05000528/FIN-2016008-02
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | Title of 10 CFR 50.55a(f)(4), requires, in part, that pumps and valves classified as ASME Code Class 1, 2, or 3 must meet the inservice test requirements set forth in the ASME Operation and Maintenance (OM) Code and addenda to the extent practical within the limitations of design, geometry, and materials of construction of the components. The inservice testing program is incorporated into the Palo Verde Nuclear Generation Station licensing basis under Technical Specification 5.5.8 and governed by the procedures controlled under that specification. ASME OM Code Case OMN-1 was adopted by Palo Verde Nuclear Generating Station per Valve Relief Request number 1, and approved by the NRC as an alternative for performing Code-required valve and pump testing for the second and third 10-year testing intervals (January 1998-2018). ASME OMN-1, Section 3.3.1(b) requires that, if insufficient data exist to determine the inservice test frequency...then [motor operated valve] MOV inservice testing shall be conducted every two refueling cycles or three years until sufficient data exist to determine a more appropriate test frequency. Palo Verde Nuclear Generating Station Procedure 73DP-9ZZ12, Motor Operated Valve Program, Section 4.5.4.5, and Appendix H, define when sufficient test data exists to justify increasing test frequencies beyond 3 years. This criteria includes completing at least two complete diagnostic testing cycles constituting a baseline pre-service test and two subsequent as-found tests. These testing requirements are invoked after complete replacement of the valve, installation of a new valve, or major maintenance, which could substantially change the valve/actuator performance. Contrary to the requirements listed above, the licensee failed to perform Code-required testing for a total of 17 valves between 2008 and 2016. The licensee identified an issue in May 2015 with the testing frequency of five valves after a modification installed new motor operated valves in the charging system. An extent of condition was performed and 11 additional valves were identified as being noncompliant. An engineering evaluation was performed to assess and manage the risk of not completing the required ASME testing per Technical Specification Surveillance Requirement 3.0.3. A prompt operability determination was also performed to provide reasonable assurance of operability until the valves could be tested again. In January 2016, an additional valve was identified as being non-compliant and a separate operability evaluation was completed to provide reasonable assurance that the valve would still perform its function. There are currently seven valves that are still in non-compliance with the Coderequired testing frequency; all other valves have been tested satisfactorily and are now in compliance. Those still requiring testing are scheduled during their respective next available system windows. This violation is of very low safety significance (Green) because the non-conforming valves were determined to have reasonable assurance of operability. The licensee entered the condition into its corrective action program and initiated corrective actions to restore compliance under Condition Report 15-02470. |
| Site: | Palo Verde  |
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| Report | IR 05000528/2016008 Section 4OA7 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Nguyen D Holman D You E Ruesch T Hipschman |
| Violation of: | 10 CFR 50.55a Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Palo Verde - IR 05000528/2016008 | ||||||||||||||||||||||||||||||||||||
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Finding List (Palo Verde) @ 2016Q1
Self-Identified List (Palo Verde)
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