ML20248D615
| ML20248D615 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/28/1989 |
| From: | Anderson C, Thomas Koshy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248D581 | List: |
| References | |
| 50-277-89-04, 50-277-89-4, 50-278-89-04, 50-278-89-4, NUDOCS 8904110520 | |
| Download: ML20248D615 (15) | |
See also: IR 05000277/1989004
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report Nos. 50-277/89-04
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50-278/89-04
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Docket Nos.
50-277
50-278
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License Nos. DPR-44
OPR-56
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Licensee: Phila.dejyhia Electric Cogany
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Correspondence Control Desk
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9. O. Box ?523
Phi,ladelpfhiadm sy'vania _ 19101-
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facility Name:
Peech 80ttom Atomic Pcwr Station Units d3
Inspection At: Delu , Penns,v1vank
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Inspect on Cor.docted: Jaruary 9-14, 1989
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- 3 23-80
lespectors:
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T. Koshy, fr. R_eactor Engineer
Approved by:
3 26-ES
Fa.,C. J. Anders'on, Chiet, Plant Sy aems Section
date
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In spe ction_Sennary:
Special announced inspection to review the licens9e's
actions in response to ao NRC letter to PECo regarding allegations on motor
operated valve refurbishment.
This inspection also reviee:d licentee ac+. ions
that vescited from IE Bul'et!n M-03 that addresses limit swKch and torque
switch settingr in eotor operated valyss,
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Results:
The inotor operated valvo allegations could not be substantiated. The
Ticensee had instituted an elaborate valve refurbishment program
to rebuild all vf the critical rnotor operateri valves.
This activity encompassed
.all of the safety relaud and some of the balance of platt valves.
This pr5 gram
addressed the concerns icientified by the allegation.
lhe licensee appropriately -addressed the requirements of the. IE BMletin 05-03.
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The coi-rective actient were properly coordinated by engineering with plant
maintenance.
8904110$20 GyO329
P Di<
ADOCK 05000777
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DETAILS
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LO Persons A ntacted
1.1 Phnadelobia Electric Compa,ny (PEco)
T. E. Cribbe, Regulatory Engineer
B. Curry, Design and Field E.igineer
- 0. K. Davenport, I&C Maintenance
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J. Franz, Plant Manager
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G. J, Hanson, Regulatory Engineer
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J. Lengyel. Maintenance Engineer
- S. McCarty, Supervisor health Physics
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- T. Neckowicz, Nuclear Engineer
J. M. Pratt, Manager, Qcality
D. M., Smith, Vice President
1.2
U.S. Nur. lear. Regulatory Commission (NRC)
- J. Cadzala,Peactor Engineei-
- T. P. Johnscn, Seher Resident Inspector
R. J. Urban, Resident Enspector
- Not present at the exit meeting on January 14, 1989.
2.0 Purpose
The purpose of this inspection was to review licensee actions in response
to an NRC letter to PECo regarding allegations relating to Motor Operated
Valve (MOV) refurbishment. This inspection also reviewed licensee actions
that resulted from IE Bulletin 85-03 that addressed limit switch and
torque switch settings in MOVs.
3.0 Background
3.1 Allegation Backg_round.
On September 21, 1987, the NRC rece ved an anonycous alleg& tion.
The
allegation was from an employee at the Peach Bottorn facility, who was
engaged in the refurbishment of Limitorque MOVs. An NRC letter,
dated October 9,1987, from the NRC Director, Division of Reactor
Projects, forwarded the contents of the allegation to the licensee.
The licensee responded to these concerns on November 25, 1987.
Copies of the NRC letter and the licensee response are provided as
Attachment A and B to this inspection report.
The licensee committed to inspect 23 of the 74 valver specified by
the allegation and develop a corrective action program based on the
findings. On March 31, if,88, an NRC Region I inspector witnessed the
'11censee inspection of tiOV 2-10-16C, one of the valves included in
the allegations,
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3.2 IE Bulletin Background
On June 9, 1985, the Davis-Bessel Plant experienced a complete loss
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of main and auxiliary feedwater which was caused, in part,' by MOV
failures. . This event resulted in IE Bulletin 85-03 that promulgateci
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NRC-requirements to assure the. operational. readiness of MOVs in the
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high pressure. coolant injectior/ core spray and emergency feedvater
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systems. . The bulletin specified that licensees take the following
actions:
(a) Review and document the design basis for the operation of
each valve, including'the maximum' differential pressure
expected during the normal'and abrormal operation.
(b) Using the above data, establish the correct switch settings
for torque, torque. bypass, position liniit and overload for-
each valve and perform modifications as needed.
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(c) Individual valves must be demonstrated to be. operable by
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testing the valve at the maximum differential pressure based on-
the performance requirements.
In the absence of differential
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pressure testing, a jui;tification should be provided.
(d) Prepare and revise, procedures to ensure that correct switch-
settings.are determined'and maintained throughout the life'of
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t'ne plant.
(e) Submit a schedule to accomplish the above program including
a final submittal with the results'of (b) througn (d).
item (a) has been reviewed and found' acceptable by the NRC Office
of Nuclear Reactor Regulation (NRR). The scope of this inspection-
was to review items (b) through (d).
4.0 Allegations
The hardware related allegations' made by the ationymous employee 'regarding
the MOV refurbishment program are identified in the October 9, 1987 letter
to the licensee, see Attachment A.
A paraphrasing of the alleger's
technical concerns is provided below.
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(a) The alleger was a member of the Limitorque Refurbishment. Team at the -
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peach Bottom Atomic Station in Delta, Pennsylvania.
Some of the work
that was done, was not carried out according to site procedures and
documents.
. (b) To team members took s'hortcuts when no'one was looking and the
task leader would cover up for them.
The shortcuts included:
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' checking the grease in the limit switch gearbox, not installing a new
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Anchorite gasket, not checking grease in Limitorque gear compartment,
and not cnecking tuounting bolts that hold the actuator to the bonnet.
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.(c) 'One individual'on'the refurbishment. team was not considered to be a
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team player by the task leader.
He found something wrong with.one of
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the Limitorques that was worked on by someone el.se. The work was
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inecrrectly signed off as being completely checked-according to
proceoures. .The 'MOV vas so . low .in grease, you could. read the stencil ,
on the gears.
This nerson was instructed to ignore the deficiencies.
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(d) One person was.se.c into the higher radiation areasi The task leader
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. was. trying to trake him quit.
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[e). Work that needed to be witnessed by QC was not properly performed.
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.One team membar did not 'know the ditference between an AC or DC
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motor.- The' task leader instructed the team to perform work without
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QC coverage and with inadequate procedures.
Safety related -aterial.
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was used with improper docunentatio:n.
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(f) When' rebuilding'a Limitorque, one'of the new replacement parts
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was damaged. The team was instructed to use the old parts. . Steps
were omitted because some of workers did know how to use an Ohmmeter.
Documents that' required signatures were signed by people who did not
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(g) A small percentage of the work was quality.
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5.0 Allegation Review and Resolution
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This section includos a review and discussion of each of the allegations,
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followed by the inspectors review of the allegation, licensee actclons to
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rectif.y the concerns and the conclusions by the l inspector regarding the
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specific allegation.
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5.1 Allegation (al
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The alleger was a member of the Limitorque Refurbishment. Team at the
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Peach Battom Atomic Station in Delte, Pennsylvania.
Some cf the work'
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that was done, was not carried out secording to site procedures and
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documents.
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Details
A contractor to PEco was used to perform the refurbishment of MOVs.
This activity was performed using PEco prctedure M-9.1 Limitorque
Switches Inspection, Maintenance, Adjustment, Replacement'and
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Lubrication, Revision 12. The allegstion that the work was not done
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according to ttg procedure was forwarded to the licensee through.an
NRC letter dated October 9,1987 (I'.tachment A).
The contractor
worked on.a to_Tal of 74 MOVs. .The I::r
nyiewed all of the
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related documentation packages and did not observe- any significant
' deficiencies. .In addition, as. discussed in Section 5.2, in 1988, the
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. licensee rebuilt and tested the subject MOVs. The NRC' inspector
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' inspected a sample of these valves.
Conclu: ion-
The allegation that MOV. refurbishment.was not performed according to
the procedures could not be substantiated. The licensee rebuilt and
inspected the' subject MOVs in 1988. subsequent to the' allegations.
JThe licensee's inspection and the NRC'.s inspection did not reveal any-
.significant discrepancy.'
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5.2 Allegation (b)
'Two. team members'took shortcuts when no one was looking and'the
-task leader would cover up' for them, cThe shortcuts ' include: ;not
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checking the grease in th.e limitswitch gearbox,.not installing a new
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Anchorite gasket, not checking grease in Limitorque gea'r compartment,
andJnot checking mounting bolts that hold the actuator to the bonnet.
Details.
The Limitorque actuators.of-74 motor operated va1ves from PBAPS
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Unit 2 were inspected and repaired by the:Limitorque Refurbishment'
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Team cf which the alleger was 8 member.
The technical direction for
the contractor maintenance craft was provided by PECo' Maintenance
Supervision. The Limitorque inspection and rework was prescribed in
the ' applicable pEco adtninistrative'and maintenance. procedures.
PECo
Quality Control Inspectors inde.oendently verified the work performed
by c-ontractor craft in accordance' with the PECo Quality' Assurance
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Program.and implementing' procedures.
Preventiv4 maintenance required by1the Environmental Qualification
Program for 'PBAPS, was performed by contractor craftsmen on 62 of the
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74 Limitorque actuators. -Out of the remaining-12, only 7 were safety
related and 5 were not safety related. Maintenance Request Forms
(MRFs) issued for this work specified that the. applicable EQ.section
(Section F Environmental Qualification Inspect' ion)-of Maintenance
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Procedure M-9.1, limitsrque Switches Inspection, Ma'inten.ance,
Adjustmer.t, Lubrication, was to be used to perforte and document the-
maintenance inspection. This section of the procedure provides-
maintenance instructions for the inspection of gear case grease,
limit switch gear cover arid conipartment' gaskets., and a check of;the
tightness of mechanical fastners.
Documentation of this inspection
by contractor craftsmen 'and verification by PECo QC Inspectors was
recorded on the Maintenance Travelers that accompanied each work
package.
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The primary activities performed by_the contractor team are addressed
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in the above allegation.; The licensec's procedure required QC
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inspections for the following attributes,
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Limit switch gear frame material.
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Rotor color. .'
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Rotor' inspection for cracks.
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' Color of finger base.
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Limit switch gear frame. packed with Mobil 28 grease.
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Limit switch' cover gasket. installation'.
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' Penetration inspection 'for leakage.
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Inspection of limit switch compartment for moisture and
corroded contacts.
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Electrical connections as found and as left.
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10. Motor'megger reading.
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11.
" TEE" drain installation.
12. Compartment cover gasket installation.
13. Compartment cover bolts.
14. Confirming that worm gear is covered with grease.
15.
Inspection of seals and fasteners.
16. Cleaning of valve stem and lubrication.
Except for items 5,14,15 and 16, the- QC check can be done with a
one' time observation to include all the. attributes.
The alleged
shortcuts taken for items 5, 14, 15 and 16 could not be readily
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identified by the licensee's QC reinspection.
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Subsequent to the refurbishment program previously described, the
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licensee decided to perform an elaborate MOV rebuilding program under.
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modification 1915 and 2231.
This called for a complete tear-down of
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MOVs, refurbishment with environmentally qualified parts'and' diagnostic
testing of all safety related and critical valves.
This effort
included ail of the valves specified in the allegation.
The licensee
utilized th'.s opportunity to record the as found data to chec% the
validity of the allegations.
This effort is currently complete.for
Unit 2.
On-March 31, 1988, the inspector witnessed the licensee's
refurbishment program.
The observations on valve 2-10-16C did not-
support the allegation.
The inspector reviewed'the inspection records
and corrective actions for the following valves.
M0-2163B
MRF 206F8806064
M0-2149A
MRF 206F8803504
MO-2-'10-398
MRF 210F8710657
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In order to assess the quality of the present condition of the
valves, the NRC inspector field inspected the following valves after
the refurbishment.
2-14-005A
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2-14-0070
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2-14-007C
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Conclusion
The results'of the licensee's. inspection, the NRC's review of the-QC
records and the NRC's observation of refurbishment did not find any
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evidence to substantiate the allegation. The extensive refurbishment'
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program has removed any potential concern from this allegation regard-
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ing the equipment conditiori.
5.3 Allegation (c)
One individual on the refurbishment team was n'ot considered to be a
' team player by the. task leader.. The individual frequently pointed
out deficiencies in the work being performed.
The work was incorrectly
signed off as being completely checked according to procedures. The
MOV was so low in grease you could read the stencil on the gears.
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This person was instructed to ignore the deficiencies.
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Discussion
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The allegation that an MOV did not have sufficient grease could not
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be substantiated.
Based on an NRC letter to.the licensee which
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summarized the allegations, the licensee reviewed all of the maintenance
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records on the 74 valves on which the contractor had worked. This
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effort revealed only one omission of an' inspection attribute and
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three entries made in the wrong section of the procedure. Moreover,
the subsequent tear-down of all of the alleged valves and inspection
did not reveal any significant hardware discrepancies in the alleged
area of work.
Conclusion
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The lack of adequate grease in the' valves could not be substantiated.
The PECo QC personnel inspected for this attribute.
The subsequent
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tear-down and refurbishment of the specified MOVs addressed all of
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the potential concerns regarding the inadequate greasing.
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5.4 A1_ legation (d)
One persen was sent into the higher radiation areas. 'The task leader
was trying to make him quit.
Discussion
The'NRC inspector reviewed the radiation exposure data for 1986 and
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1987 for the licensee contractors to verify. if any radiation exposure.
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limits were exceeded.
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Annual whole body exposure:
1987
3 to 4 rems
8 contractor personnel
1986
3 to 4 rems
4 contractor personnel-
This establishes that PECo and federal exposure limits were not
exceeded. Therefore, there is no evidence that an individual was
subjected to an undue risk of radiation exposure.
Further, the dose-
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was observed to be uniformly distributed among the workers.
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Conclusion
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It was verified that total radiation exposures for the contractor
personnel did not exceed the site and federal exposure limits.
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5.5 Allegation (e)
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Work that needed to be witnessed by'QC was not properly performed.
One team member did not know the difference between an AC,or DC
motor. The task leader instructed the team to perform work without
QC coverage and with inadequate procedures.
Safety related material
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was used with improper documentation.
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Discussion
The allegation on lack of sufficient QC review is addressed in
Section (5.2).
The QC inspectors were qualified to ANSI 45.2.6
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Level II and had specific training on MOV inspection.
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The licensee had controls on material that was issued and supplied
only quality material for replacement.
The use of. quality material
without recording the material.in the matatenance data sheets does
not constitute a safety concern,
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Conclusion
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The allegation of not being able to identify the difference.between
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AC or DC motors can not ce directly addressed; however, the licensee
used inspectors-qualified to ANSI 45.2.6 and with specific training
for MOV inspections. The use of quality-material without recording
the material in maintenance data sheets does not raise any hardware
safety concerns.
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5.6 A11egativ (D
When-rebuilding a Limitorque, one of the new replacement parts was
damaged.
The team was instructed to use the old_ parts,
Steps were
omitted because some of the workers did know how to use sn Ohmmeter.
Documents that required signatures were signed by people who did not
.do the work.
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Discussig
The_use'of unacceptable parts in the refurbishment-program could not;
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be substantiated.
The licensee's subsequent program for total tear _down,
refurbishment and diagnostic checking removes any concern in this
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area.
The use of an Ohmmeter is not required for the contractor
refurbi shment . program.
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The allegation that signatures were made by people other than those
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who did the work could not be verified.
However, it was verified
that the MOVs are in acceptable condition.
This was based'on
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licensee and NRC inspections.
Conclusion
The allegations on the use of unacceptable parts in the MOVs, lack'of
knowledge. regarding the use of an Ohmmeter, signature of documents by
people who didn't do the work could not be substantiated; however,
all suspect valves were subsequently refurbished.
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5.7 Allegation (g)
A small percentage of the work was quality.
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Discussion
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It is assumed the alleger means that of the total work performed,
only a small percentage was of acceptable quality.
This was the
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concluding statement of the list of allegations. As all the specific
allegations were addressed in the previous sections and found to be
unsubstantiated, this statement is also unsupported.
The licensee's
inspectors and the NRC inspection _did find the MOVs to be free from
any significant deficiencies.
Conclusion
The allegation that only a small percentage of the work was quality
cannot be supported.
The inspection by the licensee and the NRC
indicate that the original work and the refurbishment work satisfied
quality requirements.
6.0 PECo Response to IE Bulletin 85-03
6.1 Status of. Commitments
The licensee was a participant in the BWR owners group for
responding to the subject bulletin.
The NRC granted relief in
submitting the response to this bulletin to allow sufficient time
for the licensee to factor in the owners group recommendations.
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The' licensee responded on November 3, 1986 in a letter to the
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regional administrator.
Due to_the extended shutdown of the Peach
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Bottom' units, PECo forwarded.another letter dated January 21, 198.8
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to provide a status on the NOV program and to-present a revised
schedule for completing the response to the bulletin. ,This letter
. states that the final-report will be.made within'3 months after'MOV.
differential pressure testing completion following the Unit-2
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restart.
6.2 Affected Valves
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The MOVs. identified for Peach Bottom Units 2 & 3 consideration are
-listed in Attachment 1.
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6.3 Switch Settings
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Item (b) of the bulletin requires that the correct switch settings
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for torque, torque bypass, position limit.and overload for each
valve.be established.
These items are addressed below:
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Open Torque Switch & Open Bypass Limit Switch
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The Open Torque Switch is normally used to limit the mechanical
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thrust applied to the valve.ini the open direction.
It generally
prevides no control function and is a protection device for some
other valve related failure.
This-switen is usually bypassed during
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the initial valve unseating, which is the most challenging portion of
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the open stroke.
Failu_re to set this switch to the required value or
not bypassing this switch in the initial opening stroke, can cause
valve failure.
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The licensee does not torque seat the valve in the opening direction.
This has proven t<o be .a good practice for valve performance.
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licensee has elected.to set the open torque switch to the maximum
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possible setting based on the limitations of the assembly.
This is
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a conservative approach to provide a high confidence for valve opening
even during an abnormal operation.
As the valve is not backseated,
the valve is not subjected to any undue strain.
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The licensee has set the open bypass limit switch until after the
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valve comes off the seat. This was verified in the diagnostic check.
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This setting is sufficient to prevent the actuation of the opening
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torque switch due to the initial high. opening torque.
For the ECC
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injection valves the licensee bypasses the open torque switch for the
entire duration of the opening. stroke. This'is an acceptable con-
figuration.
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.Close Torque Switch
The_Close~ Torque Switch is used to stop motor rotation on the
completion of valve travel in the close direction. This switch'
provides a normal control function and is exercised on every closure
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stroke.
The limiting requirement of the close torque switch.is.at
the end of the closure stroke when.the thrust requirements are the
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' highest. The thrust at torque switch trip should equal the most
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limiting closure thrust requirement including the' thrust needed to
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overcome the differential pressure across the' valve. Differential.
pressure testing using process system pumps with appropriate data
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gathering and diagnostic evaluation 'is a positive.means of assuring
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the adequacy of the' torque switch set point-
Other approaches based
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on similarity and analysis may also.be acceptable with' sufficient
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basis.
PECo performed differential pressure testing for. valves M0-2-13-039,
M0-2-23-057, and M0 4244A using MOVATS equipment. The,setpoints in
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these cases were developed based on the thrust required to operate
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the valve at the design condition.
The licensse collected. thrust
values from the manufacturer for all valves and has utiMzed the.most
conservative' values constrained by the following limits.
a)
The maximum a'iluwable thrust. for the valve a. spacified by the
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valve manufacturer,
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b)
The maximum allowable thrust for the motor-operator as
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specified by the operator manufacturer.
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c)
The maximom torque capability of the actor at degraded
voltage,
d)
Spring pack specific maximum allowable settings.
PEco plans to differential pressure test 'all of the valves whenever
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practical to confirm the required torque switch settings. lIn cases
where it is not practical, an identical valve will be tested and the
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values verified. The 3 valves already tested proved the calculated
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values to be conservative.
If future tests indicate any different
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results, the NRC will be notified.
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,Close Torque Switch Bypass
The Close Torque Switch bypass acts in the same manner as the Open
Torque Switch bypass; however, contrary to its counter part function,
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it normally bypasses the torque switch during the lightest duty
portion of the stroke, the beginning of the closing stroke.
The use.
of this switch is not critical; however, if utilized it should be set
to operate during the initial part of the stroke.
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PECo has adjusted this. switch such that the: torque' switch will.not
see the initial hammer blow in the opening stroke.
No deficiencies
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were identified.
0penL Limit Switch
This switch provides the..centrol function for determin'ing.the upper
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limit of the valve stem travel in the open direction-and stops the
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motor rotation.by opening the circuit..' The settirg of.this switch
must assure adequate velve. opening and should prevent back_ seating.
Valve backseats normally provide a seal! that is redundant ~ to the
valve packing.in order to allow valve packing replacement without the
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need to drain down.the process system.
Using the. motor power to
backseat can and has caused valve stem shearing and stem thread.
twisting. Therefore, it is important to set the open-l.imit switch
'away from the back seat with enough margin to allow for motor
- de-energization and inertia.
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PECo 'cas set the open limit switch such that the valv'e does not back
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seat by ineitia. No problem was identified with this arrangement,
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Tjiermal Overic,d Relay
Thermat overloads are used to. protect motor winding insulation from
. breakdown.
Devices'used appear to uniformly consist of heaters' at
the motor cont.rol 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 ovarload relays stop operator motor rotation on
tripping, the heaters must either be sized to prevent inadvertently
stopping.the motor or the heaters.should be bypassed when motor
operation is important to safety. They should be sized to protect
the motor windings from' thermal damage.
At Peach Bottom, safety-related motor-operator thermal overload
(TOL) protection has the following features:
(1) Motor-operator thermal. overload (TOL) device trips are
annunciated in the control room.
(2) Auto-actuation signals (emergency operation) bypass the overload
trip circuitry, preventing the .TOL from de-energizing the
[
operator motor. This increases the proba'oility that the valve
will perform its safety. function.
(3) Therrul overload protection can be overridden in an emergency
by the control room operator by holding the control switch in
the open or close position.
.
.
.
--
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-_--_
- - .
.,
.
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.
13
-
.
(4) The overload heaters are sized in accordance with the special
service requirements of intermittent duty motors.
The sizing
criteria are such that the motor will rapidly trip if a locked
rotor condition occurs, provides sufficient margin for
operational loadings, and provides prompt indication.
This is an acceptable configuration.
6.5 Maintenance Procedures
IE Bulletin 85-03 specifies that licensees prepare or revise procedures
to ensure that correct switch settings are maintained throughout
the life of the plant and also to ensure that applicable industry
'
recommendations are considered in the preparation of the procedure.
I
The inspector reviewed the procedures listed in Attachment 2.
J
The licensee has developed very detailed procedures using industry
experience for the refurbishment activity.
These procedures are
I
being modified to plant maintenance procedures with proper pre-
cautions to consider the operating status of the plant.
The NRC
a
inspector's review of the MOV maintenance activities did not reveal
i
any deficiencies.
1
7.0 Conclusions
4
The licensee resolved all of the concerns in the allegation and addressed
the requirements of IE Bulletin 85-03.
Engineering and maintenance have
taken special training for addressing the concerns addressed in the bulletin.
Based on the review of the licensee activities,-it was concluded that
there is reasonable assurance that the valves covered under the bulletin
can perform their safety function during normal and abnormal operation
'
when the work is completed in full adherence to the existing program.
8.0 Exit Interview
At the conclusion of the inspection on January 14, 1989, the inspector
met with the licensee representatives, denoted'in section 1.0.
The
inspector summarized the scope and findings of the inspection at that
time.
- _ _ _ _ .
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ATTACHMENT 1
PBAPS I.E. BULLETIN 85-03 TESTING PROGRAM SUMMARY
'
.
Valve No.
Description
Test Method (*)
BY OGID#
System #13
M0-2(3)-21
RCIC Injection Valve
A)
1
MO-2(3)-27
RCIC Minimum Flow Bypass Valve
A) B)
2'
MO-2(3)-18
RCIC Condensate Storage
A) B)
3
!
Tank Suction Valve
M0-2(3)-41
RCIC Torus Suction Isolation Valve
A)
4
M0-2(3)-39
RCIC Torus Suction Isolation Valve
A) 8)
4a
MO-2(3)-30
A) B)
5
M0-2(3)-20
RCIC Injection Valve Test Valve
A) B)
8
M0-2(3)-132
RCIC Turbine Accessory
A) B)
9
Cooling Water Valve
M0-2(3)-131
RCIC Steam Admission Valve
A) B)
I
MO-2(3)-15
RCIC Steam Line Inboard
A) B)
II
Isolation Valve
MO-2(3)-16
RCIC Steam Line Outboard
A) B)
III
Isolation Valve
,
l
MO-4244
RCIC Vacuum Breaker Line
A) B)
VII
M0-5244
Isolation Valves
'
System #23
MO-2(3)-19
HPCI Injection Valve
C)
1
i
(Identical to M0-2(3)-20)
MO-2(3)-25
HPCI Min. Flow Bypass Valve
A) B)
2
M0-2(3)-17
A) B)
3
MO-2(3)-58
HPCI Torus Suction Isolation Valve
A)
4
MO-2(3)-57
HPCI Torus Suction Isolation Valve
A) B)
4a
M0-2(3)-21
A) B)
5
M0-2(3)-24
HPCI CST Test Loop Isolation Valve
A) B)
6
M0-2(3)-31
HPCI/RCIC Test Flush Valve
A) B)
7
MO-2(3)-20
HPCI Injection Valve Test Valve
A) B)
8
M0-2(3)-14
HPCI Steam Admission Valve
A) B)
I
MO-2(3)-15
HPCI Steam Line Inboard
A)
II
Isolation Valve
i
MO-2(3)-16
HPCI Steam Line Outboard
A) B)
III
l
i
Isolation Valve
j
'
M0-4244A
HPCI Vacuum Breaker Line
A) B) (1)
VII
!
M0-5244A
Isolation Valves
)
1
(*) TEST METHODS
A) Baseline MOVATS Testing - all valves except HPCI (M)-2(3)-19 due to
inaccessibility.
Identical' valve MO-2(3)-20 to be tested for proper
l
torque switch settings.
l
B) Instrumented differential pressure testing.
Currently planned for Unit 2
ONLY. Unit I valves are identical to Unit 2.
I
C) Non-instrumented differential pressure testing at design basis conditions.
!
I
NOTE (1) - Either the HPCI or RCIC vacuum breaker isolation valve will undergo
j
dP testing.
1
L____._____________
__
v-
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.
.
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.
ATTACHMENT 2
MAINTENANCE PROCEDURES
M-511.100
Rev. O
Procedure for Determining Post Maintenance
Training Retesting Identified.
>
M-511.109
Rev. O
Procedure for Spring Pack Torque Limiting
Sleeve Slotting.
M-511.105
Rev. O
Procedure for Rebuild and Lubrication of
Limitorque Motor Operators.
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Philadelphia Electric Company'
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4)
Assurance that the requisite quality control inspections were
-
performed and that associated inspection records are available and
complete
5)
Perform additional examination of the reworked operators to verify
-that refurbishment activities were properly accomplished
.
'
We request that you ' provide the results 'of your investigation to us within 30
days of receipt of this letter.
Your cooperation with us in this matter is appreciated.
Sincerely,
}
William
Kane, Director
Division of Reactor Projects
.
Dickinson M. Smith, Manager, Peach Bottom Atomic Power Station
John S. Kemper, Senior Vice President, Engineering and Production
)
Thomas S. Shaw, Jr., Vice President, Production
Troy B. Conner, J . , Esquire
W. H. Hirst, Director, Joint Generation Prcjects Departrnent,
Atlantic Electric
G. Leitch, Nuclear Generation Manager
Eugene J. Bradley, Esouire, Assistant General Counsel
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations
W. M. Alden, Engineer in Charge, Licensing Section
Doris Poulsen, Secretary of Harford County Council
Public Document Room (PDR)
Local Public Docu ert D.oc- (LP ;)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
bec w/ enc 1:
Region 1 Docket Room (with concurrences)
Management Assistant, DRMA
J. C, Linville, Section Chief, DRP
M. Shanbaky, Cnief, F U S, C;SS
!
SRI, Linerick 1.
A. Shropshire
. _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _
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UNITED STAT 38
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NUCLEAR REEULATCRY COMMISSION
!
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MelONI
.
831 PARK AVENUE
KING OF PftUSB4A, PENNSYLVANIA 19400
,
,
,
09 00T 1987
Docket Nos. 50-277
50-278
-
Philadelphia Electric Company
ATTN: Mr. J. W. Gallagher
Vice President
Nuc' ear Operations
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
We have received an anonymous allegation that pertains to the quality of work
activities performed by the Babcock and Wilcox Limitorque refurbishment team
at the Peach Bottom Atomic Power Station.
The allegation states that the
applicable rework procedures were not adhered to in that:
-
Gearbox grease levels were not checked
-
Replacement gaskets were not installed
-
Actuator mounting bolts were not checked
-
Procedure steps were improperly signed as complete when the work had
)
not been performed
.l
-
Quality Control inspections were not performed
-
Quality Control personnel were not technically competent
Damaged replacement parts were utilized for rework applications
-
In order for us to fully evaluate the significance of the allegation, we renuest
I
j
thet Philadelphia Electric Company assess the adequacy of the Limitorque refur-
l
bishment activities with respect to the alleged problems.
Your investigation
should address at least the folicwing relevant aspects of the Limitorque refur-
,
bishment program:
l
1)
The adequacy of Philadelphia Electric Company oversite of the
,
'
maintenance contractor
2)
The adequacy of the maintenance contractor's quality control
inspection procedures
l
3)
The adequacy of the craf t and quality control training prior to
rework implementation
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OM/A O l.
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PHILADELPHIA ELECTRIC COMPANY
2301 M ARKET STREET
,
,
P.O. BOX 8699
-
PHILADELPHIA. PA.19101
tatsi e46 5001
eatam w.eaL6asusa
November 25, 1987
.0"..~ll.'*:"L.
-
Docket Nos. 50-277
50-278
Hilliam F. Kane, Director
Division of Reac'.?r Projects
Hegion I
U.
S.
Nuclear Regulatory Commission
Attn:
Document Control Desk
20555
SUBJECT:
Anonymous Allegation RegarSing
The Quality of Valve Opeto.or Refurbishment
at Peach Bottom Atomic Power Station
Dear Mr. hane:
This is ir. response to your letter dated October 9,
1987 (received October 19, 1987) regarding alleged improper work
practices and procedural non-compliance during Limitorque valve
operator refurbishment at Peach Bottom.
M r .
.T . ;inville of the
NRC was notified on November 18, 1987 that a;dit;Jnal time would
be required to complete our response.
An ext. m .ve, detailed
review of seventy-four maintenance work packages was conducted,
requiring additional time.
-
-
..
A thorough investigation of this anonymous allegation
has been conducted and no evidence supporting the allegation was
discovered.
The investigation consisted of interviews with
~
Company maintenance supervisors and Quality Control (OC)
inspectors, and a review of documentation (purchase order,
completed maintenance procedures, maintenance request forms and
the daily log maintained by the subcontractor craftsmen).
Some
minor deficiencies in several of the completed work documents,
and some problems with maintenance procedures and an
administrative procedure were identified.
To verify the quality
,
!
of the work performed, 23 valve operators will be reinspected and
the results evaluated prior to startup from the current outage.
Further details are provided below.
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/ Willica F. Kona, Director
Novatb2r 25, 1987
Page 2 of 8
General Discussion:
g.
The'Limitorque motor operators of' seventy-four (74) Peach Bottom
s
Unit ? valves were inspected and/or repaired by a Babcock and
f
Wilcox team of craf tsmen, as subcontractors under a purchase
order to Crane Valve Services (formerly Mark Controls
. Corporation).
Tne subcontractor team took direction from on-site
-
PECo Maintenance Department supervision and the work'was
performed in accordance with applicable Philadelphia Electric
Company (PECo) procedures.
Independent QC. verification was
'
performed.by PECo QC inspectors in accordance with the PECo
Quality Assurance Program and Implementing Procedures.
Sixty-two (62) of the seventy-four'(74) valve operators that the
subcontractor team inspected are Environmentally Qualified (EQ)
,
and were being inspected in accordance'with Section F
(" Environmental Qualification Inspection") of Maintenance
Procedure M-9.1 ("Limitorque Switches Inspection, Maintenance,
Adjustment, Lubrication").
The other 12 motor operators'are not
EQ (seven are safety-related, five are non-safety related) and
were inspected in accordance with other sections of procedure M-
{
'9.1.
!
a-
PECo QC inspectors witnessed the sixty-two (62) EQ inspections as
l
.
required by procedure M-9.1, which included 1) limit switch gear
l
cover and compartment gaskets inspection and (if necessary)
replacement; 2) gear case grease level eheck; and 3) mechanical
,
. fasteners tightness check (which was' understood by all personnel
l
'
involved, based on subsequent-interviews,'to include actuator
mounting bolts) as.well as other items.
The inspections of.the
)
non-SQ operators consistec cf similar maintenance items; however,
j
.
PEco QC inspectors were required to witness fewer inspection
j
points.
Nine (9) of the sixty-two (62) EQ motor operators'were
~
also disassembled and repaired by the subcontractor team in
accordance w;*h Maintenance Procedure M-9.3 (" Disassembly and
Repair of Limiterque Valve Operators").
<
Each of the aspects ot tha )imitorque inspection project which
i
were specifically requested to be addressed by your letter are
I
restated below followed by nur response.
1)
The adequacy of Phdadelphia Electric Company oversite of
the maintenance contractor
Based on the completGhess of the records of the
subcontractor's work and PECo QC inspections', and interviews
with supervision and inspectors, PECo finds no indication of
inadequate oversight.
The maintenance supervisor-
responsible for thin work (PECo subforeman) met regularly
.with the subcontractor team foremen each day to assign work,
review completed work, and resolve problems.
The PECo
subforeman usually checked on the subcontractor team once a
j
-.
. - _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _
-
._
_ _ _ - _ - _ _ -
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Novcaber 25, 1987-
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,
.
. William F. Kano, DirGctor.
.
'
Page-.3 of 8
day st the work area as well.
Theeveningshift'(usuallyk
'
'
pm to midnight) always had an onsite contact-(first class
mechanic or electrician)'available'for assistance, as well
s
as the home phone number of.the PECo subforeman responsible
for,the job.
.
L2)
The adequacy of the maintenance contractor s quality-control
inspection procedures
.
'Only:PECo procedures.were used by the' subcontractor team (M-
9.1 anf*M-9.3).
.Section F of procedure M-9.1, the EQ .
1
inspections, requires an-independent OC inspection and sign-
off for 18 of the 22 steps.
This Sac. ion of.M-9.1 has been
y
reviewed and determined to be adequate from a DC standpoint;
j
l
however, we-are considering' additional QC hold points.
The
]
remainder of M-9.1 does not include any independent QC hold
'
points, which is' considered to.be-a. weakness, at=least for
,
safety-related applications.
Procedure M-9.1 will be
I
revised to add..QC hold. points'by January 7,
1988.
!
The disassembly and repair of?.the nine (9) motor:opetators
in accordance.with procedure.M-9.3-included hold points for
craftsman sign-off, but did not include any. independent QC'
hold points.
This is considered to be's weakness in the
procedure; however, no' evidence was found:to indicate that
the lack'of' independent QC inspections adversely impacted
the quality of-the work by the subcontractor.- Procedure M-
9.3 will be revised to add OC hold points by January 21,
1988.
I
3)
The adequacy of the craft and quality control training prior
to rework implementation
PECo has verified that the subcontractor craftsmen were well
,
'
qualified for the Limitorque work.
Each individual
i
satisfied the basic requirements of'" Repairmen" in
accordance with ANSI N 18.1-1971, paragraph 4.5.3.
Furthermore, each craftsman was qualified as'a "Limitorque
Refurbishment Task Leader, Engineer, or Technician"..;This-
qualification is' based on field experience requirements and.
considerable training on both the electrical and mechanical
aspects of Limitorque motor operators.
Training consisted
of oral check-outs of preventive maintenance checks, NRC
l
concerns, trouble shooting methods, previously identified
t
problems,.and use of special tools, in addition to checkouts
on the actual equipment.
Hands-on maintenance performed
under an instructor's' surveillance for. grade was also
L
included'in this qualification and a six (6) hour written
l
test was satisfactorily completed prior to certification.
- _ _ _ - _ _ _ _ _ _
%
_
7-
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,; T.'
'
,;
hillian F. KOn9, Dircctor
Novcrb0r 25, 1987
'.
Page 4 of 8
'
'The QC inspectors involved in the Limitorque work were PECo
employees and long-term QC contractors (not associated with
the valve operator maintenance subcontractor) certified to
at least, Level II in the electrical and mechanical
j
disciplines in accordance with ANSI N 45.2.6-1978,
'
paragraphs 3.3 and 3.5.2.
This level of certification is
appropriate for the work being performed.
In addition, each
.
of the Level II.QC inspectors had completed a supplementary
reading list consisting of the following:
Maintenance
'
Procedure M-56.1 ("480 Volt Motor Control Center Circuit
Breaker Assembly Maintenance Procedure"), Maintenance
Standard Work Instructions for. splicing and calibration of
I
crimping tools, NUREG-0588 (" Interim Staff Positions on
l
Environmental Qualification of Safety Related Electrical
Equipment"), and IEEE 690-1984
(" Electrical Installations in
)
l
l
Nuclear Power Plants").
'
'
i
4)
Assurance that the requisite quality control inspections
l
were performed and that associated inspection records are
l
available and complete
1
The completed work packages for all of the Limitorque
operators which the subcontractor team inspected / repaired
I
were thoroughly reviewed and were found, overall, to be
i
complete and detailed.
A few deficiencies were discovered,
,
j
as described below.
l
l
l
a)
Valve MO-2-10-31B:
Residual Heat Removal Drywell
'
Spray Injection (EO)
The inspection and installation of the limit switch
gear cover gaskets was not documented.
Verification
j
signatures and dates of subcontractor craftsman and QC
'
Inspectors were not recorded on the Maintenance
traveler (procedure sign-off sheet).
There are no
entries in any other part of the work package to
document that this was done.
Follow-up action will be
taken to address this deficiency, as discussed in
paragraph Sa of this letter.
b)
Valve MO-2-10-39B:
Residual Heat Removal Torus Spray
l
Injection (EQ)
l
l
The inspection and installation of the limit switch
gear cover gaskets was not documented in Section F of
the Maintenance Traveler.
However, there is
documentation in Section D of the Traveler that the
subcontractor craftsman did install new cover gaskets,
i
This occurred as a result of a separate work package
issued to replace the limit switch.
This and the work
package to inspect the operator for environmental
qualification, were issued to maintenance to be done
- - - - _ - _ - _ - _ -
.
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~hillicm.F. Kcn2, Dirsctor
Nsverb2r 25, 1987
Page 5 of 8
1
'
'
together.
The replacement of the switch and
'
installation of new gaskets were documented in
i
Sections B and D of the Traveler.
Because Section D
of Maintenance Procedure M-9.1 does not require QC
witness, and there were no special instructions in the
work package, QC did not verify the installation of
,
'
.the new limit switch gaskets.
Follow-up action will
,
be'taken'to address this deficiency, as discussed in
paragraph Sa of this letter.
c)
Valve MO-2-14-05C:
Core Spray Pump Minimum Flow
Bypass (EQ)
The' subcontractor craftsman's signature verifying the
_
inspection / installation of the limit switch gear cover
]
gaskets, and OC Inspector's signature for the witness
'
l
of the mechanical fastener inspection were not dated
l'
on the Maintenance Traveler.
The gasket inspection by
I
the subcontractor craftsman was witnessed by a PECO OC
l
Inspector and is properly. documented on the Traveler
'
(including date).
The mechanical fastener inspection
was documented on a OC Inspection Report as being
witnessed on the date recorded by the. subcontractor
craftsman.
Therefore, . follow-up action is not
considered to be warranted for these minor
defic 2encies.
l
l
l
d)
Valve MO-2-10-38A:
Residual Heat Removal Torus Sprav
f
Injection (EO)
)
The subcontractor craftsman's signature verifying the
l
'
inspection of the actuator gear case grease is not
dated on the Maintenance Traveler.
This inspection
i
was witnessed by the OC Inspector and is properly
l
documented on the Traveler (including date).
1
Therefore, follow-up action is not considered to be
1
warranted for this minor deficiency.
i
1
e)
Valve MO-2149A:
Reactor Feedwater Pump Discharoe
(Non-EQ)
The instructions on the Maintenance Request Form
issued for the preventive maintenance on the valve
operator required that OC be notified to monitor limit
"
switch and main gear box inspection.
There is
l
documentation that these inspections were performed by
l
the subcontractor craftsman; however, there is no
j
'
record indicating that OC witnessed this inspection.
Follow-up action will be taken to address this
l
deficiency, as discussed in paragraph 5b of this
l
letter.
l
.
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
.__
. _ _ _ _ _ _
_
n
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.
. e
s .,
'
(
Willicm F. Kcdo, Director
Novembar 25, 1987
Page 6 of 8
5') ' Perform additional examination of the reworked operators to
verify that refurbishment activities were properly
accomplish 6d
The following work will.be performed with independent OC
verification prior to startup from the current outage.
.~
a)
The limit' switch gear cover gaskets for MO-2-10-31B
and MO-2-10-39B will be inspected and replaced, if
necessary, because of the deficiencies on the
Maintenance Travelers (see paragraphs 4a cnd 4b).
b)
The limit switch and main gear box of MO-2149A will be
inspected, because OC did not witness the previous
!
inspection.(see paragraph de).
c)
The nine (9) Limitorque operators that were
.
disassembled and. repaired in accordance with M-9.3
without independent.QC verification will be reworked.
The affected valves are listed below:
Residual Heat Removal System
MO-2-10-15D
'D'
Pump Suction
MO-2-10-16B
'B' Pump Minimum Flow Bypass
'
MO-2-10-16D
'D' Pump Minimum Flow Bypass
1
MO-2-10-18
Inboard Shutdown Cooling Suction
.
MO-2-10-33
Outboard Reactor Head Spray Injection
Core Spray System
!
MO-2-14-26B 'B'
Loop Test Line
l
Reactor Water Clean.up System
i
MO-2-12-18
Outboard Pump Suction
l
Reactor Building Coolino Water System
MO-2373
Reactor Recirculation Pump Seal and
and
Motor' Oil Cooling Watcr Isolation valves
MO-2374
I
d)
The seven non-CO, safety-related operators which were
l
inspected in accordance with sect. ions of M-9.1 without
!
QC hold points will be reinspected.
The affected
l
valves are listed below.
1
l
!
l
MO-2149A,B,C
Reactor Feedwater Pumps Discharge
MO-2163A,B,C
Reactor reedwater Pump Turbines Main Steam
Supply
!
l
MO-2-32-89B
'B'
Heat Exchanger High
l
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1111cm F. Kane, Diractor
Nov;mbar 25, 1987
.
Page 7 of 8
I
' *
Pressure Service Water Outlet
1
e)
An additional sample of operators will also be
)
reinspected.
This sample of operators was selected to
i
I
be representative of work perfc:med by each craftsman
on the subcontractor team.
The selected valves are
i
listed below.
,
Residual Heat Removal System
MO-2-10-15B
'B' Pump Suction
MO-2-10-16C
'C'
Pump Minimum Flow Sypass
j
!
MO-2-10-26A
Drywell Spray Injection
Core Soray System
j
MO-2-14-05B
'B' Pump Minimum Flow Bypass
j
i
High Pressure Coolant Injection
)
MO-2-23-20
Outboard Injection
i
in total, 23 operators will be examined and the results will
be evaluated to identify any negative trends in the quality
l
of craftsman wori.
A determination will then be made, based
on the results, as to whether additional examinations should
be performed.
The NRC Resident Inspector w.ill be notified
when these examinations are complete.
If there are
4
unsatisfactory results, PECo will provide a written
)
description of the results and a schedule for additional
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examinations.
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An administrative procedural deficie'ncy has been
identified which may have affected the extent of independent QC
coverage of work performed on nine (9) of the operators.
The
work scope of nine (9) Maintenance Request Forms (MRFs) was
expanded to include disassembly and repair of the operator in
accordance with Maintenance Procedure M-9.3 without OC reviewing
the revised MRFs.
Administrative Procedure A-26A, " Corrective.
and Preventive Maintenance Using Computerized History and
Maintenance Planning System (CEAMPS)" did not require that QC
review the revised MRF (after expanding the scope).
Had QC
reviewed the revised MRF, QC hold pointc would have been
specified becauser as 6iscussed previously, procedure.M-9.3 does
not include independent OC hold points.
Procedure A-26A is being
revised to require QC review of MRF work scope changes.
&
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illicm F. Kane, Director
November 25, 1987
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Page 8 of 8
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If you have any questions or require additional
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information, please do not hesitate to contact us.
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Very truly yours,
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cc:
Addressee
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W.
T.
Russell, Administrator, Region I,
T.
P.
Johnson, Resident Site Inspector
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