IR 05000324/1990032
| ML20058B120 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/18/1990 |
| From: | Belisle G, Scott Sparks, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058B118 | List: |
| References | |
| 50-324-90-32, 50-325-90-32, NUDOCS 9010290407 | |
| Download: ML20058B120 (13) | |
Text
{{#Wiki_filter:+ i. - pate4,D UNITED ST ATES , . o NUCLEAR. REGULATORY COMMISSION f ~ -[ RE0lON ll ' p, 101 MARIETTA STREET, N.W.
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ATLANT A, GEORGI A 30323
.: -% / ' ....+ . t-Report Nos.: 50-325/90-32 and 50-324/90-32 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 v Docket Nos.: 50-325 and 50-324 License Nos.:- DPR-71 and DPR-62-Facility Name: Brunswick 1 and 2 Inspection Conducted: Au ust 6-10 and 20-24, 1990 Inspectors: Pa /D/Id/9c
S. Sparks Date 5fgned - j , //- YMW _f0l/SY90 H.-Whitener Date 5fgned Approved by: [h FR[7 /4If[#d G. - A. Eelisle, Chitf ' Date Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope: " This. routine announced inspection was conductec in: the areas of-inservice l testing, reverse. pressurization of containment is lation valves, and follow up- . .' 'on: previous. inspection findings.
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- 'Results:
. . - < . Pressure : isolation valve -(PIV) leak' rate surveillance testing had been
- , performed in accordance with the inservice testing (IST) program requirements y.,
' Paragraph.2.
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- A"weaknesslwas identified in that'the PIV leak' rate test procedures for check
- e , valves E11-F050A and:'8-and E21-F006A and B do not establish the' alert leak-rate limit
- i'.e., that' limit which.1f exceeded, requires an accelerated test
. g, - ' unediate valve, repair,sParagraph' 2.
Efrequency 3 L AJquestioi, q., : identified relating to the' licensee's application of relief J
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- .reques t :VR-27.
Further NRC -review-is necessary to determine if VR-27 grants .; ' i .%, reliefL from: IWV13421-34251and - 3427(b) requirements. for ~ PIVs as well as MM containmentjisolation valves (CIVs), Paragraph ~ 2.
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Reverse l'ocal $ leak; rat'e testing for 35 of 51 CIVs reviewed was found-to be = acceptable.' Sixteen valves require ~further NRC evaluation,cParagraph 3.' , & ~ A: weakness was---identified in the area of trending motor operated. valve (M0V)' n, performance, Paragraph 4.- ., , - In.the' areas : inspected, violations or deviations were not identified.
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, . e . REPORT DETAILS . 1.
Persons Contacted Licensee Employees l
- K. Core, Senior Specialist, Control and Administration J. Crider, Senior Specialist, ISI/IST, Technical Support T. Dao, Performance Engineer T. Groblewski, Supervisor, Component Engineering
- J. Harness, General Manager
0. Jeans Senior. Specialist, Operations T. King, Engineering Technician 1 n
- J. Leviner, _ Manager, Engineering Projects, Technical Support
- W. Link, Senior-Specialist, Regulatory Compliance H. Mayes, Senior Specialist, Technical Support and Component Engineering P. Musser, Manager, Maintenance Staff
- R. Starkey, Manager, Brunswick Nuclear Project
- L. Wheatley, Supervisor, ISI/IST, Technical Support NRC' Resident Inspectors
'
- R.- Prevatte. Senior Resident Inspector-W.-; Levis, Resident Inspector D. Nelson, Resident' Inspector Aconymns = and. initialisms _ used throughout.this report are defined in 'the last paragraph.
2." PIVInserviceandSurveillanceTesting(61701,73756) 'The purpose: of inspection activities in the area of PIVs:was to verify that the licensee had developed and implemented procedures and controls to ' leak rate test.PIVs consistent with..IST requirements.
' PIVs are defined as' two' normally closed v_alves in series that isolate the.
l - RCS from an attached low pressure system.
PIVs-~are located at, all - . RCS/ low pressure' system interfaces.
Event V'PIVs are defined.as two check - % valves in' series at RCS/ low pressure system interfaces whose failure may; j ' result inla LOCA that by-passes: containment.- Event V refers ' to the . y* . scenario described,in WASH-1400,. Reactor Safety Study. (The licenseeihas: q a
- 41dentified 12 Pivs in their program.
' > > For plants licensed since 1979,_TSs identify the PIVs and associated. test , g" ' F., requirements !In the case of. Brunswick,.ltcensed prior toi1979,: the TSs . do.not address-PIVs.
Consequently, the inspector reviewed the:PIV test . program; to the requirements of ASME Boiler and. Pressure Vessel ' Code,. Section f XI', Subsection IWV, Inservice' Testing: of Valves in Nuclear ~ + l
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- Power Plants,1980 Edition, as modified by procedure ENP-17, Pump and Valve Inservice Testing (IST), and the NRR Staff SER dated January 4, 1990 (second IST 10 year intervel).
The licensee provided the NRC with a description of the PIV test program in a letter (NLS-87-125) dated June 11, 1987.
This description is consistent with the approved IST program for the second 10 year interval.
Twelve valves were identified as PIVs for the following systems: RHR loop suction lines, RHR emergency core cooling injection lines, RHR head spray ' lines, and CS emergency core cooling injection lines.
PIV leak rate test procedures were reviewed to verify that check valves i were identified and leak rate tested in accordance with IST requirements.
Procedures developed by the licensee and reviewed by the inspector during this inspection included: PT-20.7.1, Revision 4, E11-F050A Leak Test PT-20.7.2, Revision 4. E11-F050B Leak Test PT-20.7.3, Revision 5, E21-F006A Leak Test PT-20.7.4, Revision 5. E21-F006B Leak Test Plant system drawings and penetration isometric drawings were reviewed in conjunction with' the procedure review !.o verify that adequate test instructions and leakage collection methods were specified.
Based on the review of the licensee's requirements,. test procedures, test controls, and ' test results for. the last three RFOs on each unit., the ' inspector concluded the following:. Pressure isolation check valves were correctly identified ~in the test procedures.
< g With the exception of the procedural _ weakness discussed below, adeq'uate. leak rate test procedures lwere developed and implemented.. , PIV leak rate tests were performed. by acceptable methods at the , . required frequency.- ' ,- -PIV test data was directly related to the system functional pressure, , i 1000 psi, in accordance with.IWV-3423.- h , s' ' ' Where crepairs _ were made,. post-mainteance leak. rate tests were . performed.
, . % .Four of the112Evalves (check. valves E11-F050A and B and E21-F006A'and B)- ' , interface directly'with the RCS; and function only-as PIVs.- These valves
, lare' tested;at-full system differential pressure using water as the-test' y , ' medium.1 "' ' f[ > b e 's- & if f i ' ,
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' , One weakness was identified relating to the above four valves during the review of PlV testing.
The test procedures do not require that the alert leak rate be established.
IWV 3427(b) requires that-for valves six inches and larger, the alert limit leak rates be determined based on previous test data.
If a measured leak rate is less than the maximum allowable leakage but exceeds the alert limit, the valve must be repaired immediately or tested at an accelerated frequency.
The licensee stated that since the leak rate test is performed in a RF0, it is the practice to repair any valve with significant leakage prior to returning it to service.
This avoids entering an accelerated test frequency condition.
From a review of leak rate test results from 1985 through 1989, the inspector' determined that in all cases where a leak rate exceeded the , alert limit, the valve was repaired prior to return to service.
The inspector concluded that the licensee had met this requirement of IWV 3427(b) by repairing a valve immediately when leakage was identified.
Failure to calculate the alert limit and document that, if exceeded, repair er accelerated testing was performed was identified as a weakness in the procedure.
The inspector was advised that an action item was written to revise the procedures to document that the requirements of IWV 3427(b) for-the check valves E11-F050A and B and E21-F006A and B are met.
The remainini eight PlVs are motor operated gate valves.
These. valves have dual functions as pressure isolation valves and containment isolation valves.
l In relief request VR-27, the licensee' had asked for relief from IWV leak . rate test requirements for all Category A valves and proposed testing these. valves to the requirements of 10 CFR 50, Appendix J.
All Category A ' valves would-include PlVs as well as CIVs.
In the SER issued January 4,1990, it is-clear that relief from IWV 3421-3425 and 3427(b) was granted for the containment isolation function
~ of Category A valves.
However, it is not clear that the relief: extended to. thespressure isolation function of Category A valves.
The licensee believed -that relief from IWV 3421-3425 and 3427(b)' had , been granted for both the -pressure isolation and ~ containment isolation ,
- functions through ' relief request VR-27.-
Consequently, for MOVs having .dualf safetycfunctionslas PIVs-and' CIVs.. compensation for a low pressure ' i air test:on' the valves which have a water. service functionL(PIVs)'and extrapolation of test results to system functional pressure in'accordance with,I_WV 3423(e) has. not been. performed.
Also, test data has not been ' ' W,, trended..in accordance with IWV-342.7(b).
a-s, h' ' The ; inspector acknowledged thdt the nature: of the' relief granted for ~ ' < relief request VR-27 is notLabsolutely clear.
The' licensee's; position is ' < i . a?possible interpretation. -The inspector informed' the licensee that < clarification of relief request VR-27 would be pursued within the NRC and Lthe? licensee would be_ advised:if: any -prograr changes were required once. g , , thistreview is completed.
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' A review of test results for four of the eight MOVs from 1985-1989 showed ' that, in all cases, where a leakage of any significance was identified, repairs were made prior to returning the valve to service.
Within this area, no violations or deviations were identified.
3.
Reverse Testing of Containment Isolation Valves (61720) '
Appendix J to 10 CFR 50, Paragraph III.C.1 allows reverse local leak rate ' tests under certain conditions as follows: Type C tests shall be performed by local pressurization.
The ' pressure shall be applied in the same direction as that when the valve would be, required to perform its safety function (accident direction), unless it can be determined that the results from the tests for a pressure applied in a different direction (reverse direction) will provide equivalent or more conservative results.
At NRC staff request, the licensee provided the NRC with information reflecting the current plant testing configurations in letter NLS-90-013 dated January - 25, 1990.
This submittal was evaluated to-determine if reverse LLRTs performed by the licensee were conservative.
Information used in this evaluation included the licensee's submittal , (NL' 90-013), plant system drawings, valve design drawings, and t disc,sions with licensee personnel.
Criteria used to determine if a , reve;se test is as conservative as a test where pressure is applied in the accident direction included the following: l1.- Will test pressure applied in-the reverse direction challenge all_ potential leakage paths. which would be challenged when pressure is applied in-the accident' direction?. , , 2.
Will test pressure applied in the reverse direction tend to open' , -the valve while pressure applied in the accident direction will tend to.-lose the valve tighter? l 3.
'Will -leakage through any untested _ leak path be confined to the containment when pressure is applied from the ' accident direction?! The inspector determined that 35 of the 51' valves tested in a reverse- ! direction-(both Units) are conservative tests.
No further review of these W valves was necessary.
- s Reverse test'ng 'on.the remaining 16 valves 'was considered not; as
' , conservative as ' testing in the accident direction.
For these_ valves', ,
additional; review is necessary to determine Lif the reverse' test is tacceptableFon some other idefined basis.
.The fact-that ~ the test. is I non-conservative does notipreclude acceptance of the. test method if'it' fcanLbe shown that'the risk is acceptably low.
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The inspector informed licensee management that the Region review found certain reverse tests non-conservative. The Region evaluation and recommendations will be provided to NRR for their consideration and the licensee will be advised by NRR of any further information or action required.
i Within this area, no violations or deviations were identified.
4.
Bulletin followup (92701) -, a.
(Closed) TI 2515/73, 325, 324/85-80-03, Motor Operated Valve Common Mode failure During Plant Transient; Due to Improper Switch Settings The purpose of this bulletin was to require licensees to develop and implement a testing program to ensure that switch settings for high - pressure coolant injection and emergency feedwater systems' MOVs required to be tested in accordance with 10 CFR 50.55a(g), are ' properly set, selected, and maintained.
The inspectors reviewed all M0V failures-(Bulletin and non-Bulletin valves) which had occurred within the past year, and found the following: Five valves had failed due to dirty torque switch or limit - , ' switch contacts: 1-E11-F011A,.2-SW-V15, 2-E21-F0158, 2-E11-F016A, 2-E51-F062.
The licensee's root cause evaluation concluded that abrasive cleaning contributed to oxidation of the i contacts.
Site procedures have been revised to use the appropriate contact cleaner.
L Three valves have failed due to the misadjustment or misalignment' - -of theclimit switches: 1-SW-V16, 1-SW-V20,.2-E11-F004B.
Site
-procedures have been revised to check switch continuity prior.to , returning-the valve to service, p Two valve failures have been attributed to motor failure: ' - 1-SW-V294,.1-E11-F0248.
The V294 valve motor failed due to moistureLintrusion from a ruptured ' screen wash pump expansion l joint. < The F024B-motor failed due to normal wear and use.
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! - -Valve 2-821-F0328 failed due to contact cleaner being sprayed on the torque switch shaf t' and flushing away lubricant.
, Technicians have been instructed not to spray the torque switch.
with contact cleaner.
" ' Valve 1-E51-F045 failed-due to too'much gasketing material that - was installed under the housing cover'during a previous rebuild.
j The valve was found stuck in the backseat and-had tripped on thermal overload while attempting to open the valve.
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'During periodic testing, valve 2-SW-V18 (a butterfly valve) - would not fully open.
The failure was due to an extruded rubber seat which caused the valve to trip on torque while attempting to open the valve. - _ Valve 2-B21-F016 failed due to improper installation of the handwheel assembly, which allowed the drive sleeve to ride up causing the declutch fork to remain engaged.
, I Butterfly valve 2-SW-V18 failed due to an improperly set torque - switch.
Four valves failed due to tripping on thermal overloads while - being operated during the Unit 2 plant trips of August 16 and 19;.1990.
The RCIC trip and throttle valve 2-E51-V8 tripped on thermal overload due to operating more than 3 cycles within five minutes. The thermal overloads for this valve had recently been resized to preclude exceeding.the motor's duty cycle.
The RHR torus suction isolation valves 2-E11-F004B and 0 tripped on thermal overload apparently due to thermal binding.- The recirculation bypass valve 2-B32-F0328 tripped - on thermal overload.
The licensee's subsequent diagnostic testing did not ' identify any deficiencies.
- -The HPCI turbine stop valve 2-E41-V8 operated in an undesirable manner during the August' 16, 1990 plant trip.
As HPCI was manually initiated, the V8 valve opened, then closed for a short time. and then reopened.
The licensee is still evaluating this behavior, The condensate' booster pump discharge valve 2-C00-V4 recently s
failed'during the August 19, 1990 plant trip' recovery due to the overcurrent trip-setting being adjusted too low.- Review of the above valve failures,-indicated that the.following are currently? included in the ~ licensee's Bulletin.85-03 ; program:- , 1-E51-F045, -2-E51-F062, 2-E51-V8, 2-E41-V8 (abnormal operation).
The licensee's root'cause and corrective actions for these Bulletin valves L as well. as the: other valve ; failures, appeared adequate..NRC - ', . Ins )ection - Report No. 50-325,324/89-06. previously identified a wea(ness in that' monitoring MOV performance throughout plant life was not fonnally? incorporated :into the licensee's-MOV program.
The- , y' ' ' inspectors determined ~ the licensee 'was aware off the above valvei ' failures 7 on1an: individual ~ basis, but still had.notLdeveloped an s i effective ' program t'o1 track' and; trend M0VliperformanceLthroughout'the ~ life of the' plant.
Thefinspector's rev ew concluded this1 area.
continues _to be a weakness in.the' licensee's:MOV program, t L , . [ , j ,, '., ' '! ' ' ' q , iv
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- Generic Letter 89-10, Safety-Related Motor-0perated Valve Testing and Surveillance, dated June 28, 1989 was issued to address all safety-related and position-changeable MOVs, and supersedes the actions ,' prescribed in Bulletin 85-03.
As a result of GL 89-10, the licensee is currently developing provisions to monitor valve performance throughout the life of the plant.
The licensee's GL 89-10 program is currently underway, and as such these programs had not been completed at the - time of the inspection.
GL 89-10 requirements will be revised during subsequent NRC inspections.
Within the areas inspected, no violations or deviations were identified.
5.
Action on Previous Inspection Findings (92701) a.
(Closed)IFI 50-325,324/88-25-02: Implementation of Permanent Piogram for Repetitive Failure Identification The inspectors reviewed the licenst 's activities in this area, which included the implementation of procedure PLP-05, Repetitive Failure Detection Program, Rev. 0, dated 4/1/89.
Previour inspector review of this area indicated the interim program did not recognize failures such as ASCO. solenoids failing to operate.
The purpose of the above i procedure was to formally implement a program to identify, document, evaluate, and track. the resolution of repetitive failures of key , plant equipment.
The inspectors reviewed monthly and -quarterly reports identifying parts having repetitive usage, and discussed the. general.. failure , input into the database.
The current program is dependent on the.
proper. recognition and: input of failures _to identify repetitive failures.
.In particular.- the inspectors: reviewed how MOV failures
are trended, and noted that the five' M0Vs which had failed due to ' dirty contacts within the past year (as discussed ~1n Paragraph 4 of , this ' Inspection Report) were not identified as repetitive failures.
The licensee stated that the program:is currently set = up' to identify multiple failures for unique pieces - of equipment, i.e. multiple failures of the same < valve within a given time frame. _In addition,- .t e licensee tracks usage of certain parts by reviewing -completed h . ork requests.
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Based' on the-inspector's review of M0V. failures, the licensees formal
implementation of M0V' failure tracking and trending continued to be a , weakness.
The licensee stated that the Repetitive Failure Detection Program,:and the GL 89-10 Program for trencing valve performance ' - throughout othe life Lof the plant, would be reviewed-to determine ,, which program would 'be appropriate to' address the; trending of: MOV , ' failures, s g
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(Closed) IFI 50-325,324/89-34-33, followup cn Implementation and Effectiveness of ISI Nuclear Generation Group duidelines in IAP Item D29.
The inspectors reviewed Nuclear Generation Group Manual NGGM 305-07 Inservice Inspection Program, dated July 1990.
The purpose of this document was to establish provisions for the exchange and sharing of information related to inservice inspection and testing between the three CP&L nuclear sites and corporate management. The Program also establishes ongoing corporate responsibility for ISI/IST programmatic improvements.
The Program document requires, at a minimum, that ISI/IST personnel from each site, along with corporate personnel, meet at six month intervals.
Although NGGM 305-07 was not formally issued until July 1990, several counterpart meetings were held prior to this time.
Discussions with licentee IST personnel indicated the I information exchange and lessons learned had been productive with i regard to IST program revisions in response to Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, dated April 3,1989.
Licensee IST personnel were knowledgeable of the j guidelines contained in GL 89-04, and of revisions which would be j
needed-for their current IST Program.
c.
(Closed) IFI 50-325, 324/89-34-38, Revise Periodic Test Procedures for. Proper Evaluation of Service Water Pump Performance, IAP Item.
E.6.
j This item, identified as item 2.I.4(6) in the Diagnostic Evaluation. ! Team (DET) report and IAP E6 in the licensee's Integrated Action-Plan
(IAP), involved inservice testing of the licensee's service-water ! , system pumps.
Testing is accomplished per periodic test (PT) 24.1-1
-(Unit 1) and 24.1-2-(Unit 2), Service Water Pump and Discharge Valve ! Operability Test. Testing of the pump is required to be accomplished - in accordance with-the ASME Boiler and Pressure Vessel Code, Section- ~!
- XI, Subsection IWP,Jwhich requires 'that' the-_ test be repeatable and-q capable of detecting pump' degra'dation.- As discussed in the DET
' report. it was -found that toe procedures contained inadequate
controls to " provide :;t.andardized test conditions and permit. proper j . pump performance evaluation.
PumpHflow measurement, boundary valve. leakage, andL pump discharge- -j pressure gauge were specific concerns identified.
In addition to the ) nuclear service' water header there'is'a conventional service water ' header. 'The conventional system is in service when the nuclear service water pumpf test is. performed.- These ' systems. are cross ! . connected.
Consequently, leakage'through the. valves which isolate j the conventional header from the nuclear header can result -in
unrepeatable flow indications and possible. pressure fluctuation since j e the crossties -are between'. pump discharge and the pump flow i ' , measurement.- Additionally, leakage through branch lines-between the-pump and flow indicators can cause non repeatable 'results.
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' , To improw. test control the licensee proposed to install valves with an improved seat design in the crossties between the headers.
This installation is complete in Unit 2 and scheduled for completion in Unit 1 at the fall 1990 RFO. The licensee is also in the process of developing the procedures to measure flow with an ultrasonic device.
With this device flow will be measured upstream of any gain or loss sources to the system and will provide repeatable results.
- Procedural changes to improve test control include: Control of intake canal water level.
This will provide a consistent pump suction head.
Isolated Service Water pump discharge pressure gauge except when - making a pressure reading.
This will eliminate out-of-calibration problems due to overanging the gauge during pump starts and therefore reduce measurement error.
Record both conventional and nuclear service water header pressure.
This is an attempt to minimize the differential pressure between headers to reduce variation in pressure and flow readings.
Record equipment in operation during the test that could affect Service Water Pump vibration data to aid in vibration evaluations.
Recalibrate installed pressure gauge if the reading differs from the test gauge by 1 psig.
The licensee stated that Unit I and Unit 2 procedures have been revised.
The. inspector reviewed 1-PT-24.1-1, Revision 11, to verify that the changes have been implemented.
' The inspector concluded that the licensee has implemented controls to provide standardized test conditions.
d.- (Closed) IFl-325, 324/89-06-01', Verification of Adequacy of Current Miniflow Capacity by Pump Manufacturer
'IE Bulletin 88-04,. Potential Safety-related Pump Loss,- addressed a concern for.safetys related ' pump loss as a result of inadequate flow in,the~miniflow mode.of operation.
The ' licensee. initially endorsed ' >< the Boiling Water. Reactor Owners Group (BWROG) ~ generic position.
However, at NRC. request, the licensee obtained the recomended' flow ' , ,, rate in miniflow operation from the pump vendors - for-the RHR,; CS, HPCI and ' RCIC pumps. -The vendors also provided recommended times limitations on miniflow operation since damage is cumulative rather than catastrophic..
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, The licensee-estimates a nominal miniflow operation time of about 10 hours in a 12 year period. Vendor recommendations for the licensee's miniflow rates of up to 60 hours annually is acceptable where the continuous operation period is on the order of 30-60 minutes.
Test ', operation time is about five minutes. The licensee has incorporated a warning in the pump test procedures to minimize miniflow operation time.
Calculated miniflow rate and pump operation time meet the vendor recommended minimum miniflow rate and qualifying time limits except for the CS pump.
For this pump the vendor recommended the pump not be operated at flow rates as low as 460 gpm.
The recommended low limit for short term operation, 0-60 hours annually, is 500 gpm. The licensee's calculated miniflow is 475 gpm. While this flow rate for minimal time periods is not expected to result in catastrophic failure, it can result in excessive wear. The licensee has issued an action item to establish a minimum miniflow rate of 500 gpm. Action item completion date is September 17,.1990.
Additionally, the licensee has issued an action item to perform field testing to determine the actual miniflow rate for the RHR, HPCI, and RCI pumps.
The inspector concluded that the license has responded to the low-flow rate concern and identified corrective action as necessary. The measured pump miniflow rates will provide the licensee the necessary information to conclude acceptability or base further action.
e.
- (0 pen) IFI 50-325, 324/89-34-20, Followup on Implementation and Effectiveness of MOV Maintenance Program Improvement in IAP Item D.3.
" During the NRC -Diagnostic Evaluation Team -(DET) inspection at < Brunswick in April - May 1989, it was ' determined that while the licensee's procedures were of high quality in general, certain specific improvements were needed.
. In response to the DET findings the Itcensee identified the problem areas. in the Integrated Action Plan-item D.3 as follows: , " Revise-.0CM-M0500, " Repair Instructions for Limitorque-D.3.a - o Motor Operator Model Numbers SMB-5 and SMB-5T,".to
< specify the proper gearbox grease, . Review and make' necessary. changes to ' MOV1 testing k ' D.3.b.
- procedures, , , ' Review adequacy.of MOV prevent've maintenance progr.im-D 3.c.. . - a.
an:1 scheduling.
-Review engineering procedures for consistency.
D.3.d- -- Revision 3.to.0CM-M0500 ' dated August.30, 1989 incorporates the requirement to use Exxon' Nebula'EP-1 grease for the SMB-5 and SMB-5T Limitorque operators.
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> Also, the licensee has reviewed and corrected the inconsistencies in ENP-43, Q-List Motor Operated Valve Settings.
Updated values of L, torque and limit switch settings are now incorporated into ENP-43.
The conflict between ENP-43, which requires an engineering evaluation to change an MOV switch setting, and the Nuclear Plant Modification Program, which requires a plant modification to change a switch setting, is resolved.
Change of M0V sveitch settings is now , controlled by ENP-43 for safety related valves.
The inspectors concluded that subitems a and d of IAP item D.3 are closed.
The inspector found that the licensee is pursuing the actions ' necessary to implement an effective M0V program.
Elements already developed and in place include a Repetitive Failure Detection Program and a Root Cause Analysis Program.
Also a number of activities are in progress which include establishing quantitative trend analysis, upgrading and expanding the preventative maintenance program and developing administrative procedures to define program responsibilities and management' control.
These latter activities are not yet fully implemented.
For instance the licensee recently implemented a quantitative trend
and analysis-program for M0V issues.
While it is too early to evaluate the rosults of the trend program, it is expected that the trend and analysis process in conjunction with well defined-adminis;., ation procedures will provide the method to integrate the elements into a strong, effective-M0V program. Continuing management . attention will be necessary to uchieve the objective.
' The full implementation and effectiveness of the MOV program will be reviewed at a future inspection.
Item D.3, Sub-Items b and c, of IAP . remain open.
' o , 'Within this-area, no violations or deviations were identified.
<- 6; Exit' Interview The inspection scope and' results were-summarized on August 24, 1990, with those persons indicated in paragraph 1.
The inspectors d(icribed' the' areas inspected and discussed in detail the inspection results listed . 'below.. Proprietary information is not contained in.this report.
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- Dissenting comments were not received from the' licensee,
, o , ' Weakness - Involving PIV leak rate' test procedures which do r.ct document that: the alert leak rate limit was met.
" Weakness - Involving trending M0V performance, Further NRC revi w was identified for: ( q-1.
. Reverse testing of containment isolation. valves , 2.
-Interpretation of relief request VR-27 m . , ' n ,yW , , , ,.
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Acronyms and Initialisms- ,, ,
- 1 ASME'-
American Society of Mechanical Engineers .CFR, CodeLof Federal Regulations ! r , ' CIV Containment Isolation Valve -- , Core Spray '[
CS - c ~ GL -. Generic Letter ! HPCI - High Pressure Coolant injection
I EB - - -- NRC Bulletin - !, Inspection Followup Item IFl - ISI - Inservice Inspection i ' Inservice Testi ^ IST - LLRT - . Local Leak Rate Testing
.LOCA - Loss'of Coolant Accident ' MOV. - Motor Operated Valve , NRC- - - Nuclear Regulatory Commission t Nc lear Peactor Regulations NRR
, Pressure 1001athn Valve
-PlV - Performance Test / Periodic Test PT - > i .. RCIC - Reactor Core isolation Cooling l " ' ' RCS o-Reactor Coolant System 'j- " ' RFOL - Refueling.0utager j RHR; - - Residual Heat Removal - SER, - Safety Evaluation Report j - Technical Specification - T S -- -
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