ML17286B025

4.

MOV Pro

ram Review

4.1

~Sco

e

GL-89-10 Recommendations

and Licensee

Commitments

recommended

that all safety-related

MOVs and other

NOVs

that are position-changeable

in safety-related

piping systems

be

included within the scope of the licensee's

GL 89-10 program.

Supplement

1 to the Generic Letter defined "position-changeable"

as

any

MOV in a safety-related

piping system that is not blocked from

inadvertent operation

from the control

room.

In their response

to

GL 89-10, the licensee

committed to the scope of the program

as

recommended

in GL 89-10.

Observations

The licensee

based

the scope of their program

on the

BMR owner's

group

(BMROG) generic identification of safety related valves

required to perform active design basis safety functions.

The

licensee

supplemented

the gener)c analysis with a plant specific

analysis (calculation NE-02-88-06,

R.O.

dated 10/13/88) of all 479

MOVs in the plant.

These

reviews identified 163 NOYs, including 115

gate valves,

33 globe valves

and 15 butterfly valves,

which the

licensee

considered to be within the scope of their GL 89-10

program.

All of the 163

NOVs were equipped with Limitorque

actuators.

The remaining 316

NOVs outside the scope of GL 89-10

continue to be maintained

under previously established

practices.

The inspectors

found that the licensee

did not utilize any measures

to prevent inadvertent mispositioning from the control

room as part

of their program.

As such,

the scope of the program did not exclude

any valves

based

on compensatory

measures

to preclude

mispositioning.

After reviewinq several

of the licensee's

piping and instrument

drawings,

the inspectors

found instances

where

some

MOYs in safety

had been excluded

from the licensee's

program scope.

The inspectors

found no documented justification for

their exclusion.

In one case

(RMCU MOVs beyond the containment

isolation valves), it appeared

that exclusion of the

NOVs could be

justified.

The licensee

committed to review all safety related

MOVs

that had been excluded

from the

GL 89-10 program

and to provide

documented justification.

(Followup Item 50-397/91-16-01).

The inspectors

also found that the licensee

had not reviewed

emergency

operatinq procedures

(EOPs) in establishing

the scope of

their program.

This fai lure to review EOPs is a deviation from

the recommendations

given in the

NRC response

to auestion

6 of

Supplement

1 to GL 89-10.

(Deviation Item 50-397191-16-02).

4.2

Conclusions

Based

on the above deviation

and followup item, the inspectors

determined that the scope of the licensee's

program

had not .yet been

adequately

established.

Desi

n Basis

Reviews

GL 89-10 Recommendations

and Licensee

Commitments

Recommended

Action "a" of GL 89-10 requested

the review and

documentation of the design basis for the operation of each

MOV to

determine the maximum differential pressure

and flow (and other

factors)

expected for both normal operations

and abnormal

conditions.

The licensee

committed to follow the recommendations

of

GL 89-10.

Observations

The inspectors

discussed

the performance of design basis

reviews

with licensee

personnel

and reviewed Supply System Engineering

Standard

NES-8 (REV. 0, 9/18/89), "Differential Pressure

Calculations for Motor Operated Valves," as well as several

design

basis

review packages.

At the time of the inspection,

the licensee

had completed

151 design basis

reviews of MOV's within its GL 89-10

program.

However, the licensee

had not included all appropriate

factors,

such

as flow and temperature

effects.

The licensee

recognized that

some factors

beyond differential pressure

needed to

be addressed

in its calculations

(e.g. fluid deceleration)

and

committed to more fully address

design basis factors.

This will be

a followup item for future inspections.

The licensee

applied the results of calculations

by the

BWR Owners

Group of differential pressures

predicted to be experienced

by MOVs

in generic

BWR systems.

The licensee

had not verified that those

determinations

of differential pressure

by the

BWR Owners'roup

were applicable to WNP-2.

in particular, the licensee

had not

evaluated

normal,

abnormal,

surveillance testing,

and emergency

operating procedures

to ensure that the

BWR Owners'roup

values

bound the worst case operating conditions that might be seen

by MOVs

at WNP-2.

For example,

the licensee

found during surveillance testing that

HPCS-V-23 could not close against the surveillance differential

pressure

which was greater

than the assumed

design basis

differential pressure.

The design basis

maximum differential

pressure

(DP) had been

based

on simultaneous initiation of HPCS-V-23

closure

and core spray injection valve opening.

This design basis

conditioh resulted in a maximum

DP less

than the shutoff head of the

HPCS pump, since

some pressure

reduction could be credited to the

.

opening of the injection valve.

Eventually the torque switch

setting

was increased

to accommodate

surveillance test conditions.

However, the original design basis

pressure

listed on the Master

Data Sheet

(HDS) remained

unchanged.

The inspectors

found that this

indicated that the licensee

had established

the maximum operating

requirements

for the

MOV based solely on the original design

basss

conditions.

While not .requesting that the original desiqn basis

conditions

be exceeded,

GL 89-10 recommends

that the design basis

review should conservatively establish worst case operating

conditions

under normal

and abnormal

events.

As a result of the problems

encountered

with HPCS-V-23, the licensee

had initiated a program to review surveillance

and testing

requirements

to ensure that differential pressures

experienced

during those activities were bounded

by the design-basis

differential pressures.

The licensee

was cautioned that, in the

execution of their program, if the worst case differential pressures

are not applied in determining adequate

sizing and switch settings

for MOVs within the

GL 89-10 program, this would constitute

a

departure

from the guidance

given in Supplement

1 for satisfying

recommended

action

a" of GL 89-10.

This will be

a followup item

for future inspections.

The inspectors

found that, in some instances,

the licensee

had

assumed

nominal reactor pressure

as the maximum differential

pressure

across

valves in lines that directly communicate with the

reactor vessel.

The licensee

had not demonstrated

that nominal

reactor pressure

bounds the

maximum reactor pressure

minus pressure

loss in piping from the reactor vessel

to the valve.

The licensee

committed to perform a review to ensure that nominal reactor

pressure

bounds the worst case differential pressure

across

the

valve.

The licensee's

use of nominal reactor pressure

as the design

basis for operability rather than the maximum differential pressure

at the

MOY is a deviation from recommended

action "a" of GL 89-10.

(Deviation Item 50-397/91-16-02).

The licensee

indicated that, for MOVs within the

GL 89-10 program,

the design-basis

differential pressure

is determined only for the

safety function direction of the valve.

The licensee

considered

an

MOV that must be closed to perform its safety function to have

a

close safety function direction.

Similarly, the licensee

considered

an

MOV that must be open to perform its safety function to have

an

open safety function direction.

Under the licensee

s classification

method,

some

HOVs have both open

and close safety function

.directions.

In those

cases it was not apparent that the licensee

had determined

the

maximum differential pressure

for the open safety

function direction.

The licensee

committed to ensure that the

appropriate

design basis factors are specifically determined for

HOVs with an open safety function direction.

This will be

a

followup item for a future inspection.

If an

MOV has only one safety function direction, the licensee

indicated that the differential pressure for that direction is

applied to the non-safety function direction as well.

The

inspectors

discussed

with the licensee

the possibility that the

differential pressure for the non-safety function direction could be

greater than the differential pressure for the safety function

i

I

t

i

I

f

t

'f

0'

direction.

For such

a circumstance,

the licensee

needs to ensure

that the

MOV will be able to operate

in its non-safety function

direction or that the

MOY will not be damaged

such that it is

incapable of moving to,its safety position.

This will be a.followup

item for future inspections.

The licensee

indicated that the potential for mispositioning to

cause differential pressure

higher than that provided by the

BWR

Owners

Group had not been spec>fically addressed.

While recognizing

that the condition had been corrected,

the inspectors

noted tfiat the

surveillance test failure of HPCS-Y-23 was

an example of where

mispositioning could cause

operating conditions exceeding

those

established

on the Master Data Sheet.

This failure to consider the

effects of mispositioning is a deviation from the recommendations

given in the

NRC response

to question

15 of Supplement

1 to GL 89-10.

(Deviation Item 50-397/91-16-02).

The followup items identified in this section

on design basis

reviews will be tracked

as Followup Item 50-397/91-16-03.

Conclusions

The inspectors

determined that the licensee

had not yet adequately

developed

plans

and procedures

for the performance of design basis

reviews.

MOV Sizin

and Switch Settin

Calculations

GL 89-10 Recommendations

and Licensee

Commitments

Recommended

action "b" of Generic Letter 89-10 requested

licensees

to review,

and to revise

as necessary,

the methods for selecting

and

setting all

MOY switches.

The licensee

committed to follow the

recommendations

of GL 89-10.

Observations

The inspectors

discussed

the licensee's

process for sizing

MOVs and

setting their switches

and reviewed

WNP-2 Calculation Method

NE-02-90-17

(Rev. 0).

The inspectors

reviewed several

calculation

packages

to evaluate

the development of the licensee's

program

and the licensee's

response

to Supplement

3 to GL 89-10.

The inspectors

found that the licensee

had not incorporated

the best

available data

from industry operating experience

and research

results in their selection of valve factors to be used in the

calculation of minimum required thrust.

In particular, the licensee

continued to use

a low valve factor of 0.3 in most of their

calculations of required

minimum thrust to operate

flexwedge gate

valves.

The inspectors

informed WNP-2 of a recent industry

experience

in which the

use of a 0.3 valve factor had resulted in a

70K test failure rate under high differential pressure

and flow

conditions.

Further, Calculation NE-02-87-29,

Rev.

0 indicated that

a valve factor of 1.0 would be assumed

in calculations of thrust

requirements

for globe valves.

This is less conservative

than the

Limitorque recommendation

of 1. 1 for the valve factor for globe

valves.

However, the globe valve calculations

reviewed by the

inspectors

did use

a 1..1 valve factor.

The inspectors

emphasized

that the

use of low valve factors places

a

heavy reliance

on the performance of design basis testing of NOVs

in-situ at MNP-2 in order to verify the licensee's

methodology for

sizing

HOVs and setting their switches.

The licensee will be

expected to justify its assumed

valve factors, especially in cases

where the assumed

valve factor is less

than the industry typical

value.

Further,

the inspectors

cautioned that the licensee will

need to be prepared to evaluate their methodology,

including

appropriate

consideration of NOV operability,

when results of design

basis testing are obtained.

This is particularly true for instances

where the calculation packages

indicate that the

HOYs are marginally

sized

and set.

The licensee's

FSAR indicated that Class lE motors would be sized to

erform adequately

when supplied with 80K of nominal voltage.

owever, for MOVs that were found to be inadequately

sized for the

80K bounding value, the licensee

used

a specific plant degraded

voltage calculation to establish

the actual

expected worst case

voltage condition.

For example,

RCIC V-8 appeared

to be inadequately

sized to perform it's design function when supplied with 80K of

nominal voltage.

Consequently,

a degraded

voltage of 87K was

used

to calculate motor torque requirements

for RCIC V-8.

This degraded

voltage is less conservative

than the 80K value given in the section

on "Minimum Voltage" for Class

1E motors

on page 8.3-30 of the

MNP-2

FSAR and is, therefore,

an apparent deviation from the licensee's

FSAR commitment.

(Deviation Item 50-397/91-16-04)

The inspectors

recommended that the licensee

ensure

the adequacy of

their degraded

voltage studies.

For example,

the licensee

should

ensure that appropriate

ambient temperatures

have

been

assumed

in

calculations of voltage losses

from cabling.

The staff will review

the licensee's

evaluation of degraded

voltage in future inspections.

(Followup Item 50-397/91-16-05).

MNP-2 Calculation Hethod NE-02-90-17

(Rev.

0) requires that

a 10K

thrust margin be included above the calculated

minimum requirements.

However, the licensee

considered this to be an administrative

conservatism

and not mandatory.

For example,

the licensee

included

only a 5X thrust margin in Manual Calculation NE-02-90-17

(Rev.

1)

for RMCU-V-1 and 4.

The inspectors

noted that the licensee

had not

identified a required margin to account for "rate of 1oadinq"

effects.

The licensee will be expected to address

these effects

and

to ensure that adequate

margin exists in the sizing of MOVs and

setting of their torque switches.

This will'be a followup item for

future inspections.

The licensee

had not identified any margin to account for variations

in operating characteristics

caused

by seismic/dynamic

loading.

Further, the licensee

had not included the negative

impact of high

ambient temperatures

on motor output.

These omissions constitute

a

deviation from the recommendations

given in the

NRC response

to

uestion

15 of Supplement

1 to GL 89-10,

(Deviation Item

0-397/91-16-02)

WNP-2 Calculation Method NE-02-90-17

(Rev.

0) stated that

a stem

friction coefficient of 0.2 would be used in MOV sizing

calculations.

However, in Manual Calculation NE-02-90-17

(Rev.

1)

for RWCU-V-l, the licensee

assumed

a stem friction coefficient of

0.20 to calculate

the lower bound value of the thrust window and

0.15 to calculate the upper

bound value of the thrust window.

The inspectors

cautioned the licensee

regarding the assumption of

differe'nt stem friction coefficients.

The assumption of 0. 15 as the

stem friction coefficient could be nonconservative,

unless specific

maintenance

and lubrication requirements

and frequencies

are

implemented to ensure

the continued high efficiency of motor torque

to stem thrust conversion.

The licensee typically sets thrust within the design window on

freshly lubricated

MOVs using data from diagnostic

equipment.

Provisions

should

be made to include

a margin associated

with the

difference in thrust based

on differences

between

minimum and

maximum expected

stem to stem nut friction.

The licensee will be expected to justify their use of stem friction

coefficients lower than the typical value of 0.20 and to demonstrate

that

MOV design margins include consideration of MOV performance

as

affected

by any expected

changes

in stem to stem nut friction (e.g.

during the time between

MOV lubrication service intervals).

This

will be a followup item for future inspections.

WNP-2 Calculation Method NE-02-90-17

(Rev.

0) stated that the

maximum torque switch setting will be based

on the minimum of the

actuator

gear rating, the Limitorque maximum recommended

torque

switch setting,

and the motor pullout torque at degraded

voltage.

Limitorque Update 89-01 identified that maximum torque switch

setting includes valve manufacturer limits, if they were available.

The licensee will be expected to confirm that valve components

have

been considered

in the determination of limiting conditions for

maximum allowable torque switch setting.

This will be

a followup

item for future inspections.

The licensee's

program description stated that thermal

overload

devices

are utilized in accordance

with Regulatory Guide 1. 106,

"Thermal Overload Protection for Electric Motors on Motor-Operated

Valves."

The Program Plan also indicated that thermal overload

protection of motors would not be addressed

in the program.

The inspectors

reviewed the licensee's

original criteria for sizing

and setting thermal

overloads in Technical

Memorandum

1129 (August

ll, 1978) from Burns and

Roe, Inc.,

as well as

EES-5

(Rev. 0),

"Selection of Fuses

and. Overloads for Protection of 460

VAC and

125-250

VDC Motors."

Those

documents

indicated that the purpose of

the criteria for'electing fuses

and thermal overload relay heaters

was to protect motors

and circuits from short circuits and overloads

and to avoid nuisance tripping of motors.

The Burns

and

Roe

memorandum

noted,

however, that there

was

a chance of burnout of

small motors if the valve became

jammed

and torque

and limit

switches did not operate.

The licensee

places

a high degree of

reliance

on thermal

overload protection for its motors because

torque switches

are jumpered or bypassed for 90 to 95% of valve

stroke in the safety direction for MOVs.

As the Burns

and

Roe

criteria appeared

to take credit for the presence

of torque

switches;

the inspectors

requested

the licensee to review their

thermal

overload protection criteria to ensure that appropriate

consideration

has

been given to the applicability of the criteria at

WNP-2.

In particular, the inspectors

emphasized

consideration of

the following areas:

Thermal overload devices

(TOLs) and fuses

are sized based

on

full load amps

(FLAs), which is the cur rent which the motor

draws

when operating at running torque,

which is nominally

rated

by the manufacturer at 20K of the rated motor torque.

In

the

MOV applications at

WNP 2,

FLAs greater

than

20K value were

often encountered

due to line pressure

and packing loads.

The

licensee

was cautioned to consider the actual

FLA in the

TOL

application calculations.

The licensee

should verify that the

use of rated

FLA adequately

bounds

expected

normal

and design

basis conditions.

The licensee

did not consider

motor ambient temperature

in

sizing the TOLs.

The allowable temperature

rise of 40'C was

based

on an initial ambient temperature

of 40'C (104'F).

In

certain locations

and under certain operating

modes, initial

ambient conditions

may exceed

40

C.

Also, repeated

cycling of

the

MOV may be restricted

by this limit, requiring cool off

time between cycles for the motor temperature

to return to

ambient conditions.

The licensee

committed to review their thermal

overload protection

to ensure that it has established

adequate

control of thermal

overload protection for MOVs and that the criteria are, appropriate

for WNP-2.

The licensee's

failure to address

the impact of thermal

overload switch settings

on the capability of the

MOUs to perform

their designated

safety function(s)

was

a deviation from the

recommendations

in the

NRC response

to question

21 of Supplement

1

to GL 89-10.

(Deviation Item 50-397/91-16-02).

Some

WNP-2

MOVs required motor performance

calculated

beyond the

"knee" of the manufacturer's

motor performance

curves.

NRC

sponsored

tests

have

shown that beyond the

knee of the motor

performance

curve, motor performance

under degraded

voltage

10

conditions

can

be far less

than that predicted

by the manufacturer's

performance

data.

WNP-2 is expected to provide justification when

their design calculations

take credit for motor performance

beyond

the

knee of the motor performance

curve.

This will be

a followup

item for a future inspection.

The followup items identified in this section will be tracked

as

Followup Item 50-397/91-16-06,

except

as identified in the above

discussion.

Conclusions

The inspectors

determined that the licensee

had not yet adequately

developed

plans

and procedures

for performing calculations to verify

proper sizing of MOVs and to set their'switches.

Desi

n Basis Differential Pressure

and Flow Testin

GL 89-10 Recommendations

and Licensee

Commitments

Recommended

action "c" of the generic letter requested

licensees

to

test

MOVs within the generic letter program in-situ under their

design basis differential pressure

and flow conditions.

If testing

in-situ under those conditions is not practicable,

alternate

methods

may be used to demonstrate

the capability of the

A two-stage

approach

was suggested

for situations

when design basis testing

in-situ is not practicable

and when

an alternate

method of

demonstrating

MOV capability cannot

be justified at this time.

With

the two-stage

approach,

a licensee

would evaluate

the capability of

the

MOV using the best data available

and then would work to obtain

applicable test data within the schedule of the generic letter.

The

licensee

committed to follow the recommendations

of GL 89-10.

However, the licensee

requested

a schedule

extension for MOVs

subjected

to the two-stage

approach for operability verification.

According to the licensee,

the schedule

extension

would be necessary

to complete the testing portion of their two-stage

approach

Observations

The licensee

indicated that all

MOVs in the

GL 89-10 program will

undergo static diagnostic tests.

The licensee

committed to test

MOVs under design basis differential pressure

and flow conditions,

where practicable.

The licensee

had not determined

which MOVs are

practicable to test under these worst case conditions.

e

The licensee's

program plan indicated

a possible

grouping which

would be

a deviation from the licensee's

commitment to test

MOVs,

where practicable.

If the licensee

proceeds

with the plan for

grouping,

a justification for this deviation from their commitment

to GL 89-10 needs to be considered.

The licensee

had not conducted

any differential pressure

tests in

response

to GL 89-10 at the time of the inspection.

The licensee

was behind their design basis testing schedule,

which called for

t

l

tl

4.5

approximately

30K of the differential pressure

tests to be completed

by the time of the inspection.

The licensee

had not developed

procedures

for differential pressure

testing.

This testing will be

important in verifying the licensee's

methodology for establishing

NOV size

and switch settings (particularly, in light of the

licensee's

use of low valve factors).

The lice'nsee

was cautioned

that if differential pressure

testing casts

doubt on the

MOV sizing

or switch settings, all

NOYs in the program would need to be

promptly addressed.

The licensee

had tested

several

marginally-sized

MOVs under zero

flow and degraded

voltage conditions but did not have quantitative

information regardinq the amount of margin available.

The licensee

was considering testing

some of these

MOVs under

maximum

differential pressure

under degraded

voltage conditions.

This will

be

a followup item for future inspection

(Followup Item

50-397/91-16-07).

Conclusions

Due to the lack of progress

in this area,

the inspectors

determined

that the licensee

had not yet adequately

developed

plans

and

~

rocedures for demonstrating

the capability of MOVs through design

asis differential and flow testing.

Periodic Verification of NOV Ca abilit

GL 89-10 Recommendations

and Licensee

Commitments

Recommended

action "d" of the generic letter requested

that

licensees

prepare

or revise procedures

to ensure that adequate

switch settings

are determined

and maintained throughout the life of

the plant.

Paragraph "j" of the generic letter recommended

that the

surveillance interval

be based

on the safety importance of the

as well as its maintenance

and performance history, but that the

interval not exceed

5 years or 3 refueling outages.

Further,

the

capability of the

MOV would need to be verified, if the

MOV )s

replaced,

modified, or overhauled to an extent that the existing

test results

are not representat'ive

of the

The licensee

committed to follow the recommendations

of GL 89-10.

Observations

In its Motor Operated

Valve Program Plan,

the licensee

indicated

that it intended to conduct static testing of each

MOV every

5 years

in an effort to ensure

the continued

adequacy of MOV torque switch

settings.

The inspectors

stated that the

use of static testing

alone to verify continued capability of an

MOV to operate

under

worst case differential pressure

and flow conditions

was not

considered

adequate

because

of the uncertain relationship

between

the performance of an

MOV under static conditions

and under design

basis conditions.

The inspectors

considered this to be a followup

item.

The

NRC staff will evaluate

the licensee

s justification for

II

,l

,l:~

f

12

the use of static testing during future inspections

on

a case-by-

case basis.

The licensee

had not developed

documented criteria for conducting

post-maintenance

testing for MOVs within i.ts

GL 89-10 program.

The

licensee will be expected to provide justification for the testing

performed following each

MOV maintenance activity to verify the

capability of the

MOV to operate

under design basis conditions.

The

inspectors

considered this to be a followup item.

The

NRC staff

will evaluate

the specific justification for individual post-

maintenance

tests

during future inspections

of this activity.

The followup items i'dentified in this section will be tracked

as

Followup Item S0-397/91-16-08.

Conclusions

Due to the lack of progress'in this area,

the inspectors

determined,

that the licensee

had not yet adequately

developed

plans

and

procedures

for periodic verification of the capability of MOVs.

MOV Failures

Corrective Actions

and Trendin

GL 89-10 Recommendations

and Licensee

Commitments

Recommended

action "h" of the generic letter requested

that

licensees

analyze or justify each

MOY failure and corrective action.

The documentation

should include the results

and history of each

as-found deteriorated

condition, malfunction, test, inspection,

analysis,

repair, or alteration.

All documentation

should

be

retained

and reported in accordance

with plant requirements.

This

data should

be periodically examined

(every

2 years

or after each

refueling outage after program implementation)

as part of the

monitoring and feedback effort to establish

trends of MOY

operability.

These trends

could provide the basis for a licensee

revision of the testing frequency established

to verify periodically

adequate

MOV capability.

The generic letter indicated that

a

well-structured

and component-oriented

system is necessary

to track,

capture,

and share

equipment history data.

The licensee

committed

to follow the recommendations

of GL 89-10.

Observations

The licensee is currently'rending

MOV failures but needs

to

formally document their program.

At present,

Maintenance

Mork

Requests

(MWRs) and Problem Evaluation Reports

(PERs) are received

by the

MOV coordinator for trending.

The inspectors

emphasized

the

importance of not missing opportunities to trend

degradedlaccelerated

wear conditions

as well as failures.

The inspectors

noted that the licensee

looks for trends in MOV type

as well as type of service application

and that the licensee

compares their data with industry trends.

The inspectors

encouraged

~

l

the licensee to incorporate

these attributes

when they formally

document their program.

It was noted that last year the'icensee

identified 69

MOV failures.

According to the licensee,

this number

had decreased

during the

years at WNP-2, and this indicated

some

success

in the licensee's

root cause

analysis

and corrective actions.

The inspectors

considered

the number still to be excessive.

It appeared that the

licensee's

engineering staff needed to become

more involved in the

process

of assessing

MOY failures, corrective actions,

and trending.

Through discussions

with maintenance

personnel,

the inspectors

found

that several

instances

of degraded

spring packs

had been recently

encountered

during the refurbishment

and testing of several

Fuel

Pool Cooling (FPC)

This condition was identified by the

maintenance

personnel

as spring pack collapse resulting in a loss

of preload in the spring pack.

A loss of preload in the spring pack

can cause

the actuator

to torque out prematurely

under

maximum

DP

conditions before the valve has

completed its required safety

function.

The deficiency represents

a significant condition adverse

to quality in assuring

the design basis operability of the

As a result of three instances

of the

same degradation

in six FPC

valves,

the licensee initiated replacement of all spring packs in

safety related

MOVs during refurbishment

under their GL89-10

program.

The inspector

reviewed Maintenance

Work Requests

MWR AR3151,

AR3152,

and AR314 for FPC-MQ-175,

181A, and 172 respectively.

The

inspectors

found that in each instance

the spring packs

had been

replaced

due to collapsed spring pack washers.

However, the

inspector

found that the degraded

conditions

had not been

documented

on a

PER as required by license procedure 1.3.12, "Plant Problems

Plant Problem Evaluation Request."

As a result,

no root cause

evaluation

was performed.

The generic implications

on the

operability of other valves were not addressed.

The conditions

were

not reviewed for reportability or Part 21 applicability.

This failure to follow procedures

for the identification of

significant conditions adverse to quality is an apparent violation.

(fnforcement

Item 50-397/91-16-09)

Conclusions

The inspectors

determined that the licensee

had not yet adequately

developed

plans

and procedures

for analyzing

MOV failures,

justifying corrective actions,

and trending.

14

4.7

4.8

Schedule

GL 89-10 Recommendations

and Licensee

Commitments

GL 89-10 requested

that licensees

complete. all design-basis

reviews,

analyses,

verifications, tests,

and inspections that were initiated

in order to satisfy the generic letter

recommended

actions

by June

28, 1994, or 3 refueling outages after December

28, 1989, whichever

is later.

The licensee

committed to follow the recommendations

of

GL 89-10.

However, the licensee

requested

a schedule

extension for

NOVs subjected to the two-stage

approach for operability

verification.

According to the licensee,

the schedule

extension

would be necessary

to complete the testing portion of their

two-stage

approach

NOVs.

Observations

The licensee's

equality Assurance

Organization identified a number of

areas

where the

MOV program

had fallen behind schedule.

According

to the licensee's

program description,

approximately

30X of the

design basis testing should

have

been

completed

by the time of the

inspection.

At the time of the inspection,

none of the tests

had

been performed nor had any procedures

for design basis testing

been

developed.

The inspectors

observed that the licensee's

current program schedule

places

a heavy reliance

on maximum

DP testing towards the end of the

5 year schedule to confirm the adequacy of their design setpoint

verification methodology.

In the meantime,

the design verification

program continues at rssk with low valve factors,

wh>ch have

been

found, in some cases,

to be nonconservative.

It appears

that the

licensee

has little room in their schedule for a contingency plan,

if the desiqn basis tests fail to corroborate

the design values

calculated

)n the current program.

As evidenced

by the program's

current status,

licensee

management

appears

to have underestimated

the resources

required for th>s program.

Conclusions

The inspectors

determined that the licensee

had not yet adequately

established

a schedule for the completion of the

recommended

actions

of GL 89-10.

(Followup Item 50-397/91-16-10).

Other

MOV Pro

ram Areas Addressed

4.8.1 Control of MOV Switch Settin

s

The licensee

uses

a Master Data Sheet

(NDS) under procedure

No.

1.4. 13 to control the allowable range of thrust values

and

torque switch settings.

On each Master Data Sheet,

the

licensee

provides

a minimum thrust value that must be exceeded

by the thrust readings

obtained

from the

NOVATS diagnostic

equipment during valve stroke testing.

For the

max>mum

allowable actuator output, the licensee

provides

a maximum

15

thrust value and torque switch setting

on the Master Data

Sheets.

The inspectors identified several

concerns

regarding the

licensee's

development of their Master Data Sheets

and control

of NOV switch settings.

Some of the Master Data Sheets

reviewed did not provide

complete information.

when setting

MOV switches,

the plant

technician

must ensure that neither the

maximum thrust value

nor the maximum torque switch settings

are exceeded.

The

inspectors

noted that the licensee

had not consistently

provided clear guidance to plant and contractor personnel

on

this limitation.

For example, for an

MOV with an open safety function direction,

the licensee

did not indicate the design basis differential

pressure

nor the minimum thrust requirements

on the Master Data

Sheet,

but rather simply indicated

NA (for "Not Applicable" ) on

the data sheets for those parameters.

The licensee

indicated that torque switches for an

NOV with an

open safety function direction have their open torque switch

jumpered out of the circuit.

However, the inspectors

found

that the torque switch jumpers

were not controlled under the

Master Data Sheet.

The inspectors

cautioned that the

installation of the hardwire jumper is equivalent to

establishing

a lOOX torque

sw>tch bypass setting

and appears

to warrant inclusion on the Master Data Sheet.

In the past,

the licensee

had not maintained

adequate

control of such

torque switch jumpers (e.g.,

see

Licensee

Event Reports

87-24 and 89-11).

The licensee

needs to maintain control of

its jumpering of torque switches

because

of its reliance

on

those

jumpers for the appropriate

operation of the

NOV.

In

discussions

with licensee

personnel, it appeared that the

licensee's

position on the use of jumpered torque switches

was

in response

to IE Circular 81-13,

Torque Switch Electrical

Bypass Circuit for Safeguard

Service Valve Notors."

The

NRC

staff guidance in GL 89-10 constitutes

the most recent staff

position for providing assurance

that

MOVs are capable of

reliably performing their intended functions.

The licensee

should consider the appropriateness

of the use of jumpered

torque switches in light of an integrated

approach to ensuring

the proper performance

of HOVs at WP-2.

The inspectors identified an instance

where the Master Data

Sheet for RCIC-V-63 was inconsistent with Table I in the

NOV

Program Plan regarding the open safety function of the valve.

The licensee

had identified instances

where torque switch

settings

were higher than the setting allowed by Limitorque for

particular

In the case of MS-Y-16, the high setting

resulted in valve damage.

The licensee

had completed

a PER,

which provided evidence of its review of plant documentation

on

i

k

~II

4

~,

16-

torque switch settings.

The

PER concluded that the extent of

this problem was limited.

The licensee

has

been performing

degraded

voltage tests

on those valves to determine

whether the

motors could deliver the

demanded

torque at the as-found

settings.

Such

a test of RHR-V-48B revealed that the motor

could not deliver the

demanded

torque under degraded

voltage

conditions.

The licensee

had not- completed their evaluation of

RHR-V-48B operability at the time of the inspection exit

meeting.

The

NRC will review the results of the licensee's

evaluations

during a future inspection.

In MNP-2 Operational

equality Assurance

Surveillance

Report

2-91-009,

the licensee

found that the plant procedure

controlling the Master Data Sheets

was not well understood

by

plant personnel

and identified other problems involvinq the

Master Data Sheets.

The licensee

had

an internal

commitment to

resolve the issues identified in the equality Assurance

Surveillance

Report by June 10, 1991.

The

NRC staff will

review the licensee's

response

to that equality Assurance

Surveillance during a future inspection.

In light of the above concerns

regardinq the licensee's

Master

Data Sheets,

the inspectors

discussed

with the licensee

the

importance of adequate

and justifiable control of MOV output

and switch settings.

In that the licensee relies

on jumpered

torque switches for some

MOVs, the licensee

needs

to provide

positive control over the presence

and functionality of those

jumpers.

The inspectors

requested

that the licensee

review its

control of MOV output and switch settings

to ensure that its

controls are clear to plant and contractor personnel.

The

licensee

committed to review this area

and to make

improvements

as necessary.

Concerns identified in this section will be addressed

in a

future inspection

and tracked

as Followup Item 50-397/91-16-11.

4.8.2 ~Trainin

The inspectors

discussed

the licensee's

traininq activities in

this area with licensee

personnel,

reviewed training outlines

and records,

and toured the traininq facility.

The inspectors

did not identify any problems in th)s area.

The licensee

allowed contractor personnel

to receive training

on site or

be certified as adequately trained

by the applicable

contractor.

Operational

Assurance

Surveillance

Report 2-90-002

reported that

MOVATS had failed to adequately train its

technicians

and

gC personnel

with respect to electrical

cable

splicing for MOVs.

In discussing this failure with the

inspectors,

the licensee

demonstrated

that the deficiency in .

the training of MOVATS personnel

had been identified by

licensee quality assurance

personnel

and that prompt attention

f

0

I<,

l

17

had been qiven to ensuring that

MOVATS personnel

receive onsite

training sn the deficient areas.

4.8.3

~Di

ti

The licensee

uses

MOVATS diagnostic

equipment to obtain values

for the thrust delivered by the motor operator in opening

and

closing the valve.

The licensee relies

on the accuracy

values

~

rovided by MOVATS for this equipment but has not verified the

OVATS published accuracy.

It is also

known that

MOVATS

accuracy differs between the opening

and closing direction of

the

The licensee

does not appear to consider this

information.

MOVATS Engineering

Ressort 5.0

(REV. 0, January

1991),

"Equipment Accuracy Summary, 'rovides

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.

The inspectors

noted that

the licensee

had not responded

to this report.

The licensee

committed to evaluate

the current industry testing

of MOVATS equipment

and to incorporate the results of that

testing,

as necessary.

The inspectors

also

recommended

that the

licensee

evaluate

rate of loading effects

and va]ve stem

directional effects to ensure

adequate

margin exists in the

capability of the motor operator to open

and close valves within

the

GL 89-10 program.

This will be

a followup item for future

inspections.

(Followup Item 50-397/91-16-12).

4.8.4 Modifications

Modification packages

were reviewed by the inspectors.

The

packages

appeared

thorough

and complete.

The detailed

checklists

provided with the packages

were helpful and appeared

to be a useful tool towards establ>shing

thorough

considerations

of the critical issues

affected

bv the

modifications.

No problems

were identified in this area.

4.8.5 Maintenance

The inspectors

observed portions of overhaul

and testing

activities.

In general,

the overhaul activities were found to

be well controlled.

In discussions

with the maintenance

personnel,

the inspectors

found all to be knowledgeable

and

familiar with MOV problem areas.

Further,

the inspector

observed detailed procedures

in use during the maintenance

activities.

The inspectors

observed

several

deficiencies

which were brought

to the attention of the maintenance

supervisor for resolution.

a.

a wiring lug interfering with a torque switch arm

b.

a missing arc guard

on a torque switch

c.

failure to remove

a storage

desiccant

pack from a

K

f,I

i,

,l

I

d.

e.

h.

MOV switch compartment

failure to remove spring pack calibration tags after

replacement

with a different spring pack

failure to replace limiter plates

when

a lower

maximum torque switch setti.ng

was specified

an actuator oriented vertically with the spring pack

on the bottom

T-drains installed at the high point of a motor

(drain not required for environmental qualification)

motor nameplate

data that disagreed

with the

MDS

The inspectors

found that deficiencies

encountered

during

overhaul activities were not consistently

documented

as

required

by plant procedures.

Informal tracking of the

frequency of such problems

was apparently

used to some extent

in lieu of documentation

on each work package.

The inspectors

found this to be another

example of weakness

in documenting

~

deficiencies.

This subject

was discussed

in detail in section

4. 6 of this report.

4.8.6 Industr

Ex erience

The underlying premise of GL 89-10 is that industry experience

and research

has

shown that the

use of industry standard

equations to predict

MOV performance

may not be conservative.

The approach outlined in GL 89-10 is: first

to verify the

existence of sufficient margin to reestablish

adequate

assurance

of MOV operability in light of recent industry

insights;

and,

second,

to the extent practicable,

to assure

that safety related

MOVs are tested at maximum design

conditions in order to demonstrate

operability.

MNP-2 continues to use the old industry standard

equations

and

valve factors

and does not account for motor performance at

elevated

temperature,

fluid flow rate, fluid temperature,

and

seismic/dynamic effects.

This places

heavy reliance

on the

design basis testing portion of the program.

The licensee

was

cautioned that failure of a

MQV to perform its safety function

under design basis test conditions would subject not only a

"failed" MOV to an evaluation for operability, but also all

other

MOYs which use the

same design methodology.

MNP-2 is the only Region

V operating nuclear power plant which

does

not participate in the Region

V MOV users

group.

Some of

the deficiencies

observed at MNP-2 had already

been identified

at other Region

V nuclear plants.

The licensee

program for the receipt

and distribution of

Limitorque supplied information and the incorporation of

industry experience

was reviewed.

The licensee

had established

an active interface with vendors to solicit technical

update

information.

Designated

licensee

recipients

had been

identified to be included

on distribution mailing lists.

Plant

personnel

were periodically reminded of plant requirements

I

19

regarding the receipt

and handling of unsolicited vendor

technical

information.

All Limitorque Maintenance'Updates

had been received

by the

plant and had been included within their vendor information

program.

The inspectors

emphasized

the necessity for appropriate

review

of applicable

vendor information on a timely basis to assure

that the best available

data is disseminated

and used within

the program.

4.8.7 ~li

T ti

WNP-2 stroke time acceptance

criteria did not consider motor

speed

changes

under load or degraded

voltage conditions.

In

the case of DC MOVs this will significantly affect motor speed

and,

hence,

stroke time.

The inspectors

recommended that the

licensee

review their acceptance

criteria for DC MOVs to ensure

that they are appropriate

under design basis conditions.

DC

motor speed is both load and voltage dependent.

If the design

basis

DC MOV safety function is time critical and credits

operations of the

MOV under

maximum

DP and degraded

voltage

conditions,

the acceptance

criteria for testing should either

demonstrate

acceptable

time under those design basis conditions

or account for the anticipated effect by including an appropriate

margin within the test acceptance

criteria.

The inspectors

noted that the static zero pressure

stroke times

for some

MOVs were already close to

FSAR acceptable

stroke

times.

This will be

a followup item for future inspections.

(Fo1 1 owup Item 50-397/91-16-13)

4.8.8

Im lementation of Su

lement

3 Recommendations

The licensee

provided responses

to Supplement

3 of GL 89-10 in

letters

on December 12, 1990,

and March 12, 1991.

In the March

12 response,

the licensee

indicated that

2 MOVs in the

RWCU

system

(RWCU-V-1 and 4) and

2 MOVs in the

RCIC system

(RCIC-Y-8

and V-63) were within the scope of Supplement

3 to GL 89-10 at

WNP-2.

The licensee

stated that the sizing and setpoint

calculations for the

RWCU MOVs had been re-performed

using

a

valve factor consistent with information obtained

from the

NRC-sponsored

MOY tests.

The licensee

stated that the

RWCU

MOVs would be diagnostically tested

under static conditions

during the Spring 1991 outage.

The licensee

stated that the

calculations for the

RCIC MOVs continued to use the typical

industry valve factor for flexwedge gate valves,

but that the

torque switches

were bypassed for 98X of the closing stroke.

The licensee

stated that due to its similarity with one of the

valves in the

NRC sponsored

tests,

RCIC V-63 had been evaluated

in light of the Supplement

3 information.

The evaluation

verified RCIC V-63 to have sufficient thrust capability.

20

The inspectors

reviewed the available

MOV calculations

and

raised several

concerns

to the licensee.

First, because

Manual

Calculation NE-02-87-29 (Rev.O) for RCIC-V-63 had not been

updated, it was not appare'nt that RCIC-V-63 had been evaluated

for thrust capability.

Second,

during the course of the

inspectors'uestions

on RCIC-V-8, the licensee identified an

error in Manual Calculation NE-02-90-17

(Rev. 1) for RCIC-V-8

regarding failure to consider voltage loss

between

the motor

control center

(MCC) and the motor operator.

(Note that this

report already identifies Deviation Item 50-397/91-16-04 for

qualifying the motor for 87K degraded

voltage,

the voltage at

the

MCC, rather than

SOX degraded

voltage at the motor operator

as committed in the licensee's

FSAR.)

Third, the licensee

had

not considered

rate of loading effects in their

calculations.

The licensee

committed to re-evaluate

the

calculations for the 4 MOVs within the scope of Supplement

3 to

GL 89-10 and to resubmit

a response

to the generic letter

supplement, if necessary.

The inspectors

also reminded the

licensee of the obligation to evaluate

the operability of those

MOVs upon concluding their calculations.

This wH 1 be

a

followup item for future inspections.

(Followup Item

50-397/91"16-14)

5.

Summar

of Overall

Pro

ram Administration

Based

upon the status of the licensee's

GL 89-10 program

and weaknesses

observed in the licensee's

technical

approach to reestablish

adequate

confidence of MOV operability, the following areas

are deserving of the

licensee's

prompt attention.

The current

MOV program does not adequately utilize industry

knowledge

and exper)ence.

2)

3)

The level of Supply System

management

attention

and commitment

to the

MOV program to assure

technical

work quality and test

program progress

needs

improvement.

The gA organization

needs to improve in their level of

oversight of program activities to assure that deficient

conditions are well documented,

that commitments to the

NRC are

followed, and that any deficiencies

are brought promptly to the

attention of senior

management.

A brief discussion of examples of observed deficiencies

in these

areas

follows:

Need for im roved utilization of industr

knowled

e and ex erience

e un er ylng premise

o

-

)s

a

)n us ry, experience

and research

has

shown that the industry standard

equations

to

predict

MOV performance

may not be conservative.

If

, tII

21

WNP-2 continues to use the old industry standard

equations

and

valve factors

and does not account for motor performance at

elevated

temperature,

fluid flow rate, fluid temperature,

and

seismic/dynamic effects.

This places

heavy reliance

on the

design basis testing portion of the program.

The inspectors

cautioned the licensee that failure of a

MOV to perform its

safety function under design basis test conditions would

subject not only a "failed

MOV to an evaluation for

operability, but also all other

MOVs which use the

same

design

methodology.

WNP-2 is the only Region V operating nuclear

power plant which

does not participate in the Region

V MOV users

group.

Some of

the deficiencies

observed at WNP-2 had already

been identified

at other Region

V nuclear plants.-

Need for im roved mana

ement attention

and commitment to

e

ro ram

ome

ime ago

e

icensee

s origina

V Coordinator

was taken ill.

Approximately 6 months

lapsed during his recuperation

in which little was accomplished

towards completing the licensee's

GL 89-10 commitments.

It

appeared that management

and oversight of the

MOY program at

WNP-2 had languished

in the interim.

WNP-2's allocation of resources

for the program appears

sparse.

At the time of the inspection,

only one engineer,

the

new

Coordinator,

was fully dedicated to the program,

and most of

his efforts had been

focused

on problems

encountered

during the

current outage.

According to the licensee's

program description,

approximately

30X of the

MOV design basis testing should

have

been

completed

by the time of the inspection.

At the time of the

inspection,

none of these tests

had been per'formed.

The

situation was

compounded

by the fact that test procedures

had

not been developed.

Need for im roved

A oversi ht of

ro ram activities

and

e icienc

ocumen

a ion

po

c ec

s

y

e

organization

a

i en i ie

signi scant findings which indicated program

weaknesses

symptomatic of an inadequate

program.

Two years of

this five year program

had passed.

Yet a comprehensive

audit

of the program

had not been performed,

nor was it clear that

identified problems

had been brought fully to the attention of

senior management.

The following were examples of significant findings by the gA

organization that should

have alerted

gA to inadequacies

in the

MOV program:

gA Surveillance

Report

No. 2-91-009 identified failures to

meet schedules

and

INPO commitments for MOV testing

and

refurbishment.

The report attributed

some of these

failures to lack of manpower.

22

The technical

assessment

group identified errors in

several

Master Data Sheets

(MDS} and discrepancies

in the

MDS procedures.

The

MDS are

key to contro11ing