ML052100414

CR Summary Report

ML052100414
Person / Time
Site:	Millstone
Issue date:	12/21/2004
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2005-0208, IR-04-007 CR-04-09086
Download: ML052100414 (3)

Text

MILLSTONE 860 443 5893 P.1?

VkEC-d1-.20014 14:49 CR Summary Report Tuesday, December 21, 2004 Page 1 of 3 CR number: CR-04-09086 AR number: 04005976 Sig: N Date: 1210612004 Investigator: Eric Bookmiller x 0519 Department: MGRSITEENG Problem Statement: During a recent NRC inspection an unresolved Item (URI) is being opened on Main Steam Code Safety Volvo Testing at Millstone on Unit 2.

Event: NRC INSPECTION Investigation: An unresolved item (URI) is being opened to determine how Information supplied by Appendix B certified vendors is reviewed, If Dominion can trace the M&TE equipment to a national standard and whether it is acceptable to teat main steam code safeties with the test apparatus following an actual lift of the relief valve. (URI 0500033612004007- 05).

Millstone Unit 2 main steam code safety valve TS surveillance testIng is implemented In part by SP-2730B, Main Steam Code Safety Valve Test. The Inspectors questioned the following based on a review of the surveillance procedure and supporting documentation:

AX Issue 1:

A / \ >- The surveillance procedure contained a conversion factor for the main steam code safety valves etat was developed by a 10 CFR Appendix 6 qualified vendor, however, the developmental data was not available for NRC Inspection and had not been independently reviewed by Dominion.

AdditIonally, the conversion factor does not indicate tolerances such as testing assurance, variation or error related to the development of the conversion factor and the surveillance did not address testing assurance, variation or error related to the measurement and test equipment (MT&E).

M \ ~N Millstone Power Station did not validate the vendors methodology for the determination of the Valve

(-' sConstant K. The OK" value is used in the determination of the MSSV set pressure when using the

~\/ Adz Hydroset,

i. V\ Discussion Both Millstone Unit 2 and 3 have Dresser (Consolidated) base model number 3707R MSSVs. Both t Aunits MSSVs have R orifices end use the same disc. Both units use the Dresser 1566-2 Hydroset XvTesting Devices for MSSV set pressure confirmation. The Hydroset is used to confirm the cst pressure of the MSSVs to meet Technical Specification and IST program requirements.

The original WKvalue was identified as being incorrect in Dresser 10CFR Part 21 File 90a-1.

Millstone Power Station addressed this Part 21T).nder Control Routing 7887. At that time Millstone Power Station revised the applicable procedures to Incorporate the new OK" value (Millstone Unit 2 was shutdown at the time of the Part 21 and identified e number MSSVs that were out of tolerance.

These MSSV were reset using the now "K value).

During recovery the NRC questtoned MIllstone Unit 3 as to the assist device only providing a representation of simmering on the valve, and not actually the set pressure. Millstone Unit 3 responded to this Issue by performing set pressure confirmation testing using a MSSV that was at Wyle Labs. The set pressure testing consisted of testing the valve on a test stand using a limited travel steam lift set pressure method (standard method for determining set pressure post valve overhaul and permit by the code). then performed set pressure confirmation using a Hydroset and then performed additional limited travel steam lift set pressure method to confirm set pressure.

This testing Is documented in Technical Evaluation M3-EV.408- 83 Reyv . The Technical Evaluation concluded that use of h H aeTdid provideaccurate set pressure results.

Based on the above information Millstone Power Station does not believe there Is any need to validateaverify the vendors methodology for the determining the Valve Constant WK(conversion factor). The new Valve Constant K'. was provided to MIllstone Power Station as part of the vendors Appendix B program. MIllstone Power Stations also has in house operational experience, that shows the use of the Hydroset to confirm MSSV set pressure provides an accurate method of determining set pressure of MSSVs. The IST code requires testing M&TE have an overall 3

DEC-21-2004 14:49 MILLSTONE 862 443 5893 P.18

. . I CR Summary Report Page 2 of 3 Tuesday, December 21. 2004 combined accuracy of +2% to -1% as documented In section 2.3 of Millstone procedure SP 2730B Issue 2:

There was no indication In the Dominion surveillance that the M&TE used during the implementation of the surveillance was calibrated and traceable to a National Bureau of Standards (NIST) standard.

All of the M&TE used for MSSV set pressure testing and calibrated at the Millstone Metrology Laboratory shop is traceable to NIST. For equipment or M&TE that Is not calibrated on site the requirements for calibratlon traceable to NIST Is invoked by the QA purchase order, Issue 3:

The vendor technical manual that was related to the M&TE used in the Millstone Unit 2 surveillance Indicated that the M&TE is to be used only for confirming valve set pressure once the valve has been set by the use of full system over pressure ('full lift!) testing. Dominion documentation indicates that the M&TE was used on several main steam code safety valves following full valve lifts that resulted from plant transients.

Discussion The above issue is based on the following statement in VTM 25203-190-006A introduction section.

It is recommended that the 1566 Hydroset be used only for confirning valve set pressure once the valves have been adjusted by the use of full steam overpressure! Millstone personnel reviewed this statement and the second part of the paragraph where this statement Is made. The second section of this paragraph states. 'Initial settings with the Hydroset Is not recommended If the capability exdsts in the system to overpressure end adjust the safety valves.

Millstone personnel reviewed both of these statements and determined that the statement in question is the vendor inrorrning the user that the Hydroset should only be used for set pressure confirmation and not for determination. This moans that if a MSSV is overhauled (disassembled) or rings (blowdowr, accumulation) have been adjusted that the valve needs to set pressure tested on a test stand, using no hydraulic assist lift type device (I.e. Hydroset). Millstone personnel discussed this Issue with the vendor and the vendor concurred with Millstone Power Station personnel determination on the proper use of the Hydroset. Therefore Millstone Power Station uses the 1566-2 Hydroset per the manufacturers Vendor Technical Manual and dIrectIons.

Extent of Condition: BOTH MILLSTONE UNIT 2 AND 3 HAVE DRESSER (CONSOLIDATED) BASE MODEL NUMBER 3707R MAIN STEAM SAFETY VALVES (MSSVS). BOTH UNITS' MSSVS HAVE - R' ORIFICES AND USE THE SAME DISC. BOTH UNITS USE THE DRESSER 1566.2 HYDROSET TESTING DEVICE FOR MSSV SET PRESSURE CONFIRMATION. THE HYDROSET IS USED TO CONFIRM THE SET PRESSURE OF THE MSSVS TO MEET TECHNICAL SPECIFICATION AND IST PROGRAM REQUIREMENTS.

Initiator Feedback: Initiator notfied General Trend Codes: Category Code Description CATEGORY PERSONNEL ERROR PRECURSOR CATEGORY EIND INDIVIDUAL ERROR - STATION PERSONNEL CATEGORY ENGR ENGINEERING ISSUES CATEGORY EROR HUMAN PERFORMANCE ERROR CATEGORY ]CNF CONFIGURATION CONTROL (PAPERWORK. DRAWING & DES ENGRCODES CFMT CONFIGURATION MANAGEMENT DEGRADATION HOWDISCOVR EXOV EXT. OVERSIGHT HUMAN ERROR PNEP PERSONNEL ERROR PRECURSOR HUMANPERFOR EROR HUMAN PERFORMANCE ERROR INITIALCODE ICNF CONFIGURATION CONTROL (PAPERWORK. DRAWING & DES PERFORMERRO EIND INDIVIDUAL ERROR - STATION PERSONNEL WHATHAP CFMT CONFIGURATION MANAGEMENT DEGRADATION

DEC-21-2004 14:49 MILLSTONE 860 443 5893 P.19 CR Summary Report Tuesday. December 21. 2004 Page 3 of 3 Cause Number: 1 Apparent Cause Causal Factor: NA Cause: Not eppilcable I undetermined Detail: Due to the investigation there are no corrective actions required this is a differring professional opinion between the NRC and Milstone Trend Codes:

Corrective Actions 1

Corrective Action Coordinator: Date:

Process Owner (designee): Date:

PMPO / CR Owner (level I only): Date.

TOTAL P.19