IR 05000277/1992082

Insp Repts 50-277/92-82 & 50-278/92-82 on 921019-23 & 1130. Violations Noted.Major Areas Inspected:Licensee GL 89-10 Program & Walkdown

ML20127L830
Person / Time
Site:	Peach Bottom
Issue date:	01/11/1993
From:	Drysdale P, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127L818	List: IR 05000277/1992082 ML20127L814 ML20127L822
References
50-277-92-82, 50-278-92-82, GL-89-10, NUDOCS 9301280021
Download: ML20127L830 (28)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

REPORT / DOCKET NO /92-82 50-278/92-82 LICENSE NO DPR-44 DPR-56 LICENSEE: Philadelphia Electric Company (PECo)

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s FACILITY NAME: Peach Bottom Atomic Power Station (PBAPS)

INSPECTION AT: Delta, Pennsylvania; PBAPS Wayne, Pennsylvania; Nuclear Engineering Offices INSPECTION DATES: October 19-23, and November 3,1992 at PBAPS November 2, ?, 6, 20, and 30 at the Engineering Offices TEAM MEMBERS: M. Evans, Region I R. Paolino, Region I L. Prividy, Region I T. Scarbrough, NRR J. Shea, NRR A. Trusty, INEL J. Zimmerman, Region I TEAM LEADER: 4m Ab -

Peter Drysdale, Sr. deactor Engineer,

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D' ate Systems Section, EB, DRS APPROVED BY: h'

dna Dr. P. K. Eapen, Chief, Systems Section, Date d Engineering Branch, DRS Inspection Summary: See the Executive Summary

'9301280021 930121 PDR ADOCK 05000277 G PDR _

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SUMMARY

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The Nuclear Regulatory Commission (NRC) conducted a team inspection at the Peach

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Bottom Atomic Power Station (PBAPS) on October 19 - 23, and November 3,1992 to assess the programs developed by the licensee in response to NRC Generic Letter 89-10,

" Safety-Related Motor-Operated Valve Testing and Surveillance." This inspection was

accomplished in accordance with NRC Temporary Instruction (TI) 2515/109, " Inspection Requirements for Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and

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Surveillance." The Generic Letter and its Supplements (1,2, 3 and 4) provided recommendations to the licensees for the development of adequate programs to ensure operability of safety-related motor-operated valves (MOVs) during design-basis conditions.

The team observed adequate progress in the area of design-basis testing. Static testing for all of the MOVs in the program was complete. Some limited dynamic testmg has been attempted, but the results were not considered reliable for GL 89-10 credit. The licensee is l planning to group GL 89-10 MOVs into similar families for conducting dynamic tests so that

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test results from one MOV in a group can be applied to others that are not practicable to tes The test groupings devised by the licensee might have to be expanded significantly once actual dynamic test results are reviewed and evaluated. The licensee intends to aggressively work ahead of the current program plan schedule to assure timely completion of all dynamic testing.

i The team identified the following programmatic concerns: (1) Close management attention

was not evident in several program areas in that corrective actions for nonconforming

. conditions were not adequately implemented. Multiple examples of a violation of NRC 4 requirements were identified when the licensee did not document or take appropriate corrective actions to address test discrepancies and nonconforming conditions. One example occurred as a result of untimely corrective actions taken to evaluate and repair cracks in RHR valve yokes after the actuators had experienced high over-thrust conditions; (2) the

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licensee used non-conservative valve factors during design basis reviews of GL 89-10 Supplement 3 MOVs. Several questionable MOV switch settings required resolution prior to startup of both units; (3) the current MOV program does not address a methodology for extrapolation of test results from partial to full design-basis differential pressure (d/p)

conditions. The two-stage approach for MOVs which cannot be tested at full design-basis j conditions (d/p and flow) was not incorporated into the program; and (4) several MOVs with DC motors had calculated degraded voltages less than 70% of the motor rating at the terminals.

An adequate maintenance program was established for MOVs including regular periodic actuator preventive maintenance and good procedures. An MOV failure trending program was initiated but remained to be fully develope In summary, the licensee has developed an MOV program which is addressing the recommended actions of Generic Letter 89-10 with exceptions. Close management attention was lacking in MOV program areas concerning test deficiency reporting and resolution. Table I summarizes the inspection findings for which the licensee agreed to provide resolutio i

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3 INTRODUCTION On June 28,1989, the NRC issued Generic 12tter (GL) 89-10, " Safety Related Motor-Operated Valve Testing and Surveillance," which provided recommendations to licensees for the development of adequate programs to ensure operability of

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safety-related motor-operated valves (MOVs) during postulated design-basis accident

conditions. The Generic Letter recommended that each licensee with an operating

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license complete all design basis reviews, analyses, verifications, tests and inspections that have been instituted within 5 years or three refueling outages, whichever is later, of the 4 date of the Generic Letter (June 28,1989). The staff held public workshops to discuss

the Generic Letter and to answer questions regarding its implementation. On June 13,1990, the staff issued Supplement 1 to Generic Letter 89-10 to provide the

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results of the public workshops. In Supplement 2 (issued on August 3,1990) to Generic

Letter 89-10, the staff stated that inspections of programs developed in response to the Generic Letter would not begin until January 1,1991. In response to concerns raised by the results of NRC-sponsored motor-operated valve tests, the staff issued Supplement 3

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to Generic Letter 89-10 on October 25,1990, which requested that boiling water reactor

licensees evaluate the capability of motor-operated valves used for containment isolation in the steam lines to the high pressure coolant injection system and reactor core isolation cooling system, in the supply line to the reactor water cleanup system, and in the lines to

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the isolation condenser as applicable. On February 12,1992, the staff issued Supplement

4 to Generic Letter 89-10 to clarify that considerations for inadvertent operation of

MOVs may be excluded from the scope of Generic Letter 89-10 for boiling water reactors.

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The inspection team used Temporary Instruction (TI) 2515/109 (dated

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January 14,1991), " Inspection Requirements for Generic Letter 89-10, Safety-Related

Motor-Operated Valve Testing and Surveillance," to perform this inspection. This inspection focused on Part 1 of the TI, which involves a review of the program being

established by the licensee in response to Generic Letter 89-1 .0 Tile LICENSEE'S GENERIC LE' ITER 89-10 PROGRAM On December 28,1989, the licensee responded to GL 89-10 by stating its intentions to develop an MOV program at Peach Bottom Atomic Power Station in response to the

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GL recommendations. The following clarifications were also provided:

In a reply letter on July 5,1990, the NRC staff commented on the licensee's intent to conduct design basis tests on MOVs where practicable and to establish qualification based on design basis testing of one MOV in each family of MOVs. Where in-situ testing under design basis conditions is not practicable and where application of available test data cannot be justified, the staff requested that the licensee follow the "two-stage" approach as outlined in the Generic Letter. The licensee responded to the NRC staff on March 13,1991, stating their awareness of the need to utilize the two-stage approach, as

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appropriate. However, the licensee's MOV Program Description did not describe a i methodology for the two-stage approach and did not indicate that it would be necessary l

to apply the two-stage approach to all GL 89-10 program MOVs that were not tested at

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maximum design-basis conditions. The licensee committed to putting specific information into the program plan to justify the grouping of MOVs and to subsequently

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confirm that the groupings are justified based upon test results. However, pending revision of the MOV program plan to incorporate the two-stage approach for GL 89-10 MOVs that cannot be design-basis tested, this item remains unresolved

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(URI 50-277/92-82-01; 50-278/92-82-01).

The team reviewed the GL 89-10 program details with licensee personnel. The

inspection results related to each aspect of GL 89-10 are described below.

, Scope and Aiministration of the Program

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! The program scope and administration were reviewed to assure that the licensee has an 4 adequate program plan and scope and has delineated responsibilities to complete the Generic Letter 89-10 program commitments.

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The licensee developed a GL 89-10 program description " Peach Bottom Atomic Power

] Station, MOV Program Description," in response to GL 89-10. The team reviewed i

Revision 1 of this document, dated October 14,1992. The program description established the specific responsibilities of the corporate and plant technical personnel for

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the GL 89-10 reque'sted actions. The Nuclear Engineering Department (NED) has the overall responsibility for development of the program which is implemented at PBAPS by the site Maintenance Department. The licensee has contracted out for engineering

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services related to the development of the MOV design-basis reviews. The team

interacted with various personnel in each of these groups and determined that they were

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knowledgeable of most MOV issues. The text within the MOV program description addresses the requested actions of GL 89-10. The MOV program description included

important elements such as calculations, procedures, and commitments concerning

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The team reviewed the piping and instrumentation diagrams, emergency operating d

procedures, technical specifications, and the updated final safety analysis report

(UFSAR) to verify that MOVs in safety-related systems were included in the GL 89-10

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MOV program. There are 178 MOVs included in the GL 89-10 program and twelve of I

these were in the GL 89-10 Supplement 3 category. The inspectors verified that the safety-related MOVs in the HPCI, RCIC, and RWCU systems were properly included in i the program. Based on this review, the team concluded that MOVs within the scope of

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the MOV program at PBAPS are consistent with GL 89-10 recommendations.

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1 Design Basis Reviews Item "a" of the Generic Letter recommended that licensees review and document the design basis for the operation of each motor-operated valve in the program, including differential pressure, flow, line pressure, temperature, valve orientation, minimum voltage, etc.

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The licensee's methodology for conducting design basis reviews was documented in the

"NRC Generic Letter 89-10 MOV Program Description PBAPS & LGS," and Specification NE-119," Motor Operated Valves Thrust / Torque Determination Methodology." Design-basis reviews were completed and approved for all 178 MOVs included in the GL 89-10 program scope at PBAPS Units 2 and 3.

j Specification NE-119 directed a review of the UFSAR, technical specifications, normal, abnormal, and emergency operating procedures, and other plant documents to determine

worst-case design basis differential pressure conditions that each MOV could experience.

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The licensee applied the methodology prepared by the BWR Owners Group for design-basis reviews. For instances where the BWRs Owner's Group methodology could not be

, applied, the maximum differential pressure was determined by evaluating pump curves, pressure and head of supply tanks, static heads, etc. Relief valve setpoints were considered where appropriate and included allowances for setpoint bands.

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Specification NE-119 required that design parameters such as maximum differential pressure, and fluid temperature and flow rate be determined for valve operation. The inspectors reviewed several documents, including PM 612," Determination of Maximum Differential Pressure For Motor Operated Valves," and determined that design-basis parameters specified by Specification NE-119 guidelines and other necessary design-basis parameters were adequately addressed in design basis reviews for GL 89-10 MOV The licensee performed calculations to determine the minimum motor terminal voltage

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available for alternating and direct current MOVs. AC voltage calculations were documented in PE-111," Electrical Evaluation of AC Powered Motor Operated Valves in Response to NRC Generic Letter 89-10." DC voltage calculations were documented in EE-033 " Electrical Evaluation of DC Powered Motor Operated Valves." These studies determined MOV capabilities under expected worst-case voltage conditions by considering locked rotor current, the effects of ambient temperature on cables feeding MOVs, impedances of MOV power cables, and thermal overload resistance value During the review of EE-033, the inspectors found that using the standard Limitorque equation, MOV 3-23-020 did not meet minimum thrust requirements based on the licensee's calculated degraded voltage of 50% at the actuator motor terminal. The licensee used a generic 250V motor curve to determine the capability of this MOV, but did not appear to include the reduced voltage at the motor or other uncertainties associated with the use of the generic motor curves. The licensee provided sufficient

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justification that the 50% degraded voltage condition was acceptable for operability of

this MOV prior to startup of Unit 3. This was based upon test data obtained from two

! other nuclear power facilities. The inspectors found this disposition acceptable as an interim measure for startup of Unit 3. Ilowever, the inspectors identified sixteen other l

j MOVs with terminal voltages below 70% of rated motor voltage. The licensee was

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addressing this concern during the inspection, but this item will remain unresolved

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pending complete resolution and review of the degraded voltages for these MOVs (URI 50-277/92-82-02; 50-278/92-82-02).

l Thermal Overload (TOL) devices are used on MOVs at Peach Bottom as an alarm to l i

indicate that an actuator motor has experienced excessive heat induced by high curren !

l These devices consist of heater and temperature sensing elements and are located in the !'

motor control center as part of the motor reversing contractors. In addition to the alarm

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) function, some MOVs have TOLs in the circuit that deenergize the motor when excessive current is sensed. However, a safety injection signal bypasses the TOL on all t primary containment isolation valves. Other safety-related MOVs at Peach Bottom liave -

l the ability to bypass the TOL if an operator holds the valve control switch in the desired position. TOLs in MOP with " maintained contact" control circuits will not deenergize i the motor. These motors will alarm only on thermal overload. The TOLs were sized

and selected from licensee drawing no. E-2071, and series E-1600 and E-1700 print )

{ l i Elevated temperatures have a significant effect on the output torque of DC motors. The i

environmental conditions to which these motors and cables are subjected are considered

in the licensee's analysis. However, the effects of high temperature on the torque output i of AC motors have not been determined by the licensee to date. The Limitorque j Corporation is currently evaluating the torque output of actuators with AC motors at high temperatures and the licensee committed to incorporate information provided by i Limitorque into the MOV program regarding high temperature effects on AC motors as soon as it becomes available.

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Diagnostics Systems l

l The licensee uses the Valve Operation and Test Evaluation System (VOTES) diagnostic l equipment to set the torque switches and to perform diagnostic evaluations of MOVs in j the GL 89-10 program. The inspector determined that the licensee was implementing changes to its method of setting MOV switches from MOVATS to VOTES diagnostic j test equipment. The licensee stated their plans do not call for using the VOTES torque j cartridge (VTC) equipment routinely as part of the GL 89-10 program for torque

measurement. They only intend to use the VTC for troubleshooting MOV problems, i

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7 MOV Switch Settings and Setpoint Contro!

l Item "b" of Generic Letter 89-10 recommends that licensees review and revise as !

necessary, the methods used for selecting and setting all motor-operated valve switch setting Specification NE-119 provides the methodology for performing MOV sizing calculations and switch settings. The licensee used a computer program called "MIDACALC" to perform these calculations. Valve and actuator data and system operating parameters were used as inputs to the software program to produce calculated thrust and torque requirements. A separate calculation was used to validate the MIDACALC calculation results. All of the calculations were completed and approved for the 178 MOVs in the GL 89-10 program at Peach Botto Torque switching settings (TSSs) were controlled by the Motor Operated Valve Integrated Data Acquisition System (MIDAS). This database was separated into two parts, MIDAS "A" (controlled by NED), and MIDAS "B" (controlled by the site). The inspectors observed instances where both MIDAS databases were not always updated promptly when TSSs were changed during testing. Consequently, this databases did not reflect the required TSS for all GL 8910 MOVs and prompted inspectors to examine the licensee's disposition of nonconformance reports in detail as described in this report The licensee recognized the need to ensure that the entire MIDAS database is current and took measures during this inspection to ensure that it would be updated promptly as necessar The licensee used the Limitorque and standard industry thrust equations to determine the required thrust for gate and globe valves. NE-119 stated that valve factors of 0.30 for gate valves and 1.10 for globe valves would be used. NE-119 also provided the use of other valve factors in high pressure and temperature areas.

The licensee utilized an assumed value of 0.20 for the stem friction coefficient to convert

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the minimum required thrust to a required torque. A stem friction coefficient of 0.15 was used to ensure that maximum allowable thrust was not exceeded without adequately j justifying the basis for the selection of the stem friction coefficient. The licensee

acknowledged the need to develop provisions in their program to verify that the assumed stem friction coefficient bounds worst-case lubricant conditions for MOVs at Peach I Bottom and committed to incorporate program requirements as appropriat The licensee did not formalize a method to feedback differential pressure test results in

< a manner that would validate assumptions used in thrust equations. Further, no provision was made to evaluate test results for applicability to MOVs that are not

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practicable to test. The licensee committed to perform this evaluation as part of the GL j 89-10 program.

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The methodology for determining minimum and maximum thrust requirements was also defined in NE-119. Maximum thrust limitations were based on the lesser of the valve's or actuator's structural limits. Maximum allowed thrust was adjusted by subtracting a )

margin which accounted for instrument inaccuracies and torque switch repeatabilit '

These inaccuracies were combined using the " square root of the sum of the squares" method. Minimum required thrust was adjusted by adding a margin to account for instrument inaccuracies, torque switch repeatability and an Engineered Safety Factor (ESF). The ESF value was added to account for MOV load sensitive behavior and other uncertainties related to stem friction coefficient and valve facto Specification NE.119 also stated that torque switch repeatability for SMB-000 actuators is 5% for torque output greater than 50 ft-lb and 10% for torque output less than 50 ft lb. All other SMB actuators were assumed to have 5% repeatability. The licensee agreed to review NE-119 by the end of the first quarter of 1993 and to make it consistent with the Limitorque guidanc During the review of PM 658, " Design Thrust, Torque, and Torque Switch Setting Calculation for High Pressure Coolant Injection," and PM 655 " Design Thrust, Torque and Torque Switch Setting Calculation for Reactor Water Clean-Up," inspectors noted that some recorded as-left torque switch settings did not agree with the calculated value Inspectors reviewed the resolution of nonconformance reports (NCRs) to determine if these conditions were properly evaluated and resolve *

NCR PB 92-00001 addressed an as-found under-thrust condition and an as-left over-torque condition for MOV 312-015 (reactor water cleanup system inboard isolation valve), inspectors determined that the resolution of this NCR was inadequate for the following reasons: 1) The torque switch was set at approximately 116% of the actuator torque rating without an engineering evaluation as specified in Limitorque Maintenance Update 92-1 and a Jaly 26, 1990 Limitorque letter for actuators which experience greater than 110% of the actuator's torque rating; and 2) The licensee relied on a commercial actuator rating instead of the published nuclear actuator rating to disposition this NCR without an engineering evaluatio *

NCR PB 92-00111 addressed an over-thrust condition experienced by MOV 2-12-015. The inspectors considered the iesolution of this NCR to be inadequate for the following reasons: 1) De licensee considered 200% of the actuator's thrust rating acceptable based on a study by a contractor (Kalsi Engineering Co.)

on the capabiUty of MOV actuators to withstand thrust greater than Limitorque's published ratings. However,200% thrust exceeded the maximum thrust allowable specified by Limitorque (162%) for licensees that participated in the Kalsi stud The licensee did not perform an internal engineering evaluation when 162% of the actuator's ratad thrust was exceeded as specified by Limitorque; and 2) the NCR did not iduatify if the actuator torque rating was also exceede .--

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The licensee used the Kalsi Engineering study to resolve several over-thrust conditions between 140 162% without implementing the recommendations of that study. For example, Kalsi study recommended that licensees verify adequate strength of the motor pinion key, the actuator bolting, and the stem nut as minimum actions following over-thrust event * NCR PB 92-00582 evaluated an under-thrust condition in MOV 3-23-015 (high pressure coolant injection system steam supply inboard isolation valve) in the closing direction. However, the resolution of this NCR did not consider conditions of the Kalsi report when planning to raise the allowable thrus None of the NCRs listed above discussed root causes for over-torque, over-thrust, or under-thrust conditions for the MOVs. Inadequate dispositioning of these NCRs is contrary to NRC requirements and represent examples of potential violations of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions." (VIO 50-277/92-82-03; 50-278/92-82-03).

Generic Letter 89-10. Suontement 3 MOVs The results of recent NRC-sponsored MOV testing and a subsequent evaluation by the BWR Owners Group were distributed in Supplement 3 to GL 89-10 in October 199 The NRC staff determined that the correction of any deficiencies in MOVs in the HPCI, RCIC, and RWCU systems must be given a high priority in the implementation of the GL 89-10 program due to the higher safety significance of these MOVs in providing containment isolation following a high energy line break (HELB) in these systems, inspectors reviewed the licensee's response to Supplement 3, and their evaluation of the capability of MOVs within the scope of the Supplement. The licensee determined the design-basis conditions of Supplement 3 MOVs and performed capability determination Inspectors observed that the evaluations used non-conservative valve factors and other non-conservative assumptions. Upon identification of this concern, the licensee recalculated the performance capabilities of all Supplement 3 MOVs using an approximate valve factor of 0.4. As a result, five MOVs were determined to have less than adequate thrust to close under design-basis differential pressure and flow, and that their torque switch settings must be increased. The licensee declared MOVs 3-23-015 and 3-23-016 in Unit 3 inoperable on October 22,1992 and initiated action to adjust the torque switch settings. Unit 3 remained in cold shutdown until the licensee resolved their thrust calculation methodology and adjusted the torque switch settings for 3-23-015 and 3-23-016. Prior to the end of this inspection and before Unit 3 startup, the licensee adjusted the previous as-left thrust data for these valves in accordance with a 10 CFR 21 notification from the diagnostic equipment vendor. This resulted in as-left thrust values that were above the minimum required for these valves with a 0.4 valve facto .

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7 Consequently, the licensee retracted their previous determination that these valves were )

inoperable. The inspectors agreed with this conclusion. The licensee also committed

< that the Unit 2 valve thrust and torque switch settings would be resolved for MOVs

- 2-23-015,2-23-016, and 2-12-018 before start up of that unit.

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2.5 MOV Testing i

Action "c" of the Generic Letter recommended that licensees test MOVs in situ under their design-basis differential pressure and flow conditions. If in situ testing under those conditions is not practicable, the NRC recommends a two-stage approach for

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demonstrating MOV capability. With the two-stage approach, a licensee would evaluate the capability for the MOV using the best data available and develop applicable test i data within the schedule of the Generic Letter.

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Nuclear Engineering Specifications NE-145, " Selection of Generic Letter 89-10 Program i Valves and Differential Pressure Testable Valves," and NE-146, " Generic Letter 89-10

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Motor Operated Valve Testing " provide the licensee's positions regarding MOV testing.

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Except for their approach where all MOVs in a certain group might not be tested, the

. licensee stated that it was their intent, where practicable, to perform in situ design-basis j differential pressure (d/p) and flow testing for MOVs in the GL 89-10 program. For the

178 MOVs to be tested in accordance with GL 89-10, static baseline testing has been j completed for all MOVs, except for four Beck operators serving the butterfly valves for i the cooling tower reservoir supply to the emergency service water pump bays. The

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licensee had originally set MOV switches with MOVATS equipment but are currently

rebaselining all MOVs using VOTES diagnostic test equipment. Approximately 110 MOVs had been rebaselined with VOTES. The licensee has scheduled the remaining j MOVs in Units 2 and 3 to be tested with VOTES equipment by December 1992 and

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December 1993 respectively. Some limited dynamic testing had been attempted as of l this inspection date, but none of the results were accepted or credited for GL 89-10 l purposes. The licensee's schedule in the MOV program plan called for d/p testing of 48

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MOVs during the next 3 years as follows:

Um MOVs - during outage 2R09

16 MOVs - during non-outage time between 2R09 and 2R010

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5 MOVs - during outage 2R010 i Unit 3 4 MOVs - during outage 3R09 15 MOVs - during non-outage time between 3R09 and 3R010

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During a telephone conference with the Plant Predictive Maintenance Supervisor on January 4,1993, the licensee noted somc changes to this schedule. Testing of the eight Unit 2 MOVs scheduled for 2R09 was not accomplished due to the late arrival of diagnostic test instrumentation needed to support these tests. Therefore, testing of the eight Unit 2 MOVs was deferred and eight other Unit 3 MOVs will be added to the testing in outage 3R09 to maintain the total at 48 MOV Upon review of Specifications NE-145 and NE-146, inspectors noted the following:

i e Specific guidance was not included to provide the methodology for extrapolating partial d/p and flow data to design conditions. The licensee agreed to provide this guidance to support MOV testing. The inspector also noted that the licensee did not intend to do any multi-point testing at partial d/p conditions.

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• The requirements to be included in MOV test procedures for test data evaluation and acceptance criteda were unclear. The inspector noted that these requirements shou?d include a short term assessment of MOV operability and a long term assesnnent of all MOV test data per MOV program requirements, including the impact of the data on other similar MOVs. These assessments should reflect the licensee's Nuclear Engineering Department's concurrence. The licensee agreed to include this explicit acceptance criteria in the MOV test procedures and these assessments in the MOV program prior to the conduct of design-basis differential pressure testing,

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• In Specification NE-145, Appendix C, the licensee provided a list of MOVs with reasons why they are not practicable to test. The reasons given for not testing were somewhat broad. The inspector requested that specific engineering justification be provided for each of these MOVs. The licensee agreed to provide this justification by the end of the second quarter of 199 The inspector reviewed the licensee's recent experience with MOV diagnostic testin The licensee attempted to perform partial d/p and flow tests on several Unit 2 MOVs during the shutdown at the beginning of the current refueling outage. Special test procedures were developed to perform these tests on reactor water cleanup system isolation valm 2-12-015 and 2-12-018, main steam line system drain isolation valves 2-02-074 and 2-02-077 and reactor coolant isolation control system steam supply isolation valves 2-13-015 and 2-13-016. The valves cycled satisfactorily but the diagnostic test instrumentation did not operate properly to provide accurate data. As noted above, these MOVs were scheduled for their official GL 89-10 dynamic tests during the startup after the current Unit 2 refueling outage, but their dynamic tests have been deferre i

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12 I The inspectors determined that frequent over-thrusting conditions had occurred during MOV static testing in 1992. The licensee considered that these occurrences were due ,

primarily to the prior use of MOVATS equipment when setting the MOV torque j switches in the upper end of the thrust window. Upon further review of several MOV l static tests, the inspectors determined that the following MOVs had been over-thrusted !

beyond the vendor accepted increased actuator values given in Limitorque Technical Update 92-01:

MOV 2-13 027 = 210% and MOV 2-23-025 = 186%.

These values included an allowance for diagnostic equipment inaccuracy. The licensee's Nuclear Engineering Department (NED) dispositioned these problems by nonconformance reports (NCRs). On September 17,1992, NCR 92-00353 provided a )

final disposition for MOV 2-13-027.dich accepted the over-thrust condition based on:

(1) the lack of evidence of actuator degradation from the VOTES diagnostic traces; (2)

the actuator housing cover and base fasteners were torqued to the minimum specified levels; (3) internal inspection of the actuator for any damage and replacement in-kind of any necessary parts; and (4) use of Kalsi Engineering Report 1707C which allowed the {

use of increased actuator thrust values. However, the inspectors noted that the licensee took credit for increased actuator thrust values above 162% and up to 200% of actuator rating as specified by Limitorque (based on Kalsi Engineering Report 1707C) without implementing certain Limitorque recommendations. Specifically, the licensee had not discussed these over-thrust conditions with Limitorque and had not evaluated these MOVs for potential over-torque problems as recommended by Limitorque. This represents an additional example of inadequate corrective action which is a violation of NRC requirements given in 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions." (VIO 50-277/92-82-03; 50-278/92-82-03).

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e The inspector determined that other MOVs had been over-thrusted beyond their actuator ratings although these examples of over-thrust were not as high as those noted j above. The MOVs in this category with their applicable value of over-thrust were: 1 MOV 2-12-018 = 150%,

MOV 0-48-0501A = 151%, )

MOV 3-13-027 = 161%, and MOV 3-23 025 = 162%.

These over-thrust conditions were reported to the NED for disposition in accordance with the NCR proces- For example, on October 18,1992, the licensee provided a final disposition for the over-thrust condition in MOV 3-23-025. The licensee's basis for using the MOV as-is was: (1) use of Kalsi Engineering Report 1707C; and (2) torquing the

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actuator housing cover and base fasteners to minimum specified levels. However, the I inspectors noted that the licensee had not fully implemented the recommendations of E

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Limitorque Technical Update 92-01. The licensee had not directly discussed these over thrust conditions with Limitorque and had not evaluated these MOVs for potential over-torque problems as recommended by Limitorque. This is another example of inadequate corrective action which is a violation of NRC requirements given in 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions." (VIO 50-277/92-82-03; 50 278/92-82-03).

After the onsite inspection, inspectors met with licensee personnel at their nuclear engineering offices on November 2 and 6,1992, and with plant personnel at the site on November 3,19'92 to discuss various corrective actions being taken, including MOV overdbrust problems. Additional instances of MOV over-thrusting occurred after the team left the site on October 23,1992. For example, main steam drain valve 2-2-077 was j

tested on October 29,1992 and 'over-thrusted to 262% of its actuator rating. The licensee discussed their over-thrusting problems with Limitorque and developed specific inspection criteria which were used to disassemble and inspect this and other MOV Unit 3 MOV 3-23-025 was similarly disassembled and inspected and no deficiencies were apparent in either actuator. The inspector's review at the licensee's engineering offices on November 6,1992 concluded that the corrective actions were reasonable and responsive to the team's over-thrust concerns in preparing for the restart of Unit 3. At that time, the licensee was taking corrective actions at Unit 2 which was scheduled for

. restart later in 199 , MOV Maintenance and Post-Maintenance Testing The licensee refurbished all MOVs at Peach Bottom between 1987 and 1989 while both units were in an extended shutdown. The inspectors reviewed the Engineering Work Letter associated with Modification 2231," Supplemental MOV Testing," which described the scope of the refurbishment work performed on the MOVs. This modification was extensive. The initiative to refurbish the valves was very positive, in that all subsequent baseline diagnostic testing represented behavior of fully reconditioned valves and actuators. Although the licensee does not plan to refurbish MOVs on a periodic basis, they intend to evaluate the need for periodic refurbishments as test and operating data is acquired.

h The licensee has developed a series of procedures for performing preventive and corrective maintenance for MOVs. The inspectors found corrective and preventive maintenance procedures to be detailed and comprehensive in scope. The inspectors also reviewed Limitorque Maintenance Updates for 1988 through 1991 and verified for a sample of recommendations that the licensee had appropriately included them in the maintenance procedures. The licensee had not implemented all recommendations included in Limitorque Maintenance Update 92-1; however, the inspector verified that the licensee was tracking the evaluation of the issues identified in this Update through their Action Request system. The licensee committed to completing these reviews and any necessary actions by the end of the second quarter of 199 _ _ _ _ _ _ _ _

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Maintenance Procedure M-511.129,"Limitorque MOV Periodic Maintenance" provides instructions for performing preventive maintenance (PM) on Limitorque actuators. The procedure covers a general valve inspection that includes cleaning of the threaded portion of the valve stem and checking that the stem nut locknut is tight and properly staked or held in place using a set screw. Lubrication checks and functional tests are also included with a check of torque switch and limit switch settings. The inspector noted that the PM procedure does not include an activity to inspect for the presence of excess grease in the spring pack cavity. However, the licensec performed the spring pack modification prescribed by Limitorque to alleviate this condition. Also, the PM procedure does not include an inspection for possible spring pack relaxation. However, the licensee currently checks spring pack displacement during diagnostic testing. They also plan to purchase a spring pack testing system during the first quarter of 1993. This system will be used on newly purchased spring packs before installation and for troubleshooting spring pack problem The inspector reviewed maintenance guidance MG-25.2," Motor Operated Valve Preventive Maintenance," which provides the guidelines used to establish or adjust the PM frequencies for MOVs. The method for establishing PM frequencies utilizes weighted importance factors such as an MOV's safety function, its normal and accident environment, and its testing and operating history. The inspector reviewed the database that listed PM rankings and frequencies for all GL 89-10 MOVs. The licensee established PM frequencies for all GL 89-10 MOVs as follows:

48 MOVs - every refueling outage or two years 48 MOVs - every two refueling outages or four years 82 MOVs - every three refueling outages or six years Based on review of praedures M-511.129 and MG 25.2, and the PM database, the inspectors concluded that the PM program for MOVs was generally good. The inspectors found procedure M 511.129 to be detailed and implemented with acceptable results. However, inspectors identified some specific concerns as listed below:

• The PM database contained data that was not adequately verified for acceptability. Discrepancies in the PM database indicated that it may not have been verified for accuracy when first created. Examples included different values assigned to a valve's importance to operations for Unit 2 versus Unit 3. In addition, the licensee had not updated the database to incorporate operating history gained during testing in the past yea * Five valves located in a high temperature environment (e.g., the drywell or the outboard MSIV room) were assigned a four year frequency and not a two year frequency which is more appropriate for a hotter environmen l

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• In Maintenance Update 92-1, Limitorque recommended 18-month main gear box grease inspections and a 36-month limit switch gear box inspect'on until an operating history has been established. The inspection frequencies for several !

valves did not meet the Limitorque recommendations. The licensee used four or i l

six year intervals for such inspections without justifying the basis for selecting these intervals. The licensee stated that this justification would be provided in the l next revision to the PM progra l

• Maintenance Procedure M-511.129 allows the limit switch gear box lubricant inspection to be excluded if the PM is performed on motor operators while the reactor is at power or while the motor control unit is energized. In that case, the procedure requires checking for excessive leakage only. Limitorque recommends a 36 month inspection frequency for this lubricant, until operating experience indicates otherwise. For many GL 89-10 MOVs, the PM will be performed at power or with the motor control unit energized. For these MOVs, the licensee's FM program does not ensure that the geared limit switch lubricant will eventually be inspected when the reactor is shutdown. The licensee committed that the next revision to the PM program would contain provisions to address this concer The inspector also reviewed Procedure M-511.100, " Procedure for Determining MOV Post Maintenance Testing." The procedure contained a matrix for determining post maintenance test activities. For example, valve packing adjustments or replacement of the operator torque switch or spring pack, or performance of the PM requires a reverification of thrust value or a full diagnostic test. The inspector found this procedure to be conservative and adequate to ensure appropriate post maintenance testin Except for the inconsistencies in the PM intervals for some MOVs, the inspectors concluded that the overall scope of the MOV maintenance program with respect to GL 89-10 was good.

' Periodic Verification of MOV Capability In recommended action "d" of the Generic Letter, the NRC requested that licensees prepare or revise procedures to ensure that adequate MOV switch settings were determined and maintained throughout the life of the plant. In paragraph "j" of the Generic Letter, the NRC recommended that the surveillance interval be based on the safety importance of the MOV as well as its maintenance and performance history, but that the interval not exceed 5 years or 3 refueling outages. Further, the capability of the MOV will need to be reverified if the MOV is replaced, modified, or overhauled to the extent that the existing baseline test results would no longer represent its capability,

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16 In response to the Generic Letter on December 28,1989, PECo indicated that diagnostic testing was already in use to monitor valve performance after corrective maintenance and that predictive / preventative maintenance procedures would be revised to incorporate diagnostics to assure that correct switch settings are maintained. The GL 89-10 program document indicated that the preventative maintenance procedure upgrades had been complete Periodic reverification of MOV thrust, as currently planned by the licensee, includes only static testing. The licensee acknowledged that their own test results and industry test results did not yet provide adequate correlation between static and dynamic thrust verifications to allow PECo to rule out the need for future dynamic reverification of MOV capability. The licensee agreed that periodic dynamic verification may be necessary following completion of dynamic and static thrust test correlation studies. The licensee stated that the potential need for dynamic reverification will be evaluated in the futur .8 MOV Failures, Corrective Actions, and Trending Item "h" of the Generic Letter recommends 'nat licensees analyze each MOV failure and justify corrective actions. The results and hstory of each as-found deteriorated condition, malfunction, test, inspection, a .alysis, repair, or alteration were recommended to be documented and maintained. It was recommended that this information be periodically examined as part of the monitoring and feedback effort to establish trends of MOV operabilit The licensee's overall program for evaluating conditions adverse to quality and correcting deficiencies at Peach Bottom consists of several processes. The corrective action process is described in Administrative Procedure A-C-902," Corrective Action." This procedure described the hierarchy of processes used within the licensee's organization to evaluate and disposition conditions adverse to quality. Administrative procedure A-26," Plant Work Process" is used to identify deficiencies and nonconforming conditions and provides guidance for performance and documentation of work performed within the boundaries of the plant work process. Nonconforming conditions, identified as a

" deficiency in characteristic, documentation or procedure which renders the quality of hardware (material, system, structure or component) unacceptable or indeterminate," are evaluated and resolved via procedure A-C-901, " Control of Nonconformances." The licensee documents nonconforming conditions in Nonconformance Reports (NCRs).

Procedure A-C-901 requires assignment of a cause code to each NCR from a list of possible causes, however, no specific causal evaluation is required by the NCR proces Instead, Procedure NA-02A002, " Investigation of in-house Events" provides a process by which " consequential as well as inconsequential events having causal factors that could lead to consequential events" are reviewed, and that causal factors and appropriate corrective actions are identified. Reportability Evaluation / Event Investigation Forms (RE/EIF) provide the means to document this review. Finally, procedure LR-C-6,

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" Identification and evaluation of Potentially Reportable Items and Events of Potential Public Interest" states that the RE/EIF is the means by which conditions and events are evaluated to ensure that, if necessary, they are reported to the NR Following implementation of the Generic Letter testing with VOTES diagnostic equipment in 1991, the licensee identified numerous deficiencies and nonconformance These included conditions where MOVs were found in over-thrust or under-thrust conditions. During this inspection, the team reviewed the manner in which the licensee ,

resolved these deficiencies, including corrective actions, root cause analyses, and reportability evaluations. In addition, the team reviewed the licensee's trending program recommended by GL 89-10. The team's findings and conclusions in each of these areas are discussed belo . Corrective Actions The team found that for MOVs which were retested with VOTES and identified to be in an over-thrust condition, the licensee generally documented the condition with an NC However, the team identified two examples where the licensee failed to initiate an NCR when nonconforming conditions existed. The licensee found Unit 2 reactor water cleanup (RWCU) loop isolation valve 2-12-018 in an over-thrust condition at 286%

during VOTES baseline testing in March 1992. To resolve the deficiency, Maintenance Engineering conferred via telephone with NED and determined that the actuator needed to be replaced. The licensee appropriately documented the actuator replacement using an amendment to the original work order which had requested the VOTES testing. The licensee installed the new actuator and performed a VOTES diagnostic test. The as-left measured thrust for the replacement operator also exceeded the vendor's nominal thrust rating at 150% for that actuator. Evaluation of that condition was done via telephone between NED and site personnel, however neither the original nor as-left over-thrust conditions were documented or evaluated through the formal NCR process. As a result there was no documentation or evaluation that the original over-thrust condition did not exceed the rating of other related components (such as valve internals). Additionally, the basis for accepting the replacement actuator in the as left over-thrust condition was not establishe Another example involved the Unit 3 reactor core isolation cooling (RCIC) system minimum flow valve 3-13-027. On October 17,1991, the licensee performed VOTES testing on this MOV and left it in an over-thrust condition at 161%. However, the licensee did not identify the over-thrust condition in the work package and therefore did not initiate an NCR to document and evaluate the nonconforming condition. The licensee initiated NCR 92-00659 on October 26,1992 following the inspection team's identification of the issu .

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The inspectors also identified an example of untimely corrective action on the part of the licensee. During a surveillance test of the Unit 2 'B' residual heat removal system (RHR) on April 29,1992, the torus cooling loop injection valve 2-10-34B failed to function properly. The licensee generated NCR 92-00192 to evaluate the condition. The NCR was dispositioned to replace the actuator motor and spring pack and to perform VOTES testing. When licensee personnel attempted to perform testing, a surface crack -

was discovered in the valve yoke. The licensee initiated NCR 92-00190 and performed a weld repair of the crack. There was some discussion between the site and NED about immediate corrective actions needed in response to this issue. RE/EIF 2-92-159 was initiated by NED personnel on May 4,1992. A partial event investigation was performed and documented on June 19,1992. The need to perform an additional inspection of companion RHR valves (2-10-34A,3-10-34A and 3-10-34B) was identified in this investigation. However, no timely inspection was performed on other valve NED management did not review the initial investigation until August 3,1992, at which time it was forwarded to site personnel. On August 7,1992, the licensee inspected the three companion valves. Surface cracks were also found in the yoke of MOV 2-10-34A, but none were found in the corresponding Unit 3 valves. NCR 92-00358 was generated and a weld repair was performed on the valve yoke of MOV 2-10-34A. In addition, this valve was determined to be significantly over-thrusted in the as found_ condition. The team concluded that the excessive time for the licensee to inspect valve 2-10-34A subsequent to identifying cracks in the 34B valve was inappropriat The licensee's failure to properly document nonconforming over-thrust conditions for MOVs 2-12-018 and 3-13-27; and the untimely corrective action upon identifying cracks in MOV 2-10-34B represent further examples of inadequate corrective actions, and is a potential violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action."

(VIO 50-277/92-82-03; 50-278/92-82-03).

2. Root Cause Analysis The team evaluated the licensee's actions to address the root cause for the numerous

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as-found under-thrust and over-thrust conditions. An RE/EIF was initiated during an outage in January 1992 to evaluate an observed trend of as-found under-thrust test results. The evaluation addressed the results of 36 MOVs tested during the outag Some of the 36 valves were tested because preliminary findings from Idaho _ National Engineering Laboratory (INEL) indicated that MOVATS inaccuracies may be greater than previously expected. Consequently, the licensee scheduled retesting with VOTES equipment for MOVs with as-left thrust less than 20% above the design minimum valu As a result of the VOTES test results, many as-found under thrust conditions were identified. The licensee concluded that the primary cause of the under-thrust conditions was MOVATS equipment inaccuracies. The immediate corrective action was to increase priority for MOVs whose as-left thrust was less than 35% above the required

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minimum. The team considered this an appropriate root cause evaluation and corrective actio .

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As discussed in Section 2.8.1 above, the licensee identified numerous MOV over-thrust

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conditions since the implementation of VOTES testing in the fall of 1991. At the time of this inspection, the licensee had not initiated a root cause analysis for the over-thrust conditions. The licensee indicated they had noted the trend and expected to perform a more thorough root cause analysis following completion of an MOV program review

after the current Unit 2 refueling outage. The team found that the licensee was aware of

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the need to evaluate the over-thrust trend for generic root causes, howeser, the reviews i have not been initiated in a timely manner. Overall, the licensee did not aggressively evaluate generic trends for root causes.

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2.8.3 Reportability Evaluation

The licensee reported two events concerning MOVs to the NRC via the Emergency

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Notification System on October 5,1992. The first event was reported pursuant to 10 CFR 50.72, to report a condition in which the plant was outside of its design basis due to l

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the potential of not being able to isolate a high pressure coolant injection (HPCI) system steam line break. The licensee had determined that the ability of both the inboard and

outboard Unit 3 HPCI system steam line isolation valves 3 23-015 and 3-23-016 to close following a postulated high energy line break (HELB) was not assured. The decision to declare these valves inoperable was based on NED evaluations of the results of as-found VOTES testing performed in October and November 1991 which indicated the valves i were not achieving the required thrust. The torque switch settings were adjusted at that time to obtain the required thrust and the valves were declared operable. During the intervening months, NED completed their evaluation regarding operability of the valve A second event was reported pursuant to 10 CFR 50.72 following a condition that was

outside of the plant's design-basis. The licensee determined that both loops of the Unit 2 torus cooling mode of RHR may not have been able to provide containment cooling under certain design-basis events when cracks were found on the yokes of the torus l injection valves. This caused the torus RHR cooling mode to be inoperable under j certain conditions. These conditions were identified in April and August of 1992 as 1 discussed in Section 2. The team reviewed procedure LR-C-6 and the circumstances surrounding these events and discussed them with licensee personnel. The team concluded that the licensee had

met the requirements of 10 CFR 50.72 regarding reportability. However, the team found that the time the licensee took to evaluate these conditions was excessive, especially considering that they were noted by the NRC in January 1992 and approximately eleven months passed for the HPCI valves and two months for the torus cooling valves. The

licensee still took nine additional months to complete their analysis and reportability l review. The team found that the reason for the delay in evaluating the conditions was a

lack of understanding by licensee personnel of the plant's design-basis and of the need to evaluate the under-thrust conditions from an historical perspective.

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2.8.4 Trending l

l Procedure MG-25.2-1, "MOV Performance Evaluation and Trending," describes the

methods by which MOV performance and trending is accomplished. The maintenance j engineer reviews each work order package related to MOVs. The maintenance engineer is responsible for performing the results review and collecting the trending data

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1 identified on Attachment B (Data Evaluation / Trending form) to MG-25.2-1.

1 The team reviewed MG-25.2-1 and discussed it with licensee personnel. The licensee !

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had just developed MG-25.2-1 on September 30,1992. The licensee had not begun to use the guidance to trend MOV data and instead planned to begin in the near future, by j going back in time to retrieve information for all MOVs which had VOTES testing performed en them in the past year. To date, the licensee has used the other station

processes for trending as discussed in Section 2.8.2. The team concluded that the t licensee's program for trending as recommended by GL 89-10 was not fully developed.

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The licensee indicuted that trending data will be entered into the system beginning in early 1993 after the current refueling outage at Unit .9 Training of MOV Personnel

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The team reviewed the licensee's motor-operated valve training courses, training

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facilities, and training staff's qualifications. The licensee's training program is accredited

! by the Institute of Nuclear Power Operations (INPO). The program outlines specific I initial training requirements as well as continuing and ongoing training for various skill levels. The program includes both classroom and hands-on training. Maintenance on

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MOVs is perfonned by licensee electricians and mechanics who have completed the

one week motor-operator valve training course taught by a qualified contractor. At the i

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present time contract personnel are not used for maintenance work or testing of MOV components. The licensee does not have a formal documented training requirement for contractors for performing MOV maintenance. However, the licensee stated that previous training of contract personnel would be verified as adequate prior to allowing

these personnel to perform MOV maintenance at PBAPS. Also, the licensee does not a

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have refresher training program for site personnel performing maintenance on motor i operated valves.

Training on the Valve Operator Testing and Evaluation System (VOTES) diagnostic test cquipment was provided by Babcock and Wilcox in March of 1992. Eleven individuals

completed the course and became qualified to perform VOTES diagnostic testin Training was previously provided for Motor-Operated Valve Analysis and Test Systems

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(MOVATS). This training included an understanding of Limitorque MOV operation, equipment installation procedures, and techniques for identifying valve performance and

test results. Hands-on maimenance training is provided at the on-site training center at -

Peach Bottom and at the Barbados training center located off-site. The Barbados training facility provides initial and on-going training needs beyond the capability of the

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site. Quarterly interface meetings are conducted between the training departments and the plant to assess the effectiveness of the training provided and to address the training needs which are tracked and included in continuing training course plans. Team members toured the site training center and the off site training facility for MOVs. The training aids and motor-operated valve training facilities provide a good learning environment. lesson plans reviewed were comprehensive and provided sufficient detai The instructors were well qualified and knowledgeable. Effective communications and interface was apparent between the maintenance personnel responsible for MOVs and the me!ntenance, training organization. The team concluded overall that the licensee's training program is effectiv .10 industry Experience And Vendor Information The Operating Experience Assessment program (OEAP) Procedure No. LR C-4 describes the process of evaluating industry experience and vendor information. The type of information processed by OEAP includes INPO significant events and operating _

experiences, vendor notices,10 CFR 50, Part 21 reports, and licensee event reports. The Corporate Regulatory Group acts as the clearing house for this information. Within this licensing group, the OEAP coordinator receives the incoming information via correspondence control, the nuclear network, and from internal sources. Following an initial screening, the OEAP coordinator forwards the appropriate hard copies of the OEAP documents to site contacts as required. The site contact reviews the documents and then distributes the information to the appropriate plant staff with an action reques The Plant Information Management System (PIMs) management action request module is used to track the status of OEAP reviews. The General Manager - Nuclear Quality Assurance (NOA) maintains independent oversight by line management in response to OEAP issues. The implementation of this process was verified by reviewing a sampling of completed Action Requests. The Action Requests selected for review were adequately dispositioned with required evaluation and corrective action. Follow up and closecut of the OEAP item was in accordance with the established procedure .11 Program Schedule The licensee's schedule for implementing GL 89-10 activities is described in the

' Philadelphia Electric Company Generic Letter 8910 MOV Testing and Surveillance Program Plan," dated October 15, 1992. The plan for Peach Bottom activities describe schedules for static retesting of all GL 8910 MOVs and dynamic testing for selected GL 8910 valves. The test schedule calls for the remaining testing to be conducted as follows:

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. Unit. 2 Unit 3

.51atic: Complete by the end Complete by the end of November 1994 of November 1995 (Refueling outage 2R010) (Refueling outage 3R010)

Dynamic: Extends from November 1992 Extends from Fall of 1993 l through the end of through the end of November 1994 (Refueling November 1995 (Refueling outage 2R010) outage 3R010)

The team expressed concern that in light of the extensive dynamic test groupings proposed by the licensee, waiting until the fall of 1993 to start Unit 3 activities might jeopardize completion of testing within the GL 89-10 schedule. This concern was based

on the expectation that the test groupings devised by the licensee might not be justifiable once actual dynamic test results are reviewed and that the testing population might have to be expanded significantly. In response to this expressed concern, the licensee stated that the program plan schedule was a "first cut" schedule and was based on the proposed

test groupings. The licensee acknowledged that expansion of the test population was likely once actual dynamic test results were reviewed and evaluated. The licensee stated that they intended to begin dynamic testing of Unit 3 valves during the current Unit 3 operating cycle once they gained dynamic testing experience during scheduled Unit 2

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tests. The licensee stated that they intend to work aggressively ahead of the proyum plan schedul .0 WALKDOWN During a plant walkdown, the team observed the general overall condition of the MOVs to be good. In general, valve stems were well lubricated. No excessive grease leaks were noted. The following conditions were noted and provided to the licensee for resolution:

• MOV 2-13-34A thrust adapter contained a large casting defect. A PECo metallurgist examined the defect and determined that it did not penetrate the

adapter wall and that no cracks were prrpagating from the area. No further actions were necessar * Several MOVs had visible lubricant leaking from inspection ports and gasket The leakage was not excessive and was removed on a periodic basis as necessar * General external physical condition of MOVs was good.

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! 23 CONCLUSION

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j The licensee is developing an MOV program that is consistent with the recommendations of Generic Letter 8910 for completion by June 1994. Significant work

! has been completed on design basis reviews and static MOV testing. Personnel involved in the MOV program were knowledgeable, demonstrated good technical capabilities, and interfaced well with the departments involved in maintenance and operation of MOV '

Adequate management attention and oversight of the test program was lacking in the

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area of NCR resolution and MOV switch setpoint maintenance. The licensee has i

approached testing of MOVs by performing as found diagnostic testing, utilizing

, improved diagnostic techniques and equipment, and completing static testing for all

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valves in the program.

The violation indicates that the licensee's MOV program was not in accordance with the NRC requirements as given in 10 CFR 50, Appendix B for properly identifying,

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documenting, resolving, and reporting nonconforming conditions in a timely manne '

Several additional items were identified for further program enhancement as summarized

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in Table I. The licensee agreed to address all items as noted and committe .0 UNRESOLVED ITEMS i Unresolved items are matters for which more information is required to ascertain j whether they are acceptable items, violations or deviations. Two unresolved items are j discussed in paragraphs 2.0 and 2.1 of this report.

(Paragraph 2.0) The two-stage approach to MOVs which cannot be tested at full design basis conditions (d/p and flow) was not incorporated into the program.

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, (Paragraph 2.1) Seventeen MOVs had calculated degraded voltages less than 70% of the motor rating at the terminals of DC motors. Provide engineering justification for data on each MOV and assure motor will start under degraded

voltage condition .0 MANAGEMENT MEETINGS i

The inspectors met wi.th licensee management throughout the inspection as necessary to maintain communications on all developments and concerns. The inspectors met with

! those denoted in Attachment A on October 23,1992, to discuss the preliminary inspection findings as detailed in this report. - The results of the inspection were later discussed with the licensee in the Nuclear Engineering offices on November 2,4,6, and 18,1992. The final results were presented on November 30,1992 and the licensee acknowledged the inspection findings and agreed to review commitment items listed in Table I for resolution and further improvement of the GL 89-10 MOV program.

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Table I Licensee Plans and Commitments for Further GL 8910 Program improvements Generic Letter 89-10 Program An engineering justification for MOV families and test grouping was not provided to account for prior NRR comments to the program description. The licensee committed to provide specific information in the program plan to justify the grouping of MOVs into common families for design basis testing. This effort will commence after the present Unit 2 refueling outag .2 J2n!gn Basis Reviews Evaluate the effects of high temperatures on the torque output of AC motor incorporate the results of Limitorque's evaluations into the design basis reviews and calculations for AC motors at PBAPS. The licensee committed to incorporate the results of Limitorque's evaluations into the design basis calculations for AC motors as the information becomes availabl .4 MOV Switch Settings and Setpoint Controls Justify assumed valve factors and stem coefficients for all GL 89-10 MOVs through feedback from actual test results. Assure that assumed stem coefficients bound the worst case lubricant conditions. The licensee committed to incorporate plans for this process into the MOV program and to evaluate valve factors and stem coefficients as the information is obtained from testing. Appropriate factors will be obtained for all GL 89-10 MOVs by the scheduled completion of the progra Establish program provisions to evaluate test data for applicability to MOVs that are not practicable to test. Justify switch settings for all untested MOVs based upon test results from other MOVs. The licensee committed to enter written provisions in the program document by the end of the second quarter of 1993. When sufficient data is available,it will be applied to MOVs that are not practicable to tes Clarify Specification NE-119 to be consistent with Umitorque specifications on torque switch repeatability for SMB actuators. Any SMB set for less than 50 ft lbs has a torque switch repeatability of 10%. The licensee intends to revise this procedure no later than the end of the second quarter of 199 Resolve torque switch settings set too low for three Unit 2 MOVs prior to Unit 2 startup. Assure adequate thrust for 212-18,2-2315, and 2-23-16. The licensee committed to resolve this item prior to startup of Unit .

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Table 1 2

implement appropriate controls to assure timely update of MIDAS database '.B" The

licensee committed to implement positive controls for this update no later than the end l of the first quarter of 1993.

1 MOV Testing

Assure that explicit acceptance criteria are provided in the test packages for Supplement

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3 MOVs for design basis testing. Ensure that operability determinations appropriately

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reflect NED concurrence. The licensee committed to assuring that all appropriate j acceptance criteria and concurrences for MOV operability determinations will be i provided in each test procedure prior to the conduct of design-basis differential pressure

testing.

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l The current MOV program does not address a methodology for evaluation of results from partial d/p design basis testing. The two-stage approach to MOVs which cannot be

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tested at full design basis conditions (d/p and flow) is not incorporated into the progra The licensee committed to provide this methodology in the next GL 8910 program i

revision which will be issued by the end of the second quarter of 1993 and that it will address evaluation of partial d/p test results. Overall, partial d/p data will be incorporated into the design basis reviews as it becomes availabl .6 MOV Maintenance and Post Maintenance Testing i

! Incorporate plant and MOV operating history into the PM database used for setting PM frequencies for MOVs. The licensee committed to factoring this information into the j PM database during the next revision of the PM program which will be completed by the end of the second quarter of 1993.

Justify the PM frequency for MOVs in a high temperature environment (MOVs 2-10-18,

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2-23-21,2-23-19,3-2-74, and 3-13-21 located in the drywell and the outboard MSIV room

have longer frequencies than others in high temperature environments). The licensee

! stated that this justification will be provided in the next revision to the PM program by

- the end of the second quarter of 1993, i

l Justify the lubrication frequency for MOVs that don't match the Limitorque

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recommendations in their Maintenance Update 92-01. Justify longer frequencies based

upon operating and maintenance history, as appropriate. The licensee stated that this i justification will be provided in the next revision to the PM progra Assure that no MOV will go indefinitely without a lubricant inspection internal to the limit switch gear box. The licensee committed that the next revision to the PM program will make provisions to address this concern.

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Table 1 3

' Obpdc..YuifkmL af hiOV Canability

'le r cat w > m pefc.:n dynamic reverification testing if no adequate correlation w." c'c r v static and dynamic test results for GL 89-10 MOVs at PBAPS. The ikraf v: v, 'e Jged the potential need for dynamic reverification testing and agreed a ton'.. u,m aced if no adequate correlation can be obtaine .8 MOV Failures. Corrective Actions. and Trending The MOV trending program has recently been established by procedure MG 25.2- ;

The site Maintenance Department will commence full implementation of this program at the end of the current Unit 2 outage. Entry of MOV data into the trending program will begin by January 199 .11 Schedule The licensee intends to stay ahead of the current test schedule to accommodate any necessary expansion of the population of MOVs for design-basis testing. Schedule adjustments will be made to ensure that design-basis testing is completed by the scheduled program completion dat l,

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A'ITACilMENT A Persons Contacted Philadelohia Electric Company

• J. Austin, PBAPS Project Manager

• K. Carrabine, NED MOV Program Manager G. Cranston, NED Engineering Manager

• T. Donell, OS Superintendent

A. Dycus, ISEG Superintendent

D. Foss, PBAPS Regulatory Engineer

T. Geyer, PBAPS Predictive Maintenance Branch Head

• D. Groves, NED Mechanical Equipment Branch IIcad

• R. Hauser, PBAPS MOV Coordinator

• D. Miller, PBAPS Vice President

T. Niessen, PBAPS Operations Superintendent

K. Powers, PBAPS Plant Manager

A. Raush, NED G/C Engineer

• R. Reitmeyer, NED Site Engineering Branch Head

• R. Smith, PBAPS Regulatory Engineer -

H. Vollmer, NED Civil and Mechanical Plant Section Manager U.S. Nuclear Regulatory Commission (USNRC)

P. Bonnet, Resident inspector, PBAPS -

C. Anderson, Chief, Reactor Projects Section 2B, Region 1

J. Durr, Chief, Engineering Branch, Region I

P. Eapen, Chief, Systems Section, Region I M. Hodges, Director, Division of Reactor Stifety, Region I

A. Lohmeier, Sr. Reactor Engineer, Region I

J. Lyash, Senior Resident Inspector, PBAPS E. Sulhvan, emet, EMEB, NRR E. Wenzinger, Chief, Reactor Projects Branch 2, Region I Other

M. Allen, SWEC Engineer

• - S. Maingi,-Pennsylvania Bureau of Radiation Protection

• T. Neckowicz, UE&C Engineer

P. Ott, PSE&G Site Representative

Denotes attendance at the preliminary exit meeting held at Peach Bottom Atomic Power Station, October 23,199 l