IR 05000395/1988020
| ML20205M842 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/24/1988 |
| From: | Jape F, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205M835 | List: |
| References | |
| 50-395-88-20, IEB-85-003, IEB-85-3, IEB-86-003, IEB-86-3, IEIN-85-045, IEIN-85-45, NUDOCS 8811030319 | |
| Download: ML20205M842 (12) | |
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101 MARIETTA STREET N.E SUiTC 2900
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ATLANTA 0EoRGIA 30323
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Report No.: 50-395/88-20 Licensee:
South Carolina Electric and Gas Company Columbia, SC 29218 Docket No.: 50-395 License No.:
NPF-12 3,
Facility Name:
V. C. Summer
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Ynspection Conducted:
September 12-17, 1988 g
Inspector:
)A C ihb 3. TingerY ate Signed
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Approved by:
/ (lA A bm _e
/v/av/8 F. Jape, Chief f/ /
Date Signed
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Test Programs Section a
Engineering Bran::h
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Division of Reactor Safety
SUMMARY i
Scope:
This routin's, announced inspection was conducted in the areas of
j Complex Serveillance testing, IE Bulletin followup, and IE i
Notice followup.
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Results:
In Paragraph 2, a strength was identified in the Fressurizer and Main l
Steam safety valve setpoint test program involyf ng research into
safety valve setpoint deviation.
In Paragraph J weaknesses were
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identified in the licensee'sBulletin 85-03 r,rogram involving j
differential pressure testing bulletin valves, revising procedures to l
maintain bulletin valve switch settings, and development of formal l
guidelines to maintain bulletin valve switch settings.
A strength identified in the bulletin program was that it was evident that i
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corrective action was implemented in response to IE Notices l
regarding motor operated valvr deficiencies.
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j 8811030319 081027
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. Clary, Manager Design Engineering
- D. Conrad, Operating Experience
- H. Donnelly, Senior Engineer, Nuclear Licensing
- A. Koon, Manager, Nuclear Licensing
- D. Moore, General Manager, Engineering Services
- K. Nettles, G?neral Manager, Nuclear Safety
- J. Proper, Associate Manager Quality Assurance
- L. Shealy. Operating Experience
- S. Skolds, General Manager, Nuclear Plant Operations
- G. Soult, General Mcnager, Operations and Maintenance
- M. Williams, General Manager, Nuclear Services Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, technicians, and administrdive personnel.
NRC Resident Inspector
- R. Prevatte
- Attended exit interview 2.
Complex Surveillance (61701):
Main Steam Safety Valve and Pressurizer Safety Valve Setpoint Surveillance The inspector reviewed the Main Steam Safety Valve (MSSV) and Pressurizer Safety Valve (PSV) setpoint test program scheduled to be accomplished during the upcoming Refueling Outage (RF0) 4.
Surveillance Test Procedure (STP)-401.001, Pressurizer Code Safety Valves ASME Section XI Test, STP-401.002 Main Steam Line Code Safety Valves ASME Section XI Test, observation of setpoint test training and observation of MSSV setpoint testing were used as the basis for this review.
The setpoint tolerances for MSSVs and PSVs are specified in Summer Technical Specifications (TSs).
MSSV and PSV test requirements are specified in ASME Section XI,19/7 Edition which invokes ANSI /ASME-PTC 25.3-1976, Safety and Relief Valves Perfonnance Test Codes.
The results of this review indicate that the Sunner MSSV and PSV setpoint test program meets or exceeds all Section XI and PTC 25.3 1976 requirements for safety valve testing.
Procui1res that govern this test program were well organized and easy to follow.
The procedures were adhered to while accomplishing the testin.
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a.
MSSV Testing l
Original plans were to setpoint test four of the 15 MSSVs utili2:ng Crosby Valve and Gage Company's Setpoint Verification Device (SPVD).
The SPVD is a pressure assist device that uses air pressure to
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instantaneously lift the MSSV stem a specified amount, the Main Steam System pressure is automatically inputted into the SPVD computer via
a pressure transmitter.
The SPVO computer calculates tN force required to lift the MfSV stem and the MSSV setpoint. Tht; amount of
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lif t of the MSSV stem is predetermined and specified by Crosby.
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device is used for setpoint testing Crosby and Dresser safety valves.
Once all the test equipment is calibrated and installed it takes only seconds to setpoint test a safety valve.
During the previous RF0, all MSSVs were setpoint tested in place utilizing the SPVD, therefore, any
setpoints out of tolerance encountered during this present RF0 could t
not be attributed to different test methods. Of the four "SSVs setpoint tested, two of the valves setpoints were out of TS tolerance. As a
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result all MSSVs were setpoint tasted.
The results are as follows:
Valve TS !;etpoint As-found
% Deviation As-Left No.
Tolerance Setpoints From Setpoint Setpoints 1st Attempt N/A No Adjust-
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XVS-2806A 1176 1%
Invalid (note 1)
ments made
l Test 1182.1
+0.5 1181.9
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XVS-2806F 1176 1%
1185.5
+0.8 1185.8 1188.7
+1.1 1185.6
l 1191.7
+1.3 XVS-2806K 1176t1%
1185.5
+0.8 No Adjust-
1173.5-0.2 ments made
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XVS-28068 1190!1%
1st Attempt N/A 1169.7 Invalid (note 2)
1186.9
i 1172.1-1.5 1182.9 3rd Attempt N/A
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In Valid (note 2)
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1169.1-1.8 l
i XVS-2806G 1190 1%
1215.1
+2.1 1197.6 i
1218.9-2.4 1200.0 l
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XVS-2806L 1190 1%
1197.9
+0.7 No Adjust-l 1197.5
+0.6 ments made
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XVS-2806C 1205:1%
1199.6-0.4 No Adjust-
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1204.0-0.1 ment made I
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Valve TS Setpoint As-Found
% Deviation As-Left No.
Tolerance Setpoints From Setpoint Setpoints (cont'd)
XVS-2806H 1205 1%
1211.8
+0.6 No Adjust-1214.9
+0.8 ment made XVS-2606M 1205 1%
1229.6
+2.0 No Adjust-1207.4
+0.2 ment made 1197.9-0.6 XVS-20060 122011%
1229.6
+0.8 1219,7 1232.3
+1.0 1225.4 XVS-2806!
1220 1%
1258.4
+3.1 1226.6 1253.3
+2.7 1235.9
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1222.9 1222.9 XVS-2806N 122021%
1236.2
+1.3 1227 1238.4
+1.5 1228 XVS-2806E 1235 1 1236.6
+0.1 No Adjust-1247.6
+1.0 ment made 1242.7
+0.6 1252.0
+1.4 1239.3
+0.3 1234.2-0.1
XVS-2806J 1235 1 1235.8
+0.1 NoAdjust-
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1245.3
+0.8 ment made XVS-28060 1235 1 1268.8
+2.7 1248.3 1255.0
+1.6 1241.3 1244.1
Note 1:
Test invalid because trigger i
Set a t.44" in lieu of.040" Note 2:
Exact cause of invalid test not known. A Crosby representative was present during testing and has seen this previously occur.
It is suspected the valve did not lift during the test due to higher valve internal clearances.
The licencee was disappointed with the as-found setpoint test resul ts.
The licensee considers that the SPVD is the most accurate and advanced method avoilable to determine safety valve setpoint, and since MSSVs were previcu.y set with the SPVD it was anticipated v
that the as-found setpoints woulo have been within TS tolerance during this test cycl _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - - - - _ _ _ _ _ _
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b.
PSV Testing j
Original licensee plans were to setpoint test one of the three PSVs l
ta place utilizing the SPVD while the plant was at Normal Operating Pressure (N0P) following the shutdown to commence RF04. Due to time constraints the PSV was not tested following the shutdown and has been rescheduled to be tested at a later date.
Because PSV testing was originally scheduled, mock-up training was held for the installation of SPVD test equipment.
The PSYs are located in high temperature and radiation areas and the purpose of the mock-up training was fer personnsi to become familiar with the test equipment
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installation in order to minimize radiation exposure. The inspector witJessed this mock-up training and considered it adequate.
During the April 1987 RF0, the as-found PSV setpoints were significantly higher than specified by TSs. At this time, the license began a comprehensive study to determine why the setpoints were out of tolerance.
Setpoint drift was excluded as a cause.
Because the setpoint testing performed prior to that of RF03 was performed by different test methods, the licensee study investigated the effects on a valve's setpoint utilizing different test methods.
The conclusion of the study was that the temperature imposed by ambient and internal mediums effected the growth of the valve spring, stem,
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and bonnet that results in setpoint differences.
Summer PSVs are
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I installed on insulated loop seals. One set of tests performed was to setpoint test the PSV utilizing the SPVD with hot water in the loop l
seal and then drain the loop seal and setpoint test the PSV utilizing
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the SPVD with steam in the loop seal.
Results of this testing indicated the PSV setpoints were approximately 150 psig lower with steam in the insulated loop seal.
The setpoints obtained with steam in the loop seals were compared to steam tests results run at Wyle t
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Laboratories and were not consistent.
This inconsistency was attributed to the Wyle inability to simulate actual ambient
temperature conditions.
At Wyle, the PSVs were also setpoint tested
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with the Crosby SPVD and the results were similar to Wyle setpoint
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results, therefore the difference in Summer and Wyle tests results
cannot be attributed to the SPVD inethod.
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Present Sumer safety valve test practice is to test safety valves in i
place with normal inservice conditions utilizing the Crosby SPVD.
This is considered the best method because actual ambient ccnditions (
and internal temperature conditions are present which is very l
difficult to simulate on test stands.
The PSVs are setpoint tested I
with hot water in the insulated loop seals. As previously mentioned the licensee was disappointed in the MSSVs setpoint results and is reconsid9 ring setpoint drift as a possible cause.
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No deviations or violations wet e identified.
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3.
IE Bulletin 85-03 Followup (25573)
(0 pen) 50-395/85-80-03 T2515/73, "Motor Operated Valve Comon Mode Failures During Plant Transients Dua to Improper Switch Settings."
The purpose of this bulletin is to require licensees to develop and implement
a program to ensure that switch settings for High Pressure Coolant Injection and Emergency Feedwater System Motor Operated Valves (MOVs)
subject to testing for operational readiness in accordance with 10 CFR
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50.55a(g) are properly set, sele:ted and maintained.
Action Itert a required a review of the design basis for the operation of each valve.
Action Item b requires that correct switch settings be established. Item c requires differential pressure testing or alternate methods to demonstrate operability with the settings from Item b; Item d requires plant procedures to be provided to assure the maintenance of correct switch settings throughout plant life, In order to evaluate the Summer Bulletin 85-03 program, the inspector held a
discussions with the appropriate licensee personnel and reviewed the following:
Maintenance Histories for valves XVG-1008, XVG-1001A, LCV-115D,
XVG-8801A, and XVG-88018 South Carolina Electric & Gas Company (SCE&G) inte r-of fice
correspondence, dated June 17, 1988 V. C. Sumer Nuclear Station IE Bulletin 85-03, Yalve M0 VATS Testirig SCE&G Bulletin 85-03, Response for Summer Nuclear Station, dated
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October 6, 1987 SCE&G inter-office correspondence, dated February 20, 1987
V. C. Summer N9 clear Station IE Bulletin 85-03, Valve MOVATS Testing SCE&G V. C. Sumer Nuclear Station Piping Motor Operated Valve
Data Valve and Operator thrusts, and Limitorque Operator Thrust /
Torque Comparison provided by Gilberc/Comonwealth Engineers and t
Consultants
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I Electrical Maintenance Proedure (EMP)-445.002, Limitorque Operator
l Maintenance EMP-445.001 Limitorque Preventative Maintenance
EMP-445.007, M0 VATS Testing of Limitorque Valves
l Mechanical Msintenance Procedure (MMP) - 300.18, Maintenance and
i Rework of Limitorque Valve Operators Models SMB-000, SMB-00, SB-00 and SBD-00
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MMP-445.001, Adjusting and Packing Valves
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MMP-300.025, Maintenance and Rework of Limitorque Valve Operators
Models SMB/SB/SBD-0, SMB/SB/SBD-1, SM8/SB/SBD-2, SMB/SB/SBO-3, SMB-4, SMB-4T EMP-445.008 Limitorque Valve Data
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i EMP-445.006, Setting Limits on Valves with the Torque Switch Bypassed
Gilbert /Comonwealth undervoltage thrust calculations for the initial
14 bulletin valves The initial Summer Bulletin 85-03 program identified 14 valves, through NRC correspondence 17 additicnal valves have been added to the program for e total of 31 valves.
Diagnostic and differential pressure testing has been completed for the original 14 valves, testing for the remaining 17 valves is currently being performed during RF04.
All Summer bulletin valve operators arc AC motor driven and manufactured by Limitorque.
In order to accomplish diagnostic testing, MOVATS equipment was purchased and plant personnel trained to use the equipment.
Thrust values for Summer bulletin valves have been provided by
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Westinghouse, Anchor Darling, and Gilbert /Comonwealth Engineers and Consultants. The only deficiencies encountered by the licensee during the M0 VATS testing of the original 14 valves were over or under thrusting
valves.
The valves that were over thrusting were evaluated for damage, r
and the under thrusting valves were adjusted to provide additional thrust.
Thus far, the Bulletin 85-03 program has indicated the Sumer MOVs are in good operational condition because no problems have been encountered.
This could be attributed to the fact that the plant is relatively new.
One strength with the MOV program was that it was evident that Sumer had
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implemented corrective action in reference to IE Notices regarding MOV deficiencies.
Operation at degraded voltage, was considered while c
accomplishing the Bulletin 85-03 program.
The logic for Summer bulletin valves is typical except as follows:
A number of bulletin valves motors are de-energized when the valve is shut by activation of the closed limit switch in lieu of utilizing the closed torque switch.
These are not high speed operators and there are two different procedures for setting the closed limit switches for these actuators.
The reason these valves limit close and why two different
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mei. nods of setting the closed limit switches for limit close valves exist was unknown except Westinghouse required it.
During automatic operation of bulletin valves, the thermal overload circuitry is bypassed, when the valves are operated in the non-automatic mode, the thermal overloads are (
not bypassed.
i Inspector Findings a.
One of the requirements of Bulletin 85-03 is to differentici pressure test each bulletin valve or provide justification in lieu of differential pressure testin *
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I The purpose of differential pressure testing is to verify that the thrust values and switch settings are adequate to operate the valve
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under accident design pressure.
Of the 14 original bulletin valves, four were tested at full accident pressure and four valves tested at r
partial accident pressure.
The remaining six valves were not tested because of the possibility of contaminating steam generator with i
The as-left and calculated thrust values for the six valves not pressure tested are as follows:
(Accident pressure for
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all six valves is 60 psig and all thrust values are in pounds-force)
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Valve As-Left Calculated As-Left Calculated No.
Open Thrust Open Thrust Closed Thrust Closed Thrust
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XVG-1001 A 1917 1478 2020 1597
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t XVG-10018 2912 1478 2381 1597 XVG-1002 2927 1909 4253 2057 XVG-1008 4445 1909 4846 2057
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XVG-1037A 4950 1909 3324 2057 XVG-10378 3385 1909 6403 2057 l
i Valve XVG-1001A is required to open in an accident condition and the i
difference between the as-left and calculated open thrust value is 423 pounds.
As previously stated, the purpose of differential pressure j
testing bulletin valves is to verify the calculated thrust values are
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adequate to stroke the valve in an accident condition.
The margin
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between Valve XVG-1001A calculated and as-left thrust value is i
mininal and if the calculated open thrust value is not accurate then l
the valve may not operate in an accident condition due to
insuf fic'ent th rus t.
The inspector considtrs that the licensee
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program in regards to differential pressure testing valves does not meet Bulletin 85-03 requiroments, and that additional justification is
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required in lieu of differential testing the six v61ves.
In SCE&G October 6,1987 response to NRC justification for not differential
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pressure testing was provided but it is not valid.
The justification
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stated that successful testing of four valves at high differential pressures is adequate to validate valve operation at relatively low differential pressu res.
Because the valves not differential pressure tested are different sizes and provided by L
different vendors than the valves differential pressure tested, operation under a differential pressure is required to be validated.
The inspector considers that the valves tested at a partial differential pressure meet 85-03 requirements because either accident
pressure was very close to being achieved or the as-lef t thrust l
values were significantly higher than calculated thrust values for l
low differential pressure valves.
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b.
A requirement to complete IE Bulletin 85-03 is to establish procedures to ensure that correct switch settings are determined and maintained throughout the life of the plant.
The procedures reviewed by the instructor do not fulfill this requirement.
Examples of such are:
(1)
EMP-445.008 provides data for setting up Limitorque actuator switches.
Enclosure 10.2 of this procedure provides the required switch settings and thrust values for bulletin and other safety-related valves; however, not all bulletin valve switch settings and thrust valves are specified in Enclosure 10.2.
Thrust values are presently being obtained from engineering via memorandums.
Summer has had difficulty obtaining valve thrust values and now since they are available, is in the process of revising EMP-445.008 to recognize thrust values.
P (2)
In order to maintain switch settings post-maintenance test
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requirements need to be well defined.
The licensee verbally states that it is policy that MOVATS testing is performed on bulletin valves following maintenance that could effect valve thrust. Fonnal guidelines that govern when MOVATS testing is required have not been issued nor do the procedures that perform this type of maintenance specify when M0 VATS testing is required.
Summer is in the process of revising procedures to
recognize MOVATS post-maintenance testing.
The only gaidance for
post-maintenance testing in writino was in inter-of fice correspondence memorandum dated June 17, 1988, from Design Engineering to Distribution, which stated that Procedure
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MMP-445.001, Adjusting and Packing Valves, was required to be shanged to recognize future MOVATS testing for specific valves
subsequent to valve packing / replacement.
The inspector reviewed
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MMP-445.001 and determined that it did not address M0 VATS
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testing after packing adjustment or replacement.
From discussion i
with the licensee, it appeared that the personnel responsible for t
revising MMP-445.001 to recognize M0 VATS tests were not aware of
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the June 17, 1988, memorandum to distribution.
l (3) EMP-445.002, Limitorque Maintenance Procedure, Step 7.5.3.A f
states to adjust the torque switch in 1/2 number increments until the valve cycles properly.
This is not the correct method
for establishing and maintaining a torque switch setting.
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practice was discussed with the licensee who stated this dates t
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back to preoperational testing.
This method is no longer utilized; however, the option is still contained in the procedure.
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In order to monitor plant performance throughout plant lf'e, Sumer plans to periodically diagnostic test bulletin valves
during refueling outages.
In-plant task sheets will track this
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periodic testing.
The inspector reviewed in-plant task sheets
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for several bulletin valves; the sheets did not specify any
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9 diagnostic '.esting was r4 quired.
Discussion with the licensee indicated that the in-plant status sheets would be changed to recognize periodic diagnostic testing.
No formal guidelines have been issued specifying periodic diagnostic testing requi rements.
(5) During the review of MMP-300.025, the inspector had questions regarding installation of the operator stem nut and adjustment of tripper fingers.
While discussing 'this procedure with the licensee, the inspector was informed that the licensee had just completed a training course provided by MOVATS and now realizes that this procedure could be improved and was going to be revised to make the improvements.
c.
EMP-445.003 provides instructions for adjustment of open and close limit switches.
This switches are of particular importance because on a two rotor assembly the torque switch bypass switch actuates at the same time as the limit switches.
Sumer presently uses two of
j the four rotors, future modifications are planned to utilize four rotors which will allow the limit and torque switch bypass switches to be placed on separate rotors.
Improper adjustment of these
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switches could result in the valve failing to operate or allow coasting into the valve back seat.
The Summer method to set the closed limit switch is to manually operate the valve to the full closad position and then open the valve slightly to allow coast for moving parts. At this point, the closed limit and open torq"a bypass
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j switches are set to actuate.
Sumer states that a valve disk
clearing the seat can be felt in the handwheel.
The open limit and close torque bypass switches are set similarly.
The more
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conventional ways for setting these switches is to count hai.dwheel turns or measure stem movement.
During a subsequent inspection the inspector will review the applicable Sumer technical manual for limit switch adjustment instructions.
Because the licensee has not completed all of Bulletin 85-03 action items, the inspector was unable to close out the Bulletin 85-03, however, NRC review of action Item e. of the bulletin has been completed. As requested by action Item e, of Bulletin 85-03, ' Motor-Operated Valve comon Mode Failures During plant Transients Due to Improper Switch Settings," the licensee identified the selected safety-related valves, the valves'
maximum differential pressures and the licensee's progrcm to assure valve operability in their letters dated May 14 and October 3, 1986. Review of these responses indicated the need for additional infomation which was contained in: Region Il letter dated August 18, 1987.
Review of the licensee's September 17 and November 20, 1987, responses to this request for additional information indicates that the licensee's selection of the applicable safety-related valves to be addressed and the valves' caximum differential pressures meets the requirements of the bulletin and that the program to assure valve operability requested by action Item e. of the bulletin is now acceptabl *
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The results of additional inspections to verify proper implementation of this program and the review of the final response required by action
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Item f. of the bulletin will be addressed in additional inspection
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reports.
No deviations or violations were identified.
4.
IE Bulletin Followup and Modification Testing, and IE Notice Followup
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(97703)(72701)(92701)
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(0 pen) lE Bulletin 86-03, 50-395/86-BU-03, identified a design
deficiency involving the ninimum flow recirculation path for Emergency Core Cooling System (ECCS) pumps.
The valves in the ECCS
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pump recirculation header were air operated and designed to fail
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closed when their control circuits loose electrical power or control air pressure.
The single failure (open) of the breaker associated
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with either of the two valves would isolate the minimum flow recirculation path to the pumps and cause the pumps to operate dead-headed.
Operation of the pumps deadheaded would result in pump damage and failure within minutes.
In response to this bulletin, the
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licensee evaluated the recirculation flow paths for all ECCS and
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Emergency Feedwater pumps.
The Residual Heat Removal, Reactor
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Building Spray, and Emergency Feedwater Systems were found not to have a single failure vulnerability in the minimum flow recirculation
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Evaluation of the charging / safety injection pump minimum flow line identified a single-failure vulnerability.
The discharge lines
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for each of the pumps are connected to a comon recirculation header l
to provide a test flow path and a recirculation flow path for minimum I
flow at times when the reactor coolant system exceeds the pump
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shutoff head.
The comon recirculation header is provided with a i
single motor operated valve, MVG-8106.
Spurious operation of I
MVG-8106 could result in loss of the recirculation flow path for
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minimum flow.
As corrective action during the present refueling
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outage, a power lockout will be provided to preclude spurious
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operation from causing a loss of miniflow. The power lockout switch will be installed on the Main Control Board in the Control Room,
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power to the valve motor operator will be controlled from the control
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room and will be removed when the valve is in the full open position.
i MVG-8106 is required to be manually operated from the main control i
board during an accident when transferring the safety injection pumps
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suction from the refueling water storage tank to the containment sump.
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This modification will require an administrative procedure revision
to first instruct the operator to transfer the power lockout to restore power to the valve motor. Because this modification has not
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been completed and is scheduled for the present refueling cutage, the
procedure revision recognizing valve MVG-8106 power lockout has not been
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made.
The inspector reviewed the post modification test require-ments contained in Engineering Instructions - 21156-CS.
The post
modification testing appeared to be adequate.
This item will remain open until completion of the modification and procedure revisions.
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(Closed) 50-395/T2500/16 Temporary Instruction 2500/16 provides guidance for inspecting pressurized water reactor facilities with movable in-flux mapping systems to determine whether licensees have performed a system review as a result of IE Notice 85-45, "Potential Seismic Interaction Involving the Novable In-Core Flux Mapping System Used In Westinghouse Designed Plants." The licensee has received aid
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reviewed IE Notice 85-45.
As a result of this review, two modifications are scheduled to be completed during RF04 which
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comenced September 17, 1988.
The modifications will provide an
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anti-derailment device for the flux mapping system movable cart assembly wheel, and provide lateral restraint to the lower portion of the flux mapping support to limit side sway. This item is closed.
l No deviations or violations were identified.
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Exit Interview
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The inspection scope and results were summarized on September 16, 1988,
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with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results. Proprietary
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information is not contained in this report.
Dissenting comments were
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l not rectived from the licensee.
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On October 7, 1988, additional inspection findings regarding Bulletin
85-03 differential pressure testing were discussed with A. Koon, j
Manager of Nuclear Licensing,
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