ML20057C032

From kanterella
Jump to navigation Jump to search
Insp Repts 50-498/93-27 & 50-499/93-27 on 930823-27.No Violations Noted.Major Areas Inspected:Reliability & Operability of safety-related Check Valves
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-76

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

PDR

ADOCK 05000498

i

G

PDR

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

check valves.

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

  • J. Fox, Design Engineer
  • J. Haning, Staff Engineer, Design Engineering
  • 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
  • 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

,

- 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