ML20086S644
| ML20086S644 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/26/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F191-0831, W3F191-831, NUDOCS 9201030253 | |
| Download: ML20086S644 (5) | |
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9 ENTERGY 5",",%im t:
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A. F. Durski n
W3F191-0831 A<l. 05 QA December 26, 1991 U.S. Nuclear Regulatory Conunission ATTN: Document Control Desk Washington, D.C.
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Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Audit Report of Effectiveness of Licensee Activities Regarding the Performance of Safety-Related Check Valves at Watsrford 3 Gentlemen:
gy Operations, Inc. hereby submits the responses to the specific issues L-identified in-the staff's report issued on November 10,1991, concerning the NRC's audit of Waterford 3's check valve activities. The attached responses include implementation schedules for recommended actions as requested in the NRC audit report.
If you l' ave any questions concer 'ing these responses, please contact B. R. Loetzerich at (50-1) 739-0630.
Very t uly yours,
..g-ln 8FGwl, n
V REa /BRL/drc A ttachment cc:
R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR l
R.B. McGehee N.S. Reynolds NRC Resident Inspectors Offico i
i nw1h11m e,cocxosoogg2 paa P
Attachment to W3F191-0831 Page 1 of -1 ATTACllMEN_T ENTERGY OPERATIONS, INC. RESPONSES TO STAFF RECOMMENDATIONS CONCERNING WATERFORD 3 CllECK VAINE ACTIVITIES Inservice Tasting (IST) Activities For clarity, each of the staff recommendr us involving IST activities will be treated separately.
1.
The staff recommended that the IST basis document that justifies the inclusion or exclusion of check valves Ior the IST program be formally revieweu, approved, and maintained by the licensee as part of the IST p rogram. The IST basis document will 1 e formalized in accordance with the staff's recommendation by March of 1993.
2.
The otaff recommended that the testing requirements for closure of check valves SI-107A and B be specified in the IST program. The closure requirements for these valves will be added to the IST program as part of the plan revision which will be issued following the NRC's review of Revision 7 to the IST plan. As noted in the staff's audit report, the NRC expects to complete their review in March of 1992.
In addition, the staff recommended that the need for leak rate testing of these valves be evaluated in response to NRC Information Notice 91-56,
" Potential Radioactive Leakage to Tank Venting to Atmosphere". Upon receipt of the notice, Waterford 3 initiated an engineering evaluation which is ongoing. The engineering evaluation should be completed within 4 months of receiving data which has been requested from Combustion Engineering. Actions required as a result of the evaluation will address the need for leak rate testing of theso valves.
3.
As documented in the staff's audit report, Waterford 3 committed to remove a note from the Feedwater Check Valve Test Procedure OP-903-033, Revision 9, which incorrectly indicated that the ASME Section XI requirements could be waived in lieu of a r.atisfactory maintenance inspection of check valve FW-181A. In addition, Waterford 3 agreed to review other testing procedures to determine if thegame (or a similar) note existed. If other examples are found, the reasons for the inclusion of the note will be evaluated. This review will be completed by March 31, 1992, and any procedure changes required will be implemented in conjunction with procedure revisions related to Revision 7 of Waterford 3 IST plan.
4.
The staff concluded that Surveillance Procedure OP-993108, "SI Flow Balance Testing", was uncl ear as to the definition of check valves which were being tested. As discussed in the audit report, Waterford 3 will revise this surveillance pcocedure to clarify the acceptance criteria for check valves and include appropriate sign-offs for each check valve tested. This revision will be completon in conjunction with procedure revisions related to Revision 7 of Waterford 3 IST plan.
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Attachment to W3F101 -0831 -
Page 2 cf 1 5.
Th 3 staff recommended that the acceptance criteria in Surveillance Precedure OP-903-108, "Si Flow Balance Testing", be revised for a llPSI cold leg check valves (SI-241 SI-?42, SI-243 and S1-244) to reflect the guidance in NRC Generic Letter 89-04 on testing check valves in parallel i
lines. The testing criteria in OP-903-108 will be revised to acecunt for the minimum flow through each valve rather than testing for the open function of these valves using criteria for system requirements. This procedure revision will be completed along with the procedural revision discussed in 4
item 4 above.
6.
The staff recommended that IST Relief Request 3.1.03 be rewritten to provide information which indicates why certain valves in the nitrogen gnu system cannot be full stroke exercised at each refueling outage. This relief request will be revised in the IST plan revision which will be issued following the NRC's review of Revision 'l to the Waterford 3 IST plan', which is expected to be complete by March of 1992.
Design Application Review The staff recommended that Waterford 3 perform a reevalu'ation of the check valve -
design review, including factors other than the misapplication facto s highlighted in INPO SOER 8G-03, to a) determine if additional valves should be included in the check valve program, b) provide guidance to prioritize and group chtek valves in the program,aud c) provide guidance on the frequency of mock valve monitoring and maintenance activities.
As discussed in the NRC audit report, the original Waterford 3 check valve design review referenced INPO SOER SG-03 and EPRI Application Guidelines for Check-Valves as the technical bases. The check valve design review was used as the basis for the Waterford 3 Check Valve Monitoring, Maintenance and Tronding Program when it was established in 1989.
The design review encompassed the check valve population in the critical systems identified by INPO SOER 86-03. Whlie the check valve design review included.
valve misapplication factors such as valve sizing, selection of valve type, location-in turbulent flow and orientation, the review did ennsluer other factors. When applicable, these factors included, but wera not limited to velve operation frequency, safety function, anticipated flow transioits, valve environment, corrosion of valve internale, and safety impact of valve failure. In mont cases, the review results identified misapplication because it was considered the most.
significant factor in determining whether a particular valve should be included in-the program. This emphasis is in accordance with INPO SOER 86-03 which recognizes valve misapplication as the primary reason for establishing the check-valve monitoring program. The check valves in the diesel start air system are included in the check valve program on the basis of operating frequency; this is an indication that other factors were considered in establishing)he scope of the Waterford 3 program.
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Attachment to W3F191-0831 Page 3 of 4 The check valves which were originally included in the check valvo program were selected in an attempt to identify those with the greatest potential for failure. As the design review illustrates, misapplication was the most significant factor considered. 110 wever, the program is not ihnited to check valvea selected only on the basis of misapplication. In addition to the check valves initially included in the check valvo program on the basis of operating frequency, a number of check volves have been added as the resuh of 1NPO concerns or upon consideration of maintenance history. For these reasons, Waterford 3 considers the scope of the l
check valve program to be appropriate in that it includes valves chosen for both the probability of failure as well as the consideration of actual failure.
Forty-one of thn sixty-seven valves currently included in the check valve program are also included in the Waterford 3 IST Program. Many of the valves evaluated during the initial design review may, have met some of the criteria for inclusion lu the check valve program, but the criteria was not severe enough to add the valves to the program because it was thought that the IST requirements would provido adequate protection against failure. Upon examination of the various design npplication factors considered in the initial review, only the more significant factors of mis ^ pplication and operating frequency warranted the a
nomination of check valves for the checi valve monitoring program.
The current population of check valves in the program is considered to include
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those valves most likely to experience premature wear and failure. Approximately two-thirds of the check valves in the present Waterford 3 check valve program have been inspected in the past two refueling outages. Only fourteen of the forty-one valves inspected have been found to have recognizable degradation and most of the deficiencies should not have prevented the valves from performing s
their intended design function. The remaining valves in the check valve program J
are scheduled for inspection during Waterford 3's next refueling outage, llefuel
- 5. The NRC audit report noted that, upon review of recorded check valve failure rahs. Waterford 3'e check volve failure rate for the last full cycle of operation was significantly below the indut:try avetago. Titia serves as an indication that the scope of the Waterford 3 check valve program is appropricato.
3 In consideration of the staff's recommendations concerning the Waterford 3 design application review, Design Engineering will evaluate the scope of the original dedgn review, the need for additional application criteria and any programmatic enhancements necessary to improve the existing check valve program.
Recommendations currently being considered include:
Enhance and approve the draft Check Valve Application Design Guide to specify the criteria that should be considered when evaluating present and future check valve applications.
Utilize the design guido and other applicable standards to review the mulation of check valves initially considered for the check valve p ogram and all other safety related check valves to evaluate whether the scope of program is adequate.
Develop criteria for the prioritization of valves in the check valve program.
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Attachment to W3F191-0831 Page 4 of 4 Develop criteria for possible grouphig of valves in the check valve program.
Develop guidance on the frequency of check valve monitoring and maintenance activities based on the above criteria.
In addition to the audit report recommendations discussed above, the staff recommended that the process used to evaluate and specify replacement valves be extended to include a determination for inclusion of replacement valves in the check valve program. Actions under censideration to specifically address this recommendation are:
Provide check valve application guidance on design input checklists to ensure that the application criteria of the EPRI check valvo guidelines are considered when preparing design changes and spare part equivalency evaluations.
7 Provide information on the design input checklists to ensure that now and existing check valves are considered for the check valve program as part of the design process.
Upon final determination of the specific actions required for enhancement of the dealgn application activities, Waterford 3 will formulate a schedule for implementation of those enhancements. The actions under cotilderation are currently targeted for completion to support check valve inspections during the sixth refueling outage.
Training Upon review of the Waterford 3 training program associated with check valve activities, the staff concluded that the program appeared to be minimally adequate and should be considered as an area for additional licensee management focus.
The staff specifically noted that the training program for me intenance should be enhanced.
In addition to Waterford 3's generic check valve trainii.g diacussed in the audit report, vendor speelfic training is currently offered in the continuing training p rogram. Additional training needs in this area were previously identified during curriculum committee meetings and were addressed by the training department.
As a result, specific training on Anchor Darling pressure seal check valves commenced on December 11,~1991, and will conclude in January of 1992.
Additional specific training on C k S dual plate wafer check valves is scheduled for February,.1992.
j Waterford 3's training effectiveness is monitored through the management observation program in an effort to identify areas for improvement.
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