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| {{Adams | | {{Adams |
| | number = ML20207J189 | | | number = ML20211B874 |
| | issue date = 12/17/1986 | | | issue date = 01/27/1987 |
| | title = Insp Repts 50-335/86-25 & 50-389/86-24 on 861117-21.No Violations or Deviations Noted.Major Areas Inspected:Maint & Mod Welding,Inservice Testing Program for ASME Class 1,2 & 3 Pumps & Valves & Inspector Followup Items | | | title = Forwards Info Re Contractor Employee Concerns of Alleged Poor Procedure for Welder Certification & Discriminatory Release from Plant,Documented in Insp Repts 50-335/86-25 & 50-389/86-24.Statement Withheld (Ref 10CFR2.790) |
| | author name = Blake J, Crowley B | | | author name = Verrelli D |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| | addressee name = | | | addressee name = Woody C |
| | addressee affiliation = | | | addressee affiliation = FLORIDA POWER & LIGHT CO. |
| | docket = 05000335, 05000389 | | | docket = 05000335, 05000389 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-335-86-25, 50-389-86-24, NUDOCS 8701080332 | | | document report number = NUDOCS 8702190584 |
| | package number = ML20207J138
| | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 2 |
| | page count = 13 | |
| }} | | }} |
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| UNITE 3 STATES
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| /jeEtzgDo NUCLEAR REGULATORY COMMISSION y" g REGloN 11 g j 101 MARIETTA STREET. * 2 ATLANTA, GEORGI A 30323
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| Report Nos.: 50-335/86-25 and 50-389/86-24 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.: 50-335 and 50-389 License Nos.: DPR-67 and NPF-16 Facility Name: St. Lucie 1 and 2 Inspection Condu d: November 17-21, 1986 Inspect r: . @ :7 m -m /d-// 7/#6 B. //
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| r Date Signed Approved by: // . /f
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| , /fsc.'ti on Mef /2 /7 /2
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| 'Jf67 D6te Signed ginee g Branch Division of React ety SUMMARY Scope: This routine, unannounced inspection was in the areas of maintenance /
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| modification welding (Units 1 and 2), Inservice Testing (IST) Program for ASME Classes 1, 2 and 3 pumps and valves (Units 1 and 2), and inspector followup items (Units 1 and 2).
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| Results: No violations or deviations were identifie a0332 Sg,g g
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| {DR ADOCK O$000335 PDR
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| REPORT DETAILS Persons Contacted Licensee Employees D. A. Sager, Plant Manager
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| *L. W. Pearce, Operations Supervisor
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| *N. G. Roos, Quality control (QC) Supervisor
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| *S. C. Sanders, FP&L Welding Supervisor-Plant
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| *P. D. Waldrop, FP&L Welding Supervisor-Construction
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| *D. M. Stewart, Lead Test and Performance Engineer
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| *E.' B. Carlile, Project Field Engineering Representative
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| *P. W. Heycock, ISI Coordinator A. B. Johnson, Assistant Plant Engineer J. Eyer, QC Engineer R. t Miller, Quality Control Other licensee employees contacted included construction craftsmen, engineers, technicians, security force members, and office personne NRC Resident Inspector
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| * V. Crlenjak, Senior Resident Inspector
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| * Attended exit interview Exit Interview The inspection scope and findings were summarized on November 21, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license The following new items were identified during this inspectio (0 pen) Inspector Followup Item 335/86-25-01, 389/86-24-01, Review of Revised Welding Program paragraph (Open) Inspector Followup Item 389/86-24-02, Revision to Valve Stroke Testing Frequency Requirements paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio .
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| | JAN 2 71987 |
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| | Florida Power and Light Company WiTN: Mr. C. O. Woody Group Vice President Nuclear Energy Department P. O. Box 14000 Juno Beach, FL 33408 t Gentlemen: |
| | , SUBJECT: ST. LUCIE - CONTRACTOR EMPLOYEE CONCERN REGARDING WELDER CERTIFICATION PRACTICES BY CATALYTIC, IN (RII-86-A-0132) |
| | The enclosure to this letter documents information received on April 8,1986, during discussions between Region II personnel and a former contractor employe We are providing this for your informatio The concerned individual alleged poor procedure for welder certification and a discriminatory release from your St. Lucie Nuclear Power Plan NRC inspection of welding practices at St. Lucie have been conducte The results are documented in inspection reports 335/86-25, 389/86-2 The enclosure is not being placed in the Public Document Room at this tim Appropriate safeguards must be applied to the enclosed information to preclude the release of information which is exempt from disclosure under 10 CFR 2.79 According to the concerned individual, we understand that FP&L has been made aware of these concerns as a result of discussions with personnel working at the sit Therefore, we request that you provide us with the results of your investigation and evaluatio In order to ensure appropriate protection for the information, please mark the letter with your findings as containing "Information Exempt from Disclosure Under 10 CFR 2.790." Indicate on the envelope it is "T0 BE OPENED BY ADDRESSEE ONLY." |
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| | Please provide us with your response within 30 days of the date of this lette If you have any questions or comments concerning this matter, please feel free to contact me or Mr. Tom Nash, Regional Allegation Coordinator, at (404) 331-419 We appreciate your cooperation in this matte |
| 3. Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item 335/85-04-03, Testing of Category "C" Relief Valves. This item raised a question relative to the fact that originally, relief valves in systems other than the pressurizer and main steam systems were not in the licensee's IST program. Based on differing opinions and interpretations, it is not clear when the valves should have been added to the IST program. The valves have now been included in the program and are
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| being tested in accordance with code requirements. Procedure QI 11-PR/
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| PSL-7, Revision 1 covers testing of relief valves.
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| | Sincerely, ORKINAL SIGND BY DAVID M. VERRELU 870D7 David M. Verre111, Chief kNN$ UU00fy5 G Reactor Projects Branch 1 Division of Reactor Projects Enclosure: |
| 4. Unresolved Items Unresolved items were not identified during the inspectio . Maintenance / Modification Welding (55050 and 55100) (Units 1 and 2)
| | Statement of Concerns cc w/o enc 1: |
| The inspector examined the welding activities described below relative to maintenance / modification to determine whether applicable code and regulatory requirements were being met. In general, the licensee controlling documents are:
| | i)t'. N. Harris, Vice President St. Lucie Nuclear Plant H8C406URE CONTAM INRRHATO6 EXEMPT |
| Modification (Backfit) -
| | * * P' ' e P8"intendent HM3d Dl!20SURE UNDER 10CFR 9.790 . |
| FP&L Welding Control Manual, Revision 21 Maintenance -
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| General Maintenance (GM) Procedure M-0400, Revision 8, Welding Manual
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| Parts of the Welding Control Manual Implemented by GM Procedure M-0400 In accordance with these licensee documents, the following codes apply:
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| ASME Boiler and Pressure Vessel (B&PV) Code, Section XI, 1980 Edition, W81 Addenda
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| ASME B&PV Code, Section III, 1980 Edition, W80 Addenda
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| AWS Structural Welding Code D1.1, 1983 Edition Welding Material Control The inspector verified that the filler materials used for the welds l
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| observed (see paragraph 5.d.) were the correct materials specified by l the Welding Procedure Specification (WPS) and that in general, filler materials specified on WPS were compatible with specified base materials.
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| | | - JAN 2 71987 F1rodia Power and Light Company 2 bec w/ enc 1: |
| The inspector performed the following verifications related to control and handling of welding material:
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| | T. Nash bec w/o encl: |
| - | | MCResidentInspector Document Control Desk e |
| That the licensee had established procedures for purchasing receiving, storing, disbursing, and handling of welding material The applicable procedures are:
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| WTS-3, Revision 3, Weld Material Control GM Procedure M-0028, Revision 2, Welding Electrode and Filler Metal Control QP-4.1, Revision 18, Control of Procurement Originated by Operating Plant Personnel QP-4.4, Revision 18, Review of Procurement Documents for Items and Services Other Than Spare Parts QP-7.1, Revision 8, Receipt Inspection of Materials, Parts, and Components at the Plant Site QI-4.1, Revision 8, Procurement Document Control Construction Administrative Procedure ASP-6, Revision 5, Welding Control Engineering Department Specifications - MN Series
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| That receiving _ operations were conducted in accordance with applicable procedures. Purchasing and receiving records for the welding materials listed below were reviewed.
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| That welding material storage and handling procedures contained i
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| requirements for environmental control and that actual practice
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| followed. these requirements. The backfit rod issue station was
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| ! inspected and weld material control observed during observation of
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| welding (see paragraph 5.d below).
| | State of Florida thf405URE CONTAINS itWORMAtlON EXEMPi |
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| That there were effective procedures for maintaining identifica-l tion of welding materials and that procedures are aaforce Identification control was inspected during observatio: of welding (see paragraph 5.d below).
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| That the welding material control system met the requirements for
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| the most restrictive application and personnel involved were knowledgeable of the syste That the method of disbursement of welding materials was effective and controlled in accordance with approved procedure __
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| That required ASME Code tests were performed on each lot of welding materia The purchasing, receiving inspection and material certification documentation were reviewed for the following welding materials used for the welds listed is paragraph 5.d belo Size Iype Ht. N P.O. N /32" E7018 77871 90865-3884 3/32" E7018 33043 90865-79478B 1/8" E70S-2 065472 90865-65398 1/8" E70S-2 065415 90865-77385W 3/32" E70S-2 065433 90865-79937 1/8" ER316 L1861 43921-56890 1/8" ER308 98520 SL74-294 3/32" ER308 09735 SL75700 3/32"- ER4043 3809 22279-23010 3/32"- RCuAL G-7139 02471-79697A b. ' Welding Procedures The inspector determined if procedures had been established for preparation, qualification, approval / certification and revision of WPS The applicable procedures are:
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| WTS 6, Revision 2, Weld Procedure Qualification Requirements
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| WTS 1, Revision 0, Processing Change Requests To the Welding Control Manual
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| ASP-6, Revision 5, Welding Control Welder Performance Qualification (1) The inspector verified that procedures had been established for qualification and maintaining qualification status of welders and welding operators in accordance with ASME Code requirements. The applicable procedures are:
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| WTS 5, Revision 1, Welding Performance Qualification Requirements
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| (2) The inspector reviewed a sample of the qualification and qualification status records for the below listed welders relative to the welds listed in paragraph 5.d belo Welder LMAH LMAF LMAE LMAJ LFHQ LFOS LFMV (3) Welder LMAD was observed in the process of welding a test assembly to qualify for WPS 36.
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| (4) Completed and accepted radiography (RT) film for the following '
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| welder qualifications were reviewed:
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| Welder WPS
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| . LMAD WPS 89 LMAD WPS 9 LMAD WPS 5 LMAD WPS 43 Production Welding The inspector observed in process welding and reviewed in process records for the following welds:
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| Weld Size Category 2F-9-FP-0155-005-A 6" x .280" 8Y*
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| 2F-9-FP-0155-008 6" x .280" 8Y*
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| Traveler 86-859 2" sch. 40 8*
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| 2"-FP-62
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| * Category 8 welds were observed since no higher class welds were available for observation and all categories are welded to the same requirement Since no other welds were available for observation, the inspector reviewed completed records for the following welds:
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| Weld Size Category 2F-2-SI-0652-001 3" x .216" 3A 2F-2-SI-0652-002 3" x .316 3A
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| Traveler 86-779 -
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| Traveler 86-777 -
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| Traveler 86-695 -
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| Traveler 86-696 -
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| FW-1, 2, 3, 4, 5 and 6 Traveler 86-780 -
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| Traveler 86-782 -
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| Traveler 86-645 -
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| The welding was observed and the records reviewed to determine whether:
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| Work was conducted in accordance with a document which coordinates and sequences operations, references procedures, establishes hold points, and provides for production and inspection approval
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| Weld identification and location were as specified
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| Procedures, drawings, and other instructions were at the work station and readily available
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| WPS assignment was in acccrdance with applicable code requirements
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| Welding technique and sequence were specified and adhered to
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| Welding filler materials were the specified type and traceable to certifications
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| Weld joint geometry was in accordance with applicable procedure and was inspected
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| Alignment of parts was as specified
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| Preheat and interpass temperatures were in accordance with procedures
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| Electrodes were used to positions and with electrical characteristics specified
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| Shielding gas was in accordance with the welding procedure
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| Welding equipment was in good condition
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| Temporary attachments were removed in accordance with applicable procedures
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| Gas purging, if specified, was used in accordance with applicable procedures
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| Welders were qualified
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| No peening performed on root and surface layers
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| Weld inspection personnel were qualified Examination of the welding program, as detailed in the above para-graphs, revealed the following weaknesses in the program:
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| Welding Material Control - Backfit was working to procedure WTS 3 of the Welding Control Manual. Maintenance was working to General Maintenance Procedure M-0028. The following problems were identified with procedure M-0028:
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| * Paragraph 9.2.3 addresses exposure times for types E-7016, 7018, 8016, 8018, 9016 and 9018 electrodes. Exposure times for other coated electrodes are not addresse *
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| Paragraph 9.2.4 is not clea It appears that part of the paragraph has been left ou * Paragraph 9.2.7 does not specify any controls for portable rod oven * Paragraph 9.2.6 does not provide definitive instructions for use of the " Welding Rod Control Log."
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| * Based on discussion with the Welding Supervisor, return of unused welding material is not allowe The procedure indicates that unused material is to be returne Material traceability - Procedure is not clear about how material identification is maintained and transferred to the travele * Procedure has few definitive requirements.
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| Welder Qualification - Both backfit and maintenance are working to procedure WTS 5 of the Welding Control Manual. The following problems were identified with procedure WTS 5:
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| The procedure refers to WTSs 9.2, 9.3 and It appears these documents were never issue Paragraph 6.0 details a computerized system for maintaining welder qualifications curren Backfit is using the syste However, maintenance is using an informal manual log. The
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| log has inconsistencies since it is informal. Without tne use of the informal log, it is not possible to verify for certain that a welder has maintained his qualificatio * In paragraphs 6.6 through 6.9, the terms " Weld Currency Report" and " Welders Performance Qualification Report" are not clear. The frequency for issue of these two reports is not spacified. Maintenance is not using these two report * There is very little detail on the qualification proces ASME Section IX is referenced for details of testing, test assembly details, required NDE or mechanical testing, etc. Based on discussions with welding supervision, it is up to the welding supervisor to specify the details of testin The inspector pointed out that this method of operation leads to inconsistencies and errors. Some welding supervisors that are more experienced will be able to interpret code require-ments for testing, while less experienced welding supervisors might no The procedure does not contain requirements for positive identification of welder Details for qualification renewal when a welder.does not weld in the required three or six months (when welding with another process) are not clear. Requirements, including test assembly to be welded and how it is to be tested, need to be clarifie Weld Traveler - For Maintenance, process control is covered by Maintenance Procedure M-040 Instructions for processing Traveler need to be added to procedur Welding Procedures - Welding Procedure qualification is covered by procedure WTS 6 of the Welding Control Manual. Processing of WPS is not clearly covered by Procedure WTS Although a significant number of weaknesses were identified in the welding program, the inspector did not identify any code or procedure violation in observation of welding or review of completed record In addition, discussions with welding supervisor revealed that the licensee had identified weaknesses (many similar to those identified by the inspector) in the welding program and had initiated steps to correct the weaknesses prior to the current inspectio A Quality Improvement Team (QIP), for improvement of procedures and a Welding Improvement Team, for improvement of the welding program, had been formed. The purpose of the Welding Improvement Team was to correct known weaknesses in the welding program and to formulate a welding
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| program suitable for all FP&L entities, i.e., St. Lucie Maintenance, St. Lucie Backfit, Turkey Point, etc. The inspector reviewed internal licensee correspondence documenting formation of the Welding Improve-ment Team, the agenda for the team, and some identified welding program problems to be resolved by the team Inspector Followup Item 335/86-25-01, 389/86-24-01, Review of Revised Welding Program, is-opened pending review of the revised program to verify correction of known weaknesse Within the areas inspected, no violations or deviations were identifie . Inservice Testing (IST) Program For ASME Classes 1, 2, And 3 Pumps And Valves (Units 1 And 2)
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| The inspector examined the IST activities described below to determine whether regulatory and code requirements were being met. In accordance with the pump and valve program (submitted by FP&L letter L-80-136, dated May 1, 1980) and the Safety Evaluation Report (SER), dated April 2, 1985, the applicable code for Unit 1 is the ASME B&PV Code, Section XI,1974 Edition 4 S75 Addenda. In accordance with the pump and valve program (submitted by FP&L letter L-83-644, dated October 6,1983) and the SER dated January 13, 1986, the applicable code for Unit 2 is the ASME B&PV Code, Section XI, 1980 Edition, W80 Addend See RII . Reports 50-335/85-04, 50-389/85-04, 50-335/85-14 and 50-389/85-14 for documentation of previous inspections in this are For the current inspection, only changes to documents since the last inspection were reviewe The IST Programs are implemented by the following St. Lucie Administrative Procedures:
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| 0010132, Revision 7, "ASME Code Testing of Pumps and Valves"
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| 1-0010125, Revision 67, " Schedule of Periodic Tests, Checks and f Calibrations"~
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| QI 11-PR/PSL-7, Revision 1, " Control of Code Safety and Relief Valves" The above pro 9 rams and administrative procedures and the below listed l Quality Instructions (QIs) were reviewed for general content and to the
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| extent necessary to verify that the licensee had assigned responsi-bilities for: preparation, review and approval of IST procedures;
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| scheduling of IST; performance of test functions; performance of maintenance; and performance of calibration ,
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| QI 5-PR/PSL-1, Revision 29, " Preparation, Revision, Review, Approval of Procedures" b. The inspector reviewed procedures 1-0010125 and 2-0010125 and discussed scheduling with responsible personnel to verify that tests are scheduled at reauired frequencie The inspector found that Data Sheet 8 of procedure 0010125, used to schedule testing of valves to be stroke tested quarterly, has a " built-in" possibility of allowing the surveillance interval for an individual valve to exceed the Technical Specification requirement The Unit 2 Technical Specifications defines the ASME Section XI three month test frequency as 92 days and allows a 25 percent extension on the interval. In accordance with Data Sheet 8, valves are tested during the months of February, May, August, and November. The date an individual valve is tested is not recorded -
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| only the completion date of Data Sheet 8. Therefore, if a particular valve is tested at the beginning of the month for one quarter and at the end of the month the next quarter, the 92 day plus 25% surveillance interval will be exceeded by approximately one week. However, based on informal logs kept by QC and discussions with QC relative to the tight controls QC maintains over insuring that required schedules are maintained, it is unlikely that surveillance intervals have been violated. The licensee agreed that the procedures need to be revised to insure procedurally that surveillance intervals are not exceede Pending review of revised procedures, Inspector Followup Item 389/86-24-02, Revision to Valve Stroke Testing Frequency Requirements, is opene This problem is unique to Unit 2 in that the Unit 1 Technical Specifi-cations do not define surveillance intervals specified by ASME Section X The inspector reviewed the control room " Pump and Valve Summary" as listed below to verify that status lists were maintained and reflected properly scheduled test Unit 1 -
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| Data Sheet 8 - 1986 Data Sheet 9 - 1986 Data Sheet 10 - 1986 Data Sheet 11 - 1986 Routine Pump Test Summary - 1986 Unit 2 -
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| Data Sheet 8 - 2nd, 3rd, 4th Qtrs., 1986 Data Sheet 9 - 2nd, 3rd, 4th Qtrs., 1986 Data Sheet 10 - 1986 Routine Pump Test Summary - 2nd, 3rd, 4th Qtrs. ,1986 Based on a number of problems in the industry with check valves, a question has been raised relative to the need for testing check valves in both direction St. Lucie Unit 1 pump and valve' program SER states that when a check valve has two functions important to safety - to open under certain conditions and close under others, the exercising test must verify movement to the positions necessary to satisfy both of
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| these functions. ASME Section XI requires exercising to the position required to fulfill the valve function. During the current inspection, the question was discussed with licensee's engineering personnel. The following summarizes the discussion:
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| (1) FP&L was not aware of any check valves that require exercising in both directions to fulfill their safety functio (2) FP&L considers that the function of each valve should be reviewed and, -in addition to performing the required code tests, attempts should be made to perform any other testing / monitoring considered warranted from a safety / reliability standpoin (3) The inspector questioned the licensee relative to the following instances where the need to test check valves in both directions has been questione The questions and the licensee's responses are include The Auxiliary Feedwater Pump (AFW) have check valves that are tested to open to fulfill their function. The valves need to close to prevent hot water / steam from over heating the AFW pumps under certain condition The licensee pointed out that temperature of piping upstream of the check valves is monitored on a periodic basis to detect a heatup proble The . discharges to the Safety Injection -(SI) Tanks have two valves in series whose safety function i s to ope The valves are closed and isolate the lo,/er pressure SI tanks from the higher pressure reactor coolant during normal operation Therefore, performance of the valves in the closed direction is important to prevent over pressurization of the SI tanks. The licensee pointed out that to protect from overpressurization:
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| There is an alarmed pressure monitor between the two check valves There is an alarmed level monitor in the tank The valves are leak checked per Technical Specification requirement HPSI and LPSI' system pumps in parallel trains take suction from a common line and discharge into a common line. The pump discharge lines have check valves that open to fulfill their safety functio If the pump in only one train is operating and the check valve in the parallel non-operating line is not closed or has excessive leakage, the recircula-tion back through the non-operating check valve might cause
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| insufficient flow for the system to fulfill its functio The licensee pointed out that in addition to check valves, each discharge line has an isolation valve. Also, since the flow rate in each train is tested separately, in effect check valves are being checked for excessive backflow in that if the backflow through the non-operating train is excessive, the flowrate in the system will not be acceptable and the test will fai . 7. Inspector Followup Items (IFIs) (Units 1 and 2)(92701) (Closed) Inspector Followup Item 335, 389/85-14-01, Valve Stroke Time This item pertained to the fact that valve stroke times related more to system performance requirements rather than to veri fying the operational readiness of the valve The licensee has re-examined valve stroke times and revised the program to specify more realistic valve stroke time, (Closed) Inspector Followup Item 389/83-26-03, Augmented ISI of RCP to Pump Welds. This item pertained to reference in the SSER of the possibility of augmented ISI being evoked during initial review of the ISI program for reactor coolant loop to pump welds that could not be inspected 100% to ASME Section XI during Preservice Inspection. Relief Request No. 5 to the initial ISI program requested relief from code requirement for these welds. The SER dated October 10, 1986 approved the relief, request without augmented inspectio I L
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