IR 05000440/1989003

Insp Rept 50-440/89-03 on 890206-09 & 21 .No Violations Noted.One Unresolved Item Identified Re Inservice Testing. Major Areas Inspected:Implementation of Inservice Testing, Including Administrative & Technical Procedures

ML20235T201
Person / Time
Site:	Perry
Issue date:	02/27/1989
From:	Danielson D, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235T189	List: IR 05000440/1989003 ML20235T187
References
50-440-89-03, 50-440-89-3, NUDOCS 8903080191
Download: ML20235T201 (11)

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U.S.' NUCLEAR REGULATORY COMMISSION REGION III -

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Report No. 50-440/89003(DRS)

Docket No. 50-440 License No. NPF-58 Licensee: The Cleveland Electric' Illuminating Company 10 Center Road Perry, OH 44081 Facility Name: Perry Nuclear' Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio Inspection Conducted: February 6-9 and 21, 1989 Inspector- . F. Smith '/A7/d'7

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Approved By: D. H. Danielson, Chief MM//'/

Materials and Processes Section Date Inspection Sumary i

Inspection on February 6-9 and 21, 1989 (Report No. 50-440/89003(DRS))

Areas Inspected: Unannounced inspection of implementation of Inservice Testing (IST) (73756) including administrative and technical procedures, performance of testing, retention of records and recording of trend Followup was performed on two existing Open Items: (1)ImproperStroke Timing of Valves and (2) Weeping Safety Relief Valve Results: No violations or deviations were identified. One unresolved item is discussed in Paragraph '

Within the areas reviewed, the implementation of IST follows the requirements of Section XI and the itcensee's progra The licensee has developed interim and long term solutions to conflicts resulting from the use of motor operated valve analysis data to set limit switches which also control remote position indication lights used for stroke _ timin The licensee believes that the cause of weeping SRV's has been determined and that proper test parameters can reduce or eliminate future weepin g903os0191 890228 PDR ADOCK 0500 Q

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. Base'd.on the areas ' reviewed,Jthe licensee has a competent = staff which has

.: generatedLa" sound-set of. procedures,for: operating the plant.:: TheseE procedures ~are followed during performance of.the' job, performanceLis'

documented 'and' records are properly' analyzed and manage '*'- . No~significant! weaknesses'were identified as=a result of.this inspection; f

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DETAILS I

\ Persons Contacted Cleveland Electric Illuminating Company (CEI)

• S. F. Kensicki, Director, Perry Plant Technical Department

• B. D. Bols, Quality Inspector, Operations Quality Section i *B. J. Concel, Senior Unit Lead Mechanical ISI/ Performance Unit G. A. Dunn, Supervisor, Compliance ,

• K. R. Pech, Manager, Technical Section

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J. Rivers, Lead Inservice Inspection and Performance

+*B. Schneidman, Operations Engineer, Compliance Section NRC Residents G. S. O'Dwyer, Resident Inspector, USNRC

• Attended exit meeting on February 9,198 + Participated in telephone exit meeting on February 21, 1989. Action on Previous Inspection Findings (92701)

Previous inspections disclosed problems which were of a long term nature and could not be resolved during the inspection period. Several problems related to pumps, valves, and inservice testing, were reviewed by the NRC inspector and are discussed belo (0 pen) Open Item (440/87016-06) Long Term Operational and Safety Significance of Weeping SRVs Since the Fall of 1986, the licensee has experienced a problera in increased temperature and level in the su to leakage in the Safety Relief Valves (SRV)ppression pool due made by Dikker Currently, 17 of 19 SRVs are weeping, based on temperature readings in the tailpipes of about 250 degrees The other two tailpipes are at about 175 degrees Residual Heat Removal (RHR) Suppression Pool cooling mode and the Suppression Pool Cleanup System (SPCU)

are being used to control water level and temperature with RHR Suppression Pool cooling mode used almost exclusively. Some items of concern include (1) the amount of operating time the RHR "A" and

"B" pumps are experiencing, (2) the continual attention and extra duties required of the operators to maintain Suppression Pool temperature and level, and (3) the possibility of further degradation of the SRVs (more leakage). The NRC inspector reviewed the licensee's evaluation of the SRV leakage and some of the possibilities to correct the problem The current contingent of 19 SRVs consists of 17 replacement SRVs originally procured for Unit 1 and two refurbished valves from the original Unit 1 installation. The two refurbished valves are

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not weeping. The remaining 17 valves did not leak when installed, but began weeping after being pneumatically operated at approximately 150 psig of steam pressure. The two refurbished valves have'also been pneumatically operated, but their operation took place with a steam pressure of 900 psig or greater. Increased testing pressure was deemed to be beneficial in the prevention of weeping. . This conclusion was as a result of the licensee's discussions with other power plant personnel, particularly those at Clinton Station. As a result of these discussions, the licensee has rewritten test procedures to require the use of 900 psig steam, minimum .when testing SRVs. A reduction in weeping-is expected to occur because of the additional impedance to rapid closure of the valve offered by the higher steam pressure when the pneumatic actuation is deenergized. The higher velocities possible with the lower steam

" cushion" beneath the disk are believed to induce seat damage in the impact are At the next outage, the licensee intends to replace all 19 SRVs and to perform only high pressure (900 psig or more) tests in the future to minimize the potential for the formation of additional weeping

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SRVs, Seats of the two SRVs with the worst leaks will be examined-during the valve decertification to establish the cause of the weepin Neither the manufacturer of the pump nor the designer of the plant indicated a concern for the continued use of the RHR for cooling provided the prescribed maintenance and inservice testing continued to be performed. Neither the valve manufacturer nor the plant designer appeared to be convinced that weeping resulted from seat damage or that all weeping could be avoided.' When the licensee experienced SRV leakage in the Fall of 1986, a letter from dated October 29, 1986, stated that, from a technical point of view, leakage of SRVs at operating BWRs was not uncommon and GE attributed the leakage to foreign material in the seat area, not seat damage. G.E. also stated that an increase in the leakage rate was not expected, nor was there any significant potential for valve seat damage due to this leakage. The NRC inspector's review of the Dikkers valve manuals revealed that Dikkers held similar view This item will remain open pending evidence that the new testing procedure has reduced leakage to a point where it no longer requires significant corrective action to control the Suppression Pool temperature and leve b. (Closed) Violation (440/88004-04) Failure to Measure Isolation Valve Stroke Times to the Nearest Second or 10% of Maximum Allowable Stroke Time The maximum stroke time of isolation valves, based on the requirements of the system is normally much greater than the time required by the actuator to open or close the valv In order to

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provide a stroke time which is useful in detecting degradation of the system, it is usually based on the manufacturer's stated stroke time or on the observed stroke tim Stroke time is normally measured by observation of the position indication lights in the control room. The lights are controlled by limit switches in the motor operator which operate relative to the stem position. In the case of the isolation valves, many limit switches are of the two-rotor variety in which one rotor is set near the open position and the other is set near to the close positio The exact position at which the rotors operate each switch is adjustabl The valve operator also contains another switch called the torque switch. This switch is adjusted to control the force that the stem exerts on the seat in the close direction and on the backseat in the open direction. Because the backseat is small in comparison to the seat, the force in the open direction is usually adjusted to a lower value than it is in the closed direction in order to prevent damage to the backseat if the limit switch fails to stop the stem before it contacts the backseat. Providing this margin of safety ens. During the for the start of backseat the open produces cycle, theaload problem when on the stema is valve hi op'gh in order to unseat the disk. The load is often high enough at this stage to cause the torque switch to operate and interrupt the opening strok In order for the motor operator to successfully open the valve, the limit switch on the " closed" end of the stroke is usually wired into the control circuit so that during the opening stroke it bypasses the torque switch while the unseating of the disk takes plac After the high load unseating portion of the stroke, control of the stroke is restored to the torque switch. As indicated previously, the limit switch at the open end of the stroke interrupts the current to the operator motor before the stem is backseate If the limit switch fails, the torque switch limits the force which the stem applies to the backsea The percentage of the open stroke over which the torque switch bypass is applied varies from about 5% to 20%. Because of the need to determine where the loads are in the valve stroke and where the electrical switches should be set, a number of devices were developed to analyze the needs of motor operated valves. When the switches of the MOVs were adjusted to the proper position to make the valves function correctly, the position indicating lights, which operate off the same rotors as the motor control limit switches, are shifted along with these switches (on two-rotor controls).

As a result, the time when both lights are on (which can be interpreted to be an indication of the time the stem is in motion)

might be 20% less than the time the stem is actually in motion. The difference is in the time allowed for the disk to clear the seat (up to 20%).

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-. c-In order to avoid' violation of the stroke time dictated by the system requirements, the stroke time read to determine operability must be related to the actual maximum full stroke time of the valve. The only way to directly measure this time with the present equipment is to visually-observe the valve while it operatesr This is not always possible. The alternative is to adjust the readings that can be taken from observation.of remote position indication lights in the control room so that they reflect the full stroke time. The licensee has done this. The bypass time for each valve is measured and incorporated into the appropriate surveillance procedure, so that when the time measured for each stroke (based on control room light observation) is added to this pre-established bypass time, the result is directly comparable with the original stroke time maximum values. The resolution is simple and effective. Although a slight error occurs as the stroke time increases, the error is negligible near the original stroking speed to the MO To initiate a more effective remedy for the problem, the licensee has begun revising the wiring of the MOV switches so that at the closed position the indication light will be on as soon as the. torque switch closes as the disk begins to leave the seat on the open stroke. When completed, this change will eliminate the need to add the corrections to each stroke time recorded. This item is considered close . Pump and Valve Inservice Testing (IST) Program Implementation (73756)

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The licensee's IST Program, entitled " Perry Nuclear Power Plant Unit 1 Inservice Testing (IST) Program for Pumps and Valves," 80A5237, Revision I was reviewed by the NRC inspector for information and for use as a standard to be met by Perry procedures for implementation of the program. The NRC inspector's review of program implementation covered areas from the development of,an organization and administrative controls through performance of testing, analysis of results, and trending of dat Administrative Control of Inservice Testing The NRC inspector confirmed that administrative controls were in place to satisfy the requirements of the IST program and that specific IST duties had been assigned to personnel. Most administrative guidance for implementation of IST is provided by Procedure PAP-1101, " Inservice Testing of Pumps and Valves." The NRC inspector reviewed Revision 2 of this document with Temporary Change Notice TCN-2, dated September 9, 1988. The procedure is quite comprehensive, covering (1) Resr,onsibilities for Implementation of IST; (2) Compliance Requirements; (3) Test Requirements; (4) Analysis of Data; (5) Analysis of Deviations from j Acceptable Standards; (6) Retest Requirements; (7) Administration; -

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(8) Scheduling; (9) Records; (10) Inservice Test Flow Path, and l (11) a Tabulation of Pumps and Valves listing test requirements and l

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frequency. This is the principal administrative document used in implementation of.IST at Perry. The NRC' inspector's review revealed {

one anomaly in this procedure. Guidance was provided in identifying )

that a pump shall be declared inoperable when it is found to exceed j the acceptance criteria, but-similar guidance was not provided for valves. Although.there was some reservation indicated by j the licensee concerning the propriety of inserting criteria fo declaring the valves inoperable in this procedure, subsequent review of PAP-1105, Revision 5, TCN-2, " Surveillance Test Control," j resolved the question. Paragraph 6.4.2.3.b.2 (of PAP-1105) states.-

"When unacceptable criteria is based on ISI-Pump and Valve Program acceptance criteria and the criteria is not directly from the Technical Specifications, the on call ISI Engineer should be contacted and the widance of PAP-1101, Inservice Testing of Pumps and Valves shou',d 6 used in declaring the system / component operable or inoperable." if PAP-1105 refers the ISI Engineer to PAP-1101 for this guidance, the information should be available in PAP-110 The licensee was informed of this problem and responded by inserting the operability information into a revision of PAP-1101 which was currently being processed. The NRC inspector reviewed the pertinent portion of the proposed revision and concurred in the effectiveness of the changes. In view of the prompt resolution of the problem, no further action is considered necessar Review of Administrative and Technical Procedures The NRC inspector reviewed the following procedures and sampled selected areas of application of the procedur No irregularities were note *

OM14-B:TMP-2005 "I&C Section Training Programs," Revision 1, dated June 6, 198 OM14-B:TMP-2010 " Tech Staff and Managers Training Program,"

Revision 1, dated July 26, 198 OM7A:SV1-P47-T2100 " Control Complex Chilled Water System (CCCW) Chilled Water Supply Header A Relief Valve (P47-F574A)

Set Pressure Test," Revision 1, dated May 3, 198 *

OM7A:SV1-N27-T2202, "Feedwater Leakage Control Leak Rate Test for IN27-F740, F742A, and F7428," Revision 2, dated April 29, 198 OM7A:SV1-E12-T2003, "RHR C Pump and Valve Operability Test,"

Revision 5, w/TCN-3 dated July 13, 198 OM7A:SV1-M14-T9313, " Type C Local Leak Rate Test of 1M14

. Penetration V313," Revision 4, dated July 1, 198 ,

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OM1H:IAP-0501, " Calibration / Loop Calibration Check Internals for Plant Instruments, Revision 1, w/TCN No.1, dated July 27,

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OM1H:IAP-0509, " Miles Meter Lab Calibration Program," Revision 0, dated May 29, 1986.

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OM14B:TMP-2002, "NRC License Maintenance and Requalification Programs," Revision 0, dated April 28, 198 c. Review of Performance of Inservice Testing of Pumps and Valves The NRC inspector witnessed the stroke testing of two valves (IP51-F652, Service Air (SA) Drywell Isolation Valve and IP51-150 on IH13-PC70, SA Supply HDR Containment Isolation Valve) performed on SVI-P51-T2001 for IP51F652 MCCEF1A7XC Service Air Drywell-Isolation. The test was performed in accordance with the requirements'of the procedure, using stopwatch SB-331 which had a calibration valid through June 5,198 No inservice testing of safety-related pumps was scheduled-for the inspection period. As an alternative, the NRC inspector witnessed the performance of vibration testing performed as part of the preventive maintenance program on Turbine Driven Feed Pumps A and B. The test was performed without the documentation normally present with-testing safety-related equipment and the work was performed with an instrument which could not be used for safety-related work because of inability to provide a satisfactory calibration method. The licensee's staff is currently attempting to develop a method for the satisfactory calibration of the equipment because it provides some significant advantages over the vibration measuring instruments used on safety-related work. The instrument is a Wavetek, also identified as a Rockland Mini-Analyzer, Model 5810A. Someofitsadvantagesare(1)itreadsacceleration amplitudes at a spectrum of frequencies, (2) it stores the data for future reference and (3) it allows hard copies to be made of the .

recorded data. Its size is a disadvantag It approximates the !

size of early dual channel oscilloscope Outside of the exceptions noted above, the vibration test was conducted in accordance with the procedure which would be anticipated with a safety-related application. The positions for placement of the transducers were identified by stickers which were identified by the licensee as being highly adherent and not subject to peeling or flaking. The magnetic mounts for t.he transducer were designed to permit their use on curved surface In both the stroke testing and the vibration testing, the personnel involved were familiar with the test, the equipment being tested, and the test equipment. Where appropriate, the performance of multiple sequential operations were signed off as they were performed, rather than after completion of all operation p

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In addition to the reviewing of performance of tests, the NRC i inspector also reviewed the documentation of the following completed j tests for'the component SVI-ER-T2003, completed January 21, 1989, for RHR C Pump .

1E12-C002C and 6 associated valve j SVI-N?7-T2202, completed December 2, 1987, for Feedwater Leakage Control Leak Rate Test for IN27-F740, F742A and F742 *

SVI-P47-T2100, completed January 29, 1986, for Control Complex Chilled Water System (CCCW) Chilled Water Supply Header A Relief Valve (P47-F574A) Set Pressure Tes SVI-M14-T9313, completed March 27, 1987, for Type C Local Leak Rate Test of 1M14 Penetration V31 No deficiencies were detected in the review of the inservice tests of pumps and valve Inservice Testing of Check Valves The testing of check valves is properly included in the IST program for all valves. Experience has shown, however, that this is not always the case. As a result, special emphasis is being given to check valves to assure that they are being given adequate consideration in the licensee's IST programs. One of the simpler examples of this was in keeping records. Because there is no numerical criterion normally associated with a check valve test, some licensee's kept little or no record of the test and cou'1d see no point in trending a "go-no go" test. They also kept no records of comments, such as " Failed to open on first test, but operated promptly on five following tests." Such records can be beneficial in future application The NRC inspector confirmed that the licensee has included the appropriate check valves in the IST program. The inspector also confirmed that appropriate procedures had been prepared for the testing of such valves. The importance of these valves was recognized by the licensee and substantial work has been performed by the licensee in confonning to the requirements of SOER 86-03. In performing this work, the licensee elected to follow the recommended EPRI report " Application Guidelines for Check Valves in Nuclear Power Plants"(NP-5479). After applying this guidance to all the systems covered by the SOER, any valves in these systems which were not already included in the IST valves identified in PAP-1101 were added, even though the licensee did not normally consider them to be safety-related. The valves included in this group include the following:

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(2) E51-F040

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(4 'IP45-F552 (5 IP49-F502A/B-(6 1R46-F508A/B Each of these nine valves is identified as a valve which mus be internally inspected during the first refueling outage and thereafter as the results of the inspe'ction indicate to be appropriate. Exceptions.to this are permitted in the cases of'

(3), (5), and (6) above. -When identical valves are in essentially identical systems and in the same geometric arrangement,~then only one of each pair of' valves-needs to be' internally inspecte The NRC inspector reviewed the records of inservice-testing maintained by the licensee.and found that although records and trending' data for operated valves.were orderly and current, the data for check valves included no trending information. The-records for each check valve test included space for notes by the personnel performing the test The required'information could be derived from the available records in nearly the same time required to get the 'same information from ai trending sheet, so little is lost by not trendin Additional concern was recently generated by the discovery that two balls were missing from the Charging Water Check Valves at Dresden Power Plant. At Perry, these valves were part of the preoperational testing and are included in the computerized program for repetitive ,

testing. These valves have been tested and will. continue to be tested in accordance with the licensee's program. . The NRC inspector reviewed the test procedure for these check valves.briefly while~at the plant and was unable to locate any test time criterion for establishing acceptability. This procedure was not among those which were acquired for subsequent review at Region III. Pending the location of an acceptable leak rate criterion in the procedure or justification for the absence of time from such a criterion, this is

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considered'an Unresolved Item (440/89003-01). Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. .An unresolved item is discussed in Paragraph . Exit Interview (30703)

The Region III inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on February 9,198 The inspector summarized the purpose and findings of the inspection.

< The licensee representatives acknowledged this information. The inspector

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'also discussed'th'e likely informational content of.the inspection report

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with~ regard' to the'. documents or processes - reviewed 'during the . inspection.

7, The' licensee representatives did not identify anyssuch.' documents / processes as proprietary.:.

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