IR 05000261/1991006

Insp Rept 50-261/91-06 on 910304-08.No Violations or Deviations Noted.Major Areas Inspected:Licensee Actions to Address Violations & Inspector Followup Items Noted in MOV Insp,Per Generic Ltr 89-10

ML14178A092
Person / Time
Site:	Robinson
Issue date:	03/20/1991
From:	Girard E, Jape F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14178A091	List: IR 05000261/1991006
References
50-261-91-06, 50-261-91-6, GL-89-10, NUDOCS 9104110267
Download: ML14178A092 (9)

Text

pft REG9 UNITED STATES C'

NUCLEAR REGULATORY COMMISSION

REGION II

o 101 MARIETTA STREET, Z ATLANTA, GEORGIA 30323 Report No.:

50-261/91-06 Licensee:

Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:

50-261 License No.: DPR-23 Facility Name: H. B. Robinson Inspection Con March 4-8, 1991 Inspector:

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Gir rd Date Signed Approved b : F h

^ Late ig e F. a Do C EfDate Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:

This routine, announced inspection was conducted in the areas of followup on licensee actions to address violations and inspector followup items identified in a previous motor operated valve (MOV) inspectio Results:

Licensee actions in regard to the MOV related violations and inspector followup items were found to be in accordance with their commitments to the NR Although the matters will be closed for tracking purposes, they are to be revisited in subsequent NRC inspections of the licensee's response to Generic Letter 89-10,

"Safety-Related Motor Operated Valve Testing and Surveillance".

Two areas of weakness were noted and discussed with licensee management during the inspection:

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The licensee's program for identification of repetitive failures appeared in need of improvemen The computerized maintenance history data base was found to be effectively used to identify any repeat work on the same component. However, cause entries were not always well-documented in the history and this increased the need for individual assessments with attendant inefficiencies and potential for erro Also, failures of like components and parts were not identified through the progra The responsible manager had indicated plans to implement capabilities for computer identification of such failures in discussions held during the NRC 9104110267 910320 PIR ADOCK 05000261

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PDR

Maintenance Team Inspection conducted in June 199 As a final concern, the procedure that controlled the repetitive failure program had been canceled when organizational responsibilities for the program had been changed earlier in the year. A new procedure had been drafted but had not been approve The site procedure controlling the licensee's program for assuring the adequacy of their MOVs had been canceled earlier in the year. A new procedure intended to replace it was still in draf REPORT DETAILS 1. Persons Contacted

• R. Barnett, Manager, Outages and Modifications

• D. Crook, Senior Specialist, Regulatory Compliance

• C. Dietz, Manager, Robinson Nuclear Project

• W. Dorman, Nuclear Assessment Department Manager

• S. Farmer, Manager - Engineering Programs J. Gee, Component Cooling Water System Engineer

• J. Kloosterman, Manager, Regulatory Compliance W. McCutcheon, Managed Valve Maintenance Program Coordinator M. Page, Manager, Technical Support

• W. Powell, Senior Specialist, Nuclear Engineering Department On-Site J. Sheppard, Plant General Manager

• R. Smith, Manager, Maintenance

• D. Stadler, On-Site Licensing Engineer, Nuclear Licensing

• H. Young, Manager, Quality Control

• Attended exit interview on March 8, 1991 3. Action on Previous Inspection Findings (92701, 92702) (Closed)

Inspector Followup Item 261/89-200-01, Licensee Evaluate MOV Torque Switch Settings This item identified a concern that the licensee did not have bases to support their torque switch setting In a June 6, 1989 conference call with the NRC, the licensee committed to review the adequacy of their settings for all safety-related MOV The results of the review were reported in a letter to the NRC dated October 4, 198 In it the licensee stated that the review involved "rough calculations" performed to meet a 90 day -review completion commitment made to the NRC in the June 6, 1989 conference cal They indicated that no instances were found where changes to torque switch settings were require The inspector discussed the review actions with responsible technical support personnel (especially the Managed Valve Maintenance Program (MVMP) Coordinator) and verified the documented review data which was contained in the licensee's September 5, 1989 report entitled "MOV Torque Switch and TOL Heater Setting Review" (identified Serial N RNPD/89-2413).

The report described the review as a best estimate in response to the NRC concer The inspector did not perform any detailed evaluation of the determinations in the repor The licensee has been developing an extensive evaluation in response to criteria specified in NRC Generic Letter (GL) 89-1 Details of the licensee's determinations and application of settings from this work will be reviewed in a subsequent NRC inspection as part of the current NRC progra The inspector examined some examples of licensee work in response to GL 89-1 A licensee "MOV Testing Detailed Action Plan" was reviewed and determined to provide appropriate actions and schedule dates to respond to each GL 89-10 recommendatio Diagnostic testing of one valve was observed and appeared properly performed (Auxiliary Feedwater System Valve V2 14A).

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The MVMP Coordinator demonstrated his data base for recording valve failure and degradation dat A draft copy of the procedure that administratively controls the site MOV program was verifie The MVMP Coordinator stated that the procedure which previously provided the requirements had been canceled earlier in the yea The procedure to replace it had not been issued yet due to the demands of the refueling outage that had run over-schedul The inspector expressed concern that the licensee did not currently have an approved administrative procedure for their MOV program and questioned whether their design activities to meet GL 89-10 commitments were being controlled by approved procedure He was informed that the design activities were being controlled and accomplished by the licensee's corporate engineering organization; and the corporate Nuclear Licensing Engineer stated that the procedures governing the GL 89-10 design activities had been approved and issue The NRC inspector concluded that the actions completed by the licensee in response to this inspector followup item and the further actions being undertaken by the licensee and NRC in regard to GL 89 10 provided sufficient basis for closure of this matte (Closed)

Inspector Followup Item 261/89-200-02, Licensee Evaluate MOV Thermal Overloads This item identified a concern.that the licensee did not have bases for thermal overload sizin In a June 6, 1989 conference call with the NRC, the licensee committed to review the adequacy of the thermal overload sizing for all safety-related MOVs for which the valve, the motor actuator, or the overload protective device had been modified since original plant construction. The results of the review were reported in a letter to the NRC dated October 4, 198 In it the licensee stated that they had determined that all of the valves had acceptable thermal overload protection to provide adequate valve stroke margi As for the review described in 3.a above, the inspector discussed the review actions with responsible licensee personnel and verified the documented review data which was contained in the licensee's September 5, 1989 repor The inspector did not perform any detailed evaluation of the determinations in the repor As noted in 3.a, the licensee has been performing an extensive evaluation in response to NRC Generic Letter (GL) 89-10. This evaluation includes MOV thermal overload Details of the licensee's determinations and any required changes to thermal overloads resulting from this evaluation will be reviewed in a subsequent NRC inspection of the licensee's actions in response to GL 89-1 The NRC inspector concluded that the actions completed by the licensee in response to this inspector followup item and the further actions being undertaken by the licensee and NRC in regard to GL 89-10 provided sufficient basis for closure of this matte.c (Closed) Violation 261/89-200-03, Failure to Take Adequate Correction in Response to MOV Failures This violation identified the licensee's failure to take adequate corrective action in response to repeated failures of Auxiliary Feedwater Valve V2-16A, Component Cooling Water Valve CC-730, and Feedwater Valve V2-6 The licensee's response to the violation, dated October 28, 1989, was acceptable to Region I The corrective action to preclude recurrence of the violation was to implement a repetitive failure program to identify, evaluate, and correct recurring equipment failure The inspector verified implementation of the program and reviewed a licensee notebook documenting the past repetitive failure assessments. The licensee's program for identification of repetitive failures had been effective in identifying some repeat failures but appeared in need of improvemen The licensee's computerized maintenance history data base was being used to identify any repeat work on the same component; however, cause entries were not always well-documented in the history and this increased the need for individual assessments with attendant inefficiencies and potential for erro Also, failures of like components and parts were not identified through the progra The responsible manager had indicated plans to implement capabilities for computer identification of such failures in discussions held during the NRC Maintenance Team Inspection conducted in June 199 As another related concern, the procedure that controlled the repetitive failure program had reportably been canceled earlier in the year, with transfer of responsibility for the program to the Technical Support organizatio A new

"guideline" document had been drafted to replace the procedure but had not been approved or issue The inspector expressed concern that, as for the MOV program procedure referred to in 3.a above, another procedure had been canceled before a replacement was

available for issu The inspector was shown the "guideline" document that was in review as a replacement for the previous procedur It appeared very limited in content, containing less than 3 pages of guidance tex The corrective actions reported by the licensee specific to the cited repetitive failures of the three valves were as follows:

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Auxiliary Feedwater Valve V2-16A:

The repetitive failures cited in the violation were instances when the valve would not shut electrically on May 14 and September 14, 198 In both instances the corrective maintenance was to clean the torque switch contact The reason the contacts required cleaning after such a short interval was not addressed by the license Although records were unclear, it appeared that a damaged torque switch was found and replaced later in an unrelated check of the valv As corrective action for the violation, the licensee stated that the actuator had been disassembled and no deficiencies were foun Also, they noted there had been no further failures after the replacement of the torque switch referred to abov Component Cooling Water Valve CC-730:

The repetitive failures cited for this valve involved a failure to fully open electrically on January 10, 1989, followed by a failure to close on April 6, 1989. In the first case corrective maintenance consisted of lubricating the valve stem; in the second, the torque switch contacts were cleane Records indicated that the stem had been lubricated and the contacts cleaned in November 1988. The licensee failed to consider why the failures occurred such a short time after the original stem lubrication and cleaning of the contact In their response to the violation the licensee stated that they had determined that their maintenance on this valve had been appropriat Feedwater Valve V2-6A The repetitive failures cited for this valve involved three failures to stroke on unit startup that were referred to in a work request dated October 28, 1988. The licensee's investigation determined that the thermal overload device had tripped but no evaluation of the problem was performed and corrective action consisted of merely resetting the overload device and stroking the valv In addition, the motor for this valve had been

previously replaced with one that drew higher current and there had been no evaluation of thermal overload sizin As corrective action for the violation, the licensee response stated that an extensive evaluation had been performed and it found no abnormal condition with the valve or actuator. They indicated that the probable cause was thermal binding of the valve disc when the valve was closed hot and then allowed to cool down before openin The corrective action was to provide cycling of the valve during shutdown to avoid the bindin As indicated above, the licensee indicated further corrective maintenance on the valves V2-16A and CC-730 had been determined to be unnecessar The inspector assessed this by reviewing the subsequent maintenance history for these valves to determine if further failures had been experience No failure similar to those cited was found for V2-16 For CC-730 a failure was noted that appeared somewhat similar to the past failure The valve was described as indicating mid-position in two closure attempts with full shut indication being received on the third attemp This was identified as an indication failure with the apparent cause being dirty contacts in the indicator circui The inspector found the licensee had identified this as a possible repetitive failure but their subsequent investigation concluded that it was no The procedure changes that the licensee stated would be made to avoid the failures of valve V2-6A were verified by the inspector in General Procedure GP-007, Rev. 21,

"Plant Cooldown From Hot Shutdown to Cold Shutdown".

Additionally, the inspector assessed the effectiveness of this corrective action by checking the maintenance history of the valve for further similar failures subsequent to the procedure change. None were foun In reviewing work history entries the inspector found several inadequacies in cause identificatio For example, work request 90 AGXS1 for seat leakage on valve V2-16A provided no indication of cause in the CAUSE block, CAUSE CATEGORY space or CAUSE DESCRIPTION space even though the CORRECTIVE ACTION entries indicated seat damage had to be repaired and, therefore, was a cause of the leakage (though not the root cause).

Although some weaknesses were noted in the licensee's corrective actions, the inspector concluded that the actions taken were sufficient to permit this violation to be close This area will continue to be monitored in routine inspections performed by NRC Region I.d (Closed) Violation 261/89-200-04, Failure to Consider Effects of MOV Modifications

This violation identified the licensee's failure to adequately engineer four design changes for MOV The licensee's response to the violation, dated October 28, 1989, was acceptable to Region I The specific examples cited in the violation, the licensee's corrective actions, and the inspector's verification for each were as follows:

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For Modification 551, three valves were replaced without evaluation of the continued acceptability of the old actuato With regard to this example the licensee indicated that they had not previously documented the bases but that the actuators had been determined to be acceptabl The inspector verified a logical explanation for the acceptably of the actuators described in the licensee's internal response to the report (response to commitment 89RO522).

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For Modification 638 the wrong voltage was specified for the replacement of three valve/actuator combination With regard to this example the licensee stated that no corrective action was necessary as the valves involved had no active safety functio The inspector discussed this with licensee personnel and accepted the explanation on the basis of information provided in the discussio For Modification 939, improperly sized thermal overload devices were installed in MOV circuit With regard to this example the licensee stated that a root cause analysis of the matter had determined that the causes were inadequately applied methodology in determining breaker setpoints and inadequate design verification of the calculatio The inspector reviewed the cause determinations and verified their correction as documented in licensee Significant Condition Report 89-00 For work requests 87-AFBR1 and 87-AFWS1, three actuator motors were replaced without performing thermal overload device sizing calculation With regard to this example the licensee stated that subsequent analyses had been performed that demonstrated that the thermal overload devices were adequately sized and that no additional corrective action was require The inspector accepted this explanation on the basis of discussions with licensee personne The licensee response stated that enhancements to their design control process, including their Nuclear Engineering Department taking responsibility for design control activities at their nuclear plants, should preclude recurrence of the violatio * Considering the verification of corrective actions noted above and that this area will be examined further in subsequent NRC inspections for GL 89-10, the inspector determined that this violation would be considered close.

Exit Interview The inspection scope and findings were summarized on March 8, 1991, with those persons indicated in paragraph The inspector described the areas inspected and discussed in detail the inspection results listed below and in the summary. Dissenting comments were not received from the licensee. Proprietary information is not contained in this report.