ML20057C032
| ML20057C032 | |
| Person / Time | |
|---|---|
| Site: | South Texas |
| Issue date: | 09/10/1993 |
| From: | Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20057C029 | List: |
| References | |
| 50-498-93-27, 50-499-93-27, NUDOCS 9309240311 | |
| Download: ML20057C032 (16) | |
See also: IR 05000498/1993027
Text
_
_ _ _ _ _ _ _ _
.
APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-498/93-27
50-499/93-27
Licenses:
NPF-80
Licensee: Houston Lighting & Power Company
P.O. Box 1700
Houston, Texas
Facility Name:
South Texas Project Electric Generating Station, Units 1 and 2
Inspection At: Matagorda County, Texas
Inspection Conducted: August 23-27, 1993
Inspectors:
L. E. Ellershaw, Reactor Inspector, Maintenance Section
Division of Reactor Safety
M. F. Runyan, Reactor Inspector, Engineering Section
Division of Reactor Safety
R. C. Stewart, Reactor Inspector, Maintenance Section
Division of Reactor Safety
Accompanying Personnel:
V. G. Gaddy, Reactor Engineer, Technical Support
Section, Division of Reactor Projects
Approved:
M
Nh0/U
l
Dr. Dale A. Powers, Chief, Maintenance Section
Date
Division of Reactor Safety
l
Inspection Summary
Areas Inspected (Units 1 and 21:
Routine, announced inspection to determine
the effectiveness of the licensee's program for assuring the reliability and
operability of safety-related check valves.
Results (Units 1 and 2):
A formal check valve program document did not exist, but one was being
developed (Section 2.2).
9309240311 930916
f
ADOCK 05000498
i
G
L
'
.
4
,
.
,
.
-2-
There was no formal or documented coordination established between the
check valve program coordinator and other groups whose activities could
affect the check valve program (Section 2.2).
The identity of _ check valve program valves'was maintained in a data base
that was not named, dated, or approved (Section 2.2).
Errors pertaining to inspection frequencies existed between the Unit I
and Unit 2 check valve data bases (Section 2.2).
.
A check valve monitoring activity (i.e., non-intrusive examination
methods) had been established, but not implemented (Section 2.2).
J
The check valve design application review was very comprehensive and
i
included consideration of the relevant factors affecting check valve
j
durability (Section 2.3).
A lack of conservatism in engineering judgement and an apparent
imprecision in the input data may have resulted in an inaccurate
determination of those check valves most vulnerable to structural
deterioration (Section 2.3).
The licensee utilized effective corrective maintenance procedures in
response to check valve failures (Section 2.4).
The licensee had not developed preventive maintenance procedures for
Instead, the licensee relied on the initiation of service
requests to perform disassembly and inspection of check valves (Section
2.4).
The inspectors identified instances in which check valves failed local
leak rate testing and the licensee apparently did not perform any root
cause analysis (Section 2.4).
The licensee had utilized effective corrective maintenance procedures in
response to check valve failures (Section 2.4).
Trending procedures, methodology, or criteria had not been established
with respect to the check valve program (Section 2.5).
Industry information regarding check valve problems had been received
and appropriately evaluated for impact (Section 2.6).
The licensee had provided reasonable assurance of the operability and
reliability of check valves in safety-related systems (Section 2.8).
i
.
\\
-
-
-
.
.-.
.
.
.
.
.
-
.
-3-
,
Summary of Inspection Findinas:
No inspection findings were opened or closed.
)
i
Attachments
,
Attachment 1 - Persons Contacted and Exit Meeting
Attachment 2 - Documents Reviewed
,
1
i
1
l
1
1
)
l
I
.
.
.
.
-4-
,
DETAILS
_
i
1 PLANT STATUS
i
STP, Unit 1, was in Mode 5, and Unit 2 was defueled and in no mode during this
'
inspection period.
2 PERFORMANCE OF SAFETY-RELATED CHECK VALVES (TECHNICAL INSTRUCTION 2515-110)
The purpose of this inspection was to determine the effectiveness of the
'
licensee's program to provide assurance of the operability and reliability of
check valves in safety-related systems.
j
2.1
Backaround
f
In recent years, numerous deficiencies related to check valves have been
identified throughout the nuclear industry.
Information partaining to these
j
deficiencies has been disseminated by the NRC in Information Notices (ins),
and by the Institute of Nuclear Power Operations (INP0) in Significant
Operating Experience Reports (50ERs).
SOER 86-03, dated October 15, 1986, INP0 issued and distributed to licensees
in order to call attention to check valve deficiencies and failures. The SOER
attributed the major causes of failures to valve misapplication and inadequate
preventive maintenance. The SOER provided recommendations and
guidelines / attributes for establishing a preventive maintenance program and
,
for performing a design review of check valve installations.
Coincidentally,
with the development of the SOER, a program was initiated by the Electric
Power Research Institute (EPRI) to develop application guidelines for check
valves to assist utilities in responding to the SOER. This resulted in the
development of EPRI Report NP5479, " Application Guidelines for Check Valves in
Nuclear Power Plants."
2.2 Check Valve Proaram
The inspectors were informed that a formal check valve program document did
i
not exist, but that the need for one had been recognized and one was being
developed. The licensee further indicated that while no program document
existed, their efforts have been driven by the guidelines / attributes
delineated in 50ER 86-03. The licensee had developed a single procedure that
dealt exclusively with check valve inspection activities.
The procedure was
OPSPil-ZE-0001, " Check Valve Inspection Program," Revision 2.
Other
activities such as maintenance and inservice testing were accomplished using
i
l
procedures that were not dedicated to check valves alone. The inspectors also
noted that there was no documented or formalized coordination established
between the check valve program coordinator and other groups whose activities
,
could affect the check valve program. The licensee informed the inspectors
that this condition had also been recognized and action taken. The inspectors
were provided a copy of an office memorandum dated August 17, 1993, in which
this shortcoming was addressed, including the steps necessary to correct it.
.
.
.
..
.
,
-5-
,
The inspectors expressed concern that the licensee had not developed a check
valve program document that would provide the scope and objectives, describe
,
administrative structure and division of responsibilities for implementation
'
and control, and identify implementing procedures.
Procedure OPSPil-ZE-0001 stated that "a complete listing of check valves
included in this program is provided in the Check Valve Index." The
,
inspectors were provided copies of the STP, Units 1 and 2 Check Valve Indices,
4
both Revision 0 and dated January 10, 1992. The inspectors were also informed
'
that the indices were not current and did not reflect a complete listing of
check valves in the program.
It was explained that a different data base
(unnamed, undated, and unapproved) had been established which contained all of
the program check valves for both units. The inspectors' review of the
document revealed that different inspection frequencies had been established
for certain corresponding valves in each unit. The check valve program
coordinator informed the inspectors that the correct frequencies were listed
under the Unit I valves and that there had apparently been typographical
errors made when the data was being input to the Unit 2 valves. The
inspectors' subsequent review of inspection documents did not reveal any
missed inspections resulting from these errors. The data base showed that
there were a total of 566 check valves (283 from each unit) in the program, of
which 302 (151 from each unit) were in the inservice test program.
In order to establish with reascnable certainty that all safety-related check
valves had been included in the program, the inspectors reviewed piping and
instrumentation drawings from the following safety-related systems:
feedwater, component cooling water, residual heat removal, safety injection,
essential cooling water, chemical and volume control (partial), and essential
chilled water. No exceptions were identified.
Another activity that had not been implemented dealt with check valve
monitoring. The various monitoring techniques (i.e., non-intrusive
examination methods) had been evaluated and the. licensee stated that they had
selected the acoustic emission monitoring method with an implementation date
of September / October 1993.
Equipment had been purchased and personnel had
been trained in the use of the equipment. The last, remaining action (prior
to implementation) dealt with final equipment calibration, which was in-
process.
Procedure OPEP07-ZE-0008, Revision 0, "Non-Intrusive Check Valve
Testing," became effective on March 11, 1993. The procedure was well
organized and provided detailed instructions for implementing the non-
intrusive examination program.
2.3 Desian_ Application Review
'
The licensee contracted Kalsi Engineering (Kalsi) to perform a design review
of selected check valves at STP. The review was conducted in response to INP0
SOER 86-03, which directed utilities to perform an application review of check
valves installed in the following systems: main steam, feedwater, auxiliary
feedwater, component cooling water, chemical and volume control, safety
injection, residual heat removal, nuclear service water, and diesel air start.
--.
.
.
.
-6-
,
Kalsi evaluated check valves installed in each of the 50ER 86-03 systems and
additionally assessed check valves in the following systems: chilled water,
essential chilled water, extraction steam, and diesel oil.
Several check
valves installed in the selected systems were not reviewed, including check
valves used for testing or other non-safety-related applications. The review
was based on the guidelines provided in EPRI NP-5479. The objectives of the
,
review were to identify potential check valve misapplications, recommend
appropriate maintenance and inspection schedules, and recommend design
modifications to ensure reliable check valve performance.
Flow conditions were tabulated for each check valve and an estimate was made
of the number of hours each flow condition existed during a normal year of
operation. The minimum water or steam flow velocity needed to keep the check
valve fully open (Vmin) was calculated for each flow condition. When flow
velocities fell in the range of 70 to 115 percent of Vmin, the disc was
assumed to be tapping and an estimate of fatigue wear was calculated. When
flow velocities were less than 115 percent of Vmin, an oscillation angle and
frequency was computed for input into a calculation of hinge pin wear, which
was assumed to be the limiting wear component. For conservatism, 50 percent
hinge pin wear was assigned a value of 100 percent wear life. When flow
velocities exceeded 115 percent of Vmin, the check valve was assumed to be
fully open and stable and not experiencing any wear or fatigue.
From this
information, hinge pin wear and fatigue wear rates were calculated.
Based on
the wear rates, each check valve was assigned fatigue and wear indices, the
magnitudes of which corresponded to a recommended disassembly and inspection
frequency ranging from 1 to 10 years.
The licensee received the Kalsi report on May 5,1989.
The report summarized
the analytical calculations of wear and fatigue for each check valve and
recommended a frequency for inspection of the internal components.
No check
valve misapplications were identified and no modifications were recommended.
The inspectors reviewed the Kalsi report in detail and discussed questions
with the licensee and a representative of Kalsi Engineering. As an overall
assessment, the inspectors concluded that the Kalsi design review was very
comprehensive and included consideration of the relevant factors affecting
check valve durability. The methodology appeared consistent with the
guidelines presented in EPRI NP-5479.
However, in contrast to the technical merits of the evaluation, the inspectors
were concerned that a lack of conservatism in engineering judgement and an
apparent imprecision in the input data may have worked together to result in a
less than reliable determination of those check valves most vulnerable to
structural deterioration.
In other words, the Kalsi design study may have
i
-
L
- -
J
.
1
4
.
-7
,
l
,
,
misprioritized certain check. valves for scheduling of inspection and
{
maintenance. The points supporting this position are listed below:
1.
Disc Oscillation Frequency
Kalsi calculated the disc oscillation frequency of each check valve
using three' methods: disc natural frequency, flow eddy. frequency, and
i
disc pendulum frequency. Based on the engineering judgement of the
1
individual performing the analysis, one of these three calculated
i
frequencies was selected for input into a calculation of check valve
'
hinge pin wear. The disc oscillation frequency is directly proportional
to the hinge pin wear rate.
For almost every check valve reviewed by
Kalsi, .the flow eddy frequency was selected for. input to the wear
calculation. The calculated flow eddy frequency was the lowest of the
three calculated frequencies for almost every check valve in the study.
l
As a typical example, Check Valve FW-0062, operating under its
predominant service condition, was calculated to have a disc natural
frequency of 3.29 hertz (Hz), or cycles per second, a flow eddy
frequency of 0.77 Hz, and a disc pendulum frequency of 1.98 Hz. The
flow eddy frequency was used in the wear calculation.
Questioned on this issue, the Kalsi representative stated that if the
evaluation were performed today, the disc natural frequency would
probably be selected except when the check valve disc was oscillating in
close proximity to the seat, in which case the disc pendulum frequency
would be more appropriate.
This position, which represented a change
from the methodology.Kalsi used in 1989, was consistent with a summary-
document, " Proper Applications of Check Valves," published in 1992 by
Dr. Paul Tullis, a nationally recognized check valve expert.from the
Utah State University Water Research Laboratory. The nonconservative
selection of the flow eddy frequency resulted in as much as a five-fold
decrease in the wear rate that would result from use of the natural
oscillation frequency.
2.
Disc Oscillation Angle
The disc oscillation angle is used in conjunction with.the oscillation
frequency to compute the angular velocity of a swing' check valve. The
disc oscillation frequency, like the oscillation frequency, is
proportional to the wear rate. The inspectors noted that'in many cases,
the calculated disc oscillation angle had been reduced by up to a factor
of 2.25 prior to insertion of this factor into the wear calculation.
The Kalsi representative stated that the individual performing the work
y
was authorized to make changes to the calculated oscillation angle based
~
on engineering judgement. The representative stated that the changes
were made to correct for excessive conservatisms in the calculation.
The inspectors noted that-the angle changes were not made in any
consistent manner, but appeared to have been arbitrarily applied.
Though the practice of reducing the calculated angles may have been
l
._
._ _
_ ._ - ______ _
.__
.
.
-
.
-8-
,
justified, the method in which it was applied was not well controlled.
In a worse case situation, the use of a flow eddy frequency 5 times less
than the disc natural frequency and an oscillation angle reduced by a
factor of 2.25 would result in calculated disc wear at a rate 11.25
times less than that resulting from use of the conservative or
unadjusted calculated values.
3.
Weight and Dimensional Data Input
The dimensional and component weight values used in wear and fatigue
>
calculations were based on check valve manufacturer generic
specifications, when available.
In cases where information from the
manufacturer could not be found, the study used a " program default" data
base where specifications from similar valves were used. The default
information was used for approximately 40 percent of the input values.
The inspectors were concerned that use of potentially imprecise
information in the wear and fatigue calculations may have had a
significant effect on the accuracy of the calculated values,
j
.
Dr. Paul Tullis (referenced above) performed a sensitivity analysis
showing that a 3 percent variation in the full open disc angle changed
'
the Vmin value by about 12 percent. A 10 percent variation in the disc
diameter resulted in about a 10 percent variation in Vmin.
'
4.
Incorrect Data Input
The inspectors reviewed isometric and valve drawings for Check Valves
EW-0006, CV-0291, GC-0410, CV-0300A, RH-0032A, CC-0230, and ES-0029 to
check the accuracy of the data base used in the Kalsi study. A few
errors were detected. Check valve EW-0006 was analyzed using a' disc-
diameter of 21 inches and a disc arm length of 10 inches. The correct
values were 29.5 inches for disc diameter and approximately 5 inches for
i
disc arm length. The upstream disturbance for Check Valve CV-0291 was
listed as a medium turbulence source 24 inches upstream, which
corresponded to a control valve located in this position. However, a
90-degree flow elbow 12 inches upstream of the check valve (and 12
1
inches downstream of the control valve) was not considered.
~
The Kalsi representative stated that the elbow may have been
deliberately neglected in this case, although the inspectors expressed a
,
i
concern as to whether the combined effects of the valve and elbow had
been properly modeled.
.
5.
Lack of Iterative Analysis
Wear rates were calculated using dimensions of new check valves only.
.
As a check valve wears, the wear rate increases as a result of
increasing dimensional tolerances between moving parts. This effect was
not modeled in the Kalsi study.
.
.
_g_
.
According to the Kalsi representative, the assumption was made that
conservatisms in the calculational process would compensate for this
phenomenon.
As a result of the above considerations, it is possible that some check valves
determined to have low susceptibility to wear and fatigue may in fact be
experiencing high rates of deterioration. This would more likely apply to
check valves that are oscillating at natural frequencies, but which were
-
analyzed at flow eddy frequencies. This, in combination with other factors
listed above, may have resulted in calculated wear and fatigue rates well
below actual (assuming other conservatisms inherent in the analytical process
did not provide sufficient compensation). Check valves in this category may
not be examined internally until approximately 1998, based on the 10-year
inspection frequency Kalsi recommended for check valves having the lowest
calculated wear and fatigue rates.
The inspectors encouraged the licensee to review the Kalsi report to identify
check valves that may have been misprioritized. These valves should be
considered as early candidates for non-intrusive testing.
2.4 Maintenance Procram
Service Requests (SP,s) are the documents the licensee utilizes to schedule
disassembly and inspection activities performed on the designated check valve
program check valves. The inspectors selected and reviewed 36 SRs (identified
in Attachment 2) in order to evaluate the licensee's methodology for check
valve maintenance.
The check valve program data base (mentioned in paragraph
2.2), delineated the frequency for check valve disassembly and inspection
intervals, and provided the check valve tag number, valve size, type, and
manufacturer.
Procedure OPSP11-ZE-0001 was used in conjunction with the
check valve database and delineated the method and requirements for check
valve disassembly and inspection. Valve internals were inspected for wear,
corrosion, erosion, physical damage, and anything else that would prevent
valves from smoothly operating from the full closed position to the full open
position. This inspection program was developed in response to INPO SOER 86-
03 to identify existing and incipient failures of check velves.
In addition
,
to utilizing SRs to initiate inspections, the licensee also used SRs to
initiate repairs / replacements of check valves that failed local leak rate
testing (LLRT) or had been identified as having defects.
Of the 36 SRs reviewed by the inspectors, 27 had been written to initiate
disassembly and inspection, 6 were in response to LLRT failures, I was a low
flow failure caused by a clogged traveling screen, and 2 were contingency
inspected.
Contingency inspection refers to the required inspection of an
additional check valve upon identification that a similar valve from a group
had unacceptable inspection results. This was done to assess the potential
for the existence of generic problems. The inspectors observed that 28 of the
36 check valves were included in the IST program.
~
.
.
.
.
,
-
.
-10-
,
t
,
Based on the sampled check valves, the inspectors concluded that the licensee
had utilized effective corrective maintenance procedures in response to check
valve failures. Of the check valves which have had SRs initiated, only three
check valve failures have been repeat failures since commercial operation
began (Valves CC0123 and SA0505 for Unit I and CC0123 for Unit 2). The two
component cooling water (CCW) check valves were 16-inch, dual plate check
valves manufactured by TRW Mission. The station air (SA) check valve was a
2-inch lift check valve manufactured by Borg Warner.
i
The inspectors identified five instances in which check valves failed their
LLRTs and the licensee did not perform any analysis to determine the cause of
!
the failure. The valves were simply replaced with new valves and the failure
code was listed as " unknown".
Since no root cause analysis was performed, the
check valves could not be used for failure trending purposes.
.
Currently, preventive maintenance procedures (PMs) have not been established
for check valves. This activity has been accomplished (as mentioned above) by
the initiation of SRs.
The inspectors were informed, however, that
preventive maintenance procedures for check valves were currently being
developed and would be based on the disassembly and inspection frequencies
,
i
specified by the check valve database. The inspectors observed that there was
no defined methodology for increasing inspection frequencies for check valves
with unacceptable results or other deficiencies.
Pres 3ntly, the licensee
j
relied on engineering judgement and the discretion of , a check valve
'
coordinator to increase inspection frequencies. The inspectors acknowledged
the use of engineering judgement, however, stated that there were neither
defined actions nor expectations in this area.
)
i
Further, the inspectors identified that the licensee had not established a
basis or criteria for returning failed check valves to the manufacturer for
analysis. Again, check valves are returned to the manufacturer based on
engineering judgement.
During the past 2 years, several valves have been
returned to the manufacturer for refurbishment, but in each case the licensee
did not perform, nor request a root cause analysis be performed. Without
feedback from the manufacturer, there would be no input to toe database with
respect to preventive maintenance.
2.5 Trendina
Trending procedures, methodology, or criteria had not yet been established
with respect to the check valve program. The check valve program used the
j
Kalsi recommendations as a starting point for prioritizing valves for
-
disassembly and inspection. For lower priority check valves having
recommended inspection frequencies of 3, 5, or 10 years, time zero was
1
established as the beginning of commercial operation for each unit.
Prior
operations such as during preoperational testing and startup were not
]
considered. Additionally, the program did not include provisions to establish
baseline component dimensions that could be later used as a basis for
determining actual measured wear rates. Therefore, the availability of
l
-
.
-
.
-
_11_
.
material degradation trending data would be delayed for a considerable period.
2.6 Industry Information
The inspectors reviewed Procedure IP-2.2Q, " Operating Review Experience,"
Revision 8, dated June 10, 1992, which was the document that established the
methodology for screening and reviewing industry operating experience
information, including NRC bulletins and ins. The inspectors reviewed the
actions taken by the licensee in response to two NRC bulletins (83-03 and 89-
02) and five ins (86-01, 88-70, 89-62, 90-03, and 90-79), all pertaining tn
check valve problems. The licensee had established evaluation packages for
each of the NRC documents. The evaluation packages each exhibited a well
documented evaluation of the stated problem and a determination regarding
potential impact on the licensee's check valves.
In each case, the licensee
had determined that the condition was not applicable to their check valves.
The inspectors did nat identify any information during the course on this
inspection that was contrary to the licensee's conclusions.
2.7 Check Valve Walkdown
The inspectors conducted a walkdown of the following six ch, ck valves from the
noted systems, to verify valve size, orientation, location, and general
appearance:
EWOO42 (essential cooling water), GC0410 (stator cooling water),
ES0029 (extraction steam), CV0291 and CV0300A (chemical and volume control),
and CC0230 (component cooling water). The inspectors noted that valve CC0230
was tagged with a reference to SR 214629. Further review revealed that the SR
had been initiated to correct valve orientation. The check valve program
coordinator informed the inspectors that during the performance of disassembly
and inspection activities, it had been identified that three component cooling
water check valves (all dual plate check valves) had been installed
incorrectly (i.e., rotated 90 degrees from the manufacturer's recommended
position). This resulted in the issuance of Station Problem Report 930779 on
March 11, 1993. The licensee's engineering evaluation and discussions with
the manufacturer resulted in the conclusion that orientation would not affect
the ability of the valves to perform their safety function. However, the
valve manufacturer recommended that the valves be oriented in a position such
that the hinge pin would be vertical. The licensee initiated a walkdown of
all dual plate check valves. Seven check valves in the check valve program
were identified with hinge pins in a horizontal position. Subsequently, SRs
were initiated to correct orientation, and at the time during this inspection,
three had been completed. The SR database showed that the other four check
valves were still open but were scheduled for completion during this outage.
The inspectors did not observe any additional discrepant conditions.
2.8 Surveillance Check Valve Testino
The inspectors selected 62 safety-related check valves (identified in
Attachment 2) that were contained in the check valve programs for Units 1 and
2.
Check valve candidates were based on a selection from safety-related
_
_
_
-
___ _ _ ____ ______________
_ _ _ _
,
.
'
.
.
'.
.
-
-12-
-
,
i
'
P&ID's, RCS pressure isolation valves (PIVs), specified in Technical
Specification Table 3.4-1, check valves which were applicable to the IST
Programs 1-4 and 10 of Generic Letter 89-04, and check valtes which were
designated as having alternate methods of testing in accordance with submitted
'
relief requests.
The inspectors reviewed surveillance test records, which were an integral part
of the surveillance test procedures (See procedure listing in Attachment 2),
,
and included check valve operability verification testing methodology
'
prescribed by the licensee's check valve disassembly and inspection, IST, and
.
10 CFR 50, Appendix J programs. A review was performed which verified that
the sample valves were either tested and/or inspected and that none of the
valves had been inadvertently omitted from the testing programs. A review of
all the applicable surveillance test procedure records associated with the
sampled valves was made for technical adequacy and clarity, and no
discrepancies were identified.
For full-stroke tests, the licensee met the
criteria established in Generic Letter 89-04 (i.e., for those valves not
having a visible position indicator, the open position may be verified by
passing the maximum required flow through the valves that corresponded to the
t
analyzed accident condition).
Subsequent to the exit meeting, the inspectors discussed with the licensee
representatives an observed incorsistency in the frequency of testing and the
check valve disassembly / inspection cycle for each check valve within its
respective groups. The column under " inspection frequency," contained in the
STP, Units 1 and 2, check valve index dated January 9,1992, indicated 10-year
cycles (specifically, Check Valves AF0058, AF0121, CC0336, and CC0541).
However, the referenced 10-year cycle frequency was in conflict with the IST
i
Program Testing Requirements and Generic Letter 89-04, Item 2, which
established the maximum cycle for each valve (disassembly / inspection) of
6 years.
It was further pointed out by the inspectors that the current
approved IST Program Plan, Revision 5, relief requests, RR-12 and RR-43, did
not address the 6-year limitation.
The licensee representatives stated that contrary to the check valve index
documents, testing and disassembly / inspection cycles for check valves within
the IST Program were being accomplished in accordance with Section XI Code
Requirements and/or IST Relief Requests. Clarification of the check valve
,
disassembly / inspection frequencies relative to the 6-year cycle was now
l
incorporated in Relief Request RR-51, Revision 6, of the IST Program Plan,
I
recently submitted to NRR for approval.
In addition, the licensee
representatives stated that for .. heck valves within the program, but not
within the IST Plan, disassembly / inspection frequencies were to be performed
i
within the 6-year cycle and clarified in the administrative program plan for
'
check valves (see above Section 2.2).
The inspector's review concluded that the check valve surveillance testing
program provided reasonable assurance of the operability and reliability of
check valves in safety-related systems.
c
_
_ _ _ _ _ _ - _ -
_ _ -
.
l
4-
4
ATTACHMENT 1
'
,
1 PERSONS CONTACTED
1.1 Licensee Personnel
- H. Bergendahl, Manager, Technical Services
l
- W. Blair, Manager, Staff Training Division
- D. Bryant, Chemical Analysis General Supervisor
- M. Chakravorty, Executive Director, Nuclear Safety Review Board
- T. Cloninger, Vice President, Nuclear Engineeri.7g
- R. Cook, Industry Relations
- W. Cottle, Group Vice President
- H. Coughlin, Senior Licensing Engineer
i
- H. Ebel,Section XI Coordinator
- J. Fox, Design Engineer
- J. Haning, Staff Engineer, Design Engineering
- W. Harris,Section XI Supervisor
- S. Hubbard, Quality Control Supervisor
- J. Johnson, Supervisor,- Quality Assurance
- T. Jordan. General Manager, Nuclear Engineering
- D. Keating, Director, Independent Safety Engineering Group
R. Kersey, Design Engineer
i
- D. Leazar, Manager, Plant Engineering
- L. Martin, General Manager, Nuclear Assurance
- G. Parkey, Plant Manager
,
i
- P. Parrish, Senior Licensing Specialist
'
- U. Patil, Supervising Engineer, Design Engineering
- J. Sheppard, General Manager, Nuclear Licensing
- B. Tran, Check Valve Program Coordinator
- C. Walker, Manager, Public Information
l
- P. Walker, Staff Engineer
- J. Wigginton, Associate Engineer, Licensing
1.2 Kalsi Enoineerina. Inc.
,
1
V. Sharma
1.3 NRC Personnel
- D. Loveless, Senior Resident Inspector
- Denotes personnel attending the exit meeting.
In addition to the personnel listed above, the inspectors contacted other
personnel during this inspection.
,
2 EXIT MEETING
.
An exit meeting was conducted on August 27, 1993. During this meeting, the
inspectors reviewed the scope and findings of the report. The licensee did
not identify as proprietary any information provided to, or reviewed by, the
inspectors.
l
l
l
.
..
.
.
.
-2-
On September 13, 1993, the licensee's Senior Licensing Engineer was notified
by telephone that a written response to the negative inspection findings would
be requested in the inspection report transmittal letter. The specific
negative findings were discussed at that time. On September 14, 1993, the
'
Deputy Manager of Licensing committed to provide a response within 60 days of
t
receipt of the NRC's transmittal letter.
,
t
i
$
,
1
0
..
-
-
.
.
.
\\
,
.
'
ATTACHMENT 2
,
.
DOCUMENTS REVIEWED
.
Service Recuest No.
Valve No.
Check Valve Index Disassembly and Inspection
109802
EWO259'
90697
S10038C'd
155956
EWOO42
111644
CH0295*
101343
CH0286*
150225
RH0065A'd
176209
CH0295*
'
150219
CH0286*
90748
RH0065A
111643
CH0304'
,
176210
CH0304'
176225
EWOO42*'
175615
EWO370B'd
150214
CC0540*d
92453
S10046A'd
90586
CC0051" '
92452
S10038A
2d
150245
CC0540
156336
CC0319
l
118254
CS0005'd
157004
CS0005'd
I
'
.
150239
EWO370B
-l
l
150209
EWO370A
176207
CC0319
.l
,
l
166466
CS0005'd
l
176226
EWOO79
176224
EWOOO6*'
LLRT Failures
81972
CC0183'd
81967
CC0198'd
172303
SA0505
l
118464
CC0198
j
49538
CC0123
l
118141
CC0123
Low Flow Failure
i
l
148151
CH0286
i
j
l
1
l
l
1
/
.
!
I
-
.
l
'
.
,
-2-
,
,
'
!
Contingency Failures
155955
EWOOO6*'
155957
EWOO79 '
2
' - Unit 1 Check Valve
,
- - Unit 2 Check Valve
- Valves included in the licensee's IST program
'
.
Selected Check Valve Samples (Each Unit)
l
SI-0038 A, B, C
51-0046 A, B, C
,
SI-0010 A, B, C
l
RH-0020 A, B, C
RH-0065 A, B, C
'
CC-005
CC-051
CC-0198
CC-0540
CC-0541-
CC-0319
CS-005
EW-006
i
EW-042
EW-029
EW-370 A, B, C
D0-056
D0-062
D0-127
'
Procedures
OPSPll-ZE-0001, Revision 2
Check Valve Inspection Program
2 PSP 03-51-0023, Revisions 1 & 3
Check Valve Surveillance Tests
OPSPM-ZA-005, Revision 7
Containment Leak Rate Testing
OPSPS05-EW-0019, Revision 2
Essential Water Surveillance Test
2 PSP 03-SI-0023, Revision 3
Pressure Isolation Valve-leak Rate
Test
Pump and Valve Inservice Test Plans,
Units 1 & 2, Revision 5 & 6, dated
August 23, 1990, and May 5, 1993
OPGP03-ZX-0002, Revision 1
Corrective Action Program
i