ML20133B534

Responds to NRC Re Violations Noted in Safety Insp Repts 50-315/84-13 & 50-316/84-15.Corrective Actions: Tech Spec 4.7.1.2 Will Be Changed to Clarify Discharge Pressure of 1,285 Psig

ML20133B534
Person / Time
Site:	Cook
Issue date:	11/29/1984
From:	Hering R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20133B528	List: IR 05000315/1984013 ML20133B529 ML20133B534 ML20133B542
References
AEP:NRC:0906, NUDOCS 8508060201
Download: ML20133B534 (9)

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INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 November 29, 1984 AEP:NRC:0906 Donald C. Cook Nuclear Plant Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 NRC REPORT NOS. 50-315/84-13 (DRS); 50-316/84-15 (DRS)

Mr. James G. Keppler U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

This letter responds to Mr. R. L. Spessard's letter dated October 12, 1984 which forwarded the subject Inspection Report of the routine safety inspection conducted by your staff at the Donald C. Cook Nuclear Plant during the period July 9,1984 through September 19, 1984 As confirmed with Mr. L. Reyes on November 14, 1984, an extension to November 29, 1984 was granted for our response to the inspection report. The notice of violation attached to Mr. Spessard's letter identified three items of noncompliance. Item 2 has been satisfactorily resolved, as-indicated in the report. Additionally, four unresolved items requiring a response were identified. Our responses are as follows:

ITEM OF NONCOMPLTANCE - 1 Technical Specification 4.7.1.2 for both Units 1 and 2 requires the turbine driven auxiliary feedwater pumps to develop a discharge pressure of greater than or equal to 1285 psig at 700 gpm or greater.

Contrary to the above, surveillance test procedures for testing the pumps allowed acceptance of the tests at lower discharge pressures than 1285 psig and test results were accepted that did not meet the Technical Specification requirements.

RESPONSE TO THE ITEM - 1 We disagree with the classification of this item as an item of noncompliance. However, to minimize the possibility of misinterpretation, we will pursue a technical specification chagge, which will clarify that the discharge pressure of 1285 psig is at 60 F. This clarification would indicate that the surveillance test procedures are consistent with the Technical Specification.

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Mr. James G. Keppler AEP:HRC:0906 The basis of the Technical Specification requirement for the TDAFP (T.S. 4.7.1.2.a.2.b; "The steam turbine driven pump develops a discharge pressure of 2; 1285 psig at a flow of 2; 700 gpm when the secondary steam pressure is greater than 310 psig.") was developed by degrading the manufacturer's pump performance curve by five percent. This degraded differential head, in feet, was used in calculating ghe discharge pressure, in psi, based on the specific gravity of water at 60 F. The current plant procedure adjusts the Technical Specification discharge pressure requirement of 1285 psig for temperature by establishing a minimum discharge pressure associated with the actual condensate temperature. This density adjustment allows a true comparison of pump performance (discharge pressure) to the baseline / standard that was used to establish the Technical Specification.

A review of past (i.e., last two years) performance data was made.

The maximum adjustment, due to temperature, was found to be 6 psi; the actual discharge pressure recorded in this test was 40 psi above the Technical Specification value.

In essence, the plant procedure provides adjustments for the 1285 psis specified in the Technical Specifications. Specifically, pressures, equivalent to water at 1285 psig and 60 F, are provided for various other water temperatures. These equivalent pressures are therefore readily available for comparison to the discharge pressure at the actual temperature that may be realized at the time of the test.

As discussed with Region III staff, a letter (AEP:NRC:0906A, dated November 28, 1984) was sent to NRR. The letter requests an interpretation as to whether or not our plant procedures properly implement the Technical Specification.

The NRC inspector noted that the plant requirements for heat removal were not taken into account in the licensee's justification of lowered pump discharge pressures and that discharge pressures lower than the Technical specification limit had been accepted in previous pump tests. Our response to this concern is summarized below:

The hydraulic analyses for the auxiliary feedwater ( AFW) system were performed based on supplying auxiliary feedwater at standard conditions (60 F). We have reviewed the temperatures experienced during the monthly surveillance test for the AFW pumps with respect to the density adjustments. Our review indicates that the adjusted discharge pressure for these tests are within the bounds of the hydraulic analyses and the Technical Specification limit.

In addition, we have reanalyzed the AFW system at a temperature of 120 F (value used in the safety analysis). Using a temperature of 120 F has a minimal effect on the hydraulic analyses resulting in a less than one percent deviation to the required flow rate. These results are well within the calculational accuracy of fluid hydraulic analysis.

Mr. James .G. Keppler AEP:NRC:0906 i Therefore,- the effect of a -temperature (density) correction has a minimal _ impact _ on the hydraulic analyses and is acceptable for use in determination of pump discharge pressure during surveillance testing.- ,

ITEM OF NONCCMPI.TANCE - 1

. Appendix B of 10 CFR 50, criterion IVI, and Subsection IWV of the ASME Boiler: and Pressure Vessel Code,Section II require the identification of

' conditions adverse to quality .and appropriate corrective action.

Contrary to this:

a..  ! Limiting values for valve stroke times were selected that would not meet the intent of the Code in identifying serious valve degradation

or in requiring corrective action to assure valve operational

' readiness. ,

b' . Documentation, analysis and evaluation of surveillance test results and ' corrective action was inadequate to determine if conditions adverse to quality existed other than for individual valve failures.

c. ~ Specific corrective action requirements for increased power operated valve stroke times or for-increased valve leak rates according to IWV c of the code were not followed.

.. RESPONSE TO ITEM 9.a 1

'We disagree with the classification of this item as an example of a noncompliance.

We 'believe that the demonstration of valve stroke time based on both the system response time and valve performance capability would be an enhancement. Therefore, the allowable stroke times for each valve will be evaluated on the basis _ of both system response times and valve performance e capability. The IST Valve Program for the second ten-year interval will be  !

revised to ' incorporate this enhancement. _ The Yalve Program for the second ten-year inspection interval is currently scheduled for submission in January, 1986 and implementation in July, 1986.

The NRC-inspection report, section 6 stated, in part, " Subsection IWY-2130 [IWV-2140] of section II defines exercising as 'the demonstration

based on direct or indirect visual or other positive indication that moving parts of a valve function' satisfactorily;' IWV-3410 states that the

' limiting value of full stroke time'-is one of the criteria for test acceptance. Consequently,-stroke time limits for a given valve must be chosen such that achieving ~this value would indicate the satisfactory physical condition of the valve. System response times used by the ,

licensee are not adequate for this ' purpose. Test records show that both motor and air-operated valves with observed stroke times of less than ten seconds and two seconds, respectively, have been assigned maximum stroke times of 120 seconds. These stroke times are well beyond those representative of satisfactory valve condition and hence, fail to meet the ,

code. requirement noted 'above."

_ . - _ . _ . _ _ _ . _ ~ . - _ _ . . - . _ . _ . . _ . - _ , _ _ . . _ _ _ . _ _ , _ . _ _ _ _ ,

Mr. James G. Keppler AEP:NRC:0906

.The above scenario appears to.be properly concerned with the

" demonstration ... that ... a valve function [s] satisfactorily". We believe the NRC Region III position, that system response times are not adequate for this satisfactory valve demonstration is .not supported by ASME Section II. Section II does not provide specific criteria and/or guidance for the selection of the limiting value of the full stroke time. Since the Code states that the limiting value of the full stroke time shall be specified by the owner, we have delineated criteria for each power operated valve. The delineated criteria are the system response times.

Demonstration.that valves meet the system response times assures that the valves will perform their safety function. Given no further specific criteria and/or guidance by Section II, we have met the requirement of the Code.

Furthermore, since the ability of valves to perform their safety function is adequately demonstrated with system response times, a condition adverse to quality does not exist. Therefore, we believe a violation of 10 CFR 50, Appendix B, Criterion IVI was not committed.

RESPONSE TO ITEM Lb

1. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED As an interim measure, effective November 19, 1984, identified valve failures are being documented in accordance with the Plant condition report procedure. The condition reports will be evaluated to determine the cause of the failure. Similar valves, which would be susoeptible to the cause, will then be assesced to assure that a similar valve failure is not pending.

Tentatively, " valve failure" has been defined as any valve which (1) will not meet the requirements of the maximum allowable stroke times as specified in the IST valve program or (2) will not perform any other required safety function -(such as maintaining the reactor coolant boundary). This definition is currently under review. We currently have not identified any valves that would be described as valve failures by this definition.

2. CORRRcTIVE ACTION TO BE TarRM TO AVOID FURTHER NONC MPLTANCE A procedure will be written to address how valve failures will be documented and evaluated. An assessment of our valve program will be completed by February 15, 1985 to determine what modifications are necessary to adequately address failure rate and trending activities.

3 DATE WHRM FULL CMPLTANCE WTI.T. BE ACHIEVED Full compliance will be achieved on February 15, 1985 when the interim measure described above are proceduralized and the valve program assessment is complete.

Mr. James G. Keppler AEP:NRC:0906

( RESPONSE TO IfEM '4.C

1. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The bases for this ites were identified in the Inspection Report

, (84-13; 84-15), section 8.b (pages 7 and 8) as three issues related to the plant corrective action program for valves: The program (1) would allow valve degradation to continue without increased surveillance or corrective action; (2) does not address corrective action for infrequently operated valves with increased stroke times; and (3) does not provide for analyzing increased leakage of tested valves or for corrective action which would restore the valves.

In response to issue =(1) we have revised our method of documenting increased frequency. A Valve Increased Frequency Log has been generated to keep track of all valves on increased frequency along with the test dates, times and surveillance procedures (STPs).

Also, all valves which are placed on this log are included in the QC

Weekly Report which is distributed for review to the appropriate people. This new method of recording ard reporting increased frequency will be incorporated in the revision of the ISI procedure.

In response to issue (2), the current procedure for increased frequency will be modified to address infrequently stroked valves.

Each failure of a valve in this category will be evaluated on an individual basis, for the appropriate course of action.

In response to issue (3) it is the D. C. Cook Plant's policy to take corrective actions on recurring problems. This requirement is set

. forth both in PMI-7030, " Condition Reports", and the D. C. Cook Policy Statement.

. Appendix J valves are not reviewed to criteria contained in IWV-3420(0) of the ASME Code. We have, accordingly, requested an exemption in our ISI program to exclude valves which are in the Appendix J program from the review requirements of ASIE Section II.

l Periodic reports are generated as a result of complying with 10 CFR 50 i

! . Appendix J.

We believe that although we do not review Appendix J l- valves to ASME Section II criteria, we nonetheless have an effective l

program to correct deficiencies through existing Plant Manager Instructions and 10 CFR 50 Appendix J requirements.

- 2. CORRECTIVE ACTION TO BE TAKEN TO AVOID FDRTIER MORCGtPLIAMCE >

An audit of PMI-5070 (Inservice Inspection) is presently scheduled for April, 1985. The scope of the audit will be expanded to encompass the commitments contained in the response to this item of noncompliance.

3 DATE WHEN FULL CGtPLIANCE WILL BE ACHIEVED Full compliance will be achieved by February 15, 1985, when our

procedure is revised to address infrequently stroked valves. j i

__~ _ _ _ _ _ . _ _ _ _ ___ _ _._._._ __.___ _ __

i Mr. James G. Keppler AEP:NRC:0906 l l

j numannt.YED ITEM - 915/84-11-09(DRS): 916/84-15-09(DRS)

Discussions with the licensee indicated that currently there is no test procedure which adequately demonstrates the capability of the TDAFP to respond at a given flow within the response time stated in Technical Specification 4.3.2.1 3, Table 3.3-5, upon receipt of an ESF actuation signal.' The licensee is reviewing the surveillance procedures and will revise the procedure as necessary to provide assurance that the TDAFP can perform its safety function.

RESPONSE TO THE UNRESCLYED ITEM A review of Procedure THP-4030.STP.205, for both Units 1 and 2 and Trains A and B, was completed and found that time response from sensor actuation to component actuation only included those times up to the i opening of the turbine trip and throttle valve (TDTV). Because the  !

Technical Specifications, as written, do not specify a miniania pump discharge pressure and corresponding flow for pump response timing (as is j the case with the SI, RHR and CC pumps, reference Table 3 3-5, Table i Notation), this additional ites for the turbine driven auxiliary feedwater

pump to come to pressure was not added into the overall time response.

Because it is agreed the discharge pressure and flow are highly dependent j on speed, which in the case of the turbine driven auxiliary feedwater pump l is highly dependent on the performance of the TDTV valve, this requirement for timing will be added as an enhancement to plant procedure (s). This enhancement will be completed prior to the next scheduled use of the procedure (s).

{'- HuntMnrVED ITEM - 115/84-19-07(DRS): 916/84-15-07(DRS)

Subsection IWV-3300 states that "All valves with remote position  !

! indicators, which during plant operation are inaccessible for direct j observation, shall be visually observed. . . to confirm that remote valve indications accurately reflect valve operation." In addition, ASIE Code l interpretation II-1-79-18 states "It is the intent of Section II. . . ta i require that all valves, accessible and inaccessible, that have remote

valve indicators be visually checked. . . to verify that remote valve j indications accurately reflect valve operation." The licensee stated that remote valve indications are checked for inaccessible valves only, and that

they were unaware of the code interpretation. The inspector also noted l that stroke timing of valves is generally performed by observing the light

indicators in the control room which may not indicate actual valve sten j movement. The licensee agreed to review the valve stroke test procedures ,

and revise them as necessary.

i The inspector also reviewed Surveillance Test Procedure 1-OHP-4030.STP.034, i l " Local Valve Position Verification Test," Revision 4, and questioned its  ;

i suitability for the purpose intended. It does not require timing the valve j stroke, measuring stroke distance, verifying proper limit switch setting, l relating actual stroke time to timing by position lights, etc. The ,

licensee agreed to re-evaluate the adequacy of the procedure.

i i

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Mr. James G. Keppler AEP:NRC:0906 RESPONSE TO THE UNRESOLVED ITEM We are in literal compliance with the present Code requirement. We realize that future Code versions will include interpretation 11-01-79-18 and will become requirements. The future Code versions would then require observation of local valve positions. Therefore, we will revise our procedures to be consistent with the future Code by the end of the 1985 Unit 2 refueling outage.

Our assessment of Procedure 1-OHP-4030.STP.034, Revision 4, and other plant procedures concluded that the procedures adequately incorporate the requirements of the Code. Plant procedures, other than STP.034, properly specify the requirements to set up a valve after maintenance activities.

The intent of the Code appears to be confirmation of stem movement and physical condition of the valve, not a requirement to reconfirm all valve parameters.

nuntAtuYED ITEM - 115/84-19-10 (DRSi r 916/84-15-10(nas)

Closure testing is required for valves that protect low pressure piping and vessels from reactor coolant system pressure. The licensee agreed to review its valve test program to assure compliance with this requirement.

The inspector also determined that the rotameters, IFI-305 and IFI-306, used in the leak testing of some of the pressure isolation valves are a type that can give a false, sero leakage reading if not used with caution. The licensee agreed to assure that the test flow meter was used

.in a manner that did not give falso readings or to review previous test data and take the necessary action to assure that a high leak rate was not overlooked.

RESPONSE TO THE UMBESM.VED ITEM Testing of the pressure isolation valves to assure protection of low-pressure piping has been incorporated in our current IST Valve Program as submitted via AEP:NRC:730C dated october 2, 1984. This will be incorporated into the formal IST Program by January 1986.

While on site the inspector discussed with D. C. Cock Plant personnel the possibility that rotameters, used for high to low pressure interface valve leak testing, may at times erroneously indicate zero leakage due to slippage between the metal ring flow indicator and the magnet floating in the fluid stream.

Although not previously apprised of this condition, we will incorporate a precaution into the appropriate test procedures to insure the rotameters are valved into service with proper caution. This precaution will be incorporated into the procedure before its next scheduled use.

In addition, previous high to low pressure interface valve test data were reviewed to identify if any falso readings of the nature described above could have occurred. The results of this review showed several l

b

Mr. James G. Keppler ARP:NRC:0906 instances of zero indicated leak rates. The previous and subsequent leak l rate of the valves showing zero leak rate measurements data preceding and/or following the sero leak rate measurements were well within the i allowable leak rates. It was determined that because no adverse trends were noted either before or after the sero indicated leakage, there was evidence to indicate the zero leakage rates were correct.

In summary, precautions will be added to applicable test procedures to ,

insure the proper use of magnetic rotameters before their next scheduled j use. A review of the past test data of high to low pressure interface valve testing indicated that no high leak rates were obscured by erroneous, sero leak indications on the rotameters.

Uusumnt YED ITElf - 115/84-11-11(nsA); 116/84 15-11(nsM) ,

L The inspector reviewed testing of the containment roeirculation sump j suction line isolation valves to assure that the test technique would not allow air in the suction lines. The inspector determined that the lines  !

were inadvertently being filled by the test procedure and that no positive means are presently in use to assure filling. Inadvertent filling of these lines is unacceptable.  ;

F RESPONSI TO TER UNRESQLVED ITEM An analysis was performed which verified that a hypothetical air pocket, located between the recirculation sump isolation valves and the Residual Heat Removal - Containment Spray line too, would have sufficient i time to bleed out during the switchover from the injection phase to the {

recirculation phase. Therefore, additional means to assure that these ,

lines are filled during inservice testing is not necessary.

This document has been prepared following Corporate procedures which i incorporate a reasonable set of controls to insure its accuracy and i completeness prior to signature by the undersigned.

Very truly yours, (DO R. F. Hering Vice President .

MPA/ou l oor John E. Dolan  ;

M. P. Alexich W. G. Smith, Jr. - Bridgman R. C. Callen  ;

G. Charnoff i NRC Resident Inspector - Bridgman -

George Bruchmann l

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