ML17262A862
| ML17262A862 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/04/1992 |
| From: | Eapen P, Prividy L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17262A861 | List: |
| References | |
| 50-244-92-80, GL-89-10, NUDOCS 9205260069 | |
| Download: ML17262A862 (42) | |
See also: IR 05000244/1992080
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
R p
N
.
2L2%22 K-
Docket No.
~244
License No.
QPR~1
Licensee:
R
he ter
And Electric
o
ration
Facility Name:
Inspection At:
R E
inn
Nuclear Power Pl nt
OJ
'
k
Inspection Conducted:
A ri16-10
1
2andA ri120
1
2
Inspection Team Members:
Harold Gregg, Sr. Reactor Engineer
Leanne Kay, Reactor Engineer
Francis Young, Sr. Resident Inspector
Mark Holbrook, Contractor, INEL
t(
nard J.
rividy, Team Leader,
Systems
Sec ion, EB, DRS
D te
'I
Approved By:
Dr. P. K. Eapen, Chief,
ystems Section,
Engineering Branch, DRS
Date
In
ection Summa:
See the Executive Summary
9205260069
920514
ADOCK 05000244
6
0
TABLE
F
NTENT
~Pa e
EXECUTIVESUMMARY........................ ~...... ~......
3
1.0
INTRODUCTION .......~ . ~............................
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2.0
THE LICENSEE'S GENERIC LETTER 89-10 PROGRAM
2.1
Scope and Administration of the Program.......
2.2
Design-Basis Reviews... ~..............,
2.3
Diagnostics Systems ....'....... ~......
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2.4
.MOV Switch Settings and Setpoint Control ......
2.5
Motor-Operated Valve Testing... ~.... ~.....
2.6; MOV Maintenance and Post Maintenance Testing ..
2.7
Periodic Verification of MOV Capability
2.8
MOV Failures, Corrective Actions, and Trending ..
2.9
Motor-Operated Valve Training
2.10
Industry Experience and Vendor Information .....
2.11 Schedule...........................
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3.0
WALKDOWN.......'...........................
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4.0
CONCLUSION
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5.0
UNRESOLVED ITEMS................... ~........
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6.0,
EXIT MEETING
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Table
1 - Summary of Licensee Actions to Resolve Inspection Findings
Appendix A - Persons
Contacted
EXE
TIVE
MMARY
The Nuclear Regulatory Commission (NRC) conducted a team inspection at the R.E. Ginna
Nuclear Power Plant on April 6 - 10, 1992, 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, 3
and 4) provided recommendations
to the licensees for the development of adequate
programs to ensure operability of safety-related
motor-operated valves (MOVs) during design
basis conditions.
The team observed strengths in the licensee's
management
support to the MOV program and
in the area of diagnostic test capabilities.
The licensee's initiative in utilizing a multi-channel
torque thrust cell diagnostic system was noteworthy.
The personnel involved with the
program demonstrated
excellent knowledge and technical capabilities and interfaced well with
other organizations to support the motor-operated valve program.
The licensee has developed
an effective training program including refresher training for diagnostic testing.
The
licensee's MOV program meets the schedule recommended
The licensee has performed differential pressure testing for several safety-related MOVs in
the program and has scheduled
the performance of additional differential pressure testing in
the upcoming outage.
Upon completion, twenty tests will have been conducted to cover
forty-eight MOVs. The exclusion of four residual heat removal valves from the scope of the
program, failure to review design basis worst case conditions as relied upon in normal,
abnormal, and emergency procedures,
and an inadequate margin in setting the torque switches
for power-operated
relief valve block valves 515 and 516 were some of the concerns
identified.
The licensee acknowledged
the concerns listed in Table
1 and agreed to review
th'ese concerns for resolution.
There were no violations or deviations identified during this inspection.
The team concluded
that, with few a exceptions,
the licensee has developed
a motor-operated valve program
consistent with the recommendations
1.0
INTRODUCTION
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
(MOVs) 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 Generic Letter 89-10 to
provide the results of the public workshops.
En Supplement 2 (issued on August 3, 1990) to
Generic Letter 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
motor-operated valve tests, the staff issued Supplement
3 to
Generic Letter 89-10 on October 25, 1990, which requested
that boiling water reactor
licensees evaluate the capability of motor-operated valves used for containment isolation in
the steam lines to the high pressure coolant injection system and reactor core isolation cooling
system, in the supply line to the reactor water cleanup system, and in the lines to the isolation
condenser
as applicable.
On February
12, 1992, the staff issued Supplement 4 to Generic Letter 89-10 excluding considerations be made for inadvertent operation of MOVs from the
scope of Generic Letter 89-10 for Boiling Water Reactors.
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 five years or
three refueling outages,
whichever is later, from the date of the generic letter
(June 28, 1989).
The NRC inspection team used Temporary Instruction (TI) 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
'ocused
on Part
1 of the temporary instruction (TI), which involves a review of the program
being established
by the licensee in response
2.0
THE LICENSEE'S GENERIC,LETTER 89-10 PROGRAM
Rochester
Gas And Electric Corporation (ROTE) provided their response to Generic Letter 89-10 for R.E. Ginna Nuclear Power Plant in a letter to the Nuclear Regulatory Commission
(NRC), dated December 28, 1989.
The letter stated that Ginna would comply with the
Gen'eric Letter recommendations;
T
The team reviewed the licensee's
response to the generic letter and the program details with
licensee personnel.
The inspection results related to each aspect of Generic Letter 89-10 are
described below.
2.1
Scope and Administration of the Program
The program administration was reviewed to assure. that the licensee has an adequate program
plan and schedule and has delineated responsibilities to.complete the Generic Letter 89-10
program commitments.
The Ginna Nuclear Power Plant program plans to address Generic Letter 89-10, "Motor-
Operated Valve Qualification Program Plan," Revision 0, which was issued on
February
1, 1989, documented
the licensee's MOV program description.
It adequately
described the program responsibilities assigned to licensee organizations and the requirements
to be employed in the development of calculations.
Mechanical Engineering has the overall
responsibility for coordination of program implementation and ensuring that the MOV
program complies with the intent of Generic Letter 89-10.
An Electrical
Preventive'aintenance
(PM) Analyst has been assigned from Maintenance to coordinate the efforts of
the affected working groups.
These groups include plant and corporate engineering,
operations,
maintenance,
training, and contractors.
In addition, the PM Analyst provides the
technical oversight of licensee and contractor activities with respect to MOVs.
The licensee's MOV Program Plan includes an evaluation for recovery from mispositioning
of MOVs as defined in Generic Letter 89-10.
However, the licensee stated the program
review includes those MOVs subjected to design basis conditions during either normal
operation or abnormal events only as described in Chapter 15 of the Ginna Station Updated
Final Safety Analysis Report (UFSAR) only.
Mispositioning is discussed
further in
Section 2.2, "Design Basis Reviews" of this report.
Piping and instrumentation diagrams, emergency operating procedures,
technical
specifications and the updated final safety analysis report were reviewed to verify that the
valves recommended
in GL 89-10 were included in the program.
The inspectors verified on
a sampling basis that the safety related MOVs in the reactor coolant, residual heat removal
and safety injection systems
had been included in the program.
However, review of the
residual heat removal system indicated that the licensee had excluded four MOVs which serve
as isolation valves for reactor coolant piping without adequate documented justification.
These valves are designated
as RHR valves 700, 701, 720, and 721,
These valves are part of
the licensee's In-Service Testing (IST) program, but were not considered to be part of the
Generic Letter 89-10 program.
Licensee personnel
stated that these valves were deenergized
during power operations and were only relied upon for system pressure integrity due to Ginna
being considered
a Hot Shutdown plant'.
ROTE did agree to review the exclusion of these
valves from the Generic Letter 89-10 program.
The team considered this issue to be
.
unresolved pending further NRC review.
(Unresolved Item 50-244/92-80-001)
The team noted that a feedback mechanism exists in the program description for evaluating
the impact of design basis test results 'of the previous methodology'used
to determine MOV
capability, thrust requirements,
and switch settings.
The feedback process utilizes an MOV
Field Request (MFR) and nonconformance report (NCR) where appropriate.
2.2
Design-Basis Reviews
Item "a" of the Generic Letter 89-10 and Generic Letter 89-10, Supplement
1, Question 16,
recommends that licensees review and document the design-basis for the operation of each
motor-operated valve within the program for such parameters
as
1. Differential Pressure
2.
Flow
3.
Valve Orientation
4.
External Factors
5.
Ambient Temperature
6.
Fluid Temperature
7.
Minimum Voltage
Rochester Gas &, Electric (RG&E) had completed their review for differential pressure, flow,
and fluid temperature in Design Analysis NSL-5080-0002, EWR 5080, "Design Analysis,
Ginna Station, GL 89-10 MOVs," Rev. 2, dated March 24, 1992.
This analysis documented
the expected worst-case differential pressures for MOVs which are required to function
during accident scenarios identified in Chapter
15 of Ginna's UFSAR.
Differential pressures
were also developed for certain MOVs as part of the licensee's Inspection and Enforcement
Bulletin (IEB) 85-03 program.
These differential pressure values were documented in Design
Analysis EWR 4348, "Ginna Station Motor Operated Valves IEB 85-03," Rev. 0, dated
April 30, 1986, Section 6.
In Section 1.0 of NSL-5080-0002, the licensee had taken exception to the definition of
"design basis events" as stated in footnote 2 of GL 89-10.
Specifically, RG&E only included
those MOVs required to function during the accident scenarios documented in the UFSAR's
Chapter 15 and did not consider MOVs associated
with Appendix R, Station Blackout, and
other external or natural phenomena
to be part of their generic letter program.
Further,
dynamic normal operational conditions that are more severe than those discussed in
Chapter
15 of the UFSAR were not addressed.
The licensee had not conducted
a review of the normal, abnormal, and emergency procedures
to ensure that the design basis for the MOVs envelope the worst-case conditions under such
operation as required by Section 2.1.2 of EWR 5111, "Motor-Operated Valve Qualification
Program Plan," Rev. 0, dated February
1, 1992.
The licensee indicated that these reviews
would be done, but only for procedures
related to the UFSAR's Chapter
15 accident
scenarios.
Because this issue is related to the licensee's definition of design basis events, the
team considered
this issue to be unresolved pending licensee's review of the normal,
abnormal, and emergency procedures
and assurance
that the worst case conditions from such
operation are incorporated in the design basis for the MOVs.
(Unresolved Item No. 50-
244/92-80-002)
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In general, the licensee used conservative assumptions for determining differential pressure.
However, the inspectors noted that the licensee utilized a less conservative assumption
regarding reactor pressure.
For example, the power-operated relief valve (PORV) block
valves utilized the nominal pressure of 2235 psig even though the PORV has a liftsetpoint of
2335 psia and a reset point of 2315 psia without documenting the technical justification. The
licensee agreed to review this matter for resolution.
While the licensee had addressed
flow and temperature considerations for functions related to
the closed direction, neither parameter had been considered for the opening direction.
Question
16 of Supplement
1 of GL 89-10 states that the effects of factors such as flow
should be addressed
analytically together with the most conservative differential pressure to
ensure that design basis conditions are adequately accounted in the test program.
The
licensee stated that the maximum flows achievable in existing system alignments would be
used in design-basis differential pressure
tests for both directions, as applicable, and that the
'acceptability of the flow obtained willbe addressed
in the documented resolution of test
results.
The licensee's
design basis reviews did not address seismic considerations that may arise.
when MOV thrust settings are increased.
The licensee plans to complete this task and
incorporate this information in the design basis documents.
The inspectors reviewed the licensee's
design analysis EEA-06001 and verified that the
thermal overload devices (TOLs) were adequately
addressed
in the MOV Program.
At Ginna
TOLs are bypassed
in most of the safety-related motors.
The TOLs that remain in the circuit
were adequately
sized and these resistances
incorporated in the degraded voltage calculations.
The licensee had performed degraded voltage calculations to determine the expected worst
'ase
voltage at the terminals of the MOVs. Minimum voltage was calculated in accordance
with Ginna Design Analysis EEA-06001.
The calculations utilized a computer model and
considered
impedances of MOV power cables and the effects of accident temperatures,
potential voltage drops across thermal overload heaters,
and utilized a conservative factor of
locked rotor current for determining minimum voltages available.
minimum voltages expected at terminals of the vital batteries and the end of life battery
voltages were considered in determining design minimum voltage as documented in licensee
calculation EEA-09004.
However, the inspectors noted that the licensee's design basis document, NSL-5080-0002,
failed to address
the applicability of degraded voltage considerations for MOVs 825 A and B,
and 871 A and B.
Licensee personnel
stated that this was an inadvertent omission from the
document and that degraded voltage considerations would be included for these valves.
The inspector independently verified the calculations for minimum motor terminal voltages
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during the inspection.
The team concluded that the methodology for determining MOV
capabilities un'der degraded voltages for both AC and DC MOVs required to function during
accident scenarios was conservative.
2.3
Diagnostics Systems
The Motor-Operated Valve Analysis and Test System (MOVATS) diagnostic equipment was
used to set the torque switches and perform diagnostic evaluations for motor-operated valves
addressed
in the Generic Letter 89-10 program.
All safety related valves have been evaluated
using MOVATS equipment under static conditions to provide baseline information.
Additionally, many safety-related valves have been tested under differential pressure
conditions.
Some of these differential pressure
tests have utilized a torque thrust cell (TTC)
device that measures
thrust directly.
However, for other valves where positioning of the
TTC is not physically possible, measuring devices such as stem strain rings and stem strain
transducers
are used in conjunction with load cells and a thrust measuring device (TMD) for
measuring spring pack displacement.
The team observed that the licensee is actively
evaluating and implementing recent diagnostic testing information and technologies into the
MOV program.
The licensee has received officialnotification from MOVATS regarding the diagnostic system
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inaccuracies
and their impact on the MOVs at Ginna.
At the time of this inspection, the
licensee was evaluating the above information using the guidance provided by Nuclear,
Management and Resources Concil, Inc. (NUMARC), and MOVATS Engineering Report
No. 5-2.
The licensee's preliminary evaluation identified 42 MOVs may be impacted by the
MOVATS diagnostic system inaccuracies.
The licensee stated that the motor-operated valve diagnostic systems vendor equipment
validation results,
as re'ported by the Motor-Operated Valve User's Group (MUG) have and
will continue to be reviewed and the inaccuracies from such reports and test data will be
incorporated in Ginna's MOV program for acceptance criteria where appropriate.
The
licensee has incorporated equipment inaccuracies
when setting torque switches using
MOVATS equipment.
The licensee also stated that MOVs in the Generic Letter 89-10
program will be reviewed for operability as the diagnostic equipment inaccuracies become
available from actual tests or industry equipment validation tests.
Actions, ifrequired, will
be taken as appropriate.
t
2.4
MOV Switch Settings and Setpoint Control
Item "b" of Generic Letter 89-10 recommended
that licensees review and revise as necessary,
- the methods used for selecting and setting all motor-operated valve switch settings.
The licensee's methodology. for selection and setting of motor-operated valve switches is
provided in Rochester
Gas & Electric Mechanical Engineering Design Guide, Proc. No.
MDG-22, "Safety-Related MOV Thrust Calculations," Rev. 0, dated March 9, 1992.
The
licensee had completed thrust calculations for approximately 30 MOVs that willbe tested
during the next outage,
Licensee personnel stated that the balance of MOV calculations will
be completed prior to testing.
A standard industry equation was used for determining the required minimum thrust for gate
and globe valves.
The worst case differential pressures identified in each MOV's design-
basis calculation were applied in sizing and. setting the MOVs for opening and closing
capability, where applicable.
A 0.50 valve factor was identified for the Anchor Darling
, parallel disk PORV block valves.
However, the licensee was assuming less-conservative
0.20
and 0.30 valve factors for other parallel disk and flex-wedge gate valves, respectively,
without justification.
Upon identification of this concern by the inspector, the licensee agreed
to review this matter for resolution.
The licensee used a 1.10 valve factor assumption for
The licensee used the nominal valve diameter to determine the disk area term
when orifice diameter was not available.
The licensee's
actuator capability calculations utilized a less conservative assumption of 0.15
for stem friction coefficient without documented justification.
The assumption of 0.15 as the
stem friction coefficient may not be valid unless specific maintenance,
lubrication,,and
frequency requirements
are implemented to ensure the continued high efficiency of torque to
thrust conversion.
The licensee agreed to review this matter for resolution.
The licensee added an additional safety factor (25%) to account for rate of loading effects for
MOVs in the generic letter program that were not considered practicable to dynamically test.
Rate of loading effects require MOVs to have higher available thrust during high differential
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pressure conditions than during static conditions.
The inspectors noted that the licensee had
not addressed
the rate of loading effects for partial differential pressure and/or flow testing.
The licensee agreed to review the methodology for testing under partial differential pressure
and flow conditions and incorporate the necessary
margins in this methodology as
appropriate.
The inspectors also noted that RGAE's generic letter program did not formally identify a
feedback process where an evaluation of differential pressure test results would be used to
determine available thrust margins.
However, the licensee did evaluate the apparent margin
between thrust at the torque switch trip and the thrust required to overcome differential
pressure
as part of their existing dynamic test program. Ifa test was conducted at less than
design basis conditions, thrust results were extrapolated
to 100% worst case conditions prior
10
to making this comparison.
An operability review was also performed as a part of this
evaluation.
The licensee's existing program did not adequately assure that the margin
between the required and available thrusts is adequately evaluated and verified through in situ
testing or comparison.
The licensee agreed to resolve this matter.
The licensee determined the maximum allowable thrust based on structural limits, motor
undervoltage capability, and spring pack capability.
The licensee included an adjustment in
the structural limitand motor undervoltage capability calculations to account for diagnostic
equipment inaccuracies, while ultimate spring pack capability was evaluated during tests.
Actuator ratings are also adjusted to account for additional thrust due to inertia.
The licensee used the open limit sw'itch to control the opening of all generic letter rising stem
MOVs. The open limit,switch was set at approximately 95% of the open stroke.
switch bypass was in effect for the first 30% to 35% of the open stroke to prevent high
unseating loads from prematurely stopping valve operation.
For the closing direction, all
rising stem MOVs utilize the torque switch to control motor operation to ensure adequate
seating of the valve.
Butterfly MOVs are controlled in both directions with the position limit
switches.
The inspectors reviewed several thrust calculations, including, those for the PORV block
valves, MOVs 515 and 516.
For these Anchor Darling 3 inch parallel disk gate valves, the
licensee had assumed
a valve factor of 0.50.
Because these valves are difficultto test at
design basis conditions, the licensee was including a 25% thrust margin to account for rate of
loading effects.
The licensee determined that these MOVs would not have adequate margin
to close ifa design basis pressure of 2235 psig is required.
The licensee was developing an
action plan to resolve this concern for these MOVs. This item is unresolved pending the
licensee's resolution of this concern.
(Unresolved Item 50-244/92-80-003)
The licensee's
method to control torque switch settings was reviewed,
Work packages
documenting the as-left thrust and torque switch conditions have been kept on file by the
Electrical PM Analyst.
As part of the implementation of the generic letter program, the
licensee is developing a new setpoint control program that includes an electronic database.
Licensee personnel indicated that this system will include a quality assurance
review and
approval process to ensure that MOV switch settings are controlled in accordance with the
facility's quality assurance
program requirement.
2.5
Motor-Operated Valve Testing
Item "c" of the generic letter recommended
that licensees
test motor-operated
valves in situ
under their design-basis differential pressure
and flow conditions. Iftesting in situ under
those conditions is not practicable, the NRC permits a two-stage approach for demonstrating
motor-operated valve capability.
With the two-stage approach,
a licensee would evaluate the
capability for the motor-operated valve using the best data available and develop applicable
test data within the schedule of the generic letter.
11
The licensee has performed static testing on safety-related valves since 1989, and dynamic
testing since 1990.
At the time of this inspection,
12 differential pressure (dp) tests have
been completed and 8 more were scheduled to be completed prior to startup from the 1992
outage.
For those valves where in situ full flow and dp tests are not practicable, the licensee
indicated that partial flow and partial dp tests would be'conducted
as part of the two stage
approach.
As stated in the February 28, 1992 letter to the NRC, the licensee intended to test
only one of the valves in a parallel train of identical valves.
The team observed that this was
not consistent with the GL recommendations
to test all safety-related valves where
practicable.
The licensee acknowledged this observation and stated that the program
description willbe changed to clarify that all valves willbe tested where practicable.
This
change willbe officiallydocumented in a letter to the NRC.
Currently, the licensee has no formal guidance for review of dp test results.
However, the
licensee has stated that a test specification document willbe developed by August 1, 1992, to
control review and evaluate test results for validation of basic assumptions
such as stem
friction coefficient and equipment inaccuracies.
This feedback mechanism will be incorporated into the MOU Program Plan, EWR 5111.
The licensee has demonstrated
a proactive effort in the dynamic testing on motor-operated
valves.
This testing program for MOVs was viewed by the team as a program strength.
2.6
MOV Maintenance and Post Maintenance Testing
The licensee's MOV program plan, EWR 5111, includes requirements for preventive
maintenance {PM) and corrective maintenance {CM)~ The PM program requires the MOVs
to undergo inspection, maintenance,
refurbishment and static and dynamic baseline diagnostic
testing.
Frequency of PM is based on the environmental qualification (EQ) program
commitments, regulatory requirements,
industry and vendor recommendations,
and output
from the Ginna Station Reliability Centered Maintenance (RCM) program historical data
review.
Frequency of major PM and testing of actuators was verified to be once each three
years for EQ MOUs, once each five years for non EQ safety-related MOVs, and once each
ten years for non safety-related MOVs. The PM for stem lubrication and actuator grease is
performed once each two years.
Complete valve internals disassembly overhauls are typically done on a ten year frequency
with some on a five year frequency because of prior history.
Actuator refurbishment and
valve overhaul are also'planned
and implemented at the same time whenever possible.
Repacking of valves is on a five year cycle or less and packing adjustment is on a 12, 24, or
36-month frequency dependent
on accessibility and prior history.
12
During the mid to late 1980's, this licensee was orie of two host facilities that participated
with the Electric Power Research Institute in developing a comprehensive reliability centered
maintenance program.
The R.E. Ginna RCM program covered 21 selected plant systems and
their safety-related components including MOVs. The program reviewed all prior equipment
historical data and provided a systematic basis to assign maintenance intervals.
This program
is a living program and actual operating experience is refiected in RCM updating and. changes
to the PM tasks and intervals.
The team noted that Ginna had instituted a comprehensive MOV valve maintenance program
as a result of the RCM program and the general valve improvement program that were
implemented in the 1988 outage.
Twenty-seven MOV actuators were completely refurbished
during each of the outages since 1989.
At the end of the 1992 outage, only 7 out of 118
MOVs, those in the service water system, remain to be refurbished.
These seven MOVs will
be refurbished during the 1993 outage when the reactor will be defueled and the entire
service water system is scheduled for overhaul.
During the initial implementation of RCM
and valve program activities, the licensee's review of GL 89-10 and Information Notices
caused significant changes to be made to the MOV maintenance program including
considerable use of diagnostic testing.
The benefits of early involvement in the RCM and
valve improvement programs were evidenced in fewer MOV failures and an effective base to
plan and implement GL 89-10.
The PM work order requirements reviewed by the team were determined to be fully
proceduralized for both actuator and valve maintenance
and for diagnostic testing.
The
licensee's M-64 series of maintenance procedures for actuator removal and installation, motor
actuator maintenance,
and MOVATS testing clearly described each of the task and included
cautionary notations, drawings of parts and requirements for acceptance.
The procedural task
steps 'also required final verification of performance upon work completion.
The licensee's CM routine was also reviewed by the team.
Corrective maintenance for MOV
actuators was performed in accordance with procedure No. 1007, Electric Preventive
Maintenance and Diagnostic Testing of Motor Operated Valves.
Repair and replacement of
mechanical components of ASME Code class valves was performed under ASME Section XI
requirements.
Repacking and packing adjustment was performed under the valve
improvement program under EWR 4859 and specific valve packing procedures M-1020, M-
37.116 and M-37.116.1 that fully controlled this generally prevalent problem issue.
Corrective maintenance requires a failure analysis and post corrective maintenance
testing that
could include a motor load test, partial baseline test, full baseline test, and differential
pressure
test.
The Work Order (WO) packages for PM on valve 704B (WO 9240732) and for CM on valve
9629A (WO 9023578) were reviewed.
The work packages were readily available and
included the necessary
requirements for task completion.
The as-found determinations of the
need to replace electrical wire lugs on valve 7048, evaluation of the bent wire lugs, and
justification for interim use of valve 9629A indicated craft and PM analyst attentiveness
and a
13
maintenance philosophy of effective performance and documentation.
An observation made
by the team was that while the procedural requirements led to verification of valve
performance after work completion, these two work orders and the work procedures did not
clearly specify post maintenance. testing requirements.
Specific review was made of the packing adjustment methodology used during valve
maintenance.
It was determined that valve packing adjustment and valve packing procedures
effectively describe the task. It was noted that these tasks are fully controlled and required
review of reference packing gland torque, and recording of as-found, and as-left gland
Lubrication of valve stems was evident during walkdown observations.
The MOV
Qualification Program Plan calls for lubrication of valve stems with Neolube ¹2, however,
use of Felpro N5000 was observed being placed on main feedwater angle globe valves 3976
'nd
3977 being overhauled on April 8, 1992.
From additional observations of other valve
stems, it appeared
that the Felpro N5000 had also been applied to other valve stems in the
plant.
The inspector independently verified that Felpro N5000 was a qualified and acceptable
lubricant that was used in the past and that changeover to use Neolube ¹2 was not yet fully
completed.
(Procedure M-64.0 still calls for stem lubrication with Felpro N5000.)
The team
had no further questions regarding the type of stem lubrication.
During walkdown observations, it was noted that many of the MOVs had new and deeper
actuator switch cover housings.
Followup determined that maintenance
was performed to
upgrade the limit switches from two to four rotor type and deeper switch cover housings were
needed
to accommodate
the new switches.
Valve 4614, a 10" Rockwell butterfly valve, had
the new switch cover housing and also had a new motor.
Further review determined that the
new motor replaced a failed motor during the 1991 outage.
These walkdown observations
were useful in providing the team specific MOV samples to be evaluated in several of the
inspection areas.
The inspected MOVs were in good condition.
The team concluded that the licensee has a comprehensive
maintenance program for MOVs.
The Ginna RCM program was an extensive and effective effort that has produced good
results.
RCM was made a living program and is a maintenance
mainstay.
The early
program implementation of RCM, valve improvement and MOV refurbishment provided an
effective base for evaluation and implementation of the NRC GL 89-10 recommendations.
Maintenance performance was'ffective, however, one team observation pointed to the need
for work order and procedural clarification of post maintenance
testing.
2.7
Periodic Verification of MOV Capability
Item "d" of the generic letter recommended
that licensees prepare or revise procedures to
ensure that adequate motor-operated valve switch settings are established
and maintained
throughout the life of the plant.
Paragraph "j" of the generic letter recommended
surveillance intervals be commensurate with the safety function of the motor-operated valve
as well as its maintenance
and performance history.
The surveillance interval in no case
should exceed 5 years or 3 refueling.outages.
Further, the capability of the motor-operated
valve has to be verified ifthe motor-operated valve is replaced, modified, or overhauled to an
extent that the test results are not representative of the motor-operated valve performance.
The licensee has completed procedures to establish and maintain MOV switch settings.
In
their program description, EAR 5111, Revision 0, the licensee states that periodic testing
willbe performed as scheduled
surveillances for the remaining life of the plant.
The
frequency of periodic testing would be based on the priority assigned to the specific MOV in
accordance with procedure M-1007, "Electrical PMs and Diagnostic Testing of MOVs," The
periodic verification frequency for environmentally qualified actuators is once every three
years and once every five years for non-environmentally qualified safety related actuators.
This is based on industry and vendor recommendations
as well as Ginna historical data as
presented
in the Reliability Centered Maintenance (RCM) Program.
The licensee stated that periodic testing will be conducted with the MOV in the as-found
condition to capture performance data representative of service degradation.
This data would
then be incorporated into the Preventative Maintenance Program and subsequently in the
RCM Program.
The licensee's periodic testing consists of the reverification of operability by
static diagnostic testing using MOVATS equipment following preventative maintenance
activities. It is noted that baseline signatures have been performed on all but eight safety-
related MOVs and retesting will take place following overhauls or extensive corrective
maintenance.
Testing of the eight remaining valves is scheduled to be completed prior to
startup following the 1994 outage.
The team determined the licensee demonstrated
a good understanding of the periodic
verification requirement and was implementing a periodic verification program consistent with
the GL 89-10 recommendation.
2.8
MOV Failures, Corrective Actions, and Trending
Item "h" of the generic letter recommended
that. licensees analyze each motor-operated valve
failure and justify corrective action.
The results and history of each as-found deteriorated
condition, malfunction, test, inspection, analysis, repair, or alteration were recommended
to
be documented and maintained.
This motor-operated valve information was recommended
to
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 motor-
operated valve operability.
4
15
Prior MOV failure history was reviewed from the Nuclear Plant Reliability Data System
(NPRDS), maintenance work order history and prior Reliability Centered Maintenance
(RCM) records of valve failures. It was evident that the MOV failures were sizably reduced
after the programs of refurbishment, valve improvement and RCM were implemented.
The
total history of 13 MOV problems in the past five years revealed that eight occurred in 1988
prior to the licensee's
expanded
maintenance program efforts and there were only five
occurrences after the implementation of the expanded program.
Of the recent occurrences,
none were due to similar failure causes.
The team reviewed the licensee's documentation concerning the failure and replacement of the
motor on MOV 4614, a 10" Rockwell butterfly valve.
This valve was undergoing actuator
refurbishment in the 1991 outage and during no load bench testing of the motor that was
removed from the actuator, intermittent stalling occurred.
Failure of the motor was
documented
on a discrepancy report and nonconformance report NCR-91-153, that was also
followed by a 10CFR Part 21 evaluation.
In-house evaluation of the problem identified a
short in the motor windings thought to be caused by the disassembly or normal aging.
Further, the motor was sent to the vendor for root cause determination.
At the time of the
failure, the exact motor replacement could not be made and interim use of another motor was
evaluated and justified by the licensee's engineering staff.
The interim use justification
included an engineering evaluation, vendor interface, a 10CFR 50.59 safety evaluation, and
review of past failure history to assure this was an isolated problem.
The licensee's actions
and documentation were deemed appropriate and the team also noted that there was a work
order to be implemented for the like kind motor replacement during this outage.
Valve 9701A, a 3" Fisher globe valve, was observed with a trouble tag 0010313, dated
April 1, 1992, that stated,
"Excessive noise when open and close."
Based on discussions
with cognizant licensee personnel,
the noise was thought to be caused by the stem packing.
Review of maintenance
records determined that the valve was repacked
a year ago and recent
diagnostic testing on April 3, 1992, indicated satisfactory performance.
Verification was
made that a work order had been written (WO ¹9200680) and the team had no further
questions.
An earlier corrective action, that of loose terminations on SMA-type torque switch contact
blocks identified in 1988, was reviewed by the team.
The licensee's immediate corrective
action was to tighten all torque switch termina'tions.
Subsequent
actions replaced this style
torque switch under the actuator refurbishment program and included PM requirements
to
check tightness.
Corrective action also included root cause and potential generic problem
considerations.
Trending of MOV failures is accomplished
through the licensee's RCM living program and
avoidance of repetitive type failures was a prime objective of RCM.
Corrective action
reports and all MOV maintenance
are reviewed by the PM analyst.
The failure mode is
documented
and previous failures of that particular MOV are re-evaluated
and a
~
~
16
determination is made for improved maintenance specification, changes to PM frequency or a
modification to the MOV or the system.
An example of a recent accepted RCM
recommendation
was the increased diagnostic test frequency for MOVs 896A and 896B
because of packing leakage and industry notifications.
The licensee actions in addressing failures, corrective actions and trending has been effective
and appropriately documented.
PM analyst review of all MOV failures and their updating
and re-evaluation of failure causes
has contributed to reduced failures.
2.9
Motor-Operated Valve Training
The team evaluated the licensee's
motor-operated valve training courses, training facilities,
and training staff qualifications.
The licensee's training program is Institute of Nuclear
Power Operations gNPO) accredited and specifies initial as well as refresher training.
This
training integrates classroom and hands-on, training with on-the-job training.
The program
outlines specific course requirements for electrical and mechanical maintenance personnel
involved with motor-operated valves.
Limitorque operators are maintained and tested by licensee electricians and mechanics and
contractor personnel 'who have completed a one week motor-operated valves training course
taught by a contractor.
Both licensee and contractor personnel who assist in valve
maintenance
and testing are tested prior to conducting work on motor-operated
valves,
The
training organization has contracted with MGVATS and Power Safety to provide those
personnel training.
Training includes understanding Limitorque operation, techniques for
identifying valves performance,
and evaluation of test results.
Training conducted by
contractors is audited by the licensee on a periodic basis.
A formal refresher training course,
in accordance with procedure EO183I., is conducted on a quarterly basis for review of
MOVATS diagnostic test system and procedure based training in accordance with Ginna
procedure M-64.1.2, "Periodic Surveillance and Minor Maintenance of Limitorque Motor
Operated Safeguards
Valves."
The team toured the site training center and facility for motor-operated
valve refresher
training.
The MOV training aids used for conducting diagnostic testing were good.
Lesson
plans reviewed for basic MOV theory and Limitorque actuators exhibited comprehensive
objectives and good detail.
The instructor demonstrated
a firm understanding
and interacted
effectively with plant and contractor personnel.
This established
a good interface between the
PM Analyst responsible for MOUs and the maintenance training organization.
Based on the
above, it was concluded that the licensee's MOV training program is effective.
2.10
Industry Experience and Vendor Information
The team reviewed the licensee's vendor information program to assess
its effectiveness in
disseminating industry data into the various areas of the MOV program.
The licensee's
disposition of selected NRC Information Notices on MOVs and vendor information updates
17
was reviewed and verified through documentation review and physical inspection of selected
~
~
~
~
~
~
~
valves.
The implementation of the process was reviewed for selected Limitorque 10CFR Part 21 Notifications, Limitorque Maintenance Updates,
and MOVATS Users Technical Notes.,
Plant walkdown demonstrated'refurbishment
of Limitorque valves did incorporate corrective
action and/or inspection for latest vendor problems.
A review of the maintenance procedures
=- indicated that the licensee has incorporated the current industry maintenance related
guidelines.
The Operating Experience Assessment Program (OAP) Procedure No. A-1404, Revision 12,
controls the process for evaluating documentation associated with NRC documents,
industry
experience and vendor informatio'n.'ll the 10CFR Part 21 and Limitorque Maintenance
Updates selected were identified in the system; however, the MOVATS-Users Technical
Notices were not included in the Operating Experience Assessment
Program.
The OAP
coordinator has the responsibility for incorporating information into the Operating Experience
Assessment
Program.
MOVATS was providing its Users Technical Notices directly to the
maintenance staff without routing through the OAP coordinator.
This caused this vendor
information to be omitted form the Operating Experience Assessment
Program.
Review of
the current MOVATS Users Technical Notices found no critical information that had not been
properly incorporated into the applicable station procedures
even though the documents had
not gone through the OAP coordinator.
The licensee acknowledged
the fact and agreed to
ensure copies of future notices will be sent to the OAP coordinator for proper review.
The team concluded that the licensee has established
a program to review and incorporate
-.
vendor information and industry experience.
2.11
Schedule
In Generic Letter 89-10, the staff requested
that licensee's-complete
all actions initiated to
satisfy the generic letter recommendations
by June 28, 1994, or three refueling outages after
December 28, 1989, whichever is later.
The licensee has committed to a schedule to
complete the full implementation of the MOV program by the 1994 refueling outage.
This is
consistent with Generic Letter 89-10 recommendations.
3.0
WALKDOWN
During a motor-operated
valves walkdown inspection of several MOVs, it was noted that the
valve stems were clean and adequately lubricated.
The motor-operated valve cleanliness was
generally good.
Exceptions to this was in regard to the service water valves located in the
intake structure building.
However, these service water valves are scheduled to be
refurbished during the upcoming 1993 outage.
18
Also noted,'while touring the Standby AuxiliaryFeedwater Building, was a loose power cable
conduit connection at the MOV motor housing of MOV 9629B.
The licensee took immediate
correctiv'e action by initiating a maintenance request to tighten.the power cable conduit
connection.
The general condition of the MOVs throughout the plant was good.
4.0
CONCLUSION
The licensee has taken measures
towards establishing an MOV program that is consistent with
the guidelines of NRC Generic Letter 89-10.
The inspection team observed that the
administration and engineering efforts set forth for the program were good.
Personnel
involved with the program were knowledgeable,
demonstrated
good technical capabilities, and
interfaced well with both other'departments
and contractors.
The licensee has taken a proactive and effectiv'e approach for testing MOVs by utilizing
improved diagnostic techniques and completing differential pressure testing for several valves.
The licensee's program schedule is consistent with the recommendations of
5.0
UNRESOLVED ITEMS
Unresolved items are matters for which more information is required to ascertain whether
they are acceptable,
violations or deviations.
Three unresolved items are discussed in
Sections 2.1, 2.2, and 2.4 of this report.
6.0
EXIT MEETING
The inspectors met with those denoted in Appendix A on April 10, 1992, to discuss the
preliminary inspection findings as detailed in this report.
The licensee acknowledged
the
inspection findings and agreed to review the items listed in Table
1 for resolution and further
improvement of the MOV program.
TABLE 1
Licensee Plans and Commitments for Further Program Improvements
i n21
nd A mini rati n f h
Pr
ram
Referee
Q,~ph
Justify exclusion of RHR valves 700, 701, 720,
and 721 from Generic Letter 89-10 Program
(Unresolved Item 50-244/92-80-001)
ion 2 2 De i n B si
Reviews
~
Review of normal, abnormal, and emergency
procedures
to ensure worst case design basis
conditions are incorporated
(Unresolved Item 50-244/92-80-002)
~
Technical justification for the utilization of
a less conservative assumption for reactor pressure
~
Incorporation of seismic considerations into design
basis documents
~
Implement degraded voltage considerations for MOVs
825 A and B and 871 A and B into NSL-5080-0002
10
ec ion 2 4 MOV
witch
ettin
and
e
int
ontr
1
~
Justify use of 0.20 and 0.30 valve factors for
parallel disk and flex-wedge gate valves
~
Justify use of 0.15 for stem friction coefficient
for actuators
~
Review methodology for differential pressure and
flow testing and incorporate rate of loading effects
~
Verification of margin between thrust required and
thrust available through in situ testing or comparison
Table
1
~
Resolution of inadequate margin to close for PORV
block valves 515 and 516
(Unresolved Item 50-244/92-80-003)
tion 2
Mo r
rated V lve Tes in
~
Clarification of program description to test where
practicable all valves under full differential
pressure and flow
~
Development of formal guidance fo'r review of
differential pressure test results
pl
APPENDIX A
Pr
n
n
hetr
AndEl
ri
o
ti n
- J. Baker, Electrical PM Analyst
J. Bettle, PM Engineer
M. Burneir, Design Manager, Bell Engineering
B. Carrick, Mechanical Engineering
D. Ciesielski, Engineer, Electrical Maintenance
M. Clark, Engineer, NSEcL
J. DiBiase, Electrical Engineer
L. Dipzinski, Mechanical Engineer, Bell Engineering
R. Eliasz, Sr. Nuclear Engineer
C. Forkell, Manager, Electrical Engineering
- , G. Graus, Lead Electrical Engineer
T. Harding, Modifications Support Coordinator
M. Lilley, Manager, Nuclear Assurance
R. Marchionda, Superintendent,
Support Services
K. Muller, Mechanical Engineering
W. Prokop, Manager, MOVATS
J. St.Martin, Corrective Action Coordinator
J. Summers, Engineer, Electrical Maintenance
G. Voci, Manager, Mechanical Engineering
J. Widay, Plant Manager
P. Wilkens, Department Manager, Nuclear Engr. Services
G. Wrobel, Manager, Nuclear Safety & Licensing
"
Nuclear Re ulat r
Commis ion NR
Dr. P; K. Eapen, Chief, Systems Section
E. Knutsen, Resident Inspector - Ginna
J. Linyille, Branch Chief, DRP
T. Moslak, Sr. Resident Inspector - Ginna
Denotes present at exit meeting held at R.E. Ginna Nuclear Power Plant, April 10, 1992.
1