ML17306A183

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Insp Repts 50-528/91-25,50-529/91-25 & 50-530/91-25 on 910708-910813.Violations Noted.Major Areas Inspected:Safety Related Motor Operating Valves
ML17306A183
Person / Time
Site: Palo Verde  
Issue date: 09/23/1991
From: Huey F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17306A181 List:
References
50-528-91-25, 50-529-91-25, 50-530-91-25, NUDOCS 9110070133
Download: ML17306A183 (28)


See also: IR 05000528/1991025

Text

U. S.

REGULATORY COMMISSION

~Re ion

V

50-528/91-25,

50-529/91-25,

50-530/91-25

Docket Nos.

50-528, 50-529,

50-530

License

Nos.

NPF-41,

NPF-51,

NPF-74

Licensee:

Arizona Public Service

Company

P. 0.

Box 53999, Sta.

9012

Phoenix,

Arizona

85072-3999

~Pili:Pl

d

5

1

5

102

1 .0/

1.2

d3

Ins ection Conducted:

July 8 through August 13,

1991

D. Corporandy,

Reactor Inspector,

Region

V

C. Myers, Resident

Inspector,

Region

V

C. Clark, Reactor Inspector,

Region

V

T.

S

Senior

echanical

Engineer

(NRR)

R.

'n,

MOV Cons

tan

(Contractor,

INEL)

A

roved

b

F.

R. Huey, Chief

Engineering Section

Date Signed

Ins ection

Summar

Ins ection

on Jul

8 throu

h Au ust

13

1991

Re ort Nos. 50-528/91-25

50-529/91-25

50-530 91-25

A~id:

981

1

P

1

1

20 ll

'

1

1

89-10

program for safety-related

motor operated

valves.

(SIMS Issue

GL 89-10)

Temporary Instruction 2515/109

was

used

as guidance for the inspection.

Results:

General

Conclusions

and

S ecific Findin

s

In general,

the inspection findings indicated that the licensee

was developing

an aggressive

program for assuring

MOV reliability.

Program strengths

were

found in the areas of scope

and test scheduling.

Meaknesses

were identified

in the areas

of program implementing procedures,

overall

program integration,

test acceptance

criteria, review of vendor information notices, corrective

actions

and trending.

Summar

of Violations

t

Two violations were identified.

One violation involved a failure to

adequately

review

a test deficiency of torque switch chattering for potential

reportability under

10 Part

CFR 21.

(Enforcement

Item 50-528/91-25-06;

refer

q1 go070133

~~OO~~~~~

PDR

ADOCK 0

pDR

6

-2-

to Section 4.6.)

A second violation was identified involving a .failure to

establish

appropriate

acceptance

criteria for MOV testing.

(Enforcement

Item

50-528/91-25-02;

refer to Section 4.4.)

0 en Items

Summar

Nine new followup items were identified:

91-25-01

91-25-03

91-25-04

91-25-05

91-25-07

91-25-08

91-25-09

91-25-10

91-25-11

Motor Sizing for 75K degraded

voltage (p.5)

Test acceptance

criteria (p.8)

Periodic verification (p.9)

Adequacy of test procedure

notes to preclude actuator

over-thrusting

(p. 10)

CAR 91-0021

(p.15)

Vendor services

and software (p.15)

Margin for accuracy

and rate-of-loading

(p.17)

Implementation of vendor information (p.18)

NRR evaluation of DC MOV stroke time (p.19)

TABLE OF

CONTENTS

Section

~Pa

e

1.

PERSONS

CONTACTED

2.

BACKGROUND

3.

INSPECTION

PLAN

4.

MOV PROGRAM REVIEW

4.1

Scope

4.2

Design Basis

Reviews

4.3

MOV Sizing and 'Switch Setting Calculations

4.4

Design Basis Differential Pressure

and Flow Testing

4.5

Periodic Verification of MOV Capability

4.6

MOV Failures,

Corrective Actions and Trending

t

4.7

Schedule

13

4.8

4.8.1

4.8.2

4.8.3

4.8.4

4.8.5

4.8.6

5.

6.

7.

Other

MOV Program Areas Addressed

Control of MOV Switch Settings

Training

Diagnostics

Maintenance

Industry Experience

and Vendor Information

Inservice Testing

SUMMARY OF OVERALL PROGRAM ADMINISTRATION

EXIT MEETING

LICENSEE

DOCUMENTS REVIEWED

14

14

15

16

17

18

19

19

20

20

PERSONS

CONTACTED

DETAILS

J. Levine, Vice President,

Nuclear Production

B. Ballard, Sr., Director,

QA

J. Bailey, Director,

NED

G. Overbeck, Director,

STS

J.

Hesser,

Manager,

Nuclear

ICE

J. LoCicero, Manager,

ISE

A. Ogurek, Manager,

NSLL

P. Prandjes,

Manager,

CAG

C. Russo,

Manager,

QC

R. Prabhaker,

Manager,

QE/QA

M. Radoccia,

Manager,

SNED

D. Blackson,

Manager,

Central

Maintenance

B. Webster,

Manager,

Component Engineering

T. Bradish,

Compliance

Manager

R. Badsgard,

Assistant

Manager of Nuclear Projects,

SNE

T. Weber, Supervisor,

Component

5 Speciality

S.

Coppock, Supervisor,

Component Engineering

(MOV Coordinator)

R. Rogalski, Audit Supervisor,

QA

A. Khanpour, Engineering Supervisor,

Site Nuclear

N. Eidsmoe,

Procurement

Engineering Supervisor

W. Weems,

Elec/HVAC Supervisor,

CMPO

E. Smith,

MOV Supervisor,

Nuclear

ICE

R. Rouse,

Compliance Supervisor

R. Ebann,

MOV Foreman,

Central

Maintenance

J. Baxter,

Compliance

Engineer

T. Phillips,

IEC Senior Engineer,

SNED

J. Zaghloul, Senior Electrical Engineer,

SNED

S. Schroeder,

Senior Electrical Engineer,

NED

S. Kanter, Senior Coordinator,

Owner Services

R. Henry, Salt River Project Site Representative

J. Draper,

SCE Site Representative

B. Druin, Consultant,

CMPO

The inspectors

also interviewed other licensee

and contractor

personnel

during the course of the inspection.

  • Attended Exit Meeting

BACKGROUND

Generic Letter (GL) 89-10, "Safety-Related

Motor-Operated

Valve Testing

and Surveillance,"

dated June

28,

1989 requested

that licensees

establish

a program to ensure that switch settings for safety-related

motor-operated

valves

(MOVs) and certain other

MOVs in safety-related

systems

are selected,

set

and maintained properly.

Supplement

1 to

GL 89-10 provided the results of public workshops

on the implementation of

the Generic Letter.

Supplement

2 to

GL 89-10,

dated August 3, 1990,

stated that inspections

of programs

developed in response

to

GL 89-10

would begin January

1, 1991.

In response

to concerns

raised

by the results of NRC sponsored

MOV tests,

Supplement

3 to GL 89-10, dated October 25,

1990, requested all licensees

to consider the applicability of the information obtained

from the

NRC-sponsored

tests

to MOVs within the scope of GL 89-10 and to consider

this information in the development of priorities for implementing the

Generic Letter program.

GL 89-10 requested

that licensees

submit

a response

to the Generic Letter

by December 28,

1989.

In a letter on that date,

the licensee

committed

to implement the recommendations

of GL 89-10 and stated that

a schedule

would be provided by June

28,

1990.

The licensee

indicated,

however,

that their commitment might be revised if experience

showed that testing

every

MOV was unnecessary.

In a letter dated July 2, 1990, the

NRC staff

acknowledged

the licensee's

response.

INSPECTION

PLAN

The inspection

was performed in accordance

with Temporary Instruction

(TI) 2515/109,

"Inspection Requirements for Generic Letter 89-10,

Safety-Related

Motor-Operated

Valve Testing

and Surveillance,"

dated

January

14,

1991.

The inspection

focused

on Part

1 of the Temporary

Instruction (TI), which involves

a review of the program being

established

by the licensee

in response

to

GL 89-10.

The inspectors

did

not address

Part

2 of the TI, which involves

a review of program

implementation,

except to assist

in evaluating

the licensee's

GL 89-10

program.

The inspectors

reviewed the licensee's

program commitments

as established

in their December

28,

1989 response

and the Palo Verde Nuclear Generating

Station

NRC Generic Letter 89-10 Program

document

(Rev. 1, July 5, 1991)

and supporting documentation.

In addition, the inspectors

discussed

program details with licensee

personnel.

YiOV PROGRAM REVIEW

~Sco

e

GL 89-10 Recommendations

and Licensee

Commitments

GL 89-10 recommended

that all safety-related

MOVs and other

YiOVs 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.

The licensee

response

to

GL 89-10,

committed to the scope of the program

as

recommended

in GL 89-10.

Observations

A review of the licensee's

GL 89-10 program

scope

was conducted

using the

licensee's

"Implementation Plan for NRC Generic Letter 89-10," Revision

1, dated July 5, 1991,

and other available

documents.

The licensee's

GL 89-10 program included

117

MOVs per unit. Yiost of these

MOVs have

Limitorque actuators.

However, the inspectors

noted

some Rotork and EIN

actuators

in the licensee's

GL 89-10 scope.

The inspectors

noted that the scope of the licensee's

program included

safety related

MOVs, MOVs in safety related

systems that could be

inadvertently mispositioned

from the control

room,

and

MOVs for which

credit was taken in the Emergency Operating

Procedures

(EOPs).

The inspectors

also noted that the licensee

had planned to extend

many of

the recommendations

advocated

in GL 89-10 to MOVs outside of the

GL 89-10

scope.

Conclusion

The inspectors

determined that the scope of the licensee's

program

appeared

to be 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.

The licensee

had contracted with Combustion

Engineering

(CE) to provide worst case

pressure,

flow, and differential

pressure for each of the valves in the

GL 89-10 scope.

The licensee

used

the

CE design

data

as input to their initial NOV sizing and switch

setting calculations.

The inspectors

noted that the licensee

had only recently developed

a

procedure for conducting design basis

reviews.

The inspectors

reviewed

procedure

81DP-4DC10, Revision 0, "Motor Operated

Valve Design Basis

Review and Thrust/Torque Calculation,"

and found that it appeared

to

adequately

address

the guidelines set forth in GL 89-10.

The inspectors

found that no similar specific guidance

had

been established

by the

licensee for the original design

basis

review performed

by CE.

According

to the licensee,

the initial CE review established

conservative

bounding

values for the worst case conditions for cases

where the specific design

basis conditions

had not been determined.

The licensee

committed to

review the

CE pressure,

flow, and differential pressure

design input to

verify compliance with their procedure

by December

31, 1991.

This

schedule

commitment date

was reflected in their business

plan.

The inspectors

cautioned

the licensee that if the approved

design basis

review reveals

a different differential pressure

than the previously used

CE value, the licensee

may need to repeat

NOV sizing

and torque switch

setpoint calculations,

reset the affected

NOV torque switches,

and repeat

the design basis testing.

This could impact the licensee's

program

schedule.

The licensee's

design

basis

reviews will be examined in a

future inspection.

Conclusion

The inspectors

determined that the licensee

appeared

to have developed

adequate

plans

and procedures for the performance of design basis

reviews.

4.3

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 revise

as necessary,

the methods for selecting

and setting

all

NOV switches.

The licensee

committed to follow the recommendations

of GL 89-10.

Observations

a 0

The inspectors

reviewed selected

calculations

and licensee

procedure

13-JC-ZZ-201,

"YiOV Thrust, Torque

and Actuator Sizing Calculation,"

Revision 0, dated

1991, which the licensee initially utilized for

sizing

NOVs and calculating their switch settings.

The inspectors

found that the licensee's

calculations

and procedure

did not

consider the effects of elevated

temperature

on motor performance

and cable losses for degraded

voltage calculations.

Furthermore,

the licensee

did not consider motor ambient temperature

in sizing

their thermal

overload protection devices

(TOLs).

The licensee

had

not included margin to account for rate-of-loading effects,

nor had

any, margin been established

to account for seismic/dynamic

loading.

The inspectors

found that many of these

concerns

and other

programmatic

weaknesses

were addressed

in Revision I of the Palo

Verde "Implementation

Plan for NRC Generic Letter 89-10" which was

issued

during the inspection.

In particular, the revised plan

committed to consider the following:

Physical

valve orientation, piping configuration

and fluid type

Component

weak link analysis

based

on

ASNE Code allowable

stresses

(Seismic

and stem thrust/torque

values to be considered)

Control circuit logic for the purpose of determining proper

torque/limit switch settings

and thermal

overload configurations

Degraded voltage effects

due to power supply and cable sizing,

cable

impedances

accounting for in-rush or locked rotor currents,

and temperature effects

under

normal

and abnormal

conditions

and

thermal

overload sizes

Evaluation of motor capabilities

with respect

to operating

temperature

requirements

The implementation

plan also committed to consider

rate-of-loading effects

as more data

became available.

The inspectors

observed that licensee calculations

were not

consistent

in their use of an assumed

valve stem friction

coefficient in establishing

stem factors.

The values varied from

0.2 to as

low as 0.1.

These values

would correspond

to assumed

lubrication quality ranging from poor to ideal.

The licensee

was

cautioned that use of non-conservative

valve stem friction

coefficients lower than 0.2 would require specific justification.

The inspectors

found that the licensee

had not included any margin

in their calculation of the minimum required target thrust setting

to account for potential

degradation

of valve stem lubrication

between maintenance/lubrication

intervals.

Furthermore,

the

inspectors

found that the licensee

adjusts

the torque switch setting

using

MOVATS diagnostic

equipment after cleaning

and lubricating the

valve stem.

Since the licensee

could set the torque switch at the

minimum required thrust under these

ideal lubrication conditions,

the inspectors

were concerned that any subsequent

degradation of the

lubricant quality over time would result in inadequate

thrust

capability.

(Refer to Section 4.8.4 for further discussion)

In response

to the inspectors'oncern,

the licensee identified that

general

procedural

guidance

had been established

to set torque

switch settings

to the high end of the specified target window to

establish

a margin for degradation.

The inspectors

found no instances

of torque switch settings at the

minimum value.

However, the inspectors

recommended

that the

licensee

consider the

need to more formally account for lubrication

degradation within their setpoint methodology

and controls.

In

addition, the inspectors

emphasized

the need for justification of

the assumed

consistency of lubrication based

on feedback

from the

licensee's

ongoing preventative

maintenance activities.

(Refer to

Section 4.8.4 for further discussion.)

The inspectors

noted that the Palo Verde

FSAR stated that Class

1E

motors were specified to perform under

75K degraded

voltage.

However, the inspectors

observed that certain

GL 89-10

MOVs with

Class

1E motors were

shown

by calculation to be inadequate

to

perform under worst case

design conditions at 75K degraded

voltage.

The inspectors

noted that the current equations for demonstrating

MOV operability under degraded

voltage conditions were more

conservative

than those

used in the original design (e.g. valve

factors for most flex wedge gate valves

had

been increased

from 0.3

to 0.4).

The inspectors

also noted that Palo Verde degraded

voltage

protective relays would typically limit maximum degraded

voltage to

far less

severe

conditions than

75K degraded

voltage.

Further, the

inspectors

expressed

concerns that established

design margins

were

being reduced.

This is

a followup item (Followup Item

50-528/91-25-01).

d.

The inspectors

observed that the licensee

had incorporated

recent

industry experience

into their calculational

methodology.

The

licensee's

calculations for flex wedge gate valves

used

a valve

factor of 0.4 which was more conservative

than the standard

industry

valve factor of 0.3.

Furthermore,

the inspectors

observed that,

on

a case-by-case

basis,

valve factors

had

been increased

from 0.4 to 0.5 as

a result of test

fai lures.

The licensee

had performed several differential pressure

tests to demonstrate

NOV operability

under design basis conditions.

The tests for auxiliary feedwater

(AFW) valves

13AFBUV0034 and

13AFBUV0035 failed on the first attempts.

The subsequent

increase

in torque switch setting

and thrust was sufficient to achieve valve

operability

when the subject

AFW NOVs were retested

at design basis

differential pressure.

The inspectors

were concerned,

however, that

the licensee

had increased

the valve factor as

a corrective action

only for the test failures without evaluating

the generic

applicability to other flex wedge gate valves which had not yet been

tested.

The licensee

responded that evaluation of the adequacy of

their calculational

methodology would be addressed

at the conclusion

of their test program when the fai lure data could

be statistically

assessed.

However, the inspectors

emphasized

the need for a more

timely evaluation of the generic applicability of the test results

to ensure that the licensee's

interim program

was conservatively

established.

The licensee

acknowledged

the need to evaluate their

DP test data in a more timely manner.

The inspectors

considered

the licensee's

use of an increased

valve

factor as corrective action on a case-by-case

basis in lieu of an

identifiable root cause

to be

a weakness

in'the development of the

licensee's

program.

Conclusion

The inspectors

determined that the licensee

had not yet adequately

established

procedures

for performing calculations

to verify proper

sizing of NOVs and setting of their switches.

4.4

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

NOV.

A two-stage

approach

was

suggested

for situations

when design basis testing in-situ was not

practicable

and when

an alternate

method of demonstrating

NOV capability

could not be justified at the time.

With the two-stage

approach,

a

licensee

would evaluate

the capability of the

NOV 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, except that with regard to testing all

MOVs

where practicable,

the licensee

requested

to reserve

the option to reduce

the scope of their design basis testing

program if subsequent

industry

developments

and results of the licensee's

testing

program could provide

justifiable alternatives.

Observations

a ~

b.

The licensee

uses

NOVATS diagnostic

eauipment

during testing.

The

parameters

measured

as part of the licensee's

testing

program

appeared

consistent with current industry recommendations.

The

licensee

had

an aggressive

plan for full flow differential pressure

testing

and

had completed

31 differential pressure

tests

by the time

of the inspection.

The licensee

was in the process

of prioritizing

the

NOV test schedule

by NOV safety significance

based

on input from

the licensee's

Probability Risk Assessment

Group.

The inspectors

considered

these

aspects

of the testing

program to be strengths.

The inspectors

reviewed licensee test procedures,

73TI-9ZZ43 and

73TI-9ZZ44, Rev. 0, which were used for design

basis testing of MOVs

in the

AFW and SI systems

in Unit 3 during April, 1991.

The

inspectors

noted that the procedures

had

no acceptance

criteria for

the design basis test data,

nor did they use the test data

as

feedback into their calculations.

However,

when

a valve failed to

operate,

the licensee

would modify valve factors to accommodate

the

increased

torque/thrust

requirements for the failed NOV.

Failure to incorporate appropriate

acceptance

criteria in the

DP

test procedures

is an apparent violation of 10 CFR Part 50, Appendix

B. (Enforcement

Item 50-528/91-25-02)

The inspectors

emphasized

the intended twofold pur pose of design

basis differential pressure

(DP) and flow testing: first, to

demonstrate

MOV capability to perform under design basis conditions;

and second,

to provide input for validating or refining the

licensee's

design methodology.

Without acceptance criteria, the

DP

testing

cannot satisfy these goals.

Of the

31

NOVs which underwent

DP testing,

6 failed to perform their

design function.

The failures involved

AFW valves.

Subsequently,

the valve factors for these

valves

were adjusted

from 0.4 to 0.5 and

calculations for required thrust were revised.

However,

as pointed

out in the previous section,

the licensee

had not attempted to

determine applicability of the observed

phenomena

to other similar

valves.

The inspectors

reviewed other

DP tests

which had demonstrated

NOVs

to perform their design function.

For Unit 3 Safety Injection

Valves SI-V-666 and SI-V-667, the inspectors

found that the

DP test

results indicated

a lower available margin than predicted

by the

licensee's

design calculations.

The inspectors

stressed'the

importance of verifying available margin as part of the test

acceptance criteria.

Available margin is important,

because

the

DP

tests

do not simulate all design conditions.

For example,

DP tests

are not conducted

under degraded

voltage or seismic/dynamic

conditions.

Despite completion of 31

DP tests at the time of the inspection,

none of the

MOVs were considered

by the licensee to have completed

their

GL 89-10 program.

The licensee

considered their program to be

developing

and acknowledged

the need for specific acceptance

criteria which was being prepared for future testing.

The inspectors will review the licensee's

DP test acceptance

criteria and their review of test data in a future inspection.

(Followup Item 50-528/91-25-02)

Conclusion

The inspectors

considered

the licensee's

design basis

measured

test

parameters,

number of NOVs presently

scheduled for testing,

and the fact

that

31

DP tests

had already

been conducted to be

a program strength.

However,

due to the lack of test acceptance

criteria and timely review of

test results,

the inspectors

concluded that the licensee

had not yet

adequately

established their program for demonstrating

the capability of

NOVs through design basis differential pressure

and flow testing.

4.5

Periodic Verification of MOV 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

MOV 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

NOV as well as its

maintenance

and performance history, but the interval should not exceed

5

years or 3 refueling outages.

Further,

the capability of the

NOV should

be verified, if the

NOV is replaced,

modified, or overhauled

to an extent

that the existing test results

are not representative

of the

NOV.

The

licensee

committed to follow the recommendations

of GL 89-10.

Observations

a.

The inspectors

reviewed the licensee's

procedures for post

maintenance

testing,

including Nuclear Administrative and Technical

Manual

30AC-9WP04 (Rev. 1, November 1, 1988), "Retest,"

and

73PR-9ZZ04

(Rev. 2, July 28, 1989), "Valve Motor Operator Monitoring

and Test Program."

The licensee

indicated that they intended to use

NOVATS static tests to measure thrust before

and after packing

adjustments

in conjunction with stroke time tests.

The inspectors

noted that the licensee's

post-maintenance

test procedures

did not

clarify when the use of diagnostic thrust tests

were required to

verify MOV capability for other types of maintenance activities.

The licensee

acknowledged

the concern

and committed to revise their

procedures.

The inspectors

also

recommended

that the licensee

review their procedures

to identify where thrust diagnostics

would

be needed to verify NOV operability for other

MOV maintenance

items.

b.

The inspectors

noted that the licensee

was in the process of

formulating their perio'dic verification and testing

program for

MOVs.

The inspectors

noted that the results of NRC sponsored

testing

had

shown that current static testing methods .were not

capable of detecting certain

MOV performance deficiencies

which

dynamic testing

had been able to detect.

The inspectors

emphasized

to the licensee that the use of static testing alone for periodic

verification would require justification.

The inspectors will review the licensee's

plans

and procedures for

periodic verification of NOV capability during

a future inspection.

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

Conclusion

Since the licensee

had not yet finalized this area of their

GL 89-10

program, the inspectors

determined that the licensee

had not yet

adequately

developed

plans

and procedures

for periodic verification of

the capability of NOVs.

4.6

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

NOV 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 MOV operability.

These trends

could provide the

basis for a licensee

revision of the testing frequency established

to

periodically verify adequate

NOV 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

a.

The inspectors

reviewed the over-thrusting

event of auxiliary

feedwater

MOV 3JSGAUV134,

as described

by Engineering Evaluation

Report

EER-NO-033.

The inspectors

noted that in evaluating

the

adequacy of the motor sizing, the

EER credited the dc motor as

capable of operating at 110$ torque rating without justification.

The licensee

did not consider elevated

ambient temperature

effects

in this evaluation.

In addition, the licensee

used

a stem friction

coefficient of 0.12 (as

compared to the more conservative

value of

0.20) without justification.

Based

on standard

sizing calculations,

the inspectors

concluded that it appeared

that the motor would have

been inadequately

sized to provide the required torque under

degraded

voltage conditions.

Hence, it did not appear that an

adequate

margin was established

to ensure that the subject motor

would not have stalled before the point of torque switch trip. Since

10

the thermal

overload protection is bypassed

during safety features

actuation, stalling or jamming of this valve could have resulted in

burn-out of the motor.

Subsequent

modifications

made

by the licensee

resulted in the

actuator thrust exceeding

the Limitorque rating in the opening

direction.

In attempting to justify the acceptability of this as-

left condition, the licensee

used

an industry study which had not

been

reviewed or approved

by Limitorque.

Further,

the licensee

did

not have

a documented

evaluation of the study.

While encouraging

the licensee to incorporate current industry experience

and the best

available data into their program,

the inspectors

cautioned

the

licensee

to ensure that design input data

and references

were

properly reviewed

and approved within established

design control

measures.

The inspectors

noted that over-thrusting would occur principally

during valve testing

under static conditions rather than under

design basis conditions.

The licensee

recognized this fact and the

need to limit the thrust experienced

by the actuator during testing.

The licensee

had prepared

notes to inform test personnel

to lower

the torque switch setting prior to static testing to avoid

over-thrusting

the actuator.

In a future inspection,

the inspectors

plan on reviewing the adequacy of these test procedures

notes to

preclude over-thrusting the actuator in the opening direction.

(Followup Item 50-528/91-25-05)

The inspectors

reviewed selected

tests

which had

been conducted

under maximum

DP conditions

by the licensee

during the recently

completed Unit 3 refueling outage.

The inspectors

found that in two

of seven tests

conducted

on high pressure

safety injection (SI)

valves,

the valves

had failed to close completely under

maximum dp

conditions.

The safety injection valves are normally closed,

2"

Borg-Marner wye-globe throttle valves, with SMC-04 actuators.

The

valves

have

an active safety function to open

on

a safety injection

signal for cold leg injection.

The valves also perform

a passive

safety function of containment isolation in the normally closed

position.

The licensee

had determined that the electrical

contacts

in the torque switch had chattered

under flow induced vibration

causing

the actuator to intermittently interrupt operations prior to

completely closing.

The licensee installed

a stiffer contact spring

which maintains contact closure until intended actuation of the

torque switch.

Subsequent

repeat testing

was successful

with no

further incidence of chattering.

The licensee modified the two affected valves to incorporate

the

stiffer contact spring.

In addition,

as

a precaution,

the licensee

initiated work orders to modify the remaining six safety injection

valves

and two mini-recirculation valves for the safety injection

pumps in all three units.

The licensee

had considered

the flow

induced vibration to be unique to the test conditions

and not

representative

of either normal or design basis conditions.

As such

the test deficiency was not considered

to affect the operability of

the

MOV or its capability to perform its safety function under

design basis conditions.

The inspectors

reviewed prior tests

conducted

on the safety

injection valves under similar conditions during startup of Unit 3

in 1984.

The inspectors

found that the licensee

had previously

encountered

the

same

problem on two other safety injection valves.

At that time,

a stiffer contact spring

had also

been installed

on

all 30 SMC-04 safety injection MOYs, along with other system

modifications to reduce

the flow induced vibration.

Successful

'epeat

testing at that time demonstrated

that the problem had

apparently

been eliminated.

(For all 30 SI

MOVs with SMC-04

actuators,

the replacement of the standard

contact springs with

stiffer contact springs in the

1984 time period constituted

the

first set of contact spring stiffness

increases.

The changeout of

contact springs during and subsequent

to the recent Unit 3 refueling

outage constitutes

a second contact spring stiffness increase.)

The inspectors

found that the licensee

had not evaluated

Part

21

reportabi lity at the time they became

aware of the problem of flow

induced vibration causing

torque switch chattering either in

November

1984 or in April 1991.

No MNCR had

been initiated as

a

result of the findings in either case.

The inspectors

noted that

NMCR No. 91-SI-1057

had

been initiated in 'July, 1991, addressing

the

previous incidents.

However, the inspectors

found that the

disposition of this

MNCR appeared

to discredit its validity, stating

that it was written based

on an misinterpretation of requirements

for operability.

At that time, the licensee

had determined that the

problem did not constitute

a defect

as defined under Part

21 and was

not reportable.

The licensee

determination

was based

on their

conclusion that the instances

of the problem were isolated to

non-representative

flow conditions

and that the problem did not

affect the ability of the affected

component to perform its active

safety related function.

The inspectors

found that the licensee

had not adequately

evaluated

the torque switch chattering

problem.

This conclusion

was

based

on

the following observations:

1.

The two mini-flow safety injection

pump valves which the

licensee

modified to install stiffer contact springs did have

a

close safety function which could be affected

by the

deficiency.

Although these

MOVs had not demonstrated

the

problem during testing,

they wet e identical to the affected

valves.

2.

The deficiency could directly affect the ability of SMC-04

Limitorque actuators

to perform an active safety related close

function due to flow induced vibration under high differential

pressure.

DCP 3CM-SI-150, dated

November 1984, identified all

30 SI valves with SMC-04 actuators

(10 in each unit) as having

the potential for torque switch chatter.

Two of the

MOYs in

each unit are located

on minimum recirculation lines

and have

an active safety function to close.

12

3.

The Limitorque actuators

were procured

as seismically

qualified.

The seismic qualification report for the safety

injection valve actuators

(N001-1.01-828-1) identified that

torque switch chattering

was

an analyzed failure mode which was

not expected

to be encountered

in operation of the actuator

under any expected vibration frequencies.

4.

Repeat

occur rences

of the deficiency in different valves

indicated that past corrective actions

had not been sufficient

to eliminate the problem.

For example,

40% (4 of 10) of the

safety injection valves in Unit 3 had experienced

the problem.

5.

The licensee

evaluation for Part

21 reportability appeared

to

restrict consideration of the deficiency to the safety function

of only the component

on which the problem was encountered.

There appeared

to be no evaluation of the safety related

functions of other applications of the component.

This

appeared

to be

a programmatic

weakness.

6.

The licensee

had not evaluated

the effect of the torque switch

chattering

on the actuator motor.

Although the thermal

overload devices

were bypassed

during the opening stroke, they

were relied on to provide motor protection during the closing

stroke.

The inspectors

were concerned

that previous repetitive

cycling of inrush current to the motor while the torque switch

chatters

may have resulted in motor degradation

which may go

undetected

and subsequently

preclude safety function operation.

The licensee initiated

a review to determine if the thermal

overload device settings

were adequate

to protect the actuator

motor when subjected

to chattering conditions.

The inspectors

considered this issue of torque switch chatter

may be

potentially reportable

under Part 21.

This issue will be forwarded

to

NRR for further evaluation.

The inspectors

reviewed Palo Verde Nuclear Administrative and

Technical

manual

Procedure

94AC-OLC02, Review of Conditions Adverse

to guality for 10 CFR 21.

The procedure

requires,

in part, that

a

finding be evaluated

and

a Reportability Evaluation Report initiated

if it is determined to be

a deviation.

Paragraph

4.2 defines

a

"deviation," in part,

as

a departure

from the technical

requirements

included in a procurement

document

(an engineering

or design

document).

However,

a Reportability Evaluation Report

was not

initiated for the reported

problem of contact chattering

due to

vibration in Limitorque SMC-04 actuation

under

MNCR 91-SI-1057.

This failure to adequately

evaluate

conditions for Part

21

reportability is an apparent violation.

(Enforcement

Item

50-528/91-25-06)

The inspectors

noted that the licensee

had reported

124

MOV failures

to the Nuclear Plant Reliability Data

System

(NPRDS) since

1986.

Of

the 124

NOV failures,

37 were identified as limit switches out of

adjustment, with normal or cyclic wear identified as

a contributor

13

for 12 of these failures.

The inspectors

noted that normal/cyclic

wear did not appear to be

a parameter

used in the design.

The inspectors

found that 28 of the

124 failures were .identified as

miscellaneous

breakdowns,

which the licensee identified as

seen only

once or twice since the three units went on line.

While the

licensee

had established

a data

base, it did not appear that the

program

was trending failures

by valve, operator

and component

type

(gate,

globe and/or butterfly), as well as service application.

Discussions

with the licensee identified the following:

A review of the last three years of NOV Work Order

(WO)

activity was in progress

or would be performed to ensure that

all

NOV failures

had been captured

by the Failure Data Trending

(FDT) system.

A review of all the identified

NOV failure data generated

over

the last three years

would be performed to ensure

the actual

root cause for each failure was clearly identified.

The inspectors

also emphasized

the importance of trending

accelerated

wear and degradation

of NOV components

in addition to

failures.

Conclusion

The inspectors

considered

NOV failure corrective actions

and trending to

be an area of weakness

in the licensee's

GL 89-10 program.

The

inspectors

determined that the licensee

had not yet adequately

developed

plans

and procedures for analyzing

NOV failures, justifying corrective

actions,

and trending.

4.7

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

18, 1994,

or 3 refueling outages after December

28, 1989, whichever is later.

The

licensee

committed to follow the recommendations

of GL 89-10.

Observations

The inspectors

reviewed the licensee's

schedule for implementation of

their GL 89-10 program.

The licensee

had organized their program into a

detailed set of tasks,

each of which had

a schedule

and was included in

the licensee's

business

plan.

In general,

the program schedule

appeared

reasonable

and well oroanized.

The inspectors

expressed

concern,

however, over certain aspects

of the

licensee's

program.

For example,

the licensee's

reliance

on unverified

design input (refer to section 4.2 of this report)

and performance of

0

testing without acceptance

criteria and without review of test results

(refer to section 4.4) left the licensee's

program vulnerable to

reiterations

and schedule

slippage, if current assumptions

establishing

adequate

margin could not be substantiated.

In order to keep

on schedule,

the inspectors

emphasized

the importance of

verifying design input, implementing

an

MOV sizing and switch settin9

calculation methodology which includes conservative

design margin to

assure

adequate

performance

under subsequent

design basis testing,

and

evaluating current

DP test data

on

a timely basis.

Conclusion

The inspectors

determined that the licensee

had apparently

established

an adequate

schedule for the completion of the

recommended

actions of GL 89-10.

4.8

Other

MOV Pro

ram Areas Addressed

4.8.1

Control of MOV Switch Settin

s

a ~

The inspectors

were concerned

that the licensee

was

no longer

controlling torque switch settings

on the ZZI-004 drawings per

their established

procedure,

but instead

were using Engineering

Evaluation

Requests

(EERs).

The

EER process

was adapted

to

provide

an expeditious

means for Engineering to specify switch

settings without the encumbering

delays

associated

with the

drawing change

process.

An open

ended

EER was utilized by Nuclear Engineering Division

(NED) to specify and change

required torque switch settings,

which were determined either by analysis

or testing.

The

licensee

referred to this information as the Interim Controlled

Motor Operator

Data

Base which was administered

through the

EER

process.

The

MOV monitoring and test procedure

(73-J-ZZI-004)

which directs the use of Drawing 12-J-ZZI-004,

had been

changed

to refer to either the ZZI-004 drawing or an

EER for the

required switch setting information.

In practice,

the

EER was

the only document which specified switch settings

during the

implementation of the

GL 89-10 program.

Mhile it appeared

that

some adaptation of the existing licensee

program was appropriate

during the

GL 89-10 program,

the

inspectors

emphasized

the importance of ensuring that program

controls

embodied quality assurance

measures

equivalent to

those within established

plant procedures.

The inspectors

noted that the licensee's

gA department

Corrective Action Report

(CAR) 91-0021 identified potential

problems associated

with keeping torque switch (TS) settings

in

an interim data

base via EERs.

The licensee's

Component

and

Specialty Engineering

group, which had primary responsibility

for the

MOV program,

had committed to respond to the

CAR within

15

b.

the next few months.

The inspectors

intend to review this in a

future inspection.

(Followup Item 50-528/91-25-07)

The licensee

was questioned

on the controls for torque switch

limiter plate removal.

The licensee

indicated that limiter

plates

could be removed if required to achieve

the specified

target thrust.

No special

or procedural

controls were in place

for the removal of torque switch limiter plates.

The licensee

was cautioned that setting torque switch setpoints

above the

maximum recommended

by Limitorque constituted

a design

change

of that actuator

and required appropriate

review prior to

implementation.

The inspectors

acknowledged that the

licensee's

GL 89-10 program procedures

incorporated

design

review measures

when they removed torque switch limiter plates.

~Tnainin

a ~

b.

The inspectors

discussed

the training program with licensee

management,

reviewed general

training requirements,

outlines

and records,

and toured the training facility.

The inspectors

noted that,

as part of the licensee's

indoctrination program, technical

personnel

were required to

complete

an orientation

package.

The orientation

package

was

tailored to specifically address

the necessary

requirements for

the applicable duties.

The packages

included requirements for

the licensee's

administrative

procedures,

goals

and objectives,-

NRC rules

and regulations,

and quality assurance

procedures;

as

well as industry codes,

technical specifications

and procedures

applicable to the employee's

duties.

The orientation

package

required signatures

by the employee

and the employee's

supervisor to acknowledge

completion.

Training and requirements for MOV personnel

appeared

adequate.

However, the need for refresher training courses for

maintenance

and testing technicians

was identified by the

inspectors

as

a potential

weakness

in the licensee's

program.

The inspectors

observed that the licensee relied heavily on

contract personnel

in their

MOV program.

The inspectors

checked

the licensee's

certification of NOVATS personnel.

Although the licensee verified that

NOVATS personnel

had

been

certified to comply with NOVATS standards,

the licensee

had not

verified the

NOVATS certification to be in compliance with the

licensee's

requirements.

The inspectors

also noted that

NOVATS

had also issued

updated

software for their test equipment

and

that the licensee

was apparently

using the updated

NOVATS

software without verifying compliance of the software to

PVNGS

standards.

The inspectors

emphasized

the licensee's

responsibility to adequately

control vendor services

and

software.

Review of vendor services

and software will be

addressed

in a future inspection.

(Followup Item

50-528/91-25-08)

16

nostics

~

4.8.3

~0i

a

~

c ~

The inspectors

found that the licensee

used

MOVATS diagnositc

test equipment to establish

required torque switch settings

during static baseline testing.

Diagnostic signatures

were

also obtained during

DP testing.

In addition, the licensee

has recently utilized stem strain

gaging

(Teledyne technique) for thrust determination during

DP

testing in Unit 3.

This technique

involves attaching strain

gauges to the valve stem

and analytically correlating output to

thrust.

Currently, the licensee

considers

the use of stem

strain gaging to provide supplemental

data,

acquired for

information only, in developing

the utility of the technique.

The inspectors

noted that no procedures

currently exist

controlling stem strain gaging nor is load cell calibration

performed

as

a check against

the analytically derived thrust

values.

The inspectors

cautioned

the licensee

against

subsequent

use of informal data to verify required torque

switch settings until the accuracy of the data

had

been

determined

and the data obtained

under appropriate test control

measures.

The licensee

acknowledged

the inspectors'oncerns.

The inspectors

informed the licensee of a recent Notice of

Nonconformance

issued to MOYATS for inadequate

verification of

equipment accuracy.

The licensee

noted that the results of

industry sponsored

testing of NOVATS accuracy would be

presented

at the upcoming

NUG meeting scheduled for the

following week.

The inspectors

stressed

that consideration

and

implementation of these results

were necessary

in order to

comply with the recommendations

of Gi 89-10.

At the subsequent

MUG meeting,

NUG released

a preliminary

report on its testing

program for NOYATS and other diagnostic

equipment.

NUG intends to release

a final report in January

1992.

During the period when results of the diagnostic testing

are being finalized by NUG, the licensee is encouraged

to take

inventory of all NOVs for which diagnostic

equipment

has

been

used to establish

switch settings.

This would provide the

licensee with some

advance

information about the number of

operability evaluations

and potential switch setting

changes

or

modifications that might be required

when the results of the

final report are released.

d.

The inspectors

noted that the licensee

had not addressed

MOYATS

Engineering

Report 5.0, Revision 0, January

1991,

"Equipment

Accuracy Summary," which provided guidance for the

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

available thrust delivered

by the motor operator

under high

differential pressure

conditions.

The inspectors

recommended

that the licensee

consider this information when they develop

their margin to account for rate-of-loading effects.

17

The licensee's

consideration

and implementation of NOVATS

accuracy

and rate-of-loading effects will be reviewed in a

future inspection.

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

Maintenance

a ~

b.

The inspectors

reviewed detailed assembly/disassembly

maintenance

procedures

for the licensee's

Limitorque, Rotork,

and

EIM motor operated

valve actuators.

The Limitorque

procedures

had recently

been

issued for use;

however, the

Rotork and EIN procedures

were still in draft form.

The

inspectors

found that these

procedures

appeared

to be

adequately detailed,

including requirements for maintenance

and

testing

and special tools.

The inspectors

observed that the licensee

had

an

18 month

preventative

maintenance

(PM) program for their NOVs.

The

inspectors

observed that several

of the maintenance

procedures

were lacking in details for identifying and recording excessive

wear and degredation.

For example,

the licensee's

preventative

maintenance

procedure

32NT-9ZZ48 did not require specific

observation

or evaluation of the as found condition of the stem

thread lubricant.

The inspectors

noted that such observations

were required for the quantity and quality of the actuator

housing lubricant and the limit switch lubricant.

The

inspectors

emphasized

that since there

was

no established

frequency for actuator overhaul,

the

PN observations

of

degradation

constituted

the only established

opportunity to

thoroughly assess

the actuator for unexpected

degradation.

The inspectors

observed that the licensee's

program did not

include provisions for confirming assumptions

embodied in the

calculational

methodology.

As described

above,

as-found

stem

lubricant quality was not observed

during

PN activities.

However,

stem friction coefficients

assumed

in engineering

calculations credited ideal lubricant quality in some cases.

The inspectors

found these

assumptions

to be unrealistic

and

non-conservative

without justification from PM observations.

The inspectors

pointed out that stem wear and lubricant

degradation

were

common deficiencies

as identified in

Attachment

A of GL 89-10.

Furthermore,

such

a deficiency would

directly reduce

the actual thrust delivered to the valve,

potentially causing

the actuator to torque out early before the

valve could complete its required safety function.

The inspectors

found this lack of coordination of PN activities

in verifying engineering

assumptions

to be

a weakness

in the

licensee's

program.

The inspectors

observed that the licensee

did not have

a

specific refurbishment

schedule for NOVs.

Preventative

maintenance

and diagnostic testing,

alone,

have

been

found at

some facilities to be insufficient for detecting all aspects

of

18

MOV degredation

(e.g.

stem nut wear).

The inspectors

note

that, recently, at another facility which did not have

an

MOV

refurbishment

program,

an

MOV failed because

of excessive

wear

of an actuator

component.

The solution to the problem was

refurbishment of the

MOV, but other similar NOVs at the

facility had to undergo operability evaluations

and, in some

cases,

refurbishment

before the facility was restarted.

Industr

Ex erience

and Vendor Information

The inspectors

observed that the licensee's

technical

data

group

controlled

NRC, EPRI,

and

INPO information.

This portion of the

program appeared

adequate.

The inspectors

also reviewed the licensee's

receipt, review,

and

control of vendor information.

Vendor information was controlled by

the licensee's

Site Nuclear

and Construction

Procurement

Engineering

Department.

The inspectors

selected

the Limitorque Maintenance

Update

as

a means

of sampling the licensee's

handling of vendor information; because

they contained

important information about actuator

assignment

adjustments,

operating experience,

and maintenance

which could

potentially affect valve operability.

The inspectors

noted that the review of the Limitorque Maintenance

Updates

had

been initiated in September of 1990, but had not been

completed until June 28,

1991.

The inspectors

noted that the

licensee's

Naintenance

Standards

Review group

had reviewed the

Limitorque updates

and incorporated pertinent information into

affected draft maintenance

procedures.

However, the inspectors

also noted

a number of significant omissions in the licensee's

review process.

The review package

document

had specifically waived

electrical

and engineering

reviews,

as well as review by nuclear

training.

The inspectors

were especially

concerned that information

notices

had

been allowed to bypass

the review of the licensee's

motor operated

valve group.

Furthermore,

these notices

dated

as far

back as August of 1988.

The inspectors

emphasized

the importance of timely review and

implementation of vendor documents

(where applicable)

in light of

the safety significant information they often contain.

The

inspectors

considered

the licensee's

lack of control of vendor

information to be

a significant weakness

in their NOV program.

The licensee

acknowledged

the need to evaluate

vendor

information

and provided their detailed plans for responding to Generic Letter 90-03 on vendor interface.

The inspectors

plan on reviewing this

response

and the licensee's

evaluation

and implementation of

pertinent information contained in these

documents

during a future

inspection.

(Followup Item 50-528/91-25-10)

0

19

4.8.6

Inservice Testin

5.

Palo Verde valve stroke time acceptance

criteria did not initially

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

observed

a case

where actual

MOV

stroke time was within 1/2 second of the acceptance

criteria and

questioned if the licensee

had considered

whether the valve would be able

to satisfy stroke time under

load and degraded

voltage conditions.

The

licensee

had not evaluated this case.

However, the licensee's

revised

GL 89-10 program plan, dated July 1991,

committed to include this area of

concern.

The inspectors

emphasized

that if the design basis

DC MOV safety

function was time critical and credited 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 criteria.

The licensee

kept records of MOV stroke times obtained during

surveillance testing.

While the stroke times were recorded,

the

licensee identified that they were still developing

computer

software to fully develop their trending capabilities in this area.

The inspectors

noted that the static zero pressure

stroke times for

some

MOVs were already close to

FSAR acceptable

stroke times.

This

issue will be referred to

NRR for further evaluation

and will be

a

followup item for future inspections.

(Followup Item

50-528/91-25-11)

SUMMARY OF OVERALL PROGRAM ADMINISTRATION

The inspectors

found that overall administration of the licensee's

program appeared

to be established

with interim controls which required

some customizing of plant procedures

to expedite

the program.

The

" inspector cautioned

the licensee

to insure that required controls were

not bypassed

in their efforts to expedite portions of their program.

The inspectors

found that

some of the licensee's

plant departments

did

not fully recognize

the significance of the design basis testing

program

nor the

GL 89-10 program.

This was evidenced

by the reluctance

to

recognize that the purpose of the design basis testing

was to provide

assurance

of MOV operability under design basis conditions and, for

example, in the case of the torque switch chatter,

the licensee

stated

that the failure of the

MOY to operate

under test conditions did not

constitute

a failure to operate

under design basis conditions.

Regarding

the significance of the

GL 89-10 program, there appeared

to be

some misconception that the purpose of the program

was only to satisfy

a

commitment to

NRC recommendations

and

no regulatory requirements

were

involved.

The inspectors

emphasized

that the basis of the

GL 89-10

program was to provide assurance

that specific design requirements

were

fulfilled. Specifically, these

design requirements

are given in General

Design Criteria 1, 4,

18 and

21 of Appendix

A to 10 CFR Part 50 and

Criterion NI of Appendix

B to 10 CFR Part 50.

20

In general,

the inspectors

observed

that the licensee

had

made strong

commitments to develop

an

MOV program to meet the intent of GL 89-10.

However, in light of the findings detailed in this report, the licensee

is encouraged

to maintain adequate

resources

to ensure timely and

thorough implementation of all of the

GL 89-10 program components.

6

EXIT MEETING

The inspectors

met with the licensee

management

representatives

denoted

in Section

1 on July 26,

1991.

The scope of the inspection

and the

findings were discussed.

The inspectors identified that additional

information would be reviewed in order to complete the inspection.

Review of the additional information necessary

to complete the inspection

was concluded

on August 13, 1991.

7.

LICENSEE

DOCUMENTS REVIEWED

Res

onse to

GL 89'-10:

12/28/90

Pro

ram Descri tion:

Implementation Plan,

R.O. 6/22/90, R.l., 7/5/91

~Sco e:

EER 90-XE-037

Desi

n Basis

Review:

Motor Operated

Valve Design Basis

Review and

Torque/Thrust Calculation,

81DP-4DC 10, R.O.

Sizin

and Switch Settin

Calculations:

MOV Thrust Torque

and Actuator Sizing Calculation,

13-JC-ZZ-201

R.O. 7/27/90,

CCN.1 1/16/91,

CCN.29 7/12/91

TOL Sizing,

13-EC-PH-250,

1/24/89

Engineering

Guide for AC Motor-Sizing (draft)

Desi

n Basis Testin

SI System

MOVATS testing,

73 TI 97243 R.O.

AFW System

MOVATS testing,

73 TI-97744 R.O.

Strain gaging,

W.O. 476622,

EER91-XE-016

Periodic Verification:

Retest,

NATM 30AC-9WP04, R.l 9/1/88

Valve Motor Operator Monitoring and Test Program,

73 PR-9ZZ04, R.2, 7/28/89

Failures Corrective Action and Trendin

EER-MO-033

DCP-3CM-SI-150,

10/84

N001.1.01-828-1

Seismic gualification Report

NATM 94AC-OLC02 Review of Conditions

Adverse to guality for 10 CFR 21

MNCR 91-SI-1057

21

Control of Switch Settin s:

CAR 91-0021

13'-ZZI-004

NOV Setpoint Controlled Data

Base

EER-91-NO-046 Unit 3 Interim CNODB

Dia nostics:

NOVATS Engineering

Report 5.0

R.O 1/91,

Equipment Accuracy

Summary

Maintenance:

32MT-9ZZ43.44,45,46 Limitorque Actuators

32NT-9ZZ99 R.O. Rotork Actuators (draft)

32MT-9ZZ48 Maintenance of Limitorque NOVs

32NT-9ZZ50 Niotor Generator Trouble Shooting

30AC-9WP04 Retest

~Trendin:

81DP-ORA08 Failure Data Trending

73DP-OEE02 Utilitzation and Processing

Failure Data

Trending Reports