ML18153B714
| ML18153B714 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/03/1989 |
| From: | Belisle G, Lenahan J, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153B712 | List: |
| References | |
| 50-280-89-10, 50-281-89-10, IEB-85-003, IEB-85-3, NUDOCS 8905170075 | |
| Download: ML18153B714 (13) | |
See also: IR 05000280/1989010
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 11
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
50-280/89-10 and 50-281/89-10
Licensee:
Virginia Electric and Power Company
Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.: DPR-32 and DPR-37
Inspection Conducted:
March fo7 - April 4, 1989
Inspectors:
If ;j{,_L
J. Lena ha Ir .
Date Signed
~ls/gc,
e'Signed
Accompanying Personnel:
E. Brown, Office of Nuclear Reactor Regulation
by:
c.P-~ ~__.I?/
G~ I
_ Approved
l'f:--J-f-"f
Date Signed
Scope:
Results:
Test Programs Section
Engineering Branch
Division of Reactor Safety
SUMMARY
This special, announced inspection was in the areas of motor operated
valve deficiency followup, IE Bulletin followup, and power operated
valve inservice stroke time testing.
Within the areas inspected, one violation was identified which
involved failure to take prompt corrective action in response to
motor operated valve deficiencies, paragraph 2.a.
Weaknesses were
identified in the licensee's motor operated valve recovery program,
paragraph 2.b, in the licensee's motor operated valve overhaul
procedures, paragraph 3, and in the licensee's corrective action for
excessive valve stroke times, paragraph 4.
The licensee committed to provide, in writing, to the NRC details of
the motor operated valve recovery program, and to review MOVATS test
reports issued prior to 1988, paragraph 2.b .
8905170075 890509
ADOCK 05000280
Q
-
...
1.
Persons Contacted
Licensee Employees
REPORT DETAILS
L. Adkins, Mechanical Maintenance Foreman
R. Bilyeu, Licensing Engineer
- R. Blount, Superintendent of Technical Services
- D. Christian, Assistant Station Manager
- P. Doody, Project Engineer, Motor Operated Value (MOV) Repair Project
- E. Greckeck, Assistant Station Manager
S. Hanson, Electrical Maintenance Foreman
- M. Kansler, Station Manager
- H. Miller, Director, Operations and Maintenance Support
K. Moore, Vice-President, Engineering
R. Saunders, Manager of Licensing
Other licensee employees contacted during th is inspection included
engineers, mechanics, technicians, and administrative personnel.
Other Organizations
D. Eshleman, Site Supervisor, Atlantic Nuclear Services
R. Bowen, MOV Supervisor, Atlantic Nuclear Services
NRC Resident Inspectors
- W. Holland, Senior Resident, Operations
J. York, Senior Resident, Construction
L. Nicholson, Resident Inspector
- Participated in telephone conference call on April 4, 1987
2.
MOV Deficiency Followup (92701)
(Open) 280,281/88-45-01; MOV Deficiency Followup.
During the present
Uni ts 1 and 2 outages, the licensee filed approximately 450 station
deviations against MOVs.
Examples of MOV deficiencies encompassed by the
station
deviations
are
provided
in
NRC
Inspection
Report
Nos. 50-280,281/89-03.
During this inspection, the inspectors performed
an in depth review of the testing and maintenance associated with three
valves required to be operational in order to mitigate the consequences of
a loss-of-coolant accident (LOCA).
The inspectors also reviewed the
licensee's program to restore Units 1 and 2 safety-related MOVs.
a.
Review of MOVs 2-CH-MOV-2289A, 2-CH-MOV-2289B and 1-CH-MOV-1286B
Testing and/or Maintenance Histories.
.-.
( 1)
2
Reviewing valve 2-CH-MOV-2289A Motor Operated Valve Actuator
Test System (MOVATS) test reports from 1986 revealed that the
following deficiencies were identified but not subsequently
corrected:
MOVATS test report dated November 25, 1986, identified that
the valve was not shutting off flow as crisply as a similar
valve that had recently undergone disk and seat repair.
The test report recommended checking the valve's disk and
seating ~urfaces during the next outage.
MOVATS test report dated February 10, 1987, identified that
the valve
1 s stem to disk connection was damaged.
This was
detected by observing that the stem rotated approximately
45 degrees while the valve was seating.
The test report
concluding the following:
The stem to disk movement may be do to the over torquing
of the valve into the seat.
Comparing the valve thrust signatures with similar valve
thrust signatures that underwent disk and seating surfaces
repair indicated that valve seat damage was evident.
Due to the high thrust on this valve, and the fact that
the MOVATS test performed November 25, 1986, showed seat
damage, it can only be concluded that more damage has
been done including the stem to disk connection.
The inspectors review of the valve's work orders from 1986
revealed that the valve's disk,and seating surfaces had not been
inspected for damage, nor had the damaged stem to disk
connection been repaired. After the MOVATS testing performed on
February 10, 1987, the valve was again tested on May 25, 1988;
June 12, 1988; and November 4, 1988.
None of the 1988 MOVATS
test reports identified disk to stem movement or seating surface
damage.
On April 1, 1989, the valve was scheduled to be tested
following the actuator overhaul.
The inspectors requested the
licensee to observe if disk to stem movement occurred when
performing this test.
On April 3, 1989, the inspectors wer~
informed by the licensee that valve disk to stem movement was
observed when testing and that corrective action was being
initiated.
The inspectors were also informed that disk to stem
movement was difficult to detect, which may explain why the
movement was not detected during any of the three MOVATS tests
accomplished in 1988.
The 1986 and 1987 valve MOVA TS test reports identified that
valve degradation and actuator over thrusting were occurring,
and that actual stem to disk connection damage had occurred.
The inspectors considered that these deficiencies could result
(2)
3
in va 1 ve failure, but were not promptly corrected by the
licensee after being identified.
Review of the licensee's
program during the 1986/87/88 time period indicated that MOVATS
test reports were not a 1 ways adequately being reviewed by
1 icensee personnel.
MOVATS contractors performed the testing
and submitted test reports, but the deficiencies were not being
reviewed by licensee personnel to ensure that corrective action
was being initiated.
Review of valve 2-CH-MOV-22898 i nservice test stroke time
results, station deviations, and
MOVATS test results
accomplished in 1987 indicated that valve degradation was
occurring but was
not subsequently corrected.
Valve
2-CH-MOV-22898 is categorized as a cold shutdown valve;
consequently, it is only stroke time tested during shutdown
periods.
Sta ti on records indicated that on March 15, 1987,
December 19, 1987, and on December 21, 1987, the valve's stroke
times exceeded its maximum stroke time limit of ten seconds.
The* corrective action for the March 15, 1987, valve failure
involved stroking the valve two additional times.
Since the two
additional stroke time results did not exceed ten seconds, the
valve was considered operable.
During the December 19, 1987,
stroke time test, the valve again failed since the stroke time
was 10.85 seconds.
Based on this failure the valve was MOVATS
tested.
The MOVATS test report revealed that an actuator high
running load condition existed and that the valve stroke time
was 10.4 seconds.
The test report did not indicate that limit
switches were out of adjustment.
On December 21, 1987, the
valve was tested and the stroke time was 10.37 seconds.
On
December 21, 1987, the valve's open limit switch was adjusted in
accordance with Work Order 3800059847.
The work order stated
that the excessive stroke time was due to the open limit switch
being out of adjustment.
The work order did not specify how
much the limit switch was out of adjustment or what the final
open limit switch setting was left at.
Contrary to the
licensee's policy to MOVATS test this valve following limit
switch adjustment, the valve was not MOVATS tested following the
December 21, 1987, limit switch adjustment.
After the open
limit switch was adjusted, the valve was satisfactorily stroke
time tested at 9.71 seconds.
On December 23, 1987, Unit 2 was
started up.
As previously discussed, valve 2-CH-MOV-22898 failed to stroke
within the allowable ten second time period four times; three
failures occurred during stroke time testing, and the fourth
occurred during MOVATS testing when actuator high running load
was also identified.
Since MOVATS testing did not reveal limit
switches out of adjustment it can be assumed that the open limit
switch setting was adjusted to shorten the valve stroke
distance, resulting in a decreased stroke time. This is not
considered acceptable. corrective action.
The valve may have
...
b.
4
been able to accomplish its intended function with a shortened
stroking distance; however, the degraded condition causing the
- increased stroke time was not corrected.
(3)
In 1985 the licensee was aware that both lithium and calcium
based greases had been added to Surry MOV actuators, and that
Amolith Grease No. 2, which was utilized in some MOV actuators
at Surry, was an inadequate lubricant.
In a September 26, 1985,
letter from Limitorque Corporation to Virginia Power, Limitorque
actuator lubricants were discussed, and Limitorque Corporation
recommended that Amolith Grease No. 2 not be used in Limitorque
actuators. Additionally, the 1 etter stated that under no
circumstancess should lubricants of dissimilar bases be mixed.
In a Surry inter-office memorandum from W. E. Patterson to
H. L. Miller dated September 4, 1985, corrective action
involving initiation of an aggressive MOV actuator grease
replacement program was recommended.
During the present 1988/1989 Units 1 and 2 outages, numerous
station deviations were written that describe actuator grease
deficiencies.
Examples of such deficiencies included, bad
grease in actuator housings and wrong grease types in actuator
housings.
On July 7, 1988, Station Devi.ation Sl-88-1668 was.
written against valve 1-CH-MOV-1286B and identified that*
hardened grease was found in the actuator, that metal filings
were found in the grease, that the worm gear would not turn and
had. severa 1 broken teeth.
The inspectors reviewed the work
order history for this valve from 1985.
There was no record of
grease replacement occurring until July 1988.
Valves 2-CH-MOV-2289A, 2-CH-MOV-2289B and 1-CH-1286B, are.all
included in the
IE Bulletin 85-03, Motor Operated Valve Connnon
Mode Failure During Plant Transients Due to Improper Switch
Settings program.
Inclusion into the IE Bulletin 85-03 program
means that operation of these MOVs is essential in mitigating
the consequences of a loss of coolant accident by repositioning
as required to allow injection of high pressure water into the
reactor core.
Reviewing
work orders~ station deviations, and
MOVATS test reports associated with these valves revealed that,
in all cases, known deficiencies existed that were not promptly
corrected.
Failure to promptly correct MOV deficiencies is
identified as violation 280,281/89-10-01.
Review of the Licensee's Actions to Restore MOV's for Units 1 and 2
The responsi bi 1 ities for accomplishing actions required to restore
MOVs were divided between several organizational groups.
Surry
Maintenance Department personne 1 were performing MOV el ectri ca 1
activities and directing Atlantic Nuclear Services (ANS) contractors,
who were performing the MOV mechanical activities. Surry Maintenance
Department personnel were also directing the MOVATS contractors, who
...
5
were performing MOV diagnostic testing activities.
Corporate,
Operations and Maintenance Support Branch, personnel were developing
a comprehensive program to ensure that MOVs would be properly
maintained in the future. Surry Operations Department personnel were
involved in determining which safety related MOVS were required
to be operational in order to mitigate the consequences of an
accident and safey shutdown the plant to hot standby.
As a result of
the Operations Department review, some MOVs in safety-related systems
were not included in the licensee's effort to restore MOVs because
they were not required to be operated in order to mi ti gate the
consequences of an accident or safety shutdown Uni ts 1 and 2.
One hundred Unit 1 MOVs and 103 Unit 2 MOVs ,were being evaluated to
ensure operability.
An MOV Task Group composed of Surry, North
Anna, and Corporate personnel knowledgeable of MOVs was formed to
direct, coordinate~ and provide the required engineering support to
restore the 203 Units 1 and 2 MOVs.
The activities of the Task Group
involved the following:
Review MOVATS test reports dating back to 1988.
Evaluate defi ci enci es encountered during MOVATS testing and
actuator disassembly.
Review and revise as necessary MOV switch settings.
Review adequacy of IE Bulletin 85-03 response.
Review and revise as necessary engineer sketches that provide
MOV limit switch settings.
Establish what actions are required to restore MOVs and track
the required action status.
Perform MOV wa l kdowns to verify that MOV nameplate data
corresponds to data being used to determine MOV thrust values.
Ensure all Surry MOV commitments. are met.
Review MOV work orders dating back to 1988.
Review MOV station deviations dating back to 1986.
Assign root cause and corrective action to MOV station
deviations generated in 1988 and 1989.
Valve thrust requirement ca lcul ati ons, using the la test industry
standards were being requested from applicable valve vendors.
Until
these thrust values can be obtained, the MOV task group provided
thrust values using standard equations.
Two train limit switches are
being replaced with four train limit switchs which allows the torque
switch bypass ~ettings to be increased.
MOV task group reviews of
...
- , .
6
engineering sketches that provided MOV 1 imit switch setpoints
revealed that because of the numerous revisions, it was difficult to
obtain the required information from the sketches.
Consequently, the
task group is being required to rewrite the sketches.
Another
finding of the task group was that MOVATS test reports have not been
adequately reviewed.
One of the first task group actions was to stop
MOVATS testing and prepare written guidelines to ensure that MOVATS
test reports would be adequately reviewed.
The MOV task group
identified that the Unit 1 and 2 power operated relief valves (PORVS)
were marginally sized.
The licensee is planning to replace the
actuators with larger actuators prior to the respective unit startup.
The MOV task group also identified five valves in Units 1 and 2 that
have undersized actuators.
The undersized actuators are l-CH-MOV-
I287A and B, 2-CH-MOV-2287A and B, and 2-SI-2869.
All five valves
and actuators were involved in plant modification packages previously
accomplished.
Valve 2-SI-2869 actuator will be replaced with a
larger actuator prior to startup and the charging valves' actuators
will be deenergized and locked in position until the actuators are
replaced with larger actuators.
During the MOV recovery program review, the inspector noted the
following MDV issues that have not yet been fully resolved:
As discussed in parigraphs 2.a(3) and 2.c, actuator grease was
identified as a problem.
The corrective action to resolve this
issue has not been determined.
All Surry safety-related MOVs contain either 460 volt or 440
volt alternating current motors.
The voltage specifications for
these motors is plus or minus 10 percent of the motor name plate
voltage.
Bus voltage to these motors is approximately 525 volts
AC which exceeds the manufacturer
I s recommended vo 1 tage.
The
440 volt motors are being replaced with 460 volt motors.
The
effect of high bus voltage on the 460 volt motors is being
evaluated.
The MOV recovery program review also indicated that the following
areas required clarification:
The inspector was informed that to verify operation, MOVs will
be differential pressure tested p~ior to startup.
What MOVs to
be tested, and at what pressure has not been determined.
Although there have been station deviations written against
actuators involving missing parts, modified parts, and incorrect
assembly-, the licensee does not intend to disassemble and
inspect a 11 actuators.
The criteria for determining when
disassembly would be performed was not clear .
...
7
Station deviations have been written for modified and homemade
tripper fingers, yet not all tripper fingers have been
inspected.
The criteria for not inspecting all tripper fingers
was not clear
One finding contributing to the cause of present MOV problems is
the 1 ack of a good MOV program.
As a result, Corporate is
developing a comprehensive program that was scheduled to be
issued prior to startup.
The program will involve training
qualification for station and contract personnel and a
department reorganization to ensure that all MOV related
maintenance and testing go through a central person.
Implementation of this program will take time and will likely
not be accomplished prior to startup.
In addition, after
determining root cause and corrective action in response to
station deviations, it is probable that procedural and personnel
training will be identified which may or may not be accomplished
prior to startup.
During the inspection it was not clear what
would be accomplished relative to procedural changes, training,
or other changes to the MOV program prior to startup.
The MOV recovery program indicated that the fo 11 owing action items
need to be accomplished, in addition to the action items presently
being ~ccomplished:
The MOV stroke time review indicated that some MOVs were not
stroking within specified times.
Examples of valve stroke times
exceeding allowed limits are 1-RC-MOV-1536, 2-CH~MOV-2289A, and
2-CH-MOV-22898.
In addition, the inspector reviewed a licensee
memorandum issued by J. Laflam to A. McNeill, dated February 26,
1988, that discussed MOV excessive stroke times.
As discussed
in paragraphs 2.a(2) and 4, the licensee's corrective action for
excessive stroke times did not always identify and correct the
root cause; therefore, MOV stroke times need to be reviewed and
valves with excessive stroke times need to be evaluated in order
to ensure that root cause and corrective action are performed.
As discussed in paragraph 2.a(l), MOVATS testing accomplished
in 1987 on valve 2-CH-MOV-22898 identified valve damages that
could have gone undetected during the present recovery program.
As a result, the inspectors consider it necessary for the
licensee to review all MOVATS test reports dating back to 1985.
Previous plans were to review MOVATS test reports dating back to
1988.
During the exit interview the licensee indicated that
MOVATS test reports issued prior to 1988 would also be reviewed.
In order to determine if MOV repeated problems are occurring the
licensee is reviewing work orders dating back to 1988 for
applicable MOVs.
The inspectors reviewed work orders for
various MOVs from 1985, and considered that in order to
8
determine if repeat problems were occurring, like frequent
replacement of motors for example, then the licensee needs to
review work orders as far back as practicable.
Valves 1-RH-MOV-100 and 2-RH~MOV-200 are pressure boundary, lock
closed, isolation valves backed by manual isolation valves.
In
the case of a control room fire which results in control room
. evacuation, the licensee emergency procedures require these
valves to be opened in order to provide a letdown path. Since
automatic actuation for* the valves is located in the control
room which had been evacuated, the valves would be required to
be opened manually.
The valves have been excluded from the MOVs
that are currently being evaluated.
Since there are station
deviations written for valves that do not manually cycle
properly, the inspectors consider it necessary to take the
appropria_te action to ensure that valves 1-RH-MOV-100 and
2-RH-MOV-200 are able to be manually cycled when required.
During the inspection, areas in the MOV recovery program were_
identified that needed clarification, were not fully resolved,
or in some cases not sufficient.
As a result, the inspectors
noted that personnel in different groups were diligently working
toward restoring MOVs; but how all this work would come together
to ensure that MOVS were operable prior to restart was not
clear. This was discussed during the exit interview where the
licensee committed to provide a letter to the NRC detailing how
the MOV recovery program would be accomplished.
c.
MOV Lubrication
On August 18, 1985, Station Deviation SI-85-430 was written to
document the failure of MOV-SW-104B to cycle on command from the main
control room.
Investigation of this problem by the licensee
disclosed that the cause of the MDV failure was presence of grease in
the electrical side of the housing which affected the contacts.
A
detailed investigation of this problem by the licensee's Human
Performance Evaluation System (NPES) staff disclosed weaknesses in
MDV maintenance procedures and training of maintenance personnel in
repairing MOVs.
One problem identified during the investigation
involved the type of_ grease used to lubricate the valves.
The MDV
manufacturer, L imitorque, stated that the only grease wh.ich they have
certified for their MOVS was Exxon Nebula EP-0 or EP-1, a calcium
soap based grease.
However, licensee maintenance personnel had used
Amoco Ryken No. IEP or Amolith Grease No. 2, which
are lithium
based, when lubricating the MOVs.
Maintenance personnel were not
aware of the differences in the greases, and did not properly
document which type of grease was used to lubricate various MOVs.
The maintenance procedure did not specify the type grease to be used.
As a result, the various types of greases, lithium based and calcium
based greases, were mixed.
The problems identified by the licensee
regarding MDV grease problems were documented in a Virginia Power
9
memorandum dated September 13, 1985, Subject:
Lubrication of
Limitorque Operators, Surry Power Station, NP 1175.
Investigations
performed by other licensees and the NRC have shown that the effects
of mixing lithium base and calcium base grease is that the grease
hardens resulting in unacceptable wear to MOV components, leading to
eventual failure of the MOV.
The mixing of small quantities of
lithium base grease, as little as three to five percent by weight,
with a calcium base grease, has been found to result in hardening of
the grease.
This data is documented in a Safety Evaluation Report,
dated April 28, 1988, prepared by the NRC Office of Nuclear Reactor
Regulation for the Braidwood Nuclear Plant (Docket Numbers 50-456 and
50-457, TAC Nos. 67627 and 67626).
As stated in paragraph 2.a(3),
the licensee failed to take adequate corrective action to resolve
problems noted from August - September 1985 regarding improper types
of grease used to 1 ubri cate MOVs, and the effect of mixing the
various types of greases in MOVs.
This resulted in numerous MOV
grease problems being identified during the current outage.
The inspectors questioned licensee Maintenance Supervisors regarding
planned corrective actions to address grease problems.
These
discussions disclosed that the licensee was evaluating a method which
cleans the MOV with a solvent (varsol) to remove. the old grease.
The
inspectors examined an MOV which was cleaned using this method and
noted that a 11 the grease .had been removed with the exception of some
o 1 d grease under and around the bearings. As a result of the
discussions with licensee personnel, the inspectors had the following
questions pertaining to identifying and removing grease from
safety-related MOVS.
Wbich valves have mixed grease or grease other than Exxon EP-0 or
EP-1?
How was the appropriate grease identified during valve inspection?
What limits are used to determine if grease is contaminated.? What
is maximum percentage of lithium based grease permitted to be present
in the qualified calcium based grease?
What method will be used to remove contaminated grease from MOVs?
How will valves be inspected to verify that all grease is removed.
d.
MOV Technician Qualifications
The inspectors reviewed the qualifications of the ANS mechanics,
titled MOV techs, who perform mechanical inspections and repairs to
MOVs.
The inspectors also observed two MOV techs disassemble, clean
and inspect MOV-SI-28628.
This work was performed in accordance with
procedure MMP-C-MOV-178.
The inspectors interviewed the MOV techs
and determined that they were knowledgeable and cognizant of MOV
. .
10
corrective maintenance requirements.
Based on, review of the MOV tech
qualifications and observations of work activities, the inspectors
concluded that the MOV techs were qualified and had proper training
and experience to perform MOV maintenance.
Within the areas inspected, one violation was identified.
3.
IE Bulletin 85-03 Follow-up (25573)
(Open) 50-280, *281/85-BU-03, T2515/73, Motor Operated Valve Corrmon Mode
Failure During Plant Transients Due to Improper Switch Settings.
The bulletin required licensees to develop and implement a program to
ensure that switch settings for High Pressure Coolant Injection and
Emergency* Feedwater System MOVs, subject to testing for opera ti ona 1
readiness in accordance with 10 CFR 50.55a(g), are properly set, selected,
and maintained.
The information in this Inspection Report supplements the IE Bulletin
85-03 follow-up contained in Inspection Report Nos. 50-280/89-03 and
50-281/89-03.
In order to evaluate the Surry IE Bulletin 85-03 program, the inspector
held discussions with the appropriate licensee personnel and reviewed the
following:
Procedure MMP-C-MOV-178.1, Removal and Overhaul of Limitorque Model
SMB-0 Through SMB-4 and SB-0 Through SB-4, dated March 23, 1989.
Procedure MMP-C-MOV-178, Removal and Overhaul of Limitorque Model
SMB-000 Through SMB-00 and SB-00, dated October 21, 1988.
Procedure EMP-C-MOV-18, Safety Related MOVs - Repair, Replacement,
Checkout and Adjustments, dated October 11, 1988.
Procedure EMP-L-MOV-11, Disconnect and Reconnect Safety Related MOVs,
dated October 10, 1988.
Procedure EMP-C-MOV-151, Testing MOVs Using MOVATS System; dated
March 10, 1989.
Procedure SUADM-M-08, Repair/Replacement Program, dated January 26,
1989.
Procedure EMP-L-MOV-198, Testing Butterfly MOVs using MOVAT BART
System, dated March 4, 1989.
The following comments are based on the inspector review of the licensee's
MOV procedures:
l
11
Procedure
MMP-C-MOV-178 contains actuator illustrations with
reassembly instructions. Several of the illustrations were not clear
and; therefore, would not aid the mechanics during actuator
reassembly.
Procedure MMP-C-MOV-178.1, provides instructions for removal and
overhaul of Limitorque SMB-0,1,2,3,4 and SB-0,1,2,3,4 rising stem and
butterfly actuators.
These various types and sizes of actuators
contain significant differences.* In lieu of providing detailed
illustrations, the procedure references the Limitorque
SMB
Instruction and Maintenance Manual.
For SB actuators; however, the
Limitorque maintenance manual is not referenced by the procedure.
Procedure SUADM-M-08 provides MOV retest requirements following IE
Bulletin 85-03 valve maintenance.
The retest requirements appear to
be adequate if adhered to.
Step 3.8.1.3c in this procedure allows
the Superintendent of Engineering, with the coordination with the
Superintendent of Operations or their designees, to modify these
retests requirements when plant conditions make retest performance
impractical.
As previously discussed in paragraph 2.a(2), MOVATS
testing of valve 2-CH-MOV-2289B was not performed following limit
switch adjustment which is contrary to Procedure SUADM-M-08
guidelines.
Within the areas inspected, violations or deviations were not identified.
4.
Power Operated Valves Inservice Stroke Time Testing (73756)
The criteria for stroke time testing power operated valves is contained in
Section XI of the American Society of Mechanical Engineer (ASME) code.
The licensee is committed to the 1980 edition of Section XI.
The stroke
times for the following MOVs from 1986 were reviewed by the inspectors:
2-CH-MOV-2289A
2-CH-MOV-22898
1-FW-MOV-160B
2-CH-MOV-2115B
1-RC-MOV-1535'
1-RC-MOV-1536
2-RC-MOV-2535
2-RC-MOV-2536
2-FW-MOV-251A
1-FW-MOV-1510
1-SW-MOV-105A
2-SW-MOV-204B
1-SI-MOV-1842
Review of these MOV stroke time results indicated that the stroke
frequency requirements required by Section XI of the ASME Code were met.
The only deficiencies noted were the licensee's corrective action involving
an MOV initially failing to stroke fully open or closed, initial stoke
time exceeded the maximum allowed, and adjusting the of limit switches to
shorten valve stroke to obtain the desired stroke time results.
When a
MOV fails to stroke initially fully open or closed or if the stroke time
is excessive, it had been previous licensee practice to stroke the valve
two more times.
If these two stroke times were acceptable, then the valve
was returned to service.
In early 1988 the resident inspector informed
12
the licensee that this practice was not in accordance with ASME Section XI
requirements.
As result, the 1 i censee now requires that a station
deviation be generated if a valve initially fails the first attempt, but
subsequently passes two additi ona 1 stroke time tests.
The station
deviation must be evaluated with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the initial failure. If the
reason for the first failed attempt cannot be corrected, then the valve
will be declared inoperable.
The valves that failed initial stroke
testing were 2-CH-MOV-2289A, 2-CH-MOV-22898, and 1-RC-MOV-1536.
These
valves were subsequently stroke time tested satisfactory on second and
third attempts and returned to service.
These initial stroke failures
occurred prior to licensee's corrective action in response to the resident
inspector's findings.
The inspectors also noted instances where
corrective action for excessive stroke times involved adjusting of valves
2-CH-MOV-2289A and B open and/or closed limit switches.
Station records
that accomplished limit switch adjustments for these valves did not
provide enough information to confirm that limit switches were actually
out of adjustment oi if limit switches were adjusted to shorten valve
stroke; however, the valves did have a history of exceeding stroke time
limits or just barely passing stroke time testing specifications.
In paragraph 2.a, a violation was issued when valves 2-CH-2289A and B were
identified as examples of valve deficiencies where sufficient corrective
action was not taken.
Within the areas inspected, no violations or deviations were identified.
5.
Exit Interview
The inspection scope and results were summarized during a telephone
conference call on April 4, 1989, with those persons indicated in
paragraph 1.
The inspectors described the areas inspected and discussed
in detail the inspection results listed below.
Proprietary information is
not contained in this report.
Dissenting cornnents were not received from
the licensee.
Violation 280,281/89-10-01, was identified for failure to take corrective
action in response to MOV deficiencies, paragraph 2.a.
The licensee committed fo the NRC to provide in writing details of the MOV
recovery program, and to review MOVATS test reports issued prior to 1988,
paragraph 2.b .