ML20035B936
| ML20035B936 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/30/1993 |
| From: | Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035B933 | List: |
| References | |
| 50-341-93-03, 50-341-93-3, GL-89-10, NUDOCS 9304060018 | |
| Download: ML20035B936 (11) | |
See also: IR 05000341/1993003
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-341/93003(DRS)
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Docket No. 50-341
License No. NPF-43
Licensee:
The Detroit Edison Company
6400 North Dixie Highway
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Newport, MI 48166
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Facility Name:
Fermi 2 Nuclear Power Station
Inspection At:
Fermi 2 Site, Newport, MI
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Inspection Conducted:
February 8 through 18, 1993
Inspection Team:
C. A. Gainty, Team Leader
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M. P. Huber, Reactor Inspector
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M. D. Hunt, Reactor Inspector, Region II
T. G. Scarbrough, Senior Mechanical Engineer, NRR
J. F. Smith, Reactor Inspector
NRC Consultant:
M. R. Holbrook, Idaho National Engineering Lab
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Approved y:
Stv
kSo -T3
J. SC JJcobe n, Chief
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Date
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P ter.-1s
Processes Section
Inspection Summary
Inspection conducted February 8 throuah 18. 1993(Report No. 50-341/93003(DRS))
Areas inspected: Announced safety inspection of the implementation of the
licensee's response to Generic Letter (GL) 89-10, " Safety-Related Motor--
Operated Valve (MOV) Testing and Surveillance" (2515/109).
Results: The licensee had developed and implemented a program which is
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generally consistent with the guidance of GL 89-10.
The inspection disclosed
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one noncited violation (Section 2.2.3.1), two unresolved items (Sections 2.2.2
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and 2.3.5) and five inspection follow-up items (Sections 2.2.1.1, 2.2.2 and
2.3.3).
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9304060018 930330
ADOCK 05000341-
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DETAILS-
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Persons Contacted
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Detroit Edison Company (Deco)
- W. Orser, Senior Vice President, Nuclear. Operations
- D. Gipson, Vice President,- Nuclear 0perations'
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W. Ackerman, '4uclear Engineering
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- E. Cavey,-MOV Maintenance
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- J. Francis, Electrical Engineering
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- E. Hare,. Senior Compliance Engineer-
- K. Howard,' Supervisor, Nuclear Engineering _
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- A. Nayakwadi, MOV Program Manager
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- J. Tibai, Supervisor, Compliance Licensing
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- S. Zoma, Lead Electrical Engineer
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U. S. Nuclear Reculatory Commission (NRCl
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- W. Kropp, Senior Resident Inspector
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- Denotes those attending the exit meeting on February 18, 1993.
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2.0
Inspection of the implementation of the Proaram Developed in
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Response to-Generic Letter 89-10
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2,1
Selected MOVs
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The licensee had 148 MOVs in the GL 89-10 program; differential pressure (ds)
testing was planned for approximately 44 MOVs. To assess the' licensee's GL
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89-10 program adequacy, selected M0V's received a detailed review. The
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following valves were selected based on safety significance, previous test
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results, 2nd to examine a cross-section:of the MOV population. The' details of
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the review are discussed in the sections that' follow.
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Ell 50F007A -
4" gate, SMB-000, RHR
Ell 50F024B - 18" globe, SMB-4, RHR
Ell 50F028A - 18" gate, SB-3, RHR
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E2150F005A - 12" gate, SB-3, core spray
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E2150F031A -
3" gate,-SMB-000, core spray
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E2150F015A - 10" globe, SMB-2, core spray
E4150F003 - 10" gate, SBD-3, HPCI
E4150F002 - 10" gate, SB-2, HPCI
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G3352F004 -
6" gate, SBD-0, RWCU
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2.2
Generic letter 89-10 Review for Selected MOVs
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2.2.1
Desian Basis Reviews
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The inspectors evaluated the design basis reviews of the nineJselected MOVs by'
reviewing piping diagrams, calculations, assumptions, and conclusions for
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maximum expected flow, differential pressure and degraded voltage conditions.
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2.2.1.1
Differential pressure and Flow Reauirements
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The licensee reviewed the' FSAR, technical specifications, normal, abnormal,
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and emergency operating procedures, and other plant documents to determine the
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worst-case design basis conditions for each MOV. Additionally, pump. curves,
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. supply tank pressures, and static heads were considered in determining the
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design basis maximum expected differential pressure (MEDP) for MOVs.
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The inspectors noted use of generic pump curves instead of the certified pump
curves resulted in lower calculated MEDPs for some MOVs.
For example,- the
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maximum developed head on the generic pump curve for the core spray system was
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less than that of the certified pump curve, resulting in a 'non-conservative
MEDP. During the inspection, the licensee recalculated the MEDPs and the
required thrust / torque for the affected MOVs selected for NRC review and
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determined that the MOVs would still operate. The determination was based on
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an evaluation of the available thrust seen during diagnostic testing.
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With the exception of using generic pump curves rather than certified pump
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curves the licensee's dp and flow requirement determinationas were
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appropriate.
In response to the inspectors' concerns, the licensee stated
they would review all MEDP calculations by August 1993 to ensure that the
appropriate certified pump curves were used. Additionally, the licensee
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stated they would revise and evaluate the corresponding thrust / torque
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calculations as necessary by the end of 1993. This is considered an
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inspection follow-up item and will be reviewed during a future inspection (50-
341/93003-01(DRS)).
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2.2.1.2
Reduced Voltaae Capability
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The degraded voltage calculation method had been recently revised as a result
of self-identified weaknesses in the original method. The revised assumptions
were consistent with the guidance of GL 89-10 and required the revision of all
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degraded voltage calculations, which were completed just prior to the-
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inspection.
While the licensee re-evaluated their degraded voltage calculations they
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failed to consider the new voltage's impacts on MOV operability.
Further
review determined that all valves were operable. The inspectors reviewed the
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bases for these conclusions and found no problems.
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2.2.2
MOV Switch Settinos
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The inspectors reviewed " Fermi 2 Motor-0perated Valve (MOV) Program Guideline
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for MOV Design Basis Review, Testing, and Evaluation," Revision D, and
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associated calculations for the selected MOVs. Three inspection followup
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items and one unresolved item were identified as discussed below.
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Thrust control windows were not adjusted for uncertainties associated with
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torque switch repeatability (approximately 5% - 10% according to Limitorque).
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Instead, the choice of stem friction coefficient was relied on to ensure
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adequate margin in the torque switch setup. However, the stem friction
coefficient would not always account for situations where the control switch
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trip (CST) point was set close to the upper or lower end of the thrust window.
For example, test results for M0V Ell 50F028A identified a condition where CST
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was set too close to the minimum thrust requirement to account for torque
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switch repeatability. The licensee planned to adjust the torque switch to
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correct this condition.
In- the interim, valve operability was based on the
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duration of the close torque switch bypass. The licensee agreed to revise
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their methodology to consistently account for torque switch repeatability in a
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quantified manner. This issue is considered an' inspection follow-up item and
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will be reviewed during a future inspection (50-341/93003-02(DRS)).
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Uncertainties associated with MOV load sensitive behavior were not accounted
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for in the switch setting calculations.
Load sensitive behavior'may-reduce
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the thrust delivered by the operator under high differential pressure and flow
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conditions. Again, the licensee relied on a conservative stem friction
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coefficient choice to provide adequate margin in the torque switch setup,
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Test results at Fermi indicated load sensitive behavior, in some cases as high
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as 25%.
In response to the inspectors' concerns, the licensee indicated plans
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to incorporate plant specific test data and industry data for load sensitive
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behavior into the program for MOVs.
This issue is considered an inspection
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follow-up item and will be reviewed during a future inspection (50-341/93003-
03(DRS)).
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No allowance was made for stem lubricant degradation in determining required
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thrust, which could reduce MOV capability.
Based on preliminary test results
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for MOVs on an 18 month stem lubrication frequency, the licensee indicated-
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that degradation was not a problem. However, most MOVs in the GL 89-10
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program were lubricated on a 36 month frequency. A longer lubrication
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interval may affect assumptions regarding lubricant degradation.
In response
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to the inspectors' concerns, the licensee stated that a 5% margin would be
utilized until analysis of test results was complete.
This issue is
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considered an inspection follow-up item and will be reviewed during a' future
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inspection (50-341/93003-04(DRS)).
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DER 92-0196 discussed the possible reliance on Limitorque Technical Update 92-
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01, which endorsed a study by Kalsi Engineering concerning the structural
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overthrust capability of actuators up to 140% of the thrust rating. The DER
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stated that the Fermi 2 Design Guide and applicable procedures might have to
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be revised as a result of the generic response being prepared by the industry
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to the NRC questions concerning the Kalsi study provided in an NRC. inspection
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report for the Wolf Creek nuclear power plant.
This is an unresolved item,
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pending NRR review of the industry's response (50-341/93003-05(DRS)).
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2.2.3
Desian Basis capability
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The inspectors reviewed completed static and dp testing packages to verify the
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adequacy of the methods used to demonstrate MOV capability.
At the time of
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the inspection, 21 MOVs had been dp tested.
Generally, the licensee was
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progressing in this area, however problems were noted.
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The licensee had not performed multi-point testing and had not justified that
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the extrapolation method was adequate over the long term to predict design
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basis thrust requirements.
The inspectors reviewed static test packages for
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the high pressure coolent injection (HPCI) E4150F002 and E4150F003 MOVs, and
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dynamic test- packages for the residual heat removal (RHR) Ell 50F028A and
E1150F024B MOVs. The two dynamic tests were conducted at greater than 80% of
design basis conditions and a straight line extrapolation was used to
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determine the output thrust at the design basis dp. Therefore, the inspectors
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considered these tests to be the first stage of the two stage approach where
the valves have been setup using the best available data.
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The licensee's review of Ell 50F028A, (18 inch Powell gate valve) dynamic test
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results for the dp test conducted April 20, 1991, determined that the actual
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valve factor was significantly greater than the 0.30 that was assumed-in
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original calculations. The as-left torque switch setting was determined by
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the licensee to be inadequate when considering diagnostic equipment
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inaccuracy, torque switch repeatability, and stem lubricant degradation.
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However, the licensee considered the valve operable based on the close torque
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switch being bypassed to within .023 seconds of flow isolation and inertial
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thrust that was present during the dynamic test. The inspectors agreed with
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the licensee's decision on operability.
Review of corrective actions and
resolution of this issue is considered an inspection follow-up item
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(50-341/93003-08).
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2.2.3.1
Acceptance Criteria for MOV Testina
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The inspectnrs noted concerns with dp test acceptance criteria and evaluation
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timeliness. Acceptance criteria used at the time of the dynamic tests
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consisted of a check list that did not address the difference between the test
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conditions and design basis conditions. A more complete "MOV Post-testing
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Review" evaluation form had been developed in January 1993;, however, by the
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time of the inspection, the form had only been used to evaluate the nine MOVs
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selected for review by the NRC.
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The dynamic test data for MOV E1150F028A, tested on April 20, 1991, indicated
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that the MOV actually required 32734 lbf thrust to isolate flow and that 35905
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lbf was required to achieve hard seating. The calculated thrust to close the
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valve under the MEDP was 26064 lbf (without correction for diagnostic
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equipment inaccuracy). Since the required thrust to close the valve was much
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greater than expected, an evaluation should have been performed at the time of
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the test to determine the MOV capability.
Instead, in a comment section
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attached to the acceptance criteria, the licensee stated that the margin was
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small, but the MOV had opened and closed against pump shutof f head which was
said to be approximately equal to the MEDP of 325 psid.
However, the actual
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test differential pressure was later determined to be only 286 psid (88% of
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MEDP). Also, the licensee had not considered diagnostic equipment
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inaccuracies or torque switch repeatability in evaluating whether adequate
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margin was available.
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Design Calculation 5038 stated that a calculation for predicted thrust
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requirement using a 0.5 valve factor would be used where test results revealed
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an actual thrust requirement greater than predicted using a 0.3 valve factor.
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Although the MOV test on April 20, 1991, indicated a thrust requirement
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greater than predicted by a 0.3 valve factor, there had been no evaluation of
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the MOV capability to perform its safety function based on the higher valve
factor.
During the inspection, the licensee re-evaluated the data from the above test
using the new "MOV Post-testing Review" evaluation form. This evaluation
considered diagnostic equipment inaccuracies including the October 2, 1992,
Liberty Technolcgies Part 21 information discussed in Section 2.3.3.
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calculation predicted an approximate 5 percent margin between the current
torque switch setting and the thrust that would be required to close the valve
under MEDP.
10 CFR Part 50, Appendix B, Criterion XI, " Test Control," of requires
licensees to evaluate the results of tests to assure that test requirements
have been satisfied.
Failure to promptly evaluate results from MOV dynamic
testing performed as part of its commitment to GL 89-10 is considered a
violation of Criterion XI.
However, the 14RC wants to encourage and support
licensee's initiatives for self-identification and correction of the problems.
Therefore, this violation is not being cited because the criteria specified in
Section Vll.B.2 of the " General Statement of Policy and Procedures for f4RC
Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C) were
satisfied.
Specifically, the licensee identified that thorough test result
evaluations were not completed at the time of the dp tests and subsequently
developed an *MOV Post-testing Review" evaluation form to review the results.
The licensee committed to complete an evaluation form for the 21 previously
performed dp tests by May 14, 1993, and to include consideration of motor
capability.
In addition, plant procedures were revised to require prompt
evaluation following future dp tests.
2.2.3.2
Review of VOTES Diagnostic Traces
The inspectors noted that thrust measurements for MOV E2150F015A were outside
the calibration range estabiished on October 12, 1992. The upper limit of the
best fit straight line (EFSL) calibration range was approximately 62,000 lbf.
Post-calibration testing produced thrusts outside the calibration range.
Control switch trip (CST) for Test I was 91,814 lbf (51% extrapolation) and
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CST for Test 3 was 65,174 lbf.
The post-test review acknowledged that the as-
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left static test utilized an extrapolation outside the calibration range:
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however, licensee personnel were unaware that the use of BFSL calibrations for
extrapolation outside the calibration range was not recommended by Liberty
Technologies.
The licensee agreed to review all calibrations and take
necessary actions to ensure that valid thrust measurements were recorded where
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inappropriate extrapolations were originally performed.
2.2.4
Periodic Verification of MOV Capability
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Plans for periodic MOV capability verification met the guidance of GL 89-10
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with respect to frequency, but did not identify an objective method for
ensuring that capability.
The licensee will need to justify the method of
providing assurance of the capability of the MOV to perform adequately when
called upon during an accident.
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2.2.5
MOV Failures. Corrective Actions and Trendina
The inspectors reviewed the corrective actions for selected deviation reports.
In the cases reviewed, the root cause determination and corrective actions-
were complete and well documented. A large number'of MOVs had experienced
overthrusting conditions, which had been evaluated _ and resolved. Some
evaluations required an assessment by the valve manufacturer _ and some relied
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on a-study performed by Kalsi Engineering which allowe exceeding Limitorque's..
thrust iimits. No specific failures indicated any program weaknesses,
however, the use of the Kalsi report is under NRC review as discussed in
Section 2.2.2 of this report.
The trending program was considered a strength. A variety of classifications
were provided in the area of maintenance and failures. The. program also
provided a rational basis for consistent classification.
2.2.6
Schedule
The licensee planned to accomplish the actions in GL 89-10 in accordance with
the recommended schedule. -Testing was being accomplished as prescribed by the
licensee's program, however, the number of tests that remain indicated that it
may be difficult to complete the dp testing that was planned.
The inspectors
informed the licensee that extension of the testing schedule, if required,
must include verification of the capability of all MOV's by June 1994.
2.3
Associated Reviews
2.3.1
Maintenance
The licensee's nominal preventive maintenance (PM) frequency was changed from
18 months for all MOVs to 36 months for most MOVs. This exceeded the-
manufacturer's (Limitorque) recommended 18 month frequency.for stem
lubrication. The decision to extend the maintenance interval was. based on the
licensee's trending program; however, the effects of the extended maintenance
frequency have not been quantified.
Some additional degradation and increased
stem factors may be expected. The licensee planned to justify.their use of
stem factor, but had not determined the method as of the time of the
inspection. Such justification could be supported by as-found design basis
testing.
Static diagnostic testing may not be as valuable due to
uncertainties in the relationship between the performance of MOVs under static.
and design basis conditions.
The post maintenance testing specified for valve stem packing adjustments was
to perform thrust testing for MOVs with small thrust margins.
For MOVs with
large thrust margins, the adjustment was considered acceptable if a motor
current increase of up to 5% was observed. The licensee indicated that motor
power was being pursued to replace current in this application to avoid.the
errors resulting from power factor. change with load. Although ac motor
current is generally considered to be a poor packing load indicator, its use.
under these conditions appears to offer an acceptable interim method
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2.3.2
Trainina
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The inspectors witnessed a Fermi test loop demonstration.
The loop contains-
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typical pumps, manual valves, MOVs, orifices and. instrumentation for measuring
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pressure, flow and MOV diagnostics. The_ loop is used in training' personnel to
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perform routine maintenance on pumps and valves, to perform MOV diagnostics,
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to adjust MOV switches, and to observe the results of such work. The loop is
designed to permit the insertion and removal of spool pieces containing
various components and can also be used to perform individual component flow
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testing. Use of a test loop for training and component testing is considered
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a valve program strength.
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2.3.3
Diaanostics
The licensee used the Valve Operational Test Equipment System (V0TES) to test
MOVs under both static and dynamic conditions. Because the testing did not
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currently include a method to verify torque, stem friction factors may not be
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quantifiable, except in the case of one MOV where a calibrated spring pack was
used. Actual motor capability will be difficult to assess without a method to
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measure torque or stem friction due to the known inaccuracy of the generic
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spring pack curves used. The licensee agreed to review this issue further.
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This is considered an inspection follow-up item and will be reviewed during a
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later inspection (50-341/93003-06(DRS)).
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The current probes used with the V0TES equipment were calibrated, but there
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was no record in the work package of which probe was used for each test.
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Documentation of the probe number is recommended because the information-could
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prove useful if one probe is found to be malfunctioning or out of calibration,
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In accordance with 10 CFR Part 21, Liberty Technologies notified the NRC staff
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and nuclear power plant licensees in October 1992 of a generic issue regarding
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the accuracy of its VOTES diagnostic equipment used in measuring the thrust
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delivered by motor actuators. The. licensee had prepared the "MOV Post _-Testing
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Review" evaluation form, which analyzed the changes in valve capability based
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on the correction factors provided in the Part 21.
This evaluation also
analyzed the increased inaccuracy resulting from the use of torque correction
factors.
2.3.4
Walkdown
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The inspectors performed a general plant inspection and a detailed inspection
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of several MOVs.
In general, housekeeping was considered good. Actuator
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limit switch covers were not r moved during the inspection, however, the
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general external condition of the MOVs was considered to be good. None of the.
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MOVs observed during the walkdown were in adverse environments, valve stems
were well lubricated, and no grease leaks were noted. Valve and motor
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operator nameplate data was readily retrievable.
The inspectors examined a pipe section in the standby feedwater system which
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had been observed to move appreciably when valve N21037F001 was opened to
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pressurize the system from less than 40 psig to approximately 1100 psig. The_
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licensee's inspection of this line identified one bent hanger and one loose
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hanger. The: motion was attributed to loose hangers. The inspectors found
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evidence of prior movement over a large portion of the length, but found
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- nothing to challenge the-licensee's conclusion.- The planned corrective-action
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was to. repair the' damaged hanger, tighten loose hangers and repressurize-the
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system while observing for-motion. This was considered to be- reasonable and
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prudent.
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2.3.5
Pressure Lockina and Thermal Bindino
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In a memorandum dated October 4, 1985, the licensee listed gate valve type
MOVs that were susceptible to pressure locking or thermal binding.
The. memo
was not clear as to the criteria for placing the valves on the list or the
motor actuators capability to~ overcome these phenomena.
For-example, the-
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memorandum referred to relief ports as a resolution of the pressure locking
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issue and to the performance of inservice tests as prevention for thermal
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binding. However, the licensee informed the inspectors that the relief ports-
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are capped.
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In response to General Electric (GE) SIL 368, " Recirculation Discharge
Isolation Valve Locking," DER 89-0121 was issued to reevaluate the. pressure
locking and thermal binding issue.
Review of the specific MOVs-. listed in the
GE SIL disclosed 18 MOVs susceptible to pressure locking or thermal binding at-
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Fermi 2.
Of the 18 MOVs, 12 were exempted from a more detailed analysis for
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various reasons, however, the inspectors had concerns with the licensee's-
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justification. For example, the licensee exempted RHR shutdown' cooling MOVs.
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F006, 008 and 009 because they are closed during cold conditions and RHR '.
minimum flow MOVs F007A and B were exempted because the ' operating conditions
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were low-temperature and differential temperature. The justification used for
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the two sets of valv s would eliminate any thermal binding concerns, but does-
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not address the potential for pressure locking. The licensee reassessed the
evaluation of the 18 MOVs in DER 89-0669 following NRC Information Notice 92--
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considered the licensee's evaluation to lack sufficient detail to support thel
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conclusions.
In Calculation 5132, the licensee evaluated the capability of the six
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remaining MOVs to overcome a predicted thrust requirement for pressure
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locking.
The inspectors noted concerns with the licensee's calculations.
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example:
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The required thrust calculation was based on the wedge area as opposed
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to the combined area of the two discs, which would see the effect of
pressure locking between the discs.
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(2)
The assumption for differential pressure appeared low.
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(3)
The calculated thrust output capability for each M0V was not. documented.
In response to the inspectors' request for details of the MOV calculations,
the licensee reevaluated the capability of the six MOVs because of
uncertainties surrounding the original calculations.
In DCN 5132
(February 19,1993), the licensee provided the inspectors with calculations
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addressing the six H0Vs capability to overcome pressure locking. The
inspectors-received DCN 5132 at the end of- the inspection and did not have an
opportunity to review the calculations independently. The inspectors 1
considered this issue to be unresolved pending further evaluation
(50-41/93003-07(DRS)).
3.0
Licensee Self-Assessment
The licensee's 1992 formal MOV program surveillance was considered to be-
adequate. The surveillance compared the program to the recommendatic.ns of GL 89-10.
One finding was that the committed schedule may not be met considering
the past testing rate as discussed in this report. DERs were issued to-
document and track finding resolution, with a due date assigned to each.
In
addition, other weaknesses in the program had been identified and corrected
through monitoring the results of other licensees' GL 89-10 inspections.
For-
example, the licensee had identified that the original degraded voltage' .
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calculations did not include thermal overload resistance and were in need~ of
o+her corrections, and the results of dp tests had not been formally evaluated
and documented.
In general, efforts in this area were considered to be good.
4.0
Unresolved items
Unresolved items are matters about which more information is required in order
to ascertain whether they are acceptable items, items of noncompliance, or
deviations. Unresolved items disclosed during this inspection are discussed
in Sections 2.2.2 and 2.3.5 of this report.
5.0
Inspection Follow-up Items
Inspection follow-up items are matters which have been discussed with the
licensee which will be reviewed further by the inspector and which involve
some action on the part of the NRC or licensee or both.
Six inspection
follow-up items were identified during this inspection and are discussed-in
Sections 2.2.1.1, 2.'2.2, 2.2.3, and 2.3.3.
6.0
Violations For Which A " Notice of Violation"'Will Not Be issued
The NRC uses the Notice of Violation to formally document failure to meet .a
legally binding requirement. However, because the HRC wants to encourage and
support licensee's initiatives for self-identification and correction of the
problems, the NRC may not issue a Notice of Violation if the requirements set
forth in 10 CFR Part 2, Appendix C, Sections VII.B.1 or VII.B.2 are met.
Violations of regulatory requirements identified during the inspection for
which a Notice of Violation will not be issued is discussed in Section
2.2.3.1.
7.0
Exit Meetina
The inspectors met with liceasee representatives (denoted in Section 1) at the
conclusion of the inspection on February 18, 1993. The inspectors summarized
the purpose and scope of the inspection and the findings, including the non--
cited violation, two unresolved items, and five inspection follow-up items.
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The inspectors also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspectors during the inspection.
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