Operations

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• A. Fulvio, Technical Engineer

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M. Kelly, Project Group IST Lead Engineer

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• J. McElwain, QC Supervisor

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• 0. Smith, Plant Manager

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• J. Rovansek, QA Engineer

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R. Turner, ISI Maintenance

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0. Wheeler, Project Group Leader

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• J. Wilson, QA Supervisor

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R. Wright, Systems Group Engineer

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United States Nuclear Regulatory Commission (USNRC)

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• T. Johnson, Senior Resident Inspector

• L. liyers, Resident Inspector

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• R. Urban, Resident Inspector

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• Denotes those present at exit meeting

16.0 Reference Documents

]

The documents used to assess the licensee's adherence to IST requirements.

,

included:

,

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10 CFR 50.55 a(g) Inservice Inspection Requirements

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10 CFR 50 Appendix B Quality Assurance Criteria

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ASME Code Section XI IST Subsections IWP and IWV, 1980 Edition

i

through Winter 1981 Addenda

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Peach Bottom 2 and 3 Second Ten Year Interval IST Submittal, 6/28/84

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Request for Additional Information and IST Review Meeting, 10/22/87

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letter from R. E. Martin (NRC) to E. Bauer (PECO).

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Safety Evaluation Report dated March 30, 1984 on Peach Bottom 2 and 3

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First Ten Year Interval IST Program

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I&E Manual Inspection Procedure 73756, Inservice Inspection of Pumps

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and Valves 3/16/87

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-- . . l

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18

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Licensee's Administrative Procedures

A-43, Rev. 19, Surveillance Testing Systems, 5/28/87

A-47, Rev. 8, Procedure for Generation of Surveillance Tests, 5/28/87

A-7, Rev. 23, Shift Operations, 4/10/87

Licensee's Surveillance Test (ST) Procedures

ST-6.3 (Rev.13), Emergency Service Water Pump, Valve, Flow Cooler,

7/7/87.

ST 6.10-2 (Rev. 7) of 2/12/87 and 6.10-3 (Rev. 9) of 1/14/87 High

Pressure Service Water Pump and Valve Operability and Flow Rate Test

ST-6.5 (Rev. 42), HPCI Pump, Valve, Flow, Cooler, 2/27/87

ST-6.58 (Rev. 5), HPCI Torus Section Check Valve Operability, 3/6/87

ST-6.9F (Rev. 8), RHR 8 Pump, Valve, Flow and Unit Cooler Functional

Flow Test, 4/16/87

ST-6.18 (Rev. 5), ISI Normally Closed Valve Testing, 3/20/87

ST-6.11, (Rev. 31), RCIC Pump, Valve, Flow, Cooler, 2/6/87

Licensee's Test Records

ST 6.10-3 Records dated 2/20/87, 2/5/87, 3/21/87, 4/20/87, 5/22/87,

S/19/87, 7/17/87, 8/22/87, and 10/17/87.

Licensee's Piping and Instrument Drawing, P& ids M-315, M-361 and

M-362

Licensee's Maintenance Request Forms 8704749, 8704750, and 8705361

Vender Information

Technical Manual for Emergency Service Water Pumps.

Rockwell Manufacturing Co. drawing PD-420657 for tilting disk check

valves and the associated vendor instruction manuals.

Atwood and Morrill testable check valve information.

Licensee's QA Audits AP 86-106 151, 12/10/86 and AP 86-109, 12/8/86

_ ________.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _

.

19

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17.0 Exit Meeting

TFs inspector met with the licensee's representative (identified in

paragraph 15.0) at the conclusion of the inspection on November 6, 1987,

to summarize the findings of this inspection.

The NRC Resident

Inspectors, were also in attendance.

During this inspection, the inspector did not provide any written material

to the licensee,

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