IR 05000483/1992014

Insp Rept 50-483/92-14 on 921102-20.No Violations or Deviations Noted.Major Areas Inspected:Licensee Inservice Testing Program,Program on Check Valves & self-assessment

ML20125D755
Person / Time
Site:	Callaway
Issue date:	12/08/1992
From:	Huber M, Jeffrey Jacobson, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20125D753	List: IR 05000483/1992014 ML20125D750
References
50-483-92-14, NUDOCS 9212160017
Download: ML20125D755 (7)

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U. S. liUCLEAR REGULATORY COMMISSIOli REGIOli III Report lio.: 50-483/92014(DRS)

Docket lio.: 50-483 License lio.: tipF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166

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Facility llame: Callaway liuclear Plant Inspection At: Steedman, MO 65077 Inspection Conducted: 11ovember 2 through 20, 1992 ,

Inupectori: d v /t suo $$/>, / L - 8' - 9 *

( M . 'P /llub' ' ' Date aJ. , F' gg'i }&$4C-Sm th

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Date Approved '

• " dM /1 'if"'? L J./ ff. /laco ~ son, Chief Date M ter is & Processes Section Ipfp_ection Summary Innpoction conducted Movember 2 throuah 20, 1992 (Report li / 92 014 ( DRS) )

Areas Insnected: Announced safety issues inspection of the licensee's inservice testing (IST) program (TI 2515/110), the licensee's program on check valves (TI 2515/114), and licensee self assessment in these area Resulini The inspection disclosed no open items, violations or deviation The following strengths were identified during the inspection:

The training _of personnel in the maintenance of pumps and valves was enhanced by an operating closed ~1oop hydraulic-system provided exclusively for trainin *

Management and engineering attention was directed to the implementation of the IST and check valve programs.

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9212160017 921200 PDR ADOCK 05000403 G PDR

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TABLE OF CONTENTS Pacre

^ Persons Contacted..................................... 1 Inservice Testing of Pumps and Valves................. 1 Scope............................................ .1 Pump Testing..................................... 1 Valve Testing.................................... 2 (1) Check Valve Testing......................... 2 (2) Position Indicator Verification Testing..... 2

,! Check Valve Program................................... Scope............................................ 3 Design Application Review........................ 3 Non-Intrusive Testing Methods.................... 4 Training.............................................. 4 Trending.............................................. 4- Post-Maintenance Testing.............................. -4 Licensee Self-Assessment.............................. 5 Exit Meeting.......................................... .5

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DETAILS Persons Contacted

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Union Electric Company (UE) i

• W. R. Campbell, Manager, Callaway Plant

• J. McGraw, Superintendent, System Engineering

• G. Hughes, Supervising Engineer, Nuclear Safety  ;

• J. Cunningham, Shift Supervisor, Nuclear Operations +

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• G. N. Belchik, Senior Planning Supervisor, Nuclear Operations

• R. C. Wink, Systems Engineer, Nuclear Engineering

• C. J. Dorner, Systems Engineer, Nuclear Engineering ,

• G. J. Roesner, Systems Engineer, Nuclear Engineering

• J. D. Schnack, Quality Assurance Engineer, Quality Assurance U. S. Nuclear Reaulatory Commission (NRC)

• Bartlett, Senior Resident Inspector, Callaway Plant

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• Denotes those personnel attending the exit meeting on November 20, 199 . Inservice Testina (IST) of Pumns and Valves ,

The inspectors reviewed IST procedures and completed IST surveillances. Generally, the methods used for the testing of pumps and valves were adequate. The test frequencies and acceptance criteria were specified and provisions were-made  :

for prompt operability determinations, Scone The scope of the licensee's IST Program appeared l adequate. Selected plant systems were reviewed to

ensure that the program scope was adequate. Technical l Specifications (TS) and Emergency Operating Procedures

{ (EOPs) were also reviewed to evaluate the program scop Eumn Testina 1 The testing of pumps in the IST program was generally

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considered to be adequate. - However, a problem was-

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noted with the test procedure for the Essential Service

} Water (ESW) pumps. The test procedure did not

establish a five minute run time after the required l flow rate was achieve IWP-3500, " Duration of Tests,"

j requires that each pump shall be run at-least 5 minutes i

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under conditions as stable as the system permits. The ,

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measurements or observations of each of the quantities specified by the code shall be measured at the end of that 5 minute perio The inspectors noted the error while observing surveillance testing of the train B ESW pum Although the procedure did not establish the run time controls, the equipment operator performing the surveillance did not begin measuring the Code specified quantities until five minutes had elapse ,

The licensee implemented changes to the ESW pump testing procedures to correct the erro No further problems were noted, c. Valve Testina Some concerns were noted and are discussed belo In each case the inspectors reviewed the licensee's response and concurred in the resolutio (1) Check Valve Testina Check valves on the instrument air supply line to turbine-driven auxiliary feedwater pump discharge valves AL-HV-6, 8, 10, and 12, were tested without-using quantitative leak rate acceptance criteri The acceptance criteria used was qualitative and relied on the judgement of the person performing the tes The check valves on the air supply line must close and maintain a certain amount of leak-tightness so the nitrogen gas supply does not leak back through the air system, which would render-the discharge valves inoperable. The licensee agreed that a leak rate should be specified and used as the acceptance criteria when performing the leak test. During the inspection, the licensee initiated actions to revise the procedur (2) Position Indicator Verification Testina Remote position indicators were observed by the licensee at least once every two years to verify that valve operation was accurately indicate However, certain position indicators on motor control centers were not among those observe Section XI of the ASME Code requires-that valves with remoto position indicators be observed at least once every two years to verify that valv operation is accurately indicated. The

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interpretation of the requirement by ASME was that only the indications that were used for stroke timing'needed to be verified. This was the position that had been taken at Callawa However, the position of the NRC is that remote position indicators should_be observed to verify that valve operation is accurate ; indicated wherever a valve could be operatsd during an accident. The licensee stated that the valves with position indicating lights that were required to be operated from the motor control centers would be incorporated into their surveillance program for position indicator verification testin . Check Valve Prouram SCoDO The check valve program was generally considered to be goo It consisted of two parts: (1) the IST Program, and (2) the Check Valve Predictive Performance Manua The Check Valve Predictive Performance Manual was developed in response to Institute of Nuclear Power Operations (INPO) Significant Operating Experience Report (SOER) 86-03, " Check Valve Failures or Degradation."

The IST program included 155 check valves and the Predictive Performance Manual included 120 check valve Approximately 84 check valves were in both '

programs. This was considered to be a good overlap between the programs, Desian Anolication Review The licensee adopted a conservative approach to determining which valves should be in the check valve reliability program. The licensee performed an application design review for check valves in systems addressed by SOER 86-03 to determine the scope of the program. The design equations specified in EPRI NP-5479, " Application Guidelines for Check Valves,"Iwere applied in the design revie As a result of the review, the licensee deleted certain valves frca the check valve program on the basis of -

function (valves used for operating convenience or maintenance), but not for size or design. Also as a result of the review, the licensee found seven valves in the auxiliary feedwater system,-which were already in the IST program for testing in the open position;

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however, had active safety functions in the closed position. The valves involved were AL-V-0001, 2, and 3, and EG-V-0003, 7, 12, and 1 The licensee was incorporating the testing of these valves in the closed position into the IST program, Non-Intrusive Testina Methods Acoustic monitoring equipment was used during check valve stroke testing to provide indication that a valve would go to its full open position. The licensee had the equipment and training necessary to confirm acoustic indications by magnetic means, but did not pursue this option because it would require welding a magnet to the valve disk (use of an independent, confirming system is desirable for NIT). The licensee planned to procure other magnetic testing equipment as indicated in their Check Valve Program Action P?nn. If field testing confirms other methods to be effective, the equipment could update existing magnetic equipment to give position indication without modifying valve . Trainina Training for personnel performing work on pumps and valves appeared to be adequate in course content and duratio Training records were readily retrievable and appeared adequate. Additionally, the licensee constructed an operating test facility to train personnel in the operation and maintenance of the different components and systam The test facility allowed the traineo to work on the equipment and then to operate the components and the system to demonstrate that the werk was done properly. The use of the test facility in the licensee's training program was considered a strengt . Trendina Trending of maintenance performed, failure data, and test results for pumps and valves was acceptabl Recorded information was available in computer and hard copy for Trends of test results were maintained and evaluated by the IST, Check Valve, and LLRT Coordinators. Records for all items reviewed were available and all postings were curren . Post-Maintenance Testing Post-maintenance testing (PMT) at Callaway was controlled by a procedure entitled " Retest Development." The program outlined in the procedure appeared acceptable, but was not comprehensive in prescribing a specific retest for a.given component. The procedure covered PMT of essentially all'

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equipment at callaway, but only offered options of which tests should be considere It did not prescribe minimum ;

mandatory testing. Coverage of valves was reasonably detailed, but coverage of pumps was margina For example, the only entry describing PMT for pumps was " Repair or

, Replacement of Safety or Non-Safety-Related Pumps." i Although several test options were offered, there was no

, guidance concerning what constituted routine maintenance or i

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repai The decision of whether an operation such as a pacr.ing adjustment should be considered a repair or if such

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adjustment would warrant a subsequent leak test, rotest for new baseline, or operability check, was left to the discretion of the person preparing the work order. The inspectors presented the issue for the licensee to conside No further action was deemed necessar . Licensee Self-As.sessment The licensee's self-assessment plan was administered by  !

Quality Assurance and was generally acceptable. The i planning guide for licensee self-assessment activities identified a number of critical attributes to be evaluated in each area and appeared to cover the areas adequatel Not every attribute was inspected on overy assessment. A i review of inservice testing and check valve testing documents shoved that only the area of test performance had been selected for assessment. However, sections were provided in the planning guide to address the areas of test

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frequencies,-trending, PMT, test plans, evaluations and i other Code requirement Inasmuch as these are identified

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subject of future evaluation . Exit Meetina i

The inspectors met with licensee representatives (denoted in *

Paragraph 1) at the conclusion of the inspection on November 20, 199 The inspectors summarized the purpose, scope and the findings of the inspection and discussed the likely informational content of the inspection report. The-licensee did not identify any of the documents or-processes reviewed by the inspectors during the inspection as-proprietar >

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