IR 05000213/1992081
| ML20127D765 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/08/1993 |
| From: | Eapen P, Prividy L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127D747 | List: |
| References | |
| 50-213-92-81, GL-89-10, NUDOCS 9301190033 | |
| Download: ML20127D765 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I ,
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REPORT / DOCKET NOS, 50 213/92-81 LICENSE NO DPR-61 LICENSEE: Connecticut Yankee Atomic Power Company FACILITY' NAME: Haddam Neck Plant INSPECTION AT: Haddam, . Connecticut INSPECTION DATES: October 5-9,1992 onsite October 29, November 12, December 10,1992 and January 5,1993 in Region 1 Office TEAM MEMBERS: M. Buckley, Region I P. Drysdale, Region I L. Kay, Region I A. Wang, NRR M. Holbrook, Contractor, INEL fa~m4 Q. fs&r, llEl93 ~
Leonard J. Prividy, Team Ifader, Date Systems Section, EB, DRS APPROVED BY: 'ke Ls Dr. P. K. Eapen, Chief, Systems Section, i[Yf3
' Ijate .
Engineering Branch, DRS Inspection Summary: See the Executive Summary 9301190033 930111 PDR ADOCK 05000213 O PDR
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TABLE OF CONTENTS EXECUTIVE SUhtMARY ...................................... 2 I NT R O D U CTI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3~ THE LICENSEE'S GENERIC LE' ITER 89-10 PROGRAM . . . . . . . . . . . . . . 3 Scope and Administration of the Program .................... 4 Design-Basis Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Diagnostics Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 MOV Switch Settings and Setpoint Control . . . . . . . . . . . . . . . . . . . . 7 Motor-Operated Valve Testing ,.......................... 8 MOV Maintenance, Modincations, and Post Maintenance Testing . . . . . 10 Periodic Verification of MOV Capability . . . . . . . . . . . . . . . . . . . . 12 MOV Failures, Corrective Actions and Trending . . . . , . . . . . . , , . 12
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' Motor-Operated Valve Training . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.10 Industry Experience and Vendor Information ................. 15 2.11 S c h ed ul e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 WALKDOWN ........................................ 16 C O N C LU S I O N . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 UNRESOLVED ITEMS .................................. 17 EX IT M E ETI N G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 TABLE 1 - Licensee Plans and Commitments for Further Program Improvements t APPENDIX A - Persons Contacted t
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t EXECUTIVE SUMMARY The Nuclear Regulatory Commission (NRC) conducted a team inspection at the Haddam Neck Plant on October 5-9,1992, to assess the programs developed by the licensee in response to NRC Generic Letter 8910, " Safety-Related Motor-Operated Valve Testing and Surveillance " This team inspection was accomplished in accordance with NRC Temporary Instruction (TI) 2515/109, " Inspection Requirements for Generic Letter 89-10, Safety Related Motor-Operated Valve Testing and Surveillance " The generic letter and its Supplements (1, 2,3 and 4) provided recommendations to the licensees for the development of adequate programs to ensure operability of safety-related motor-operated valves (MOVs) during design basis condition The licensee has developed an MOV Engineering Program Plan to address the recommended actions of Generic Letter 89-10; however, many details of the licensee's MOV program were still in preliminary form. The project instructions (Pis), which will implement the MOV program, were incomplete and in various stages of review. No design-basis reviews, thrust .
calculations or in-situ, differential pressure (D/P) testing per Generic Letter 89-10 had been completed. An internal licensee audit conducted in early 1992 informed the licensee's management that the MOV program was behind schedule and the program details were not developed by April 1991. Based on this audit, the licensee informed the NRC on May 4,1992, that the MOV program details had not been submitted as previously committed and the PIs would only be completed by December 31,1992. - The licensee provided additional engineering resources, established an MOV program team to coordinate, control and monitor the MOV program development and met this revised commitment by issuing the MOV program manual on December 18, 199 The team identified a violation of NRC requirements where the licensee had used inadequate criteria for dispositioning a nonconformance report which was issued to resolve overthrusting conditions for an MOV. The team also observed that the data for prior D/P tests were not always adequately reviewed for operabilit Go(xl MOV maintenance procedures with detailed inspection sheets were noted. Post maintenance test requirements were generally well specified and controlled, However, requirements for periodic actuator refurbishments and measures for preventing hydraulic lock and spring pack relaxation problems were not adequately addresse The licensee has good facilities for training its personnel for both operator overhauls and MOV diagnostic testing with VOTES equipment. The licensee had a good training program in place to meet the needs of the MOV program. Also, the team concluded that the licensee had established adequate measures to review and incorporate vendor information and industry -
experience into their MOV progra In summary, although the licensee had developed an Engineering Program Plan to address the recommended actions of Generic Letter 89-10, the detailed MOV program PIs were-incomplete at the time of the onsite inspection. Continued management attention is needed to ensure timely development and implementation of the MOV program. The licensee agreed to enhance the MOV program, as summarized in Table _ _ _ . _ _ _ _ _ _ _ _ _ _
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3 INTRODUCTION On June 28,1989, the NRC staff issued Generic Letter (GL) 89-10, " Safety-Related Motor-l Operated Valve Testing and Surveillance," which provided recommendations to the licensees I for the development of adequate programs to ensure operability of safety-related motor-
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operated valves (MOVs) during design basis conditions. The generic letter recommended that each licensee with an operating license complete all design-basis reviews, analyses, verifications, tests and inspections that have been instituted within 5 years or three refueling _
outages, whichever is later, of the date of the generic letter (June 28,1989). The staff held i
public workshops to discuss the generic letter and to answer questions regarding its implementation. On June 13, 1990, the staff issued Supplement I to Generic Letter 89-10 to provide the results of the public workshops. In Supplement 2 (issued on August 3,1990) to Generic Letter 89-10, the staff stated that inspections of programs developed in response to the generic letter would not begin until January 1,1991. In response to concerns raised by the results of NRC-sponsored motor-operated valve tests, the staff issued Supplement 3 to Generic Letter 89-10 on October 25,1990, which requested that boiling water reactor licensees evaluate the capability of motor-operated valves used for containment isolation in the steam lines to the high pressure coolant injection system and reactor core isolation
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cooling system, in the supply line to the reactor water cleanup system, and in the lines to the isolation condenser as applicable. On February 12,1992 the staff issued Supplement 4 to l
l Generic Letter 89-10 excluding considerations be made for inadvertent operation of MOVs from the scope of Generic Letter 89-10 for Boiling Water Reactor The NRC inspection team used Temporary Instruction (TI) 2515/109 (dated January 14,1991), " Inspection Requirements for Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance," to perform this inspection. The inspection focused on TI 2515/109, Part 1, which involves a review of the program being established by the licensee in response to Generic Letter 89-10, TIIE LICENSEE'S GENERIC LETTER 89-10 PROGRAM On December 15, 1989, the licensee responded to GL 8910 with a commitment to develop an MOV program description by April 1991. However, on May 4,1992, the licensee informed the NRC that they had not completed the Haddam Neck MOV program description as previously committed and would not be able to complete it until the end of 1992. As stated in letters dated July 11,1990, and September 30,1992,' the NRC accepted this delay with the expectation that the initial MOV testing program be completed by the third refueling outage. If the program could not be completed within this schedule, the licensee was requested to provide justification to the NRC for such delay The team reviewed the licensee's response to GL 89-10 and the program details with licensee personnel. The inspection results related to each aspect of GL 89-10 are described below.
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4 Scope and Administration of the Program The program scope and administration were reviewed to assure that the licensee has an adequate program plan and scope and has delineated responsibilities to complete the Generic Letter 89-10 program commitment NU has developed an MOV Engineering Program Plan, Revision 1, dated July 16,1992, to address the recommended actions of GL 89-10. The documents that implement this plan are the MOV Program Manual and the Project Instructions (PIs), These documents were not available in final form for the team's review as they were in various stages of preparatio >
Based on the results of an internal audit, the licensee recognized that they were behind schedule in meeting their prior commitment to develop an MOV Program description per GL ,
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89-10 for Hadaam Neck by April,1991. Management took action to correct this problem by assigning lead responsibility for MOV program development to the systems engineering group. To complete this effort the licensee is using contractor assistance to prepare the MOV Pls, differential pressure (D/P) test procedures and other related documents. The licensee committed to have the MOV Program Manual and PIs in place by December 31,1992, and they completed this effort on December 18, 199 The team reviewed the piping and instrumentation diagrams, emergency operating procedures "
(EOPs), technical specifications and the Updated Final Safety Analysis Report to verify that MOVs in safety-related systems were included in the Haddam Neck GL 89-10 progra There are 93 MOVs within the scope of the GL 89-10 program. However, the licents considered that only 59 of these MOVs were required to be fully evaluated and tested in accordance with the recommended actions of GL 89-10. At the time of this inspection, the licensee planned to D/P test 40 of the 59 MOVs within the schedule recommended in the generic lette The team reviewed the licensee's basis for excluding the 34 MOVs frem the full evaluation and testing and observed that the justifications for exclusion were not always adequately established. Specifically,
- The low temperature overpressure protection (LTOP) isolation MOVs (PR-MOV-596, 597,598,599) were excluded because the licensee considered that satisfactory MOV operation had been demonstrated since 1978 when subjecting these MOVs to design -
basis conditions of temperature and D/P during plant heatups and cooldowns, without demonstrating the ability of these MOVs to function under flow condition The reactor coolant pump (RCP) seal water return MOVs (CH-MOV-311, 312, 313, 314) were excluded because the licensee considered that these MOVs have no safety-related design basis accident mitigation function. However, the team noted that these MOVs are called upon to function in numerous EOPs. For example, they_ are required to close as a backup to seal water return air-operated valves in the event of a loss of control air, loss of semi-vital power or partial loss of DC ~ powe : -g . .
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- Additionally, eighteen other MOVs included in the licensee's inservice testing program were excluded from the GL 89-10 program without adequate justificatio This item is unresolved pending the licensee's evaluation and documentation of the justifications for exclusion of the above 34 MOVs (50-213/92-81-01). Design Basis Reviews P Item "a" of the Generic Letter 89-10 and Generic Letter 8940, Supplement 1, recommended that the licensees review and document the design-basis for the operation of each motor-operated valve in the program for such parameters as:
1. Differential Pressure 5 Ambient Temperature 2. Flow 6. Fluid Temperature 3. Valve Orientmion 7. Minimum Voltage -
4. External Factors The methodology to be used for conducting design basis reviews was documented in Northeast Utilities Service Company's (NUSCO) PI-S3, "MOV System Functional Design -
Basis Review," Rev. O. Ilowever, this program instruction did not include the licensee's final review and approval With the exception of efforu to obtain seismic / weak lin information from valve vendors, the design-basis review effort for GL 89-10 had not been initiated. In a telephone discussion on November 12,1992, the licensee agreed to complete all design-basis reviews by December 31,199 >
Drall PI-S3 specified a review of the Final Safety Analy. sis Report (FSAR), technical specifications, normal operating procedures, emergency operating procedures, plant elevation drawings, component specifications, and design basis documentation packages to determine worst case design basis differential pressure conditions for the valves. Guidance for use of assumptions regarding pump curves, piping elevations, and pipinglosses were provided.
l Relief valve setpoints, including allowance for setpoint band, were considered, Draft PI-S3 also directed the determination of the highest temperature and . flow that corresponded with '
the line pressure / differential pressure scenario listed. The differential pressure resulting from'
l' inadvertent valve mispositioning will also be determine The licensee has requested valve vendors to provide seismic / weak-link analysis for use in i determining valve thrust limitations. Industry code allowables were being used in the interim to establish valve thrust limits, i
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Several design basis review packages developed for NRC IMletin 85-03 were reviewed by the inspectors, including packages for FR-MOV-567 and 569 (PORV block valves), SI-MOV-854 A, and SI-MOV-871 A and B. The calculations reviewed made reasonable assumptions regarding differential pressure, inchiding the use of PORV iift setpoint pressure plus accumulation for the PORV block valve NUSCO's draft GL 89-10 program instructions had not evaluated the effects of high temperature on the output of the AC motors. Licensee personnel stated that any information provided by Limitorque regarding the effects of high ambient temperature on AC motors would be factored into the MOV program, as appropriat At the time of this inspection the licensee had completed design basis electrical reviews for 15 of the 91 MOVs in their Gnneric Letter 89-10 program. The team reviewed the completed design basis electrical reviews for the 15 valves tested during the 1991 refueling outage. Minimum voltage calculations are documented in licensee calculation no. 89-092-072-EY. This calculation appropriately considered impedances of MOV power cables, accident umperature effects on ine cables, and thermal overk>ad heater resistances for deterraining the voltage drop from the motor control center to the valves. Irlowever, this calculation utilized motor current values at rated torque instead of locked rotor current as recommended in the generic letter. Upon identiGcation of this concem by the team, the licensee ar.;ed to revise electrical calculations for the GL 89-10 MOVs using locked rotor current instead of motor current at rated torqu The inspectors reviewed the licensee's calculations for the sizing of thermal overksad heaters and the procedures for the replacement of thermal overloads and concluded they were adequate. MOV thermal overload devices are not bypassed at Haddam Nec The licensee h6 verified that the properly sized thermal overloads are installed and replaced as necessary. Thermal overloads are replaced in accordance with the !icersee's procedure, ACPL2-4.1," Procurement Document Preparation and Review." The plant tests thermal overloads following n design change but does not test them periodicall The licensee was evaluating periodic testing of toermal overloads for inclusion in the MOV progra .3 Dingnostics Systems The licensee uses the Valve Operation and Test Evaluation System (VOTES) diagnostic equipment to set the torque switches and perform diagnostic evaluations for MOVs in the GL 89-i0 progra Minimum and maximtun thrus'. requirements included 9.2% margin for diagnostic equipment inaccuracy, a iO% margin to account for torque switch repeatability when output is less than 50 ft-lbs and a 5% raargin when output is greater than 50 ft-lb These margins are combined using the square root of the sum of the squares metho i i
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The licensee did not have diagnostic equipment available to measure the output of Auma actuators for the Adams filter bypass valves in the service water system. Further, the licensee did not have the necessary torque measurement transducers to verify stem friction coefficients and to ensure that torque limitations nre not exceeded. The licensee .
stated that diagnostic equipment had been ordered for use with the Auma actuators and 4 that additional transducers will be procured to allow measurement of torque. These MOVs are scheduled for design basis testing with the appropriate diagnostic equipment in the 1995 outag .4 MOV Switch Settings and Setpoint Contml 3-Item "b" of Gerieric Letter 89-10 recommei.ded that licensees review and revise as necessary, the methods used for selecting and setting all motor operated valve switch
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setting The methodology to be used for determining thrust requirements a6J selecting switch -
settings was documented in the licemee's PI D2, " Program Instruction for Target Torque S
& Thrust Analysis Methods," Rev. O. However, this program instruction was in draft and the licensee had not completed the final review and approval at the time of this inspection. Thrust calculations for GL 89-10 had not been initiated. In a telephone discussion on November 12,1992, the licensee stated that thrust calculations for 44 MOVs would be completed by the end of the 1995 outage. The calculations for the L remaining MOVs would be completed by the 1996 outag .
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Draft PI-D4, " Program Instruction for Valve an(! Stem Factor Selection," Rev. O, outlines a three stage process where stage 1 would use valve factors of 0.30 for flex-wedge gate -
valves,0.20 for parallel di_sk gate valces, and 1.10 for globe valves to establish operabilit Stage 2 would use valve factors of 0.50,0.40, andl.10 for flex wedge, paraP.el dit.k, and globe valves for the purpose of providing target thrast values for diagnostic testing and for prioritizing MOVs for testing and margin improvement. Stage 3 will use dynamic test
< results to establish actual valve factors.- For valves that the licensee cannot test, results from EPRI's Performance Prediction Program will be used. The licenme intends to use
- an assumed value of 0.20 for stem frictiou coefficient in all cases. He inspector -
observed that the draft program did not identify the equations to be used to determine actuator output capability for Crane Teledyne or Auma actuators. The licensee has inittated efforts to obtain the necessary equations and incorporate them intci the GL 89-10 progra :
Details hwe not been developed in several areas of the nensee's GL 89-10 program.- ;
These include methods for evaluation of the results of dynamic testing, methods for y assessing load sensitive behavior of MOYs during D/P testing, methods for extrapolation ;
A of test results, and methods for feedback 6f dynamic test results into the original thrust calculations.
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8 i Torque switchet are generally bypassed in the opening direction for approximatsy the first 45 - 65% of the stroke. The open limit switch is used to control termination of the open stroki. for rising stem valves to prevent inadvertent bactseating of the valve. Tne I'
torque switch is bypasseJ m the closing direction except for the :ast 5 - 20% of the stroke. Butter 0y valves used limit switches to control operation in both direction The licensee's method to control torque switch setti ngs was reviewed The licensee's MOV Setpoint Database is used to document and control the minimum and maximum allowed 11cust at torque switch trip. The maxianun allowed peak thrust due to inertia and the limit switch settings for bypassing the totque switch are also identified. The vendor-supplied maximum allowed torque switch dial setting is also documented, when 7 available. The licensee procedure ACP 1.2-3.3, "Setpoint Change Request (SCR)," Re , dated March 26,1992 is used to control all changes, additions, or deletions to the setpoint database to ensure that appropriate reviews occur prior to implementation in the plant. The inspector concluded that the licensee's MOV setpoint control method was consistent with the generic letter recommendation .5 Motor Operated Valve Testing Action "c" of the puerie letter recommended that licensees test motor-operated valves in situ under their design-basis differential pressure and flow conditions. If in situ testing ,
under those conditions is not pracdcable, the NRC recommends a two-stege approach for demonstrating motor-operated vntre capability. With the two-stage approach, a licensee wouid evaluate tw. capability for the motor-operated valve using the beu data available and develop applicable test data within the schedule of the generic lette The liceasce stated that it was their intent, where practicable, to perform in situ design-basis D/P and flow testing for GL 89-10 MOVs. For the 59 MOVs to be tested in _
accordance with GL 8940, static baseline testing has been completed for 24 MOVs daring the refueliag outage completed in March,1992. No D/P testing per GL 8910
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had been performed at the time oi this inspection. Ilov/ever, the team noted that the licensee had perfonned MOV D/P testiag per NRC Bulletin 85-03 during previous refueling outages. During the next two refueling outages the licensee o~lans to perform D/P testing of 40 MOV The team reviewed the results of the MOV diagnostic tests as detailed below:
- Renew of the CH-MOV-292A and B data indicated the prese,ce of load sensitive behavior. The torque switch settings established during static testing deUvered approximately 800 -2400 pounds less thrust during dynamic tening. The MOVs operated satisfactorily during both tests with the D/P equal to 2600 2700 psi Similar static und dyimmic test data were available for RH-MOV-33A and The licensee acknowledged the team's concern that a comprehensive evaluation of this data was not performed and agreed to perform this evaluation upon issuance of Ptogram Instruction Pl-MTIO, Evaluation of Test Results, but not later than March 1,1993. This item is unresolved pending completion of the evaluatbn of these test results by thc licensee (50-213/92-81-02).
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- lleview of several maintenance work orders from the last two outages for hiOV diagnostic tests indicated that overthrusting of Cil h10V-29211 and C beyond the actuator housing rating had occurred. These hiOVs are 3 inch rplit wedge gate valves with Limitorque SIMO actuators which have an actuator rating of 14,000 pounds. Diagnostic testing had been performed for Cll hiOV 292B on February 15,1992 in accordance with Procedure PhiP 9.3105," Testing hiOVs Using VOTliS" The maximum allowable thrust per this procedure was 17,199 pounds. The team noted that Nonconformance lleports (NCits) were issued for those instances where the maximum thrust measured during the test exceeded the procedural maximum thrust limit. For example, NCil 92100 was issued to evaluate an overthrust condition on Cil MOV 29211 of 17,867 pounds measured versus 17,199 allowable experienced during the test on February 15,1992. The licensce's technical resolution for accepting this test information "as is" was based on NUSCO Calculation No. 89 092 060 Ehi, llev.1, dated January 10,1992, which concluded the maximum allowable thrust to be 19,000 pounds based on the limit for the valve body. Ilowever, the team noted that the actuator had a limit of 14,000 pounds which was more limiting than the valve body limit of 19,000 pounds. The licensee acknowledged the team's concer The licensee's preliminary assessment indicated that overthrust conditions for Cll-292C; FW-11 through 14; and 1111780,781,803 and 804 l'ad been similarly evaluated. Based on vendor information, industry experience :nd test reports as documented in a licensee memorandum of October 6,1992, the licensee considered these hiOVs operable. The licensee indicated hat NUSCO Calculation No.86-003 8980P, llev. O, dated September b,1989, which was indirectly referenced in the resolution of NCll 92-100, provided the basis for increasing thrust and torque allownbles by 75% above the Limhorque rating This conclusion was based on a fatigue analysis performed by a licensee contractor in February 1988. This analysis used the endurance limit for cast iron in conjunction with the thrust determined at actuator failure. The analysis concluded that a value of 84% above the ShiB 00 actuator rating was plabl The lleensee's current review of this analysis concluded that calculatic 003-898GP was not suitable for use in dispositioning NCil 92100, Consequently, this ,
concern was identified for resolution in a plant information report on October 8, 1992, which resulted in the initiation of a lleportability Evaluation Form / Operability Determination (ItEF/OD 92-81). This is a violation of 10 CFit 50, Appendix ll, Criterion XVI, Corrective Action in that the licensee
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had been using inadequate criteria for dispositioning nonconformance reports (50-213/92 81 03).
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In a telephone discussion on October 29,1992, the licensee provided the status of their actions in response to REF/OD 92-81. A preliminary evaluation had been completed in accordance with the licensee's procedures. Only Cil MOV 292H had been evaluated. The evaluation revealed another overthrust condition of 29,000 pounds for this MOV during diagnostic testing in November,199 Ilowever, the preliminary evaluation had determined that the MOVs referenced in REF/OD 92-M were operable. A final evaluation was completed on December 17,199 The team also noted that the test procedures did not have measures to preclude overthrusting of MOVs in the future. The licensee acknowledged this team obseivation and agreed to caution its test personnel concerning future MOV testin The team reviewed the licensee's schedule for future D/P testing of MOVs and noted that HA-MOV 366 was not scheduled for diagnostic testing until the 1995 outage. This schedule appeared to be inconsistent with this valve's safety significance for boration service. The licensee agreed to consider testing this MOV during the 1993 outag .6 MOV Maintenance, Modifications, and Post Maintenance Testing The licensee's MOV Program Plan describes four general maintenance topics including guidelines for monitoring MOV maintenance, developing a control switch setpoint master list, developing guidelines for periodic as-found testing, and updating maintenance procedures, llowever, none of these maintenance topics had been developed at the time of this inspection and the maintenance on safety related MOVs was performed using existing maintenance department requirements for safety related equipmen The licensee has developed maintenance procedures to perform preventive maintenance (PM) and refurbishments on actuators. Approximately fourteen formalized maintenance procedures specify PM and icfurbishment activities for the MOV maintenance progra These procedures provide standard instructions for motor replacement, operator inspection and overhaul, lubrication, switch setting, and diagnostic testing, among other maintenance activities for all Limitorque SMB-000 through SMB 4 and T-40 Crane Teledyne actuators. The inspectors reviewed the following procedures in detail:
PMP 9.5 0, " Maintenance Department Preventive Maintenance Program" PMP 9.5 3, " Crane-Teledyne Valve Motor Operator Preventive Maintencace" PMP 9.5-4, "Limitorque Valve Motor Operator Preventive Maintenance" PMP 9.5-215.1, "Limitorque Operator Removal, Installation and Adjustment" PMP 9.5-21 "Limitorque SMB/SH 000 and 00 Operator Disassembly and Assembly" PMP 9.5-21 "Limitorque SMB 0 Thru 4 Operator Disassembly and Assembly" PMP 9.5-22 " Crane-Teledyne Model T-4 Operator Maintenance" PMP 9.5-22 " Crane-Teledyne Model T-1 Operator Maintenance"
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Overall, maintenance procedures were well detailed with exploded-view equipment subassembly illustrations. MOV maintenance procedures included detailed inspection sheets, appropriate notes and cautions, and adequate acceptance criteri The oreventive nwintenance (FM) program document is PMP 9.5 0," Maintenance Department Preventive Maintenance Program" which requires an MOV PM task trequency to be based upon vendor recommendations, industry and station experience, regulatory and code requirements and other factors. Actuator refurbishments were not scheduled on a periodic basis. The maintenance program required refurbishment of actuators only on an as-necessary basis and a PM every outage. This PM included a stem inspection and lubrication. The licensee had not planned to perform actuator refmbishments prior to conducting baseline diagnostic testing on GL 89-10 MOV Vendor recommendations have been addressed for routine maintenance of 1.imitorque operators regarding visual inspections, grease sampling, stem lubrication, and motor winding resistance checks. The following observations suggested that MOV maintenance practices needed further improvement PM activities for Gl. 89-10 MOVs at lladdam Neck were varied in scope for the various types of actuators in the plant. For example, Limitorque actuators are afforded a gearbox grease level check and a limit switch and torque switch position check, llowever, Crane Teledyne actuators were only afforded a gearbox grease level check. No limit switch or toteue switch check was require Additionally, for Auma actuators, no 1 M procedure existed or was planned and for llllC" gearboxes, no PMs had been conducte The licensee had no method to verify the torque switch settings on Crane Teledyne actuators at the time of this inspection. Ilowever, the licensee agreed to investigate possible ways to accomplish this for supporting applicable MOV testing during the 1993 outag No regular inspection of the spring pack or spring pack cavity for grease conditions has been provided. The maintenance department considered that the probability of hydranlic lock was minimal as it never occurred in MOVs at the plant. Also, maintenance procedures did not have a specific check for evidence of spring pack relaxation. Also, no spring pack test equipment has been used. The licensee agreed to review this matter for resolutio During the 1989-90 refueling outage, the licensee installed two Auma valve actuators as part of a modification to provide a Dow bypass around the service water " Adams Filters." Although these actuators were suitable for the application, the licensee has not developed corrective maintenance procedures for these actuator I
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Post maintenance test (PMT) requirements were generally well specified and controlled within the work order system. The guidelines for proper PMT specifications were provided by procedure ACP 1.211.3,"Itetest/ Functional Verification." A PMT requirements matrix was included in this procedure. The matrix provided good detail for the types of post maintenance tests of MOVs. It indicated that MOV maintenance activities which could affect the baseline test by changing or potentially affecting valve thrust (e.g., torque switch adjustment or replacement) would require a new diagnostic test. The current PMT requirements specify statie diagnostic testing only and do not identify any type of maintenance for which a dynamic diagnostic test would be an appropriate PM The inspector concluded that the MOV PM program was consistent with the GL 89-10 recommendations with the exceptions discussed abov .7 Periodic Verification of MOV Capability Paragraph "j" of the generic letter recommended that surveillance intervals should be commensurate with the safety function of the MOV and with its maintenance and performance history. The surveillance interval in no case should exceed five years or three refueling outages. Further, the capability of the motor-operated valve has to be verified if the motor operated valve is replaced, modified, or overhauled to an extent that the test results are not representative of the motor operated valve performanc The team reviewed the licensee's preliminary program for periodic verification of MOV capability. Maintenance procedures are in place to verify, adjust, and replace limit and torque switches. Periodic verifications are identified in the MOV Program Plan as items that were to be developed; however, no specific plans had been implemented at the time of this inspection. The licensee recognizes that adjustments to this initial approach may be necessary upon reviewing all MOV data after full implementation of the GL 8910 program. The licensee intends to review all MOV data from maintenance history, preventive maintenance, static test results, dynamic test results and industry testing for defining the appropriate periodic tests for the verification of MOV switch settings at lladdam Neck. The licensee recognized that this review could conclude that certain MOVs might require D/P testing, dependent primarily on the testing of MOVs at the sit .8 MOV Failures, Corrective Actions and Trending Item 'h' of the generic letter recommended that licensees analyze each MOV failure and justify corrective action. The letter recommended that the results and history of each as- ,
found deteriorated condition, malfunction, test, inspection, analysis, repair, or alteration -
be documented and maintained. It further recommended that this information be per.odically i examined (every two years or after each refueling outt.ge 'after program-implementation) as part of the monitoring and feedback effort to establish trends of -
MOV operabilit .
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According to the licensee's MOV program document, all corrective work on MOVs is performed through the work request process. Procedure ACP 1.2 5.1 describes the method for documenting failures or nonconforming conditions that occur during operation, testing, or maintenance. Depending on the particular failure or deteriorated condition, followup action may include:
e Generation of a Plant incident Report (PIR)
e Performance of a Root Cause Deterrnination (RCD)
e Notification under the Nuclear Plant Reliability Data System (NPRDS).
- Generation of an additional work package (s) for follow up or corrective maintenanc In general, the inspectors considered that these corrective action systems provided good processes for resolving discrepant condition Guidance for the review of maintenance work requests is given in procedure MDI 76
" Predictive Maintenance Program." The procedure provides direction for pedictive failure analysis and trending through vibration monitoring, thermography, and oil analysis as part of reliability centered maintenance activities. Ilowever, this program specifically excludes MOV diagnostic testing and corrective maintenance. Procedure MDI-77,
" Guidance for Evaluation of PMs Performed on Equipment" provided some guidance for evaluating the effectiveness of MOV PMs, but was limited in scope and did not prescribe techniques for trending indicators on specific MOV The licensee recognized the need for more specific information to trend MOV performance effectively in accordance with GL 8910 recommendations. The MOV program document outlines a specific topic (PI MT3) to develop an MOV tracking and trending program by December 31,199 The team reviewed several maintenance work packages to determine the effectiveness of the licensee's corrective actions for prior MOV problems. During 1991, several torque switch problems contributed to MOV failures. Improper torque switch setting prevented two MOVs from completing their full stroke. These incidents were attributed to inadequate torque switch lubrication or maintenance. An improperly set torque switch allowed internal damage to occur on one MOV from an overthrust condition.-
One steam dump isolation MOV drive bushing failed and it prevented the valve from opening and a wc n stem nut prevented a containment sump isolation valve from achieving full thrust. These failures occurred during periodic testing and maintenance of the valves while shutdown. The specific failures were different in each case reviewe The inspectors did not identify a pattern of repetitive failures. The corrective action
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process for these failures were effective to preclude recurrence.
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14 The team concluded that the licensee was taking adequate corrective actions to known hiOV problems. The licensee was collecting more specific hiOV data at the time of this ,
inspection to develop an hiOV failure trending progra . Motor Operated Valve Training The team reviewed the lleensee's hiOV training courses, training facilities, and training i f
staff qualifications relating to the implementation of the GL 89-10 program. The licensee's hiOV training program has been accredited by the Institute of Nuclear Power Operations (INPO). It outlines the specific requirements as well as continuing and refresher training for various technicians and engineers. Tids program includes both classroom knowledge and hands-on laboratory skill developmen The inspectms observed many types of hiOV hardware that were used as training aids at the licensee's training facility. Valve Operation Test and Evaluation System (VOTES).
equipment is borrowed from Generation Test Support (GTS) for training and returned for actual work during overhaul. Dedicated VOTES equipment for training is planned for 199 Each of the instructors has a individual training folder which contained qualifying documentation and demonstrated the background and qualifications of the instructo Discussions with the training staff regarding h10V issues verified that they were knowledgeable and experience The Nuclear Training Departrnent (NTD) staff stated that contractor training is checked o and validated by examination requiring an 80% on a written test and a display of '
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proficiency in the laboratory before being allowed to assist qualified personnel from Connecticut Yankee (CY) or Generation Test Support (GTS).
The plant engineering staff is not VOTES qualified. The ISI Engineering Supervisor stated that he would have two trained engineers VOTES qualified before the -
commencement of the next outag Training maintains a matrix of all qualified personnel in each department and distributes *
this information to department heads periodically. After completion of the required hiOV training, the depanment head qualifies the trainee with applicable job related training. The completed training information is sent to NTD to update the matrix with a ;
qualification status and a date for requalification. Required training updates are -
' designated on the matrix to signify when new elements of tralaing are require The NTD and Training Program Control Committee review regulatory and industry documents to determine their applicability to the licensee's MOV progra Representatives from training and maintenance meet periodically to discuss the need to modify training as a result of any new industry or vendor information.
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A review of selected Limitorque maintenance updates and 10 CFR Part 21 notifkations indicated that they had been incorporated into students handouts, instructor lesson plans, and test questions. The NTD has incorporated an intun91 system of tracking industry information and experience so that incorporation of incoming update type information is completed in a timely manne The team concluded that the licensee had a good training program in place to address and support the various aspects of the GL 8910 progra .
2.10 Industry thperience and Vendor Information The team reviewed the licensee's vendor information program to assess its effectiveness in disseminating industry data into the various areas of the MOV progra Plant procedure ACPl.2 6.14 " Vendor Information Routing" provides guidance for review, evnluation, and recommended disposition of vendor generated technical information including 10 CFil Part 21 notifications. A vendor information routing is tracked by a controlled routing (CR) process per procedure ADM 1.145, Rev.10,
" Relational Database Processor Commitment Tracking and Controlled Routing". The CR process is a licensee management control for providing a documented assignment, follow up and closcout of open items. Ilowever, the inspector noted that this process did not always include action to verify that an open item had been complete The inspector reviewed several CRs that dispositioned vendor information concerning ,
MOVs with the following observations:
- Motor-Operated Valve Actuator Testing System (MOVATS) Engineering Report (ER) 5.2, regarding the analysis needed to resolve the MOV open versus closed inaccuracy issue, was evaluated as "N/A to CYAPCO" and closed prematmely on CR 92 0721 in May 1992. This same issue was reopened and tracked by CR 92-0881 which recommended that it be closed in August,1992. A more substantive review occurred at this time. The inspector discussed the results of this review with the licensee.
l NRC Information Notice 92 23 alerted licensees to potential inaccuracles with the MOVNI'S Thrust Measuring Device (TMD) and its use for establishing MOV switch settings. The Nuclear Utilities Management and Resources Council (NUMARC) provided guidance to utilities to resolve this problem. The licensee had used the MOVATS TMD to set MOV torque switches in the past. After reviewing MOVATS ER 5.2, the licensee determined that this report applied to FW MOV- 35 and 160 since they had not been tested with VOTES diagnostic equipment subsequently. To resolve the issue, the licensee performed successful surveillance tests and concluded that these MOVs were operable.
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The inspector had two observations concerning the licensee's review of this issu l The licensee's review had not considered the impact of the increased uncertainties on the maximum allowable thrust limits. The inspector also noted that SI hiOV-861C was not tested using VOTES equipment subsequent to the initial test using MOVATS equipment. Ilowever, this MOV was not afforded a similar revie !
These comments were discussed with the licensee's systems engineering supervisor on November 12,1992, and the lleensee agreed to resolve these ,
comments in a review of these MOVs for consistency with established NUhMRC guidance. The review of each MOV would be completed in conjunction with the work being performed for that MOV for GL 891 lleplacement of Melamine torque switches to resolve problems identified in a 10 :
CFil Part 21 notification was accomplished by a change in maintenance procedure PMP 9.5-4. The Melamine torque switches were replaced with Fiberite torque .
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switches. The inspector verified that the licensee took corrective action to this Part 21 notification by tracking the changes via the CR process. The licensee acknowledged this comment and agreed to use the NCR process for the disposition of Part 21 concern ;
- Vendor information updates and 10 CFR Part 21 notifications were consistently ,
assigned solely to the maintemmce department when evaluation by engineering would also have been appropriate. This joint assignment was especially missing for the evaluation of the MOV issues concerning spring pack relaxation and hydraulle lock as provided in Limitorque maintenance updates 90-1 and 89 Overall, the team concluded that the licensee had established adequate measures to review and incorporate vendor information and industry experience into their GL 89-10 MOV progra .11 Schedule
- In GL 89-10, the staff requested that licensee's complete all actions initiated to satisfy the generic letter recommendations by June 28,1994, or 3 refueling outages after December 28,1989, whichever is later. The licensee has committed to complete their GL 8910 actions by the end of the 1995 refueling outag .0 WALKDOWN During a plant walkdown, the team observed a wide range of valve operators from original plant Limitorque operators to new Auma operators installed on butterfly valves in the service water system and new limitorque operators installed on the feedwater isolation valves per recent plant modifications. : No internal inspections of MOVs were
- made as the plant was operating. No concerns were identifie ,
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17 CONCLUSION Although the licensee had developed an Engineering Program Plan to address the recommended actions of Generic Letter 8910, the detailed MOV program Pts were incomplete at the time of the onsite inspection. These Pls were completed with the issuing of the MOV program manual on December 18,1992. The team identified a violation of NilC requirements concerning inadequate criteria for dispositioning a nonconformance report which was issued to resolve overthrusting conditions for an MOV. The team also observed that data for prior D/P tests were not always adequately reviewed for operability. Good MOV maintenance procedures and training facilities were noted. The licensee agreed to enhance the MOV program, as summarized in Table .0 UNRESOLVED ITEMS Unresolved items are matters for which more information is required to ascertain whether incy are acceptable items, violations or deviations. Two unresolved items are discussed in sections 2.1 and 2.5 of this repor .0 EXIT MEETING The inspectors met with those denoted in Appendix A on October 9,1992, to discuss the preliminary inspection findingt ::s detailed in this report. The licensee acknowledged the inspection f'mdings and agreed to review the items listed in Table 1 for resolution and further improvement of the MOV progra _
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TAllLE I Licensee Plans and Commitments for Further Program improvements Reference Paragraph Section 2.1 Scope and Administration of the Program
Complete evaluation and documentation of the 5 justifications for excluding 34 MOV Section 2.2 Design 33 sis Reviews
- 2 Complete all design basis reviews by December 31,199 *
Evaluate high mnblent temperatures on motor performance 6 when more information is available from Limitorqu *
Revise electrical calculations using locked rotor 7 current instead of motor current at rated torqu Section 23 Diagnostic Systems
Obtain diagnostic equipment to monitor Auma actuators 3 for Adams filter bypass valves to support testing during the 1995 outag Section 2.4 MOV Switch Settings and Setpoint Control
Complete MOV thrust calculations by the 1095 outag '
Obtain equations to be used for output capability of 3 the Crane Teledyne and Auma actuators. Incorporate this information into MOV progra *
Develop detailed methods for evaluation of the results 4 of dynamic testing, assessing load sensitive behavior, extrapolation of test results and feedback of dynamic test results into original thrust calculation _ _ _ _ _ _ _ _ _
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i Table 1 2 11eference Paragraph Section 2.5 Motor Operated Valve Testing
- Complete static and dynamic testing of MOVs by the 2 1995 outag * Complete evaluation of test data for Ril MOV 33A and 11 3 in accordance with PI MT10 by March 1,199 * Take appropriate corrective actions to resolve 5 problems with inadequate criteria for dispositioning NCRs (50-213/92-8103).
Caution test personnel concerning the potential for 6 overthrusting MOV *
Consider D/P testing IIA MOV 366 during the 1993 outag Serlinit2A MOV Maintenance. Modifications and Post Maintenance Testing
- Investigate ways to verify torque switch settings for 6 Crane Teledyne actuator *
Address maintenance program weaknesses noted concerning 7 MOV hydraulic lock and spring pack relaxation problem Section 2.7 Periodic VerifLqation of MOV Caoability
- Develop a program for periodic verification of MOV 2 switch setting Section 2.8 MOV Failures. Corrective Actions and Trending
- Develop an MOV failure and performance trending 4 progra Section 2.10 Industry Experience and Vendor information
Resolve MOVATS open versus closed issue for FW-MOV-35, 5 FW MOV-160 and SI MOV-861 * Use the NCR process for the correction of problems 6 concerning Part 21 notifications.
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