ML17354A804

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Confirms That Representatives of NRC Will Be Visiting Turkey Point Facility During Wk of 980323,to Gather Info on Air Operated Valves.Encl Document Describes Program Plan for Study of air-operated Valves
ML17354A804
Person / Time
Site: Turkey Point, Quad Cities  NextEra Energy icon.png
Issue date: 02/11/1998
From: Croteau R
NRC (Affiliation Not Assigned)
To: Plunkett T
FLORIDA POWER & LIGHT CO.
References
NUDOCS 9802270119
Download: ML17354A804 (37)


Text

Mr. Thomas F. Plunkett President - Nuclear Division Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 ebruary 11, 1998

SUBJECT:

SITE VISIT TO GATHER INFORMATION ON AIR-OPERATED VALVES, TURKEY POINT UNITS 3 AND 4

Dear Mr. Plunkett:

This letter is to confirm that representatives of the Nuclear Regulatory Commission (NRC) will be visiting your Turkey Point facility during the week of March 23, 1998, to gather information on air operated valves.

The NRC is gathering information to determine if the NRC needs to focus additional attention on air-operated valves.

The enclosed document describes the program plan for the study of air-operated valves.

The dates of the visit were determined after consultation with Olga Hanek of your staff.

If you have any questions regarding this matter, please contact me at (301) 415-1475.

Sincerely,

/s/

Richard P. Croteau, Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

As stated L7 4'+tlat.d "L--~ -- "'

cc w/enclosure:

See next page Docket File PUBLIC Turkey Pt. Rdg.

M. Tschuitz J. Zwolinski Document Name: G:TURKEY(TP-AIR.VST To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure Copy with attachment/enclosure "N" = No copy OFFICE PDII-3/PM NAME RCroteau DATE 02/ &/98 PD II-3/LA BClaytorl.

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0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 February 11, 1998 Mr. Thomas F. Plunkett President - Nuclear Division Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

SITE VISIT TO GATHER INFORMATIONON AIR-OPERATED VALVES, TURKEY POINT UNITS 3 AND 4

Dear Mr. Plunkett:

This letter is to confirm that representatives of the Nuclear Regulatory Commission (NRC) will be visiting your Turkey Point facility during the week of March 23, 1998, to gather information on air operated valves.

The NRC is gathering information to determine if the NRC needs-to focus additional attention on air-operated valves.

The enclosed document describes the program plan for the study of air-operated valves.

The dates of the visit were determined after consultation with Olga Hanek of your staff.

If you have any questions regarding this matter, please contact me at (301) 415-1475.

Sincerely, Richard P. Croteau, Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

As stated cc w/enclosure:

See next page

Mr. T. F. Plunkett Florida Power and Light Company TURKEY POINT PLANT CC:

M. S. Ross, Attorney Florida Power 8 Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 John T. Butler, Esquire Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Mr. Robert J. Hovey, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Armando Vidal County Manager Metropolitan Dade County 111 NW 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Generating Station U.S.'Nuclear Regulatory Commission P.O. Box 1448 Homestead, Florida 33090 Mr. Bill Passetti Office of. Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32399-0700 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Regional Administrator, Region II U.S.

Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Mr. H.N. Paduano, Manager Licensing L Special Programs Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 Mr. Gary E. Hollinger Licensing Manager Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035 Mr. Kerry Landis U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415

JCN E8238, Task Order No. 15, Study of AOVs PROGRAM PLAN FOR THE STUDY OF AIR-OPERATED VALVECONCERNS IN NUCLEAR POWER PLANTS INEELI LMITCO A.

B.

The purpose of the study outlined in this program plan is to determine ifthe NRC needs to focus additional attention on the design, qualification, testing (initial and in-service), and/or maintenance of safety-related and important non-safety-related air-operated valves (AOVs), as described below, in order to reduce plant vulnerabilities associated with individual, common cause, or common mode failures.

Ifadditional NRC attention regarding AOVs is found necessary, recommendations will be provided.

A.

B.

C.

D.

E.

F.

G.

H.

I.

J.

K.

PROJECT TITLE'OB CODE:

NRC B&R NUMBER:

CONTRACTOR:

NRC PROJECT MANAGER:

NRC TECHNICALMONITOR:

INEEL PROJECT MANAGER:

INEEL PRINCIPAL INVESTIGATOR:

INEEL INVESTIGATOR:

INEEL INVESTIGATOR'NEEL INVESTIGATOR:

Study of Air-Operated Valves E8238, Task Order No. 15 782-15-1140-25 Idaho National Engineering and Environmental Laboratory (INEEL)

E. Trager, (301)415-6350 H. Omstein, (301)415-7574 J.

Bryce, (208)526-8231 O. Rothberg, (301) 816-7773 M. Holbrook, (208) 526-4362 S. T. Khericha, (208)526-9254 J. Watkins, (208)526-0567 III.

Qjgh~gf5f A.

B.

Operating experience (recent AOVfailures and recently discovered AOVdesign deficienci~s) indicates that the Nuclear Regulatory Commission (NRC) may need to focus additional attention on the design, operation, testing (qualification and in-service), and maintenance of AOVs in order to reduce plant vulnerabilities associated with individual or common-mode AOVfailure. Although degradation, malfunction, or failure of a particular AOVmay not be safety significant, there is concern regarding common cause or common mode AOVfailures that could affect multiple safety systems as well as multiple trains of redundant safety systems.

AOVs are used in all U. S. nuclear power plants (NPPs). The number of AOVs per plant varies widely and the number of safety-related AOVs per plant varies from several to many hundreds.

Boiling water reactors (BWRs) usually have more AOVs than pressurized water reactors (PWRs) because AOVs are used extensively in BWR scram systems.

Excluding the BWR scram system, older RovRrN8 Ocgbe,@2,";4987.:

Enclosure

JCN E8238, Task Order No. 15, Study ofAOVs INEEL/ LMITCO plants generally have more safety-related AOVs than do newer plants.

Many plants have large numbers ofAOVs that are not necessarily designated as safety-related but whose failure might affect safety are also inciuded.

AOVs are actually systems composed of several subsystems which include the valve body, actuator, and control system.

In NUREG/CR-6016, the NRC staff produced an analysis of more than 1500 safety-related AOVfailures [Nuciear Plant Reliability Data System (NPRDS) data covering the period 1988 through 1990]. That study showed that:

1.

42 percent of the failures were attributed to the control subsystem (includes sensors, controllers, solenoid-operated valves (SOVs),

positioners, pressure regulators, filters, and supply air);

2.

36 percent of the failures were attributed to the actuator subsystem (includes diaphragms, springs, bonnets, yokes, pistons, cylinders, stems);

3.

19 percent of the failures were attributed to the main valve (includes the pressure-retaining component which directs or controls the fluid of interest);

4.

subsystem components that were the dominant contributors to AOV failures included SOVs, diaphragms, seals, trim, and air lines.

D.

E.

AEOD issued two case studies, NUREG-1275, Volume 2 on air systems problems and NUREG-1275, Volume 6 on SOV problems.

Although those studies were not focused on AOVs, they contained relevant information on two of the dominant contributors to AOVfailures. These NRC Office for Analysis and Evaluation of Operational Data (AEOD) studies on air systems and SOVs provide examples illustrating plant vulnerability to common mode and common cause failures (CCFs).

The NRC issued over six dozen generic communications addressing AOVs and their associated subsystems including SOVs and air systems.

The NRC issued generic letters to alert licensees and describe corrective actions to minimize the risk from instrument air systems'(Generic Letter 88-14) and SOVs (Generic Letter 91-15).

F.

The industry took a wide rar ge of actions to address these issues since the generic letters were sent.

Some piants instituted aggressive programs to upgrade their air systems and implement extensive SOV design verification, maintenance, and testing improvements.

Many utilities implemented AOVdiagnostics programs that utilize recently available AOVdiagnostic equipment.

In contrast, some utilities have taken a minimal approach to AOVand air system improvements.

It should be noted that there are no NRC requests outstanding (such as those in Generic Letter 89-10 and its supplements regarding motor-operated valves) for diagnostic testing of safety-related AOVs.

JCN E8238, Task Order No. 15, Study of AOVs lV.

Qhgzfhm 1NEEL I LMITCO A.

Evaluate recent (last 12 years) AOV operating experience with emphasis on the most recent and most significant events in order to help the NRC draw conclusions about the effectiveness of NRC regulations and industry actions regarding AOVdesign, qualification, operation, maintenance, and testing.

1.

Safety-related AOVs and important non-safety-related AOVs (see the discussion of equipment to be considered in the study, below) are to be included.

B.

Evaluate the safety significance of the AOVoperating experience, C.

Summarize and assess the relevant regulatory requirements that apply to AOVs.

D.

Summarize and assess the relevant industry requirements that apply to AOVs.

E.

Summarize and assess the relevant design basis requirements that apply to

'OVs.

F.

Assess the adequacy and effectiveness of AOVtesting (initial and in-service) to demonstrate AOVcapabilities to perform under postulated accident conditions.

Assess the adequacy and effectiveness of plant preventative maintenance and corrective maintenance practices, and compare such practices with AOV manufacturer's recommendations.

H.

The focus of the study willbe with the root causes that prevent the AOYfrom performing its intended function within its assigned mission time. Problems associated with the air or inert gas supply and other operating parts or mechanisms, such as controllers, positioners, boosters, regulators, springs, gaskets, diaphragms, solenoids, or the valve, willbe of interest ifsuch component or equipment problems, related to the air (pneumatic) operator's function, cause degradation or failure of the AOVto pe.form its function within its designated time restraints.

1.

For example, a manual valve in an air supply line might not be of interest in this study unless some cause of failure or potential failure of the valve had an effect on the air system and thus had potential or actual effects on AOVs that use the supply line as a source of operating fluid. However, a solenoid operator that controls an air pilot valve that is a part of a valve operator would usually be of interest.

V.

A.

Air-operated valves (AOVs):

1.

AOVs are defined as valves which use air or inert gas as the motive power

JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO

'ource to change the position of valve, valve operator, or a component of the valve.

a.

Other parts or mechanisms such as springs, diaphragms, transducers, plungers, or solenoids may be part of the operator as well.

2.

Pneumatic controllers, positioners, boosters, and regulators willalso be considered to be within the definition of "air operators" (or, at least, part of the operating system) for AOVs for the purposes of this study.

B.

AOVoperating and support systems and components:

1.

Airor inert gas supply system and components, a.

The air or inert gas operating fluid might be supplied from the plant's pneumatic systems such as instrument air/service air system(s), accumulators, or receivers, or from the process fluid.

C.

2.

Electrical supply system and components that serve the AOV directly.

The following safety-related and non-safety-related AOVs and AOVsupport systems are included in this study:

Safety-related AOVs and AOVsupport systems that are relied upon to:

a.

remain functional during and following design basis events, b.

ensure the integrity of the reactor coolant pressure boundary, c.

ensure the capability to shut down the reactor and maintain it in a safe-shutdown condition, and d.

ensure the capability to prevent or mitigate the consequences of accidents the could result in potential offsite exposure comparable to the 10 CFR 100 guidelines.

2.

Non-safety-related AOVs and AOVsupport systems:

a.

that are relied upon to mitigate accidents or transie,h, b.

that are used in plant emergency operating procedures, c.

whose failure could prevent safety-related structures, systems, and components (SSCs) from fulfillingtheir safety-related functions, or d.

whose failure could cause a reactor scram (trip) or actuation of a safety-related system.

3.

the safety-related and non-safety-related AOVs described above should perform their intended function under design-basis conditions, as well as normal operating conditions.

D.

Information may be collected and analyzed concerning other non-safety-related AOVs ifit appears that information about those components may be pertinent to the study of AOVs and AOVsupport systems included in the above categories.

4

JCN E8238, Task Order No. 15, Study ofAOVs INEEL/ LMITCO Vl.

A.

Task 1 - Develop Program Plan.

B.

Task 2 - Collect data and review literature.

C.

Task 3-Perform an analysis of events identified from the collected data and literature review.

D.

Task 4-Visit 7 sites and collect data in parallel with, and to supplement Task 3.

E.

Task 5-Perform risk assessments to characterize and rank significance of failures.

F.

Task 6 - Prepare draft and final reports.

G.

Submit progress reports and respond to TM comments throughout the progress of this study, as described in the INEEL Cost Estimate, Schedule, and Spending Plan dated July 17, 1997 for Task Order 15 of NRC Job Code E8232.

VII.

A.

C.

D.

This program plan provides a detailed outline for the study of AOVperformance in nuclear power plants.

This program plan is based on the Statement of Vlork(Letter from C. Rossi, NRC to J. Wilcynski, DOE/ID dated July 29, 1997) for Task Order 15 of NRC Job Code E8238, "Investigation of Air-Operated Valves.

INEEL resources willbe allocated to Task Order 15 as described in the INEEL Cost Estimate, Schedule, and Spending Plan dated July 17, 1997. Level-of-effort information that follows was reproduced from that plan.

The eshinated total INEEL level-of-effort on this project is 66 staff-weeks in FY-97 and FY-98. The level-of-effort for each Task is estimated to be as follows:

s e

k

JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO 6.1 52 Total 13 14 66 E.

The schedule presented in the Statement of Work was based on a start date of 7/28/97.

However, the actual start date was 8/1/97. Accordingly, the schedule should be as follows:

TASK./Node No.

1 /15-1 none / 15-2 2/15-3 none / 15-4 3/15-5 4/<$4 none /15-7 5/ 15-8 6.1 / 15-9 6.2 / 15-10 TASKTITLE Develop Program Plan PROGRAM REVIEW POINT 1 Perform Literature Review and Collect Data PROGRAM REVIEW POINT 2 Perform Analysis of Events Perfom Site Visits PROGRAM REVIEW POINT 3 Perform Risk Assessments Prepare Draft Report Prepare Final Report EST. COMPL. DATE 9/4/97 10/23/97 12/4/97 12/5/97 3/26/98 2/19/98 2/6/98 2/19/98 5/28/98 7/1/98 F.

This program plan willbe submitted to the NRC technical monitor for approval concurrent with commencement of Task 2.

Revision 8

P

JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO Vill.

Failures, degraded conditions, or precursor events involving AOVs that degraded plant safety margins, or that affected or could have affected safe plant operations are to be identified.

Review recent events in nuclear plants to identify events comparable or similar to those described in (but not limited to) the following publications:

a.

NUREG-1275, Vol. 2, "Operating Experience Feedback Report - Air Systems Problems b.

NUREG-1275, Vol. 6, "Operating Experience Feedback Report-Solenoid-Operated Valve Problems c.

NUREG/CR016 (ORNL<748), "Aging and Service Wear of Air-Operated Valves Used in Safety-Related Systems in Nuclear Power Plants" d.

Nuclear Safety Analysis Center NASC/128, "Pneumatic Systems and Nuclear Plant Safety," EPRI, Pickard, Lowe and Garrick, Inc.,

10/88 2.

Review recent events in (but not limited to) the following systems:

a.

Shutdown cooling system, b.

Auxiliaryfeedwater system, c.

BWR scram systems, d.

Powerwperated relief valves, e.

Low temperature overpressure protection (LTOP) system, f.

Service water system, g.

Component cooling water system, h.

Main steam isolation valves, i.

Feedwater isolation valves, j.

Emergency diesel generator air systems, k.

Safety injection systems, I.

Reactor coolant pump seal injection systems, m.

Reactor cavity and spent fuel pool pneumatic seal systems, n.

Other systems listed i.> Table 1 (page 6) of NUREG-1275, Vol. 2.

Identify "significant" failures or events involving:

a.

Safety-related AOVs and support systems, b.

Other non-safety related AOVs and support systems (as defined above),

c.

Precursors or failures, d.

Common cause or common mode failures or precursors.

Databases and sources to be used include (but are not limited to):

1.

NRC Licensee Event Reports (LERs),

2.

NRC Diagnostic Evaluation Team (DET) Reports, 3.

NRC Generic Letters, Bulletins, Circulars, Notices, NUREG Reports, 4.

NRC correspondence (including close-out correspondence for the above),

JCN E8238, Task Order No. 15, Study ofAOVs INEEL/ LMITCO 5.

6.

7.

10.

11.

12.

13.

14.

15.

16.

17.

18.

19.

NRC Generic Issues database and resolutions, NRC Inspection Reports, Power Reactor Licensee reports submitted in accordance with various provisions of 10 CFR, such as 10 CFR 50.59 and 10 CFR 50.72, NRC regulations, NRC Sequence Code Search System (SCSS), Accident Sequence Precursor (ASP), and Common Cause Failure (CCF) databases, INPO NPRDS data, publications, and correspondence, EPRI Nuclear Maintenance Assistance Center (NMAC)publications, Individual nuclear power plant data, publications, and correspondence (see Task 4),

Equipment vendor catalogs, publications, correspondence, and data, American Society of Mechanical Engineers (ASME) and other, code/standards organization codes, standards, publications, or correspondence including:

a.

OM codes and standards, b.

ASME B&PVcode, c.

ANSI and other pertinent standards, Department of Energy (DOE) Occurrence Reporting and Processing System (ORPS) database, DOE regulations, standards, publications, and correspondence, Government Industry Data Exchange Program (GIDEP) database, Available Department of Defense (DOD) data, Foreign reactor experience data.

The components to be considered include (but are not limited to):

1.

2.

3.

4.

5.

6.

7.

8.

9 10.

11.

12.

13.

14.

15.

16.

Solenoid assisted actuators, Spring and diaphragm assisted actuators, Piston actuators, Rotary actuators,

Sensors, Controllers, Positioners, Supports and attachments, Attached piping and components (receivers, etc.),

Attached wiring, Check valves, Globe valves, Gate valves, Ball valves, Butterfly valves, Pilot valves or pilot operators as piece-parts of other valves.

JCN E8238, Task Order No. 15, Study of AOVs INEELl LMITCO D.

Materials and component parts to be considered include (but are not limited to):

1.

2.

3.

4, 5.

6.

7.

8.

9.

10.

11.

12.

Diaphragms,

Seals, Packing s, Elastomers, Dissimilar metallic materials, Process fluids and contaminants, Operating fluids and contaminants, Lubricants,
Coils, Switches,
Seats, Springs.

E.

Environmental conditions to be considered include (but are not limited to):

2.

3.

4, 5.

6.

7.

8.

9 10.

12.

13.

14.

Moisture or other contamination in the air supply system, Aging effects including consideration of:

a.

Organic materials, b.

Wear, Temperature and heat sources,
Steam, Radiation,
Wear, External exposure to corrosive or caustic fluids, Airborne or surface particulate contamination, Electric power supply interfaces, Process fluid characteristics (pressure, temperature, flowrate, viscosity, contamination, potential forwater hammer effects, etc.),

Airor inert gas operating fluid characteristics (pressure, temperature, flow rate, viscosity, contamination, etc.),

Vibration and dynamic interaction with adjacent equipment, Seismic load and configuration considerations,

<ynergistic effects.

Review design and application procedures forAOVs.

2.

Selection of AOVs for a particular service, a,

Materials used, b.

Valve type used.

Sizing methods, a.

Study margins under operating and design basis conditions.

b.

Study how designs are verified.

(1)

Test programs and results, (2)

Calculations and analyses.

JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO G.

Study installation procedures forAOVs.

1.

In accordance with manufacturer's instructions, 2.

In accordance with codes and standards, 3.

Differences and potential conflicts.

H.

Study operation and maintenance ofAOVs.

2.

4, Maintenance practices, such as:

a.

Predictive and preventive, b.

PRA based.

Maintenance problems, such as:

a.

Frequency, b.

Assembly and disassembly difficulties, c.

Replacement part compatibility, d.

Training.

e the similarities for comparable problems, methods of design, maintenance, and testing used for other valve operator types such as:

a.

Motor-operated, b.

Hydraulic, Defective, suspect, or counterfeit parts:

a.

Plant experience, b.

Industry data, c.

Government data.

Study testing procedures and equipment forAOVs.

1.

Qualification, 2.

In-service, 3.

Diagnostic.

J.

Study common mode and common cause failures and potential failures.

1.

Synergistic effects K.

Make comparisons and draw conclusions, ifappropriate, with industry efforts regarding other valve types such as:

Motor-operated valves, 2.

Hydrauli~perated valves.

IX.

A.

Construct a matrix of events and equipment, in accordance with the objectives descnbed above, and including the following categories:

1.

events affecting individual valves or operators, 2.

events affecting multiple valves or operators, 10

JCN E8238, Task Order No. 15, Study of AOYs INEELl LMITCO 5.

6.

7.

8.

9 10.

11.

12.

13.

14.

15.

events affecting individual trains of redundant safety-related systems or systems important to safety, events affecting multiple trains of redundant safety-related systems or systems important to safety, events affecting multiple safety-related systems or systems important to

safety, valve type or types (gate, globe, ball, butterfly, etc.,

operator type (piston, diaphragm, solenoid, etc.),

power sources (instrument air, accumulators, auxiliary electrical, auxiliary mechanical, etc.),

controller and control system description and characterization, pertinent dates or times, pertinent environmental and ambient conditions, pertinent vendor or plant identifications, failure mechanisms identification:

a.

root cause, b.

common cause scenarios, c.

common mode scenarios, pertinent design, qualification, maintenance, operation, or test information, safety significance.

B.

Integrate and analyze data obtained from site visits with information obtained independently.

1.

Identify and analyze recurring safety-related AOVfailures or events not revealed elsewhere.

2.

Identify and analyze recurring pertinent AOVfailures or events not revealed elsewhere.

Identify AOYpopulations in plant systems and categorize (such as):

1.

Plant, 2.
System, 3.

AOVdescription:

a.

Manufacturer, b.

Type, c.
Size, d.

Pertinent service parameters (temperati".e, environment, etc.).

D.

Qualitatively prioritize events involving AOVs in terms of safety significance.

Emphasize identification and analysis of actual and potential common mode and common cause failures.

E.

Compare the data analyses and results of this task with the results described in NUREG-6016, which used the NPRDS as the data source.

11

JCN E8238, Task Order No. 15, Study of AOVs X.

INEEL/ LMITCO A.

The following 7 (choose from list) sites willbe visited in accordance with the following approximate schedule:

PLANT NAMEIiPRQJECT;:MRNAGER Millstone Diablo Canyon Palo Verde;'$,::;Kristine'NJj'Thomas LaSalle I::;Qonrl,.";84iij Palisades";f:Robe'rt',Staff Grand Gulf North Anna Fermi 2gIpndreVt<Kggfer.

Peach Bottom Crystal River Davis Besse Turkey Point SCHEDULED VlSIT TBD

$,0f28".2 Rgb'hjKj.i@4 I44/g$8-"1,0PN,.

TBD TBD TBD TBD TBD TBD B.

The following plant-specific information is to be obtained prior to site visits, if practical.

Furnish a description to the plant point-of-contact of the information in-hand and the information and data to be collected on-site.

Failure data, a.

Events (LERs, Bulletins, Notices, etc. specific to this plant),

b.

Recurring failures specific to.thls plant (Common cause or common mode),

c.

Number and types of failures, events, or precursors, (1)

Safety-related, (2)

Other pertinent, 2.

PRA application and data use, a.'ow are plant PRA and PRA tools used in plant, relationship to Maintenance Rule?

b.

Are predictive and preventive maintenance tasks based on PRA calculations'P Maintenance Data and Diagnostic systems in use, 12

N I

t

JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO a.

b.

C.

d.

Description,

Methods,

'requency, Results and description of the data collected.

4.

d.

e.

f.

g.

Design data:

a.

Number of AOVs (1)

Safety-related (2)

Important non-safety related AOVs (as defined previously) b.

Types of AOVs (1)

Diaphragm, piston, etc.

(2)

Controllers, regulators, etc.

c.

Air(and/or inert gas) supply system description (1)

Number, type, size of pumps (2)

Supply system description (3)

Filters, regulators, etc.

(4)

Backup and protocol Breakdown of air system service and AOVuse by system Sizes of AOVs and operators in use Operating and process fluids Selection and sizing methods (1)

Design verification including consideration of postulated transient and accident conditions.

C.

Personnel to be contacted prior to each site visit should include:

2.

3.

4.

Headquarters, regional and on-site NRC personnel, a.

NRC plant project manager, b.

Cognizant NRC Region staff, c.

NRC Resident Inspector, Plant maintenance staff representatives, Plant engineering staff representatives, Plant and utilitymanagement representatives.

D.

Interv 2.

3.

4, 5.

6.

7.

8.

iew information to be obtained on-site should include:

'lame(s) of interviewer(s) and titles, Date(s) of visit, Plant name and docket number, Person(s) interviewed, titles, phone numbers, E-mail, addresses, etc.

Describe organization and position of the person interviewed.

Provide information on overall number of AOYs, air system, AOVs broken down by system, ifsuch infogmation was not obtained prior to the visit.

Describe events involving AOVs and air systems including:

a.

Recent, b.

Recurring, c.

Significant (regardless of time frame).

Describe AOVfailures.

a.

Actual and potential, b.

Common cause or common mode.

13

JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO 10 12.

13.

14.

15.

Describe actions taken after AOVevents or failures.

a.

Immediate, b.

Follow-up.

Describe root cause analyses.

a.

Lessons learned regarding AOVs, b.

Unique procedures forAOVs, ifany.

Describe maintenance and IST procedures for AOVs.

a.

Safety-related, important non-safety-related (as defined previously), other non-safety-related, b.

What procedures, ifany, are vendor approved and/or supervised' c.

ASME and other code requirements, d.

Describe maintenance, test, and analysis resources available.

(1)

On site, corporate, consulting, industry, etc.

Describe diagnostic systems used for AOVs.

a.

Description, b.

Specifications, c.

Data collected, d.

Availabilityto plant staff, e.

Frequency of use.

f.

Vendor approved and/or supervised Describe design (and analysis) procedures for AOVs.

a.

Design bases, b.

Vendor approved and/or supervised.

Describe training for installation, maintenance, and testing of AOVs.

Note: Emphasize to all site personnel interviewed that this is a fact-finding visit for information applicable to all plants and the information to be collected willnot be used to reflect negatively on the specific plant performance.

We do not intend to subject any single plant to criticism.

E.

Examine design, maintenance, failure, or event records ifpractical.

1.

Describe maintenance, failure or event database and processes for the plant.

a.

Assessment of availability, accuracy, completeness, b.

Obtain copies of examples ifpossible.

Assess overall capability of plant personnel regarding AOV:

a.

design, b.

equipment qualification, c,

maintenance, d.

testing, e.

failure and events analyses.

F.

View representative AOVs, ifpractical.

1.

In situ, 2.

In shop, storage, or test facilities.

G.

Trip reports for each site visit should be prepared within two weeks of the end of each visit, ifpractical.

14

JCN E8238, Task Order No. 15, Study ofAOVs INEEL/ LMITCO 2.

3.

Trip reports should be submitted to the NRC TM.

Include information obtained (as described above).

Furnish copies to NRC PM, Region staff, Resident Inspector, and plant host as a courtesy and to seek feedback.

XI.

H.

An interview form is attached to this program plan.

A.

The Accident Sequence Precursor (ASP) program involves the systematic review and evaluation of operational events or conditions that have occurred at U. S.

commercial light-water reactors, reported under the Licensee Event Report (LER) program.

Precursors and potential severe core damage accident sequences are identified and categorized in the ASP program.

The LERs generated from 1969 through 1995 have been evaluated under the ASP program and those LERs that met a screening criteria of the ASP evaluation process were further analyzed to compute conditional core damage probability (CCDP). The events which were not analyzed were considered (in accordance with the screening criteria) to be not risk significant with respect to core damage.

ASP models willbe used in two ways to assess AOV risk significance:

1.

ASP evaluations developed over the period considered in this study willbe reviewed to identify any risk significant ASP AOVand AOVsupport system failures that occurred in operating plants, as well as the conditional core damage probability (CCDP) associated with each of these AOV(or support system) failures.

a.

Although the simplified nature of the ASP models and reporting criteria for the LER means that many plant AOYs are not included in these models (and, thus, many AOVfailures willnot have been evaluated in this way), some AOV failures may have been included in these ASP analyses and willprovide a useful starting point to understand the risk significance of AOVfailures.

2.

ASP models willbe used to evaluate the CCDP of selected hyg}ibgfiggf AOVfailures to the extent that the current leve! of model development will support such evaluation.

B.

In addition to the use ofASP models, the risk significance ofAOVand AOV support system failures willbe evaluated by performing limited scope evaluations and'sensitivity studies using completed plant SAPHIRE (Systems Analysis Programs for Hands-on Integrated Reliability Evaluations) data bases developed at the INEEL. Selected plant models willbe used to evaluate the relative risk importance of AOVs in selected plant systems and the sensitivity of plant core damage'frequency to changes in AOVfailure rates.

1.

Both independent AOVfailures and common cause AOVfailures willbe considered.

15 Ocg%g~j$ 997j

JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO 2.

3.

To the extent practical, the current study willmake use of information developed in a previous study, "Gl-158: Performance of Safety Related Power Operated valves Under Operating Conditions, INEL-95/0550.

a.

Power-operated valves, including AOVs but excluding motor-operated valves were included in the Gl-15& study.

b.

AOVsupport systems were not included in the Gl-158 study.

c.

The Gl-158 study described core damage frequency sensitivity in relation to changes in POV failure probability.

The Gl-158 study included representatives of ti o. Westinghouse three and four loop plants as well as a GE BWR plant, for which IPE models were available in the SAPHIRE data base at the time of the study. The CE and B&Wplants were not available in the SAPHIRE data base at the time, and thus were not included in the Gl-158 study.

A representative plant willbe selected for each reactor vendor and the risk significance of AOVand AOVsupport system failures willbe calculated.

Since the Gl-158 study was submitted to the NRC, more IPE data has been loaded in to the SAPHIRE data base.

Plants now loaded in the SAPHIRE data base now include the AP<00, CESSAR System 80+, Beaver Valley 2, Brunswick 1 and 2, Dresden 2 and 3, Fort Calhoun, Grand Gulf 1, Indian Point 2, Fitzpatrick, Farley, LaSalle 2, Oconee 3, Oyster Creek 1, Peach Bottom 2, River Bend 1, San Onofre 2 and 3, Sequoyah 1, Suny 1(NUREGlCR-1150),

Zion 1, Palo Verde, Commanche Peak, and Surry-IPE.'.

For the selected plants, PRA importance measures willbe calculated to leam more about both potential reductions in core damage frequency ("risk reduction importance") ana potential increases in core damage frequency ("risk achievement importance") associated with AOVevents identified in the IPEs.

XII.'.

Task 6.1 - Draft Report Contents:

1.

Abstract 2.

Executive Summary 3.

Introduction

'The IPEs for Palo Verde, Commanche Peak, and Surry cannot be used without the individual owner's approval.

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JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO 5.

8.

10.

a.

Purpose of the study b.

Background

c.

Objectives of the study d.

Scope of the study Description of Equipment a.

See Items 8 and 9 in this Program Plan Applications in Nuclear Power Plants a.

See Items 9, 10, and 11 in this Program Plan Failure Modes Description a.

See Items 9, 10, 11, and 12 in this Program Plan Significant Events a.

Important Events

b. 'mportant Precursors c.

Common Cause or Common Mode Failures d.

See Items 9, 10, 11, and 12 in this Program Plan Failures and Precursor Descriptions a.

Design b.

Equipment Qualification c.

Application d.

Operation e.

Maintenance f.

Inservice Testing g.

Support System Failures h.

Common Mode and Common Cause Failures i.

See Items 9, 10, 11, and 12 in this Program Plan Analysis and Evaluation of Operational Experience a.

Design b.

Equipment Qualification c.

Application d.

Operation e.

Maintenance f.

Inservice Testing g.

Support System Failures h.

Common Mode and Common Cause Failures Safety Anaiysis j.

Risk Assessment(s) k.

See Items 9, 10, 11, and 12 in this Program Plan Conclusions a.

Design b.

Equipment Qualification c.

Application d.

Operation e.

Maintenance f.

Inservice Testing g.

Support Systems and Equipment h.

Risk Assessment(s) i.

See Items 9, 10, 11, and 12 in this Program Plan Recommendations 17

1

JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO 12.

13.

14.

15.

a.

Design b.

Equipment Qualification c.

Application d.

Operation e.

Maintenance f.

Inservice Testing g.

Support Systems and Equipment h.

See Items 9, 10, 11, and 12 in this Program Plan References Figures Tables Appendices a.

Listing of Pertinent LERs b.

Listing of Pertinent Generic Communications c.

Listing of Pertinent Failure Data and incidents From Other NRC Sources Failure Data From Sources Other Than the NRC Trip Reports of Site Visits Abbreviations B.

Task 6.2 - Final Report includes:

1.

2.

3.

INEEL peer review of the draft report, NRC review of the draft report.

a.

NRR comments, b.

RESEARCH comments.

Report should be revised to include response to the comments and resubmitted to the NRC TM.

XIII.

A.

Weekly reports:

1.

Addressed to NRC TM and PM, 2.

Describe weekly progress and problems in standardized format.

Monthly reports:

1.

Addressed to NRC TM and PM 2.

Include description.

XlV.

A,

Purpose:

1.

To determine the extent and direction of remainder of effort.

18

JCN E8238, Task Order No. 15, Study of AOVs B.

Procedure:

INEEL/ LMITCO NRC TM, PM and their management are to review progress of work to that point.

2.

Notify INEEL PM of planned direction.

19

~g

JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO TOPICS."'TO,REVIEW, FOR AIR OPERATED VALVESTUDY SITE VISITS ITEM No.

Date.

INFORMATION RESPONSE OR INFORMATION Use se arate sheets and refer to item numbers, ifnecessa Name of Interviewer.

Plant Name & Docket No.

Person(s) Interviewed, Title(s), Phone Number(s), E-Mail address, short description of organization(s) and duties.

If necessary, and ifperson(s) interviewed can do so, obtain any missing information not provided prior to the site visit, as described in the outline for Task 4 above.

Note what information was provided.

Describe plant events involving AOVs and provide reference information, if possible.

Recent:

Recurring:

Significant:

Describe AOVor air-system actual or detected potential failures at the plant? Provide reference information, ifpossible.

Describe actions taken after events or failures involving AOVs or the air system.

Provide reference information, ifpossible.

20 OctoberP275$ 997,:

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JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO

'JOP,.!CS~"TO'RENEW FOR AIR OPERATED YALVESTUDY SITE VISITS ITEM No.

INFORMATION Were there any actual or potential common mode or common cause failures in the air system or AOVs at the plant'P Describe and provide reference information, ifpossible.

RESPONSE OR INFORMATION Use se arate sheets and refer to item numbers, ifnecessa 10 Describe root cause analysis procedures for the plant. Provide reference information, ifpossible.

Describe root-cause analyses performed for air system or AOV failures at the plant. Provide reference information, ifpossible.

12 Describe maintenance procedures for the air system.

Provide reference information, ifpossible.

Describe maintenance procedures for AOYs. Provide reference information, ifpossible.

Safety-related:

Important non-sa sty-related:

Non-safety-related:

14 Describe IST procedures for the air system.

Provide reference information, ifpossible.

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JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO 7OPfCSÃG'REVQIW FOR AIR OPERATED VALVESTUDY SITE VISITS ITEM No.

15 INFORMATION Describe IST procedures forAOVs.

Provide reference information, if possible.

Safety-related:

Important non-safety-related:

Non-safety-related:

RESPONSE OR INFORMATION Use se arate sheets and refer to item numbers, ifnecessa Describe diagnostic systems, ifany, used forAOVs. Provide reference information, ifpossible.

Description of system:

Specifications:

Data collected and frequency of collection:

Vendor assistance provided, ifany:

17 Describe design (and analysis) procedures for AOVs. Describe how design basis is established and maintained forAOVs. Provide reierence informatior ifpossible.

18 Describe analyses and/or testing for verification of operability during postulated transient or accident conditions.

Provide reference information, ifpossible.

Describe training for installation, maintenance, and testing of AOVs.

Provide reference information, if possible.

22 OQoSee:.:22.':5997,:

JCN E8238, Task Order No. 15, Study of AOVs INEELI LMITCO

/OP/C8.70;REVUE)g FOR AIR OPERATED VALVESTUDY SITE VISITS ITEM No.

20 INFORMATION Describe databases used to track maintenance, failures, and events regarding AOVs. Provide reference information ifpossible.

On site:

Company wide:

Industry:

RESPONSE OR INFORMATION Use se arate sheets and refer to item numbers, ifnecessa 21 Describe the impact of the Maintenance Rule, 10 CFR 50.65 on AOVand air system maintenance and testing.

Provide reference information ifpossible.

22 Is PRA data used for predictive maintenance or replacement of AOVs? Ifso, how?

23 Are AOVs serviced on site, serviced off site, or replaced as piece-parts if found to require service?

24 gfeybfj'~ggdesctjbe the most common recumng maintenance problem(s) and failures regarding AOVs and the air system.

Qggt4P gg>$$$$Provide reference Inform*ation ifpossible.

25 Interviewer comments regarding actual valves viewed during the visit, in the plant, undergoing maintenance or replacement, or in the plant stock system, ifapplicable to this interview.

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JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO

~~fC+876.'REMI,. FOR AIR OPERATED VALVESTUDY SITE VISITS ITEM No.

26 INFORMATION Has the plant made changes to valves or systems that Include AOVs, or replaced AOVs with different models of AOVs or different valves that are not AOVs?

Ifso, describe the changes and the circumstances.

RESPONSE OR INFORMATION Use se arate sheets and refer to item numbers ifnecessa What prompted the change?

Was the change made for this plant only?

27 Does the plant followEPRI/NMAC guidelines for maintaining AOVs and the air system(s)?

Ifnot, describe differences and reasons for the differences.

Provide reference information, ifpossible.

28 What is the plant doing or planning to do in response to the recent Industry correspondence on AOVs.

Provide reference information, ifpossible.

29 Do you have any suggestions for improving the performance of AOVs, particularly in the areas of surveillance, testing, or maintenance?

30 Provide a list of 10 CFR 50.59 and 10 CFR 50.72 reports on AOVs and AOV support systems (air or inert gas supply, etc.) that have been issued for this plant.

24

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JCN E8238, Task Order No. 15, Study of AOVs INEEL/ LMITCO

,gPICS~70':RENEW FOR AIROPERATED VALVESTUDY SITE VISITS EM No.

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y,afigy,-rif,ted'AC5fiV, VJfPaf,"maintenance,:or aini@IIarjce"5

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