IR 05000528/1993002

Insp Repts 50-528/93-02,50-529/93-02 & 50-530/93-02 on 930111-0205.No Violations Noted.Major Areas Inspected: Licensee IST Activities & Verified Completion of Previously Identified Items

ML20044C564
Person / Time
Site:	Palo Verde
Issue date:	03/09/1993
From:	Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20044C562	List: IR 05000528/1993002
References
50-528-93-02, 50-528-93-2, 50-529-93-02, 50-529-93-2, 50-530-93-02, 50-530-93-2, NUDOCS 9303240165
Download: ML20044C564 (15)

Text

+,

r--

.

[

U. S. NUCLEAR REGULATORY COMMISSION

REGION V

!

i

.

Report Nos.:

50-528/93-02, 50-529/93-02 and 50-530/93-02

[

Docket Nos.:

50-528, 50-529, and 50-530 i

,

License Nos.:

NPF-41, NPF-51, and NPF-74

Licensee:

Arizona Public Service Company

P. O. Box 53999, Station 9082 Phoenix, Arizona 85072-3999

,

Facility Name:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Inspected at:

Palo Verde Nuclear Generating Station,

Wintersburg, Arizona Inspection conducted:

January 11 through February 5, 1993 Inspector:

C. Clark, Reactor Inspector, Region V

3"i* N Approved by:

M

f v

W. P. Ang, Chief Date Signed Engineering Section

.

Inspection Summary:

Inspection durina the period January 11 through February 5,1993 (Report Nos.

50-528/93-02, 50-529/93-02, and 50-530/93-02)

Areas Inspected: This routine announced inspection reviewed the licensee's f

inservice testing (IST) activities and verified completion of previously

'

identified open items.

'

Inspection Module 73756 provided' guidance for inspection of the Inservice Testing (IST) Activities.

Inspection Modules 92700, 92701, and 92703 provided l

guidance for the followup of previously identified items.

l f

.

9303240165 930309

,

DR ADOCK 050

i s

'

-

-

..

-

_ -. - - _ - _ _ _.,

-

_

..

.

~

!

!

'

.

t i

~ Safety Issues Management System (SIMS) Item:

,

None

.Results:

i General Conclusions and Specific Findings

.I

'

Surveillance testing of the turbine driven auxiliary feedwater pump AFA-Pol

,

safety related equipment was performed using an out of date revision of the

i procedure.

!

Significant Safety Matters:

None

{

.

Summary of Violation or Deviations:

One non-cited violation was identified. The violation concerned the use of an

cut of date procecure revision for surveillance testing of the turbine driven auxiliary feedwater pump AFA-P01.

{

Open-Items Summary t

Eight followup items were closed during this inspection.

l t

,

i i

i

,

!

,

t

!

!

!

I i

i

!

!

i

'

.

!

- -

.

-

.

'

I i

l

-

.

'

.

DETAILS i

,

I 1.

Persons Contacted r

J. Bailey, Director, Site Technical Support

!

J. Bergstedt, Quality Audits and Monitoring Specialist

!

• R. Bernier, Supervisor, Nuclear Regulatory Affairs

'

• T. Bradish, Manager, Nuclear Regulatory Affairs

• D. Ensign, Shift Supervisor, Unit 2 Operation

• D. Garchow, Manager, Performance Engineering

• D. Kanitz, Nuclear Regulatory Affairs, Engineer

• D. Larkin, Nuclear Regulatory Affairs, Engineer

• B. Linderlaub, Component Condition Monitoring Engineer i

• D. Oakes, Component Condition Monitoring Primary Discipline j

l Engineer l

• R. Pouquot, Supervisor, Quality Audits

• T. Weber, Supervisor, Component Condition Monitoring

Others l

• R. Henry, Salt River Project Site Representative

• J. Draper, Southern California Edison Site Representative U. S. Nuclear Reculatory Commissig E

• J. Sloan, Jr., Resident Inspector, Region V

!

The inspector also held discussions with other licensee and contractor

~

personnel during the course of the inspection.

l Denotes those attending the exit meetings on January 15 and/or

i

,

February 5,1993.

,.

2.

Inservice Testing of Pumps and Valves (73756)

!

,

The inspector reviewed and observed surveillance activities to verify

!

'

that technical specification requirements and licensee commitments for inservice testing (IST) were being met. On January 12-13, 1993, the inspector observed the performance of IST in Units 1 and 2.

a.

Unit 1 IST Activities

,

'On January 13, 1993, the inspector observed the monthly technical specification surveillance test of motor driven Auxiliary Feedwater

Pump AFB-P01. This IST-was performed in accordance with section 8.1 of surveillance test procedure 41ST-1AF03, Rev. 05.8, " Auxiliary feedwater Pump AFB-P01 Operability Test 4.7.1.2.a&c."

The testing was performed using approved procedures and properly calibrated

-

instruments. Pump test data and vibration data recorded.during the i

test met the procedure acceptance criteria. Surveillance personnel.

observed during this test appeared to be knowledgeable and performed the surveillance activities in an acceptable manner.

l-

>

\\

ll

.

.

-

,

b.

Unit 2 IST Activities On January 12-13, 1993, the inspector observed the performance of

the technical specification surveillance test of turbine driven

'

Auxiliary Feedwater Pump AFA-P01. The inspector noted the following:

The licensee had initiated the surveillance using Rev. 04.11 of surveillance test procedure 42ST-2AF02, " Auxiliary Feedwater Pump AFA-P01 Operability Test 4.7.1.2.a&c".

Rev. 04.12 of procedure 42ST-2AF02 was issued January 6,1993, with an effective date of January 12, 1993. The NRC inspector informed

,

the licensee that the procedure being used for the test was out of date and that Rev. 04.12 was in effect.

• The licensee placed the test on hold and obtained a copy of Rev. 04.12 of procedure 42ST-2AF02. The differences between Rev. 04.11 and 04.12 of the procedure were evaluated. The licensee concluded that the differences between these two revisions did not affect the test acceptance criteria nor how the surveillance test was performed. The inspector noted that

,

Rev. 04.12 added Sections 8.1.22.4 and 8.1.22.6 to the procedure to open and close root valve AFA-V131. This valve had to be opened and closed during the test to record the Steam Supply Pressure to pump AFA-P01, as indicated on instrument AFN-PI-55. This gauge was isolated during normal system standby operation as a result of operational concerns with associated excess flow check valves.

• Using Rev. 04.12 of the procedure, testing was restarted and satisfactorily completed to restore the inoperable equipment.

The licensee issued Condition Report / Disposition Request (CRDR)

e 2-3-0020 on January 13, 1993, to document this error.

Section 3.5.2 of Procedure 73AC-9ZZ04, Rev. 09.01, " Surveillance Testing," required that the most recent revision of the procedure be used for performance of surveillance tests. However, the inspector concluded that the differences between the revisions in question was of minor significance. No other 47 ;ances involving the use of the wrong procedure revision for performance of a surveillance test were identified during the inspection. This use of the wrong procedure revision appeared to be an isolated case.

Prompt corrective action for the identified condition was accomplished by the licensee.

In addition, a CRDR was issued for further review of the procedure controls. This violation is not being cited because the criteria specified in Section VII.B of the Enforcement Policy were satisfied.

(Closed Non-cited Violation 50-529/93-02-01).

i

..

.

.. -

.

3.

Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities (92700)

a.

(0 pen) Unit 1 LER 89-17-LO:

Four Penetrations in Gap Between Diesel Generator (DG) Buildina & Control Buildina lack Fire Barrier Separation.

A review of licensee corrective action for this LER was initiated.

However, the inspector was informed that a design change package (DCP) was being processed to install the required fire barrier seals and correct the reported condition. The DCP was scheduled to be submitted for licensee management review and approval on March 3, 1993. This LER will remain open until the DCP and its scheduled implementation date can be reviewed during a future inspection.-

.

b.

(0 pen) Unit 1 LER 92-10-LO:

Loss of Heatino. Ventilation. and Air i

'

Conditionino (HVAC) to Shutdown Equipment Due to Fire.

A review of licensee corrective action was initiated for this LER.

However, the inspector was informed that a DCP was required to correct the reported condition, and an action plan for development

,

of the modification to reconfigure the existing fire protection detection and suppression system was scheduled to be established by'

June 30, 1993. This item will remain open until the DCP, action

plan and scheduled implementation date have been established by the

licensee.

i

,

4.

Followup of Previously Identified Items (92701)

{

a.

(Closed) Followup Item 50-528/91-05-02: Maintenance Procedures will be Improved in Area of Detailed Tool Lists and Feedback from l

Previous Job.

l An NRC inspection of pressurizer code safety valve removal and installation activities identified that neither the Work Order (WD)

>

nor the procedure contained a detailed tool list for work performed i

in a radiation area.

Inclusion of tool lists in work instructions for repetitive work activities in radiation areas would reduce j

radiation exposure to maintenance personnel and help keep radiation exposure "As Low As Reasonably Achievable" (ALARA).

.'

.

The licensee acknowledged this concern and stated that they were working on the improvement of procedure tool lists through.

The development of model work instructions in accordance with

Procedure 30DP-0WP06, Rev. 3, "Model Work Instruction Control."

i t

An increase emphasis on previous work feedback through the

!

completion of the work enhancement forms identified in

Procedure 30DP-9MP01, Rev. 3, " Conduct of Maintenance."

!

t I

!

!

f

.

-

-

-

!

!

.

!

.

,

'

The inspector reviewed Procedure 31MT-9RCN, Rev. 3, " Pressurizer

!

Code Safety Valve Removal and Installation" and noted that it

.

contained an Appendix A, " Recommended Tools and Material." - While Appendix A identified a list of recommended tools, it did not identify any other wrenches or sockets by sizes other than torque

!

wrenches identified by torque range. Standard wrenches, sockets.

[

t and crowfoot wrenches, appeared to be required to disassemble and reassemble the valve 2-inch inlet flange fasteners and the 1/8-inch

outlet flange fasteners.

.

The inspector reviewed model work order No. 000151, Rev. 000, f

!

" Rework seat leakage of Target Rock solenoid valve" (written December 1991) and model work order No. 000568, Rev. 000, " Rework-Borg Warner 3/4 inch manual globe valve" (written June 1992). Both l

documents identified torque wrenches by torque ranges, but no

.

standard wrenches, sockets or other wrenches were identified in the i

work material lists. However, model work order No. 000151 contained

'

a Model Work Attachment (page 49) which stated in part that, "The

intent of this form is to develop a complete listing of tools and

'

material used in the performance of this work for inclusion in

.

future rework... Please list all additional Material and Test Equipment (M&TE), hand tools, special tools and/or any additional

material (s)....used to perform this work." Model work order No.

l 000151, Rev. 000 is applicable to approximately 342 valves. During

work on valve 3PCHNV845, in accordance with work order No. 00566004

,

'

(which was prepared using model work order No. 000151), a work order feedback (page 11) was generated that identified that an additional 11/16 inch standard socket and 1/2 inch crowsfoot wrench were used

L to perform the valve work.

Based on the inspector review of the latest model work instructions and the work order feedback page, it appears the licensee has

administrative instructions presently in place to improve tool lists, and the latest work packages are implementing these instructions. This item is closed.

b.

(Closed) Followun item 50-528/91-05-03:

Potential'Inadeauate Flowrates of Essential Chilled Water to Enaineered Safetv-Feature Air Handling Units.

-

,

L An NRC inspection of licensee activities related to NRC Information Notice 90-26, " Inadequate Flow of Essential Service Water to Room Coolers and Heat Exchangers for Engineering Safety-Features System,"

.

noted that American Air Filter (AAF) had supplied incorrect pressure

'

'

drop data to the lit.ansee. This incorrect pressur'e drop data was used by the licensee to balance the flow to the individual Air i

Handling Units (AHU's). As a result of the licensee using the

,

t incorrect pressure drop data, a licensee review determined that assurance that the Engineered Safety-Feature (ESF) air handling

'

units would perform their intended function during accident condition was indeterminate.

,

.

t

-

,

,

!

!

The inspector reviewed the following documents, and noted:

Incident Investigation Report 3-1-91-021 (PRS 1417), Rev. O,

!

" Potential for inadequate flow of essential chilled water through ESF Air Cooling Units", was issued July 12, 1991. This report identified that during startup testing the licensee balanced the essential chilled (EC) water system using incorrect pressure drop information, without taking actual flow measurements, which resulted in inadequate flow in some areas of the system. The root cause of the flow balancing deficiency was identified as failure of startup engineering to ensure compliance with specification / procedure requirements. During this investigation several other potential causes of inadequate EC system flow were also analyzed as part of the investigation.

,

Incorrect throttle valve position had previously been identified as a potential cause of inadequate EC system flow,

!

but corrective actions taken to the date of the incident investigation report had not prevented recurrence of this problem. This report also identified that Information Notice

,

90-26 was not evaluated in a timely manner.

l t

in response to the problems identified in the incident

'

investigation report, the licensee accomplished the following:

(1) The EC system flow balancing was performed in all three F

units using direct flow measurements.

(2) A program was established to performance test safety related heat exchangers during each refueling outage.

(3) A procedure was issued to ensure valve positions are verified in a consistent manner in accordance with the most recent flow balancing by direct flow measurements.

,

The incident investigation report also recommended that senior engineering management assess the need for engineering training on identifying problems that represent potential operability concerns and providing the appropriate level of documentation.

The licensee's engineering management assessed the need for additional training and determined that a letter to the engineering staff would be sufficient. The licensee's engineering management issued letter No. 281-00454-JAB /MFH to their staff on March 27, 1991, to reinforce the problem identification and evaluation requirements.

Vendor corrective action report (CAR) No. VC91-008, issued

February 19, 1991. This CAR identified that incorrect water

,

side pressure drop data was provided by American Air Filter (AAF), and requested AAF to assess the failure of the AAF Quality Assurance Program. The AAF response to the licensee provided the cause and AAF corrective action for the reported

.

.

!

,

,

AAF QA program deficiency. The response from AAF was reviewed,

!

evaluated and accepted by the licensee on September 3, 1991.

Corrective action report (CAR) No.91-002, issued March 30,

1992.

" Recommended action 3" of this CAR identified that the licensee should restrict future purchases of cooling coils from

AAF to "Like For Like" replacement. Other coil designs would require submittal of design calculations and procedures for determining waterside pressure drop.

,

The inspector reviewed the documents identified above and other i

'

associated documents and concluded that the licensee was taking adequate corrective for establishing satisfactory essential chilled water flow rates. Furthermore, the licensee actions in response to

!

the incident investigation recommendations were reasonable. This item is closed.

c.

(Closed) Followup Item 50-528/91-05-04: Check Miniflow Calculations for Condensate Transfer and Auxiliary Feedwater Pumps.

An NRC inspection of licensee action for NRC Bulletin 88-04,

[

" Potential Safety-Related Pump loss", identified a concern with licensee calculation No.13-MC-CT-303, " Evaluation of Auxiliary Feedwater and Condensate Transfer Systems for NRC Bulletin 88-04."

A common header exists on the discharge side of the auxiliary feedwater (AF) pumps and condensate transfer (CT) pumps. This

calculation documented the evaluation of the AF and CT pump interaction in the miniflow mode. The calculation identified a

worst case miniflow of 26.3 gallons per minute (GPM) for the CT pump. Minor errors and omissions in the calculation were identified. While the net effect of the errors and omissions were small, they would reduce the calculated CT pump miniflow. The CT

pump manufacturer, Ingersoll Rand, recommended a miniflow of 30 GPM.

In response to the inspector concern, the licensee committed to I

revising the calculation to account for additional pump degradation beyond the maximum 10 percent pump degradation of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (CODE) and to submitting the revised calculated CT pump

miniflow to Ingersoll Rand for their concurrence. This licensee's action was completed and the results documented in Rev.1 of the calculation.

Based on review of the licensee's revised calculation, the inspection results for the Unit 1 CT pumps, and the licensee verification of satisfactory miniflow for the CT pumps, the inspector considered this item adequately resolved. This item is closed.

i i

f

.

.

'

r

,

d.

(Closed) Followup Item 50-528/91-05-05: Review Assessment of Condensate Transfer Pump Operability for Extended Miniflow Operations.

An NRC inspection of licensee action for NRC Bulletin 88-04,

" Potential Safety-Related Pump Loss," identified an issue of what was an acceptable pump operating time for condensate transfer (CT).

pumps operating under miniflow conditions. The pumps were manufactured by Ingersoll Rand, and they originally recommended a minimum flow of 30 gallons per minute (GPM) during miniflow

conditions.

The licensee calculations identified that minimum flow for the CT pumps could be less than 30 GPM during miniflow conditions. As a result of the lack of clear guidance from the pump manufacturer on acceptable pump operating time under miniflow conditions, the licensee elected to disassemble the Unit 1 CT pumps and inspect for evidence of low flow damage to the internals of the pumps.

l The CT pumps had been in operation for over seven years and had experienced considerable testing, especially during plant startup, in the minimum flow condition. The Unit 1 pumps were disassembled and inspected in accordance with work order No. 00419536 and 00493280.

The inspector reviewed the following documents and noted:

Work order Nos. 00419536 and 00493280 provided instructions for disassembly and inspection of the Unit 1 CT pum9s. The results of the Unit 1 CT pump inspections did not identify any evidence of impeller low flow damage and verified that the wear ring clearances were within tolerances.

,

Engineering evaluation request (EER) No. 91-CT-007 and an

attachment (Instruction Change Request No. 24508) recommended inspecting CT pumps on a ten year interval. After reviewing this recommendation the licensee decided that condition monitoring would be acccmplished by component vibration analysis during the quarterly ASME Section XI testing of the CT pumps in lieu of disassembly and inspection every ten years.

• An attachment to Rev.1 of licensee calculation No.13-MC-CT-303, " Evaluation of AF and CT systems for IEB 88-04," contained confirmation from the pump manufacturer that operation of the CT pump for as much as ten hours at a minimum flow rate.of 25-GPM on a once-a-year basis was acceptable. The pump manufacturer also agreed that with the identified pump operating speed and impeller diameter considered, it could be

,

assumed that the specified minimum flow for long term operation is not an absolute value.

,

.

-

..

!

After reviewing the above documents, the licensee's assessment of

!

the CT pumps operability under conditions of extended operation in

,

the miniflow mode, and the additional pump information submitted by the vendor, the inspector concluded that this item had been

,

'

satisfactorily resolved. This item is closed.

e.

(Closed) Followup Item 50-528/91-05-06: Review Maintenance and Operatino Procedures for Auxiliary Feedwater and Condensate Transfer

.

Pumos

!

,

An NRC inspection identified that the licensee had committed to perform routine maintenance and testing of the auxiliary feedwater (Af) and condensate transfer (CT) pumps as recommended by the

.

>

vendors, until a trending system could be developed. As of April 26, 1991 the licensee had not developed a trending system for the AF

'

and CT pumps. The licensee stated that they had established a

Quarterly Pump Vibration Monitoring Program in lieu of establishing a trending system. The licensee considered that increased pump

vibration can be an indicator of pump degraded performance.

The licensee committed to documenting this change from their earlier i

trending commitments in a letter to the NRC. The licensee issued a

letter No. 161-04032-WFC/MEP/JMQ on July 1,1991 to revise their commitments as noted above. The letter was reviewed by the NRC inspector and was found to have accomplished the commitment change as previously noted.

The NRC inspector reviewed the following licensee's procedures to ensure maintenance and operating procedures reflected the licensee's latest commitments:

31MT-9AF01, Rev. 2, procedure change notice (PCN) 8, " Auxiliary e

Feedwater Pump Disassembly / Assembly."

e 40ST-9AF06, Rev. 0.00, " Auxiliary Feedwater Pump AFN-P01 Monthly Valve Alignment."

e 40ST-9AF07, Rev. 0.02, " Auxiliary Feedwater Pump AFA-P01

'

Monthly Valve Alignment."

.

e 40ST-9AF08, Rev. 0.02, " Auxiliary Feedwater Pump AFB-P01 Monthly Valve Alignment."

e 410P-1AF02, Rev. 8.03, "Non-Safety Auxiliary Feedwater Pump

,

Operation."

400P-9CT01, Rev. 0.00, " Condensate Transfer and Storage (CT)."

e

'

40ST-9CT01, Rev. 00.04, " Condensate Transfer Pump Operability."

e The above procedures appeared to reflect the licensee's latest commitments for these pumps.

.

-

.

.

l

.

!

.

Based on review of the documents identified above, and discussions with the licensee's staff, the inspector concluded that this item had been satisfactorily resolved. This item is closed.

f.

(Ooen) Followup 50-528/91-25-01: Motor Sizina For Dearaded Voltaae An NRC inspection identified that licensee calculations showed that the performance of certain GL 89-10 MOVs with Class 1E motors was inadequate to perform acceptably under worst case design conditions at 75% degraded voltage.

The licensee has evaluated this concern and is scheduled to submit information on this item to NRR and review its status by June 30, 1993. This item will remain open pending licensee submittal of new information to NRR and pending subsequent NRR review.

g.

(Closed) Followup Item 50-528/91-25-04:

Review procedures for Periodic Verification of MOV Capability A previous NRC inspection reviewed the program which the licensee had established in response to Generic Letter (GL) 89-10. A concern was identified regarding the performance of GL 89-10 recommended periodic verification of MOV capability by static testing alone.

The NRC inspector reviewed the following licensee documents and procedures.

Based on the review, the following information was obtained.

,

Section VI.A of the Implementation Plan For NRC Generic letter

89-10, Rev.1, states in part that "At this time Palo Verde Nuclear Generating Station (PVNGS) foresees the development of

,

a static test methodology that can confirm adequate available thrusting margin to ensure design basis operability following

,

preventive MOV maintenance.... Periodic testing requirements can also be satisfied by the performance of post maintenance baseline testing."

Section 3.4.3.2 of. procedure 73PR-9ZZO4, Rev. 04.01, " Valve e

Motor Operator Monitoring and Test Program" states in part that

" Initially, the frequency identified in GL 89-10 of 5 years or 3 refueling outages (whichever is longer) shall be the interval for performing periodic testing." This program procedure did not identify which specific testing method (dynamic / static)

will be used to perform periodic testing.

A licensee response to regulatory commitment tracking system e

(RCTS) commitment 40799, in a January 13, 1992, letter (No.

320-00141-MSC), stated in part that:

(1)

...the MOV Program Document... states that initially, the

"

frequency identified in GL 89-10 of 5 years or 3 refueling outages (whichever is longer) shall be the interval for i

-

-

-

-

.

.

q w

!

a

,

'

!

.j performing periodic testing. The periodic test frequency l

may be increased or decreased following evaluation by the l

Component & Specialty Engineering (C&SE) and proper i

justification by C&SE."

(2)

" Currently, PVNGS plans... to perform static diagnostic

tests to meet the periodic testing requirements. This

'

static test methodology may also be changed following an evaluation and justification by C&SE."

i After reviewing the above information and discussions with licensee j

staff the inspector concluded that the licensee had implemented the

'<

static test methodology for periodic testing but has not completed development of a justification for this position. As of the.date of i

this inspection, no periodic testing of MOVs had been performed i

using the static test methodology. This program weakness will be

reviewed further during subsequent NRC GL 89-10 M0V inspections

!

tracked under Followup Item 91-25-02. This item is closed.

i h.

(0 pen) Followuo Item 50-528/91-25-08:

Review licensee's control of

!

vendor services and software l

,

An NRC inspection identified that although the licensee verified l

that Motor Operated Valve Analysis and Test System (MOVATS)

'

Incorporated personnel had been certified to comply with MOVATS

';

standards, the licensee had not verified the MOVATS certification to

be in compliance with the licensee requirements. Furthermore,

!

M0 VATS Incorporated had issued updated software for their valve test

!

equipment, which the licensee was apparently using without verifying compliance of the software to the PVNGS standards. Prior to using

any new software, the licensee has a procedure that requires the new software to be checked to verify acceptable performance.

l An inspection was initiated to evaluate licensee action regarding this item. The licensee stated they had verified compliance of all i

MOVATS Incorporated provided software. However, at the time of this

,

inspection, the licensee stated that while they had implemented new

administrative controls for the verification of new software, they were still in the process of evaluating the vendor services concern.

This item will remain open pending completion of licensee evaluation and subsequent inspector review.

!

i.

(Closed) Followup Item 50-528/91-25-09:

Review Licensee's

Incorporation of Margin for Diaanostic Eauipment Accuracy and Rate-

Loadina An NRC inspection identified that the licensee had not addressed M0 VATS Incorporated Engineering Report 5.0, Rev. O, January 1991,

" Equipment Accuracy Summary," which provided guidance for the

!

!

consideration of rate-of-loading effects that might reduce the.

available thrust delivered by the motor operator under high

. differential pressure conditions.

.

,

!

l

.

-

.

.

The NRC inspector reviewed licensee documents, procedures, and determined the following:

Section 5.2.5 of licensee procedure 39DP-9ZZ01, Rev. O, "PVNGS

Guidelines for Evaluation of Motor Operator Valve Dynamic Test Data," lists ITI-MOVATS ER-5.0, Rev. 4, dated March 13, 1992 as a developmental reference.

A licensee response to regulatory commitment tracking system e

(RCTS) commitment 40802, in a January 13, 1992, letter (No.

320-00141-MSC), stated in part that, "The MOVATS accuracy and rate-of-loading issues are still being evaluated...C&SE intends to consider other industry experience as part of the rate-of-loading evaluation.... Evaluation of these issues are ongoing and will take more time to properly assess before any i

implementation takes place."

j Based on the review of the above information and subsequent discussions with the licensee staff, the inspector concluded that i

the licensee was still in the process of evaluating the rate-of-load i

issue. This program weakness will be reviewed as part of a future

NRC GL 89-10 MOV inspection tracked under Followup Item 91-25-02.

This item is closed.

l 5.

Followup on Corrective Actions for Violations and Deviations (92703)

a.

(Closed) Violation 50-528/91-44-01: Limitoraue Valve Operators Missing Fasteners.

An NRC review of various Motor Operator Valves (MOV's)

configurations in all three units identified approximately seven l

valves that either were missing limit switch cover p' ate fasteners, l

had loose fastener installations or incorrect fastener material installations.

t All the valves found with these nonconforming fastener

,

configurations had various past maintenance activities performed where the subject limit switch cover plates and associated fasteners were removed. The licensee issued condition report / disposition request (CRDR) 9-1-0282 to determine the root cause of the failure to restore the MOV limit switch covers properly and the cause of fastener material substitution.

In a February 14, 1992, licensee

-

reply letter (No. 102-02113-WFG/TRB/JRP) to this violation, the licensee stated the following:

e The reason for the violation was personnel error by maintenance

,

personnel in restoring certain MOV limit switch covers to proper design configuration following maintenance activities.

Maintenance personnel who perform work on MOVs were briefed on

'

e the identified conditions and the importance of proper restoration of MOVs was stressed.

i i

l

-

,

'

.

e Based on similar problems recently identified by the licensee and NRC, an investigation of equipment hardware configuration to determine if there are additional causes would be performed.

e Licensee insppctions were initiated in Units 1, 2, and 3 to walk down accessible safety related MOV operators to verify that covers and fasteners were properly installed.

After reviewing the above information, the inspector concluded that the licensee actions implemented to identify the root causes of the loss of MOV limit switch cover fasteners configurations and to i

implement corrective actions to prevent the recurrence of poor maintenance were satisfactory. This item is closed.

b.

(0 pen) Violation 50-528/91-25-02:

Failure to Establish Appropriate Acceptance Criteria for MOVs An NRC inspection identified that MOV test procedures did not contain acceptance criteria for the design basis test data, nor did

.

these procedures use the test data as feedback into their calculations.

The licensee responded to this violation in letters dated October 24,1991 (No.102-02077-WFC/TRB/JRB), July 10, 1992 (No. 102-02201-

,

WFC/JRB) and October 7,1992 (No.102-02306-WFC/TRB/JNI). The NRC replied to the above identified licensee responses in letters dated

-

February 28, 1992 and August 27, 1992.

The licensee responses to the Notice of Violation as noted above, committed to adding the acceptance criteria to procedure 39DP-9ZZ01.

This same letter also identified that previous test data would be reviewed against this new acceptance criteria within six months of issuance of the procedure.

Procedure 39DP-9ZZ01, Rev. 00.00 was issued with an effective date of October 22, 1992. The inspector reviewed Procedure 39DP-9ZZ01, Rev. 00.01 and determined that it contained acceptance criteria instructions for the design test data and feedback of the test data

,

into the licensee's calculations. The licensee had initiated evaluation of previous obtained test data. Evaluations of the previous test data results and the feedback of this data into thrir calculations from previous tests was not yet complete.

Pending completion of licensee evaluations of the previous derign basis test data results, this item will remain open.

t

_-.

,

.

.

,

13 i

6.

Exit Meetina

!

'

The inspector met with the licensee management representatives denoted in Section 1, on January 15, and February 5, 1993. The scope of the inspection and the inspector's findings up to the time of the meetings were discussed. The inspector informed the licensee.that additional

.

information had bean requested, and this information would be reviewed in

!

the NRC Regional Office in order to complete the inspection. The licensee acknowledged the inspector's findings.

i

<

i

,

,

I

,

>

e

+

!

t P

f