IR 05000382/1988015

Insp Rept 50-382/88-15 on 880516-20 & 0606-09.No Violations or Deviations Noted.Major Areas Inspected:Inservice Testing Program for Pumps & Valves,Including Tracking Methodology for Inservice Testing,Test Procedures & Results & QA Audits

ML20151G368
Person / Time
Site:	Waterford
Issue date:	07/14/1988
From:	Barnes I, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151G365	List: IR 05000382/1988015 ML20151G363
References
50-382-88-15, NUDOCS 8807280314
Download: ML20151G368 (7)

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APPENDIX B  !

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U.S. NUCLEAR REGULATORY COMMISSION REGION'lV NRC Inspection Report: -50-382/88-15 Operating License: NPF-38 Docket: 50-382-

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Licensee: Louisiana Power & Light Company.(LP&L)

317 Baronne Street New Orleans, Louisian'a 70160 Facility Name: Waterford 3 Steam Electric Station (WAT)

-Inspection At: WAT, Taft, Louisiana Inspection Conducted: May 16-20 and June 6-9, 1988

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Inspector: / 8c%

k R. C. Stewart, Reactor Inspector, Materials 7-i + -P y Date ;

and. Quality Programs Section, Division of Reactor Safety i

Approved: /8%

I. Barnes, Chief. Materials and Quality

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7 -/ w -Pfr Date Programs Section, Division of Reactor Safety i

Inspection Sumary .

InspectionConductedMay16-20anditne 6-9, 1988 (Report 50-382/88-15)

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Areas Inspected: Routine, unannounced inspection of the inservice testing program for pumps and valves. Subject activities reviewed in'this area of the inspection included tracking methodology for inservice testing, test procedures and results, inservice testing trend reports, quality assurance audits, witnessing of inservice tests, and review of potential reportaole even Results: l'ithin the area inspected, no violations or deviations were identifie $$[ $Do$ g2 l

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DETAILS Persons Contacted LP{L

• P. Barkhurst, Vice President, Nuclear

• S. Carns, Plant' Manager

+* A. Alleman,. Quality Assurance (QA) Manager

• R. Gaines, Events Analysis Supervisor

+* A. Schultz, STA Supervisor

+ R. McGaha, N0E&C Manager

• S. Starkey, Operations Supervisor

• J. Harris, STA Operations

+*L. W. Laughlin, Licensing B. E. Meyers, Operations, QA J. J. Zabritski, Operations QA Manager The NRC inspector also interviewed other licensee employees during the inspectio * Denotes those attending the exit interview on May 20, 198 +0enotes those attending the exit interview on June 9,198 . service Testing (IST) Program - Pumps and Valves (MC73756)

The objectives of this inspection were' to evaluate the implementation of the WAT IST program for safety-related pumps and valves and to assess the adequacy of the testing performed with respect to the licensee commitments and guidelines of Section XI of the ASME cod IST Program Overview The NRC inspector ascertained from the IST program review that the WAT IST program for pumps and valves is subject to the requirements of 10 CFR 50.55a(g) and the ASME Boiler and Pressure Vessel Code,Section XI. Subsections IWP and IWV, 1980 Edition through winter 1981 addend The WAT final Safety Analysis Report (FSAR), Section 3.9.6 addresses the licensee connitments to the ASME Code requirements. These commitments are also referenced in Section 4.0.5 of the WAT Technical Specifications (TSs).

The licensee's administrative control document, "Pump & Valve Inservice Test Plan," describes the connitments for compliance with the ASME Code and ASME Code relief requests granted by NRR. The IST r

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- plan, initially issued in 1984, is currently being implemented under Revision 5 dated April 27, 198 In addition to the above, the NRC inspector reviewed Supplement 5, and related correspondence, of the Safety Evaluation Report (SER)

relative to ASME Code relief requests by the licensee and approvals granted by NRR. The NRC inspector concluded from his review that the WAT.IST program appeared to be reasonably structured, complete, and consistent with regulatory and ASME Code requirement There were no violations or deviations identified during the above revie Methodology Used in Implementing IST Program i

In assessing the method used by the licenses in controlling the test frecuencies, the NRC inspector observed that the IST program is administratively controlled by the Shift Technical Advisor (STA)

Department staff, utilizing Administrative Procedure UNT-7-020, "Pump and Valve Inservice Testing," Revicion 1, in conjunction with the

"Pump and Valve Inservice Test Plan" as the principal guideline procedure The pump and valve testing is integrated into the plant operations TS surveillar.ce requirements and maintained by a master surveillance computer progra The STA coordinator is responsible for implementing the IST surveillance scheduling, specifying test dates, frequency of tests, and assuring the administrative window for each IST surveillance tes An operations surveillance quarterly schedule has been developed from the computer log which reflects the day-to-day, shift-by-shift, working schedule utilized by both the operations staff and the STA coordinator to assure compliance with the frequency of tests prescribed by TSs and ASME Section XI Code requirement There were no violations or deviations identified during the above revie Review of IST Procedures and Test Results During the inspection, the NRC inspector made a random selection of completed IST operational test procedures in order to verify that procedures contained referenced values and other pertinent attributes prescribed by guidelines of the ASME Section XI Code, Articles IWP/IWV-300 Procedures selected included the following:

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Pump Tests

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OP-903-003, "Charging Pump Operability Check," Pump A, tests

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December 28, 1987; and January 5, February 2, and

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May 1, 1988

OP-903-003, "Charging Pump Operability Check," Pump B, test conducted:- December 18, 1987

OP-903-046, "Emergency Feed Pump Operability Check," Pump A/B, tests conducted: November 2 and October 8, 1987

OP-903-030, "Safety Injection Pump Operability Verification,"

Low Pressure . Injection, Pump B, tests conducted: October 1 and December 10, 1987; and March'15 and May 4, 1988

OP-903-030, "Safety Injection Pump Operability Verification,"

High Pressure Injection, Pump A, tests conducted: September i and November 24, 1987; and February 16 and April 16, 1988 Valve Tests

OP-903-033, MS-116A & B, tested January 20, 1987 .

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• OP-903-033, MS-124A & B, tested January 20, 1987

• OP-903-033, BAM-1293, tested January 27, 1987

OP-903-033 BAM ,129A, tested January 21, 1987 OP-903-008, "RC System Isolation Leakage Test," tests conducted:

May 26-29, 1988 (24 valves)

• OP-903-035, "Quarterly ISI Valve Tests," tests conducted:

October 13, 1987 - CVR-201, 101, 401A & 401B; December 11, 1987

- MS-120A, 1208, 119A, 1198, and MS-124B

OP-903-014. "Emergency Feedwater Flow Verification," tests conducted: October 8, 1987 - EFW-207A & B, EFW-2191A & B

• MM-06-001, "Disassembly, Inspection, Check Valves," tests conducted: May 19, 1988 - SI-335B; April 16, 1988 - SI-329B; January 20, 1987 - SI-335A

• OP-903-033, "ISI Valve Cold Shutdown," tests conducted:

January 8 and 25, 1987; and May 23, 1988 - FW-184A & B; May 23, 1988 - MS-124A & B No violations or deviations were identifie ,

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d. Witness of Tests During the period June 6-9, 1988, the NRC inspector' accompanied plant operations and engineering personnel to observe IST functional tests performed on the following components:

OP-903-030 "Safety Injection Pump Operability Verification,"

Low Pressure Injection, Pump B, and High Pressure Injection, Pump B OP-903-035 "Containment Spray Pump Operability Test," Pump B

OP-903-032, "IST Valve Test," Gaseous Waste Management System, Valves GWM-104 & 105; Fire Protection System, Valves FP-601A &

FP-601B

OP-903-004, "Boric Acid Pump Operability Test," BAM Pump B The NRC inspector observed that each test was conducted by an operations coordinator located in the control room and in complete control of each step of the applicable test procedure. In addition, the NRC inspector verified that both permanent and temporary installed instruments utilized in the tests were within the calibration due dates, pertinent data was independently verified, acceptance criteria was clearly defined, and valve positions independently verified whenever procedures so dictate N3 violations or deviations were identified, e. IST Trending During this inspection, the NRC '1spector reviewed the licensee's IST component trending program log The NRC inspector observed that accumulated data was current with the chronological testing status and reflected the ability to detect'IST component degradatio No violations or deviations were identified, f. QA Audits During this inspection, the NRC inspector reviewed the 1985 and 1987 licensee QA audits of the inservice inspection (ISI)/IST progra During the review, the NRC inspector made the following observations:

QA Audit SA-W3-QA-85-43, "Inservice Inspection Program,"

conducted August 30 through November 14, 1985. This audit appeared to be a comprehensive, in-depth, overvistw of the IST program relative to plant procedures and ASME Code requirement F'ndings and concorns, which appeared to be principally programatic in r.o.are and did not reflect significant safety

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' issues, were adequately documented; howa er, there appeared to be a significant time delay in the final documentation of the resolution of the audit findings. The NRC inspector identified this weakness to the cognizant licensee representatives during the exit-intervie *

QA Audit SA-87-032.1, "Inservice Inspection (ISI)," -conducted April througn May 1987. One finding identified during this-audit involved a discrepancy found in valve stroke test data recorded during IST stroke testing of main feedwater isolation valves, FW-184A, Train A & QualityNotice(QN)QA-37-069datedMay 29, 1987, states, in part, "Valve FW-184A has aa acceptable valve stroke criteria of greater than 2.3 sec. and less than or equal to 5 sec. in accordance with PE-1-004. Contrary to the above, acceptance criteria FW-184A had a' stroke time of 2.13 sec. on 1-25-87 which is not in accordance with the above criteria."

The NRC inspector also observed that accompanying. documentation, includingaprojectevaluation/informationrequest(PEIR) response (No. 70884) would suggest that the matter should have been resolved based ~on the engineering evaluation contained in the PEIR; however, the current competer QN status report indicated that QN QA-87-069 remained an open item despite a completion schedule of June 5, 198 In discussing this matter with 'the cognizant licensee QA repmsentatives, the NRC inspector was informed that copies of all documentation may not have been contained in the specific file package reviewed by the NRC inspector. This matter is considered an unresolved item pending review of additional information that would indicate a basis for this issue remaining open (382/8815-01).

g. Review of Potential Reportable Event On May 13, 1988, with the plant in a refueling outage, the licensee reported that Main Feedwater Isolation Valves (MFIVs) FW-184A A B, may not meet TS response times under full flow conditions. This was apparently discovered during data review of previous testing and correspondence with the valve manufacturer. TS 3.3.2, Table 3.3.5

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specifies an ESFAS response time of 6 seconds for MFIVs to close on a Main Steam Isolation Signal (MSIS). This time includes the time of signal propagation through protective circuitry in addition to valve stroke time. The maximum allowed stroke time set by the IST program

! and operations procedure, OP-100-011, was 5 seconds, and the valves were stroked under zero flow conditions, corresponding to 7 to 9 seconds under full flow conditions. FSAR Section 6.2.1.4 assumes i

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100 percent feedwater flow for 5 seconds for the limiting accident for peak containment pressure inside containment (main steam line break) with a concurrent failure of one containment cooling trai This was initially thought to be a potential unreviewed safety issue;.

however, subsequent evaluations by the licensee identified that the feedwater regulating valves close in less than 5 seconds as a result of a MSIS under full flow conditions (feedwater regulating valves are also tested periodically under the Section XI IST program). The licersee concluded that the containment pressure would not have exceeded design limits -in the limiting-accident and the plant was never in an enanalyzed condition nor a condition prohibited by TS As an additional ineasure the licensee is readjusting the MFIV actuators and the administrative controls to assure a 2 second (minimom), 3 second (maximum) valve closure tim 'The NRC inspector reviewed this matter and the relevant IST valve stroke time records. Subsequent review in the-Region IV office has identified a need to perform additional inspection of this subjec The subject has accordingly been referred to the NRC Senior Resident Inspector for followu No violations or deviations were identified.

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3. Unresolved Item An unresolved item is one about which additional information is required in order to determine whether or not the item is acceptable, a violation, or a deviation. One unresolved item was identified during this inspection which is discussed in paragraph 2.f of this repor . Exit Interview The NRC inspector met with the licensee personnel denoted in paragraph 1 on May 20 and June 9, 1988, respectively. The NRC inspector sunnarized the inspection scope and findings.