IR 05000266/1999012

Insp Repts 50-266/99-12 & 50-301/99-12 on 990614-18.No Violations Noted.Major Areas Inspected:Implementation of Inservice Test Program & MOVs Capability,Per GL 96-05

ML20209H564
Person / Time
Site:	Point Beach
Issue date:	07/14/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209H553	List: IR 05000266/1999012 ML20209H547
References
50-266-99-12, 50-301-99-12, GL-96-05, GL-96-5, NUDOCS 9907210015
Download: ML20209H564 (17)

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I j U.S. NUCLEAR REGULATORY COMMISSION REGION 111 ,

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i Docket Nos: 50-266;50-301 License Nos: DPR-24; DPR-27 Report Nos: 50-266/99012(DRS); 50-301/99012(DRS)

Licensee: Wisconsin Electric Power Company Facility: Point Beach Nuclear Plant, Units 1 & 2 Location: 6610 Nuclear Road Two Rivers, WI 54241 Dates: June 14-18,1999 Inspector. A. Dunlop, Reactor Engineer Accompanying Personnel: T. Scarbrough, Senior Mechanical Engineer, NRR J. Colaccino, Mechanical Engineer, NRR Approved by: John M. Jacobson, Chief Mechanical Engineering Branch Division of Reactor Safety i

9907210015 990714 PDR ADOCK 05000246 0 PDR l

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EXECUTIVE SUMMARY Point Beach Nuclear Power Plant, Units 1 & 2 NRC Inspection Reports 50-266/99012(DRS); 50-301/99012(DRS)

The NRC conducted an announced inspection that had a two-fold purpose. First, to review the implementation of the inservice test program, which had recently been revised. Secondly, to determine whether activities associated with Generic Letter 96-05, " Periodic Verificatbn of Design-Basis Capability of Safety-Related Motor-Operated Valves," were sufficient to ensure the continued capability of motor-operated valves.

Maintenance

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The revised inservice test program and associated surveillance procedures included a nurnber of improvements, which ensured the applicable safety-related components were properly tested as required. (Section M1.1)

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The scoping of components for the three systems reviewed was good. The inservice

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testing background document was considered a good tool to compile component bases and design requirements in one location. (Section M1.1)

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Inappropriate positions on relief valve acceptance criteria for determining test failures

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(non-cited violation) and the inadequate justification for deferring quarterly testing of manual valves indicated some further inservice test program refinements were appropriate. (Section M1.1)

. Based on a review of sample motor-operated valves (MOVs), licensee submittals, calculations, procedures, and condition reports, the inspectors determined that the licensee was still engaged in its effort to establish a program to provide long-term i assurance that MOVs within the scope of Generic Letter 96-05 were capable of performing their design-basis safety functions. As such, Temporary Instruction 2515/140," Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves (GL 96-05)," could not be closed. (Section M1.2)

- Weaknesses were identified that resulted from the delay in the implementation of the long-term MOV program following completion of Generic Letter 89-10. The three most significant weaknesses needing attention included: (1) the establishment of a dynamic diagnostic test plan to provide information on potential valve age-related degradation, (2) the establishment of a plan to trend qualitative and quantitative information on MOV performance and to periodically asse.ss that information, and (3) resolution of the large backlog of condition reports on MOV performance. (Section M1.2)

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Report Details 11. Maintenance M1 Conduct of Maintenance M1.1 Inservice Testina (IST) of Pumos and Valves a

a. Inspection Scooe (73756)

The inspectors reviewed documentation associated with the licensee's IST program.

Arcas reviewed during the inspection included the program scope, IST background J

document, licensee positions, refueling and cold shutdown Justifications, relief requests pump testing, and valve testing. The service water (SW), unit 2 component cooling ,

water (CC), and unit i residual heat removal (RHR) systems were selected to review in 4 detail to ensure that all components required to be tested by the American Society of

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Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code) were s included in the program and adequate testing was identified to verify the safety functions of each component. The inspectors used IP 73756," Inservice Testing of Pumps and Valves," and NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants,"

as guidance during the inspection.

b. Observations and Findinos

. The licensee's IST program was recently revised, along with the IST background document, as part of the Program improvement Project. The revised IST program was .

submitted to the NRC on September 30,1998. The revised program was developed to be in compliance with the requirements of the 1986 Edition of the ASME Code,Section XI, although portions of the required testing was performed in accordance with Operation and Maintenance (OM) standards; OM-6 for pumps, OM-10 for vcives, and OM-1 for pressure relief devices. However, the program submittal was not clear in all

- cases as to which edition of the Code was being applied. A clarification letter on Code commitments was submitted to the NRC on April 19,1999, and the program was revised to incorporate these clarifications. Several examples were identified during this inspection where clarification was still necessary as to Code usage, and where and how guidance from NUREG 1482 was being implemented. As a result of the revised IST program, numerous surveillance procedures were revised or written to conduct the required testing.' In general, the procedures adequately tested the components, although some minor procedure errors (typos) were identified.

b.1 gggpe of IST Prooram The inspectors reviewed the revised IST program and did not identify any concems with '

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the scoping of components for the SW, CC, and RHR systems. The required testing established for these systems' components was also considered acceptable. The licensee developed an IST background document in support of the revised IST program, which included information such as safety functions, justification for excluding

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components from scope, and component design information. The background document was considered a good tool to compile component bases and design requirements in one place. The licensee considered this a living document that would be updated based on changes associated with the plant. Some minor errors were identified with the valve l matrix and background document for the systems reviewed, which the licensee agreed I to revise.

b.2 Licensee Positions. Justifications. and Relief Reauests

,In general, acceptable justification was included with technical positions in the IST program. The licensee submitted three relief requests that required NRC approval and were yet to be approved by the Office of Nuclear Reactor Regulation (NRR). The majority of cold shutdown justifications and refueling justifications were acceptable to ,

defer the required quarterly component testing, however, one concern was identified with j the position on deferring the testing of manual valves as stated in several cold shutdown '

justifications.

Cold shutdown justifications CSJ-23, CSJ-31, and CSJ-32 contained a licensee position that " quarterly exercising of manual valves, unless exercised during a plant evolution, is burdensome without a commensurate increase in the level of valve reliability." The 1986 edition of ASME Section XI, Subsection IWV-3411 required that " Category A and B '

valves shall be exercised at least once every three months" unless operation was impractical during plant operation. Therefore, the position was not in accordance with the Code requirements and as such the basis for the co'd shutdown justification was .

Inappropriate. Condition Report 99-1592 was initiated to evaluate this concem. As a !

result of this evaluation, the licensee identified 32 manual valves that were covered by i

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this position, which were documented in Condition Report 99-1634. These manual valves were recently added to the IST program as part of the Program improvement Project. A review indicated that ti e 32 valves were exercised within the last associated unit operating cycle, which provided reasonable assurance the valves were capable of performing their safety function. The licensee indicated that the affected deferred test justifications would be revised and adjustments would be implemented to the test frequency of the specific valves to comply with the Code requirements. This approach was acceptable to the inspectors.

b.3 Pumo Testing For the three systems reviewed, pump testing was conducted in accordance with Code requirements. The inspectors noted that the RHR pump test did not require recording pump flow. Although flow was the fixed reference value, establishing this fixed value for each test precisely may not be possible. However, knowing the flow value may assist in the review of test results. The licensee was considering whether to record this value in subsequent revisions to the procedure.

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. i b.4 Valve Testina in general, valve testing was conducted in accordance with Code requirements, although two issues were identified. The first concerned the testing frequency of manual valves as discussed in Section M1.1.b.2, while the second concerned stroke timing of power-operated valves.

The IST program categorized the safety functions of several valves in a manner which was inconsistent with the terminobgy contained within the ASME Code and may result in certain power-operated valve stroke time tests not being credited for Code compliance. The 1986 edition of ASME Section XI, Table IWV-3700-1, summarized the testing requirements for valves with either an active or passive safety function.

Active power-operated valves were required to be tested in accordance with Subsection IWV-3413, which required that "the stroke time of all power-operated valves shall be measured." The licensee classified valve safety functions in the IST program as )

active, passive, or inactive. An inactive safety function was defined for cases where a l

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valve had safety functions in both the open and closed positions; but was only required to be maintained in one position (e.g., inactive closed function), and was not required under design basis conditions to reposition (e.g., close) after the valve had moved to its safety position in the opposite direction (e.g., active open function). The Code, however, did not define an inactive valve or valve function. In addition, the Code did not specify a hybrid designation of a valve having an active safety function in one direction (either i I

open or closed) and a passive safety function in the other direction. This position was also stated in the response to Question 2.1.9 from the " Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756," Inservice Testing of Pumps and Valves," and Answers to Panel QueW:,s on Inservice Testing issues," July 18,1997.

Therefore, the designation of a valve safety function as inactive appeared inconsistent with the terminology defined in the Code and position of the NRC staff.

The types of valves affected by this position included manual valves, relief valves, and power-operated valves. The testing performed on manual valves and relief valves, however, was the same regardless of the IST program designation. Power-operated valves that had an " inactive" safety function designation for either the open or closed position were tested (stroke-timed) in that direction, but the results of the test were not credited for compliance with the ASME Code and were not intended to be used to perform operability determinations. Four examples were identified: two motor-operated valves (1SI-00896A/B) and two air-operated valves (1SI-897A/B).

Although the licensee agreed a valve could not be both active and passive, they disagreed with the position that the valves were required to be stroke-timed tested in both directions per the Code. Condition Report 99-1659 was initiated to document the ,

issue and the licensee will be submitting an inquiry to the ASME OM Code Committee.

This issue is considered an unresolved item (URI 50-266/301-99012-01(DRS)) pending l the issuance of a Code interpretation by ASME. This was considered a Code compliance issue and not a safety concern since the valves were stroke-time tested in both directions to ensure the valves functioned as required.

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b.5 ~ Relief Valve Testina

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. Procedures CMP 3.2, " Relief / Safety Valves," and MI 5.4.1, " Relief, Safety and Safety Relief Valve Testing-General," were reviewed to ensure compliance with OM-1. The procedures were adequate to perform as-found testing of relief valves, although one concem related to set pressure acceptance criteria was identified by the inspectors.

For relief valve testing, the licensee was using OM-1-1990,1994 Addenda, as allowed by Section 4.3.9 of NUREG 1482. This edition allowed the establishment of a set pressure acceptance criteria for relief valves. Step 4.2.2 of CMP 3.2 established the criteria at 12 psi for set pressure up to 70 psig and i3 percent of the stamped set pressure for valves above 70 psig. However, step 4.2.2 of CMP 3.2 also stated that exceeding the acceptance criteria on the low side was not a test failure and did not require a review to expand the testing sample. This position was based on Code Interpretation 92-8 of the OM-1 Code. This interpretation, however, was based on the OM-1 1981 edition and was not applicable to the 1994 Addenda. The 1981 only -

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specified a +3 percent acceptance criteria, such that the inquiry requested clarification that the Code did not require expanded testing for failures below the acceptance criteria.

The 1994 Addenda was revised based on Code Interpretation 92-8 to include the i3 percent acceptance criteria rendering the interpretation moot for later editions of the Code. As such, exceeding the acceptance criteria on the low side would be a test failure and would potentially require expanded testing.

The inspectors identified two relief valves where the test results were below the established acceptance criteria, but not considered test failures, As a result, no expanded testing was considered.: The two examples were as follows:

, Valve Number : Setooint Acceptance Criteria Test Results Test Date SW-02959 100 psi ,97-103 psig 84 psig 5/14/99 2-SC-00991 2750 psi 2667-2750 psig 2650 psig (1st) 12/29/98 2600 psig (2nd)

Failure to declare test failures and consider expanded relief valve testing was not in i

accordance with the Code and considered a violation of Technical Specification 15.4.2.B, which required testing of Code class components in accordance with Code ,

requirements. This Severity Level IV violation is being treated as a Non-Cited I Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Condition Report 99-1568 (NCV 50-266/301-99012-02(DRS)).

c. Conclusions The revised IST program included a number of improvements and associated surveillance procedures, which ensured the applicable safety-related components were properly tested as required per the Code. The scoping of components for the three systems reviewed was good. The IST program background document was considered a

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l good tool to compile component bases and design requirements in one location. i However, inappropriate positions on relief valve acceptance criteria for determining test failures (non-cited violation) and the inadequate justification for deferring the quarterly )

testing of manual valves indicated some further IST program refinements were i appropriate. The position on stroke timing power-operated valves was in disagreement with the inspectors' interpretation of the Code, which resulted in an unresolved item pending a Code inquiry.

M1.2 Imolementation of Generic Letter 96-05. " Periodic Verification of Desian-Basis Capability i of Safetv-Related Motor-Operated Valves"  !

a. Insoection Scope (Temocrary Instruction (TI) 2515/140)

Generic Letter (GL) 96-05 requested licensees to establish programs to verify through 1 periodic testing that safety-related motor-operated valves (MOVs) were capable of performing their safety functions within the current licensing basis. Prior to the -

inspection, the licensee responded to the recommendations of GL 96-05 in letters to the j NRC dated November 18,1996, and March 17,1997.

A three-phase MOV periodic verification program developed by the Joint Owners Group (JOG) was reviewed by the NRC staff and determined to be acceptable with certain conditions and limitations documented in a safety evaluation report issued on October 30,1997. In its March 17,1997 letter, the licensee described an alternative program plan. This inspection evaluated Point Beach's altemative plan to determine whether it was consistent with the licensee's commitments and with the recommendations of GL 96-05. The inspection was conducted through reviews of .

documentation and interviews with licensee personnel. The inspectors selected a I sample of MOVs considering dynamic test availability, valve type, and risk significance l to evaluate program implementation. The following valves were included: I

. 1-RC-515 and 1-RC-516, Pressurizer Power-Operated Relief Valve isolation Valves (3-inch Velan flexible wedge gate valve)

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. 2-RC-515 and 2-RC-516, Pressurizer Power-Operated Relief Valve isolation Valves (3-inch Anchor Darling double disc gate valve)

• 2-SW-2907, Containment Recirculation Heat Exchanger Emergency Flow Control Valve (12-inch Powell solid wedge gate valve)

a 2-CC-738B, Residual Heat Removal Heat Exchanger Shell Side Inlet Valve (10-inch Velan flexible wedge gate valve)

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b. - Observations and Findinas

Commitments to GL 96-05 (Tl 2515/140. Paraaraoh 03.01)

The licensee indicated in its letter to the NRC dated March 17,1997, that they had not committed to the JOG program. However, they would review any JOG valve recommendations and, if necessary, the test results on which they were based, and

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incorporate the results of the review into the MOV program.

The attemative periodic verification plan consisted of a combination of static and

' dynamic diagnostic testing and periodic maintenance activities for MOVs in the

. GL 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance," program.

The licensee committed to statically test with diagnostic equipment all safety-related MOVs every 5 years and nonsafety-related MOVs every 10 years. In addition, they would dynamically test with diagnostics 26 MOVs within 5 years of the GL 89-10

. close-out inspection and establish a specific age related degradation margin. Test resuits would be evaluated to validate valve factor and rate of loading assumptions. The licensee would also review NRC and industry valve performance degradation information, including the Electric Power Research Institute (EPRI) performance prediction program. Applicable information would be incorporated into the program.

GL 89-10 Lona-Term Actions (Tl 2515/140. Paraaraoh 03.02)

In NRC Inspection Report 50-266/301-95007, th'e NRC closed its review of the GL 89-10 program, based on the licensee's actions to verify the design-basis capability of its safety-related MOVs and to periodically confirm this capability. The inspectors identified several long-term actions to be addressed in that report.

The inspectors reviewed the status of the long-term MOV actions planned following completion of GL 89-10 close-out inspection. In particular, the licensee had not

. I completed the overall review of the assumptions for valve factor and load sensitive behavior because of the limited progress made in performing dynamic testing as part of the long-term MOV program. Actions completed included the following:

• - Revised CMP 2.2.7, " Engineering Instructions for Performing Valve Operator !

Checkouts," to include guidance on evaluating MOV capability to achieve

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unwedging thrust requirementst

= Revised CMP 2.2.6, " Analysis of MOV Test Signatures Taken During Differential Pressure Tests of Gate and Globe Valves," to specify that dynamic tests must be ;

conducted under differential pressure conditions of at least 60 percent of the

.MOV design basis to allow reliable extrapolation of the test results. j

+ Revised the specific CMP 2.2.8, "MOV Design Basis Review," calculation for each MOV family to include diagnostic equipment inaccuracy and torque switch repeatability in the MOV switch setting requirements.

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Applied test resv'ts to increase the valve factor specified for MOVs 1(2)CC-719 and 1(2)SI-87%(B) in Calculation P-94-005.

. Increased the valve factor applied for globe valves to 1.1 in Calculation P-94-005 consistent with general industry information.

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Improved the calibration of its MOV load-cell diagnostic equipment thrcqh the use of instrumented valve stems and initiated plans to obtain additional MOV advanced diagnostic equipment.

In GL 89-10, the NRC recommended that MOV performance be trended on a long-term basisc During the close-out of GL 89-10, the inspectors noted that the licensee had adequate plans to perform MOV trending. However, they did not follow through with those plans for tracking and trending MOV performance. For example, periodic reports were not prepared on trends of qualitative (such as maintenance and condition reports)

and quantitative (such as MOV thrust and torque data)information on MOV performance.

' With respect to the long-ter,n GL 89-10 isti es, the licensee had not adhered to its efforts to implement planned dynamic tests, to peiform an overall evaluation of program assumptions for valve factor or load sensitive behavior, or to perform qualitative and quantitative trending of MOV performance.

F. 96-05 Proaram (Tl 2515/140. Paraaraoh 03.03)

The March 17,1997, letter summarized the licensee's GL ^S-05 program of static and dynamic di%nostic testing, preventive maintenance, and trending. The inspectors reviewe's the program and implementing documents and found that the long-term MOV prograng had made little progress until mid-1998 when efforts were re-initiated to update the GL 96-05 program. The inspectors noted that the quality assurance organization did

- not appear to be sufficiently monitoring the progress of the MOV program to identify these implementation delays. Since then, a number of MOV program documents were revised or in the process of being updatea, including plans to revise maintenance and test procedures to include individual task completion requirements for improved control of those activities.

Scope of MOVs included in the Proaram In GL 93-05, the NRC stated that the scope of the long-term MOV program should be consistent with the scope of GL 89-10. Further, the NRC staff recommended that the GL 96-05 program consider safety-related MOVs that were assumed to be capable of retuming to their safety position when placed in a position that prevents their safety system (or train) from performing its safety function; and the system (or train) was not

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declared inoperable when the MOVs were in their non-safety position.

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The licensee stated that its MOV program included 126 safety-related MOVs and 54 nonsafety-related MOVs. As the result of recently completed or planned

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L l modifications, additional MOVs were appropriately being added to the GL 96-05 program. The NRC close-out inspection report ststed that the licensee was evaluating

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the need to include service water ring isolation valves SW-2869,2870,2890, and 2891 l

in the MOV program. Since then, the licensee determined that these MOVs need not be

included in the GL 96-05 program, but continued to provide diagnostic and stroke-time l testing to monitor their performance. Based on review of these MOVs by NRR systems personnel, the inspectors did not identify any concems with the treatment of these

service water valves. Based on the sample review, the inspectors found that the scope l of the MOV orogram was consistent with the recommendations oi GL 96-05.

l MOV Desian Basis l

l The licensee reconfirmed the intent to maintain a "living" MOV program and was in the process of updating the program and calculations in response to new information. For example, Calculation P 90-0017 was updated to address recent guidance from the actuator manufacturer on MOV motor actuator output. Other MOV documents, such as CMP 2.2, " Motor Operated Valves," remained to be updated to reflect current program plans. Recently installed MOVs were being added to the GL 96-05 program as appropriate. Based on the sample review, the inspectors concluded that the licensee was in the process of maintaining an up-to-date design basis for its safety-related MOVs.

Dearadition Rate for Potential increase in Thrust or Toraue Operatina Reauirements l The March 17,1997, letter indicated the licensee's commitment to diagnostically test l 26 MOVs under differential pressure conditions within 5 years of the date of the close-out inspection report to evaluate assumptions regarding age degradation and to establish a 1 l specific age-related degradation margin. The inspectors found that little progress was I made in performing those dynamic tests. The licensee stated current plans were to perform dynamic testing of a sample of MOVs on a rotating basis every 5 years to establish a degradation rate for valve performance. High margin MOVs (such as gate valves with a 0.95 valve factor capability and globe valves with a 1.5 valve factor capability) may be exempt from dynamic testing. In addition to establishing a dynamic testing plan, the licensee needed to establish criteria for reassessing the dynamic test )

l frequency based on test results and to consider the effects of static testing immediately l l prior to dynamic testing. The inspect :rs determined that the licensea had not completed l plans to establish an acceptable test program to identify potential valve age-related l l degradation. l Deoradation Rate for Potential Decrease in MOV Motor Actuator Outout l

The licensee planned to monitor potential degradation in MOV performance through periodic static diagnostic testing of each GL 96-05 MOV. In addition, infon% tion would be obtained on MOV motor actuator output during periodic dynamic diagnostic tests of a sample of GL 96-05 MOVs. The parameters to be monitored included thrust, motor ;

current, stem friction coefficient, rate of loading, and stroke time, as appropriate.

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Periodic preventive maintenance activities of GL 96-05 MOVr were specified in CMP 2.2 to help ensure the MOVs' continued reliable output capability. The Marca 17,1997, letter summarized the preventive maintenance program to pravide rebuilding of MOVs located in high temperature environments every 5 years, MOVs cycled during quarterly testing every 10 years, and MOVs infrequently cycled every 15 years. The licensee also would review information from the NRC and industry (including EPRI) on valve l performance degradation.

The licensee responded to the updansd guidance on AC-powered MOV motor actuator

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output provided in 1.imitorque Technical Update 98-01 and its Supplement 1 by revising

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Calculation P 90-0017. The Commonwealth Edison Company (Comed) methodology developed to predict MOV motor actuator output was applied in revising the calculations.

The licensae will address any modifications to the Comed methodology resulting from the updated Limitorque guidance. The licensee did not identify any operability concerns during the evaluation of the new information. ,

I Technica! Update 98-01 noted that additional guidance will be provided on the prediction of DC-power MOV motor actuator output. There were 10 DC-powered MOVs in the program. The licensee applied " pullout" efficiency and the application factor recommended by Limitorque for those DC-powered MOVs. The industry effort was being followed on this issue and will address any additional guidance when issued.

Based on the sample review, the inspectors found that the licensee had established adequate means to monitor the output performance of its safety-related MOVs, including consideration of guidance on motor actuator output.

Periodic Test Method The licensee planned to conduct periodic static and dynamic testing on GL 96-05 MOVs to monitor their continued design basis capability. The static diagnostic testing frequency of each safety-related MOV was once every 5 years, and the dynamic testing l was planned on a sample of MOVs on a rotating basis every 5 years. Tne licensee

! might exempt some high-margin MOVs with operating requirements sufficient to bound l potential valve age-related degradation from dynamic testing and would monitor those MOVs through static diagnostic tests. Although high safety-significant MOVs were iderI?ied, the licensee did not rely on f .V risk rankings in establishing the GL 96-05 l MOVs' diagnostic testing schedule. The inspectors reinforced the importance of considering risk in implementing the MOV program for test schedule and method.

i l The inspectors found that the licensee was continuing its effort to establish periodic test

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methods for identifying the degradation of valve operating requirements and actuator output consistent with the recommendations of GL 96-05.

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l MOV Performance Evaluation Test performance of MOVs was evaluated in accordance with CMP 2.2.6, which included ,

the review of valve factor, pullout thrust requirements, and actuator output changes. The l MOV performance evaluation guidance needed to be updated to reflect the MOV dynamic test plans and to ensure feedback of test information for all applicable MOVs.

The test schedule provided data over the first 5 years to support longer MOV test intervals. The inspectors noted that the licensee had a significant backlog of condition reports related to MOV performance. The MOV condition report backlog had increased along with other engineering programs as noted in the recent engineering and technical support inspection report 266/301-99005. The inspectors did not identify any immediate safety concems resulting from the backlog, but noted that this caused a concem ,

regarding the quality of a "living" MOV program. The inspectors found that the licensee I was continuing efforts to update the evaluation of MOV performance and to reduce the ,

backlog of MOV condition reports.

MOV Test Interval A static diagnostic test interval of 5 years was established for all safety-related GL 96-05 MOVs, while a dynamic test interval of 5 years for a sample of GL 96-05 MOVs on a rotating basis was considered. The test schedule provided MOV performance information over the first 5-year interval with a maximun, in'erval of 10 years. The licensee needed to complete plans for periodic dynamic testing in order to determine the appropriate MOV test interval in the GL G6-05 program. The inspectors found that the licensee was continuing its effort to justify a periodic test interval that ensured continued MOV design-basis capability until the next scheduled test.

l c. Conclusions ,

Based on a review of sample MOVs, licensee submittals, calculations, procedures, and condition reports. the inspectors determined that the licensee was still engaged in its effort to establish a program to provide long-terrn assurance that MOVs within the scope of GL 96-05 were capable of performing their design-basis safety functions.

Weaknesses were identified that resulted from the delay in the implementation of the long-term MOV program following completion of GL 89-10. The three most significant weaknesses needing attention included: (1) the establishment of a dynamic diagnostic test plan to provide information on potential valve age-related degradation, W) the establishment of a plan tc, trend qualitative and quantitative information on MOV performance and to periodically assess that information, and (3) resolution of the large backlog of condition reports on MOV performance. The licensee stated that it planned to submit an update to its response to GL 96-05 to describe planned or accomplished actions. The NRC staff will review the information provided in the updated GL 96-05 submittal and this inspection report to pmps.re a safety evaluation on the response to GL 96-05.

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V. Manaaement Meetingg X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on June 18,1999. The licensee acknowledged the findings

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presented. The inspectors asked the licensee whether any material exantined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Bishop, System Engineer F. Flentje, Senior Regulatory Compliance Specialist

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A. Guenther, IST Engineer T. Cottingem, IST Engineer J. Knorr, Manager, Regulation & Compliance C. Neuser, System Engineer R. Mende, Plant Manager C. Peterson, Director, Engineering i E. Phillips, MOV Engineer I M.~ Reddemann, Site Vice President J. Roberts, MOV Engineet:

i J. Schweitzer, Manager, System Er9gineering G. Sherwood, Supervisor, Component Engineering LIST OF INSPECTION PROCEDURES (IP) USED J

Tl 2515/140: Periodic Verification of Design-Basis Capability of Safety-Related l Motor-Operated Valves (GL 96-05) l IP 73756: Inservice Testing of Pumps and Valves LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-266/301-99012-01 URI- Stroke Timing Active Power-Operated Valves in Both Directions 50-266/301-99012-02 NCV Failure to Perform Additional Relief Valve Testing After Set Pressure Test Failures Q9Ed 50-266/301-99012-02 NCV Failure to Perform Additional Relief Valve Testing After Set Pressure Test Failures

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LIST OF ACRONYMS

'AC Alternating Current ASME American Society of Mechanical Engineers CFR _ Code of Federal Regulations Comed Commonwealth Edison CR- Condition Report .

CC Component Cooling Water DC' Direct Currer:t DHR Decay Heat Removal DRS Division of Reactor Safety EPRI Electric Power Research Institute . 1 GL Genedc Leuer '

IFl Inspection Follow-up Item )

IP inspection Procedure  !

IST Inservice Test JOG Joint Owners Group ,

LHSI Low Head Safety injection

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MOV Motor-Operated Valve ,

l NCV Non-Cited Violation l NRC Nuclear Regulatory Commission l NRR Office of Nuclear Reactor Regulation OM Operation and Maintenance psig Pounds per Square Inch Gage j QCR Quality Condition Report l RC Reactor Coolant l

'RHR Residual Heat Removal j SW Service Wa'er TI Temporary instruction i URI Unresolved item

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l LIST OF DOCUMENTS REVIEWED The following is a list of licensee documents reviewed during the inspection, including documents prepared by others for the licensee. Inclusion on this list does not imply that NRC team reviewed the documents in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overallinspection effort. Inclusion of a document in this list does not imply NRC acceptance of the document, unless specifically stated in the inspection report.

Proarams/ Procedures inservice Testing Program Third Ten-Year Test Interval, Revision 6,6/6/99 Inservice Testing Program Background Document, Revision 4,11/12/98 1 Pump and Valve IST Program Acceptance Criteria, Revision 29,6/4/99 CMP 2.2 Motor Operated Valves, Revision 2,11/12/98 CMP 2.2.1 Determination of the Set-Up Criteria for Motor Operated Valves, Revision 2,8/9/98 CMP 2.2.2 Design Basis Review of Valves Driven by Motor Operators, Revision 1,8/25/98 CMP 2.2.4 Database Access for MOV Trending !nformation and MOV Specs, Revision 0,6/29/94 j CMP 2.2.5 MOV Signature Analysis Softwarc Program, Revision 1,7/27/98 CMP 2.2.6 Analysis of MOV Test Signatures Taken During Differential Pressure Tests of Gate and Globe Valves, Revision 1,4/25/96 CMP 2.2.7 Engineering Instructions for Performing Valve Operator Checkouts, Revision 4,12/4/93 C M P 2.2.8 MOV Design Basis Review, Revision 1,1/4/99 CMP 2.2.8.7 MOV Design Basis Review for Valve Family 7, Revision 0,2/1/99 CMP 2.2.8.10 MOV Design Basis Review for Valve Family 10, Revision 0,2/5/99 CMP 2.2.8.27 MOV Design Basis Review for Valve Family 27, Revision 0,2/16/99 CMP 2.2.9 MOV Overthrust /Overtorque Review guidance, Revision 0,6/22/94 CMP 2.2.10 Planning Guide,for Motor Operated Valve Maintenance, Revision 3,11/30/98 CMP 3.2 Relief / Safety Valves, Revision 3,4/9/99 OM 4.2.2 Inservice Tests, Revision 4, S/3/99 Calculations P 90-0017 Motor-Operated Valve Undervoltage Stem Thrust and Torque, Revision 9,5/24/99 P 94-0004 MOV Overload Heater Evaluation, Revision 3,5/14/99 P 94-005 MOV Stem Thrust Calculation for Gate and Globe Valves, Revision 5,2/19/99 PB 89-0031 Voltage Drop Across MOV Power Lines, Revision 4,4/25/99 97-0091 Hot-Smart-Short Overvoltage Stem Thrust and Torque, Revision 4,5/24/99 I

Pioina and Instrumentation Diaarams Service Water System Component Cooling Water System, Unit 2 l Residual Heat Removal System, Unit 1 Quality Condition Reoorts QCR 97-0148 Requirements for Testing Safety-Related Relief Valves per ASME Section XI,1986, OM-1 (1981) Criteria Were Not Met in All Instances.

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'I Condition Reoorts CR 97-3147 _ Inservice Test Requirements in lST Program Not Implemented

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CR 98-3815 Inservice Test Program Excluded Thermal Barrier CCW Supply & Retum Valves CR 97-3826 Inservice Test Program CCW Surge Tank Valves Mlssed Testing Requirements CR 98-3893 - Inservice Test Program Does Not include All CCW System Applicable Components CR 99-1568 . Criteria for Declaring Relief Valve Test Failure Not in Accordance With Code CR 99-1592 Manual Valve Position on not Testing on Quarterly Basis

' CR 99-1634 ' . 32 Manual Valves not Tested on Quarterly Basis CR 99-1659 Differing Opinion on " inactive" Valve Position in IST Program Surveillance Procedures '

IT-3 Low Head Safety injection Pumps and Valves (Quarterly) Unit 1, Revision 34, 3/24/99 )

' IT-3A . RHR Pump and Valve Tests in DHR Mode (Cold Shutdown), Revision 8,5/30/97 J IT-3B LHSI Valve Exercise Test in Cold Shutdonn Unit 1, Revision 4,4/19/99 iT-3D RHR Valve Exercise Test for Operations or Shutdown, Revision 1,4/24/98 L

IT-7A- P-32A Service Water Pump (Quarterly), Revision 2,4/24/98 i IT-7B P-32B Service Water Pump (Quarterly), Revision 2,4/24/98 IT-7C . P-32C Service Water Pump (Quarterly), Revision 2,4/24/98 i IT-7D P-32D Service Water Pump (Quarterly), Revision 2,4/24/98 IT-7E ' P-32E Service Water Pump (Quarterly), Revision 2,4/24/98 IT-7F - P-32F Service Water Pump (Quarterly), Revision 2,4/24/98 IT-7G Service Water Valves (Quarterly), Revision 0, 9/19/97 IT-13 Component Cooling Water Pumps and Valves (Quarterly) Unit 2, Revision 19, 2/12/99 L IT-13A CC Pumps and Valves While Aligned for RHR Operation (Cold Shutdown), Revision 2, 12/1/98'

IT-40 Safety injection Valves (Quarterly), Revision 34,6/1/98 IT-65 Containment isolation Valves (Quarterly) Unit 2, Revision 25,1/25/99 iT-72 Service Water Valves (Quarterly), Revision 8, 8/5/98 iT-255 Chemical and Volume Control and Component Cooling System Valves (Cold Shutdown), Revision 15,5/28/99 IT-390 Safety injection Valves (Annual), Revision 3,1/29/96 IT-605 Radwaste Component Cooling Water Supply and Retu.n Valves (Refueling), Revision 5, 5/7/99 MI5.4.1 Relief, Safety and Safety Relief Valve Testing-General, Revision 10,4/29/98 Miscellaneous Documents PBM 95-0520 ~ Declassification of SW Ring Header isolation Valve Motors SW-2869-M,2870-M, 2890-M, 2891-M, Revision 1,8/16/95

' NPM 98-0961 - GL 84-10 MOV Program Self-Assessment on Limitorque Technical Update 98-01 Evaluation,8/5/98

.VPNPD-96-097 Response to NRC Generic Letter 96-05,11/18/96 NPL 97-0090 Response to NRC Generic Letter 96-05,3/17/97 NPL 99-0230 Inservice Testing Propam Improvement Project,4/19/99 j

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