IR 05000254/1994008
| ML20029D100 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/28/1994 |
| From: | Dunlop A, Gardner R, Mendez R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20029D081 | List: |
| References | |
| 50-254-94-08, 50-254-94-8, 50-265-94-08, 50-265-94-8, GL-89-04, GL-89-4, NUDOCS 9405040032 | |
| Download: ML20029D100 (15) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Reports No. 50-254/94008(DRS); 50-265/94008(DRS)
Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30 Licensee: Commonwealth Edison Company Executive Towers West III 1400 Opus Place - Suite 300 Downers Grove,-IL 60515 Facility Name: Quad Cities Nuclear Power Station - Units 1 and 2 Inspection At: Quad Cities Site, Cordova, IL i
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Inspection Conducted: March 7-25, 1994 j
Telephone Exit: April 11, 1994 I
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l Inspectors:
u, it V-2APV A. Dunlop
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Date l
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$~ E S VY
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i R. Mendez
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Date
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Accompani.ed By:
L. Sage, Illinois Department of Nuclear Safety March 7-11 and 21-25, 1994
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Approved By:
l R. N. Gardner, Chief Date Plant Systems Section i
t Inspection Summary l
Inspection conducted March 7-25. 1994 (Reports No. 50-254/94008(DRS):
No. 50-265/94008(DRS))
l Areas Inspected: Announced safety issues inspection of the licensee's l
incorporation of Generic Letter-(GL) 89-04, " Guidance on Developing Acceptable Inservice Test Programs," into the Inservice Testing (IST) Program l
l (TI 2515/114), the licensee's program on check valves (TI 2515/110), the j
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Iicensee's self-assessment in these areas, and follow-up of licensee actions
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i to previously identified items.
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Results: Two violation were identified during the inspection concerning the j
failure to adequately test several valves included in the IST program 9405'040032 940428 '
PDR ADDCK 05000254 O
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Inspection Summary
j (Paragraph 2.d.(1)) and the failure to implement corrective actions when a valve did not meet its seat leakage acceptance criteria (Paragraph 2.d.(5)).
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. One deviation was identified concerning not incorporating a high pressure
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coolant injection check valve in the IST program per a commitment to a j
violation (Paragraph 2.b.(3)). One inspection follow-up' item (IFI) was identified concerning the inclusion of several' pumps with safety functions in
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the IST program (Paragraph 2.b.(1)). Based on this inspection, TI 2515/114 and TI 2515/110 are considered closed.
The inspection identified the following strengths and weaknesses:
Implementation of the IST program was considered weak based on the
number of valves with rafety functions that were not adequately tested.
For example, several c..tck valves were not tested in accordance with the guidance contained in GL 89-04.
The implementation of the third 10-Year IST program was not timely in
that procedures were not revised to incorporate the requirements-of the 1986 ASME Code by the program implementation date.
The quality verification program did not identify the significant a
problems with the implementation of the IST program.
The commitment tracking system appeared weak in that corrective actions a
were not implemented by the required date as stated in response to an NRC violation, The check valve program was considered good. The use of a
disassembly / inspections and non-intrusive testing provided useful
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indications of valve conditions.
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TABLE OF CONTENTS Paae 1.
Persons Contacted..............................................
2.
Inservice Testing (IST) of Pumps and Valves....................
I a.
Implementation of the Third 10-Year IST Program..........
b.
Scope....................................................
c.
Pump Testing.............................................
d.
Va l v e Te s t i n g............................................
e.
Trending.................................................
f.
Test Observations........................................
3.
Check Valve Program............................................
a.
Scope....................................................
b.
Design Application Review................................
c.
Preventive Maintenance...................................
d.
Inservice Testing........................................
4.
Li cen s ee Sel f-As ses smen t.......................................
5.
Follow-up of Previously Identified Inspection Items............
6.
Inspection Follow-up Items.....................................
7.
Exit Meeting...................................................
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DETAILS
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1.
Persons Contacted-Commonwealth Edison Company (CECO)
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R. Pleniewicz, Site Vice President-
- G. G. Campbell, Station Manager L. J. Tucker, ' Technical Services Super.intendent T. M. Kroll, Maintenance Superintendent
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R. J. Moravec, Engineering and Nuclear Construction Site Manager
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H. J. Hentschel, Operations Manager
- D. Winchester, Site Quality Verification Director
- M. Hayse, Site Quality Verification Audit Supervisor
- J. Burkhead, Site Quality Verification Program Supervisor
- D. VanPelt, System Engineering Supervisor
- A. M. Scott, System Engineering
- R. Baumer, Regulatory Assurance NRC Coordinator
- M. Richter, Engineering and Nuclear Construction
- D. W. Zebrauskas, Corporate Inservice Testing Coordinator J. A. Vega,. Corporate Check Valve Coordinator
- G. Knapp, Inservice Testing Coordinator.
- S. Aiken, Inservice Testing Group-Leader
- P. Yost, Check Valve Coordinator
- S. Childers, Operations D. Kunzmann, System Engineering
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Hartford Steam Boiler l
- G. Bosley, ANI/ANII
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VECTRA K. R. Heorman, IST Support Illinois Department of Nuclear Safety (IDNS)
- L. Sage, Head, Code Compliance Section
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U. 'S. Nuclear Reaulatory Commission (NRC)
- C. Miller, Senior Resident Inspector T. E. Taylor, Senior Resident Inspector R. K. Walton, Resident Inspector
- P. Prescott, Resident Inspector
- Denotes those personnel attending the exit meeting on March 25, 1994.
- Denotes those personnel involved in the telephone exit on April 11, 1994.
2.
Inservice Testina (IST) of Pumos and Valves The inspectors reviewed IST procedures and completed IST surveillances.
The _ test frequencies and acceptance criteria were normally specified and
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l provisions were made for prompt operability determinations.
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the methods used for the testing of pumps were adequate; however, several concerns were identified in the area of valve testing. Areas i
reviewed are discussed below.
a.
Implementation of the Third 10-Year IST Proaram The third 10-year program was based on the requirements of the American Society of Mechanical Engineers (ASME) Boiler and l
Pressure Vessel Code (the Code),Section XI, 1986 Edition.
The program was submitted to the NRC on January 7, 1993, with a
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scheduled implementation date of February 18, 1993, for both units. Due to~ the submittal timing, a Safety Evaluation Report (SER) was not issued prior to the program implementation date and l
was further delayed by concerns identified with the IST program by l
the NRC Diagnostic Evaluation Team (DET) in 1993.
l The program implementation was. considered weak based on the number l
of inadequate test procedures.
In addition, several test l
procedures were not revised or written to perform testing as required by the updated program. Management support in this area
l did not ensure that the updated program was implemented in a l
timely manner, nor was there adequate oversight to ensure that the
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test procedures verified valve safety functions.
This weakness in program implementation resulted in numerous safety-related valves not being tested in accordance with the
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Code. Although no operability issues were identified from the
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inadequate testing concerns that require immediate actions, the testing necessary to comply with the Code for the testing deficiencies identified in Violation 254/265-94008-03, Deviation 254/265-94008-02, and other commitments in the report will be performed prior to returning Unit 1 to service from its current refueling outage.
In addition, quarterly testing required by these items should commence as soon as possible for Unit 2.
Action was in progress to resolve program implementation concerns.
These actions, based on the results of the DET, included an independent assessment of the IST program by outside contractors and supplementing the IST staff. The assessment was to verify that components performing a safety function uere included in the program, IST test procedures were adequate, and development of an
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IST basis document.
In January 1994, the assessment commenced with an April completion date to support the submittal of a revised IST program.
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Scope l
Selected plant systems were reviewed to ensure adequate program scope in accordance with the Code Section XI requirements.
Technical Specifications (TS), Updated Final Safety Analysis Report (UFSAR), NRC Safety Evaluation Report (SER), and Emergency Operating Procedures (E0Ps) were also reviewed to evaluate the program scope. The following issues were identified:
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(1)
The high nressure coolant injection (HPCI) auxiliary oil pumps and the keep fill system pumps appeared to have safety-related functions although they were not. included in the IST program. These safety functions were to operate the HPCI steam inlet stop valves and to maintain the emergency core cooling system (ECCS) discharge piping filled with water to prevent a water hammer event when the pumps were started, respectively. A review was in process'to. determine if inclusion in the IST program was required. This is considered an inspection follow-up item (IFI) (254/265-94008-01) pending the licensee's' review.
(2)
Cold shutdown justification CS-23A for HPCI steam supply valves 1(2)-2301-4, 5 was not supportable. The
. justification stated, "These valves should remain in the open position to ensure _that' steam will be supplied to the HPCI turbine.... Closing these valves during normal operations places the system in an uncertain situation."
These valves, however, were closed during normal operations on a quarterly basis to test valves 1(2)-2301-3.
The licensee agreed that the justification was not valid and the
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valves could be tested quarterly. The licensee committed to revise the test procedure and update the IST. program to require quarterly testing.
(3)
HPCI pump suction check valves 1(2)-2301-39 had a safety
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function in the closed direction that was not included in
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the IST program. This issue was the subject of previous violations (254/265-93005-1 and 254/265-93005-2). The licensee's response to these violations, dated March 29,
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1993, stated the corrective action would incorporate the
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closed safety function into the IST program by September 30, 1993. However, the closed safety function for 1(2)-2301-39 was not incorporated in the IST. program nor was testing
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being conducted at the time of the inspection. This is considered a deviation (254/265-94008-02) from an NRC commitment.
The licensee's tracking system had identified the corrective action completion date as stated in the response; however, the system did not distinguish that this was a commitment to the NRC and the date could not be changed without requesting an extension from the NRC.
The IST coordinator had delayed the response date to April 1, 1994, based on an assessment being conducted on the IST program to determine if the valves do have a closed safety function.
This determination was not complete at the end of this inspection.
(4)
The following discrepancies were identified in the IST program:
Containment isolation valves (CIVs) 1(2)-1001-23A/B,
26A/B, and 29A/B in the residual heat removal (RHR)
system required leak testing per Appendix J~and were
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not identified as category A in the IST program, even though all required testing was conducted.
The IST program did not identify a position indication
test was required for HPCI steam exhaust vacuum breaker isolation valves 1(2)-2399-40 and 41, although the test was performed.
The IST program did not identify a test was required
to _ verify the open safety function for HPCI steam
. exhaust vacuum breaker check valves 1(2)-2399-64, 65, 66, and 67, even though the test was performed.
The IST program identified a leak test for valve
1(2)-301-71 and a partial close test for_ valves 1(2)-2301-51 and 76 even though no test procedures existed. ' A further review by the licensee indicated these tests were not required and would be deleted from the program.
The licensee committed to revise the program during the next update to correct these discrepancies.
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c.
Pump Testina Several IST pump procedures were not revised to incorporate the vibration points required by O&M-6 committed to in the third 10-year update. The vibration data'was recorded, even though it did not have to be compared with the IST acceptance criteria.
Procedures will be revised to incorporate the required IST.
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vibration measurement points.
d.
Valve Testina In most cases, GL 89-04 guidance was incorporated into the valve IST program, with the exception of testing several check valves in the open and closed directions. Several examples were identified where this guidance was not adequately implemented.
This and other areas of concern are discussed below.
(1)
The following valves were identified with safety functions in the IST program although testing was either not performed or inadequate.
Failure to test these safety functions are considered examples of a violation of 10CFR50.55a (254/265-94008-03).
No test procedure was in place to quarterly test the e
open safety function of HPCI system vacuum breaker isolation valves 1(2)-2399-40 and 41 (254/265-94008-03a).
No test procedure was in place to quarterly test the
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closed safety function of service water system check valve to control room HVAC 1/2-5799-410.
This valve
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was previously identified during the NRC service water -
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1992 (254/265-94008-03b).
No test procedure was -in place to quarterly test the
open safety function of residual heat removal service water (RHRSW)- flow control valves 1(2)-1001-5A/58.
These valves were previously identified during the SWSOPI in 1992 (254/265-94008-03c).
No test procedure was in place to quarterly test the
partial open stroke for HPCI system check valves 1(2)-2301-50 and 75 as stated in relief request RV-00E (254/265-94008-03d).
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No' test procedure was in place to quarterly test the
- open safety function of the RHR pump minimum flow check valves 1(2)-1001-142A/B/C/D (254/265-94008-03e).
Test procedure QCOS 1000-6, " Quarterly RHR Pump
Operability Test," did not adequately verify that the
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RHR pump discharge check valves 1(2)-1001-67A/B/C/D were full open by passing the. maximum accident-flow rate of 4500 gpm through the valves. -The test.
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acceptance criteria for the valves was based on the pump acceptance. criteria, which could be less than the required 4500 gpm.
For example, the acceptance criteria was 3948-4284 gpm for pump 1A, 4324-4692 gpm-fcr pump 28 and 20, 3760-4080 gpm for pump 2C,'and 4230-4590 gpm for pumps 2A,-18, IC,-and 10.
During testing performed in February 1994, four check valves did not pass 4500 gpm (254/265-94008-03f).
Test procedure QCOS 1000-6, did not adequately verify
the closed safety function of the RHR pump minimum flow check valves 1(2)-1001-142A/B/C/D.
The test acceptance criteria for the. valves was based on the pump flow being acceptable (254/265/94008-03g).
Although the valves identified above should have been tested in accordance with the IST program, the valves were exercised on a periodic basis.to alleviate any operability concerns with the operating unit.
Since Unit 1 just
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commenced a refueling outage, the above valves need to be tested in accordance with the Code prior to returning the unit to service.
In addition, testing that can be conducted on a quarterly basis should commence as soon as possible on Unit 2.
The response to the violation should specifically address the time frame for having procedures in place and j
testing scheduled.
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(2)
The acceptance criteria used for stroke time testing of power operated valves was not in compliance with the methodology stated in 0&M-10.
Relief request RV-00D was submitted to perform stroke time testing using reference -
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a values versus the methodology committed to in the 1986 ASME Code.
10CFR50.55a(f)(4)(iv) stated that subsequent editions of the Code may be used provided that all related requirements of the respective editions were met.
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stroke time limits referenced in RV-000 were greater than those allowed by 0&M-10, Section 4.2.1.8.
In addition, the maximum stroke time was determined by multiplying the reference value by two, which for motor-operated valves would appear excessive.
The SER for the IST program also will address this issue and provide the guidance necessary for which related requirements need to be met for approval of the relief request.
(3)
The procedure for bench testing relief valves was not
updated to O&M-1 as committed to for the third 10-year program. The licensee committed to revise the procedure and perform the applicable testing to 0&M-1 for the current Unit 1 outage.
(4)
Valves 1(2)-1001-28A/B, 29A/B were not tested quarterly as stated in the IST program as the valves were included in the cold shutdown test procedure. The procedures were in process of revision to include the valves in the quarterly stroke test procedure. This was considered acceptable.
(5)
A concern was identified that prompt corrective action was not taken to repair a CIV after a local leak rate test (LLRT) indicated the valve was in the required action range.
On November 5,1992, standby liquid control (SBLC) check valve 1-1101-16 was tested and the leakage rate was measured to be 16 SCFH. The LLRT procedure QTS 100-63, " Local Leak Rate Test Procedure for the Standby Liquid Control CK 1 (2)-1101-15 and CK 1 (2)-1101-16," Revision 1, stated the required action range for individual valve leakage limit was
10.0 SCFH.
If the valve exceeded the required action range, then a Nuclear Work Request (NWR) and a Problem Analysis
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Data Sheet (PADS) shall be initiated. The procedure further stated that immediate corrective actions were required.
No NWR or PADS were initiated and no corrective action was
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taken to repair the valve or declare the valve inoperable.
The failure to take prompt corrective action to repair or evaluate the operability of valve 1-1101-16 is considered a violation of 10CFR50.55a (254/94008-04).
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In December 1993 the licensee determined, through discussions with a system engineer, that valve 1-1101-16 was not repaired because the engineer had concluded that 10CRF50, Appendix J, 0.6 La limit had not been exceeded.
In addition, the engineer deferred the work to give the station adequate time to modify or find an adequate replacement valve. The engineer, however, was not aware the IST limit
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had been exceeded. On December 29, 1993, the licensee issued a Problem Identification Form (PIF) to disposition the inoperability of valve 1-1101-16.
The licensee's
disposition was mainly based on the Appendix J limit and not i
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the IST limit. The licensee also issued a temporary procedure change to allow an increase in the action limit for valve 1-1101-16, from 10.0 SCFH to 20.0 SCFH. The limit
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would change back to 10.0 SCFH when the valve was repaired during the current refueling outage.
e.
Trendina
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The IST coordinator maintained pump and valve test data for comparison with previous test results.
Since the data was not done graphically, it was difficult to determine trends especially if reference values were changed. A computerized database to graphically trend pump and valve performance was.recently initiated. This should allow for easy interpretation and o mparison of test results to the appropriate alert and required action ranges, f.
Test Observation The inspectors witnessed the testing of the diesel generator fuel
oil transfer pump. The test procedure was properly followed, test i
equipment was in calibration, and the test was conducted in a l
professional manner. No concerns were identified-l 3.
Check Valve Proaram l
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Scope In response to INP0 SOER 86-03, " Check Valve Failures and Degradation," Architect Engineer Sargent & Lundy performed an j
evaluation for all Ceco stations that determined which check
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valves should be included in the program. This study was then incorporated into Corporate. Nuclear Operations Directive N0D-TS.9,
" Check Valve Directive," dated May 15, 1989. Ceco issued Revision 1 to the directive on February 20, 1992, which was subsequently incorporated into the present program delineated in
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QCAP 400-6, Revision 1, " Check Valve Preventive Maintenance Program."
i The scope of the check valve program (CVP) was consistent with the
.i SOER and had the proper amount of inanagement support. A discrepancy, however, was identified in QCAP 400-6. The SBLC check valves were not included in the program scope. A further review indicated that 90 check valves-were inadvertently omitted from the scope list. These valves had been reviewed as part of the generic NRC' audit findings at Byron station and were to be i
included as category C valves. A procedure change was initiated to correct the discrepancy.
There were approximately 398 valves in the CVP, including all the check valves which were in the IST program.. Valves were categorized into three priority levels based on the results of the design application review discussed in paragraph 3.b.
Priority level A valves (73) were determined to be the most likely to experience wear und should be disassembled and inspected (D/I).
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Priority level B valves (140) were less likely to experience wear or degradation, but still required monitoring by diagnostic testing.
Priority level C valves (185) did not exhibit failure i
characteristics, but would be periodically reviewed to determine if the priority level should be increased.
Program optimization had commenced to revise the preventive maintenance (PM) activities required for the check valves in the program. The optimization phase was based on a computer program that would rank the valve based on several factors to determine if the priority level should be increased or decreased. These factors included inspection results, diagnostic data, maintenance history, and safety significance. Several evaluations had been completed and were reviewed by the inspectors.
No concerns were identified.
During the NRC check valve audit at Byron Station in July 1991, several issues were discussed in the audit report dated September 13, 1991, concerning the program and corporate directive. The licensee's response to these issues, dated November 27, 1991, stated that three issues were generic and would be reviewed by September 1, 1992, for all Ceco stations.
The first issue concerned the generic exclusion of 2 inch diameter and smaller check valves from the check valve program without addressing criteria such as system cleanliness, operational frequency, chemical stressors or component wear. The second issue was that the corporate directive allowed the use of IST program testing as an indicator of check valve degradation in lieu of PM.
The third issue identified several CIVs greater than 2 inches in diameter that were in the IST program, but not included in the CVP.
These issues were adequately resolved at Quad Cities by increasing the program scope to include 2 inch and under valves and 18 larger CIVs, and not taking credit for IST results in lieu of PM activities.
Interactions between corporate and other Ceco stations were noted with the quarterly check valve coordinator meetings held to discuss CVP activities and to exchange information on check valve issues.
b.
Desian Aonlication Review The corporate directive included the study performed by Sargent & Lundy that determined which check valves should be included in the program. This study was developed from information in INP0 SOER 86-03 and EPRI report NP-5479,
" Application Guidelines for Check Valves in Nuclear Power Plants."
Included in this information was the development of a centralized check valve data base that will be maintained at the corporate level with input from the station. The study was based on criteria such as valve sizing, type, location / orientation, flow stability, and past history. Valves were categorized according to a check valve applicability matrix, where one axis of the matrix was flow stability and the other axis was system severity.
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l application matrix was used to classify each valve into one l
of five levels and then reduced to the three priority levels
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discussed in paragraph 3.a.
The D/I and diagnostic testing would be performed on a repetitive four outage cycle.
l Except for the generic issues identified.in the Byron audit,
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tFe engineering evaluation was determined to be comprehensive, considered appropriate vendor and industry data and information, _and provided a rational basis for screening potential problem valves from the total population of check valves analyzed.
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c.
Preventive. Maintenance l
Preventative maintenance of check' valves was divided into two parts: disassembly and inspection (D/I); and non-intrusive ~ testing (NIT).
A significant amount of D/I was identified as the PM requirement for the check valve program. The licensee was using the D/I to gather base line data on each valve. _ In addition, although the program did not require it, NIT was being performed on valves prior to and after D/I.
By performing both types of PM, the licensee should be able to validate the diagnostic testing results. This base line
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l information was being used for the CVP optimization phase to i
revise valve priority levels after obtaining sufficient data.
Non-intrusive testing of valves as implemented by QCTS 763-2, Revision 1, " Check Valve Acoustic Emission Testing,"
was used to examine for valve degradation. The acoustic monitoring system was used to identify the disc hitting the seat, backstop, or the side of the valve to detect possible
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hinge pin problems. Based on the results of NIT, several i
valves were to be D/I to verify if a problem exists.
Data
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from the monitoring equipment was analyzed by a computer program and stored for_ future reference and trending.
No formal trending program was in place although based on an upcoming revision to the corporate directive, trending guidance was being made available for incorporation into station programs.
Data which could be used in a trending program; however, was presently being recorded and analyzed.
j The check valve D/I station travelers were of sufficient detail and documented items such as whether valve discs traveled its
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full-stroke in both the as-found and as-left condition.
Based on the HPCI check valve problem discussed in paragraph 2.a.(2), the i
inspection data sheet was revised to include verification for proper mating of disc to seat surfaces, such as a blue or light check. The D/I identified valve internals that required replacement or cleaning to ensure the valve would continue to function as designed. The D/I performed identified several valve
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failures and a significant amount of corrective actions for valve
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degradation. All the appropriate actions required for these problems were adequately addressed.
The inspectors witnessed the D/I of two check valves in the HPCI system. The procedure was properly followed to inspect the valves. No concerns were identified with the valves' material condition.
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Inservice Testina of Check Valves Test procedures did not appear to follow the guidance contained in GL 89-04 to verify check valves were tested in accordance with the Code requirements.
Examples of not passing the maximum accident flow through the valve for an open exercise or some positive means of verifying cessation of flow for a closed test were discussed in i
Paragraph 2.c.(1) of this report.
4.
Licensee Self-Assessment The licensee's implementation of quality assurance (QA) audits in the IST area was weak. The licensee's audit methods were documented on field monitoring verification inspections reports which assessed the procedural adherence and were performance based.
No significant concerns were identified during the field monitoring inspection audits.
No formal or comprehensive QA audit of the IST program, however, had been performed since 1991. Consequently, the quality verification organization did not identify the valves with safety functions that were not adequately tested by the IST program.
The licensee stated that due to concerns raised by the DET, the next IST QA audit was scheduled for July 1994.
The lack of comprehensive QA audits in the IST area was considered a weakness.
5.
Follow-up of Previously Identified Inspection Items a.
(Closed)
IFI (50-254/265-94004-34(DRS))
This item concerned failure to test and repair high radiation sampiin<1 system valve 1-8941-705 (identified by the DET as a fire protection valve).
The valve was added to the IST program in March 1991 and successfully tested in June 1991. Subsequently, the valve would repetitively fail the surveillance and would require repairs.
As a result of obtaining incorrect parts and the low priority given the work request, the valve remained inoperable for almost 2 years. The valve was repaired, tested, and returned to service in December 1993. This item is considered closed.
b.
(Closed) Unresolved Item (50-254/265-92201-05)
This item
identified several valves in the safety-related service water
systems as not being included in the IST program. The valves were added to the program, however, two valves as discussed in Paragraph 2.d.(1) were not being t<tsted.
This item is considered closed as the incomplete portions of the item are now being tracked as part of violation 254/265-94008-04.
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c.
(Closed) Unresolved Item (50-254/265-94004-31) This item identified valves not being declared inoperable when they exceeded the non-Technical Specification stroke time limit.
No specific valves were identified in the DET report, so a review of all valve stroke time data was performed.
QAP 350-S4, Revision 6, " Power
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Operated Valve Surveillance Values," contained a maximum allowable
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stroke time limit alorg with the quarterly or cold shutdown test data.
In some cases it was noted that the measured stroke time exceeded the maxime.n allowable.
The licensee stated the trend data sheet, QAP L O-S4, should have been revised to delete the maximum allowaMe stroke times as they had been superseded by QAP 350-S10, "IST Valve Surveillance Acceptance Criteria Summary Sheet," den test results started to be compared with reference values. The out of tolerance data was then compared with the QAP
350-S10 acceptance criteria. Only one stroke time was identified within the required action range and that valve was properly
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declared inoperable. As a result of the DET finding, the trend j
data sheets and acceptance criteria summary sheets are now contained in QCAP 410-1, Appendix I and E, respectively, with only one maximum stroke time for each valve.
This item is considered closed.
d.
(Closed)
IFI (254/265-94004-24)
This item concerned the overall resolution of IST issues identified by the DET and actions taken in response to GL 89-04. This inspectiN reviewed the actions taken in response to the GL and concluded that generally the IST program had incorporated the GL guidance; however, several examples were identified concerning the inadequate testing of check valves that should have been identified and corrected based on the GL. As discussed in this report, the implementation of the IST program was considered weak and required significant actions to correct the identified concerns.
This item is considereo closed based on this inspection.
e.
(Closed) Unresolved Item (254/265-94004-30) This item concerned the high failure rate of RHR relief valves to pass lift setpoint tests. The root cause of the relief valve failures was not identified. The valves were replaced with either new, rebuilt, or repaired valves.
A Correct 1 Action Record (CAR) was initiated to address the relief valve problem and was closed in August 1992 based on a plan to test several valves during the Q2R12 outage. No RHR relief valves were tested during QlR12 or Q2R12 outages.
Several RHR relief valves were scheduled for testing during the Q2R12 outage; however, the testing was deleted when the outage scope was reduced. This was based on the valves being on a 5 year test cycle and tested in the previous outage. There was no correlation that the testing was to be performed as a result of the CAR and not the IST requirement. This is a similar example where corrective actions were not adequately tracked to ensure the item was completed as scheduled. This item is considered closed.
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i 6.
Inspection Follow-up Items Ins'pection follow-up items are matters which have been discussed with the licensee which will be reviewed further by the inspector and which involve some action on the part of the NRC or licensee or both. One inspection follow-up item was identified during this inspection and
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described in Paragraph 2.b.(1).
7.
Exit Meetina The inspectors met with licensee representatives (denoted in.
Paragraph 1) at the conclusion of the inspection cm March 25, 1994.
The (
inspectors re-exited with the licensee representatives (denoted in l
Paragraph 1) during a telephone conference on April 11, 1994. The.
l-inspectors summarized the purpose, scope and findings of. the inspection l
and discussed the -likely informational content of the. inspection report.
The licensee identified none of the documents or processes reviewed by -
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the inspectors during the inspection to be proprietary.
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