IR 05000219/1997005
| ML20149K114 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/17/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20149K113 | List: |
| References | |
| 50-219-97-05, 50-219-97-5, NUDOCS 9707290256 | |
| Download: ML20149K114 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.
50-219'
72-1004 Report No.
97-05 License No.
DPR-16 Licensee:
GPU Nuclear incorporated Parsippany, New Jersey 07054 Facility Name:
Oyster Creek Nuclear Generating Station I
Location:
Forked River, New Jersey
- Dates:
April 7-11,1997 e
inspectors:
Thomas J. Kenny, Senior Reactor inspector Richard Cain, INEL Contractor Approved By:
Eugene M. Kelly, Chief Systems Engineering Branch I
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9707290256 970717
- PDR ADOCK 05000219
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EXECUTIVE SUMMARY i
i Oyster Creek inspection Report 50 219/97-05 April 7-11,1997 This inspection evaluated the Generic Letter (GL) 8910 motor operated valve (MOV)
program and various aspects of engineering.
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Enaineerina
Tho GL 89-10 program was stated to be complete by GPUN letter dated February, 1995, but was not able to be closed because:
' Assumptions affecting load sensitive behavior were not well supported and
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not of high statistical confidence due to the limited amount of data.
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A " weight factor" was established to select certain valve factors for
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untested MOVs, but was not adequately justified with reliable test data.
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GPUN's recent self assessment of the GL 89-10 program identified weaknesses similar to the NRC inspection findings, but progress was only just started in addressing those findings.
- The standby liquid control system (SLCS) was well maintained and the as-found i
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condition of the SLCS meets the requirements of the ATWS rule.
OA audits of Oyster Creek engineering findings were acted upon promptly and
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appropriate actions were taken.
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TABLE OF CONTENTS Paae No.
E1 Conduct of Engineering
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E1.1 Generic Letter (GL) 89-10 Motor Operated Valve (MOV) Program ( 2 51 5 /1 0 9 )............................................ 1-E1.2 Summary Status of Generic Letter 8910 Motor. Operated Valves
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E1.3 MOV Sizing and Switch Settings........................ 2 E1.4 Assessment of the Standby Liquid Control System (SLCS)
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E7 Quality Assurance in Engineering Activities.......................... 9 E7.1 Self and Independent Assessments........................... 9 E8 U F S A R R e vie w............................................. 10 E9 E xit M e e t ing............................................... 10 i
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Report Details E1 Conduct of Engineering
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E1.1 Generic Letter (GL) 89-10 Motor Operated Valve (MOV) Proaram (2515/109)
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Backaround
GPUN had informed the NRC that the Oyster Creek GL 89-10 program was complete on February 17,1995. Afterwards, due to 89-10 MOV program problems
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discovered at Three Mile Island (TMI) GPUN assembled a diverse team of MOV experts, including contractors to assess the TMl MOV program. The team made recommendations that eventually led to the resolution of the problems at TMI.
GPUN then used the~same team to assess the Oyster Creek 89-10 MOV program.
The team identified areas of concern at the Oyster Creek facility and issued recommendations to correct these areas. The inspectors reviewed the team's
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assessment after they had assessed the Oyster Creek 89-10 MOV program.
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The NRC findings delineated in the following paragraphs identified many of the same findings as the GPUN team. Discussions at the time of this inspection indicated that Oyster Creek engineers were going to make the necessary changes to
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the 8910 program by using their self-assessment and the application of the Electric Power Research Institute (EPRI) Performance Prediction Model (PPM). As of the
completion of this inspection, the implementation of these actions had not yet begun.
E1.2 Summary Status of Generic Letter 89-10 Motor-Ocerated Valves a.
Incoection Scooe The inspectors reviewed GPUN's " Program Description For NRC Generic Letter 8910 Motor Operated Valve Program," Rev. 2, dated January 30 1996, Engineering Position Papers on " Rate Of Loading," " Stem Lubricant Degradation,"
" Valve Factor Justification," and a self-assessment performed by an independent
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review team. Also, the inspectors reviewed thrust calculations, as well as the available valve factor (or thrust margin). Using these documents, a valve sample was selected that included valves with small differences between required and
- available thrust or " low margin."
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The program scope consisted of 31 MOVs (29 gate and 2 globe valves), and seven t
dynamic tests of gate and globe valves were performed. GPUN's methods for demonstrating MOV design-basis capability included verification by: 1) valve-specific dynamic test at design-basis conditions, 2) valve-specific test, linearly'
j extrapolated to design-basis conditions, and 3) industry information obtained from n
testing of similar MOVs. The inspectors reviewed test packages, calculations, and engineering evaluations for the following MOVs:
V 5147
~ Reactor Bldg. CCW DW Inlet isolation Valve -
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.V-14-33 l lsolation Condenser B inboard Steam isolation Valve
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V-14-34 Isolation Condenser A Condensate Return Valve V 14-36 isolation Condenser A Return Isolation Valve V-16-2 Auxiliary RWCU Pump Inlet isolation Valve V-16-14 RWCU Inboard Isolation Valve
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'E1.3 MOV Sizina and Switch Settinas
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Insoection Scoos.
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l The inspectors reviewed thrust calculations and test evaluation summaries for the i
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selected MOVs, including assessments of load sensitive behavior and stem friction j
coefficient.
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- Observation and Findioaf
With one exception, GPUN used the B&W Nuclear Service Company Motor Operated Valve Evaluation (MOVE) computer program to calculate thrust / torque
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requirements for gate and globe valves in their program. The MOVE program used standard industry equations to determine thrust and torque requirements for gate
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valves and non-rotating stem globe valves. The exception involved Anchor / Darling
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Double Disc Gate valves for which GPUN used spread sheet files with the NMAC equation or the Electrical Power Research Institute's (EPRI's) Performance Prediction Model (PPM).
The two globe valves at Oyster Creek are rising / rotating stem MOVs, and were set-up based on torque requirements. A packing torque was determined using the valve
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manufacture /s method that was then converted to a packing thrust that was
included in the standard industry equation. The two globe valves had their minimum required thrust adjusted to account for load sensitive behavior. Similar to
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the gate valves, the globe valves' minimum and maximum calculated thrust requirements were adjusted to account for diagnostic equipment uncertainties and torque switch repeatability, n
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- Valve Factor and Grouoina Because of the limited amount of in-situ dynamic testing, GPUN gathered a large amount of, industry data. Valve disc friction factors were appropriately adjusted to obtain valve factor, as well as for instrument accuracy. GPUN utilized eight valve groups. 'Some groups contained valves.with small variations in design-basis
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differential pressure (d/p), pressure class, and valve size. Therefore, these groups
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were divided into subgroups. The resulting 12 groups / subgroups contained MOVs that were similar with respect to manufacturer, size, pressure class, disc / wedge type, and design basis differential pressure.
Valve factors were adjusted by a " weight factor" that was determined by how closely the industry valve types matched GPUN's MOVs. A higher weight factor was applied to data that were obtained from valves that matched an Oyster Creek MOV. A lower weight factor was applied to valve data similar to a GPUN MOV (e.g.,6-inch valve data applied to an 8-inch valve). Finally, the data were compiled statistically, and the valve factor applied to a group was computed as the mean of the weighted valve factor plus one standard deviation. However, since GPUN had not justified or provided a more sound, technical basis for their methodology for
" weight factor," the inspectors independently evaluated the valve factors for each group without relying on the " weight factor," and had the following observations:
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GPUN's analysis of industry data indicated a value of 0.59 was most
appropriate for Groups 1 A and 1C valves. Group 1 A (three MOVs) contained 6-inch Anchor / Darling 600 pound flexible (flex) wedge gate valves that may be required to operate under blowdown conditions; Group 1C (two MOVs)
contained 10-inch Anchor Darling 600 pound flex wedge gate valves that
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may be required to operate under blowdown conditions.
f GPUN recalculated the available valve factor for valve V-14-37 (the only MOV with an available valve factor less than O.60) using a value for stem friction coefficient that was based on analysis of in-plant data. This resulted in a revised available valve factor of 0.664. However, the inspectors reviewed other industry data that indicated that GPUN's actual valve factor value10.59) was low. GPUN intends to run the EPRI PPM program on these MOVs and inspect the valve internals in order to provide a better basis for
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the minimum required thrust. Valve factors were calculated for these MOVs, with the lowest value being 0.533.
Group 1B (six MOVs) contained 8-inch Anchor Darling 600 pound flexible
wedge gate valves that may be required to operate in non-blowdown conditions. These MOVs were set-up based er a valve factor of 1.0, with GPUN " weight factor" methods predicting a value of 0.60 as appropriate.
However, the inspectors independently analyzed industry data and considered the 0.60 valve factor to be questionable. The inspectors noted that GPUN intends to run the EPRI PPM program on these MOVs in order to better substantiate the assumed valve factor.
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Group 3A (two MOVs) contained 14 inch' Ohio injection 150 pound flexible
wedge gate valves. These MOVs could not be dynamically tested and no industry information was found to support the valve factor basis for these MOVs. GPUN compared these MOVs to Walworth valves based on similar construction. These valves were set-up using a valve factor of 0.60.- The inspectors independently performed an analysis of available Walworth industry data which showed the 0.60 valve factor to be questionable.
Because of the low design-basis differential pressures (84 & 70 psid) and the
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piesent thrust margin on these MOVs, the inspectors did not question functionality.
Group 4 (two MOVs) included 14 inch Velan 900 pound flex wedge gate
valves. These valves were set-up using a valve factor of 0.68. Because of i
the low design-basis differential pressures (0.0 psid) and the present thrust margin on these MOVs, the inspectors found the valve factor acceptable.
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Group 6 (two MOVs) included 4 inch Velan 150 pound flex wedge gate
valves. These valves were set-up using a valve factor of 0.60. The inspectors independently performed an analysis of available Velan industry data which showed the 0.60 valve factor to be questionable.
Valve V-16-2 was a 6 inch Hirata 900 pound solid wedge gate valve. This
valve was the only MOV in its group. The MOV was set up using a valve factor of 0.70 and a design basis differential pressure of 0.0 psid. However, a recent self-assessment by GPUN identified that the valve was sometimes operated at design reactor vessel pressure of 1020 psid. GPUN shut and locked the valve on March 12,1997, until new calculations are performed to support the new design basis differential pressure.
The inspectors considered GPUN's valve factor justifications to be questionable in the cases stated above. The inspectors noted that GPUN evaluated industry test data and established a weight factor for applying the industry information to Oyster Creek MOVs, but did not develop a test-based justification for the reliability of this approach. As a result, the NRC inspectors found the valve factors assumed for some valve groups to be inadequately supported when compared to available industry data.
Load Sensitive Behavior The inspectors reviewed Engineering Position Paper, " Rate Of Loading (Load
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Sensitive Behavior)" dated September 19,1994, which documented GPUN's evaluation of load sensitive behavior. GPUN analyzed five data points. This analysis indicated a bounding value of 5.0%. Therefore, a 5% bias error was added to the minimum required thrust. Further, GPUN added an uncertainty factor (random error) of 5.0% in the square root sum of the squares methodology with -
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other uncertainties. This differed from a more rigorous statistical approach that would apply the mean of the data as a bias, and the two standard deviations in the square root sum of the squares combined with other uncertainties. GPUN's method
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differed from this approach largely because of the limited amount of available in-
plant data. The inspectors noted that a small amount of data currently exists, and-the acquisition of additional data could substantially change the bias and random i
amount attributed to load sensitive behavior.. The inspectors considered the assumption for load sensitive behavior not well supported and not of high statistica!
confidence due to the limited amount of data.
Stem Friction Coefficient
The inspectors reviewed Engineering Position Paper, " Stem Lubricant Degradation,"
- dated May 28,1996. GPUN used Syncogel Superlube as a stem lubricant. GPUN had performed a statistical analysis of stem friction coefficient that used seven data points. This analysis indicated a mean of 0.10, and a mean plus two standard
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deviations value of 0.16.~ Further, GPUN data indicated a stem lubricant
. degradation of approximately 2.4%. GPUN originally assumed a stem friction
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coefficient of 0.20 for their MOVs. The inspectors considered GPUN's 0.20 assumption for stem friction coefficient to be adequate for program closure, although a relatively small amount of data were used in the statistical analysis. If GPUN intends to reduce the 0.20 assumption, more data will be needed to justify a
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lower SFC assumption.
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Conclusions As a result of only seven MOVs being dynamically tested at Oyster Creek, GPUN had to obtain valve performance information from other sources to justify its assumptions for valve factor, stem friction coefficient and rate of loading effects.
GPUN established a weight factor for applying the industry information, but did not develop a test-based justification for the reliability of this approach. NRC inspectors found the valve factors to be inadequately supported wher compared to available industry data.
GPUN had only a few test data points at Oyster Creek to support its assumptions i
I for stem friction coefficient and rate of loading effects. Although a reasonably-bounding value for stem friction coefficient was assumed, the assumption for rate of loading effects was not well supported and not of high statistical confidence based on the small amount of plant-specific data.
Therefore, the program was not closed since GPUN had not yet adequately verified
design bases capability of GL 89-10 MOV's. Recent self assessment findings are intended to better justify various program assumptions,'and reach completion of the GL 89-10 baseline program.
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l E1.4 Assessment of the Standbv Liould Control System (SLCS)
a.
.Insoection Scone (375501
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This system was inspected to ascertain if the installed system status was consistent with the Technical Specifications (TS), FSAR, system drawings,
calculations, and operating and surveillance procedures.
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_ Observations and Findinas The GPUN system engineer accompanied the inspector on a walk down of the
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SLCS. The inspector compared the as-found system to the drawing and operating
procedures. The inspector found the drawing was up to date and reflected the
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plant configuration. The in-line valves were locked as required by operating
. procedures. The inspector found that the area of the plant in which the SLCS is -
f located was clean and free of contamination. The inspector reviewed FSAR
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Section 9.3.5 and determined that the installation of the components reflected the
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FSAR description.
On October 21,1986, GPUN was informed by the NRC that certain criteria had to i
be met to comply with the ATWS rule (10 CFR 50.62, Requirements for Reduction for Risk from Anticipated Transients Without a Scram (ATWS) Events for Light-
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Water-Cooled Nuclear Power Plants). Generic Letter (GL) 85-03, Clarification of
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Equivalent Control Capacity for SLCS, dated January 28,1985,' further clarified the new rule requiring a change to the chemistry specifications of the SLCS.
e The inspector reviewed the calculations that formulated the new chemistry
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parameters (C-1302-213-5370-014 & 009). The inspector also reviewed amendment 124 to the Technical Specifications (TS) and the accompanying 50.59 safety evaluation (SE-328232-001). The inspector verified that the changes were reflected in the FSAR, TS, and current operating and emergency procedures (EMG-3200.01B "RPV Control With ATWS" with Support Procedure 23 " Alternate Boron Injection with the Cleanup System," Support Procedure 24 " Alternate Boron injection with the Feed and Condensate System"). The inspector found the above i
calculations were correct, had received the necessary reviews, and had the
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necessary safety evaluations performed.
The inspector also determined that the ATWS safety analysis delineated in FSAR Section 15.8 was up to date and reflected the requirements of the ATWS rule. The ATWS rule requires that the SLCS' minimum flow capacity and boron content be equivalent in control capacity to 86 gallons per minute (gpm) of 13 weight percent (wt.%) sodium pentaborate solution. To comply with the Rule, GPUN required an equivalent control capacity of a solution of a minimum of 15 wt.% sodium pentaborate.-and a maximum of 19 wt.% with a minimum of 35 atom % Boron-10
. delivered at 30 gpm the pump capacity of OC. The TS, FSAR, and operating procedures were up to date and reflected the requirements of the calculations.
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The inspector reviewed the following surveillances required by TS:
Pumo Ooerability This test is required every 3 months. The inspector reviewed the last four tests and noted that the tests were run on time and satisfied all the requirements. The inspector also noted that the pumps are monitored by the IST program as required.
The results of the tests did not reveal any adverse trends in pump performance.
The inspector also verified that the check valves in the SLCS were also in the IST program and were being tested at the required frequency.
Boron Concentration Determination
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This test is required once per month. The inspector reviewed the last three tests noting they were performed on time with satisfactory results.
Functional Test This test is required once every 24 months and verifies the functionality of the system including firing the squib valves V-19-44 & 45. The inspector reviewed the last two functional tests and found them to be complete with no problems.
Solution Volume and Temperature Check This check is required once daily. The inspector reviewed one month of checks and found no adverse trends.
Solution. Boron 10 Enrichment This test is required by TS every 24 months and was to be performed by an independent laboratory. TS requires that the results of the test should be received (by GPUN) within 30 days of the sampling or notify the NRC within seven days of plans to obtain the test results. The inspector asked GPUN for the last two tests.
GPUN then informed the inspector that the last test had not met the 30-day requirements of TS and had not been reported as required. This constitutes a violation of TS 4.2.E.5. GPUN promptly wrote a deviation report and processed it resulting in a notification to the NRC. The call was to be followed up by an LER describing the reason for not making the necessary TS notification.
The details of why the above problem occurred are as follows:
March 22,1996 the sample was obtained
April 29,1996 the sample was received by the vendor who was to perform the test
May 10,1996 GPUN received the results of the test which were satisfactory
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GPUN drew the sample in the allotted time frame, but did not send it to the vendor j
for over one month because its contract with the vendor had expired. After receipt, i
the vendor returned the results in two weeks. GPUN stated in its deviation report -
that they had alternate methods to obtain the sample results and should have followed them. GPUN also recorded in the deviation report that the sampling procedure would be updated to reflect the reporting requirement. Since the tank ~
was sampled in the required time frame and the results were satisfactory, this failure constitutes a violation of minor significance and is being treated as a non-i cited violation consistent with Section IV of the enforcement policy.
(50-219/97-05-01)
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.Qtherissues I
'l The inspector was informed that valve V-19-OO23, used for throttling during recirculation testing of the positive displacement pumps, had been creating system
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problems.
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The valve was replaced by an improved valve with better throttling capability to i
enhance the testing of the system. The inspector reviewed the alternate f
replacement evaluation and design change for the installation of the new throttle j
valve including the seismic assumptions made and entered into the calculation. The i
inspector found that the replacement evaluation was detailed and compared all aspects of the original and its replacement. The new valve met all cf the requirements of the replaced valve including the ANSI and ASME codes required.
The new valve was heavier by 69 pounds and required a reevaluation of the seismic
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capabilities of the run of pipe containing the valve. The seismic evaluations showed that the current configuration _of the SLCS piping could support the new valve. The sizing calculation for the new valve was performed to select a valve giving a wider
opening for the flow characteristics desired to stop the vibration and flow control problems. Test data reviewed by the inspector showed the new valve has been
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successful in eliminating the testing problems.
The installation requirements were in accordance with GPUN approved procedures
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with one exception. A field change notice was required to be filed to update the systems design basis. The inspector noted that the item in the alternate replacement evaluation was marked "yes" indicating the FCN was written, however, the FCN number was not recorded. The inspector asked for the FCN and-
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subsequently learned that the document was written. However, due to an
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oversight, the document was left with the original package and never processed
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through the system. The inspector reviewed the consequences of this action and
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determined there was not safety significance for the time frame of installation to l
present because the valve data was not required for design changes to the SLCS, j
This data is, however, required for the remainder of plant life. The vendor manual l
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change request was processed and the vendor manual was updated should t
maintenance have been required on the valve. GPUN wrote a deviation notice
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delineating the omission of the FCN requirement. This failure to follow procedure
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constitutes a violation of minor significance and is being treated as a non-cited violation consistent with Section IV of the enforcement policy. (50 219/97-05-02)
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Conclusions The inspector concluded that the SLCS has been well maintained and functions in accordance with the design basis. The as-found condition of the SLCS is consistent
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with the TS, emergency and operating procedures, the UFSAR, and surveillance
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procedures. The SLCS was also found to meet the requirements of the ATWS rule.
E7
- Quality Assurance in Engineering Activities E7.1 Self and Independent Assessments a.
Insoection Scoce (37550)
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The inspector selected four QA audits of engineering activities, and evaluated the effectiveness of corrective actions as well as self-assessment of the OC Engineering Department.
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b.
Observations and Findinas Audit S-OC-96-05 performed April and May 1996 - This audit was performed to assess the plant support activities. The audit concluded that Plant Engineering Support was providing effective support to the operations and maintenance functions. Three deviation reports were issued as a result of the audit. Problems were identified with procedure biennial reviews (13 of 13 procedures had not received the reviews), and the performance of vendor-recommended maintenance
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on the blackout combustion turbines. The inspector verified that the biennial
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reviews were subsequently performed and that the vendor recommendations are now incorporated in the appropriate procedures.
Audit 0-OC-96-01 performed May and June 1996 - This audit was performed to assess the design control at OC The audit concluded that the design process at OC was effective and in compliance with OC procedures. One finding from this audit was that the bill of materials procedure was not followed. By the review of GPUN responses to the finding, the inspector verified that additional review of bills of material for five additional modifications were reviewed and no additional discrepancies were identified. The inspector concluded that GPUN's assessment of an isolated case of procedure adherence was appropriate, and that actions to clarify the procedure was completed in December of 1996.
c.
Conclusions The inspector determined that the audits reviewed were effectivo, self critical, and well organized. Two of the audits reviewed (S-OC-95-02 and 0-COM-96-03) had no findings; therefore, corrective actions could not be assessed. The findings reviewed by the inspector were acted upon promptly and appropriate actions were taken to resolve the problems.
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E8 UFSAR Review l
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While performing the inspections discussed in Engineering Section E1.2, the inspector reviewed the applicable portions of the UFSAR and found no concerns.
The above modification package identified and included the appropriate changes to be incorporated in the UFSAR as required.
XI. Exit Meetina Summarv E9 Exit Meeting.
An exit interview was conducted on April 11,1997, at the Oyster Creek station.
-The purpose and scope of the inspection were reviewed and the preliminary findings s
. were presented. Since the exit, in a phone call on ' June 30,1997,GPUN
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committed to review its assumptions for group valve factors, stem friction j
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coefficient, and rate of loading effects, and strengthen the bases for these assumed
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' valve parameters and inform the NRC of the program changes via a letter. This
should include review of available industry test data, application of industry analytical techniques (such as the EPRI MOV Performance Prediction Program), and
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performance of static or dynamic tests at Oyster Creek.
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PARTIAL LIST OF PERSONS CONTACTED
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GPUN i
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W. Behrle Director, Equipment Reliability
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P. Cervenka.
Equipment Reliability, Components
- D. Croneberger Director, Engineering Support P.Goya Licensing
R. Keaten Vice President, Engineering, GPUN S. Levin Director, Operations and Maintenance
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c A. Rone Vice President, NS&TS
D. Slear Director, Configuration Management B. Tilton NSA Manager, Oyster Creek
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L INSPECTION 3ROCEDURES USED Tl 2515/109; Inspection Requirements for Generic Letter 8910 ITEMS OPENED, CLOSED, DISCUSSED i
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Closed >
50 219/97-05-01; NCV failure to perform surveillance test 50-219/97-05-02; NCV failure to process final change notice i
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