IR 05000483/1990010
| ML20043F893 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/08/1990 |
| From: | Danielson D, Huber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20043F885 | List: |
| References | |
| 50-483-90-10, IEB-85-003, IEB-85-3, NUDOCS 9006180275 | |
| Download: ML20043F893 (6) | |
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U. S. NUCLEAR REGULATORY C0t'. MISSION
REGION 111 t
Report No.:
50-483/90010(DRS)
Docket No.: 50-483 License No.:
NPF-30 Licensee: Union Electric Company i
Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name:
Callaway Nuclear Plant inspection At:
Callaway Site, Steedman, M0 65077 Inspection Conducted: May 14 through 18, 1990
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Inspector:
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(y P. HtWe'r Approved By:
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[Q. H.Wanielson, Chief Dat'e Viaterials and Processes Section Inspection Summary Inspection on May 14 through 18, 1990 (Report No. 30-483/90010(DRS))
Areas Inspected:
Routine announced safety inspection of maintenance and inservice testing (IST) of pumps and valves (73756).
Included were the dCtions taken in response to IE Bulletin (IEB) 85-03 (25573). Areas covered in this inspection included a review of administrative procedures, performance of testing, and a review of previously recorded IST data.
Results: Within the areas inspected, no violations, deviations, or other items were identified.
Based on the areas inspected, the NRC inspector noted the following:
The use of the IST surveillance flow charts as a reference was seen as a
strength.
Use of the flow chart should aid in efficient implementation of the IST program.
The use of differential pressure (dp) testing methodology to address IEB
85-03 was good.
IEB 85-03 was also considered closed.
9006180275 900608 PDR ADOCK 03000483 Q
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DETAILS
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Persons Contacted
Union Electric Company (UE)
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- C. D. Naslund, Manager, Operations Support l
- D. E. Young, Superintendent, Operations
- J. C. Gearheart, Superintendent, Quality Assurance
- J. V. Laux, Manager, Quality Assurance
- R. D.-Affolter, Superintendent, Systems Engineering i
- M. E. Taylor, Assistant Manager, Work Control
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- J. R. Polchow, Superintendent, Chemistry /Radwaste p
- W. A. Witt, Supervising System Engineer y
SC. E. Slizt.wski, Supervising Engireer b
- G. J. Rosener, BT Engineer
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- R. C. Wink, MOV Engineer N
- S. H. Rexo, MOV Engineer-
- C. S. Petzel,_ Engineer, QA
- J. D. Schnack, Engineer, QA i
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- U.
S.. Nuclear Regulatory Connissio,n (U. S. NRC)
- B. L. Bartlett, Senior Resident inspector
- Denotes those_present at-the exit meeting on May 16, 1990.
The NRC inspector also contacted other licensee personnel during the.
course _of the inspection.
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Pump and Valve IST Program Implementation (73756)
The licensee's IST program was based on the requirements of Section XI of the ASME Code, 1980-Edition, Winter 1981 Addenda.- The licensee's program-was reviewed by the NRC and a Safety Evaluation Report (SER) was issued October 2, 1987, approving the program for implementation.
a.
. Administrative Controls of IST
--The NRC inspector confirmed that administrative controls were in place to satisfy the requirements of the licensee's IST program and that specific IST duties had been assigned to personnel'. The i
inspectnr reviewed portions of administrative and technical documents for content and for compliance with specific requirements of the
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U Callaway IST program. Documents reviewed included:
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APA-ZZ-00356, "Section XI Pump and Valve Program", Revision 3,-
dated March 27, 1990; and 1~.
" Inservice Testing Program - Callaway Nuclear Plant", Revision 10,
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dated March 31, 1988.
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During the review of APA-ZZ-00356, the NRC inspector.noted that.the-licenseeincorporated" Pump (andValve)SurveillanceTestflowpath" diagrams into the procedure. These flowpaths, one for pump and one for valve surveillances, were used as references by personnel responsible for implementing the IST program to ensure that applicable-requirements are met. The flowpath describes the various stages of testing, review and approval of the surveillance.
Other actions such as increased frequency testing or declaring a component inoperable were-clearly c.:lineated in the flowpath.
The use of the flowpath at Callaway was considered a strength, b.
Establishing Equipment inoperability Position 8 of Attachment 1 to Generic Letter (GL) 89-04, "Guidanc.e on Developing Acceptable Inservice Testing Programs", indicated that e pump or valve shall be declared inoperable as soon as the data was recognized to be outsida the IST acceptance criteria.
However, ASME
'Section XI allowed deferring the declaration of inoperability ~of valves for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (IWV-3417) after the problem was recognized.
Although IWP-3230 required that pumps with test data deviations which fell within the Required Action Range be declared immediately inoperable, the effects of this guidance was nullified by IWP-3220, which permitted a delay of up to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to analyze the data after
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completing the test. The licensee _'s program conformed to GL 89-04
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requirements and no problems were noted with the implementation.
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Surveillance Procedure Review The NRC inspector reviewed several procedures and completed surveillances to further evaluate the licensee's program implementation adequacy and effectiveness.
The following surveillances were reviewed:
OSP-AL-P0002, "Section XI Turbine Driven Auxiliary Feedwater
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Pump Operability", Revision 12, dated April 23, 1990.
OSP-BB-VLOO6, "Section XI RCS Pressure Isolation' Valves Leak
Rote Tests", Revision 7 dated March 7, 1990, and Revision 5, completed May 19, 1989.
L OSP-EG-P01AC, "Section XI CCW Train "A'? Operability", Revision 8, dated March 7, 1990.
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OSP-EJ-V0002, "Section XI RHR Mode 5 Valve Operability",
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Revision 3, dated August 5, 1987, and completed October 6, 1987, and May 6, 1989.
The NRC inspector verified that the acceptance criteria and i
allowable ranges for the test parameters were as specified by the Code, and that the surveillance data were within acceptable levels.
For the component cooling water pump PEG 01A and the turbine driven j
auxiliary feed pump, the inspector reviewed design data to evaluate j
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the ability of the test to gauge actual pump performance and
ensure that operability limits did not exceed the design limits.
Based on the review, no operability concerns were noted.
However, the inspector noted that the development of the allowable ranges of test quantities specified in Table IWP-3100-2 were improper. The values for the upper and lower limits of the acceptable range were equal to the lower value of the high alert range and the upper value of the low alert range, respectively.
Simply, a test quantity could not be acceptable and be in the alert range at the same time.
Additionally, minor administrative errors were noted with the reference values but did not affect the measured IST parameters.
Both problems were addressed by the licensee to determine if the anomalies resulted or would have resulted in any deleterious affects on previous surveillances. None were noted and the the licensee implemented corrections to the procedures, d.
Valve Stroke Time Limits GL 89-0' atated that the limiting value for full stroke of power operated valves should be based on the average stroke time of the valve when it was known to be in good condition and operating-properly.
The limiting value should be a reasonable deviation from this reference stroke time based on the valve size, type and actuator type. Technical Specification and safety analysis limits should also be included in the review of the most restrictive stroke time value to establish the guidelines for limiting values of full stroke time. The NRC inspector discussed this issue with the U c.'nsee and reviewed associated documentation, including a revi 3 of a sample of valves and their stroke times.
It was noted tha the licensee had documented criteria for establishing stroke times. The criteria established were within the guidelines established in GL 89-04. No problems were noted, e.
Test Observation The NRC inspector witnessed the performance of surveillance OSP-EG-P01AC, "Section XI CCW Train " A" Operability". The licensee used operations personnel to perform all aspects of the testing.
Vibration data was obtained using calibrated equipment and the locations used for measurement were clearly marked on the pump.
Reference conditions were established in accordance with the Code to adequately assess the pump condition. The work was done in a professional and efficient manner with no problems noted, f.
Quality Assurance -(QA) Audit Review The NRC inspector reviewed the methodology and findings of licensee conducted QA audits of the IST program. The audits reviewed were entitled " Quality Assurance Audit of Inservice Testing", Numbers AP88-015 and AP89-007, dated August 18, 1988, and July 21, 1989, respectively.
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AP88-015: This audit emphasized observation of ASME Section XI pump and valve testing. The areas audited included test procedure adequacy, control of test activity, test conduct, test instrumentation, and test result evaluations by operations. Problems with the conduct of testing were noted. The need of improvements to facilitate performance of the testing, and problems with MT&E were identified.
AP89-007: The audit scope included (1) safety and relief valve testing, (2) M0 VATS testing, and ('3) check valve testing.
This was a performance based assessment with emphasis placed on verifying that equipment was capable of performing its safety function. Minor discrepancies were noted and recommendations were provided. Test performance and involvement and evaluation by technically qualified personnel were considered strong points.
The audit methodologies were good and those problems noted during the audits were adequately addressed.
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W ensee Action on IE Bulletins (IEB)
(Closed) Tl 2515/73, IEB 85-03, and Supplement 1 to IEB 85-03 T50 N 3/85003-BB): Motor Operated Valve (MOV) Common Mode Failure During-FTant. Transients Due to Improper Switch Settings.
Action Item a of the bulletin requests a review and documentation of the design basis for the operation of each valve addressed, including an evaluntion of limiting differential pressure conditions; Action Items b throuc,h d require actions to assure that the MOV switch settings are set, tested, and maintained properly; and' Action item e requires a 180 day report of the results of Action item a and a program to accomplish Action Items b through d.
Supplement I to IEB 85-03 was issued to clarify misunderstandings in IEB 85-03 and to clarify which valves are required to be included in the scope of the belletin program. A special safety inspection of the licensee's activities with response to IEB 85-03 was conducted in July 1987 and was documented in NRC Inspection Report No. 50-483/87022(DRS).
It was noted in the report that additional actions were required to close IEB 85-03 at Callaway. The additional actions noted by the inspector included more testing and completion of the final report by the licensee.
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Program Review The NRC inspector reviewed the final report submitted in response to action item f of IEB 85-03. This report included a summary of valve operability prior to any adjustments made, and a summary of data in ace dance with the suggested data summary format as found in Table 2 of IEB 85-03. The data enclosed was discussed with the licensee to determine the adequacy of the program implementation.
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-The switch setting and testing methodologies were found to be acceptable by the NRC. At Callaway, valves within the scope of the IEB 85-03 program were tested while under operating conditions simulating actual or near dp conditions. Some experimental data reviewed by the NRC has shown that the industry methoo for calculating the thrusts required to operate valves under dp conditions is questionable. Therefore, testing of valves under dp conditions is considered to be a more reliable method to ensure that a valve is capable of operating under design basis dp conditions. Use of this method of testing valves at Callaway was considered a strength, b.
Test Data Review The NRC inspector reviewed the results of the valve testing done at differential pressure while the valves were instrumented with the M0 VATS,-Inc., diagnostic equipment.
All valves in the IEB 85-03 program scope were tested at or very near the maximum operating dp.
Where valves were not tested at the maximum dp, additional thrust margin was added. Test data was retrievable for the testing performed for the valves and no problems were noted.
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11aintenance of Switch Settings Procedures are in place to perform testing of valves as necessary.
The licensee has also established criteria that identifies the situations where testing using diagnostic equipment is required to declare the valve operable. The NRC inspector reviewed the list of maintenance work that requires a diagnostic test or partial test of the valves. The list was comprehensive and appeared adequate. The combination of continued diagnostic evaluation and the maintenance
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procedures in place should provide continued operability of the valves in the IEB 85-03 program, d.
Conclusion The licensee has addressed all of the significant aspects of the bulletin. The commitments communicated to the NRC in previous correspondence were verified to be met. Based on the review of the licensee activities during this and the previous inspection (NRC Inspection Report 50-483/d7022), it was concluded that there is reasonable assurance that valves covered under the bulletin can perform their safety function during normal and abnormal operations.
This item is considered closed.
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Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)'
at the conclusion of the inspection on May 18, 1990, and summarized the scope and findings of the inspection activities. The licensee acknowledged these findings. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietary.
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