IR 05000528/1985020

Insp Rept 50-528/85-20 on 850603-07.No Violation Noted.Major Areas Inspected:Program Plan,Procedures & Records Re Inservice Testing Program for Pumps & Valves & Insp Procedure 61700

ML20137E497
Person / Time
Site:	Palo Verde
Issue date:	08/09/1985
From:	Campton R, Clark C, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20137E491	List: IR 05000528/1985020 ML20137E485
References
50-528-85-20, NUDOCS 8508230266
Download: ML20137E497 (7)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /85-20 Docket N License N NPF-34 Licensee: Arizona Nuclear Power Project Post Office Box 52034

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Phoenix, Arizona 85072-2034 Facility Name: Palo Verde Nuclear Generating Station - Unit 1 Inspection at: Palo Verde Site, Wintersburg, Arizona Inspection conducted: June 3-7, 1985 Inspectors: N 9 cf5 C. Clsick, Reactor Inspector

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Date Signed 11 .

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mpton,NRCfonsult

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8A-W Date Signed

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Approved By: .

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T. Young, Chief // // Date Signed Engineering Sectidfi U Summary:

Inspect' ion during June 3-7, 1985 (Report 50-528/85-20)

Areas Inspected: This announced inspection consisted of a review of the program plan, procedures and records pertaining to the Palo Verde 1 inservice testing program for pumps and valves. Inspection procedure 61700 was covered. The inspection involved a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> onsite by one NRC consultan Results: In the areas inspected, no violations of NRC requirements were identifie D08230266 G50009 PDH ADOCK 05000528 G PDR

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.-DETAILS

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l . t i- Persons Contacted

• E. E. Van Brunt, Jr., Executive Vice President

• J. Bynum, Plant Manager

• J. Minnicks, I&C Superintendent

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R.~Kropp, Lead Mechanical Engineer A.- Pallon, QA Specialist

• M. Karbassian, Mechanical Engineer

.*T. Nishikara, Mechanical Engineer D. Deruiter, Planning Supervisor

• R. Zimmerman, NRC Senior Resident Inspector

• Denotes those attending the exit meeting on June 7, 1985.  !

The inspector also interviewed other licensee employees, including members of thet technical, operations, maintenance, and training staf . Inservice Testing (IST) Program Plan

' Inservice testing is required to be performed in nuclear power plants in accordance with the ASME Boiler and Pressure Vessel Code by

, 10 CFR 50.55a(g). The ASME Code, in subsections IWP and IWV of

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_Section XI, provides specific requirements for inservice testing of pumps and valves. The IST program at Palo Verde is outlined in a~ document entitled " Pump and Valve Inservice Testing Program." This document is a-formally controlled and reviewed procedure with preparer, reviewer and approval signatures. The current revision, Rev. 2 issued in July 1984,

.has been' submitted to the NRC Office of Nuclear Reactor Regulation (NRR)

for review and approval. At the time of this inspection, NRR was completing its detailed review and had not yet issued the supplemental Safety Evaluation Report (SSER) or other formal comments on this progra NRR had given preliminary approval to the basic program submitted by APS in April 1982 in SSER No. 3 (September 1982).

The IST program will become formally effective at the commencement of commercial operation, however, most program requirements and commitments are already being met. This is appropriate _in that the plant is fueled and operating and the evaluation and trending of safety-related equipment operability is warranted. The applicable addition of the ASME Code is the.1980 Edition through Winter 1981 Addenda. This program applies to 30 pumps and approximately 500 valve The IST program plan document wa's reviewed for compliance with the applicable edition of Section XI of the ASME Code and the requests for ;

relief detailed in the plan. The types and frequencies of tests appear to be in compliance with Code requirements. The inspector did note that

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known changes to this plan were being documented on an interim basis by

! marking up a copy of Revision ~2. Based on observations at other sites, j the inspector considers that the program plan should be formally updated in a timely manner to reflect current status.

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The inspector also noted that the program plan lists all plant Class 1, 2 and 3 numbered valves, including approximately 500 that are not required to be tested per Code. Inclusion of valves outside of the program is

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somewhat confusing and makes the plan much larger than necessary. The licensee indicated these non-tested valves will be removed from the program plan documen Minor differences .were noted between Section XI requirements and site procedures that have not been clearly documented by APS on relief requests. This is an open item previously identified by the NRC resident inspectors in report 50-528/85-08 and is being reviewed and corrected by the license There were no violations of NRC requirements identifie . IST Program Procedures The Palo Verde IST program plan is implemented through various site procedures. The following procedures were reviewed for compliance with the ASME Code, the IST program plan document and 10 CFR 50 Appendix B requirements:

73AC-0ZZ30, Rev. 0, " Inservice Testing of Safety-Related Pumps and Valves"

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73AC-9ZZ04, Rev. 1, PCN1,'" Surveillance Testing"

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30AC-9ZZ01, " Work Control" ,

36AC-9ZZO2, Rev. 1, " Preventive Maintenance" 32MT-92Z66, " Rotating Machinery Vibration Signature Tests" Maintenance' Control Center Instruction (MCCI) 10, Rev. 2, " Retest

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Instructions" Various surveillance test procedures related to pumps and valve In general, the above listed procedures provided the information and guidance necessary to adequately manage and control IST activities. The detail and cross references provided in most of the procedures reviewed was excellent. The following are inspector observations and discussions of several procedural weaknesses noted: Pump test procedures do not indicate where pump vibration measurements are to be taken and site personnel indicated that the pumps do not have targets or benchmarks to facilitate repeatability of tests. Vibration tests are performed by specialists in the

maintenance organization. Discussions with the responsible i maintenance personnel indicated that the individuals were l

knowledgeable and a very good vibration assessment program was being

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established. However, sketches for vibration reading locations and program details that need to be put in surveillance procedures are still in the preparation stage ,. - - -

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, In procedure 73ST-9SIO3, " Leak Test of RCS Isolation Pressure Valves," there were no signoff blocks for performance and review of leakage calculations for SIUV-652, 653 and 654. Also, thi procedure did not provide for recording of the ID number and calibration due date of the test gauge used. A review of available test records did reveal that "M&TE Usage Logs" were attached indicating the gauges use Review sheets for IST surveillances do not provide for indications of acceptability /or unacceptability or any required justification or corrective action specified by the ASME Technical Reviewe Procedure 73ST-92Z01, "Section XI Safety and Relief Valve Testing,"

lists the various valve set pressures in Appendix "D" but, refers the user to the " Instrument Calibration Data List" for official set pressures and tolerance If the Appendix "D" values are not to be updated and accurate, they should be deleted from the procedure to preclude their misuse. The procedure does not require any signoff that the correct set pressures from the official Data List were utilized for testing and evaluation, The test procedure 73ST-9ZZ01 also provides for a single generic signature to indicate acceptable tests for multiple valve tests (10 or more) of pressurizer and main steam reliefs. Individual test data sheets are attached. It should be clarified in this basic procedure, to specify which valves were tested satisfactoril Discussions with responsible personnel and review of procedures indicated that retesting of equipment after maintenance activities that could affect operability was properly controlled. Procedures for this 3::tivity appeared to be very thoroug An additional weakness related to procedures is detailed in paragraph 4 belo The above areas of procedural weakness will be identified as a followup item (50-528/85-20-01) and will be examined on future inspection No violations of NRC requirements were identifie . IST Records Various types of IST records for pumps and valves were examined for conformance to code and site procedural requirements. Due to the recent initiation of the IST program, the amount of meaningful records available for review was limited. Summary listings of the current test status of pumps and valves and the corrective actions taken with regard to pumps have not yet been established or only partially developed. These summaries are required by ASME Section XI, Subsections IWP-6210, IWP-6250

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and IWV-6210 and are essential to permit proper engineering evaluation and trending. The APS Operations Engineering staff was aware of these shortcomings and intends to develop, formalize and finalize the required summarie J

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l The IST documentation does not clearly detail reference values and the i date/ source of their development. This information needs to be compiled l at this stage of the program for future reference and to aid in the proper evaluation of pump and valve performance Following are discussions of the specific inspection areas and observations for the review of pump and valve IST records: Pumps The inspector has a concern regarding the thoroughness of the engineering review of pump surveillance test procedures for content, of completed test results and proper documentation of test problems / failures. Following are examples of discrepancies contributing to this concer Test records for the Auxiliary Feedwater System Pump AFA-P01 were reviewed. Reference values for the initial IST were taken from the manufacturer's pump curves. ASME Section XI requires establishment of reference values based on preoperational test results on the first inservice tests. The initial test, performed on May 1, 1984, was unsatisfactory for low differential pressure. A retest was performed on May 2 after a Procedure Change Notice (PCN) had been i issued to record pump speed and to use temporary gauges in lieu of I plant gauges. This test was satisfactory. Ilowever, during this i test, it appears that the turbine speed control was adjusted during l test performance such that the procedure step to " verify speed at l 3500 rpm" was apparently not performed. The adjustment of the turbine speed was not documented / referenced in the PCN or the initial Surveillance Test Deficiency (STD) and the IST was not redone after this adjustmen Subsequently, the turbine governor was readjusted and the pump retested satisfactorily on May 16. No ID number or calibration due date was shown for the portable tachometer used (space was marked "not applicable"). It is possible that turbine speed gauge in the control room was used, but the procedure does not reference what instrument is to be use Test records for the Diesel Oil Transfer Pumps were reviewed. The reference values for these pumps were calculated based on special operational tests and assumed a flow of 15.3 gpm and a fuel specific gravity of 0.86. The actual test procedure requires establishing a flow of 15.0 gpm and the actual specific gravity of the feel received onsite is 0.8 These differences should not have a great effect on the established pump curves. Ilowever, they would be evaluated for significance and properly documented in the pump record. In addition, the current surveillance procedure contains a page of calculations to be used if the data is in the alert range of the curve "to more accurately determine pump performance". This is inappropriate as the existing test procedure and acceptance criteria should provide the consistency and accuracy necessary to assure pump operabilit Charging Pumps A, B and E test records were examined. The May 29, 1985, test of pump A failed. A Technical Specification Component

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'O Condition Report (TSCCR) was written to document the failure and a Work Request (WR) was issued. The WR was subsequently cancelled and the test rerun with satisfactory results. The original unsatisfactory test was apparently performed using a temporary test gauge in lieu of the process gauge specified in the procedur liowever, there was no record of a gauge ID number or calibration due date in the test record and no documentation could be provided that the reason for the test failure was properly identified, documented, corrected and action taken to prevent recurrence. Because the procedure allows the use of a temporary gauge for this test when the

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plant is in a different mode than when the above tests were run, the inspector questions if the use of different gauges (in different locations, for different modes) affects the repeatability of the test as the procedure is.now writte The test records for the Essential Chille.d Water Pumps were examined. It appears that the pump curves established for Pump A based on the first inservice test and system balance tests may not be reflective of normal pump performance. Subsequent test results r were at the alert limits. This pump test data will need to be monitored closely to verify the validity of the " reference" pump l curve values. This method of establishing pump acceptance criteria l is not as specified in ASME Section XI and thus a relief request !

will be required to document and obtain NRR approval of the method i being use '

The following process test devices (installed plant pressure level I and flow indicators) were selected at random and their calibration records were checked for proper frequency and compliance with accuracy requirements of Section XI.

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FT-40 A/B PI-212 FT-41 A/B FI-212 PI-2 PI-3 PI-17 PI-4 PI-18' FI-534 FI-9 PI-9 LI-5A PI-10

, FI-13 FI-14

'Calibrat' ion' records were available, out of specification results were properly resolved and accuracy requirements were satisfactor '

These obse'rvations on pump records will be identified as a followup

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Valves r

. The summary of valve tests and methods of scheduling and reviewing

<were still being developed. A combination of manual and computer lists was being used by.the IST engineer to document and control the

- program. It was noted that' power operated valve stroke times wer not being recorded in summary form and test data sheets did not

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, ., < 6 provide for the IST engineer to indicate the results of his review and any required actio The inspector reviewed test results, any resulting Surveillance Test Deficiency Reports (STDRs) and closeout actions for tests performed on Work Orders 75337, 65923, 77131 and 82673. Frequency, stroke times, engineering evaluations and corrective actions conformed to code and program plan requirement Results of tests on Main Steam and Pressurizer relief valves per procedure 73ST-9ZZ01 were reviewed. The inspector considers that the records for testing of the pressurizer reliefs needs to be clearly tied to valve serial numbers rather than system designator Unit 1 valves have already been switched with stored valves from Palo Verde Unit 3 due to seat leakage problems. A clearly controlled process recording tests by valve serial numbers will be necessary to minimize confusion and chances for errors as the number of tests and valves increase These observation on valve records will be identified as a followup item (50-528/85-20-03) and will be examined on future inspection No violations of NRC requirements were identifie A 5. Exit Meeting ,

On' June 7,.1985', an exit' meeting was conducted with licensee representatives identified in~ paragraph The inspector summarized the scope o'f the inspecti'on and findings as described in this repor . . -

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