ML17251A129

Pro

ram

The licensee

is currently implementing its second

10-year interval

program for safety related

pumps

and valves for the period January

1,

1981.'hrough

December

31,

1989.

This program is defined

and controlled by the

licensee

by including i't as Appendix

C to the Ginna Station Quality

Assurance

(QA) Manual.

Revision 8, dated October

1,

1987 is the current

revision to the

IST program.

The original version (Revision

0 of Appendix

C to the

QA Manual) of the

IST Program

was submitted to the

NRC on

September

4,

1980,

in compliance with the requirements

of 10 CFR 50.55a.

It committed to ASME Code,

Section

XI

,

1977 Edition through the

Summer

1978 Addenda.

An

NRC safety evaluation report which endorsed

the valve

program

was issued

on May 26,

1981.

Appendix

C of the

QA Manual provides the necessary

testing

inform'ation

that is requi red to implement

ASME Code,

Section

XI requirements

for the

listed

pumps

and valves.

The testing information for the valves is

provided in the form of valve tables.

These tables refer to many notes

which identify exceptions

to the testing

requirements

of Article IWV of

ASME Code,

Section XI.

It is the

immediate responsibility of the Ginna Station Results

and Test

(R&T) supervisor

and the

R&T foreman to implement the IST program

and

develop test procedures

which will define the specific test for each

pump

and valve in the program.

Overall responsibility rests with the Technical

Manager to whom the

R&T Supervisor reports.

Most of the required testing

is accomplished

by the performance of Periodic Test (PTs) under the control

of the

R&T foreman

and his test personnel.

The inspectors

performed detailed reviews of various completed

PTs (see

Attachment A) for procedure

content

and to determi'ne

the adequacy

of the

actual

pump and valve test data

taken during prior tests.

This

PT

information was reviewed from an overall

IST programmatic

standpoint

and

more specifically as it pertained

to the

pump and valve portions of the

program.

Also the inspectors

witnessed

the performance of five PTs.

2.1

Findin

s and Conclusions

The

R&T personnel

perform the detailed testing operations

(e.g.

valve operation

and data recording) locally at the equipment while

in constant

communication with the licensed operators

in the Control

Room.

The

R&T foreman is usually in the Control

Room coordinating

the activities of his test personnel

and Control

Room personnel.

The inspectors

observed this overall test coordination

on May 17,

1988, during the performance of the testing of the Standby Auxiliary

Feedwater

(SAFW) pumps

and the Auxiliary Feedwater

(AFW) pumps.

Detailed inspector observations

concerning this test witnessing

are

included below in Section 3.0 and 4.0.

The inspector discussed

with R&T personnel

the licensee'

system for

scheduling

various

IST tests to meet the frequency requirements

of

ASME Code,

Section XI.

Pump testing is general.ly

done

on

a monthly

basis while the plant is operating

.

During these

pump tests

many

associated

valves in the

system are also tested.

Other valve testing

is performed quarterly, cold shutdown or refueling bases,

as

applicable.

The monthly testing is manually tracked

on

a status

board

which occupies

a complete wall in the

R&T office.

Color coding is

utilized to highlight such significant testing conditions

as

more

frequent testing of certain valves that might be required if increased

valve stroke times occurred that are abnormal.

Special

tracking of

valves that can only be stroked during cold shutdown is kept by the

R&T supervisor to meet the intent of ASME Code,

Section XI.

The

testing for these

cold shutdown valves is provided in several

separate'Ts.

The inspector

noted that the licensee

practice of monthly pump

testing which also includes

many valve tests is

a strength

since this

practice

goes well beyond the quarterly frequency

requirement

in ASME

Code,

Section XI.

Discussions with RET personnel

indicated that test results

are

adequately

reviewed.

Both the

R&T foreman

and supervisor

review the

test results.

Any system or component abnormalities identified

during the tests

are

immediately brought to'he attention of the

Control

Room licensed operators.

Resolution of such abnormalities

would be notated

in the "comments" section of the procedure.

After

final review of the test results,

the completed

procedure is

forwarded to Central

Records for permanent

record keeping.

During the preparation for this inspection,

the inspectors identified

several

technical

concerns,

such as,

the possible

lack of fu11-stroke

exercising of certain

Main steam isolation valves

and leak testing of pressure

boundary isolation valves.

These

concerns

were provided to. the

licensee prior to this announced

inspection.

The inspector also

requested

that cognizant engineering

personnel

be

made available to

discuss

and resolve

these

concerns.

'As discussed

in Section 3.0

below,

several

of the possible

check valve concerns

were confirmed by

the on-site inspection.

Cognizant corporate

engineering

personnel

were not generally available to discuss

these

concerns.

These

check

valve concerns

led the inspection

team to the conclusion of a perceived

licensee

weakness

in engineering

support

since correct check valve

testing requirements

were not adequately

defined to meet the require-

ments of ASME Code,

Section XI.

Because

of the deficiencies identified

in check valve testing,

the inspector's

also concluded that the

licensee

had not responded

adequately

to the information provided in

'NPO

SOER 86-03

and

NRC Information Notice 86-01 in this regard.

1

The inspectors

determined that,

from an

IST programmatic

standpoint,

the licensee

was generally performing the testing within the required

frequencies.

Also, the required

IST data were being obtained

and

reviewed.

However, specific findings indicate that management

involve-

ment is warranted to ensure

adequate

engineering

support for proper

definition of check valve testing consistent with the requirements

of

ASME Code,

Section XI.

3.0

Valve Testin

Pro

ram

The valve testing

requirements

of the

IST program are

implemented

through

periodic tests

(PTs), which are well written and clear to follow from an

IST standpoint.

Acceptance criteria are clearly defined in the procedures.

The inspector

reviewed the completed

procedures

listed in Attachment

A and

determined

in general that:

acceptance

criteria were met;

proper review and approval's

were obtained;

data evaluations

were performed;

position indication devices'ere

checked;

fail-safe operation of valve actuators

was properly checked

where applicable;

and

disposition of failures

was adequate

~

Also, the inspection

sampled

several prior valve maintenance activities to

determine

the licensee's

practice concerning

post maintenance

testing.

The inspector determined that satisfactory

post maintenance

testing

consistent with the requirements

of ASME Code,

Section

XI had

been

accomplished

for:

Letdown high pressure relief valve - RV-203.

(MSIV) 3516 and 3517.

The inspectors

witnessed

various valve testing that was accomplished

in

conjunction with the

AFW and

SAFW pump testing per PT-16

and PT-36, re-

spectively.

Specific areas of concern

were identified especially regarding

check valve testing.

10 CFR 50.55a(g)

requires

an

IST Program for safety

and valves to meet the requirements

of the

ASME Code,

Section

XI.

However, certain valves

were omitted from the

IST program

and also

certain

check valves were inadequately

tested.

Both of these

matters

are

apparent violations of NRC requirements

(50-244/88-10-01)

and they are

discussed

in further detail below.

3.1

~Findin

n

A.

Multi le

Exam les of Inade uate Testin

of Check Valves

Section

XI of the

ASME Code requires full-stroke tests for check

valves.

Full-stroke testing

may be verified using flow.

The

NRC staff position is that verification of the

maximum flow rate

through the valve as defined in the plant's safety analyses

would

be

an adequate

demonstration

of the full-stroke requirement.

Any lesser

flow rate is considered partial-stroke exercising

unless it can

be

shown (by some

means

such

as

measurement

of the

differential pressure

across

the valve), tgat the check valve's

disc position at the lower flow rate would permit maximum

required flow through the valve.

If the licensee

cannot

meet

the requirements

of the

ASME Code,

10 CFR 50.55a .requires

the

licensee

to submit appropriate relief requests

to the

NRC.

The

inspector

noted the following examples

where the licens'ee's

program .did not conform to the full-stroke requirements

of ASME

Code,

Section

XI or the licensee

did not'submit appropriate

relief requests

to the

NRC.

( 1)

Check Valve 9627A

8 B:

These 4-inch valves are located at

the service water suction inlet for the

SAFW pumps

1C and

1D and and they are

an integral part of the seismic Category

I source of water for these

pumps.

The inspector witnessed

testing of these

valves per PT-36.

The check valve test

consists

of supplying service water pressure

upstream of

the check valve with all valves shut downstream of the

check valve except

a 3/4-inch vent valve (9630A/B). 'low

through this vent valve and attached plastic tubing was

estimated

to be between

2-3

gpm which is significantly less

than the required

200

gpm and essentially constitutes

a

part-stroke

exercise

of the check valve.

While Article

IWV-3522 of ASME Code,

Section

XI requires part-stroke

exercising of check valves if full stroke exercising is

not practical

during normal plant operation, it requires

full-stroke exercising during cold shutdowns.

However, the

inspector determined that

no other exercising tests

were

being conducted for these

and they had not

been disassembled

since their original installation around

1981.

This is especially

a concern for the service water

application

as the water quality is conducive to silt

buildup in the valve.

The inspector identified this concern

to the licensee's

representatives.

The licensee

provided

a

quick response

to the inspector's

concern

by disassembly,

inspection,

cleaning

and reassembly

of both check valves

on

May 19 and 20,

1988.

The inspector witnessed

the work

performed

on check valve 9627A.

The valve internals

were

in very good condition, considering

the application, with

only minor amounts of 'rust evident.

The valve disc/seating

surfaces

were in good condition.

Also, there

was strong

evidence that the check valve disc

had

been stroking fully

due to peen

marks noted at the valve disc/disc

stop mating

surface.

The inspector

was informed by maintenance

person-

nel that similar results

were found for check valve 9627B.

As

a result of these

inspections

the immediate question of

check val,ve operabiliiy was resolved.

The licensee

indicated

that long range corrective action

was being pursued

which

may entail

annual

disassembly

and inspection of the check

valve internals.

The

IST program indicates that

SAFP

SW valves

9627 A/B are

exercised quarterly.

Per

PT-36 these

valves are only

partial-stroke

exercised

using

a 3/4" test line.

The

ASME

Code,

Section XI, requires full stroke exercising 'quarterly

at power or during cold shutdown.

The licensee

has not

submitted

an appropriate relief request.

(2)

(3)

Check Valves 862AEB:

These 6-inch valves are located at

the discharge

of each containment

spray

(CS)

pump.

Review

of the

CS system

procedure

(PT-3) indicated that the flow

rate through check valve 862A or

B in conjunction with its

pump test

was

38

gpm which is significantly less

than the

minimum design flow of 1200

gpm as stated

in the

FSAR.

The licensee

indicated that

no other tests

were being

conducted for these

However, the licensee

noted that these

valves contained

an external

position

indicator for the check valve disc which could be

used to

demonstrate

full-stroke exercising.

Utilization of this

feature

had not been

included in PT-3.

On May 20,

1988,

the licensee

adequately

demonstrated

to the inspectors

full-stroke exercising of these

check valves using this

external

position indicator.

The licensee

indicated that

the long range corrective action would consist of upgrading

PT-3 to include this testing.

RHR Dischar

e Check Valves

710A/B and 853A/B

and

RHR

Suction

Check Valve

854

from the

RMST:

The inspector

reviewed procedure

PT-2.2

used for the monthly testing of

the

RHR system

pumps

and valves.

This procedure

requires

that

a flow'rate of 200

gpm be established.

The inspector

noted that this flow rate only accomplishes

partial-stroke

exercising of check valves

710A and B, 853A and

B, and 854

since the

RHR pump design flow rate specified in Table

5.4-6 of the

FSAR is 1560

gpm.

The licensee

indicated

that these

do experience

design

flow rates

during refueling operations

when the refueling cavity is

filled.

However, current procedures

do not take credit

for such operations

as demonstrating full stroking of

these

The licensee

indicated that this

issue required further evaluation.

The IST Program indicates that

RHR valve 710 A/B, 853 A/B

and 854 are exercised quarterly.

Per PT-2.2 these

valves

are only partial-stroke

exercised

monthly.

Various other.

procedures

result in partial-stroking of these

valves at

other frequencies.

The

ASME Code,

Section XI, requires

full-stroke exercising quarterly.

If these

valves cannot

be ful-1-stroke exercised

quarterly at power or during cold

shutdown,

10 CFR 50.55a requires that relief from the

Code

requirements

be included in the IST program.

The licensee

has not submitted

a relief request to the

NRC.

(4)

(6)

(7)

SI Accumulator Discharge

Check Valves 842A/B and 867A/B

The inspector

reviewed procedures

PT-2. 10. 1 and PT-2. 10.7

which describe

the exercising of these

PT-2 '0. 1 requires that

a flow rate of 300

gpm be

established

during

a refueling outage

to verify the

opening of check valves

867A and

B.

PT-2

~ 10.7 requires

that the opening of. check valves

842A and

B be verified

using

a 3/4-inch

RWST test linc'll of these

check

valves must

be capable

of discharging fluid from the

accumulator

within the time specified in the safety

analysis

which is considerably

higher than the flow rate

established

in the above procedures.

However,

the flow

rates

obtained during both procedures

only accomplish

partial-stroke

exerci sing for the respective

The licensee

indicated that since they have requested

relief from full stroke exercising, this item will not be

addressed

until the relief request is dispositioned

as

part of the

IST program review.

The

IST program indicates that SI pumps discharge

check

valves

870 A/B and 889 A/B are exercised

quarterly.

Per

PT-2. 1 these

valves are only partial-stroke

exercised

using

a 3/4" test line.

The

ASME Code,

Section

XI requires

full-stroke exercising quarterly at power or during cold

shutdown.

The licensee

has not submitted

an appropriate

relief request

to the

NRC.

The

IST program indicates that High Head Safety, Injection

877 A/B and 878 F/H are leak rate tested

every

forty months.

Per discussion with the plant personnel

and

review of the associated

PAID, the inspectors

learned that

valves

877 A/878

F and 877B/878

H are being leak rate tested

in series.

It was noted that there is no test connection

between

the two check valves in series

which would make

individual leak rate testing possible.

The

ASME Code,

Section XI, requires

check valves that perform

a pressure

isolation function to be leak rate tested individually at

least

once every two years.

The licensee

has not submitted

an appropriate relief request to the

NRC.

The

IST program indicates that Service Water

Pump Discharge

valves

4601,

4602,

4603

and

4604 are exercised quarterly.

Per discussion with the plant personnel

and review of the

associated

P8 ID; it was noted that there is

no flow instru-

ment installed at the

pump discharge

of, the service water

pumps.

PT-2.7 requires that

a flow rate of 1100

gpm be

established

through the associated

containment recircula-

tion fan unit during the

pump testing.

Measuring this flow

10

rate does not verify full-stroke exercising of these

check

valves.

The

ASME Code,

Section XI, paragraph

IWV-3522

requires that these

valves

be full-stroke exercised

quarter-

ly which the licensee

in this case

does not verify.

The

licensee

has not submitted

an appropriate relief request

to

the

NRC.

B.

Valves Not in IST Pro

ram

Check Valves 3992

and 3993

'The inspector

observed

from a review of the

IST program

that the main feedwater

3992 and

3993 were not

included in the

IST program.

However,

these

two check

valves

have

a safety related function to close to prevent

diversion of auxiliary feedwater

back through the main

feedwater

system.

Reverse

flow testing is required to

demonstrate

the ability of the valves to close

by ASNE

Section XI, IWV-3522.

The inspector

noted that such valves

need to be evaluated

to assure

that the safety related

systems will function,

when called upon.

In response

to this concern,

the licensee

noted that recent

maintenance

(2/22/87 for 3992 and 3/10/86 for 3993)

had

been

performed

on both valves with only minor internal

repairs required.

The licensee

indicated that the long

term approach

to satisfying the

IST requirements

may be to

perform periodic disassembly

and inspection of these

valves.

(2)

Check Valves

3504B and

350SB

These

are 6-inch check valves located

downstream of steam

admission

MO valves

3504A and 3505A which direct steam

from

each

steam generator

upstream of each

NSIV to the turbine

driven

AFW pump.

Downstream of the check valves the piping

connects

to

a

common line and then to the

AFW pump turbine.

The inspector

noted that neither check valve was included

in the

IST program.

The licensee

indicated that this was

an inadvertent error and would be corrected.

During the performance of the turbine driven

AFW pump

testing the inspector

noted several

inadequacies

with PT-3

regarding

the testing for check valves

3504B and

3505B as

follows: (I) neither

valve was tested for reverse

flow

seating capability (i.e., in the check position)

and (2)

the valves were not individually tested for forward flow.

Since the check valves

have external

counterweight

arms

which are attached

to the check valve disc,

the licensee

took immediate

steps

to individually assess

valve

operability by using thi s external

counterweight

arm.

" Check

valve

3505B operated freely.

However,

check valve 3504B

was binding in that the disc would remain in the position

to which it was forced when operating

the counterweight

arm.

The counterweight

arm apparently

was not functioning

as designed

to keep the check valve disc in the closed

position during its normal, non-flow condition.

Valve

3504B was declared

inoperable

on May 18,

1988,

and mainte-

nance work was initiated to replace

the packing which

exists in the packing gland around the counterweight

actuator shaft.

It was postulated

that this packing

was

causing

the check valve binding problem.

The packing

was

removed

on May 19,

1988, but check valve 3504B still evi'-

denced binding and did not fully operate.

At the

end of

the inspection

3504B was still inoperable

and the licensee

was preparing to do further maintenance

on the valve.

The

inspector

noted that uncertain

check valve operation

in the

check position presented

a potentially significant safety

issue.

If the turbine driven

AFW pump is assumed

to be

operating

in conjunction with a main

steam line break

accident

and either check valve fails to seat in the check

position,

the intact steam generator

could feed the break

at the faulted

steam generator.

Although this matter

was

discussed

with the licensee,

no formal response

was received

which evaluated

the safety significance of this item relative

to the accident

analyses.

Concerning the issue of not individually testing the check

valves for forward flow, the inspector

noted that PT-16 was

performed with steam flow supplied simultaneously

from both

steam generators

to the

AFW pump turbine.

Periodic testing

in this manner

does

not assure

detection of a failure in,

one check valve when the other is functional.

The licensee

indicated that PT-16 would be upgraded

to individually test

these

check valves for forward flow and reverse. flow.

3.2

Other Observations

Concernin

Valve Testin

Discussions

with RKT personnel

indicate that the licensee

practice

concerning

the

maximum allowable stroke times for power operated

valves

was reasonable

and conservative.

The method basically

consists

of establishing

an average

stroke time based

on

3 valve

strokes.

The average

stroke time is increased

by a factor of 1.25

for valves with a stroke time greater

than

10 seconds

and 1.5 for

valves with a stroke time less

than

10 seconds

to obtain

maximum

allowable stroke times.

12

The review of several

procedures

indicated that the licensee

did

perform full-'stroke exercising of some check valves.

Procedure

PT-2.8 for the component cooling water system requires that check

valves

723A and

B be exercised

by establishing

a flow rate of 2500

gpm which is an acceptable

full-stroke exercising.

Similarly

procedures

PT-16

and 36 demonstrate

full-stroke exercising for the

Condensate

Storage

Tank suction

and the

pump discharge

by establishing

a flow rate of 200

gpm and 400

gpm for

the motor driven

and turbine driven pumps,

respectively.

4.0

Pum

Testin

Pro

ram

Similar to the valve testing

program,

implementation of the

pump testing

requirements

of the

IST program is achieved

through the performance of PTs

which are well written and clear to follow from an

IST standpoint.

Acceptance criteria are clearly defined

and are basically contained

on" an

individual inservice test data

sheet for each

pump at the

end of the

procedure.

In addition to reviewing many

PTs with the associated

data

which had already

been

performed,

the inspectors

witnessed

S pump tests

three

AFM pump tests

per PT-16

and two

SAFW pump tests

per PT-36.

The inspector

reviewed the completed

procedures

listed in Attachment

A and determined

in general

that:

acceptance

criteria were established;

proper review and approvals

were obtained;

data evaluation

were performed;

instrumentation

was calibrated;

and,

dispositions of failures were adequate.

Also, the inspector

reviewed the post maintenance

testing

performed

on the "A" Safety Injection (SI)

pump subsequent

to the

r epai rs

(pump disassembly

to install

new mechanical

seals)

completed

on Narch

6,

1988.

The SI

pump test per

PT 2. 1 was performed

and it

reconfirmed that the prior pump acceptance

criteria were still valid.

e

The inspector

had several

observations

as

a result of the

pump test

witnessing

as detailed

below.

4.1

Findin<is

Good coordination

between

the test personnel

and Control

Room, licensed

operators

was

a strength.

Constant

and close

phone

communication

was

maintained

throughout

each test.

It was evident that the test

personnel

were knowledgeable

and well experienced

as evidenced

by the

deliberate

and careful controlled warmup procedure for the turbine

driven

AFW pump test.

13

Each of the

5 pump tests

observed

was conducted

such that full flow

(typically 200

gpm to each

steam generator)

testing resulted with

pump run time of approximately

15 minutes.

This type of testing is

considered

to be

a strength

from a

pump performance

and

standpoint.

The inspectors

observed vibration measurements

taken during the

auxiliary feedwater

pump testing

on May 17,

1988.

Measurements

were

taken in the horizontal

and vertical directions

on both the inboard

and outboard bearings.

This practice

exceeds

the

Code requirement of

taking readings

on only one bearing

and in the vertical or horizontal

direction with highest baseline vibration amplitude.

This approach

represents

good engineering

practice

and would likely,reveal

pump

degradation

sooner

than

by following Code requirements.

The inspector

reviewed several

pump record

sheets

incorporated into

the procedures

for the testing of pumps

and valves in the

IST program.

The acceptable

range

on these

sheets

permits simultaneous

plus or

minus deviation from the reference

values for both pressure

and flow.

The

ASME Code Section XI, paragraph

IWP-3100, requires that the

system resistance

be varied until either the measured

pressure

or

flow rate equals

the reference

value

and that the other parameter

be

measured.

However,

based

on discussions

with test personnel

and test

witnessing,

the inspectors

determined that actual testing

was meeting

the

Code requirement

and

a procedure clarification would be

appropriate

to resolve

the above discrepancy.

This item will be

carried

as unresolved

(50-244/88-10-02)

pending the licensee's

action

to clarify the affected procedures.

5.0

Review Comments

on Current

IST Pro

ram

During the inspection,

the inspector

had several

observations

concerning

the

IST program.

The more significant i.tems were previously mentioned

concerning

the omission .of certain clieck'alves

from the

IST program

and

inadequate

testing of certain check valves.

Other items were discussed

with the licensee

where certain observations/questions

pertinent to the

IST program were presented.

These

are items requiring resolution during

the forthcoming

NRC staff review of the next

10-year interval

IST program.

The specific items are detailed

below and they will be carried

as

unresolved

items

as applicable

pending the formal

NRC staff review of the

IST program.

5. 1

Full-Stroke Exercisin

of MSIVs

The MSIVs (valves

3516

and 3517) are designated

in the

IST program

to be full-stroke exercised

on

a refueling cycle basis.

While this

is consistent with the plant technical

specifications, it is not

consistent with the

ASME Code,

Section

XI which stipulates

a cold

14

shutdown (not refueling) frequency for those valves where quarterly

exercising is not practical during plant operation.

The inspector

requested

the licensee

to evaluate this matter

and determine their

basis for the .full-stroke exercising

frequency of the MSIVs.

This

item is unresolved

(50-244/88-10-03)

pending the licensee's

action

to resolve this issue;

5.2

Testin

of Service Water Solenoid Valves for AFW Pum

Lube

Oil Coolers

These valves are designated

as

4324,

4325

and 4326.

They serve to

warn the operator of potential

clogging of the filter in the service

water piping upstream of the lube oil cooler for each

AFW pump.

The

valves

appear

to have

a safety related function but they are not

~

currently included in the

IST program.

However,

these

valves are

tested

monthly with the

AFW pump testing in PT-16.

Since the valves

are being periodically tested

and they appear to have

a safety

related function, the inspector

requested

the licensee

to evaluate

inclusion of these

valves in the

IST program.

This item is unresolved

(50-244/88-10-04)

pending completion of the licensee's

evaluation.

5.3

Inclusion of Manual

Valves

4098

4344

and

4345 Into IST Pro

ram

These

manual

valves

are normally closed

and when opened

they direct

service water flow to the suction of each

AFW pump.

The valves are

not currently included in the

IST program

even though they are being

full stroke exercised

monthly in PT-16.

Since these

valves must

change positions to serve their safety related function, they should

be formally included in the

IST program.

The licensee

indicated

that valves

4098,

4344 and

4345 would be included in the IST program.

6.0

General

Comments

Concernin

Basis of IST Pro

ram

The. inspectors

performed

a preliminary review of the Ginna

IST program.

Also several

procedures

were reviewed during the inspection.

This review

revealed

a lack of understanding

of the check valve stroking requirements

and omission of key information from the testing

program.

Specifically,.

the

IST program does

not indicate

how

a check valves is exercised, i.e.,

partial stroke and/or full stroke including its associated

frequency.

Also, the program does not identify what is the safety-related

position of

the check valve, i.e.,

open,

closed,

or open

and closed.

It is not

possible,

for example,

to determine

from the program whether

reverse

flow

testing is being performed.

These deficiencies

in the program resulted in

reverse

flow testing not being performed in general,

and full stroke

exercising

not being performed in many cases.

These deficiencies will be

carried

as

an unresolved

item (50-244/88-10-05)

pending resubmittal of the

IST program for formal

HRC review.

15

In addition,

valve number

9705A,

on Process

and Instrumentation

diagram

(P8 ID) No.

33013 Revision 2,

was incorrectly identified as

9075A.

Upon

identification of this concern,

the licensee

representatives

agreed

to

review and revise this P&ID.

7.0

A/

C Involvement in IST Pro

ram

The inspector

reviewed the

1986

and

1987 audit reports

completed

by the

licensee's

QA group for the

IST program.

Also the inspector

reviewed

a

sample of surveillance

reports

issued

in 1988 by the

QC group for certain

IST activities.

Based

on these

reviews

and discussions

with licensee

personnel

ihe inspector

observed

the following:

The licensee's

QA and

QC independent

oversight

and assessment

of the

IST activities resulted

in certain findings.

However,

these findings

have not been significant to the extent that the major elements

of

the

IST program

have not'een

affected.

Finding resolution

and

conclusion

have

been

such that component operability

has not been

addressed

since the causes

for the findings (a missed surveillance or

an incorrect instrument reading)

have

been classified

as isolated

problems.

Generally

each

PT includes instructions to notify QC prior to the

test.

QC surveillance

personnel

were present

to monitor the

5 pump

tests

that were performed

on May 17,

1988 per PT-16 and 36.

However,

discussions

with QC personnel

indicated that there

was

a random

selection of PTs for QC involvement based

on available

QC manpower.

In conclusion,

while there is

some level of QA/QC coverage for the