ML20046B038
| ML20046B038 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/26/1993 |
| From: | Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20046B033 | List: |
| References | |
| 50-382-93-24, NUDOCS 9308030030 | |
| Download: ML20046B038 (7) | |
See also: IR 05000382/1993024
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APPDWIX
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U.S. NUCLEAR REGULATORY COMISSION
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REGION IV
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Inspection Report:
50-382/93-24
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License:
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Licensee:
Entergy Operations, Inc.
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P.O. Box B
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K111ona, Louisiana
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Facility Name:
Waterford Steam Elec'tric Station, Unit 3'
Inspection At:
Taft, Louisiana
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Inspection Conducted:
July 6-9, 1993
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Inspector:
L. E. E11ershaw, Reactor Inspector, Division of~ Reactor Safety
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Approved:
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Dr. Dale A. Powers, Chief, Maintenance Section
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Division of Reactor Safety
Inspection Sumary
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Areas Inspectedt - Routine, announced followup inspection of the effectiveness ..
of licensee activities taken in response to an NRC audit of the safety-related
check valve program.
Results:
The licensee's extensive reevaluation of its check valve program.
exceeded the recomendations identified in the 1991 NRC audit report.
The licensee's approach toward program improvements was proactive-
(Section 2.2).
Sumary of Inspection Findinas:
All of the recomendations were closed (Section 2.2).
Attachments:
Attachment - Persons Contacted and Exit Meeting
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9308030030 930727'
ADOCK 05000382
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DETAILS
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PLANT STATUS
During this inspection period, the plant was operating at 100 percent power.
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FOLLOWUP (92701)
During September 30 through October 4, 1991, the NRC conducted an audit of the
licensee's check valve program using draft Temporary Instruction 2515/110,
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" Effectiveness of Licensee Activities Regarding the performance of Safety
Related Check Valves." The NRC audit report was issued November 19, 1991.
The audit report concluded that the licensee had a satisfactory and effective
inservice test (IST) program and a satisfactory check valve reliability
program; however, certain concerns were identified for licensee consideratior.
2.1 Discussion
The licensee submitted letter W3F191-0831 dated December 26, 1991, in which
responses to the recommendations, including implementing schedules, were
provided. A subsequent licensee letter, W3F193-0129 dated March 29, 1993,
documented a discussion with the NRC in which an extension had been discussed
and concurred with regarding one of the responses.
The inspector reviewed the audit report and licensee responses, and verified
that all issues had been appropriately addressed. The licensee grouped the
responses by subject matter and assigned a commitment tracking number to each
grouping. Since the NRC audit report did not assign unique identifiers to
each recommendation, the inspector used the licensee's commitment tracking
numbers to identify, sort, and evaluate the responses to the recommendations.
Commitment Tracking No. A-17914 dealt with the need to perform a
reevaluation of the check valve design review to determine if additional
valves should be included in the check valve program, and to provide
guidance on prioritizing, grouping, and establishing frequencies of
check valve monitoring and maintenance activities.
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The licensee responded by establishing actions to (1) evaluate the
adequacy of the check valve program scope; (2) specify enhanced criteria
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to be considered when evaluating present and future check valve
applications; (3) develop criteria for prioritizir.g, grouping, and
establishing frequencies for monitoring and maintenance activities;
(4) provide application guidance on design input checklists; and
(5) provide information on the design input checklists to ensure that
new and existing check valves were considered for the check valve
program. These actions had been scheduled for completion to support
check valve inspections during the sixth refueling outage, which is
scheduled for March 1994.
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The inspector verified that the methodology for implementing these
actions had been incorporated into the following program
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documents: Check Valve Analysis and Prioritization Program, a
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computer program that was installed in June,1993; Waterford 3.
Steam Electric Station Check Valve Program Plan dated December 29,
1992; and Waterford 3 Design Engineering Guide M/C-D-001,
Revision 1, dated January 4, 1993.
Commitment Tracking No. A-17915 dealt with the need to strengthen the
check valve maintenance training program,
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The licensee responded by stating that additional training needs had
already been identified during curriculum comittee meetings. As a
result, training on specific types of valves was established and
initiated on December 11, 1991.
The inspector verified, by review of attendance records, that
maintenance training was provided to maintenance personnel during
December 1991, and January and February 1992, on specific types of check
valves, and that lesson plans had been strengthened and revised. Also,
a management observation program was in place to monitor various
activities, including training effectiveness.
Comitment Tracking No. A-17916 dealt with six specifically identified
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issues related to the IST program.
Each issue, including the licensee's
response and actions, is as follows:
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Recomendation 1 dealt with the IST basis document' that justified the
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inclusion or exclusion of check valves for the IST program.
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recommended that the licensee formally review, approve, and maintain the
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document as part of the IST program.
The licensee's response comitted to formalize the document by March
1993.
Subsequently, the licansee requested and received an extension
until December 18, 1993. This was done so that the licensee could
update the IST basis document concurrent with a resubmittal of the_
Waterford 3 IST Plan, which is scheduled for August 1993. The inspector
verified that the licensee had documented (by Letter W3F193-0129 dated
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March 29, 1993) the extension request made on March 11, 1993, and the
NRC concurrence. The inspector also noted that the licensee had issued
memoranda which directed and provided guidance in formalizing the IST
basis document.
Recommendation 2 dealt with the need to specify the testing requirements
for closure of Safety Injection Valves SI-107A and 1078 in the IST
program.
In addition, it was recommended that the need for leak rate
testing of these valves be evaluated in terms of NRC Information Notice 91-56, " Potential Radioactive Leakage to Tank Vented to
Atmosphere."
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The licensee committed to add the closure testing requirements (or
submit relief requests) to the IST program as part of the program
revision that will be issued following NRC's review of Change 4 to
Revision 7 of the program. This was scheduled to occur in August 1993.
The inspector noted that relief requests and alternate testing proposals
were prepared for submittal to the NRC.
Further, the inspector noted
that the licensee performed an evaluation of leak rate testing of the
safety injection valves in terms of Information Notice 91-56. This was
documented on an Engineering Review Record dated May 20, 1992. The
evaluation summary stated that the conclusion of the original
calculation was unchanged.
Recommendation 3 dealt with Feedwater Check Valve Test
Procedure OP-903-033, " Surveillance Procedure for Cold Shutdown IST
Valve Testing," incorrectly indicating that ASME Section XI requirements
could be waived for Check Valve FW-181A upon satisfactory performance of
a maintenance visual inspection.
The licensee committed to correct the procedure and to conduct a review
of other testing procedures to determine if the same, or similar notes
existed.
The inspector verified that Procedure OP-903-033 was revised on
November 1, 1991, eliminating the erroneous note. The Event Analysis.
Reporting and Response Department performed a review of past use of this
procedure to determine if the note had ever been invoked.
It was
determined that the provisions of the note had not been used.
Further,
by Memorandum W385-92-0035 dated January 31, 1992, it was documented
that a review of all other procedures that implement IST requirements
revealed no other similar provisions.
Recommendations 4 and 5 suggested that the licensee revise Surveillance
Procedure OP-903-108,"SI Flow Balance Testing," due to its unclear
definition of which check valves were being tested and to revise the
acceptance criteria of the high pressure safety injection cold leg check
valves to reflect the guidance in NRC Generic Letter 89-04, " Guidance on
Developing Acceptable Inservice Testing Programs," respectively.
The licensee committed to revise the procedure to clarify which check
valves were being tested, and to clarify the acceptance criteria for
check valves, and to include appropriate sign-offs for each check valve
tested.
The inspector verified that the clarifications had been made, and that
the testing criteria was revised to account for the minimum flow through
each valve rather than testing the open function of these valves using
criteria for system requirements.
Sign-off locations were also
designated to show completion or verification of check valve testing.
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These changes were incorporated into Revision 3 of Surveillance
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Procedure OP-903-108, dated September 30, 1992.
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Recomendation 6 dealt with revising Relief Request 3.1.63 to provide
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information which would indicate why certain valves in the nitrogen gas
system could not be full-stroke exercised during each refueling outage.
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The licensee comitted to revise the relief request following the NRC's
review of Revision 7 to the Waterford 3 IST program.
The inspector verified that the licensee had prepared new Relief
Request 3.2.28, which addressed partial-stroke exercising on a quarterly
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basis and full-stroke exercising during cold shutdown conditions.
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was scheduled to be submitted with Change 4 to Revision 7 of the
Waterford 3 IST program in August 1993.
The inspector identified a recomendation in the NRC audit report that
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apparently was not formally included in the licensee's comitment tracking
system. The audit report stated that neither the check valve program nor the
corrective maintenance program included a formal mechanism for routing
corrective maintenance work authorizations to the check valve coordinator
prior to work being performed. The concern was for a potential change that
could impact check valves performance without the check valve coordinator
being cognizant of the change.
While the licensee had not formally identified this recomendation with a
comitment tracking number, it had previously addressed the concern. The
inspector was provided with Testing Procedure MM-007-021, " Check Valve
Monitoring by Non Intrusive Tests and Inspection Methods," Revision 2, dated
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September 17, 1992. Testing Procedure MM-007-021 provided instructions for
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gathering data on check valves to used in support of Administrative Procedure
MD-001-029, " Check Valve Monitoring, Maintenance, and Trending Program,"
Revision 1, dated April 1, 1990. Test Procedure MM-007-021 addressed r quired
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input on an attached form at designated points that must be reviewed by the
check valve coordinator prior to work' proceeding beyond that point. Further,
all disassembly activities to be performed on ASME check valves had to receive
an ASME Section XI review by the check valve coordinator.
2.2 Conclusion
The licensee's extensive peevaluation of its check valve' program exceeded the
recomendations identified in the 1991 NRC audit report. The licensee's
approach toward program improvements was proactive. All of the NRC's 1991
audit recomendations for followup are considered closed.
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ATTActMENT
I PERSONS CONTACTED
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Licensee Personnel
- R. Azzarello, Director, Design Engineering
0. Bulich, Supervisor, Mechanical / Civil Design Engineering
- D. Constance, Shift Technical Advisor and Inservice Test Coordinator
- D. Dormady, Technical Assistant, Design Engineering
- T. Gaudet, Supervisor, Operations Licensing
- J. Hoffpauir, Superintendent,-Maintenance
- J. Hologa, Manager, Mechanical / Civil Design Engineering
- T. Leonard, Manager, Technical Services
B. Loetzerich, Licensing Engineer
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- C. Rousse, Training Engineer
M. Smith, Supervisor, Mechanical Maintenance Training
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- B. Taylor, Check Valve Program Coordinator, Arkansas Nuclear One
In addition to the personnel listed above, the inspector contacted other
personnel during this inspection period.
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- Denotes personnel that attended the exit meeting.
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EXIT MEETING
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An exit meeting was conducted on July 9,1993. During this meeting, the
inspector reviewed the scope and findings of the report. The licensee did not
identify as proprietary any information provided to, or reviewed by, the
inspector.
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