IR 05000397/1993035
| ML17290A725 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/20/1993 |
| From: | Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A724 | List: |
| References | |
| 50-397-93-35, NUDOCS 9311090063 | |
| Download: ML17290A725 (19) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION REGION Y Report No.
Docket No.
License No.
50-397/93-35 50-397 NPF-21 Licensee:
Washington Public Power Supply System P.O.
Box 968
,
Richland, Washington 99352 Facility Name:
Inspection at:
Washington Nuclear Project No.
(WNP-2)
WNP-2 Site near Richland, Washington Inspection Conducted:
September 20-24, 1993
,n Inspectors:
M. J.
Royack, Reactor Inspector M. K. Payne, Reactor Inspector Approved by:
Ins ection Summar
. Ang, C ie Engineering Section
)0 <<QeQ)
ate Signe Ins ection durin the eriod of Se tember 20 24 1993 Re ort No. 50-397 93-Areas Ins ected This inspection reviewed the effectiveness of the licensee's activities to provide assurance of the operability and reliability of check valves in safety related systems.
Temporary Instruction 2515/110 was used as guidance for this inspection.
Back<around NRC regulations require that check valves be treated in a manner that assures their performance be maintained at an acceptable level.
NRC requirements for testing was defined in 10 CFR Part 50 with reference to the American Society of Mechanical Engineering (ASME) Boiler and Pressure 93110900h3 931022 PDR ADOCK 05000397
Vessel Code Section XI.
Previous NRC 'inspections of check valve testing and performance programs of vari.ous NRC licensed facilities found program and implementation deficiencies.
Examples of these deficiencies were that not all safety related check valves had been included in the inservice testing (IST) program, and that not all safety related check valves in the IST programs were being tested in a manner that would verify their ability to perform their safety related function.
Results The inspectors found that the licensee had implemented a comprehensive and aggressive check valve IST and check valve reliability program (CVRP).
However, procedures or guidelines did not clearly define the elements which needed to be considered when determining check valve reliability factors, and what elements were to be covered in the check valve yearly failure report.
Stren ths and Weaknesses
~Stren ths
~
Licensee management had provided funding and oversight of the check valve reliability program.
~
Except for one check valve of the 786 check valves in the IST program all valves are tested in accordance with ASME Section XI Code requirements.
The one valve that is not tested is intrusively inspected as an approved alternative method.
All of the check valves that are in the IST program are included in the CYRP.
Weaknesses
~
Licensee check valve reliability program and maintenance procedures which require trending.or yearly check valve failure reports had not provided guidance for which elements were to be included in the check valve trending criteria and yearly check valve failure reports.
Safet Issues Mana ement S stem SINS Item:
SIMS Issue Number GL 89-04 [Multiple Plant Action (MPA) Item Number A025]
Si nificant Safet Matters:
Non Summar of Violation or Deviations:
None.
0 en Items Summary:
No inspector follow-up items were opened or closed during this inspectio DETAILS Persons Contacted Washin ton Public Power Su l
S stem S. Davison, Plant gA Manager M. Eades Licensing Engineer
- C; Fies, Licensing Engineer J.
Fu, Nuclear Safety Engineer
- H. Grindel, Power Systems Supervisor
- P. Harness,'esign Engineering Hanager
- A. Hosier, Licensing Manager
- V. Parrish, Assistant Managing Director, Operations
- R. Rana, IST Program Coordinator
- M. Reis, Technical Program Manager
- J. Rhoads, Operating Events and Resolution Manager
- J. Sampson, Maintenance Division Manager
- W. 'Sawyer, Operations Shift Manager
- H. Schmitz, CVRP Coordinator
- W. Shaeffer, Operations Manager
- G. Smith, Operations Division Manager
- S. Washington, Nuclear Safety Engineering Manager
- R. Webring, Technical Division Manager U. S. Nuclear Re ulator Commission
- S. Sanchez, Resident Inspector The inspectors also held discussions with other licensee personnel during the inspection.
- Denotes those attending the exit meeting on September 24, 1993.
Check Valve Back round NRC regulations and the ASHE Code require that check valves be periodically tested in a manner that provides assurance of their performance.
Events involving safety-related check valves, including the water hammer-event; at San Onofre Nuclear Generating Station (SONGS) in 1985, demonstrated to the NRC staff that additional inspection effort should be dedicated toward the review of licensee check valve programs against NRC and ASME Code requirements.
On August 29, 1988, the NRC issued Information Notice (IN) 88-70,
"Check Valve Inservice Testing Program Deficiencies."
This IN described the result of inspections of check valve activities at several nuclear power plants.
These inspections found that some check valves within IST p) ograms were not being tested in a manner that verified their ability to perform their safety-related function On April 3, 1989, the NRC issued Generic Letter (GL) 89-04,
"Guidance on Developing Acceptable Inservice Testing Programs."
This GL provided clarification of ASHE Code requirements in an effort to assist licensees in correcting deficiencies that the NRC had found in IST programs.
The minutes of a public meeting, held by the NRC, provided detailed information on the implementation of the GL.
As part of an action plan to inspect licensee's check valve IST activities, the NRC developed Temporary Instruction (TI) 2515/110,
"Perfo'rmance of Safety-Related Check Valves," to assess the effectiveness of licensee check valve programs.
Check Valve Ins ection Plan The inspectors used TI 2515/110 to develop an inspection plan.
The purpose of the inspection was to verify that the licensee had a program in place to ensure the operational readiness of check valves in safety-related systems.
During the inspection, the inspectors:
1) conducted a review. of a sample of check valves to verify the implementation of the check valve testing program, 2) reviewed check valve corrective and preventive macintenance activities, 3) determined the extent of the licensee's design application reviews, '4) reviewed the adequacy of licensee check valve failure trending, and 5) assessed licensee management involvement in the development, implementation and support of the check valve program.
General Comments on Check Valves Generic Letter 89-04 listed MNP-2 as a Table 1 plant.
Plants listed in Table 1 of the GL had NRC Safety Evaluation Reports (SERs)
pending for their IST programs at the time GL 89-04 was issued.
GL 89-04 specifically indicated that there was no need for these plants to review their IST programs for conformance to GL 89-04 unless a change to the licensee's IST program for conformance was necessary.
GL 89-04 contained positions used in the preparation of the SERs and provided guidance to licensees for correcting generic procedure and program deficiencies.
The NRC issued the WNP-2 IST program SER on Hay 7, 1991.
The NRC's SER documented the review of Revision 3 and Revision 38 of the MNP-2 IST program scope and proposed alternatives to ASHE requirements.
Check Valve Pro ram Review
~Sco e
The inspectors reviewed the scope of the licensee's check valve program to verify that it complied with GL 89-04 and IST criteria.
MNP-2 check valve program consisted of two parts.
The first part was the ASHE Code
.Section XI IST requirements.
The second part was the Check Valve Reliability Program (CVRP).
The CVRP was based on the Institute of Nuclear Power Operations (INPO) Sign'ificant Operating Experience Report
(SOER)
No. 86-03,
"Check Valve Failure or Degradation" which initiated the action for all nuclear utilities to develop a
CVRP.
5.1. 1 ASHE Code Section XI Inservice Testin Pro ram 5.1.2 The licensee's ASHE Section XI IST program for WNP-2 was documented in WNP-2 IST Program Plan, Revision 4., The licensee's IST program identified components that were to be tested in compliance with the rules and regulations of 10 CFR Part 50.55a and Section XI of the ASHE Boiler and Pressure Vessel Code, 1980 Edition, Winter 1981 Addenda.
The licensee's IST program plan was referenced in the WNP-2 Updated Final Safety Analysis Report (UFSAR) Section 3.9.6.
The inspectors reviewed the licensee's IST program plan and sampled five safety related systems.
The inspectors review of the IST program and safety related systems was to determine if the licensee had correctly included all of the required check valves in those
'ystems in the IST program.
The five systems that were reviewed by the inspectors for ASHE Code Class 1, 2, and 3 check valves with safety-related functions were:
the high pressure core spray (HPCS), reactor core isolation cooling (RCIC), low pressure core spray (LPCS),
emergency diesel fuel oil (DFO)
and emergency diesel starting air (DGA) systems.
The inspectors found that the ASHE Code Class 1, 2, and 3 check valves for the above systems were included in the IST program.
The inspectors found that the licensee's IST program contained 786 check valves.
The 786 check valves included:
555 hydraulic control unit ball check valves for the control rod drive system, 36 main steam relief valve tail pipe vacuum breaker check valves, and 117 instrumentation line excess flow check valves.
The inspectors also found that one of the 786 check valves, a service water to residual heat removal system cross-tie check valve, had an approved relief request which allowed visual intrusive inspection as a method for satisfying full flow testing criteria required by the ASHE Section XI Code.
Check Valve Reliabilit Pro ram Pro<rr am The licensee's CVRP was described in licensee procedure PPH 8.3.131, Revision 3 "Check Valve Reliability Program".
The licensee's CVRP describes the methods used for selecting and categorizing check valves, inspection and testing guidelines.
The valves in the CVRP were selected using INPO guidelines and Electric Power Research Institute (EPRI) Report RP-2233-20,
"Application Guidelines for Check Valves in Nuclear Power P1@nts".
The inspectors reviewed the CVRP and sampled two groups of check valves that were intentionally omitted from the CVRP.
The inspectors reviewed the CVRP to determine: I) if the licensee had included all check valves that were required to perform a safety function and 2) to determine if the licensee established criteria for placing the check valves in the CVRP.
Initial Check Valve Selection The inspectors found that the licensee had initially considered 2081 check valves for inclusion in the CVRP.
The inspectors also found that two groups of the initial 2081 check valves were not considered for inclusion in the CVRP.
One group of check valves were the 555 ball check valves in the control rod drive system which are located in manifolds on individual hydraulic control units.
These check valves were periodically tested in other procedures to ensure the control rod drive system is operable.
The second group were ball check valves installed at hose bibs in the station air system.
These check valves were used to prevent contaminants from entering the service air system and have no safety significance.
The inspectors also found that the remaining valves had been evaluated and an active check val.ve inspection list had been generated based on spare parts availability, valve history, and if scheduled maintenance tasks already existed.
The inspectors found that the licensee had evaluated all of the check valves that were in the IST program and that the valves were currently on the active list for periodic inspection.
Check Valve List U date The inspectors reviewed the licensee's program for updating the CVRP to include or delete check valves.
Deletion The inspectors found that the licensee had'not deleted any check valves from the active valve CVRP inspection list since the initial screening.
The inspectors found that check valves that had satisfactory inspections were assigned a highet reliability number which could have reduced the licensee's inspection frequency.
Addition The inspectors noted that INPO had performed a
CVRP evaluation in 1992 and provided the licensee with additional check valves which they considered to need periodic inspections.
The inspectors reviewed the CVRP and found that the licensee had included the additional check valves into the CVR The inspectors noted that licensee procedure PPM 8.3. 131 required that a check valve reliability matrix be developed.and maintained.
The inspectors found that the licensee had.developed and had maintained a check valve reliability matrix.
The inspectors found that the licensee had used the reliability matrix as input to update the CVRP for inclusion of check valves and inspection schedule changes.
The inspectors reviewed the licensee's check valve reliability matrix required by procedure PPM 8.3.131.
The check valve reliability matrix was developed to document check valve reliability and subsequently to develop inspection schedules.
The inspectors found that the licensee used various indicators to determine a check valves reliability.
The indicators the licensee used for the reliability matrix were: results of detailed design reviews, ASNE IST operability surveillance tests, equipment history, leak rate results, review of operation event reports (OER's), previous inspection results, and pending maintenance work requests (MWRs).
The inspectors noted that licensee check valve program personnel had developed numerical weighting factors for the check valve indicators
'sed in the reliability matrix.
The inspectors noted that licensee procedure PPM 8.3. 131 did not provide guidelines for establishing and assigning check valve reliability numbers.
The inspectors found that licensee check valve engineers had independently developed numerical weighting criteria for the check valve reliability matrix indicators.
The inspectors reviewed the numerical weighting factors for check valve reliability determination indicators.
Conclusions Inservice Test The inspectors concluded that the IST,program plan identified check valves to be included in the program.
The licensee also requested and had obtained code test relief when code tests were not possible.
For these cases the licensee had proved a technical basis and had provided an alternate testing methods for each check valve.
The inspectors considered that the program's low number of check valves which substituted visual inspection for testing was a program strength.
Check Valve Reliabilit Pro ram The inspectors concluded that the check valve reliability program appears to have evaluated all check valves, including all IST check valves, required to perform a safety functions.
The inspectors concluded that the CVRP had a process and criteria for placing the valves in the check valve reliability progra I
The inspectors concluded that licensee check valve engineering personnel had independently developed a numerical method for determining the check valve reliability matrix numbers.
However, licensee procedures did not define what numerical values were to be used in developing the CVRP check valve reliability matrix.
The licensee acknowledged that methods for determining numerical check valve reliability factors needed to be formalized and that procedures would be reviewed and revised to incorporate the guidanc..
No violations or deviations of NRC requirements were identified.
5.2 Desi n
A lication Re ew Industry guidance, such as INPO Significant Operating Experience Report (SOER) 86-3,
"Check Valve Failures or Degradation" recommended that licensees perform a i'esign application review of the check valve installations for va'ves in the check valve program.
The design application review was intended to identify check valves subject to potentially severe service conditions.
The licensee's.
design review had been documented in OER 82052-0, dated March 8, 1989.
The inspectors reviewed the licensee's design review report and sampled a
total of seven check valves.
Six of the check valves were in the licensee's IST program plan.
The inspectors reviewed the check valves to determine if a design review had been performed for each of the check valves.
The inspectors reviewed the design review report in OER 82052-0 to determine if the licensee had included review elements identified-in NRC Temporary Instruction 2515/110 for review and analysis.
The inspectors also reviewed OER 82052-0 to determine if the licensee's design review included safety related valves.
I The inspectors found that the licensee's check valve design review had evaluated the following elements defined in NRC Temporary Instruction 2515/110: sizing requirements, corrosion allowances, valve selection by type and applications to line conditions, effects on line orientation, effects on upstream disturbances, elimination of unnecessary valves, use of backstops, securing internal parts, and vendor information.
The seven check valves that were reviewed by the inspectors to determine if design reviews were performed were:
DO-V-1B (diesel fuel oil transfer pump to day tank check),
HPCS-V-24 (HPCS pump 1 discharge check),
LPCS-V-
(LPCS pump 2 discharge check),
RCIC-Y-30 (suppression pool to RCIC pump 1 suction check),
RCIC-V-65 (RCIC pump 1 discharge to RPV head spray check),
and DSA-V-75 (DSA to spare air r'eceiver check).
The inspectors found that the check valves were included in the licensee's design revie The inspectors performed independent flow calculations to verify 100X check valve opening for minimum flow conditions and design conditions oF the check valves.
The inspectors found that the licensee's design review included accurate system design and flow conditions for the check valves.
Conclusion The inspectors concluded that the licensee's check valve design review study had been completed and that recommended actions for prioritization of check valve inspections had been incorporated into in the CVRP.
The, inspectors also concluded that the licensee's design review incorporated accurate system design and floe conditions.
No violat'ions or deviations of NRC requirements'were identified.
5.3 'heck Valve Testin Pro ram The inspectors reviewed a sample of check valves in six plant systems to determine; I) if all safety related valves had been, reviewed for inclusion in the IST program, 2) if the valves in the IST program were tested in an appropriate manner for their safety-related functions, 3) if the selected test methodology demonstrated valve operability, 4) if test procedures correctly identified appropriate acceptance criteria, and 5)
if the Code clarifications in GL 89-04 were properly addressed in a
testing program.
The inspectors selected 15 check valves from the following six plant systems:
emergency diesel generator fuel oil (DFO), emergency diesel generator air start (DGA), high pressure core spray (HPCS),
low pressure core spray (LPCS), reactor core isolation cooling (RCIC),
and residual heat removal (RHR) systems.
The inspectors selected pressure isolation check valves, pump discharge check valves, and containment isolation check valves for review.
The inspectors found that all of the fifteen check valves for the six systems had been eva1uated and all check valves that performed a safety-related function were included in the IST program.
The inspectors reviewed test procedures for the selected fifteen check valves to verify both open and closed operation testing.
The inspectors found that procedures provided for verification of quantitative acceptance criteria for both valve positions
{open and closed).
The inspectors noted that there was one check valve, not included in the sample of fifteen, which was not tested in the open and closed position.
The valve had an approved relief request and was intrusively inspected as an alternative means of testing (see section 5.4).
Conclusion The inspectors concluded that the fifteen check valves that were selected for review were safety related and were included in the IST program pla.4 The inspectors concluded that testing methodologies demonstrated open and closed positions of the check valves.
The inspectors also concluded that licensee check valve test procedures had quantitative acceptance criteria to verify valve operability in both the open and closed positions.
No violations or deviations of NRC requirements were identified.
Haintenance Pro ram The inspectors reviewed licensee maintenance work requests and check valve material history to determine if appropriate corrective actions were taken to address problems based on maintenance results, and if recurring problems existed.
The inspectors reviewed seven check valve Haintenance Work Requests (HWR)
AP0441, AR8324, AR001, AV2145, AS3405, AR7426, and AU4802.
The HWRs were reviewed to determine if the visual inspection program included; 1) the external and internal valve body conditions, 2) disc and seat conditions, 3) condition of the hinge, hinge pin, and other internal parts, and 4)
dimensions of the various items with appropriate acceptance criteria delineated.
Of the seven check valve HWRs reviewed two check valves were intrusively inspected.
One of the check valves was RHR-Y-89 which was intrusively inspected to satisfy IST full flow requirements (see section 5.3).
High pressure core spray valve (HPCS)
HPCS-V-5 was intrusively inspected under the CVRP for valve degradation.
The remaining five check valve related HWRs performed maintenance and repairs on the valves.
The inspectors found that maintenance and repairs performed on the five check valves were not recurring problems that could have been predicted.
The inspectors also reviewed material maintenance history for the five valves.
The inspectors did not identify any recurring maintenance problems associated with any of the valves.
Therefore, no check valve failure trends were identified for the five check valves.
The inspectors found that the HWRs that were reviewed contained adequate instructions for repair and referenced a engineering procedures when extensive maintenance and repairs were being performed.
The inspectors found that licensee check valve inspection procedures were adequately detailed to accurately evaluate check valve conditions.
In cases where extensive work was to be performed inspection criteria and check lists were used for documenting the inspections.
Conclusion The inspectors concluded that the maintenance work requests included detailed inspection criteria for intrusively inspecting the two check valves.
Licensee procedures and instructions were adequately detailed to accomplish the maintenance or repair.5
The inspectors did not identify any trends in check valve problems.
No.violations or deviations of NRC requirements were identified.
Trendin Pro ram The inspectors reviewed the licensee trending program for check valves.
A trending program was required by licensee procedure PPH 8.3. 131, Revision 3,
"Check Yalve Reliability Program."
This procedure required a
matrix be maintained which serves as a summary of indicators of a given check valve's reliability.
The matrix is used primarily as a convenient way to track and rate a valves plant and industry performance and will be used to select the highest priority valves for inspection during the next period.
The licensee stated that the check valve reliability matrix was used as their check valve trend indication.
Details of the check valve reliability matrix are in section 5. 1 of this report.
Conclusion 5.6 The inspectors concluded that the licensee has a check valve trending program.
The licensee had continuously evaluated check valves and used the check valve reliability matrix as a basis for revising check valve inspections.
See section 5. 1 of this report for inspectors comments on
. the licensee's check valve reliability matrix.
No violations or deviations of NRC requirements were identified.
Use of Non-Intrusive Test Methods The inspectors reviewed the licensee's non-intrusive test methods.
The licensee informed the inspectors that current non-intrusive testing consisted mainly of radiography to determine check valve closure and that the results were used for relief request bases.
The licensee indicated that they were in the process of establishing a non-intrusive testing program and that plans and budgets had been approved to purchase equipment to perform non intrusive testing during the April, 1994 ninth Refueling Outage (R9).
The inspectors reviewed the licensee's, 1994 budget plan and found that the licensee had approved funding for the purchase of non-intt usive check valve testing equipment and schedules to perform the testing.
The inspectors reviewed radiographs for three check valves.
The inspectors found that the radiographs of the check valves were clear and that the valve position could be determined.
The inspectors also found that anomalies in the valve could be identified using radiography as an alternative method to intrusive inspections.
The inspectors verified that the licensee had approved relief requests for the radiographed check valve Conclusion The inspectors concluded that th'e licensee did not have a formal non-intrusive check valve testing program.
However, funding had been approved for the purchase of non-intrusive check valve test equipment and that schedules have been approved for performing non-intrusive check valve inspections during the R9 Refueling Outage.
No violations or deviaiions of NRC requirements were identified.
5.7 Licensee Mana ement Involvement 5.7.1 Three licensee management oversight areas of the licensee's check valve IST and check valve reliability programs were reviewed by the inspectors.
The three areas were; management oversight and support, quality program implementation, and assessments of licensee and industry experiences.
Mana ement Oversi ht and Su ort The inspectors reviewed licensee IST and check valve reliability programs and procedures.
The licensee's IST program for check valves is included in the WNP-2
"Pump and Valve Inservice Test Program Plan."
The licensee's CYRP was documented in licensee plant manual procedure PPM 8.3. 131, Revision 3,
"Check Valve Reliability Program."
The inspectors found that licensee management reviewed and approved the IST and check valve.reliability programs.
The inspectors also found that licensee management had required that periodic reports be issued to management on program results, potential problem areas, and operability concerns for check valves.
The inspectors found that licensee management had issued general guidance,
{"Customer/Supplier Agreements," for a
"Team Approach" ) to engineering, operations, and maintenance groups detailing their expectations.
The management expectations defined the relationships among the organizations and their expectations how each group. and individual needed to interact to identify and resolve, problems.
The guidelines applied to all systems and programs.
As part of the licensee management expectations and guidance the inspectors found that licensee management had required that a
program of weekly, monthly, quarterly, and annual and biennial plant system walkdowns be performed.
The walkdowns were to be performed by plant technical system engineering.
The results of the walkdowns were required to be reviewed with plant operations and maintenance personnel.
Reviews were to include emerging technical issues, regulatory and licensing concerns, licensee internal program reviews, and equipment trending.
Completed reviews and recommendations were required to be evaluated by licensee managemen The inspectors randomly selected and reviewed two weekly, three monthly, two quarterly, and one annual completed walkdown p'ackages.
The inspectors found that the walkdowns had been performed as scheduled, the walkdown engineering, operations and maintenance reviews had been completed, and, where required, appropriate corrective actions were initiated for identified problems.
The inspectors reviewed a licensee program change implemented on February 1,
1993.
The program change restructured the licensee's Technical Services Engineering department to have a separate lead engineers for IST and the check valve reliability programs.
The check valve reliability program engineer was designated as a full time position.
The inspectors found that both the licensee's IST program and check valve reliability program were each led by individual lead engineers.
The inspectors also found that the lead engineers for 1ST and check valve reliability programs had routinely attended ASHE Operations and =Maintenance (OLH) Code, Electric Power Research Institute {EPRI), and Nuclear Industry Check Valve Group
{NIC)
meetings.
Additionally the two lead engineers have held offices on the ASME 0&M code committees for the past five years.
The inspectors reviewed the licensee's fiscal year (FY) 1994 budget plan.
The inspectors found that the licensee had budgeted funds for the check valve reliability program.
The budget included funds for:
procurement of non-intrusive test equipment for check valves, the addition of 62 balance of plant check valve into the check valve reliability program, outage funding for disassembly of valves for inspection, and continued participation of technical staff in ASHE and other industry code groups related to check valves.
The inspectors also found. that. the addition of the 62 balance of plant valves to the check valve reliability program had been approved by the plant operations committee (POC).
ualit Pro ram Im lementation The inspectors reviewed three licensee corporate licensing and assurance audit reports90-536, 91-557, and 92-608 issued September 21, 1990, December 20, 1992, and June 3, 1993 respectively.
The audits were performed for conformance to Technical Specification and license conditions.
Licensee corporate licensing and assurance audit reports for conformance to Technical Specification and license conditions included audits of the licensee IST program which covered check valves.
The inspectors also reviewed one Quality Assurance (QA) surveillance report 293-0041, Safety Related Check Valves, issued September 9,
1993.
The licensee's Quality Assurance surveillance report for safety related check valves reviewed.the adequacy of safety related check valve population established in the check valve reliability'rogram (PPH 8.3. 131),
Quality Assurance surveillance report 293-
0041 also reviewed the adequacy of the check valve trending program and the adequacy of guality Control involvement.
The inspectors found that the licensee had been in the process of responding to the findings at the time of the this inspection.
The inspectors found that the licensee had performed audits of their IST program which included check valves within the twelve month
"cycle as required by Technical Specification section 6.5.2.8.a.
The inspectors found that the licensee's audits appeared to be comprehensive and identified programmatic and performance based areas of weakness.
The inspect'ors also found that the licensee had taken actions to address the audit findings.
Licensee and Industr Ex eriences The inspectors reviewed the licensee's incorporation of internal and industry experiences with check valve problems, testing, and operating experiences.
The inspectors also reviewed the licensee's evaluations of NRC Information Notices 88-70, Check Valve Inservice Testing Program Deficiencies, 89-62, Malfunction of Borg-Warner Pressure Seal Bonnet Check Valves Caused by Vertical Misalignment of Disk, and 90-79, Failure of Hain Steam Isolation Check Valves Resulting in Disc Separation.
The inspectors randomly sampled four industry vendor notices, received by to licensee, for check valves and -the licensee's associated engineering evaluations.
The inspectors found that licensee engineering staff had reviewed the documents for applicability to WNP-2.
For the four cases the licensee's review concluded that the notices were not applicable to WNP-2 since the notices did not apply to check valves installed at WNP-2.
The inspectors reviewed licensee check valve lists in the IST and check valve reliability programs.
The inspectors found that the model and types of valves. identified in the notices were not in the JST and check valve reliability programs.
The inspectors reviewed the licensee's engineering evaluation,
"Operating Experience Review Summary," for NRC Information Notices 88-70, 89-62 and 90-79.
The inspectors found that NRC Information Notices 89-62 and 90-72 was not applicable to WNP-2 since the valves were not part of the WNP-2 design.
For NRC Information Notice 88-70 the inspectors found that the licensee had submitted a revision 4 of the IST program to the Nucle'ar Reactor Regulation (NRR) which included IST of check valves and relief requests on December 3,
1991.
On December 22, 1992 the licensee submitted revisions to prior relief requests and additional check valve testing relief.
requests.
At the time of the inspection NRR had not submitted a
response (Safety Evaluation (SE)) to the relief requests.
As identified in the management and oversight section above the licensee had established and maintained industry contact through
~ '
professional organizations and specific technical groups for check valve IST and reliability programs.
Conclusion The inspectors concluded that licensee management was providing check valve IST and reliability program oversight.
Licensee management was ensuring that their expectations were being followed and that priorities had been set to improve support of operations through continued improvement initiatives.
Licensee management was also cognizant of
. procedures, work, and the operability check valves.
Licensee management was supporting the IST and check valve reliability program through funding, management oversight, and personnel and program improvement.
The inspectors concluded that licensee gA had performed audits on the licensee's IST and check valve reliability program.
The inspectors concluded that the gA audits were comprehensive and had revealed programmatic and testing and inspection problems w'hich were being or had been resolved.
The inspectors found that the licensee had been reviewing industry experiences and incorporating industry, licensee, and NRC information into the IST and check valve reliability programs.
No violations or deviations of NRC requirements were identified.
t.
~Ei II tt The inspectors met with the licensee management representatives denoted in Section 1,
on September 24, 1993.
The scope of the inspection and the inspectors'indings up to the time of the meeting were discussed.
The
- inspectors identified that additional information had been requested, and this information would be reviewed in the NRC Regional Office in order to complete the inspection.
Review of the additional information was completed and the results are included in this report.
At the conclusion of the meeting the inspector requested that the licensee identify any documents given to the inspectors that might be proprietary so that they could be returned.
The licensee indicated that there were no documents that were proprietar I~