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Safety Insp Repts 50-254/89-13 & 50-265/89-13 on 890522-0608.No Violations,Deviations or Open Items Noted. Major Areas Inspected:Maint & Inservice Testing of Pumps & Valves,Including Actions in Response to NRC Bulletin 85-003
	ML20246C347
Person / Time
Site:	Quad Cities
Issue date:	06/29/1989
From:	Danielson D, Huber M, James Smith; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20246C344	List: ML20246C341; ML20246C347;
References
	50-254-89-13, 50-265-89-13, IEB-85-003, IEB-85-3, NUDOCS 8907100326
	Download: ML20246C347 (13)
	v • d • e

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-254/89013(DRS); 50-265/89013(DRS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30

Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name: Quad Cities Station - Units 1 and 2

Inspection At: Quad Cities Site, Cordova, IL 61241

Inspection Conducted: ay 22, 1989 through June 8, 1989 ,

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Inspectors: J. . Smit 4 2 Ae9

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Approved By: D. H.

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anielson, Chief Mar

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Materials and Processes Date

Section

Inspection Summary

Inspection on May 22, 1989, through June 8, 1989 (Reports No. 50-254/89013(DRS);

ED-265/89013(DRS))

Areas Inspected: Routine announced safety inspection of maintenance and

inservice testing of pumps and valves. The areas covered included actions

taken in response to NRC Bulletin 85-03 (25573) and implementation of inservice

testing (IST) (73756) including administrative and technical procedures,

l performance of testing, retention of records, and recording of trends.

Results: Within the areas inspected, no violations, deviations or open items

were identified. During the course of the inspection, the following was noted:

Within the areas inspected, the implementation of IST follows the

requirements of Section XI r.nd the licensee's program.

The licensee committed to adopt the more conservative philosophy of l

declaring pumps and valves inoperable as soon as they are recognized to '

be outside of IST acceptance criteria instead of using the ASME

Section XI allowances of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay for valves and 96 nours for

pumps.

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. Based on the areas reviewed, the licensee appears to have a competent

staff which has generated an effective set of procedures for pump and

valve testing activities. The procedures are followed during the job,

performance is documented, and records are properly analyzed, trended,

and stored.

The licensee's use of velocity measurement and analysis techniques to

assess pump condition is more effective than the displacement method

required by the Code.

Actions taken to address IEB 85-03 were very good, although the program

is not yet complete.

The licensee's own QA audits provided good feedback to the 15T coordinator.

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DETAILS

1. Persons Contacted

Commonwealth Edison Company (CECO)

R. Robey, Technical Superintendent

J. Dierbeck, Technical Staff Supervisor

J. W. Wethington, Quality Assurance Superintendent

J. D. Pacilio, Technical Staff Engineer

R. Korneta, Technical Staff Engineer

G. E. Knapp, Inservice Testing Coordinator

T. Barber, Regulatory Assurance

NUTECH

^J. M. Clauss, Staff Consultant

Nuclear Regulatory Commission (NRC)

R. Higgins, Senior Resident Inspector

Denotes those present at the Exit Meeting on June 8, 1989.

Other members of the plant staff were also contacted as a matter of <

routine during the course of the inspection. !

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2. Pump and Valve IST Program Implementation (73756)

The licensee's second 10 year program for both units was written to comply

with the rules and regulations of 10 CFR 50.55a and Section XI of the ASME i

Boiler and Pressure Vessel Code,1980 Edition including the addenda ;

through Winter 1980. The program was submitted to the NRC but the review I

of the program was not completed when Generic Letter (GL) 89-04 was

issued. The GL identified those plants for which an SER was issued or

would be issued shortly. The Quad Cities Station was not included in the

plants in either list. As a result, the licensee is among those whose

currently submitted IST program relief requests were conditionally approved

in GL 89-04.

The licensee is in the process of revising their IST program to conform

to the requirements of GL 89-04. The inspection was conducted to assess

the licensee's implementation of the inservice testing program and to

assess the adequacy of the process by which the program transition to

the GL 89-04 requirements is being made.

a. Administrative Controls of IST

The NRC inspector confirmed that administrative controls were in ^

place to satisfy the requirements of the IST program and that

specific IST duties had been assigned to personnel. The NRC

inspector reviewed the following IST procedures:

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Quad Administrative Procedure (QAP) 350-1, Revision 9, dated j

June 1988, " Inservice Testing Program Standard Pump Testing i

Methods" !

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QAP 350-2, Revision 8, dated March 1987, " Inservice Testing i

Program Standard Valve Testing Methods"

b. Establishing Component Inopernoi h' y j

Position 8 of Attachment 1 to GL 89-04 (Guidance on Developing

Acceptable Inservice Testing Programs) indicated that a pump or 1

valve shall be declared inoperable as soon as the data is recognized

to be outside of the IST acceptance criteria. The NRC inspectors

found that the licensee's surveillance procedures generically !

conformed to the less conservative responses permitted by the ASME

Boiler and Pressure Vessel Code,Section XI. The Code allows !

deferring the declaration of inoperability of valves for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months j

(IWV-3417) after recognizing the problem. Although IWP-3230

requires that pumps with test data deviations which fall within the

Required Action Range be declared inoperable immediately, the effect

of this guidance is vitiated by IWP-3220, which permits a delay of

an to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months in analyzing the data after completing the test.

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As indicated in GL 89-04, Position 8:

When the data is determined to be within the Required Action

Range of Table IWP-3100-2 the pump is inoperable and the

Technical Specification (TS) ACTION statement time starts.

The provisions in IWP-3230(d) to recalibrates the instruments

involved and rerun the test to show the pump is still capable of

fulfilling its function are an alternative to replace or repair,

not an additional action that can be taken before declaring the

pump inoperable.

l * The above position, which has been stated in terms of pump

testing, is equally valid for valve testing.

In summary, it is the staff's position that as soon as the data

is recognized as being within the Required Action Range for

i pumps or exceeding the limiting value of full-stroke time for

I valves, the associated component must be declared inoperable

and the TS ACTION time must be started.

l The requirements of the Generic Letter are directly applicable to

the licensee's program; the licensee agreed to conform to the

requirements of GL 89-04, Position 8.

c. Pump Program Implementation

The licensee's pump IST program implementation was inspected to

verify compliance with Appendix B of 10 CFR 50; 10 CFR 50.55a(g);

and subsection IWP of Section XI of the ASME Code (1980 Edition with

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addenda through Winter 1980). The inspection included a review of

administrative controls, selected surveillance procedures, test

results and documentation.

(1) Program / Relief Requests l

The NRC inspector reviewed the licensee's procedure governing

the conduct of IST, including associated relief requests.

As previously discussed in Paragraph 2, the licensee's program

had been approved, subject to conditions, in GL 39-04. The NRC

inspector reviewed the licensee's relief requests to determine

the extent to which the licensee was in compliance with GL 89-04.

The following items were noted:

Relief Request No. PR-2 was to be implemented by the

licensee when a pump was tested and the results fell into

the " Required Action Range." It was the intent to use

this result to allow relief from declaring the pump

inoperable if further analysis showed that pump

operability was not impaired and Technical Specification

requirements for the pump performance were met.

This relief request contradicts the intent of GL 89-04.

The licensee informed the inspector that Relief Request

PR-2 was not implencted previously, and would be

withdrawn from the procam.

The method used by the licensee to analyze pump vibration

indications was by vibration velocity analysis. This

technique is generally a more comprehensive analysis

of the pump condition than conventional analysis using

displacement measurements.

(2) Completed Surveillance Review

The NRC inspector reviewed several procedures and completed

surveillance to further evaluate the licensee's program

implementation adequacy and effectiveness.

The following surveillance packages were reviewed:

Quad Operating Surveillance (QOS) 6600-6, " Diesel

Generator Cooling Water Pump Flow Rate Test - Operations

- Every 90 days," performed March 7, 1988 and September 7,

1988 for pump 2-3903 and performed on December 30, 1988

and February 14, 1989 for pump 1-3903.

QOS 2300-51, "HPCI Inservice Testing Data Sheet,"

performed on December 7, 1988 and March 3, 1989.

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The respective reference values for the pumps were recorded )

on QAP 350-51, " Inservice Testing Program Pump Reference

Value - Data Sheet," prior to performance of a test. The work

was then issued to operations personnel for conduct of the I

surveillance. The IST coordinator maintained the controlled '

copy, and a copy was on file in the Control Room for use by

the Shift Control Room Engineer in evaluating the completed

surveillance to determine pump operability status. {

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The NRC inspector verified that the acceptance criteria for

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the allowable range of test parameters were adequate and all u

surveillance data was within acceptable levels. )

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Regarding Q05 2300-51 completed on March 3, 1989, the licensee

did not review the pump data until seven hours following ,

performance of the test. The pump was operable. The delay in '

analysis was consistent with the licensee's less conservative

policy of making op9rability determinations in conformance with

the response per W ted by the Code. Future operability

determinations will be made in a more conservative manner as

stated 4 Paragraph 2.b. No other problems were noted.

(3) Test Observation

The NRC inspector witnessed the performance of QOS 6600-5,

" Diesel Generator Fuel Oil Transfer Pump Flow Rate Testing

- Operations - Every 90 days." The licensee used operations

personnel to perform all aspects of the testing except for

obtaining the pump vibration measurement. Vibration data was

obtained using calibrated equipment and the points used for {

measurement were clearly marked on the pump. Reference (

differential pressure was established in accordance with the

Code to adequately assess the pump condition.

The work was done in a professional manner and the operations

staff was knowledgeable. No problems were noted.

d. Valve Program Implementation

(1) Valve Position Indication Verification

The NRC inspector confirmed that valves with remote position

indicators were observed at least once every two years to

verify that valve operation is accurately indicated.

In addition to the lights on the control panel, there are two

other groups of lights. The first is a position indicating

light at a pistol grip control on the motor control center. One

set of these lights is provided for each unit. Each set of

these lights is tested in the same way, at the same time as the

control panel lights are tested. The second group consists of )

position indicating lights at a number of local controls which

are provided for maintenance work during shutdowns. These

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controls are locked out of service during plant operation. These

position indicating lights are not periodically checked for

accuracy of position indication because they are not used for

controlling the plant while it is in operation. These lights ;

are checked whenever changes are made in a system which might )

affect the accuracy of their indication. They are connected to i

the light' indicating conductors at the motor control center,

rather than at the motor operated valve, so they are less

susceptible to damage than they might be if connected at the {

motor operated valve. These installations are considered *

obsolescent by Quad Cities management and are gradually being

phased out. The replacement equipment will not include

position indicating lights.

The subject of remote position indication lights is currently

undergoing evaluation by NRC as a result of inquiries to ASME

by another licensee. Pending the result of that evaluation,

the NRC inspector considers the course proposed by the licensee

'to be adequate to assure continued accuracy of the remote

position indicating lights.

(2) Testable Check Valves

Testable check valves employ a number of different devices for

disk operation and for confirming the activation and deactivation

of the operator. Some testable check valves are fully operated

by the test mechanism and have position indicating lights

activated by the disk position to confirm the action.

When activated, the operator swings the disk free of the seat.

Ideally, the disk would be fully open and an "open" signal would

be generated. 'When the disk returns to the seat, a " closed"

signal would appear. The testable check valve operator opens

the valve, but does not close it. When the operator is in the

" closed" position, the disk is free of mechanical encumbrance

and its position is dictated by the fluid in the system. In

this ideal case, the position indicating lights still show if

the disk is open, closed or inbetween. However, there are a

number of other testable check valve designs available which

act quite differently. For example, when fully operated, the

actuators in some valves only open the valve 10% of its stroke.

When the positio.-indicating lights of such a valve are located

on the operator instead of on the valve disk, a full stroke test

of the operator would show an "open" signal at the end of the

actuator stroke, but the disk might be only 10% open.

The Standard Valve Testing Methods of QAP 350-2, Rev 8, dated

March 1987, Part 2.a(1) indicates " Valve operability to full

stroke will Se verified by stroking the valve to full open with

the test operator and verifying the valves return to the closed

position." Obviously, if the operator will only open the valve

a short distance, it cannot stroke the valve full open.

Additionally, if the position indicating light switches are on

the operator, the closure of the operator cannot guarantee the

closure of the valve.

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In order'to determine if there were.any undesirable design.

characteristics in the' plant's valves, the available drawings i

of. testable check valves in the plant were checked _byothe

licensee and the inspector. _One manufacturer (Atwood Morrill)

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used a pneumatic operator to rotate the disk shaft and located.

the-position indication. lights on the-operator. This design has

a high probability of providing_less than full stroke exercising

and its_ lights show operator position instead of disk position.

A second manufacturer (Rockwell) provided a pneumatic operator

to rotate the disk shaft and the position indicating switches

.were operated by a cam on the opposite end of the disk shaft..

(The shaft os. the cam end is solidly connected.to the disk; the

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shaft on the operator end is linked to the disk so that it can

open, but it carmot close the disk). If properly adjusted,

these switches wi?1 accurately identify the position of the

disk. But they are adjustable and their proper' adjustment,shoulo

on this information. The drawings

be confirmed

for the before relying (Schutte-Korting) were not.available

third manufacturer

at the time of the inspection.

Prior to planning and submitting an IST program conforming to

GL 89-04, the licensee must either confirm the validity of using

the testable check valve operator'to full stroke exercise the check-

valves or.use another methed such as full flow testing. Before

position indicating lights can be used to show disk position, the

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(This cannot be done on the Atwood-Morril valves because, as

previously indicated, the lights show operator positicn rather than

disk position.)

(4) Charging Water Check Valves

A problem was observed at another BWR with charging water check

valves in the control rod drive (CRD) system. In the original

problem Stellite #6 balls were found missing or degraded in

the check valves. The licensee was familiar with that problem

and had taken preventive measures to preclude a similar

occurrence at Quad Cities Station. The licensee's method for

testing the valves appeared to be capable of accurately

reflecting the desired characteristics. The control rod drive

pump was tripped and the time for the accumulator pressure of

each hydraulic control unit to drop to the point of alarm was

recorded. The original tests were intended to show missing

or severely degraded balls so the acceptanct criterion of a

ten minute interval from tripping of pumps to an alarm was

quite conservative.

The inspector concluded that the test prescribed for the CRD

system was acceptable and that the results confirmed the

integrity'of the charging water check valves.

No violations or deviations were identified.

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3. Licensee' Action on'IE Bulletin

(0 pen) TI 2515/73 and IE Bulletin -(IEB) 85-03 and Supplement 1 to

IEB 83-03 (254/85003-G8; 50-265/85003-8B): Motor-Operated Valve (MOV)

Common Mode Failure During Plant Transients Due to Improper Switch

Settings.

Action Item a of the bulletin requests a review and documentation of the

design basis for the operation of esch valve addressed, including an

evaluation of limiting differential pressure conditions; Action Items b

through d require actions to assure that the MOV switch settings are set,

tested, and maintained properly; and Action Item e requires a 180 day

report of the results of Action Item a and a program to accomplish Action

Items b through d.

Supplement 1 to IEB 85-03 was issued to clarify misunderstandings in

IEB 85-03 and to clarify which valves are required to be included in

the scope of the bulletin program.

a. Program Scope

During review of the valves identified by the licensee that would be

included in the program scope, the NRC inspectors found that most of <

the valves in the RCIC' system, pump suction and discharge valves for

example, were not included in the scope of the IEB 85-03 program.

The licensee stated that RCIC is not a safety system and not a Code

classed system and therefore does not warrant inclusion into their

IEB 85-03 program.

The NRC inspector questioned the justification for this omission in

that the BWR Owners Group (BWROG) Report Methodology NEDC-31322 as

amended by Supplement i was to be used by the memt utilities as a

basis for the selection of IEB 85-03 valves and inciuded the RCIC

system.

Additionally, although the RCIC system is not " Safety-Related,"

it is important to safety, as indicated by Technical Specification

requirements for operability. NRC Headquarters is currently

reviewing the licensee's IEB 85-03 program and plans to issue

a Request for Additional Information. This bulletin will remain

open pending further review by both NRC and the licensee.

b. Switch Setting Evaluation

Below is a discussion of the switches involved and concerns for l

their proper sttting, typical setting approaches that have been 1

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taken in the industry, and either the resolution adopted at the

Quad Cities plant or an identification of the need for additional

information or other action. The switches discussed are as follows:

Thermal overload relay

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, Open. torque switch

Close torque switch

Geared limit switen

Open limit

Open indication

Open torque switch bypass

Close limit

Close indication

Close torque switch bypass

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(1) Thermal Overload Relay

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Discussion: Thermal overloads are sometimes used to protect

motor winding insulation from breakdown. Devices used consist

of heaters at the motor control center which trip a heat

sensitive relay, the contacts of which either interrupt current

to the contactor closure coil (which stops the motor) or

initiate an overload alarm, or both. Where thermal overload

relays stop operator motor rotation on tripping, the heaters

must either be sized to prevent inadvert' 41y stopping the

motor, or bypassed when motor operation is important to safety.

Site Specifics: Thermal overload switches used on MOV's at

Quad Cities do not utilize bypass features and will always trip

the motor on overloads. The licensee uses their corporate Design

Guide No. 26, which incorporates the philosophy of using locked

rotor currant as the basis for determining overload sizes.

This philosophy needs further detailed review by the NRC

inspectors to determine if this approach meets the intent of

Regulatory Guide 1.106, " Thermal Overload Protection for

Electric Motors on Motor-0perated Valves (MOV)." This review

will be corJucted during the future inspection needed to close

the bulletin. ,

(2) Open Torque Switch

Discussion: This switch is normally used as a mechanical fuse

to limit the mechanical thrust applied to a valve or operator

when stroking the valve in the open direction. It generally

provides no normal control function and is a backup for some

other failure that may require its need. If the switch is used,

it must be set properly to enable the valve operator to apply

adequate thrust on the valve stem to operate the valve againJ.

the limiting differential pressure (dp).

Site Specifics: The open torque switch at Quad Cities is wired

into the circuit for the valves, but is bypassed for nc less

than 20% of valve stroke. This setting accounts for the

unseating of the valve and highest demand portion with respect

to thrust requirements.

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Following the bypassed portion of the stroke, the torque switch l

is part of the circuit. The torque switch settings for the i

valves were set using MOVATS Inc. equipment to meet the

calculated thrust requirements.

The NRC inspector reviewed completed work packages and found

that the as-left configurations were in accordance with the

licensee's program.

(3) Close Torque Switch

Discussion: The close torque switch is normally used to stop

motor rotation on the completion of valve travel in the close

direction. The limiting requirement for closure is at the end

of travel when the thrust requirements are highest. The thrust

at torque switch trip should equal the most limiting closure

thrust requirement including the thrust needed to overcome the

dp across the valve.

Site Specifics: The bulletin valves at Quad Cities close with

the close torque switch limiting torque for essentially the

entire valve stroke. Settings were provided to Quad Cities and

MOVATS Inc. equipment was used to ensure that the valves were

set to provide adequate margin for the required closure thrust.

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No problems were noted.

(4) Open Limit Switch

Discussion: This switch provides the control function of

determining'the upper limit of valve stem trsvel in the open

direction and stops motor rotation by opening the circuit to

the associated motor contactor coil. The setting of this

switch must provide an adequate valve stroke'but, normally,

must prevent backseating. Deliberate backseating using the

power of the motor-operator, or motor inertia, can and has

caused valve stem shearing, stem thread twisting, and valve

bonnet metal working until stem scoring and packing blowout

occur. Hence, it is important to set the open limit switch

away from the backseat and with enough margin to allow for

motor contactor dropout time and inertia.

Sites Specifics: The valves at Quad Cities "open on limit" with

the use of the open limit switch stopping the motor before the

valve backseats.

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The open limit switch setting is verified manually and checks

for backseating were done during the work performed by MOVATS.

The licensee utilizes QEMP 600-1, " Electrical Maintenance of

Safety-Related and Non-Safety-Related M0V'S," for setting the

switch. Verification of proper switch setting and manual

backseating checks are incorporated in the procedure.

No problems were noted.

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(5) Open Indication i

Discussio_n: Ci vr. indication is usually identified by the

presence of a red light that goes out only when the valve

is fully closed. Of N the same rotor is used for the open

torque switch bypass, which may cause problems because of

conflicting requirements for the two functions.

In setting for ideal position indication, there is not

adequate bypass of the torque switch to assure valve

operability; conversely, changes to satisfy the bypass

requirements have resulted in false valve position

indication.

Site Specifics: Quad Cities derives signals for both the open

indication and open torque switch bypass from the same rotor.

Since the torque switch bypass is set at the point (greater ;

than 20% of valve stroke) where unseating loads have subsided,

the rotor operates at.a distance from the point of complete

valve closure. As a result, as the valve is closed the switch

operates to provide a closed indication before the valve is

completely seated. The licensee indicated that all IEd 85-03

valves have a motor contactor seal-in feature which ensures

complete valve seating, once the closure cycle is initiated.

Replacement of the two rotor limit switches with four rotor

limit switches would eliminate the conflicting requirements for

the same switch. This course of action has not been fully

reviewed by the licensee, and additional review needs to be

conducted to fully a6 dress the anomaly. The NRC inspector

verified that all open indications were set in accordance with

the licensee's program. Besides the anomaly discussed above,

no problems were noted.

(6) Open Torque Switch Bypass

Discussion: When an open torque switch is used, the bypass

switch is required to function during the initial portion of

the open stroke so that the torque switch will not prematurely

stop valve travel due to the high torque conditions required

for initial valve movement. There is no clear answer on where

co. set the bypass; but, if the valve disk (not the stem) has

moved between 10% and 20% of its total travel distance away

from the seat when the bypass opens, this has been accepted

as adequate.

Site Specifics: The valves at Quad Cities have the torque

switch bypass set to prevent the actuation of the open torque

switch during the initial high demand at valve unseating. All

valves set with the diagnostic equipment have been verified to

have the open torque switch bypass set at 20% of valve stroke.

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(7) Close Limit

Discussion: The close limit switch is not often used on rising

stem valves. When it is utilized, it is usually related to a

special' application and takes the place of the close torque

switch by opening the motor circuit at the end of valve closure.

Site Specifics: None of the bulletin valves at Quad Cities

are wired to "close on limit." The circuit is opened for the

valves, stopping the motor in all cases by actuation of the

close torque switch.

(8) Close Indication

Discussion: Close indication is usually identified by the

presence of a light that goes out only when the valve is fully

open. This function is usually derived off the same mtor as

the open limit switch, and while concern exists for t b setting

of. the open limit, no problem has been identified wit' the

corresponding closed indication light switch.

Site Specifics: There was no concern for this switch setting

based on a review of valve schematic diagrams and discussions

with the licensee. Quad Cities has set the switch based on

the open limit switch requirements.

(9) Close Torque Switch Bypass

Discussion: The close torque switch bypass acts in the same

manner as the open torque switch bypass; however, contrary to

its counterpart function, it normally bypasses the torque

switch during the lightest duty portion of the stroke. If

ut'lized, it should be set to operate during the initial part

of ?.he stroke.

Site Specifics: The close torque switch bypass is on the same

rotor as the open limit which opens early in travel. The

licensee used no close torque switch bypass, and since the

valves were properly guarded against backseating, there was

no concern identified with respect to this switch setting.

Final closure of IEB 85-03 at Quad Cities will require further

inspection following program approval. Other considerations that

were discussed with the licensee but need to be addressed further by

) the NRC, licensee, or both, include equipment operation under low

voltage conditions and long term operability.

4. Exit Meeting

The inspectors met with licensee representatives (denoted in Paragraph 1)

on June 8, 1989, to discuss the scope and findings of the inspection.

In addition, 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. The licensee did not

identify any such documents or processes as proprietary.

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