ML20129B291

Insp Rept 50-333/85-09 on 850401-0531.No Violation Noted. Concern Expressed Re Failure to Implement Mod in Containment Atmosphere Dilution Sys to Protect Carbon Steel Nitrogen Makeup Lines from Low Temp Brittle Fracture

ML20129B291
Person / Time
Site:	FitzPatrick
Issue date:	06/28/1985
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129B279	List: IR 05000333/1985009 ML20129B274
References
50-333-85-09, 50-333-85-9, NUDOCS 8507150483
Download: ML20129B291 (21)

See also: IR 05000401/2005031

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

DCS Numbers

50-333-850322

50-333-850418

50-333-850421

50-333-850503

50-333-850220

50-333-850506

Report No. 85-09

Docket No. 50-333

License No. OPR-59 Priority --

Category C

Licensee: Power Authority of the State of New York

P.O. Box 41

Lycoming, New York 13093

Facility Name: J.A. FitzPatrick Nuclear Power Plant

Inspection At: Scriba, New York

Inspection Conducted: April 1, - May 31, 1985

Inspectors:

L.T. Doerflein, Senior Resident Inspector

W.J. Lazarus, Senior Emergency

Preparedness Specialist

A.J. Luptak, Resident Inspector, NMP-1

Approved by:

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rojects Section 2C V

' Inspection Summary:

Inspection on April 1, - May 31, 1985

(Report No. 50-333/85-09)

Areas Inspected: Routine and reactive inspection during day and backshift hours

by two resident inspectors and one region based inspector (200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />) of

licensee action on previous inspection findings, licensee' event report review,

operational safety verification, survelliance observations, maintenance

observations, plant startup from refueling, determination of reactor shutdown

- margin, startup testing of the Analog Transmitter Trip System, followup on

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licensee response to GE Service Information Letter No. 402, review of the

Emergency Core Cooling Systems subject to potential overpressurization, follow-

up on licensee event, relocation of the Emergency Operations Facility and

review of periodic and special reports.

Results: No violations were identified in the areas inspected.

However, as discussed in paragraph 10, we are concerned about the failure to

implement a modification on the Containment Atmosphere Dilution System to

protect the carbon steel nitrogen makeup lines from low temperature brittle

fracture. The significance of this modification was highlighted by the

failure of the vent header.at another facility, during the past year, due to

improper operation of the nitrogen inerting system. We are also concerned

that this maybe indicative of a general lack of progress in reducing the

modification backlog identified in inspection report 50-333/82-24.

The continuing problems with pilot valve seat leakage and setpoint drift of

the target Rock safety relief valves (discussed in paragraph 3) renew concerns

regarding the need for increased management attention in pursuing resolution

of these problems.

Other concerns involving Source Range Monitor and Intermediate Range Monitor

instrument dry tube cracking, the Shutdown Margin demonstration, and the

inadvertent lifting of a fuel bundle from the reactor core are documented in

paragraphs 6., 8., and 12. respectively.

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DETAILS

1. Persons Contacted

• R. Baker, Technical Services Superintendent

V. Childs, Senior Licensing Engineer

• R. Converse, Superintendent of Power

M. Curling, Training Superintendent

• W. Fernandez, Operations Superintendent

• H. Glovier, Resident Manager

H. Keith, Instrument and Control Superintendent

D. Lindsey, Assistant Operations Superintendent

R. Liseno, Maintenance Superintendent

• E. Mulcahey, Radiological & Environmental

Services Superintendent

R. Patch, Quality Assurance Superintendent

T. Teifke, Security & Safety Superintendent

The inspector also interviewed other licensee personnel during this

inspection including shift supervisors, administrative, operations, health

physics, security, instrument and control, maintenance and contractor

personnel.

• Denotes those present at the exit interview.

2. Licensee Action on Previous Inspection Findings

(0 pen) Unresolved Item (333/77-26-06): In a letter dated November 14,

1977, the architect-engineer indicated that the Containment Atmosphere

Dilution System logic would be modified to provide low temperature pro-

tection for the carbon steel nitrogen makeup lines. The inspector noted

that this modification has not been implemented. Additional details on

this item are discussed in paragraph 10. of this report.

(0 pen) Inspector Followup Item (333/83-04-03): The inspector noted that

the licensee continues to have problems with setpoint drift on the two

stage Target Rock safety relief valves. Additional details on this item

are discussed in paragraph 3. of this report.

3. LicenseeEventReport(LER) Review

The inspector reviewed LER's to verify that the details of the events were

clearly reported. The inspector determined that reporting requirements

had been met, the report was adequate to assess the event, the cause

appeared accurate and was supported by details, corrective actions

appeared appropriate to correct the cause, the form was complete and

generic applicability to other plants was not in question.

LER's 85-09*, 85-10*, 85-11, 85-12, 85-13* were

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• LER's selected for onsite followup.

LER's 85-09 and 85-13 reported that, when tested, a total of five Target

Rock two stage safety relief valves had setpoints outside the Technical

Specification allowable tolerance. The vendor believes that the possible

causes of this setpoint drift are inadequate clearances in the laberinth

seal area and pilot valve seat leakage. The vendor is paying particular

attention to laberinth seal clearance during valve overhaul. The licensee

was also informed by the vendor that the pilot seat leakage could be

caused by testing the valves at to low a steam pressure such that the

pilot valve doesn't have any cushion effect when shutting. As a result,

the licensee revised the surveillance procedure to increase the test

pressure to 250-300 psig. However, despite this change, following safety

relief valve testing during the startup from the 1985 refueling outage,

the licensee noted indications of pilot seat leakage on the "F" safety

relief valve. The inspector will continue to review licensee's progress

in resolving the safety relief valve drift during a subsequent inspection.

LER 85-10 reported that a fuel bundle was inadvertently lifted from the

reactor core when it was caught on one of the lock levers of the fuel

support grapple. Details of this event are discussed in paragraph 12. of

this report.

4. Operational Safety Verification

a. Control Room Observations

Daily, the inspectors verified selected plant parameters and equip-

ment availability to ensure compliance with limiting conditions for

operation of the_ plant Technical Specifications. Selected lit

annunciators were discussed with control room operators to verify

that the reasons for them were understood and corrective action, if

required,' was being taken. The inspectors observed shift turnovers

biweekly to ensure proper control room and shift manning. The

inspectors directly observed the operations, listed below to ensure

adherence to approved procedures:

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Reactor startup on May 28, 1985.

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Issuance of RWP's and Work Request / Event / Deficiency forms.

No violations'were identified,

b. Shift loos ~ and Operating Records

Se'locted shif t logs and operating records were reviewed to obtain

information on plant problems and operations, detect changes and

trends in performance, detect possible conflicts with Technical

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Specifications or regulatory requirements, determine that records are

being maintained an'd reviewed as required, and assess the effective-

ness of the communications provided by the logs.

No violations-were identified,

c . Plant Tours

During the inspection period, the inspectors made observations and

conducted tours of the plant. During the plant tours, the inspectors

conducted a visual inspection of selected piping between containment

and the isolation valves for leakage or leakage paths. This included

verification that manual valves were shut, capped and locked when

required and that motor operated valves were not mechanically

blocked. The inspectors also checked fire protection, house-

keeping / cleanliness, radiation protection, and physical security

conditions to ensure compliance with plant procedures and regulatory

requirements.

No violations were identified.

d. Tagout Verification

The inspector verified that the following safety-related

protective tagout records (PTR's) were proper by

observing the positions of breakers, switches and/or valves.

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PTR 850548 on "C" Residual Heat Retraval Service Water System.

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PTR 850572 on "B" Station Battery Charger.

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PTR 850603 on the Reactor Protection System.

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PTR-850647 on the "A" Emergency Service Water System.

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PTR 850783 on the "B" Residual Heat Removal System.

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PTR 850858 on the "B" Residual Heat Removal Service Water

System.

No violations were identified.

5. ' Surveillance Observations

The inspector observed portions of the surveillance procedures listed

below to verify that the test instrumentation was properly calibrated,

approved procedures were used, the work was performed by qualified per-

sonnel, limiting conditions for operation were met, and the system was

correctly restored following the testing:

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F-ST-398, Type "B" and "C" LLRT of Containment Penetrations,

Revision 14, dated March 20, 1985, performed April 8, 9 and 15,

1985.

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F-ST-29E, Backup Scram Valves Functional Test, Revision 0,

dated February 27, 1985, performed April 19, 1985.

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F-ST-39L, Reactor Vessel Hydrostatic Test, Revision 0, dated

May 1, 1985, performed May 7, 1985.

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F-ISP-1, Instrument Line Flow Check Valve Operability Test,

Revision 5, dated June 18, 1981, performed May 8, 1985.

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F-ST-16I, 125 VDC Station Battery Service Discharge and

Charger Performance Test, Revision 1, dated April 27, 1983,

performed May 17, 1985.

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F-ST-290, Integrated Scram System Test, Revision 2, dated

January 23, 1985, performed May 31, 1985.

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F-ST-5N, APRM Instrument Functional Test (Refuel, Startup,

Shutdown Mode), Revision 7, dated October 31, 1984, performed May

, 31, 1985.

The observations of the Local Leak Rate Testing (LLRT). included the post

maintenance LLRT on the repaired Reactor Water Cleanup inboard contain-

ment isolation valve (12-MOV-15) and the "B" Feedwater outboard contain-

ment isolation valve (34-NRV-1118). The inspector noted that 12-M0V-15

passed the LLRT while 34-NRV-111B failed and had to be reworked. The

inspector also noted that 34-NRV-111B had to be reworked several times

before successfully passing an LLRT. As discussed in paragraph 6. of this

report, the inspector witnessed a portion of the maintenance performed on

34-NRV-1118. Based on these observations and discussions with licensee

personnel, the inspector determined that the licensee adequately performed

retesting (LLRT) on repaired containment isolation valves.

No violations were identified.

6. Maintenance Observations

a. The inspector observed portions of various safety-related maintenance

activities to determine that redundant components were operable,

these activities did not violate the limiting conditions for opera-

tion, required administrative approvals and tagouts were obtained

prior to initiating the work, approved procedures were used or the

activity was within the " skills of the trade," appropriate radio-

logical controls were properly implemented, ignition / fire prevention

controls were properly implemented, and equipment was properly tested

prior to returning it to service.

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b. During this inspection period, the following activities

were observed:

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WR 00/21073 on the functional testing of safety related

snubbers

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WR 07/38673 on the replacement of "D" Intermediate Range

Monitor dry tube.

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WR 34/35562 on the repair of "B" Feedwater Outboard

Containment Isol.cion Check Valve.

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WR 46/25455 on the repair of the "A" Emergency Service Water

Pump discharge check valve.

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WR 71/22674 on the replacement of "A" Low Pressure Coolant

Injection System Battery

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F-IMP-71.18B on the post maintenance testing of replaced HFA

relays.

c. During the 1985 refueling outage in-vessel Inservice Inspection (ISI)

visual examinations, the licensee identified cracks in all twelve

Source Range Monitor (SRM) and Intermediate Range Monitor (IRM)

instrument dry tubes. The cracks were all in the upper portion of

the dry tube and were similar to those observed at other BWR's and

discussed in General Electric Service Information Letter (SIL) ido.

409. The indications are believed to be the result of Irradiation

Assisted Stress Corrosion Cracking (IASCC). The inspector observed

portions of the videotape containing the dry tube examinations. The

inspector noted that the licensee individual performing the evalua-

tions was qualified as a Level III inspector.

The dry tube ISI results were also evaluated by General Electric (GE)

who concluded that the licensee could operate one additional cycle

with the existing dry tubes with no adverse impact on safety. How-

ever, GE recommended that five of the dry tubes be replaced. Based

on this recommendation, the licensee replaced the dry tubes at core

locations 12-9, 28-33, 36-9, and 36-25 (IRM H, D, G and SRM C) which

had possible indications below the bottom tube weld at the primary

pressure boundary and the dry tube at 28-25 (IRM E) which had a

noticeable bend at the crack location. The licensee also had to

replace the dry tube at 12-33 (SRM A) after the top portion broke off

when it was bumped by a double blade guide during core alterations.

The inspector noted that the licensee recovered the piece which broke

off.

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The inspector noted that the replacement dry tubes were the same

design as the original dry tubes and therefore subject to IASCC.

General Electric in'dicated that a dry tube with materials less

susceptable to IASCC would be available in the near future. The

licensee tentatively plans on replacing the remaining six cracked

dry tubes with ones of the new design during the next refueling

outage and on replacing the six dry tubes just installed during the

following outage to resolve the problem with dry tube cracking.

No violations were identified.

7. Plant Startup from Refueling

The inspectors witnessed portions of the plant startup conducted May 28-

31, 1985 to verify that: the startup was performed in accordance with

approved procedures; surveillance tests required to be performed

prior to startup were satisfactorily completed; systems were properly

aligned prior to startup; the control rod withdrawal sequence was avail-

able; and startup activities were conducted in accordance with Technical

Specification requirements.

No violations were identified.

8. Shutdown Margin Demonstration

The inspector observed the Shutdown Margin (SDM) demonstration performed

on May 6, 1985. The test utilized the diagonally adjacent rod method and

was performed in accordance with an approved procedure. The inspector.

noted that the licensee terminated the test with the margin rod (22-27) at

notch position 12 and the object rod (26-31), the analytically determined

highest reactivity worth control rod, at position 36 after Source Range

Monitor (SRM) count rate went from 60 counts per second (cps) to approxi-

mately 200,000 cps during the test. The procedure required the object rod

to be fully withdrawn. Using data obtained during the test, the fuel

vendor determined the SDM to be .54% AK/K. The Technical Specifications

required that the SDM for Cycle 7 be greater than .44%_AK/K. However, due.

to the unusual increase in SRM count rate during the test and because the

calculated SDM was significantly below the SDM design value of 1.17% AK/K,

additional NRC inspections by regional specialists were conducted to

evaluate the results of the tests.

As part of his followup to the SDM test, the resident inspector reviewed

the completed core verification maps prepared by the licensee and noted

that the final verified position of the fuel bundles was in accordance

with the FitzPatrick Cycle 7 Management Report dated April 1985. The

inspector noted that the verification had been performed by a Reactor

Engineer and a licensed operator. A separate review of the videotapes was

conducted by two Quality Control (QC) inspectors. Following the SDM test,

two additional QC inspectors performed another review of the core veri-

fication videotapes. The resident inspector also viewed the core

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verification videotapes and verified, for a sample of one half the core,

that the fuel bundle position and orientation were in accordance with the

core map. The videotapes were generally clear and the serial numbers on

the fuel assemblies were adequately visible. No discrepancies were

identified.

On May 25, 1985, the licensee performed a SDM demonstration using the

in-sequence critical method to verify adequate SDM before the startup

from the refueling outage. The inspector reviewed the test results

obtained in accordance with the licensee's procedure and noted that the

calculated SDM with the strongest control rod fully withdrawn was .79%

AK/K. During the plant startup on May 28, 1985, another in-sequence

critical demonstration resulted in a calculated SDM of .81% AK/K.

Based on the data reviewed, the inspector determined that the demonstrated

SDM met the Technical Specification requirements. Based on a review of

correspondence with the fuel vendor and on di!cussions with licensee

personnel, the inspector noted that the deviations between the calculated

SDM and the design values are probably due to calculational uncertainties.

Additional details on the evaluation of the SDM demonstrations are docu-

mented in inspection reports no. 50-333/85-14 and 50-333/85-17.

9. Startup Testing-Analog Transmitter Trip System

The inspector reviewed portions of preoperational procedure no. Misc. 02A,

"Preoperational Test of Analog Transmitter / Trip System for RPS and ECCS

Sensor Trip Inputs (Mod. No. F1-82-53)", Revision 1, dated April 24, 1985,

to verify that the procedure was properly approved and included: procedure

scope and objectives; prerequisities; precautions; acceptance criteria;

checkoff lists; reference to drawings and applicable procedures; pro-

visions for recording details of the conduct of the test; provision for

identification of personnel conducting the testing and evaluation of test

data; and provision for quality control verification of critical' steps.

The inspector also verified that changes to the preoperational procedure

were reviewed as required by Technical Specifications.

The inspector also witnessed portions of the testing and verified that the

test was conducted in accordance with the approved procedure and that

quality control verification was performed during the test. For the

testing observed, the inspector noted that the test results were within

the previously established acceptance criteria.

No violations were identified.

10. Followup on licensee response to General Electric Service

Information Letter (SIL) No.402, Wetwell/Drywell Inerting

, Based on discussions with licensee personnel and a review of Operating

Experience Report No. 185, the inspector verified that the licensee eval-

uated the design and operation of the liquid nitrogen based inerting

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system as recommended by General Electric SIL No. 402. The evaluation was

performed by the Performance and Reliability Department in accordance with

procedure PS0 28, " Operating Experience Feedback," and identified problems

with the operation and testing of the liquid nitrogen inerting system.

The inspector reviewed procedures F-0P-37, " Nitrogen Ventilation and

Purge; Containment Atmosphere Dilution (CAD); Containment Vacuum

Relief and Containment Differential Pressure Systems," Revision 20, and

F-ST-25A, " Nitrogen System Low Temperature Simulated Automatic Isolation

Functional Test," Revision 0, and determined that, in response to these

findings, the licensee revised or developed procedures to verify proper

operation of the nitrogen inerting system automatic isolation prior to

inerting the containment and to add cautions on system monitoring if the

automatic isolation . valves are bypassed, such as during containment

inerting directly from a nitrogen truck. The inspector also reviewed

calibration data sheets dated October 2,1984 to verify that the tempera-

ture sensors used for nitrogen system monitoring and for the automatic

isolation functions were properly calibrated. The inspector verified that

these sensors have been added on the calibration schedule to ensure

periodic recalibration.

The inspector also noted that, during the evaluation, the licensee

reviewed the portions of the liquid nitrogen system used for containment

makeup during normal operations. This review noted that a modification

was proposed by the architect-engineer in a letter dated November 14,

1977, to resolve a deficiency identified in Inspection Report No.

50-333/77-26 concerning the lack of low temperature isolation protection

for the carbon steel nitrogen makeup lines in case of a loss of the elec-

tric heater downstream of the ambient vaporizers._ Based on discussions

with licensee personnel, the inspector found that this modification had

not been implemented. The inspector expressed concern that no action had

.been taken on this problem for so long. The' licensee acknowledged the

inspector's concern and stated that after the refueling outage emphasis

would be placed on identifying and completing these old moficiations. The

inspector will review licensee progress in this area during future

inspections.

The inspector reviewed the completed data sheets for procedure F-ST-39E,

"Drywell to Suppression Chamber Vacuum Breaker Leak Test," performed on

February 15, 1985. The purpose of this procedure is to determine the

total equivalent bypass area leakag'e (normally expected through the vacuum

breakers) between the Drywell and Suppression Pool. The test consists of

maintaining a specified differential pressure (1.0 psid) between the

Drywell and Suppression Pool and monitoring the rise in Suppression Pool

pressure over a ten minute period. The inspector noted that the results

of.the test were satisfactory and there were no indications of bypass

leakage. As discussed in paragraph 6. of Inspection Report No. 50-333/-

84-18, the inspector has previously determined that the licensee reviewed

plant data and concluded that there were no anomalies which could be

indicative of Suppression Pool vent header cracks. The inspector had also

previously reviewed Quality Control Inspection Report No. F84-057, which

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documented the visual inspections performed on portions of the vent

header, both inside and outside, including the nitrogen penetration to

suppression pool shell weldment. No cracks were.found during these visual

inspections. The inspector noted that no ultrasonic testing of the

nitrogen penetration was performed due to lack of baseline data.

Based on his review, the inspector concluded that the licensee implemented

the recommendations of SIL No. 402 regarding vent header cracking. As

noted above, the inspector's only concern was the licensee's failure to

implement the modification needed to provide low. temperature isolation

protection for the nitrogen makeup lines.

11. Review of Emergency Core Cooling Systems Subject

to Potential Overpressurization

The inspectors reviewed records and procedures and held discussions with

licensee personnel to evaluate the design features and administrative

controls that are used to minimize the potential for Emergency Core

Cociing System (ECCS) overpressurization.

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a. Verification of as-built isolation interfaces

The inspectors reviewed various drawings and Stone and Webster Line

Designation Tables to identify those systems which contain components

or piping with design pressures equal to or less than 70% of the

design pressure of the primary coolant system. The inspectors noted

that the High Pressure Coolant Injection (HPCI), Reactor Core Isola-

tion Cooling (RCIC), Residual Heat Removal (including the Low

Pressure Coolant Injection (LPCI) and Shutdown Cooling / Head Spray

Modes), and Core Spray (CS) Systems all contain such high/ low

pressure interfaces. Additional details on the component configur-

ation and the design high and low pressures can be found in attach-

ment A to this report.

The inspectors also.noted that, with respect to these systems, LPCI,

l CS, HPCI and RCIC all have testable check valves (valves 10-A0V-68A

i and B, 14-A0V-13 A and B, 23-A0V-18, and 13-A0V-22 respectively).

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The air operators on these valves are maintained operable and are

used only during cold shutdown to verify operability of the check

valve as required by Technical Specifications.

The inspectors determined that for each of the systems with a test-

able check valve, the air operated check valve (A0V) and the first

motor operated valve (MOV) (a normally closed valve) upstream of the

A0V provide isolation for the high and low pressure interface. The

second MOV (a normally open valve) upstream of the A0V can also be

i used to provide the isolation function. For Head Spray, the isola-

i tion function is provided by a check valve and the normally closed

l inboard and outboard containment isolation MOV's. For Shutdown

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C:oling, the isolation function is provided by the normally closed

l inboard and outboard containment isolation MOV's.

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The inspectors focused their review of surveillance and maintenance

activities on the " isolation valves" identified above which normally

maintain isolation for each high/ low pressure interface as well as

those valves which could be used to provide the isolation function.

b. Surveillance Activities

The inspectors reviewed the various surveillance test procedures

listed in attachment B and held discussions with licensee

personnel to determine the surveillance activities that apply to

the isolation valves at each high/ low pressure interface. The-

inspectors noted that there are several surveillance tests which

are conducted to test the operation of the isolation valves for

each ECCS system and RCIC. The inspector also noted that,

although there is considerable overlap with ASME Section XI, the

frequency of the tests are usually determined by the Technical

Specifications which are more restrictive. The following is a

summary of the surveillance testing performed on the isolation

valves:

1. A valve operability test is performed once a month to verify

the valves operate correctly when cycled from the control room.

When performing this test on CS or RHR the plant may be at power

or shutdown. For HPCI and RCIC'the plant must be at power with

steam available.

2. A system automatic actuation test is performed once a cycle

by inputing simulated signals and ensuring the systems respond as

appropriate. When performing this test on CS or RHR the plant

must be shutdown and depressurized as the isolation valves are

operated. For HPCI and RCIC the test is performed at power with

the pump discharge lined up to the Condensate Storage Tank and

with the inboard isolation shut and power removed.

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3. A system logic functional test is performed every six months

by inputing simulated signals and assuring that the system logic

functions properly. The plant may be operating or shutdown when

testing CS or RHR. The plant is at power when testing HPCI and

RCIC. During this test the inboard isolation valve (for each

system) is shut with the power removed.

4. Local Leak Rate Testing is performed on all isolation valves

(except for the HPCI and RCIC testable check valve and outboard

isolation valve) each refueling outage.

5. The CS, RHR, HPCI and RCIC testable check valves are cycled

j each cold shutdown greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if not done within the

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The inspectors noted that the preceutions associated with the sur-

veillance tests are.not uniform. Several of the tests contain

precautions concerning opening both isolation valves simultaneously

while a few others caution to ensure steps are followed in proper

sequence. Some of the tests contain no precautions concerning the

isolation valves. The inspectors also noted that the precautions

appear to be concerned with the possibility of injecting water into

the reactor vessel rather than.the potential for ECCS overpressuri-

zation. However, the inspectors determined that the sequence of the

test procedures (consisting of concise, specific, and identifiable

steps each of which requires a verification signature on the data

sheet) minimizes the potential for ECCS overpressurization.

The inspectors also noted that, in some of the tests, the

interlock between the isolation valves for the low pressure ECCS

systems is bypassed when simulated pressure signals are inputed.

Inadvertent valve operation is presented during these tests by

removing power to the valve operators. The inspectors determined

that, if a jumper is installed or an interlock bypassed, the

procedure ensures that the system is returned to normal at the

completion of testing.

The inspectors noted that the training for operators, with respect to

the isolation valves, has basically consisted of. placing industry

information on valve problems (IE Information Notices, INPO SOER's

etc.) in the required reading book. There is no specific training on

the surveillance testing of these violation valves.

c. Maintenance Activities-

The inspectors reviewed maintenance procedures, work requests and

Licensee Events Reports to determine the maintenance activities and

practices that apply to the isolation valves and their operators.

Based on this review and discussions with licensee personnel, the

inspectors noted that, in general, the licensee has not performed

preventive maintenance on the isolation valves. However, the

licensee indicated that a preventive maintenance program for all

safety related motor operated valves (M0V's) would be implemented in

the near future. This program would include items such as changing

grease and checking torque switch settings on a periodic basis. With

the exception of a few failures of valve motors and air operated

solenoid valves, the inspectors noted that the majority of corrective

maintenance on the isolation valves was due to Local Leak Rate Test

failures, body to bonnet and packing leaks, problems with torque

switch settings, and position indication failures. The frequency of

the maintenance varied for the isolation valve involved.

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Some valves required very little maintenance while others, such as

the RHR, CS and RCIC testable check valves and both shutdown cooling

isolation valves, required considerable maintenance.

Only one modification (other than environmental qualification

. upgrading) has been completed on these isolation valves. This modi-

fication was. initiated to resolve recurring maintenance problems on

the inboard Shutdown Cooling (SDC) isolation valve and involved

rerouting the SDC line (to provide easy access to the valve for

-maintenance) and installing a new valve. Another recurring problem

has been the failure of the disc position indication on the RHR and

CS testable. check valves (3 out of 4 are currently inoperable). The

licensee has decided not to maintain these indicators operable due to

the frequency of failures and ALARA considerations. As a result the

licensee uses actuator arm and valve stem movement to verify opera-

tion during required surve.illance testing. The licensee has also

recently implemented procedure TOP-72, " Verification of Disk Position

for. CS and RHR Testable Check Valves," to verify these valves

(without position indication) are shut following t,esting by

monitoring the pressure lag across the valve during a reactor

startup.

The inspectors reviewed the maintenance procedures, (listed in

attachment B) used on the isolation valves and determined that

they were adequate. The inspectors noted that there are separate

procedures for maintenance on motor operators, pneumatic valve

operators, check valves, and gate valves. Each procedure contains

Quality Control inspection hold points including in the area of post

maintenance testing. In general, the post maintenance testing

section of each procedure requires cycling the valve several times to

verify proper. actuator and/or valve operation. Following valve main-

tenance, the licensee's Work Activity Control Procedures raquire the

operations department to perform any additional testing to verify the

valve meets the Technical Specification requirements (stroke time,

leak rate, etc.) before declaring the valve operable.

Although not related to the industry problems with the isolation

valves, the inspectors noted that maintenance personnel (Electricians

and Mechanics) have received training on valve maintenance from valve

vendors within the last two years. The inspectors noted that the

amount of corrective maintenance on all safety related valves appears

to be declining and the licensee attributes part of it to this

training.

d. Conclusion

The inspectors noted that the licenree has one design feature which

would provide early indication of an ECCS overpressurization.

Specifically, the Core Spray System is annunciated and provides an

alarm (Core Spray System A (B) High Pressure Valve Leakage) if the

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pressure upstream of the inboard injection valve increases to 450

psig, indicating leakage by the inboard and testable check valves.

In addition, the inspectors noted that, in response to industry

operating experience regarding previous isolation valve problems, the

licensee now has the auxiliary operator monitor and log (shiftly)

HPCI and RCIC casing temperatures which would increase if there was

backleakage through the isolation valves. The auxiliary operators

are also required to tour (at least once per shift) the areas con-

taining the ECCS and RCIC systems to identify and log any abnormal-

ities some of which, such as CS and RHR system relief valve lifting

or excessive pump seal leakage, may be indicative of a backleakage

problem.

Based on the records reviewed and discussions with licensee per-

sonnel, the inspectors determined that there does not appear to have

been any instances of actual overpressurization of the low pressure

ECCS piping or components. The inspectors also determined that the

maintenance and surveillance procedures reviewed appear adequate to

minimize the potential for such an event.

12. Followup on a 1.icensee Event

On April 21, 1985, while preparing to remove a fuel support piece to allow.

uncoupling control rod 10-35 from the refuel floor, the licensee inadver-

tently lifted a fuel bundle (at location 7-36) out of the reactor core.

The operators had just lowered the fuel support grapple, which was

attached to the frame mounted hoist, to the upper grid. When they-

operated the engage button to allow the grapple to pass.through the upper

grid, an air leak developed which obscured the operators' vision. The

grapple was raised to determine the source of the air leak. As it was

being raised the air leak stopped after the operator cycled the engage and

disengage buttons. When vision was restored, the operators noted that a

fuel bundle had been caught on one of the grapple lock levers and had been

lifted completely out of the core. The operators immediately stopped

grapple motion and informed the control room. The inspector noted that,

prior to and during this event, the licensee had the Standby Gas Treatment

System operating and the reactor building ventilation isolated. During

the event the licensee also evacuated unnecessary personnel from the

Reactor Building. Additional supervisory and management personnel

reported to the refuel floor.

The licensee secured the fuel bundle to the refuel bridge using a "J" hook

and rope. The fuel bundle was then raised using the frame mounted hoist-

and transferred to the Spent Fuel Pool. The inspector noted that the

bundle always remained underwater and that there was no change in the

refuel floor radiation readings monitored during the event. When the

bundle was lowered into a rack in the Spent Fuel Pool, it. slipped off the

grapple lock lever and had to be-manually lowered using the "J" hook and

rope. The fuel bundle was subsequently inspected by the licensee and

General Electric personnel and found undamaged. The licensee counseled

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all operators on this event and cautioned them to immediately stop all

in-vessel operations when visual contact is lost. The event was also

reviewed by the Plant Operations Review Committee who concurred and

approved of the actions'taken. Based on discussions with the operators

and management personnel involved, and on a review of Technical Specifi -

cation and Emergency Plan requirements, the inspector determined that the

licensee's actions were appropriate and had no further questions regarding

this event.

13. Relocation of the Emergency Operations Facility (EOF)

In a letter dated April 3,1985, the licensee informed Region I that they

planned to begin transferring equipment from the existing EOF at the

Information Center to the nearly completed permanent facility at the

Fulton County Airport on May 1, 1985. During the one month interval-

estimated for the transfer, Emergency Plan activation would necessitate

that EOF functions be carried out from the Technical Support Center (TSC)

until equipment was transferred back to the Visitor Center. A review of

the Emergency Plan and the associated implementing procedures indicates

that the TSC is formally tasked with carrying out the responsibilities of

the EOF until that facility is fully activated and the TSC is relieved of

those duties. The inspector verified that personnel had been designated

to retrieve and set up the equipment if activation was necessary during

the transition period. The reactor will be shut down until approximately

May 15, 1985 to complete a refueling / maintenance outage. The plans for

the transition to the new EOF were acceptable. The inspector had no

further questions in this area.

14. Review of Periodic and Special Reports

Upon receipt, the inspector reviewed periodic and special reports. The

review included the following: Inclusion of information required by the

NRC; test results and/or supporting information consistent with design

predictions and performance specifications; planned corrective action for

resolution of problems, and reportability and validity of report informa-

tion. The following periodic reports were reviewed:

.

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March 1985 Operating Status Report, dated April 9,1985.

4

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April 1985 Operating Status Report, dated May 7, 1985.

15. Exit Interview

At periodic intervals during the course of this inspection, meetings were

held with senior facility management to discuss inspection scope and

findings. On June 7,1985, the inspector met with licensee represen-

tatives (denoted in paragraph 1) and summarized the scope and findings of

the inspection as they are described in this report.

.

Based on his review of this report, the inspector determined that this

i report does not contain information subject to 10 CFR 2.790 restrictions.

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Attachment A

Component Configurations

The systems listed below were noted to contain components on -

piping with design pressures equal to or less than 70% of the

design pressure of the primary coolant system.

'

1) Interfacing system: Core Spray

Piping location: In

Number of. Penetrations: 2 Penetration diameter: 10 inches

Component lineup:

RPV-MV-AOCK-I-MOV-MOV-H/L-PRV-CK-P

LO' NC NO

Low Pressure (psig): 400

High Pressure (psig): 1250

2). Interfacing system: Low Pressure Coolant Injection (RHR)

Piping location: In

Number of penetrations: 2 Penetration diameter: 24 inches

~

Component lineup:

RCS-MV-AOCK-I-MOV-MOV-H/L-PRV-MOV-MV-CK-P

L0 NC NO NO NO

,

Low Pressure (psig): 325

High Pressure (psig): 1380

3) Interfacing system: Head Spray (RHR)

Piping location: In

Number of penetrations: 1 Penetration diameter: 4 inches

Component lineup:

RPV-CK-MOV-I-MOV-H/L-PRV-CV-PRV-MOV-MV-CK-P

NC NC NO LO

Low Pressure (psig): 320

High Pressure (psig): 1250

4) Interfacing system: Shutdown Cooling (RHR)

Piping locations: Out

Number of penetrations: 1 Penetration diameter: 20 inches

Component lineup:

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RCS-MV-MOV-I-MOV-H/L-PRV-MOV-P

L0 NC NC NC

Low Pressure (psig): 150

High Pressure (psig): 1250

5)' Interfacing system: High Pressure Coolant Injection

Piping. location: . In

Number of' penetrations: 1 Penetration diameter: 14 inches

Component lineup:

RPV-MV-CK-I-AOCK-MOV-MOV-P-H/L

N0 NC NO

Low Pressure (psig): 100

High Pressure (psig): 1320

6) Interfacing system: Reactor Core Isolation Cooling

Piping location: In

Number of penetrations: 1 Penetration diameter: 4 inches

Component lineup:

RPV-MV-CK-I-AOCK-MOV-MOV-P-H/L

NO NC NO

Low Pressure (psig): 60

High Pressure (psig): 1320

Abbreviations on this Attachment

AOCK - Air Operated Check Valve

. CK - Check Valve

CV - Control' Valve

H/L High/ Low Pressure Interface

I - ~ Containment Penetration

IN - Flow Toward Reactor

LO - Locked Open

MOV - Motor Operated Valve

MV - Manual Valve

NC'- Normally' Closed

NO - Normally Open

OUT -~ Flow From Reactor

-P - Pump

PRV - Pressure Relief. Valve

RCS - Reactor Coolant System

RPV - Reactor Pressure Vessel

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Attachment B

Procedures Reviewed

The following procedures were. reviewed as part of the evaluation of the

licensee's surveillance and maintenance' activities on those valves which

isolate primary coolant from low pressure ECCS piping and components.

1) Maintenance Procedures

--

MP-59.3, Limitorque Motor Operators - SMB Model, Revision 3,

dated November 7, 1984.

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MP-59.4, Maintenance Procedure for Pneumatic Valve Operators,

Revision 1, dated January 10,'1985.

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.MP-59.10, Maintenance Procedure for Non-Pressure Seal Style

Gate Valves, Revision 1, dated January 16, 1985.

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MP-59.12, Maintenance Procedure for Non-Pressure Style Swing &

Piston Check Valves, Revision 0, dated August 29, 1984.

2)' Surveillance Procedures

--

F-ST-2C, RHR MOV Valve Operability' Test, Revision 13, dated

November 7, 1984.

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F-ST-2F, LPCI and LPCI MOV Power Supply Simulated Automatic

Actuation Test and LPCI Battery Service Test, Revision 15,' dated

April 10, 1985.

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F-ST-2G, RHR Isolation Valve Control Logic System Functional

Test, Revision 13, dated April 17, 1985.

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F-ST-2H, LPCI Subsystem Logic System Functional Test, Revision

12, dated April 17, 1985.

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F-ST-2P, RHR Shutdown Cooling and Head Spray Simulated

Automatic Isolation Test, Revision 8, dated April 10, 1985.

--

F-ST-2S, Valve Testing - Residual Heat Removal, Revision 7,

dated December 14, 1983.

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F-ST-3A, Core Spray / Flow Rate / Valve Operability Test, Revision

17, dated December 19, 1984.

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F-ST-38, Core Spray Simulated Automatic Actuation Test,

Revision 8, dated April 10, 1985.

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F-ST-3J, Core Spray Subsystem Logic Functional Test, Revision

12, dated April 17, 1985.

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F-ST-3M, Valve Testing - Core Spray System - Cold Shutdown

Only,-Revision 3, dated May 19, 1982.

--

F-ST-4A, HPCI Simulated Automatic Actuation Test, Revision 12,

dated April 10, 1985.

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F-ST-48, HPCI Flow Rate /HPCI Pump Operability /HPCI Valve

Operability Tests, Revision 19, dated January 3, 1985.

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F-ST-4E, HPCI Subsystem Logic System Functional Test, Revision

19, dated April 10, 1985.

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F-ST-4H, RCIC/HPCI Valve Testing, Revision 8, dated August 17,

1984.

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F-ST-24, ISI RCIC Valve Testing, Revision 6, dated April 18,

1984.

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F-ST-24A, RICI Pump and Valve Operability / Flow Rate Test,

Revision 17, dated January 3, 1985.

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F-ST-24E, RCIC Simulated Automatic Actuation Test, Revision 9,

dated April 10, 1985.

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F-ST-398, Type "B" & "C" LLRT of Containment Penetrations,

Revision 14, dated March 20, 1985.

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F-ST-39J, Leak Testing of RHR and Core Spray Testable Check

Valves ~, Revision 0, dated May 18, 1983.

3) Miscellaneous Procedures .

--

TOP-72, Verification of Disk Position for CS and RHR Testable

Check Valves, Revision 0, dated May 24, 1985.

--

WACP 10.1.1, Procedure for Control of Maintenance, Revision 9,

dated September 28, 1984.

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NRC Form 6 Rev. Oct. 80

Transaction Type

New Item OUTSTANDING ITEMS FILE

_x_ Modi fy SINGLE DOCKET ENTRY FORM

Delete

Docket Number Doerflein Linville

50-333

Originator Reviewing Supervisor

Item Number Type Module # Area Resp. Action Due Date Updt/Close Date 0/M/C

77-26-06 85-09-0 85-05-31

Originator Modifier / Closer

'Doerflein

Description:

Item Number Type Module # Area Resp. Action Due Date Updt/Close Date 0/M/C

83-04-03 85-09-0 85-05-31

Originator Modifier / Closer

Doerflein

Description:

Item Number Type Module # Area Resp. Action Due Date Updt/Close Date 0/M/C

---

Originator Modifier / Closer

Description:

Item Number Type Module # Area Resp. Action Due Date Updt/Close Date 0/M/C

- -

Originator Modifier / Closer

Descript. ion:

IR FITZ 85-09 - 0029.0.0

06/19/85