IR 05000387/1991080
| ML17157A959 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/12/1991 |
| From: | Eapen P, Prividy L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157A958 | List: |
| References | |
| 50-387-91-80, 50-388-91-80, GL-89-10, NUDOCS 9112090192 | |
| Download: ML17157A959 (23) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
8 8 ll
. ~877-8 Docket Nos. ~M7
,'i~3~
License Nos, NPF-14 NPF-22 Licensee:
Penns lvania P wer &Li ht om an 2 North Ninth Street Allentown Penn lvania
1
Facility Name:
Inspection At:
u uehanna Steam Electric Station u
iehanna team Electric Station Berwick PA Inspection Conducted:
Inspection Team Members:
e tember 2 -27
1 Jim Trapp, Region I Jimi Yerokun, Region I Astrid Lopez-Goldberg, Region I Tom Scarbrough, NRR Andrew Trusty, Contractor, Inspector:
nard J. Prividy, Team Lea r,
Systems Section, EB, DRS
date Approved By:
Dr. P. K. Eapen, Chi, Systems Section, Engineering Branch, DRS dat
~li:888887
EXE TI UMMARY The Nuclear Regulatory Commission conducted a team inspection at the Susquehanna Station on September 23-27, 1991, to assess the programs developed by the licensee in response to NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance".
This team inspection was accomplished in accordance with NRC Temporary Instruction (Ti) 2515/109, "Inspection Requirements for Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance".
The generic letter and its supplements (1,2 and 3) discuss the many factors and efforts required by licensees to develop adequate programs that willensure design-basis operability of safety-related motor-operated valves (MOV)~
In general, the team found that the MOV program was thorough, well managed and on schedule.
Design basis reviews and MOV switch settings were thorough and technically sound.
Considerable effort has been made, in conjunction with industry groups, in the use of diagnostic MOV test equipment.
MOV training provided to mechanics and electricians was identified as a program strength.
The impact of dc motor speed on valve stroke time and the use of voltages that are in excess of those assumed in the UFSAR were identified as
'unresolved items.
No violations or deviations were identified during this inspectio TABLE OF NTENT
~PA E
1.0 Introduction
~
2.0 Generic Letter 89-10 Program for Susquehanna Steam Electric Station 2.1 Scope and Administration of Program 2.2 Design Basis Reviews 2.3 Diagnostics System 2.4 MOV Switch Settings and Setpoint Control 2.5 MOV Testing 2.6 Periodic Verification of MOV Capability 2.7 MOV Maintenance and Post Maintenance Testing 2.8 MOV Failures, Corrective Actions, and Trending 2.9 Training and Control of Contractors 2.10 Industry Experience and Vendor Information 2.11 Schedule
6
7
10
12
14
3.0 Generic Letter 89-10, Supplement
4.0 Walkdown
15 5.0 Conclusion
6.0 Significant Operating Occurrence 7.0 Engineering Discrepancy Reports 8.0 Exit Meeting Appendix A - Persons Contacted
16
1.0 I~ntr du tion On June 28, 1989, the NRC staff issued, Generic Letter.(GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," which requested that licensees and construction permit holders establish a program to ensure that switch settings for motor-operated valves (MOV) in safety-related systems are selected, set and maintained properly.
The staff held public workshops to discuss the generic letter and to answer questions regarding its implementation. On June 13, 1990, the staff issued Supplement 1 to GL 89-10 to provide the results of public workshops.
In Supplement 2 (issued on August 3, 1990) to GL 89-10, the staff stated that inspections of programs developed in response to the generic letter would not begin until January 1, 1991.
In response to concerns raised by the results of NRC-sponsored MOV tests, the staff issued Supplement 3 to GL 89-10 on October 25, 1990, which requested that boiling water reactor licensees evaluate the capability of MOVs used for containment isolation in the steam lines to the High Pressure Coolant Injection and Reactor Core Isolation Cooling Systems, in the supply line to the Reactor Water Cleanup System, and in the lines to the Isolation Condenser as applicable.
The generic letter also recommended that each licensee with an operating license complete all design basis reviews, analyses, verifications, tests and
, inspections that have been instituted, within 5 years or three refueling outages, whichever is later, of the date of the. generic letter (June 28, 1989).
The NRC inspection team used Temporary Instruction (Tl) 2515/109 (dated January 14, 1991), "Inspection Requirements for Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance," to perform this inspection.
The inspection focused on Part 1 of the temporary instruction (TI), which involves a review of the program being established by the licensee in response to GL 89-10.
2.0 eneric Letter-10 Pro m f r s uehanna earn Electri tati n S
In their letter dated December 26, 1989 to the NRC, Pennsylvania Power and Light (PPEcL) Company provided their response to GL 89-10 for SSES.
They concluded preliminarily that the NRC proposed schedule was overly aggressive for the GL 89-10 recommended actions.
However, PPEcL stated that they would make every effort to meet the proposed 5 year schedule.
The team reviewed the aforementioned PP&L response to GL 89-10 and the various documentation generated subsequently to des'cribe the program.
The inspectors reviewed the program details with licensee personnel.
The inspection results related to each aspect of GL 89-10 are described belo eandA mini rai nof hePr m
In their document,'Susquehanna Steam Electric.Station Motor-Operated Valve Program, Revision 1", dated February 1991, PP&L provided a general program description and a schedule for its implementation.
Using this document as a basis, PP&L issued in September, 1991, the following detailed MOV program documents:
"Mo or rated V I Pr m"
I-A-1
- This nuclear department instruction identifies the 300 MOVs (150 per unit) within the scope'of the GL 89-10 program, including several position-changeable MOVs. Also, it defines the responsibilities of the various working groups for implementing the MOV program at SSES.
Detailed documentation for selecting each of the MOVs in the scope of the GL 89-10 program is included in a document titled, "Determination of MOVs within the Scope of GL 89-10" (SEA-ME-245).
2.
"Mot r r ted V lv M intenance Pr m" AD-A-5
- This document complements NDI-QA-15.3.5 by defining the SSES administrative controls necessary to implement the recommendations of GL 89-10.
The inspectors reviewed the above documents and the P&IDs for the Nuclear Boiler, High Pressure Coolant Injection (HPCI), Reactor Water Clean Up (RWCU), Main Steam Isolation Valve (MSIV) Leakage Control, Control Structure Chilled Water and Standby Liquid Control system and verified that the licensee had adequately defined the valves to be included in the GL 89-10 program.
The inspectors noted that the justification for exclusion of valves from the Program was well documented, with the exception of the justification for deleting RWCU valves F100, F101, F104 and F106.
Upon identification of this concern, SEA-ME-245 was revised to justify excluding these RWCU valves from the GL 89-10 program.
The inspectors concluded that the scope of the GL 89-10 program for SSES appeared to be consistent with the generic letter recommendations.
The designated SSES "Valve Group" has been addressing station MOV concerns for approximately five years.
It is a matrix organization utilizing knowledgeable personnel from the station and the corporate office. The inspectors observed good communication among the valve project personne The inspectors observed several valve project proactive efforts with industry groups to evaluate and improve MOV performance.
Examples included efforts with EPRI concerning the VOTES validation and MOV grease improvement projects.
However, it was not apparent how the licensee collected and evaluated MOV test results from other utilities for developing its MOV methodology.
Overall, the inspectors considered the licensee's administration of the MOV program to be a strength.
2.2 De i n-B i
Reviews Action "a" of the generic letter, recommended that licensees review and document the design basis for the operation, of each MOV within the program for such parameters as:
1.
Differential Pressure 2.
Flow 3.
Valve Orientation 4.
Line Pressure 5.
Temperature 6, Minimum Voltage The licensee has completed design basis reviews for all MOVs in their GL 89-10 program.
Stone & Webster performed the reviews for the licensee.
The inspectors reviewed the licensee's design basis reviews in'SEA-ME-237, 238, 239.and 240.
Those documents provide design factors such as differential pressure, flow, and ambient temperatures for six event accidentltransient scenarios and inadvertent operation.
The licensee stated that plant procedures had been reviewed for all normal and abnormal conditions.
Where the licensee found design basis factors in those analyses or procedures not bounded by factors for the six listed scenarios, the licensee stated that it included the higher factors in one of the listed scenarios.
The design basis reviews were thorough.
However, the documentation did not adequately provide all the details of these reviews.
The inspectors considered the licensees'rocess for design basis reviews to be consistent with GL 89-10.
The licensee indicated that the worst case differential pressure was being determined across the MOVs. In certain instances, the licensee reduced the predicted differential pressure below its initial assumed value.
The inspectors stated that the licensee should ensure that its assumed differential pressures remain consistent with GL 89-10.
The licensee is performing detailed evaluations of the minimum voltage available to the MOVs in its GL 89-10 program.
The licensee stated that those detailed evaluations are scheduled to be completed by January 199.3 The licensee uses VOTES (Valve Operation Test. and Evaluation System)
equipment to set the torque switches for MOVs in the GL 89-10 program.
The torque switch setpoint is determined by measuring the thrust when the torque switch trips.
The licensee uses a 9.2% VOTES uncertainty for both C-Clamp and U-Clamp calibrated VOTES sensors.
The licensee has reviewed the vendor's letter, dated April 12, 1991, which adds additional uncertainty to VOTES calibrated sensors.
The licensee has reviewed unit 1, supplement 3 valves and is presently reviewing the unit 2, supplement 3 valves for the impact of additional VOTES uncertainty on torque switch settings.
At the time of this inspection, none of the supplement 3 valves reviewed for this impact were found unacceptable.
VOTES testing is implemented using a detailed Maintenance. Procedure, MT-EO-021, "VOTES - MOV Diagnostic Test."
The licensee presently utilizes expertise from a vendor for VOTES data evaluation.
Static VOTES testing of approximately 103 valves has been completed.
Using the VOTES mockup and by performing a number of static VOTES tests the licensee has developed significant expertise in diagnostic equipment testing of valves.
The licensee is a member of the Technical Advisory Group to the VOTES vendor.
The=
licensee's diagnostic testing capability and efforts were viewed by the inspectors as a program strength.
2.4 M V Sizin and witch et in Action "b" of Generic Letter 89-10 recommended that licensees review, and revise as necessary, the methods for selecting and setting all MOV switch settings.
These switch settings should enable the MOV to perform its safety function and/or to survive and recover from a valve mis-positioning event.
The inspectors reviewed MDS-01 (Rev. 0), "Sizing of Limitorque Actuators including Thrust Calculation, Actuator Sizing, Spring Pack Selection and Torque Switch Setting Determination."
The licensee stated that operator sizing and switch setting calculations for 43 MOVs in its GL 89-10 program were complete.
The licensee'indicated that the remaining calculations would be complete by Spring 199 The licensee uses a valve factor of 0.3 for calculating minimum thrust requirements for fiexible wedge gate valves.
The inspectors indicated that the use of a valve factor of 0.3 has been shown to be non-conservative in recent NRC sponsored tests.
The licensee provided documentation justifying their use of a 0.3 valve factor.
In addition, the licensee demonstrated that their use of the mean seat diameter in lieu,of the orifice diameter, added additional conservatism into their minimum required thrust calculations.
The licensee
.
indicated that the 0.3 valve factor would be evaluated during the design basis testing and changes would be made to the valve factor, ifrequired.
The licensee presently incorporates a 0.15 stem friction coefficient for the MOV operator sizing calculations.
A stem friction factor of 0. 15 is appropriate only for well lubricated valve stems.
The licensee justification for the use of the stem friction factor was, in part, the information gathered from its participation in the industry grease lubrication programs and a comprehensive stem lubrication program at SSES.
The inspectors observed that the licensee's stem lubrication frequency did not satisfy the vendor recommendations.
Additionally, the inspectors identified several inadequately lubricated valve stems during plant walkdowns.
The licensee stated that they willdocument their justification for using the 0.15 stem friction coefficient.
In PPScL SEA-ME-367 (Rev, 0), "MOV Rate of Loading," the licensee described its plans to evaluate the rate of loading effect through in-situ design basis testing and other efforts.
The licensee stated that torque switch settings willbe adjusted to account for that effect, as appropriate.
The licensee is developing specifications to procure structural limitanalysis for GL 89-10 valves.
In the past, approximately 50 torque switches were set near the minimum calculated thrust value.
The licensee presently sets torque switches near the middle of the allowable thrust range.
The licensee stated that each torque switch setting willbe reviewed after the design basis testing and adjusted, if required.
The licensee's Updated Safety Analysis Report, Section 8.1.3.9 indicated that MOVs willbe able to function with a 20% reduction in voltage.
The licensee stated that this commitment willbe satisfied except where greater than 80%
voltage is necessary to demonstrate the capability of the MOV. In several calculation packages, the licensee had assumed 80% voltage in determining the minimum torque switch setting, but had assumed greater than 80% voltage for
the maximum torque switch settin'g.
With the torque switch set near the maximum value, those MOVs willrequire greater than 80% voltage in order to produce sufficient torque'to trip the torque switch.
This is an unresolved item (UNR 50-387/91-80-01, 50-388/91-80-01) pending licensee's resolution of the differerices between the voltages assumed for certain MOVs and those stated in the UFSAR.
The licensee has incorporated ambient temperature effects on the output of dc
. motors in their MOV calculations.
The licensee stated that the results of the limitorque study on ambient temperature effects on ac motors would be reviewed and incorporated into switch setting calculations, ifapplicable, DC-powered MOV capability calculations rely on the torque output of,the dc motors to increase as the speed of dc motors decrease.
The effect of valve stroke time limits on decreased motor speed had not been reviewed by the licensee and is an unresolved item (UNR 50-387/91-80-02 and 50-388/91-80-02).
The licensee'stated that thermal overload protection devices are bypassed, They indicated that the resistance of the thermal overload devices are included in their voltage drop calculations.
2.5 M VTetin Action "c" of the generic letter, recommended that licensees test MOVs in situ under their design-basis differential pressure and flow conditions. Iftesting in situ under those conditions is not practicable, the NRC allows alternate methods to be used to demonstrate the capability of the MOV. The NRC suggested a two-stage approach for a situation where neither design-basis testing in situ is practicable nor an alternate method of demonstrating MOV capability can be justified. With the two-stage approach, a licensee would evaluate the capability of the MOV using the best data available and then would work to obtain applicable test data within the schedule of the generic letter.
The licensee has not performed any dynamic pressure testing at the time of this inspection.
The licensee stated that they plan to perform design basis dynamic pressure-testing where practicable.
Dynamic testing is planned for approximately 100 of the 300 MOVs in the GL 89-10 program, For valves which are not practical to dynamic test, the licensee plans to:
Perform the two step test approach described in GL 89-10.
or 2.
Utilize industry sponsored tests and positions.
or 3.
Use a parent/candidate approach for similar valve configurations in identical systems.
At the time of this inspection, the licensee had not developed adequate justification for the parent/candidate approach.
The licensee stated that they are aware of the need to justify testing by the parent/candidate approach and would establish the justification prior to the use of this approach.
2.6 Periodic Verification fM V a abili Action "d" of the generic letter recommended that the licensees prepare or revise procedures to ensure that adequate MOV switch settings are established and maintained throughout the life of the plant.
Paragraph "j" of the generic letter recommended that the surveillance interval be commensurate with the safety function of the MOV as well as its maintenance and performance history.
But in no case should the interval exceed 5 years or 3 refueling outages:
Further, the capability of the MOV has to be verified ifthe MOV is replaced, modified, or overhauled to an extent that the test results are not representative of the MOV.
The licensee indicated that periodic static testing, on a 5 year interval, would be used to ensure the continued adequacy of MOV torque switch settings.
The relationship between the performance of an MOV under static conditions and that under design basis conditions is not clearly established.
Therefore, it is not clear that a static test would verify the valve performance under design'asis dynamic conditions.
The licensee acknowledged this concern and stated that the position to periodically test MOVs under static conditions would be re-evaluated following the dynamic test progra.7 M V Main enan n
P M in n nce Te tin Maintenance Procedure MR-GM-050, "Limitorque Type SMB 000-4 Operator Maintenance," contains instructions for performing preventive maintenance (PM) and overhauls on type SMB limitorque valve operators.
The inspectors reviewed the procedure'and discussed maintenance practices with plant personnel.
While the overall activities were being adequately performed, the following concerns were noted:
stem and-stem nut lubrication is not routinely done during the periodic 18 month grease sampling.
'the 18 month grease sampling is strictly an inspection of lubricant condition, the result of which determines whether the actuator is to be re-lubricated or not.
there is no fixed schedule for actuator overhaul.
the method used for checking for spring pack relaxation does not in fact determine ifa spring pack is relaxed.
Upon identification by the inspector, the licensee stated that past practices have ensured that actuators are overhauled when required and that the 18 month periodic grease sampling had produced good results to ensure lubrication as required, However, the licensee did not adequately demonstrate how the grease sampling was used to identify stem nut wear and determine when lubrication or overhaul is required.
The inspector reviewed past grease sampling/overhaul histories and noted that, with a few exceptions.
Th'
licensee had been overhauling actuators on an average of about every third refueling outage.
This frequency was well within the industry average.
The licensee agreed to review this matter for resolution.
The licensee acknowledged the concern in'he area of checking for spring pack relaxation and indicated that actions were on-going to improve this area.
The licensee has acquired a spring pack tester and plans to revise the maintenance procedure (MT-GM-050) to require the use of spring pack tester fog checking spring pack relaxation during overhauls.
The licensee also stated that adequate justification willbe maintained for any deviations from the vendor's recommended maintenance schedules.
Planned improvements in the maintenance program, are described in the PM Improvement Program discussed in Section Procedure AD-QA-531, "Motor Operated Valve (MOV) Maintenance Program," was developed to describe the program established for MOV maintenance.
A review of the procedure showed that the minimum required maintenance activities; PM frequency; periodic verification; and post maintenance test (PMT) requirements are being addressed in this procedure.
The PMT guidelines contained adequate information to require an operability test after maintenance activities.
The inspectors witnessed an on-going actuator overhaul.
Work authorization number S10753 was used to implement maintenance overhaul procedure MT-GM-050 on valve HV112F073A.
The inspectors observed that the work was performed in accordance with the procedure and work documents were adequately controlled and kept.
No discrepancies were identified.
2.8 M V Failures rrective A ion and Tr n in Action "h" of the generic letter recommended that licensees analyze each MOV failure and justify corrective action.
The results and history of each as-found deteriorated condition, malfunction, test, inspection, analysis, repair, or alteration should be documented and maintained.
The material should be periodically examined (every 2 years or after each refueling outage after program implementation) as part of the monitoring and feedback effort to establish trends of MOV operability.
The maintenance organization developed a maintenance instruction, MI-VL-003, "MOV Performance, Evaluation, & Trending," which, at the time of this inspection, was still in draft form. This MI assigns the MOV engineer to complete the "MOV Data Evaluation/Trending Form," after each MOV work authorization is complete.
This form willbe used to trend for the type of deficiencies and failures described in GL 89-10, Attachment A. The MI has divided the failures described in Attachment A into broader categories to develop a more meaningful statistical basis.
AD-QA-531, "MOVMaintenance Program," requires the MOV engineer to do a quarterly review of previously performed MOV maintenance and testing activities to identify degradation, identify-MOV's for which increased attention is required, adjust the frequency of PM activities, and identify needs for specific training and procedure contro.9 The inspectors reviewed NSI-4.1.1, "Preventive Maintenance Improvement Program."
This program requires the incorporation of all past history regarding MOVs (i.e., SSES failures; industry failures; vendor, industry, and SSES requirements, etc.) into a package for use by the MOV engineer.
Such a package would include recommendations for change to the PM process.
The review required by this program was scheduled to be completed by the end of this year.
T inin n
n r l f n
r The inspectors evaluated the licensee's MOV training courses, facilities, and knowledge of their training personnel relating to the implementation of the GL 89-10 program.
The inspectors reviewed MOV training docum'entation ME-018, "Limitorque Valve Actuator Maintenance," interviewed training personnel, and toured the training facility.
The MOV training is provided as part of the Task Certification Program for electrical and mechanical maintenance personnel.
The course includes one week of classroom training, on-the-.job training and task certification.
On-the job-training (OJT) is conducted by qualified maintenance supervisors (usually assistant foremen) who are trained to conduct OJT and to evaluate trainees.
Procedures OJ001, "How to Conduct OJT" and MA040, "Evaluation Training" provide guidelines for this process.
The course is part of the INPO approved training program.
Nearly all the station maintenance personnel, and approximately 20 PP&L construction personnel, have taken this training.
PP&L does not u'se contractor personnel to perform maintenance on MOVs.
The training course for data acquisition using VOTES equipment has been provided to PP&L construction and predicative maintenance personnel.
Advanced diagnostic test'equipment training was under development at the time of this inspection.
The licensee has constructed a VOTES testing facility. The facility was used to improve VOTES sensor mounting techniques and has been used for VOTES training.
The licensee plans to use the mockup to conduct independent
"Rate
'f Loading" studies.
The licensee has provided refresher training to maintenance and construction personnel prior to refueling outages on an informal basis.
The licensee recently changed AD-QA-531 to require refresher training prior to outage The licensee verifies that contractor personnel used as trainers for the use of the diagnostic system (VOTES) are certified monthly by the vendor for the system.
The inspectors reviewed some of these certifications and found them to be acceptable.
The quality of the training material and facilities was good.
The instructors
.
were knowledgeable of the requirements of the GL 89-10.
The training with regard to MOVs was viewed by the inspectors as a program strength.
2.10 In Ex eriencean V n rInf rmai n Plant procedure NDI-QA-6.2.2, "Industry Events Review Program PERP)",
describes the process through which the plant personnel review relevant industry information and experience, and distributes such information to appropriate plant departments.
The scope of the procedure includes 10CFR 21 notices, vendor information, and other industry inputs.
The inspectors reviewed the licensee's evaluation of certain Limitorque information updates.
While the licensee provided evaluations for all updates specified by the inspector, it was noted that all evaluations had been performed in July 1991.
Some of the updates were from 1988 and 1989.
The licensee indicated that their program had been weak in the past but was being improved to be up-to-date.
The inspector verified that the information contained in the updates had been addressed or was planned to be addressed in plant procedures.
2.11 Schedule In GL 89-10, the staff requested that licensees complete all design-basis reviews, analyses, verifications, tests, and inspections that were initiated in order to satisfy the generic letter recommended actions by June 28, 1994, or 3 refueling outages after December 28, 1989, whichever is later.
The licensee intends to meet the GL 89-10 schedule.
The inspectors considered the licensee to be on schedule at the time of the inspection.
3.0 Generic Letter 8 -10 Su lement 3 Six MOVs, two each in the HPCI, RCIC, and RWCU systems, are within the scope of Supplement 3 to GL 89-10 for both Susquehanna units.
In response to Supplement 3, the licensee prepared a safety assessment to demonstrate that the 18 month schedule to correct any deficiencies in these MOVs was applicable to Susquehanna.
The inspectors identified no concerns with that assessment, except with
respect to the licensee's reliance on the leak before break phenomenon which has been accepted by the staff only for pipe restraints.
The licensee evaluated their MOVs within the scope of Supplement 3 and concluded that each MOV was capable of performing its design basis functions.
The inspectors reviewed the licensee's MOV evaluations with regard to research test program and industry experience.
The inspectors discussed the use of a 0.3 valve factor for these flexible wedge valves.
A review was conducted of PP&L SEA-ME-359 (Rev. 0),
"Impact of NRC Sponsored MOV Dynamic Test Results on Valve Factor in Gate Valve Actuator Sizing" and Project Report No. 03-0160-1334 (Rev. 0, March 6, 1991), "Evaluation of RWCU, RCIC, and HPCI Isolation Valves at Susquehanna Steam Electric Station with respect to NRC Information Notice 90-40 and Generic Letter 89-10, Supplement 3," by a contractor (ABB Impell Corporation).
The-report provided bounding calculations for the capability of the MOVs assuming valve factors of 0.3 and 0.5 with full and 80% voltage.
The report also included several recommendations to improve the reliability of the MOVs involved.
The inspectors independently reviewed the licensee's evaluations and requested the licensee to determine the capability of MOV HV-155F002.
The licensee determined that the available valve factor for HV-155F002 ranged from 0.42 to 0.48 depending on the assumptions regarding motor torque output.
In those calculations, the licensee assumed actual voltages available at the time of seating.
It should be noted that the FSAR assures only 80% of the nominal voltage to be available during a design basis accident.
The licensee's evaluation of MOV capability'is acceptable for the interim, provided: (1) The assumed voltage is available when the MOV is called upon to function, (2) the MOV is structurally capable of withstanding the developed thrust, and (3) the licensee implements a stem lubrication policy that assures the assumed stem friction coefficients.
4,0
~Walkd wn The inspectors conducted a walkdown of several MOVs and observed maintenance on MOV HV-112F073A.
The inspectors identified HV-152F015B and HV-151F024B with minimal stem lubrication.
The licensee initiated Work Authorization S14465 to ensure that all accessible safety-related MOVs have adequate stem lubrication.
The inspectors noted that the bonnet retainer cap bolts were not fully inserted on HV-149F022 and HV-150F045.
The licensee indicated that a work authorization would be initiated to tighten or replace those bolts.
The inspectors noted that the stem protector cap was not installed on HV-149F022 or HV-149F062.
The licensee indicated that a work authorization would be initiated to install the stem protector caps for those MOVs. The inspectors identified grease dripping from the spring pack areas of HV-152F015B, The licensee indicated that the effect of the dripping grease would be evaluated.
The inspectors identified a loose bolt on the limit switch compartment cover of HV-151F024B.
The licensee indicated that a work
'
authorization would be initiated to check and tighten all bolts on the limitswitch compartment cover for this MOV.
5.0 Conclusions The licensee has made a good beginning in developing a program to verify that MOVs willbe capable of performing their functions under design.-basis conditions.
The licensee provided reasonable justification for the low valve factor assumed in the thrust calculations, The licensee also provided assurance that the results of their design basis testing would be used to evaluate the methodology in a timely fashion.
6.0 Si nificant 0 eratin ccurrence Re The Significant Operating Occurrence Reports (SOORs) are used primarily by operations personnel to document reportability and root cause analysis for operating events.
A number of SOORs were reviewed by the inspector to verify that the SOORs process was being conducted in accordance with station administrative procedures.
The inspector reviewed AD-QA-424, "SOORs," and the following SOORs; 1-91-091, "RHR Loop Failed Test RHR Check Valves" 2-91-046, "Loss of Control Room Alarms" 1-90-177, "Loss of Instrument Bus 1Y115" The administrative procedure AD-QA-424, "SOORs" clearly delineates responsibilities and provides detailed guidance on the SOOR process.
Reportability evaluations were done in accordance with the procedure guidance, and SOOR resolutions were comprehensive and provided adequate technically detail.
The licensee's corrective actions were sufficient to prevent recurrence.
The trending and tracking of SOORs was comprehensive.
The inspector concluded that the SOOR program assures detailed and well documented evaluations of operational events.
7.0 En ineerin Di cre anc Re rts The Engineering Discrepancy Report (EDR) system is used to track, determine reportability, and resolve engineering discrepancies.
EDRs are normally initiated in NPE as a result of an engineering study or calculation.
The EDR program is independent from the station SOOR program which is primarily event driven.
The scope of this inspection was to review selected EDRs for the folfowing:
1.
Reportability requirements 2.
Technical content 3.
Adequacy of the EDR administrative procedures 4.
EDR evaluation timeliness The EDR program is coordinated by the Engineering Discrepancies Management group (EDMG). The EDR program was initiated in December of 1989.
The EDMG group presently consists of a supervisor and staff of 2 engineers, a program advisor and a planner.
Training on the EDR process has been provided to plant and engineering staff.
The program is administratively controlled by Nuclear Plant Engineering Procedures Manual EPM-QA-122, Rev. 3, "Engineering Discrepancy Management."
As of July 1990, there were approximately 140 open EDRs. In addition, the following EDRs were reviewed:
EDR-G10103 -
"HV-151F015A/B, HV-251F015A/B - LPCI Outboard Injection Valves.", Initiated August 2, 1991.
EDR-G10070-EDR-G10089-
"Agastat EGP Relays, Panel OC876A", Initiated March 8, 1991.
"Environmental and Dynamic Qualification of continuously energized Agastat relays, various locations." Initiated May 8, 1991.
The EDR program is an effective licensee initiative to resolve outstanding technical discrepancies.
The EDMG supervision and staff were interviewed by the inspector.
The EDMG staff and supervision were knowledgeable of EDR program requirements and had good technical understanding of the EDR issues.
EDR evaluations were detailed and technically correct.
The organization and responsibilities were clearly defined in EPM-QA-122, "Engineering Discrepancy Management."
The EDMG tracking and management of open EDRs is effective.
However, one weakness was identified in the area of timely resolution of open EDRs.
EDRs are initially screened for safety significance.
EPM-QA-122 states that EDRs entered into the system should be "quickly" screened but does not provided specific time requirements.
Operability/reportability evaluation are not made until screening is complete.
EPM-QA-122 is inadequate in that it does not assure timely reportability and operability determinations are made for EDR For the EDRs reviewed, none had completed the screening process at the time of the inspection.
However, significant documentation of the screening step had been
'ompleted.
The licensee had not made reportability/operability determinations for the EDRs reviewed, at the time of this inspection.
The EDRs were screened and reportability/operability determinations were provided to the inspector following the inspection.
The EDMG supervisor stated that EPM-QA-122 would be reviewed and necessary actions would be taken to assure screening of EDRs would be completed in a timely manner.
8.0 Exit Meetin The inspectors met with those denoted in Appendix A on September 27, 1991, to discuss the preliminary inspection findings as detailed in this repor ~A~nlix A r
n n
Sus ueh nna Nu lear Power Plant K. Anderson, Project Engineer K. Chambliss, Maintenance Production Supervisor N. Coddington, Senior Licensing Project Engineer E. Figard, Maintenance Manager M. Golden, Plant Engineering Supervisor - Tech J. Gutshall, Valve Maintenance Supervisor K. Hart, Valve Team Senior Project Engineer V. Kelly, Senior Nuclear Maintenance Engineer, J. Murray, Project Manager T. Oldenhage, Valve Team Senior Project Engineer M. Rose, Nuclear Design Senior Project Engineer.
D. Roth, Senior Compliance Engineer D. Sadvary, MOV Engineer B. Skoras, Nuclear Electrical Design Project Engineer
'. Stanley, Plant Superintendent Nuclear Re ul to Commis i n S. Barber, Senior Resident Inspector - SSES P.K. Eapen, Systems Section Chief, Region I J. Durr, Engineering Branch Chief, Region I