IR 05000282/1993012
| ML20058F326 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/01/1993 |
| From: | Gainty C, Jeffrey Jacobson, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058F293 | List: |
| References | |
| 50-282-93-12, 50-306-93-12, GL-89-10, NUDOCS 9312080070 | |
| Download: ML20058F326 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION Ill Reports No. 50-282/93012(DRS); No. 50-306/93012(DRS)
Docket Nos. 50-282; 50-306 Licenses No. DPR-42; No. OPR-60 Licensee:
Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 facility Name:
Prairie Island Nuclear Generating Station Units 1 and 2 Inspection At: Welch, MN 55089 Inspection Conducted: September 27 through November 15, 1993 Inspectors:
-
w L&
-g.n
/7 - / - 5 J
's C, f. Gainty
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Date y
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</-95 a
/3.~T. k
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i NRCConsditant:
M. R.- Holbrook, Idaho National Engineering Laboratory (INEL)
Approved By':
[M
/ L ' 'i 3 E ' da<'obson, Chief Date i
' G aterials & Processes Section Inspection Summary inspection conducted September 27 through November 15. 1993 (Reports No.
50-282/93012fDRS): No. 50-306/93012(DRS))
Areas _ inspected: Announced routine safety inspection of the licensee's implementation of commitments to Generic Letter (GL)' 89-10, " Safety-Related Motor-0perated Valve (MOV)-Testing and Surveillance" (2515/109).
Results:_ The licensee has developed and imple'mented a program which is generally consistent with the guidance of GL 89-10.
A satisfactory amount of program testing had been completed as of the date of the inspection; however, there was insufficient progress-in the program to justify certain elements.
One violation was identified regarding corrective actions (Section 2.3).
A future inspection will be necessary in order to close GL 89-10 for Prairie Island and to evaluate the three inspection followup items identified in this report (Sections 2.2.2 and 2.7 2).
9312000070 931202 PDR ADOCK 05000282 O
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Inspection Summary
The licensee demonstrated strengths in the following areas:
o Considerable progress was noted in the MOV program since the previous -
inspection in November 1991.
o Personnel involved in the program were dedicated and knowledgeable.
The licensee demonstrated weaknesses in the following areas:
o Technical evaluations sometimes failed to consider the impact of new information on operability of MOVs.
o Errors and inconsistencies were noted in test control and document control.
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TABLE OF CONTENTS i
t Pace'
I 1.0 Persons Contacted.............................................
2.0 Generic Letter 89-10 Program Implementation..................
l 2.1 Selected M0Vs...........................................
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2.2 Design Basis Reviews....................................
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2.3 MOV Sizing and Switch Settings..........................
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2.4 Design Basis Capability.................................
2.5 Pe ri od i c Ve ri fi cat i on...................................
l 2.6 Schedule................................................
2.7 Associated Reviews....................
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i 3.0 L i cen s ee Sel f-As s e s sme n t......................................
j 4.0 Inspection Followup Items.....................................
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5.0 Exit Meeting...................................................
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DETAILS
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1.0 Persons Contacted i
Northern States Power Company (NSP1
- E. Watzl, Site General Manager
+*K.. Albrecht, General Superintendent, Engineering
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- D. Baxa, MOV Engineer
- M. Blaskowski, Electrical Engineer
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- B. Johnson, Electrical Engineer
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- J. Maki, Superintendent, Electrical Systems
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- J. Mcdonald, Superintendent, Site Quality Assurance l
+*G. Miller, Superintendent, Technical Support
+*H. Wadley, Plant Manager
+*R. Wirkkala, MOV Engineer U.-S. Nuclear Regulatory Commission (NRCl
- M. Dapas, Senior Resident inspector j
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- Denotes those persons attending the exit meeting on October 8, 1993.
+ Denotes those persons participating in the telephone conference exit meeting on November 15, 1993.
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2.0 Generic letter 89-10 Program Imolementation-l
2.1 Selected MOVs l
The scope of the GL 39-10 program at Prairie. Island included 205 MOVs, of which approximately 74 MOVs would be tested under. differential pressure (dp)
l conditions. At the time of the inspection, 41 dp tests were completed. The 12 MOVs identified in Enclosure 3 were selected for detailed review on the basis of
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safety significance and test results.
The details of the review are discussed i
in the following sections.
2.2 Desian Basis Reviews 2.2.1 Differential Pressure and Flow Reauirements'
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The inspectors' reviewed the licensee's method for determining the design. basis maximum expected differential pressure (dp) for the selected MOVs, and found it to be acceptable. Since the Part 1 inspection, the licensee' reviewed the USAR, emergency operating procedures, normal-and abnormal procedures, and other plant documents to ensure that the most conservative' design basis dp was used for each MOV.
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2.2.2 Reduced Voltaae CaoabilitY
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The inspectors concluded that engineering evaluations to assess two recent MOV
manufacturer issues did not completely address operability or effect on plant
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operation, as discussed below:
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The licensee became aware of a manufacturer's _ technical bulletin, which stated
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that motor brakes may not release at less than 90% of nameplate voltage. Since i
degraded motor terminal voltage for most MOVs was calculated to be between 80%
and 88% of nameplate, a thorough assessment of the potential effect 'on MOV operability was appropriate.
To address this issue, the licensee performed limited bench testing of three motors and closed the issue without contacting the
manufacturer or addressing the applicability of the test results_to the remaining 34 MOVs with motor brakes. In response to the inspectors' concerns, the licensee contacted the manufacturer and other utilities and prepared a more complete
corrective action plan and operability assessment.
The planned actions to.
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resolve the motor brake issue and modifications to remove all motor brakes will be evaluated in a future inspection as an inspection followup item (50-282/93012-
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01; 50-306/93012-01(DRS)).
i The preliminary assessment of Limitorque's May 13,1993, Part 21 report regarding
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high ambient temperature effects on MOV motor output torque assumed that therc
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would be no net loss of torque and assigned a date of March 1994 for completion.
l The licensee assumed that torque output. losses due to high temperature would be
offset by gains due to Limitorque's allowance to use an application factor of 1.0
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j in certain instances instead of the 0.9 originally used.
This assumption was questioned by the inspectors and found to be invalid.
In response to the inspectors' concerns, the licensee performed calculations for some of the most
affected MOVs and showed that the worst case torque reduction would be 4.7%.
These MOVs were shown to have sufficient margin to compensate for the loss in
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torque; however, a more thorough initial review should have been done to preclude operability concerns.
The licensee will request additional information from
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Limitorque in order to evaluate some MOV motors and detailed calculations will
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be performed for each MOV affected by the Part 21.
This is considered an
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inspection followup item that will be evaluated in a future inspection (50-
282/93012-02; 50-306/93012-02(DRS)).
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The licensee's calculations for the degraded voltage capability of. the selected i
MOVs were found to be acceptable. However, prompt attention to the two issues L
discussed above is neces>ary to ensure that calculations are based on actual
conditions.
'i 2.3 MOV Sizina and Switch Settinas j
The inspectors reviewed procedure H5, " Motor Operated Valve Program," Revision 4, which included the licensee's methodology for determination of thrust and
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torque requirements. The gate valve thrust calculation typically assumed a valve
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factor of 0.5, and provided margin to account for load sensitive behavior (10%)
and stem lubrication degradation (5%). The assumed stem friction coefficient was 0.15 for the closing direction and 0.20 for the opening direction.
Individual.
thrust calculations were revised to reflect the results of dynamic test results.
The licensee's method was considered to be acceptable; however, the assumptions
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applied to those valves that will not be dynamically tested, must be justified before the scheduled completion date of the GL 89-10 program.
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The licensee had recently determined that a valve factor of 0.75 would be
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required for the Powell gate valves to recognize the higher valve factors seen during dp testing.
The thrust calculations for dp tested and non-dp tested Powell valves were revised to reflect the higher thrust requirements; however,
there was no objective evidence that operability. of the non-dp' tested Powell valves (MV32387, 32132, 32135, 32138, 32141, 32147, 32150, 32153, 32156) had been addressed. In order to properly assess the operability of the MOVs at the higher thrust requirements, both the motor capability and the current torque. switch
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settings must be considered.
The valves are normally open fan coil unit isolation valves, which have two safety functions: (1) to remain open to supply cooling water for containment heat removal, and (2) to close in case of a leak
inside containment.
The closing function is required to be initiated.upon
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operator identification of the condition and is not an automatic function. The i
licensee determined by calculations that the valves could not perform the closing function at design basis dp, assuming a 0.75 valve factor; however, modifications
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were planned to increase the motor and actuator sizes in the upcoming outages.
In response to the inspectors' concerns, the licensee completed an Issue i
Re. solution form, and documented the basis for the operability determination in a safety evaluation. The inspectors briefly reviewed the licensee's operability
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determination and took no exceptions to it. The failure on the licensee's part j
to promptly address the potential condition adverse to quality of several non-dp i
tested Powell MOVs is considered to be a violation of Criterion XVI, " Corrective l
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Action," of 10 CfR Part 50, Appendix B (50-282/93012-03; 50-306/93012-03(DRS)).
i The test data indicated that the use of the 0.15 stem friction coeffic ent for the closing direction was not always justified.
The licensee was prompt in revising thrust calculations for the specific valve when higher than assumed
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values were identified.
However, appropriate values must also be used when
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determining actuator capability for MOVs that can not be dynamically tested. In l
addition, several torque values used to determine the stem friction coefficient l
were based on generic spring pack curves, without consideration of the
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uncertainty of those curves. Uncertainties must be considered when establishinc i
factors to be applied to MOVs not dynamically tested.
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The licensee planned to test some MOVs in their as-found condition to snow that
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MOV degradation over the maintenance period (18 months) would not inhibit MOV
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operability.
The use of a new stem lubricant (Moly 101) was begun in February t
1992. Evaluation of as-found test results at the end of the maintenance interval j
should help to justify the program's 5% allowance for degradation.
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The inspectors were concerned that the calculation summary sheet for MOVs did not
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directly compare opening thrust requirements with the actuator thrust available.
This omission could prevent detection of undersize actuators. The licensee had l
included conservatisms in the thrust calculation which were intended to make the
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closing thrust setting always greater than either the opening or closir:9 thrust i
requirements.
However, these assumptions did not consider differences in
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operator efficiency between opening and closing.
The inspectors reviewed the
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- results of several calculations and found no operability problems. The licensee i
agreed to revise their calculations and to ensure that the minimum thrust
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requirements.for the open direction are clearly identified in the future.
l Minimum thrust requirements were adjusted to account for diagnostic equipment inaccuracy and torque switch repeatability. However, no allowance was provided ~
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for torque switch repeatability when the measured maximum thrust was compared to the thrust-related structural limits.
The licensee has agreed to include I
consideration of torque switch repeatability until an alternative position can
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2.4 Desian Basis Capability i
The inspectors reviewed completed static and dp test packages to verify the i
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. adequacy of the methods used to demonstrate MOV' capability. At the time of the-i inspection, 41 MOVs had been dp tested of which 12 were selected for detailed i
review.
The review resulted in gate valve factors of 0.47 to 0.93 and globe valve frctors of 1.08 to 1.14.
Dynamic stem friction coefficients as high as
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0.18 were observed and load sensitive behavior ranged up to approximately 21%.
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B; sed on this review, the licensee's programmatic assumptions for valve factor, l
stem friction coefficient, and load sensitive behavior do not appear
conservative, fio operability concerns were identified, however, assumptions applied to those MOVs that are not dp tested must be supported by actual test
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data.
The licensee will be expected to reevaluate and justify their use of
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assumptions as the program progresses.
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Accentance Criteria for MOV Testina The licensee's program had made considerable progress in the area of test evaluations and procedure D70.1, " Motor Operated Valve Testing Using V0TES,"
Rc-lsion 2, had recently been revised.
However, some problems were noted as discussed below:
(1)
-The method used for post-test data reconciliation did not include-an.
adjustment to the force required to overcome stem rejection, which was necessary to account for the difference between test conditions and design basis conditions.
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(2)
Post-test data reconciliation did not address inaccuracy associated with the line pressure and differential pressure measured during testing.
(3)
The comparison of extrapolated required thrust with the control switch.
setting, which appeared in the previous revision, was inadvertently omitted from the latest revision of the procedure.
(4)
Paximum measured torque values were not compared with the actuator's-
torque limit.
(5)
There were no precautions to alert the MOV coordinator of values outside the calibration range in the close direction.
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se licensee confirmed that no improper use of data resulted from the above i
discrepancies and agreed to revise the procedure to make the necessary j
corrections.
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During review of the test package for MOV32027, it was noted that the closing l
thrust margin was only approximately 6%. This margin was not adequate to account
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for torque switch repeatability, which was 10% for this valve's torque switch i
setting per Limitorque Maintenance Update 92-2.
In response to the inspectors'
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questions, the licensee performed an operability assessment that was acceptable, l
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margin to allow for degradation and torque switch repeatability, i
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2.4.2 MOV Test Control
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During review of the static and dynamic test packages, the inspectors concluded
that testing was generally performed properly; however, several examples of
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l weaknesses in the documentation and performance of test activities.were j
identified, as discussed below MOV32093 - Some.icceptance criteria steps were initialed, but the l
associated "yes/no" answers wcre not circled to indicate acceptance
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of the test results. Also, calibration steps :581 were not required
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to be completed were initialed as being performed instead of beina
marked *NA."
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MOV32129 -
Steps. were initialed that direcie: the technician to l
compare the maximum measured thrust to the trnst limits listed in j
Table 1,
however, there were no limits - e-:sred in the table.
i Licensee personnel indicated that the tecr-ician was verbally i
directed to use the limits provided by a thrus: :alculation sheet in lieu of t he table.
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.l MOV323SE The Delta P Test Evaluation Sheet. Table 4 containec a math error in the extrapolation of test tr.st to design basis j
thrust.
This resulted in a 234 lbf error, L: did not affect tne j
0;>erability determination for the valve.
j The inspectors did not identify any specific concerr.s associated with the above
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findings, but expressed concern that test control wennesses could detract from the MOV program effectiveness.
2.5 Periodic Verification The licensee's program document and schedule for futuri activities indicated that
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periodic verification for valves that had been dp tested would include continued.
dp testing, pending additional industry guidance. Al' program MOVs would receive static testing; at a minimum, and the frequenc;. si this. testing met the recommendations of.the GL This approach was co sidered to be acceptable; however, any industry guidance that may be used to -educe the scope of testing must be justified.
2.6 Schedule j
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The licensee had developed an aggressive schedule to dynamically test 33 MOVs and statically test 121 MOVs between the. time of the inspection and June 1994. The
inspectors did not identify any specific obstacle to meeting this schedule; i
however, the licensee discussed the possibility of a schedule extension.
The
licensee ' was informed that the justification for their methodology will be
expected to be in place by 1994 and that any request fnr schedule extension -
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should be for testing 'only.
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In a letter dated December 28, 1989, the licensee committed to implement the
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recommendations of GL 89-10 within the schedule proposed by the GL, including the
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recommendation to perform dp testing where practicable.
However, during the
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inspection, the licensee indicated that certain MOVs would not be dp tested if
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it was determined that they would not provide meaningful-data.
The inspectors
stated that any changes to the conmitments must be submitted in writing.
The
licensee indicated that they would revise the commitment on the docket.
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l 2.7 Associated Reviews l
2.7.1 Diagnostics i
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The licensee used the Valve Operational Test Equi: ment System (VOTES) to test i
MOVs under both static and dynamic conditions.
Recently, they ha: started l
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cal:Drating spring packs in the shop prior to installation in the plart so that.
l torcue values could be determined during testir.; using the linear variable
dif ferential transformer (LVDT) attachment.
This allowed collectie of data-j during testing such that stem friction f actors cald be better quar-ified ?t different points of interest, such as flow cut-of.
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i Personnel =ing tne diagnostic equipment appeared.; be knowledgeable anc well l
trained, as evidenced by accurately marked traces and proper uss of the equipment.
l 2.7.2 Pressure Locking and Thermal Bindina lhe licensee evaluated the susceptibility of 122 ga:t valves to pressure locking and thermal binding.
The evaluation disclosed tha: 12 valves were suceptible to tressure locking and 8 valves were susceptib's to thermal bind g.
The licensee responded to these problems as follows:
o Four valves (RHR to vessel injection) corsidered susceptible to both pressure locking and thermal binding were charged from normally :losed to normally open, thereby avoiding the problem.
The license indicated that PRA evaluations confirmed the actions to be appropriate.
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Eight valves (RHR to Si and RHR to CSP) consicered susceptible to pressure j
locking were not modified.
The licensee reviewed MOV capability and indicated that the valves could open against aximum bonnet pressure with a 100% margin of safety, o
Four valves (fW to SG isolation) susceptit's to thermal binc ng, were modified by changing to an SB-3 actuator wi.. compensating spr'ng pack,
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i which the licensee feels will ameliorate the effects of inertia on'
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closing.
I Ten MOVs (RHR to loop B, Loop A hotleg RHR suction, and loop B hotleg RHR
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suction) are potentially susceptible to pressure locking during normal shutdown I
to cold shutdown.
The licensee indicated that cooldown and depressurization i
rates are slow enough so that bonnet depressurization occurs before the valves are needed.
The inspectors recommended that the evaluation be reconsidered,
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because valve seat.s which are designed to be leak-tight should not be relied upon i
to leak at a prescribed rate.
'i The inspectors noted that eight sump B MOVs were classified as not susceptible to either pressure locking or thermal binding.
However, the licensee was i
provided with two scenarios by which the inspectors felt the valves might' be
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susceptible to pressure locking. The licensee had not considered these scenarios
but committed to review them and to take appropriate action.
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The licensee's actions regarding pressure locking is considered to be an f
inspection followup item that will be evaluated in a futura inspection (50-
282/93012-04(DRS); 50-306/93012-04(DRS)).
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.i 2.7.3 Maintenance I,
The inspectors observed portions of modification arid VOTES testing of PJV32389, i
fan coil unit cooling water isol ation valve.
Tne rodification involved
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increasing the actuator and motor size to improve output capabilit;..
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maintenance and testing were performed properly; hooe.er, Ine concern was'noted
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regarding document control. The thrust calculation used tc establish tre target thrust window had not been updated to reflect the revised, reduced voltage f actor-that was calculated based upon the modification. Ir, inis particular case using
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the correct reduced voltage f actor would have resultec in a larger thrust window, i
and was not a problem. However, the control of documents and the use of correct
inputs when performing calculations is essential tc ersure effectiveness of the j
program.
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2.7.4 Walkdown
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.I The inspectors performed a general inspection of the plant as well as a :etailed inspection of approximately 20 MOVs, including most of those listed in Enclosure
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Housekeeping and MOV conditions were very good.
3.0 Licensee Self Assessment
The inspectors considered the licensee's Internal Audit Reports and Surveillance
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Reports regarding MOV issues to be acceptable.
Although the reports did not
disclose any of the technical findings identified by tne tiRC inspectors useful
recommendations were provided by the reports.
Ir addition, the 'icensee j
evaluated their program using information contained % an fiRC internal merorandum
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" Guidance for Inspection of Programs in Response to Gereric Letter 89-10. dated
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April 30, 1993, and identified several areas in whid to improve the ;rogram.
Most of these areas had been improved prior to the ins:ection.
In general, self assessment was considered to be effective.
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4.0 Inspection followup items
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.i Inspection followup items are items that have been discussed with the licensee,
which will be reviewed further by the inspectors and involve some action on the i
part of the licensee.
Three inspection followup items were identified during i
this inspection and are discussed in Sections 2.2.2 and 2.7.2 of the inspection report.
i 5.0 Exit Meeting i
i The inspectors met with licensee. representatives (denoted in Section 1.0) at the l
Prairie Island Huclear Generating Station at the conclusion of the inspection on j
October 8, 1993. A. supplemental exit was conducted by telephone conference on
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November 15, 1993.
The inspectors summarized the purpose and scope of the
inspection and the findings.
The inspectors informed the licensee of.the l
violation and three inspection followup items identified during this inspection.
r The inspectors also discussed the likely informational content of the inspection l
report with regard to documents reviewed by the inspectors during the inspection.
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i PRAIRIE ISLAND GATE & GLOBE VALVE DATA
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r Diagnostics: VOTES System with VTC for Torque Measurements
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I VALVE VALVE S!ZE int DVNAMIC STIM I C Alr*
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CONDmONS VAIVE MtlCTION SENSITIVI:
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MANUFACTURER FAC105t*
COEn1CIENT llEllAVIOR
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i h1V-32116 6* Aloyco 278 psid (Clase)
Unknown (Close)
0.01 (Dynamic)
-5.9 %
f 300# Double > Disk 278 psid (Open)
0 OS (Open)
0.01 (Static)
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Wedge Gate MW32380 5" Powc!!
100 psid (Close)
0 68 (Che)
0.17 (Dynamic)
-13.9 %
150# Solid-Wedge 100 psid (Open)
044 (Open)
0.19 (Statie)
l Gate
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MV 32388 E' powell 103 psid (Close)
0 49 (Closed)
0.14 (Dynamic)
-2.7 %
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150# SobJ Wedge 103 psid (Open)
0 53 (open)
015 (Static)
Gate I
i M VO2025 4' Vehn 115 psid (Closc)
Unknown Udnown (Dynamic)
Unknown
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150# Flcx-Wedge 115 p,id (O;en)
0 09 (Static)
Gate
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t MVG2027 4" Vclan 101 psid (Close)
0 56 (Close)
0 0) (Dynamie)
8.7%
j 150 FiaWedge 101 psid (Open)
010 (Opera 0 i2 (Static)
Gatc
MV 32073 3" Velan 2150 paid (Close)
0 59 (Close)
0 O$ (Dynamic)
10 4 %
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1500t Flex Wedge 2150 psid (Open)
0 $2 (Operi.
0 06 (Sutic)
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Gate l
MVG2177 3' Velan 2200 psid (Close)
04 (Close)
012 (Dynamic)
10.1 % -
1500* Fica Wedge 2200 psid (Open)
0 66 (Opera O G4 (Static)
C3tC I
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MV 32008 2 Velar.
2180 psid (Che)
1 CS (Clase:
0 ;$ (Dynamic)
21 E
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-t 1500s GLhe 21E0 psiJ (Open)
SA (Open)
1 013 (Stitic)
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MVO2203 2* Vclan 2180 paid (Close)
1 3 4 (Clow)
0 D (Dynamic)
2S%
I 1500* GkJx 2180 psid (Open)
N/ A (Open)
012 (Static)
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i MVO?O93 10' Pow e*J E6 psid (Cbc)
0 O (Che)
0 3 (Dynamic)
-7.45
1502 SnLJ WeJge 86 psid (Open)
O C (Openi D:6 (Static)
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Gate
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M V O2&)4 10" Poac!!
89 psid (Close)
0 93 (Close)
016 (Dynamic)
11.4 %
150# Solid-Wedge 89 psid (Open)
06S (O;wn)
0 D (Static)
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M V-32129 10* Powell 91 psid (Close)
0 63 (Close)
0."40 (Dynamic)
6.6%
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150# Sohd-Wedge 91 psid (Open)
0.62 (open)
O ;6 (Sutic)
l Gate
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The dynamic valve factors listed were calculated by the Ikensee using an on ~,ce dbmeter.
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A negative number indantes that the thrust obscrsed at CST dunng the dyrun.se test was greater than the thrust observed
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at CST during the static tes:
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