Information Notice 1992-17, NRC Inspections of Programs Being Developed at Nuclear Power Plants in Response to Generic Letter 89-10: Difference between revisions

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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


===OFFICE OF NUCLEAR REACTOR REGULATION===
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555 February 26, 1992 NRC INFORMATION


NOTICE 92-17: NRC INSPECTIONS
WASHINGTON, D.C. 20555 February 26, 1992 NRC INFORMATION NOTICE 92-17:   NRC INSPECTIONS OF PROGRAMS BEING DEVELOPED


OF PROGRAMS BEING DEVELOPED AT NUCLEAR POWER PLANTS IN RESPONSE TO GENERIC LETTER 89-10  
AT NUCLEAR POWER PLANTS IN RESPONSE TO
 
GENERIC LETTER 89-10


==Addressees==
==Addressees==
All holders of operating
All holders of operating licenses or construction permits for nuclear power
 
licenses or construction


permits for nuclear power reactors.
reactors.


==Purpose==
==Purpose==
The U.S. Nuclear Regulatory
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice
 
Commission (NRC) is issuing this information
 
notice to alert addressees
 
to the general conclusions
 
derived from the NRC inspections
 
of the programs being developed
 
at nuclear power plants in response to Generic Letter (GL) 89-10, "Safety-Related
 
Motor-Operated
 
Valve Testing and Surveillance." It is expected that recipients
 
will review the information
 
for applicability
 
to their facilities
 
and consider actions, as appropriate, to avoid similar problems.
 
However, suggestions
 
contained


in this information
to alert addressees to the general conclusions derived from the NRC inspections


notice are not NRC requirements;
of the programs being developed at nuclear power plants in response to
therefore, no specific action or written response is required.Background


In GL 89-10 (June 28, 1989), the NRC staff requested
Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and


that holders of nuclear power plant operating
Surveillance." It is expected that recipients will review the information for


licenses and construction
applicability to their facilities and consider actions, as appropriate, to


permits ensure the capability
avoid similar problems. However, suggestions contained in this information


of motor-operated
notice are not NRC requirements; therefore, no specific action or written


valves (MOVs) in safety-related
response is required.


systems by reviewing
Background


MOV design bases, verifying
In GL 89-10 (June 28, 1989), the NRC staff requested that holders of nuclear


MOV switch settings initially
power plant operating licenses and construction permits ensure the capability


and periodically, testing MOYs under design basis conditions
of motor-operated valves (MOVs) in safety-related systems by reviewing MOV


where practicable, improving
design bases, verifying MOV switch settings initially and periodically, testing


evaluations
MOYs under design basis conditions where practicable, improving evaluations of


of MOV failures and necessary
MOV failures and necessary corrective action, and determining trends of MOV


corrective
problems. The NRC staff requested that licensees complete the GL 89-10 program


action, and determining
by the end of the third refueling outage or 5 years from the issuance of the


trends of MOV problems.
generic letter, whichever is later. On June 13, 1990, the NRC staff issued


The NRC staff requested
Supplement 1 to GL 89-10 to provide detailed information on the results of


that licensees
public workshops held to discuss the generic letter. On August 3, 1990, the


complete the GL 89-10 program by the end of the third refueling
NRC staff issued Supplement 2 to GL 89-10 to allow licensees additional time to


outage or 5 years from the issuance of the generic letter, whichever
review and to incorporate the information provided in Supplement 1 into their


is later. On June 13, 1990, the NRC staff issued Supplement
programs in response to the generic letter. Upon reviewing the results of


1 to GL 89-10 to provide detailed information
NRC-sponsored MOV tests, the NRC staff issued Supplement 3 to GL 89-10 on


on the results of public workshops
October 25, 1990, which requested licensees of boiling water reactor (BWR)
nuclear plants to take action in advance of the GL 89-10 schedule to resolve


held to discuss the generic letter. On August 3, 1990, the NRC staff issued Supplement
concerns about the capability of MOYs used for containment isolation in the


2 to GL 89-10 to allow licensees
steam supply line of the high pressure coolant injection and reactor core


additional
isolation cooling systems, in the supply line of the reactor water cleanup


time to review and to incorporate
system, and in other systems directly connected to the 'reactor vessel. In


the information
4                ek219371 t=      v      dsO]-            qWog          Xe


provided in Supplement
IN 92-17 February 26, 1992 Supplement 4 to GL 89-10, the NRC staff indicated that BWR licensees need not


1 into their programs in response to the generic letter. Upon reviewing
address inadvertent MOY operation in their GL 89-10 programs. The NRC staff is


the results of NRC-sponsored
considering whether or not similar actions should be taken regarding the need


MOV tests, the NRC staff issued Supplement
for licensees of pressurized-water reactor (PWR) nuclear plants to address the


3 to GL 89-10 on October 25, 1990, which requested
inadvertent operation of MOVs in their programs to respond to GL 89-10.


licensees
==Description of Circumstances==
The NRC staff has conducted inspections at more than 30 nuclear power plant


of boiling water reactor (BWR)nuclear plants to take action in advance of the GL 89-10 schedule to resolve concerns about the capability
sites of programs being developed by, licensees in response to GL 89-10. The


of MOYs used for containment
reports of those inspections are available in the NRC Public Document Room. In


isolation
performing the inspections, the NRC staff has followed Temporary Instruction


in the steam supply line of the high pressure coolant injection
(TI) 2515/109 of January 14, 1991, Inspection Requirements for


and reactor core isolation
Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Sur- veillance.' Part 1 of TI 2515/109 provides guidance for reviewing the program


cooling systems, in the supply line of the reactor water cleanup system, and in other systems directly connected
being established.by theLlicensee. in response to GL 89-10, and.Part 2 provides


to the 'reactor vessel. In ek219371 4 t= v dsO]- qWog Xe
guidance for reviewing program implementation. The NRC has focused these


IN 92-17 February 26, 1992 Supplement
inspections on reviewing the GL 89-10 programs (Part 1 of TI 2515/109). The


4 to GL 89-10, the NRC staff indicated
staff is issuing this information notice to provide the more significant
 
that BWR licensees
 
need not address inadvertent
 
MOY operation
 
in their GL 89-10 programs.
 
The NRC staff is considering
 
whether or not similar actions should be taken regarding
 
the need for licensees
 
of pressurized-water
 
reactor (PWR) nuclear plants to address the inadvertent
 
operation
 
of MOVs in their programs to respond to GL 89-10.Description
 
of Circumstances
 
The NRC staff has conducted
 
inspections
 
at more than 30 nuclear power plant sites of programs being developed
 
by, licensees
 
in response to GL 89-10. The reports of those inspections
 
are available
 
in the NRC Public Document Room. In performing
 
the inspections, the NRC staff has followed Temporary
 
Instruction (TI) 2515/109 of January 14, 1991, Inspection
 
Requirements
 
for Generic Letter 89-10, Safety-Related
 
Motor-Operated
 
Valve Testing and Sur-veillance.'
Part 1 of TI 2515/109 provides guidance for reviewing
 
the program being established.by
 
theLlicensee.
 
in response to GL 89-10, and.Part 2 provides guidance for reviewing
 
program implementation.
 
The NRC has focused these inspections
 
on reviewing
 
the GL 89-10 programs (Part 1 of TI 2515/109).
 
The staff is issuing this information
 
notice to provide the more significant


results of those NRC inspections.
results of those NRC inspections.


In GL 89-10, the NRC staff requested
In GL 89-10, the NRC staff requested that licensees prepare descriptions of


that licensees
their programs established in response to GL 89-10 within 1 year after the


prepare descriptions
generic letter was issued or by the first refueling outage after


of their programs established
December 28, 1989, whichever was later. The NRC staff's response to


in response to GL 89-10 within 1 year after the generic letter was issued or by the first refueling
Question 44 in Supplement 1 to GL 89-10 provided guidance on information


outage after December 28, 1989, whichever
expected in the program descriptions. The NRC inspectors found-some licensees


was later. The NRC staff's response to Question 44 in Supplement
to have program descriptions that are thorough while other licensees did not.


1 to GL 89-10 provided guidance on information
Attachment 1 Is a discussion of the inspection findings pertaining to the


expected in the program descriptions.
recommendations of GL 89-10.


The NRC inspectors
===Related Generic Communications===
In addition to NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve


found-some
Testing and Surveillance," and its supplements, the NRC has addressed.this and


licensees to have program descriptions
related topics in NRC Information Notices.89-88, "Recent NRC-Sponsored Testing


that are thorough while other licensees
of Motor-Operated Valves;" 90-40,."Results of NRC-Sponsored Testing of


did not.Attachment
Motor-Operated Valves;" 90-72, "Testing of Parallel Disc Gate Valves in


1 Is a discussion
Europe;" and 91-61, "Preliminary Results of Validation Testing of Motor- Operated Valve Diagnostic Equipment.".


of the inspection
IN 92X17 February 26, 1992 This information notice requires no specific action or written response. If


findings pertaining
you have any questions about the Information in this notice, please contact the


to the recommendations
technical contact listed below or the appropriate Office of Nuclear Reactor


of GL 89-10.Related Generic Communications
Regulation (NRR) project manager.


In addition to NRC Generic Letter 89-10, "Safety-Related
arIes E. Ross  D rec o


Motor-Operated
Division of Operational Events Assessment


Valve Testing and Surveillance," and its supplements, the NRC has addressed.this
and related topics in NRC Information
Notices.89-88, "Recent NRC-Sponsored
Testing of Motor-Operated
Valves;" 90-40,."Results
of NRC-Sponsored
Testing of Motor-Operated
Valves;" 90-72, "Testing of Parallel Disc Gate Valves in Europe;" and 91-61, "Preliminary
Results of Validation
Testing of Motor-Operated Valve Diagnostic
Equipment.".
IN 92X17 February 26, 1992 This information
notice requires no specific action or written response.
If you have any questions
about the Information
in this notice, please contact the technical
contact listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.arIes E. Ross D rec o Division of Operational
===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
Technical contact:  Thomas G. Scarbrough, NRR


contact: Thomas G. Scarbrough, NRR (301) 504-2794 Attachments:
(301) 504-2794 Attachments:
1. Inspection
1. Inspection Findings Pertaining to the Recommendations Contained In


Findings Pertaining
Generic Letter 89-10
2. List of Recently Issued NRC Information Notices


to the Recommendations
Attachment 1 IN 92-17 February 26, 1992 INSPECTION FINDINGS PERTAINING


Contained
TO THE RECOMMENDATIONS CONTAINED IN GENERIC LETTER 89-10


In Generic Letter 89-10 2. List of Recently Issued NRC Information
===Administration===
Some licensees have not ensured adequate management oversight and direction for


Notices
the motor-operated valve (MOY) program. One licensee had contracted an


Attachment
internal audit that revealed problems with the MOY program similar to those


1 IN 92-17 February 26, 1992 INSPECTION
found subsequently during the NRC inspection, but the licensee had not taken


===FINDINGS PERTAINING===
action to correct the deficiencies. The safety significance of the MOV program
TO THE RECOMMENDATIONS


CONTAINED
and the extensive resources needed to develop and implement the program make it


IN GENERIC LETTER 89-10 Administration
imperative that licensee's management closely monitor its staff's activities.


Some licensees
Scope


have not ensured adequate management
In issuirng Generic Letter (GL) 89-10, the NRC staff intended that the scope


oversight
include all safety-related MOVs and other MOVs in safety-related systems. In


and direction
Supplement 1 to GL 89-10, the NRC staff limited the scope of GL 89-10 to


for the motor-operated
safety-related MOYs and other MOVs that are position-changeable in safety- related piping systems, as well as safety-related MOVs that might be in


valve (MOY) program. One licensee had contracted
nonsafety-related piping systems. The NRC staff's response to Questions 3-13 in Supplement 1 to GL 89-10 provided further guidance on the scope of GL 89-10.


an internal audit that revealed problems with the MOY program similar to those found subsequently
For example, in the NRC staff's response to Question 4 in Supplement 1, the


during the NRC inspection, but the licensee had not taken action to correct the deficiencies.
staff defined "position-changeable" as any MOV in a safety-related piping


The safety significance
system that is not blocked from inadvertent operation from the control room.


of the MOV program and the extensive
In Supplement 4 to GL 89-10, the NRC staff indicated that licensees for boiling


resources
water reactor (BWR) plants need not address inadvertent MOV operation in their


needed to develop and implement
GL 89-10 programs. The NRC staff is considering whether or not similar actions


the program make it imperative
should be taken regarding the need for the licensees of pressurized-water


that licensee's
reactor (PWR) plants to address inadvertent MOV operation in their programs to


management
respond to GL 89-10.


closely monitor its staff's activities.
The NRC inspectors found most licensees to be establishing the scope of their


Scope In issuirng Generic Letter (GL) 89-10, the NRC staff intended that the scope include all safety-related
GL 89-10 programs consistent with the recommendations of the generic letter.


MOVs and other MOVs in safety-related
However, some licensees needed to improve the documentation of their justifi- cation for excluding particular MOVs from the GL 89-10 program.


systems. In Supplement
Design-Basis Reviews


1 to GL 89-10, the NRC staff limited the scope of GL 89-10 to safety-related
In recommended action "a" of GL 89-10, the NRC staff requested the licensees to


MOYs and other MOVs that are position-changeable
review and document the design basis for operating each MOV within the generic


in safety-related piping systems, as well as safety-related
letter program to determine the maximum differential pressure and flow (and


MOVs that might be in nonsafety-related
other factors) expected for both normal operations and abnormal conditions.


piping systems. The NRC staff's response to Questions
The NRC staff's response to Questions 14 to 18 and 36 in Supplement 1 to


3-13 in Supplement
GL 89-10 provides guidance on performing design-basis reviews under GL 89-10.


1 to GL 89-10 provided further guidance on the scope of GL 89-10.For example, in the NRC staff's response to Question 4 in Supplement
Many licensees are appropriately reviewing plant documentation such as the


1, the staff defined "position-changeable" as any MOV in a safety-related
final safety analysis report and the technical specifications as part of their


piping system that is not blocked from inadvertent
design-basis reviews. However, some licensees had failed to identify


operation
worst-case conditions for various design-basis scenarios. Some licensees have


from the control room.In Supplement
's.- Attachment 1 IN 92-17 February 26, 1992 assumed nominal reactor pressure for differential pressure across MOVs in lines


4 to GL 89-10, the NRC staff indicated
directly connected to the reactor vessel without evaluating whether this


that licensees
differential pressure bounds the worst-case MOV design-basis differential


for boiling water reactor (BWR) plants need not address inadvertent
pressure. At certain facilities, the licensee found errors in the previous


MOV operation
design basis determinations for many MOVs that would have affected the cap- ability of the MOVs to perform their safety function if called upon under


in their GL 89-10 programs.
design-basis conditions.


The NRC staff is considering
Some licensees focused on differential pressure and had not adequately ad- dressed other design-basis parameters such as flow, fluid temperature, ambient


whether or not similar actions should be taken regarding
temperature, and the effects of seismic and dynamic events. Although differen- tial pressure is the primary design-basis parameter used to predict the thrust


the need for the licensees
requirements in the industry's equations, the other design-basis parameters are


of pressurized-water
needed to ensure that the test results demonstrate that the MOV would operate


reactor (PWR) plants to address inadvertent
under design-basis conditions. Some licensees have not ensured that generic


MOV operation
studies of design-basis differential pressure apply to specific plants.


in their programs to respond to GL 89-10.The NRC inspectors
===MOY Sizing and Switch Settings===
In recommended action "b" of GL 89-10, the NRC staff requested licensees to


found most licensees
review and revise, as necessary, the methods for selecting and setting all MOV


to be establishing
switches. The NRC staff's response to Questions 19-21 in Supplement 1 to


the scope of their GL 89-10 programs consistent
GL 89-10 provides guidance on selecting and setting MOV switches.


with the recommendations
The recommendations of GL 89-10 for selecting and setting MOV switches apply to


of the generic letter.However, some licensees
switches for torque, torque bypass, limit, and thermal overload. The licensees


needed to improve the documentation
are using various methods to determine the proper size of MOVs and their


of their justifi-cation for excluding
appropriate torque switch settings. Some licensees have increased the valve


particular
factors assumed in the industry's equations used to predict the thrust required


MOVs from the GL 89-10 program.Design-Basis
to operate the valves to reflect experience throughout the industry and at


Reviews In recommended
their specific plant. However, other licensees continue to use old guidance


action "a" of GL 89-10, the NRC staff requested
from valve vendors and manufacturers in estimating the thrust requirements that


the licensees
may be found inadequate during design-basis tests.


to review and document the design basis for operating
The NRC inspectors found that licensees for various facilities had not done the


each MOV within the generic letter program to determine
following when establishing methods to size MOVs and set their switches:
(1) Provide justification for assumptions regarding stem friction coefficients


the maximum differential
and changes in stem friction over the lubrication interval


pressure and flow (and other factors) expected for both normal operations
(2) Consider effects that can reduce the thrust delivered by the motor opera- tor under high differential pressure and flow conditions in relation to


and abnormal conditions.
the thrust delivered under no-load conditions


The NRC staff's response to Questions
(3) Consider the effects of ambient temperature on motor output and thermal


14 to 18 and 36 in Supplement
overload sizing


1 to GL 89-10 provides guidance on performing
(4) Demonstrate applicability of industry's databases in predicting thrust


design-basis
requirements
 
reviews under GL 89-10.Many licensees
 
are appropriately
 
reviewing
 
plant documentation
 
such as the final safety analysis report and the technical
 
specifications
 
as part of their design-basis
 
reviews. However, some licensees
 
had failed to identify worst-case
 
conditions
 
for various design-basis
 
scenarios.
 
Some licensees
 
have
 
's.- Attachment
 
1 IN 92-17 February 26, 1992 assumed nominal reactor pressure for differential
 
pressure across MOVs in lines directly connected
 
to the reactor vessel without evaluating
 
whether this differential
 
pressure bounds the worst-case
 
MOV design-basis
 
differential
 
pressure.
 
At certain facilities, the licensee found errors in the previous design basis determinations
 
for many MOVs that would have affected the cap-ability of the MOVs to perform their safety function if called upon under design-basis
 
conditions.
 
Some licensees
 
focused on differential
 
pressure and had not adequately
 
ad-dressed other design-basis
 
parameters
 
such as flow, fluid temperature, ambient temperature, and the effects of seismic and dynamic events. Although differen-tial pressure is the primary design-basis
 
parameter
 
used to predict the thrust requirements
 
in the industry's
 
equations, the other design-basis
 
parameters
 
are needed to ensure that the test results demonstrate
 
that the MOV would operate under design-basis
 
conditions.
 
Some licensees
 
have not ensured that generic studies of design-basis
 
differential
 
pressure apply to specific plants.MOY Sizing and Switch Settings In recommended
 
action "b" of GL 89-10, the NRC staff requested
 
licensees
 
to review and revise, as necessary, the methods for selecting
 
and setting all MOV switches.


The NRC staff's response to Questions
(5) Consider inertia in establishing the maximum settings for torque switches


19-21 in Supplement
Attachment 1 IN 92-17 February 26, 1992 (6) Demonstrate applicability of contractors' studies of actuator capability


1 to GL 89-10 provides guidance on selecting
(7) Demonstrate applicability of generic motor curves for specific motors


and setting MOV switches.The recommendations
(8) Provide justification for removing conservatisms (such as the application


of GL 89-10 for selecting
factor) from the industry's standard sizing calculations
 
and setting MOV switches apply to switches for torque, torque bypass, limit, and thermal overload.
 
The licensees are using various methods to determine
 
the proper size of MOVs and their appropriate
 
torque switch settings.
 
Some licensees
 
have increased
 
the valve factors assumed in the industry's
 
equations
 
used to predict the thrust required to operate the valves to reflect experience
 
throughout
 
the industry and at their specific plant. However, other licensees
 
continue to use old guidance from valve vendors and manufacturers
 
in estimating
 
the thrust requirements
 
that may be found inadequate
 
during design-basis
 
tests.The NRC inspectors
 
found that licensees
 
for various facilities
 
had not done the following
 
when establishing
 
methods to size MOVs and set their switches: (1) Provide justification
 
for assumptions
 
regarding
 
stem friction coefficients
 
and changes in stem friction over the lubrication
 
interval (2) Consider effects that can reduce the thrust delivered
 
by the motor opera-tor under high differential
 
pressure and flow conditions
 
in relation to the thrust delivered
 
under no-load conditions
 
(3) Consider the effects of ambient temperature
 
on motor output and thermal overload sizing (4) Demonstrate
 
applicability
 
of industry's
 
databases
 
in predicting
 
thrust requirements
 
(5) Consider inertia in establishing
 
the maximum settings for torque switches
 
Attachment
 
1 IN 92-17 February 26, 1992 (6) Demonstrate
 
applicability
 
of contractors'
studies of actuator capability
 
(7) Demonstrate
 
applicability
 
of generic motor curves for specific motors (8) Provide justification
 
for removing conservatisms (such as the application
 
factor) from the industry's
 
standard sizing calculations


(9) Consider torque switch repeatability
(9) Consider torque switch repeatability


(10) Consider uncertainties
(10) Consider uncertainties regarding the accuracy of MOV diagnostic equipment.
 
regarding
 
the accuracy of MOV diagnostic
 
equipment.
 
Some licensees
 
have had problems in performing
 
MOV sizing and switch setting calculations
 
because of (1) incorrect
 
spring packs installed
 
in MOVs, (2) incorrect
 
MOV data on the motor or actuator nameplates
 
and in the procure-ment documents
 
from the vendor, and (3) spring packs with different
 
performance


characteristics
Some licensees have had problems in performing MOV sizing and switch setting


from different
calculations because of (1) incorrect spring packs installed in MOVs,
(2) incorrect MOV data on the motor or actuator nameplates and in the procure- ment documents from the vendor, and (3) spring packs with different performance


manufacturers, but with the same part number.One licensee determined
characteristics from different manufacturers, but with the same part number.


that the MOV sizing and switch setting activities
One licensee determined that the MOV sizing and switch setting activities to


to establish
establish motor operator capability had not adequately addressed the effect of


motor operator capability
those activities on other MOY safety functions. These activities had hindered


had not adequately
the ability of the clutch of certain MOYs to be released to enable the MOV to


addressed
be manually operated in the event of an evacuation of the control room.


the effect of those activities
Many licensees are updating their degraded voltage studies to ensure that the


on other MOY safety functions.
worst-case minimum voltage available at the motor has been determined for each


These activities
MOV. Some licensees had not ensured that their assumptions of minimum voltage


had hindered the ability of the clutch of certain MOYs to be released to enable the MOV to be manually operated in the event of an evacuation
available at the MOYs were consistent with their licensing commitments in


of the control room.Many licensees
safety analyses. Some licensees did not justify the assumptions for the


are updating their degraded voltage studies to ensure that the worst-case
starting point for the degraded voltage calculations, current used to calculate


minimum voltage available
cable losses, losses caused by the resistance of thermal overload devices in


at the motor has been determined
the circuit, or the effects on MOV stroke time under degraded voltage condi- tions. Of particular significance, the inspectors found one licensee to be


for each MOV. Some licensees
assuming an excessively small locked-rotor power factor (0.2) in the motor for


had not ensured that their assumptions
use in the calculation of voltage drop from the motor control center to the


of minimum voltage available
MOV. The licensee's selection of this power factor was based on guidance in an


at the MOYs were consistent
Institute of Electrical and Electronics Engineers' standard that was not


with their licensing
applicable to the size of motors typically used to operate valves in nuclear


commitments
power plants. The assumption of an excessively small power factor causes an


in safety analyses.
underestimation of the cable voltage drop and may result in the overestimation


Some licensees
of MOV capability under design-basis conditions.


did not justify the assumptions
Licensees are improving their documentation of current and required MOV switch


for the starting point for the degraded voltage calculations, current used to calculate cable losses, losses caused by the resistance
settings, but some weaknesses remain. For example, one licensee had simplified


of thermal overload devices in the circuit, or the effects on MOV stroke time under degraded voltage condi-tions. Of particular
its control over changes to torque switch settings to expedite the process but, In so doing, caused the concern that the quality assurance department may not


significance, the inspectors
participate adequately in accepting those changes. Some of the weakness in


found one licensee to be assuming an excessively
documenting torque switch settings appears to result from the difficulty in


small locked-rotor
reading the switches. Some licensees have raised torque switch settings for


power factor (0.2) in the motor for use in the calculation
MOVs above the manufacturer's maximum specified value without performing an


of voltage drop from the motor control center to the MOV. The licensee's
adequate safety analysis in accordance with the requirements of 10 CFR 50.59.


selection
-'- Attachment 1 IN 92-17 February 26, 1992 Design-Basis Differential Pressure and Flow Testing


of this power factor was based on guidance in an Institute
In recommended action "c" of GL 89-10, the NRC staff requested


of Electrical
test MOVs within the generic letter program in situ under            licensees to


and Electronics
differential pressure and flow conditions. The NRC staff    their    design-basis


Engineers'
methods to be used to demonstrate the capability of the    allows      alternate
standard that was not applicable


to the size of motors typically
MOV if testing in situ


used to operate valves in nuclear power plants. The assumption
under those conditions is not practicable. The NRC staff


of an excessively
licensees follow a two-stage approach for a situation in suggested that the


small power factor causes an underestimation
testing in situ is not practicable and the licensees couldwhich design-basis


of the cable voltage drop and may result in the overestimation
not justify an


of MOV capability
alternate method of demonstrating MOV capability. In performing


under design-basis
approach, a licensee would evaluate the capability of the              the two-stage


conditions.
data available and then would obtain applicable test data  MOV  using    the best


Licensees
of the generic letter. The NRC staff's response to Questionswithin      the  schedule


are improving
Supplement 1 to GL 89-10 provides guidance on design-basis        22-32    and  37 in


their documentation
two-stage approach.                                          testing    and  the


of current and required MOV switch settings, but some weaknesses
Many licensees have committed to test MOVs within the scope


remain. For example, one licensee had simplified
program under design-basis conditions, where practicable.     of their GL 89-10
                                                              Some


its control over changes to torque switch settings to expedite the process but, In so doing, caused the concern that the quality assurance
indicated that most MOVs can be tested at or near design-basis licensees have


department
Other licensees (primarily those of BWR plants) estimate            conditions.


may not participate
that a much smaller


adequately
percentage of MOVs can be tested at or near design-basis


in accepting
conditions. These


those changes. Some of the weakness in documenting
licensees have not thoroughly evaluated the dbility to conduct


torque switch settings appears to result from the difficulty
design-basis or maximum achievable conditions.                      MOV tests under


in reading the switches.
Licensees who have begun differential pressure and flow testing


Some licensees
MOYs to require more thrust to operate than predicted by              have found some


have raised torque switch settings for MOVs above the manufacturer's
dard equation with typical valve factors (such as 0.3 for the   industry's       stan- flexible      wedge    gate


maximum specified
valves) assumed in the pdst. For example, the Alabama Power


value without performing
licensee of the Joseph M. Farley Nuclear Plant, found less      Company,    the


an adequate safety analysis in accordance
than half of the


with the requirements
55 flexible wedge gate valves tested under differential pressure


of 10 CFR 50.59.
conditions to have their thrust requirements bounded by the            and flow


-'- Attachment
equation with a 0.3 valve factor. The industry's test results  industry's      standard


1 IN 92-17 February 26, 1992 Design-Basis
conclusions of NRC-sponsored MOV research that the industry's      confirm    the


Differential
determining the size of MOYs and setting their torque switches past methods of


Pressure and Flow Testing In recommended
for some MOVs.                                                      were inadequate


action "c" of GL 89-10, the NRC staff requested
The NRC staff has found weaknesses in the licensees' procedures


licensees
the differential pressure and flow tests, the acceptance criteriafor conducting


to test MOVs within the generic letter program in situ under their design-basis
in evaluating the capability of the MOV to perform its safety            for the tests


differential
design-basis conditions, and the process for incorporating        function    under


pressure and flow conditions.
into the methodology used by the licensee in predicting MOY  the  test    results


The NRC staff allows alternate methods to be used to demonstrate
thrust require- ments. The NRC regulations and the plant's technical specifications


the capability
establish requirements for licensees' actions and reporting                  (TS)
equipment is determined to be, or has been, unable to perform  when    safety-related


of the MOV if testing in situ under those conditions
functions. Some licensees did not appear aware of their            its safety


is not practicable.
MOV operability following testing performed under their    obligations      to address


The NRC staff suggested
response to GL 89-10. For example, some licensees have notprograms      established    in


that the licensees
results of MOV tests to verify the capability of the tested    been    evaluating    the


follow a two-stage
their safety functions under design-basis conditions and      MOYs to perform


approach for a situation
adequacy of their methodology to size and set other MOYs.  to  evaluate the


in which design-basis
appeared to discard test data as suspect without careful      Some    licensees


testing in situ is not practicable
evaluation. The NRC


and the licensees
Attachment 1 IN 92-17 February 26, 1992 staff has also found a lack of coordination among licensees in disseminating


could not justify an alternate
and using MOV test data. For example, some licensees are not considering tests


method of demonstrating
conducted by other licensees which might reflect on the adequacy of their


MOV capability.
assumptions in predicting thrust requirements.


In performing
For MOVs that cannot be tested under design-basis differential pressure and


the two-stage approach, a licensee would evaluate the capability
flow conditions, the NRC inspectors have found that some licensees are not


of the MOV using the best data available
following their commitments to the two-stage approach (discussed in


and then would obtain applicable
Supplement 1 to GL 89-10) to test those MOVs at the maximum differential


test data within the schedule of the generic letter. The NRC staff's response to Questions
pressure and flow achievable. If the test pressure and flow are near to the


22-32 and 37 in Supplement
design-basis conditions, the licensee may be able to Justify extrapolating from


1 to GL 89-10 provides guidance on design-basis
the test results to demonstrate the capability of the MOY to perform its safety


testing and the two-stage
function under design-basis conditions. Where the MOV cannot be tested near


approach.Many licensees
design-basis conditions, the licensee can use the results of the test at


have committed
maximum achievable conditions to help confirm valve factor assumptions in its


to test MOVs within the scope of their GL 89-10 program under design-basis
sizing and switch setting methodology and to set the MOV using the best avail- able data. The licensee may also find TS actions and reporting requirements
 
conditions, where practicable.
 
Some licensees
 
have indicated
 
that most MOVs can be tested at or near design-basis
 
conditions.
 
Other licensees (primarily
 
those of BWR plants) estimate that a much smaller percentage
 
of MOVs can be tested at or near design-basis
 
conditions.
 
These licensees
 
have not thoroughly
 
evaluated
 
the dbility to conduct MOV tests under design-basis
 
or maximum achievable
 
conditions.
 
Licensees
 
who have begun differential
 
pressure and flow testing have found some MOYs to require more thrust to operate than predicted
 
by the industry's
 
stan-dard equation with typical valve factors (such as 0.3 for flexible wedge gate valves) assumed in the pdst. For example, the Alabama Power Company, the licensee of the Joseph M. Farley Nuclear Plant, found less than half of the 55 flexible wedge gate valves tested under differential
 
pressure and flow conditions
 
to have their thrust requirements
 
bounded by the industry's
 
standard equation with a 0.3 valve factor. The industry's
 
test results confirm the conclusions
 
of NRC-sponsored
 
MOV research that the industry's
 
past methods of determining
 
the size of MOYs and setting their torque switches were inadequate
 
for some MOVs.The NRC staff has found weaknesses
 
in the licensees'
procedures
 
for conducting
 
the differential
 
pressure and flow tests, the acceptance
 
criteria for the tests in evaluating
 
the capability
 
of the MOV to perform its safety function under design-basis
 
conditions, and the process for incorporating
 
the test results into the methodology
 
used by the licensee in predicting
 
MOY thrust require-ments. The NRC regulations
 
and the plant's technical
 
specifications (TS)establish
 
requirements
 
for licensees'
actions and reporting
 
when safety-related
 
equipment
 
is determined
 
to be, or has been, unable to perform its safety functions.
 
Some licensees
 
did not appear aware of their obligations
 
to address MOV operability
 
following
 
testing performed
 
under their programs established
 
in response to GL 89-10. For example, some licensees
 
have not been evaluating
 
the results of MOV tests to verify the capability
 
of the tested MOYs to perform their safety functions
 
under design-basis
 
conditions
 
and to evaluate the adequacy of their methodology
 
to size and set other MOYs. Some licensees appeared to discard test data as suspect without careful evaluation.
 
The NRC
 
Attachment
 
1 IN 92-17 February 26, 1992 staff has also found a lack of coordination
 
among licensees
 
in disseminating
 
and using MOV test data. For example, some licensees
 
are not considering
 
tests conducted
 
by other licensees
 
which might reflect on the adequacy of their assumptions
 
in predicting
 
thrust requirements.
 
For MOVs that cannot be tested under design-basis
 
differential
 
pressure and flow conditions, the NRC inspectors
 
have found that some licensees
 
are not following
 
their commitments
 
to the two-stage
 
approach (discussed
 
in Supplement
 
1 to GL 89-10) to test those MOVs at the maximum differential
 
pressure and flow achievable.
 
If the test pressure and flow are near to the design-basis
 
conditions, the licensee may be able to Justify extrapolating
 
from the test results to demonstrate
 
the capability
 
of the MOY to perform its safety function under design-basis
 
conditions.
 
Where the MOV cannot be tested near design-basis
 
conditions, the licensee can use the results of the test at maximum achievable
 
conditions
 
to help confirm valve factor assumptions
 
in its sizing and switch setting methodology
 
and to set the MOV using the best avail-able data. The licensee may also find TS actions and reporting
 
requirements


that take effect as a result of tests of MOVs at less than full design-basis
that take effect as a result of tests of MOVs at less than full design-basis


differential
differential pressure and flow conditions if those tests reveal that the MOYs


pressure and flow conditions
could not perform their safety functions under design-basis conditions.


if those tests reveal that the MOYs could not perform their safety functions
Testing MOVs at maximum achievable conditions is especially helpful in estab- lishing a plant-specific database if the licensee estimates that only a small


under design-basis
percentage of 14OVs can be tested at or near design-basis conditions.


conditions.
Some licensees who, in their initial response to GL 89-10, committed to imple- ment the recommendations of GL 89-10 to test MOYs where practicable have


Testing MOVs at maximum achievable
indicated an interest in grouping certain MOVs to reduce the amount of testing


conditions
(although testing of those MOVs would be practicable). Item 1. of GL 89-10
states that licensees shall submit any changes to scheduled commitments, and


is especially
that revised schedules or alternative actions may be implemented without NRC


helpful in estab-lishing a plant-specific
approval with justification retained on site.


database if the licensee estimates
In their initial responses to GL 89-10, some licensees stated that they would


that only a small percentage
attempt to group MOVs to limit the extent of design-basis testing. The prelim- inary results of design-basis tests at several plants (for example, Catawba, Farley, Oconee and Surry) Indicated that apparently identical MOYs performed


of 14OVs can be tested at or near design-basis
significantly different uider high differential pressure and flow conditions.


conditions.
This could cause difficulty in grouping MOVs in such a manner that a small


Some licensees
sample of MOV tests can be used to demonstrate that all MOVs can perform their


who, in their initial response to GL 89-10, committed
safety functions under design-basis conditions.


to imple-ment the recommendations
The motor operators for most gate valves are set to close on torque to provide


of GL 89-10 to test MOYs where practicable
adequate leakage control. Licensees are attempting to develop a method to


have indicated
ensure that MOVs closed using the limit switch meet the requisite leakage


an interest in grouping certain MOVs to reduce the amount of testing (although
limitations in safety analyses without causing an MOV overstress condition.


testing of those MOVs would be practicable).
===Periodic Verification of MOV Capability===
In recommended action 'Id"of GL 89-10, the NRC staff requested that licensees


Item 1. of GL 89-10 states that licensees
prepare or revise procedures to ensure that adequate MOV switch settings are


shall submit any changes to scheduled
Attachment 1 IN 92-17 February 26, 1992 determined and maintained throughout the life of the plant.


commitments, and that revised schedules
of GL 89-10, the NRC staff recommended that the surveillance In paragraph "ij


or alternative
on (1) the safety importance and (2) the maintenance and        interval be based


actions may be implemented
the MOV, but that the interval not exceed 5 years or 3    performance      history of


without NRC approval with justification
refueling outages, whichever is later. Further, the staff stated that the
 
retained on site.In their initial responses
 
to GL 89-10, some licensees
 
stated that they would attempt to group MOVs to limit the extent of design-basis
 
testing. The prelim-inary results of design-basis
 
tests at several plants (for example, Catawba, Farley, Oconee and Surry) Indicated
 
that apparently
 
identical
 
MOYs performed significantly
 
different
 
uider high differential
 
pressure and flow conditions.
 
This could cause difficulty
 
in grouping MOVs in such a manner that a small sample of MOV tests can be used to demonstrate
 
that all MOVs can perform their safety functions
 
under design-basis
 
conditions.
 
The motor operators
 
for most gate valves are set to close on torque to provide adequate leakage control. Licensees
 
are attempting
 
to develop a method to ensure that MOVs closed using the limit switch meet the requisite
 
leakage limitations
 
in safety analyses without causing an MOV overstress
 
condition.
 
Periodic Verification
 
of MOV Capability
 
In recommended
 
action 'Id" of GL 89-10, the NRC staff requested
 
that licensees prepare or revise procedures
 
to ensure that adequate MOV switch settings are
 
Attachment
 
1 IN 92-17 February 26, 1992 determined
 
and maintained
 
throughout
 
the life of the plant. In paragraph "ij of GL 89-10, the NRC staff recommended
 
that the surveillance
 
interval be based on (1) the safety importance
 
and (2) the maintenance
 
and performance
 
history of the MOV, but that the interval not exceed 5 years or 3 refueling
 
outages, whichever
 
is later. Further, the staff stated that the capability
 
of the MOY should be verified if the MOV Is replaced, modified, or overhauled
 
to an extent that the existing test results do not represent
 
the MOV. The NRC staff's response to Questions
 
33-35 and 38 in Supplement
 
1 to GL 89-10 provides guidance on periodically
 
verifying
 
MOY switches and performing
 
tests after completing
 
maintenance.
 
The recommendation
 
of GL 89-10 for verifying
 
periodically
 
the adequacy of MOV switch settings includes torque, torque bypass, limit, and thermal overloads.
 
Many licensees
 
have stdted that they will attempt to use tests of MOVs with diagnostic
 
equipment
 
under zero differential
 
pressure and flow conditions (static conditions)
to demonstrate
 
the adequacy of torque switch settings and the continued


capability
capability


of MOYs to perform their safety functions
should be verified if the MOV Is replaced, modified, or overhauled of the MOY
 
under design-basis
 
conditions.
 
However, to date, none of those licensees
 
have pro-vided justification
 
for applying the results of tests conducted
 
under static conditions


to demonstrate
that the existing test results do not represent the MOV.                to an extent


design-basis
response to Questions 33-35 and 38 in Supplement 1 to GL  The  NRC  staff's


capability.
89-10 provides


These licensees
guidance on periodically verifying MOY switches and performing


appear to be waiting on yet to be developed
completing maintenance.                                            tests after


generic justification
The recommendation of GL 89-10 for verifying periodically


for static or low differential
switch settings includes torque, torque bypass, limit, and the adequacy of MOV


pressure and flow testing.At least one licensee indicated
Many licensees have stdted that they will attempt to use    thermal overloads.


an intent to clean and lubricate
tests of MOVs with


the valve stem before performing
diagnostic equipment under zero differential pressure and


periodic verification
(static conditions) to demonstrate the adequacy of torque flow conditions


testing. This would be inconsistent
the continued capability of MOYs to perform their safety switch settings and


with demonstrating
design-basis conditions. However, to date, none of those functions under


that the MOV had been set adequately
licensees have pro- vided justification for applying the results of tests conducted


and was capable of performing
conditions to demonstrate design-basis capability. These            under static


its function at the end of the test interval.In GL 89-10, the NRC staff stated that testing at design-basis
licensees      appear to


conditions
be waiting on yet to be developed generic justification for


need not be repeated unless the MOV is replaced, modified, or overhauled
differential pressure and flow testing.                      static    or   low


to the extent that the licensee considers
At least one licensee indicated an intent to clean and lubricate


that the existing test results are not representative
before performing periodic verification testing. This would            the valve stem


of the MOV in its modified configuration.
with demonstrating that the MOV had been set adequately        be    inconsistent


Many licensees
performing its function at the end of the test interval. and was capable of


are improving
In GL 89-10, the NRC staff stated that testing at design-basis


their methods to demonstrate
not be repeated unless the MOV is replaced, modified, or            conditions need


that the MOVs are capable of performing
extent that the licensee considers that the existing test  overhauled      to the


their safety functions
representative of the MOV in its modified configuration.    results    are  not


under design-basis
Many


conditions
improving their methods to demonstrate that the MOVs are capable    licensees    are


following
their safety functions under design-basis conditions following         of  performing


maintenance.
maintenance.


MOV Failures, Corrective
MOV Failures, Corrective Actions, and Trending


Actions, and Trending In recommended
In recommended action "h" of GL 89-10, the NRC staff requested


action "h" of GL 89-10, the NRC staff requested
analyze or justify each MOV failure and corrective action.        that licensees


that licensees analyze or justify each MOV failure and corrective
requested that the documentation include the results and     The    staff also


action. The staff also requested
history


that the documentation
as-found deteriorated condition, malfunction, test, inspection, of each


include the results and history of each as-found deteriorated
repair, or alteration. The staff noted that the licensee            analysis, report all documentation in accordance with the plant's      must  retain    and


condition, malfunction, test, inspection, analysis, repair, or alteration.
staff also suggested that the material be examined every requirements.         The


The staff noted that the licensee must retain and report all documentation
2 years or after each


in accordance
refueling outage after the program is Implemented as part


with the plant's requirements.
of the monitoring and


The staff also suggested
feedback effort to establish trends of MOV operability.


that the material be examined every 2 years or after each refueling
provide the basis on which the licensee can revise the    These    trends could


outage after the program is Implemented
testing frequency


as part of the monitoring
established to verify periodically that the MOV has adequate


and feedback effort to establish
NRC staff indicated that the system should be well-structured capability. The


trends of MOV operability.
capture, and share history datd on individual components.         and should track, response to Questions 39 and 40 in Supplement 1 to GL 89-10  The  NRC staff's


These trends could provide the basis on which the licensee can revise the testing frequency established
on identifying trends of MOV problems.                        provides      guidance


to verify periodically
Attachment 1 IN 92-17 February 26, 1992 The NRC inspectors have found some licensees to have weaknesses in evaluating


that the MOV has adequate capability.
MOV failures and deficiencies (such as the operability effects of spring pack


The NRC staff indicated
relaxation). Some licensees have not been thorough in performing root cause


that the system should be well-structured
analyses of MOY problems. Most licensees are attempting to improve their


and should track, capture, and share history datd on individual
methods for identifying trends in MOY problems.


components.
Schedule


The NRC staff's response to Questions
In GL 89-10, the NRC staff requested that, by June 28, 1994, or by the third


39 and 40 in Supplement
refueling outage after December 28, 1989, whichever is later, licensees com- plete all design-basis reviews, analyses, verifications, tests, and inspections


1 to GL 89-10 provides guidance on identifying
that were initiated in order to satisfy the actions recommended in the generic


trends of MOV problems.
letter. The NRC staff's response to Question 41 in Supplement 1 to GL 89-10
provides guidance on the schedule for implementing these actions specified in


Attachment
GL 89-10.


1 IN 92-17 February 26, 1992 The NRC inspectors
Some licensees have not made adequate progress for resolving the MOV issue for


have found some licensees
their facilities within the recommended schedule of GL 89-10. The findings of


to have weaknesses
licensees as they begin to initiate their programs in response to GL 89-10 and


in evaluating
the results of the NRC inspections of GL 89-10 programs reinforce the impor- tance of promptly resolving this safety-significant issue. The NRC staff has


MOV failures and deficiencies (such as the operability
accepted limited extensions of the GL 89-10 schedule for particular licensees


effects of spring pack relaxation).
who have provided Justification.


Some licensees
I    emnt2 February 26. 1992 Pap 1 of I


have not been thorough in performing
LIST OF RECEITLY ISSUED


root cause analyses of MOY problems.
NRCIIIFORITION NOTICES


Most licensees
Information                                    Date of


are attempting
notice No..          Subject                    Issuance  Issued to


to improve their methods for identifying
92-16          Loss of Flow from the            02/25192  All holders of OLs or CPs


trends in MOY problems.Schedule In GL 89-10, the NRC staff requested
Residual Heat Removal                      for nuclear power reactors.


that, by June 28, 1994, or by the third refueling
Pump during Refueling


outage after December 28, 1989, whichever
Cavity Dr"indown


is later, licensees
92-15          Failure of Primary System        02/24/92  All holders of OLs or CPs


com-plete all design-basis
Compression Fitting                        for nuclear power reactors.


reviews, analyses, verifications, tests, and inspections
92-14          Uranium Oxide Fires at Fuel      02/21/92  All fuel cycle and uranium


that were initiated
Cycle Facilities                          fuel research and development


in order to satisfy the actions recommended
licensees.
 
in the generic letter. The NRC staff's response to Question 41 in Supplement
 
1 to GL 89-10 provides guidance on the schedule for implementing
 
these actions specified
 
in GL 89-10.Some licensees
 
have not made adequate progress for resolving
 
the MOV issue for their facilities
 
within the recommended


schedule of GL 89-10. The findings of licensees
92-02.         RelapS/Hod3 Computer Code        02/19/92  All holders of OLs or CPs


as they begin to initiate their programs in response to GL 89-10 and the results of the NRC inspections
Supp. I        Error Associated with the                 for nuclear power reactors.


of GL 89-10 programs reinforce
Conservation of Energy


the impor-tance of promptly resolving
Equation


this safety-significant
92-13          Inadequate Control Over          02/18/92  All holders of OLs or CPs


issue. The NRC staff has accepted limited extensions
Vehicular Traffic at'                      for nuclear power reactors.


of the GL 89-10 schedule for particular
Nuclear Power Plant Sites


licensees who have provided Justification.
92-12          Effects of Cable Leakage        02/10/92. All holders of OLs or CPs


I emnt2 February 26. 1992 Pap 1 of I LIST OF RECEITLY ISSUED NRC IIIFORITION
Currents on Instrument                    for nuclear power reactors.


===NOTICES Information===
Settings and Indications
notice No.. Subject 92-16 Loss of Flow from the Residual Heat Removal Pump during Refueling Cavity Dr"indown 92-15 Failure of Primary System Compression


Fitting 92-14 Uranium Oxide Fires at Fuel Cycle Facilities
92-11          Soll and hater Contamina-        02/05/92  All uranium fuel fabrica- tion at Fuel Cycle Facil-                  tion and conversion facil- ities                                      ities.


92-02. RelapS/Hod3 Computer Code Supp. I Error Associated
92-10          8rachytherapy Incidents          01/31/92  AlI luclear Regulatory Com- Involving Irdium-192 Wire -                mission (NRC) licensees


with the Conservation
Used i Endobronchisl                      authorized to use


of Energy Equation 92-13 Inadequate
Treatments                                iridium-192 for brachy- therapyi manufacturers and


Control Over Vehicular
distributors of iridiu-I92 wire for use in brachy- therapy.


Traffic at'Nuclear Power Plant Sites 92-12 Effects of Cable Leakage Currents on Instrument
OL


===Settings and Indications===
* Operating License
92-11 Soll and hater Contamina- tion at Fuel Cycle Facil-ities 92-10 8rachytherapy


Incidents Involving
CP


Irdium-192 Wire -Used i Endobronchisl
* Construction Permit


Treatments
UNITED STATES


Date of Issuance 02/25192 Issued to All holders of OLs or CPs for nuclear power reactors.02/24/92 All holders of OLs or CPs for nuclear power reactors.02/21/92 All fuel cycle and uranium fuel research and development
NUCLEAR REGULATORY COMMISSION                                                                                      POSTAGE FEES PAID


licensees.
WASHINGTON, D.C. 20555                                                                                              UMNO


02/19/92 All holders of OLs or CPs for nuclear power reactors.02/18/92 All holders of OLs or CPs for nuclear power reactors.02/10/92.
nIEM No. 0J


All holders of OLs or CPs for nuclear power reactors.02/05/92 All uranium fuel fabrica-tion and conversion
OFFICIAL BUSINESS


facil-ities.01/31/92 AlI luclear Regulatory
PENALTY FOR PRIVATE USE, $300


Com-mission (NRC) licensees authorized
IN 92-17 February 26, 1992 This information notice requires no specific action or written response. If


to use iridium-192 for brachy-therapyi manufacturers
you have any questions about the information in this notice, please contact the


and distributors
technical contact listed below or the appropriate Office of Nuclear Reactor


of iridiu-I92 wire for use in brachy-therapy.OL
Regulation (NRR) project manager.


* Operating
Charles E. Rossi, Director


License CP
Division of Operational Events Assessment


* Construction
Permit UNITED STATES NUCLEAR REGULATORY
COMMISSION
WASHINGTON, D.C. 20555 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 POSTAGE FEES PAID UMNO nIEM No. 0J
IN 92-17 February 26, 1992 This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact the technical
contact listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
Technical contact:   Thomas G. Scarbrough, NRR
 
contact: Thomas G. Scarbrough, NRR (301) 504-2794 Attachments:
1. Inspection
 
Findings Pertaining


to the Recommendations
(301) 504-2794 Attachments:
1. Inspection Findings Pertaining to the Recommendations Contained In


Contained
Generic Letter 89-10
2. List of Recently Issued NRC Information Notices


In Generic Letter 89-10 2. List of Recently Issued NRC Information
Document Name: GL 89-10 INSPECTION RESULTS IN


Notices Document Name: GL 89-10*SEE PREVIOUS CONCURRENCES
*SEE PREVIOUS CONCURRENCES


INSPECTION
*C/OGCB:DOEA:NRR
 
RESULTS IN*C/OGCB:DOEA:NRR


CHBerlinger
CHBerlinger


02/11/92'*RPB:ADM TechEd 01/14/92*OGCB:DOEA:NRR
02/11/92
 
  *OGCB:DOEA:NRR      *EMEB:DET:NRR   *C/EMEB:DET:NRR*D/DET:NRR    '*RPB:ADM
RJKiessel 01/14/92*EMEB:DET:NRR


===TGScarbrough===
RJKiessel            TGScarbrough   JANorberg      JERlchardson    TechEd
01/09/92*C/EMEB:DET:NRR*D/DET:NRR


JANorberg
01/14/92            01/09/92      01/13/92      01/29/92        01/14/92


===JERlchardson===
IN 92-XX
01/13/92 01/29/92 IN 92-XX February xx, 1992 This information


notice requires no specific action or written response.
February xx, 1992 This information notice requires no specific action or written response. If


If you have any questions
you have any questions about the information in this notice, please contact the


about the information
technical contact listed below or the appropriate Office of Nuclear Reactor


in this notice, please contact the technical
Regulation (NRR) project manager.


contact listed below or the appropriate
Charles E. Rossi, Director


Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Division of Operational Events Assessment


===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
Technical contact:   Thomas G. Scarbrough, NRR
 
contact: Thomas G. Scarbrough, NRR (301) 504-2794 Attachments:
1. Inspection
 
Findings Pertaining
 
to the Recommendations
 
Contained
 
In Generic Letter 89-10 2. Inspection
 
Findings Pertaining
 
to Other MOY Areas 3. List of Recently Issued NRC Information


Notices Document Name: GL 89-10 INSPECTION
(301) 504-2794 Attachments:
1. Inspection Findings Pertaining to the Recommendations Contained In


RESULTS IN*SEE PREVIOUS CONCURRENCES
Generic Letter 89-10
2.  Inspection Findings Pertaining to Other MOY Areas


D/DOEA:NRR
3. List of Recently Issued NRC Information Notices


CERossi 02/ /92*C/EMEB:DET:NRR*D/DET:NRR
Document Name: GL 89-10 INSPECTION RESULTS IN


JANorberg
*SEE PREVIOUS CONCURRENCES


===JERichardson===
D/DOEA:NRR  *C/OGCB:DOEA:NR11! -
01/13/92 01/29/92*C/OGCB:DOEA:NR
                                                      CERossi      CHBerlinger        -0
                                                      02/ /92       01/31/92             A


11! -CHBerlinger
*OGCB:DOEA:NRR      *EMEB:DET:NRR *C/EMEB:DET:NRR*D/DET:NRR      *RPB:ADM


-0 01/31/92 A*RPB:ADM TechEd 01/14/92*OGCB:DOEA:NRR
RJKiessel            TGScarbrough  JANorberg      JERichardson TechEd


RJKiessel 01/14/92*EMEB:DET:NRR
01/14/92             01/09/92      01/13/92      01/29/92      01/14/92


===TGScarbrough===
IN 92-XX
01/09/92 IN 92-XX January xx, 1992 This information


notice requires no specific action or written response.
January xx, 1992 This information notice requires no specific action or written response. If


If you have any questions
you have any questions about the information in this notice, please contact the


about the information
technical contact listed below or the appropriate Office of Nuclear Reactor


in this notice, please contact the technical
Regulation (NRR) project manager.


contact listed below or the appropriate
Charles E. Rossi, Director


Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Division of Operational Events Assessment


===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
Technical contact:   Thomas G. Scarbrough, NRR
 
contact: Thomas G. Scarbrough, NRR (301) 504-2794 Attachments:
1. Inspection
 
Findings Pertaining


to the Recommendations
(301) 504-2794 Attachments:
1. Inspection Findings Pertaining to the Recommendations Contained In


Contained
Generic Letter 89-10
2. Inspection Findings Pertaining to Other MOV Areas


In Generic Letter 89-10 2. Inspection
3. List of Recently Issued NRC Information Notices


Findings Pertaining
Document Name: GL 89-10 INSPECTION RESULTS IN


to Other MOV Areas 3. List of Recently Issued NRC Information
*SEE PREVIOUS CONCURRENCES                                                    ---- -'11/
                                                    D/DOEA:NRR    C/OGCB:DOEA:N    Zg;
                                                    CERossi    HBerlinger              to


Notices Document Name: GL 89-10 INSPECTION
01/ /92    /  0lL1/92
*OGCB:DOEA:NRR    *EMEB:DET:NRR *C/EMEB:DET:NRR D/DE tAJg*RPF.ADM


RESULTS IN*SEE PREVIOUS CONCURRENCES
RJKiessel          TGScarbrough  JANorberg      JER i d d q TechEd


---- -'11/*OGCB:DOEA:NRR
01/14/92            01/09/92      01/13/92  Ad 01//            01/14/92


RJKiessel 01/14/92*EMEB:DET:NRR
Charles E. Rossi, Director


===TGScarbrough===
Division of Operational Events Assessment
01/09/92 D/DOEA:NRR


C/OGCB:DOEA:N
Zg;CERossi HBerlinger
to 01/ /92 / 0lL1/92*C/EMEB:DET:NRR
D/DE tAJg *RPF.ADM JANorberg
JER i d d q TechEd 01/13/92 Ad 0 1// 01/14/92 Charles E. Rossi, Director Division of Operational
===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
Technical contact:   Thomas G. Scarbrough, NRR
 
contact: Thomas G. Scarbrough, NRR (301) 504-2794 Attachments:
1. Inspection
 
Findings Pertaining
 
to the Recommendations


Contained
(301) 504-2794 Attachments:
1. Inspection Findings Pertaining to the Recommendations Contained In


In Generic Letter 89-10 2. Inspection
Generic Letter 89-10
2. Inspection Findings Pertaining to Other MOV Areas


Findings Pertaining
3. List of Recently Issued NRC Information Notices


to Other MOV Areas 3. List of Recently Issued NRC Information
Document Name:  GL 89-10 INSPECTION RESULTS IN


Notices Document Name: GL 89-10 INSPECTION
D/DOEA:NRR  C/OGCB:DOEA:NRR


RESULTS IN D/DOEA:NRR
CERossi      CHBerlinger


CERossi Ol/ /92 D/DET: NRR JERichardson
Ol/ /92     01/  /92 OGCB:DOEA:NRR        EMEB:DET:NRR    C/EMEB:DET:NRR D/DET: NRR   RPB:ADM


01/ /92 C/OGCB:DOEA:NRR
RJKiessel            TGScarbrough    JANorberg      JERichardson TechEd 1Miain 91
01/   /92           01/  /92        01/  /92      01/  /92    01/jq/92


CHBerlinger
Charles E. Rossi, Director


01/ /92 RPB:ADM TechEd 1Miain 91 01/jq/92 OGCB:DOEA:NRR
Division of Operational Events Assessment


RJKiessel 01/ /92 EMEB:DET:NRR
===TGScarbrough===
01/ /92 C/EMEB:DET:NRR
JANorberg 01/ /92 Charles E. Rossi, Director Division of Operational
===Events Assessment===
Office of Nuclear Reactor Regulation
Office of Nuclear Reactor Regulation


Technical
Technical contact:   Thomas G. Scarbrough, NRR
 
contact: Thomas G. Scarbrough, NRR (301) 504-2794 Attachments:
1. Inspection
 
Findings Pertaining
 
to the Recommendations
 
Contained
 
In Generic Letter 89-10 2. Inspection
 
Findings Pertaining
 
to Other MOV Areas 3. List of Recently Issued NRC Information
 
Notices Document Name: GL 89-10 INSPECTION


RESULTS IN D/DOEA:NRR
(301) 504-2794 Attachments:
1. Inspection Findings Pertaining to the Recommendations Contained In


CERossi 01/ /92 D/DET:NRR JERicharoson
Generic Letter 89-10
2. Inspection Findings Pertaining to Other MOV Areas


01/ /92 C/OGCB:DOEA:NRR
3. List of Recently Issued NRC Information Notices
 
CHBerlinger


01/ /92 RPB:ADM TechEd JIMahl97 01//q/92 OGCB:DOEA:NRR
Document Name:   GL 89-10 INSPECTION RESULTS IN


RJKiessel
D/DOEA:NRR  C/OGCB:DOEA:NRR


L 01/fl/9 2 EMEB:DET:NRR
CERossi      CHBerlinger


===TGScarbrough===
01/ /92     01/  /92 OGCB:DOEA:NRR        EMEB:DET:NRR    C/EMEB:DET:NRR D/DET:NRR    RPB:ADM
01/ /92 C/EMEB:DET:NRR


JANorberg 01/ /92}}
RJKiessel      L    TGScarbrough    JANorberg     JERicharoson TechEd  JIMahl97
01/fl/ 92            01/  /92        01/  /92      01/  /92      01//q/92}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 03:20, 24 November 2019

NRC Inspections of Programs Being Developed at Nuclear Power Plants in Response to Generic Letter 89-10
ML031200576
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 02/26/1992
From: Rossi C
Office of Nuclear Reactor Regulation
To:
References
GL-89-010 IN-92-017, NUDOCS 9202190371
Download: ML031200576 (16)


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555 February 26, 1992 NRC INFORMATION NOTICE 92-17: NRC INSPECTIONS OF PROGRAMS BEING DEVELOPED

AT NUCLEAR POWER PLANTS IN RESPONSE TO

GENERIC LETTER 89-10

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice

to alert addressees to the general conclusions derived from the NRC inspections

of the programs being developed at nuclear power plants in response to

Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and

Surveillance." It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to

avoid similar problems. However, suggestions contained in this information

notice are not NRC requirements; therefore, no specific action or written

response is required.

Background

In GL 89-10 (June 28, 1989), the NRC staff requested that holders of nuclear

power plant operating licenses and construction permits ensure the capability

of motor-operated valves (MOVs) in safety-related systems by reviewing MOV

design bases, verifying MOV switch settings initially and periodically, testing

MOYs under design basis conditions where practicable, improving evaluations of

MOV failures and necessary corrective action, and determining trends of MOV

problems. The NRC staff requested that licensees complete the GL 89-10 program

by the end of the third refueling outage or 5 years from the issuance of the

generic letter, whichever is later. On June 13, 1990, the NRC staff issued

Supplement 1 to GL 89-10 to provide detailed information on the results of

public workshops held to discuss the generic letter. On August 3, 1990, the

NRC staff issued Supplement 2 to GL 89-10 to allow licensees additional time to

review and to incorporate the information provided in Supplement 1 into their

programs in response to the generic letter. Upon reviewing the results of

NRC-sponsored MOV tests, the NRC staff issued Supplement 3 to GL 89-10 on

October 25, 1990, which requested licensees of boiling water reactor (BWR)

nuclear plants to take action in advance of the GL 89-10 schedule to resolve

concerns about the capability of MOYs used for containment isolation in the

steam supply line of the high pressure coolant injection and reactor core

isolation cooling systems, in the supply line of the reactor water cleanup

system, and in other systems directly connected to the 'reactor vessel. In

4 ek219371 t= v dsO]- qWog Xe

IN 92-17 February 26, 1992 Supplement 4 to GL 89-10, the NRC staff indicated that BWR licensees need not

address inadvertent MOY operation in their GL 89-10 programs. The NRC staff is

considering whether or not similar actions should be taken regarding the need

for licensees of pressurized-water reactor (PWR) nuclear plants to address the

inadvertent operation of MOVs in their programs to respond to GL 89-10.

Description of Circumstances

The NRC staff has conducted inspections at more than 30 nuclear power plant

sites of programs being developed by, licensees in response to GL 89-10. The

reports of those inspections are available in the NRC Public Document Room. In

performing the inspections, the NRC staff has followed Temporary Instruction

(TI) 2515/109 of January 14, 1991, Inspection Requirements for

Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Sur- veillance.' Part 1 of TI 2515/109 provides guidance for reviewing the program

being established.by theLlicensee. in response to GL 89-10, and.Part 2 provides

guidance for reviewing program implementation. The NRC has focused these

inspections on reviewing the GL 89-10 programs (Part 1 of TI 2515/109). The

staff is issuing this information notice to provide the more significant

results of those NRC inspections.

In GL 89-10, the NRC staff requested that licensees prepare descriptions of

their programs established in response to GL 89-10 within 1 year after the

generic letter was issued or by the first refueling outage after

December 28, 1989, whichever was later. The NRC staff's response to

Question 44 in Supplement 1 to GL 89-10 provided guidance on information

expected in the program descriptions. The NRC inspectors found-some licensees

to have program descriptions that are thorough while other licensees did not.

Attachment 1 Is a discussion of the inspection findings pertaining to the

recommendations of GL 89-10.

Related Generic Communications

In addition to NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve

Testing and Surveillance," and its supplements, the NRC has addressed.this and

related topics in NRC Information Notices.89-88, "Recent NRC-Sponsored Testing

of Motor-Operated Valves;" 90-40,."Results of NRC-Sponsored Testing of

Motor-Operated Valves;" 90-72, "Testing of Parallel Disc Gate Valves in

Europe;" and 91-61, "Preliminary Results of Validation Testing of Motor- Operated Valve Diagnostic Equipment.".

IN 92X17 February 26, 1992 This information notice requires no specific action or written response. If

you have any questions about the Information in this notice, please contact the

technical contact listed below or the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

arIes E. Ross D rec o

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical contact: Thomas G. Scarbrough, NRR

(301) 504-2794 Attachments:

1. Inspection Findings Pertaining to the Recommendations Contained In

Generic Letter 89-10

2. List of Recently Issued NRC Information Notices

Attachment 1 IN 92-17 February 26, 1992 INSPECTION FINDINGS PERTAINING

TO THE RECOMMENDATIONS CONTAINED IN GENERIC LETTER 89-10

Administration

Some licensees have not ensured adequate management oversight and direction for

the motor-operated valve (MOY) program. One licensee had contracted an

internal audit that revealed problems with the MOY program similar to those

found subsequently during the NRC inspection, but the licensee had not taken

action to correct the deficiencies. The safety significance of the MOV program

and the extensive resources needed to develop and implement the program make it

imperative that licensee's management closely monitor its staff's activities.

Scope

In issuirng Generic Letter (GL) 89-10, the NRC staff intended that the scope

include all safety-related MOVs and other MOVs in safety-related systems. In

Supplement 1 to GL 89-10, the NRC staff limited the scope of GL 89-10 to

safety-related MOYs and other MOVs that are position-changeable in safety- related piping systems, as well as safety-related MOVs that might be in

nonsafety-related piping systems. The NRC staff's response to Questions 3-13 in Supplement 1 to GL 89-10 provided further guidance on the scope of GL 89-10.

For example, in the NRC staff's response to Question 4 in Supplement 1, the

staff defined "position-changeable" as any MOV in a safety-related piping

system that is not blocked from inadvertent operation from the control room.

In Supplement 4 to GL 89-10, the NRC staff indicated that licensees for boiling

water reactor (BWR) plants need not address inadvertent MOV operation in their

GL 89-10 programs. The NRC staff is considering whether or not similar actions

should be taken regarding the need for the licensees of pressurized-water

reactor (PWR) plants to address inadvertent MOV operation in their programs to

respond to GL 89-10.

The NRC inspectors found most licensees to be establishing the scope of their

GL 89-10 programs consistent with the recommendations of the generic letter.

However, some licensees needed to improve the documentation of their justifi- cation for excluding particular MOVs from the GL 89-10 program.

Design-Basis Reviews

In recommended action "a" of GL 89-10, the NRC staff requested the licensees to

review and document the design basis for operating each MOV within the generic

letter program to determine the maximum differential pressure and flow (and

other factors) expected for both normal operations and abnormal conditions.

The NRC staff's response to Questions 14 to 18 and 36 in Supplement 1 to

GL 89-10 provides guidance on performing design-basis reviews under GL 89-10.

Many licensees are appropriately reviewing plant documentation such as the

final safety analysis report and the technical specifications as part of their

design-basis reviews. However, some licensees had failed to identify

worst-case conditions for various design-basis scenarios. Some licensees have

's.- Attachment 1 IN 92-17 February 26, 1992 assumed nominal reactor pressure for differential pressure across MOVs in lines

directly connected to the reactor vessel without evaluating whether this

differential pressure bounds the worst-case MOV design-basis differential

pressure. At certain facilities, the licensee found errors in the previous

design basis determinations for many MOVs that would have affected the cap- ability of the MOVs to perform their safety function if called upon under

design-basis conditions.

Some licensees focused on differential pressure and had not adequately ad- dressed other design-basis parameters such as flow, fluid temperature, ambient

temperature, and the effects of seismic and dynamic events. Although differen- tial pressure is the primary design-basis parameter used to predict the thrust

requirements in the industry's equations, the other design-basis parameters are

needed to ensure that the test results demonstrate that the MOV would operate

under design-basis conditions. Some licensees have not ensured that generic

studies of design-basis differential pressure apply to specific plants.

MOY Sizing and Switch Settings

In recommended action "b" of GL 89-10, the NRC staff requested licensees to

review and revise, as necessary, the methods for selecting and setting all MOV

switches. The NRC staff's response to Questions 19-21 in Supplement 1 to

GL 89-10 provides guidance on selecting and setting MOV switches.

The recommendations of GL 89-10 for selecting and setting MOV switches apply to

switches for torque, torque bypass, limit, and thermal overload. The licensees

are using various methods to determine the proper size of MOVs and their

appropriate torque switch settings. Some licensees have increased the valve

factors assumed in the industry's equations used to predict the thrust required

to operate the valves to reflect experience throughout the industry and at

their specific plant. However, other licensees continue to use old guidance

from valve vendors and manufacturers in estimating the thrust requirements that

may be found inadequate during design-basis tests.

The NRC inspectors found that licensees for various facilities had not done the

following when establishing methods to size MOVs and set their switches:

(1) Provide justification for assumptions regarding stem friction coefficients

and changes in stem friction over the lubrication interval

(2) Consider effects that can reduce the thrust delivered by the motor opera- tor under high differential pressure and flow conditions in relation to

the thrust delivered under no-load conditions

(3) Consider the effects of ambient temperature on motor output and thermal

overload sizing

(4) Demonstrate applicability of industry's databases in predicting thrust

requirements

(5) Consider inertia in establishing the maximum settings for torque switches

Attachment 1 IN 92-17 February 26, 1992 (6) Demonstrate applicability of contractors' studies of actuator capability

(7) Demonstrate applicability of generic motor curves for specific motors

(8) Provide justification for removing conservatisms (such as the application

factor) from the industry's standard sizing calculations

(9) Consider torque switch repeatability

(10) Consider uncertainties regarding the accuracy of MOV diagnostic equipment.

Some licensees have had problems in performing MOV sizing and switch setting

calculations because of (1) incorrect spring packs installed in MOVs,

(2) incorrect MOV data on the motor or actuator nameplates and in the procure- ment documents from the vendor, and (3) spring packs with different performance

characteristics from different manufacturers, but with the same part number.

One licensee determined that the MOV sizing and switch setting activities to

establish motor operator capability had not adequately addressed the effect of

those activities on other MOY safety functions. These activities had hindered

the ability of the clutch of certain MOYs to be released to enable the MOV to

be manually operated in the event of an evacuation of the control room.

Many licensees are updating their degraded voltage studies to ensure that the

worst-case minimum voltage available at the motor has been determined for each

MOV. Some licensees had not ensured that their assumptions of minimum voltage

available at the MOYs were consistent with their licensing commitments in

safety analyses. Some licensees did not justify the assumptions for the

starting point for the degraded voltage calculations, current used to calculate

cable losses, losses caused by the resistance of thermal overload devices in

the circuit, or the effects on MOV stroke time under degraded voltage condi- tions. Of particular significance, the inspectors found one licensee to be

assuming an excessively small locked-rotor power factor (0.2) in the motor for

use in the calculation of voltage drop from the motor control center to the

MOV. The licensee's selection of this power factor was based on guidance in an

Institute of Electrical and Electronics Engineers' standard that was not

applicable to the size of motors typically used to operate valves in nuclear

power plants. The assumption of an excessively small power factor causes an

underestimation of the cable voltage drop and may result in the overestimation

of MOV capability under design-basis conditions.

Licensees are improving their documentation of current and required MOV switch

settings, but some weaknesses remain. For example, one licensee had simplified

its control over changes to torque switch settings to expedite the process but, In so doing, caused the concern that the quality assurance department may not

participate adequately in accepting those changes. Some of the weakness in

documenting torque switch settings appears to result from the difficulty in

reading the switches. Some licensees have raised torque switch settings for

MOVs above the manufacturer's maximum specified value without performing an

adequate safety analysis in accordance with the requirements of 10 CFR 50.59.

-'- Attachment 1 IN 92-17 February 26, 1992 Design-Basis Differential Pressure and Flow Testing

In recommended action "c" of GL 89-10, the NRC staff requested

test MOVs within the generic letter program in situ under licensees to

differential pressure and flow conditions. The NRC staff their design-basis

methods to be used to demonstrate the capability of the allows alternate

MOV if testing in situ

under those conditions is not practicable. The NRC staff

licensees follow a two-stage approach for a situation in suggested that the

testing in situ is not practicable and the licensees couldwhich design-basis

not justify an

alternate method of demonstrating MOV capability. In performing

approach, a licensee would evaluate the capability of the the two-stage

data available and then would obtain applicable test data MOV using the best

of the generic letter. The NRC staff's response to Questionswithin the schedule

Supplement 1 to GL 89-10 provides guidance on design-basis 22-32 and 37 in

two-stage approach. testing and the

Many licensees have committed to test MOVs within the scope

program under design-basis conditions, where practicable. of their GL 89-10

Some

indicated that most MOVs can be tested at or near design-basis licensees have

Other licensees (primarily those of BWR plants) estimate conditions.

that a much smaller

percentage of MOVs can be tested at or near design-basis

conditions. These

licensees have not thoroughly evaluated the dbility to conduct

design-basis or maximum achievable conditions. MOV tests under

Licensees who have begun differential pressure and flow testing

MOYs to require more thrust to operate than predicted by have found some

dard equation with typical valve factors (such as 0.3 for the industry's stan- flexible wedge gate

valves) assumed in the pdst. For example, the Alabama Power

licensee of the Joseph M. Farley Nuclear Plant, found less Company, the

than half of the

55 flexible wedge gate valves tested under differential pressure

conditions to have their thrust requirements bounded by the and flow

equation with a 0.3 valve factor. The industry's test results industry's standard

conclusions of NRC-sponsored MOV research that the industry's confirm the

determining the size of MOYs and setting their torque switches past methods of

for some MOVs. were inadequate

The NRC staff has found weaknesses in the licensees' procedures

the differential pressure and flow tests, the acceptance criteriafor conducting

in evaluating the capability of the MOV to perform its safety for the tests

design-basis conditions, and the process for incorporating function under

into the methodology used by the licensee in predicting MOY the test results

thrust require- ments. The NRC regulations and the plant's technical specifications

establish requirements for licensees' actions and reporting (TS)

equipment is determined to be, or has been, unable to perform when safety-related

functions. Some licensees did not appear aware of their its safety

MOV operability following testing performed under their obligations to address

response to GL 89-10. For example, some licensees have notprograms established in

results of MOV tests to verify the capability of the tested been evaluating the

their safety functions under design-basis conditions and MOYs to perform

adequacy of their methodology to size and set other MOYs. to evaluate the

appeared to discard test data as suspect without careful Some licensees

evaluation. The NRC

Attachment 1 IN 92-17 February 26, 1992 staff has also found a lack of coordination among licensees in disseminating

and using MOV test data. For example, some licensees are not considering tests

conducted by other licensees which might reflect on the adequacy of their

assumptions in predicting thrust requirements.

For MOVs that cannot be tested under design-basis differential pressure and

flow conditions, the NRC inspectors have found that some licensees are not

following their commitments to the two-stage approach (discussed in

Supplement 1 to GL 89-10) to test those MOVs at the maximum differential

pressure and flow achievable. If the test pressure and flow are near to the

design-basis conditions, the licensee may be able to Justify extrapolating from

the test results to demonstrate the capability of the MOY to perform its safety

function under design-basis conditions. Where the MOV cannot be tested near

design-basis conditions, the licensee can use the results of the test at

maximum achievable conditions to help confirm valve factor assumptions in its

sizing and switch setting methodology and to set the MOV using the best avail- able data. The licensee may also find TS actions and reporting requirements

that take effect as a result of tests of MOVs at less than full design-basis

differential pressure and flow conditions if those tests reveal that the MOYs

could not perform their safety functions under design-basis conditions.

Testing MOVs at maximum achievable conditions is especially helpful in estab- lishing a plant-specific database if the licensee estimates that only a small

percentage of 14OVs can be tested at or near design-basis conditions.

Some licensees who, in their initial response to GL 89-10, committed to imple- ment the recommendations of GL 89-10 to test MOYs where practicable have

indicated an interest in grouping certain MOVs to reduce the amount of testing

(although testing of those MOVs would be practicable). Item 1. of GL 89-10

states that licensees shall submit any changes to scheduled commitments, and

that revised schedules or alternative actions may be implemented without NRC

approval with justification retained on site.

In their initial responses to GL 89-10, some licensees stated that they would

attempt to group MOVs to limit the extent of design-basis testing. The prelim- inary results of design-basis tests at several plants (for example, Catawba, Farley, Oconee and Surry) Indicated that apparently identical MOYs performed

significantly different uider high differential pressure and flow conditions.

This could cause difficulty in grouping MOVs in such a manner that a small

sample of MOV tests can be used to demonstrate that all MOVs can perform their

safety functions under design-basis conditions.

The motor operators for most gate valves are set to close on torque to provide

adequate leakage control. Licensees are attempting to develop a method to

ensure that MOVs closed using the limit switch meet the requisite leakage

limitations in safety analyses without causing an MOV overstress condition.

Periodic Verification of MOV Capability

In recommended action 'Id"of GL 89-10, the NRC staff requested that licensees

prepare or revise procedures to ensure that adequate MOV switch settings are

Attachment 1 IN 92-17 February 26, 1992 determined and maintained throughout the life of the plant.

of GL 89-10, the NRC staff recommended that the surveillance In paragraph "ij

on (1) the safety importance and (2) the maintenance and interval be based

the MOV, but that the interval not exceed 5 years or 3 performance history of

refueling outages, whichever is later. Further, the staff stated that the

capability

should be verified if the MOV Is replaced, modified, or overhauled of the MOY

that the existing test results do not represent the MOV. to an extent

response to Questions 33-35 and 38 in Supplement 1 to GL The NRC staff's

89-10 provides

guidance on periodically verifying MOY switches and performing

completing maintenance. tests after

The recommendation of GL 89-10 for verifying periodically

switch settings includes torque, torque bypass, limit, and the adequacy of MOV

Many licensees have stdted that they will attempt to use thermal overloads.

tests of MOVs with

diagnostic equipment under zero differential pressure and

(static conditions) to demonstrate the adequacy of torque flow conditions

the continued capability of MOYs to perform their safety switch settings and

design-basis conditions. However, to date, none of those functions under

licensees have pro- vided justification for applying the results of tests conducted

conditions to demonstrate design-basis capability. These under static

licensees appear to

be waiting on yet to be developed generic justification for

differential pressure and flow testing. static or low

At least one licensee indicated an intent to clean and lubricate

before performing periodic verification testing. This would the valve stem

with demonstrating that the MOV had been set adequately be inconsistent

performing its function at the end of the test interval. and was capable of

In GL 89-10, the NRC staff stated that testing at design-basis

not be repeated unless the MOV is replaced, modified, or conditions need

extent that the licensee considers that the existing test overhauled to the

representative of the MOV in its modified configuration. results are not

Many

improving their methods to demonstrate that the MOVs are capable licensees are

their safety functions under design-basis conditions following of performing

maintenance.

MOV Failures, Corrective Actions, and Trending

In recommended action "h" of GL 89-10, the NRC staff requested

analyze or justify each MOV failure and corrective action. that licensees

requested that the documentation include the results and The staff also

history

as-found deteriorated condition, malfunction, test, inspection, of each

repair, or alteration. The staff noted that the licensee analysis, report all documentation in accordance with the plant's must retain and

staff also suggested that the material be examined every requirements. The

2 years or after each

refueling outage after the program is Implemented as part

of the monitoring and

feedback effort to establish trends of MOV operability.

provide the basis on which the licensee can revise the These trends could

testing frequency

established to verify periodically that the MOV has adequate

NRC staff indicated that the system should be well-structured capability. The

capture, and share history datd on individual components. and should track, response to Questions 39 and 40 in Supplement 1 to GL 89-10 The NRC staff's

on identifying trends of MOV problems. provides guidance

Attachment 1 IN 92-17 February 26, 1992 The NRC inspectors have found some licensees to have weaknesses in evaluating

MOV failures and deficiencies (such as the operability effects of spring pack

relaxation). Some licensees have not been thorough in performing root cause

analyses of MOY problems. Most licensees are attempting to improve their

methods for identifying trends in MOY problems.

Schedule

In GL 89-10, the NRC staff requested that, by June 28, 1994, or by the third

refueling outage after December 28, 1989, whichever is later, licensees com- plete all design-basis reviews, analyses, verifications, tests, and inspections

that were initiated in order to satisfy the actions recommended in the generic

letter. The NRC staff's response to Question 41 in Supplement 1 to GL 89-10

provides guidance on the schedule for implementing these actions specified in

GL 89-10.

Some licensees have not made adequate progress for resolving the MOV issue for

their facilities within the recommended schedule of GL 89-10. The findings of

licensees as they begin to initiate their programs in response to GL 89-10 and

the results of the NRC inspections of GL 89-10 programs reinforce the impor- tance of promptly resolving this safety-significant issue. The NRC staff has

accepted limited extensions of the GL 89-10 schedule for particular licensees

who have provided Justification.

I emnt2 February 26. 1992 Pap 1 of I

LIST OF RECEITLY ISSUED

NRCIIIFORITION NOTICES

Information Date of

notice No.. Subject Issuance Issued to

92-16 Loss of Flow from the 02/25192 All holders of OLs or CPs

Residual Heat Removal for nuclear power reactors.

Pump during Refueling

Cavity Dr"indown

92-15 Failure of Primary System 02/24/92 All holders of OLs or CPs

Compression Fitting for nuclear power reactors.

92-14 Uranium Oxide Fires at Fuel 02/21/92 All fuel cycle and uranium

Cycle Facilities fuel research and development

licensees.

92-02. RelapS/Hod3 Computer Code 02/19/92 All holders of OLs or CPs

Supp. I Error Associated with the for nuclear power reactors.

Conservation of Energy

Equation

92-13 Inadequate Control Over 02/18/92 All holders of OLs or CPs

Vehicular Traffic at' for nuclear power reactors.

Nuclear Power Plant Sites

92-12 Effects of Cable Leakage 02/10/92. All holders of OLs or CPs

Currents on Instrument for nuclear power reactors.

Settings and Indications

92-11 Soll and hater Contamina- 02/05/92 All uranium fuel fabrica- tion at Fuel Cycle Facil- tion and conversion facil- ities ities.

92-10 8rachytherapy Incidents 01/31/92 AlI luclear Regulatory Com- Involving Irdium-192 Wire - mission (NRC) licensees

Used i Endobronchisl authorized to use

Treatments iridium-192 for brachy- therapyi manufacturers and

distributors of iridiu-I92 wire for use in brachy- therapy.

OL

  • Operating License

CP

  • Construction Permit

UNITED STATES

NUCLEAR REGULATORY COMMISSION POSTAGE FEES PAID

WASHINGTON, D.C. 20555 UMNO

nIEM No. 0J

OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE, $300

IN 92-17 February 26, 1992 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact the

technical contact listed below or the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical contact: Thomas G. Scarbrough, NRR

(301) 504-2794 Attachments:

1. Inspection Findings Pertaining to the Recommendations Contained In

Generic Letter 89-10

2. List of Recently Issued NRC Information Notices

Document Name: GL 89-10 INSPECTION RESULTS IN

  • SEE PREVIOUS CONCURRENCES
  • C/OGCB:DOEA:NRR

CHBerlinger

02/11/92

  • OGCB:DOEA:NRR *EMEB:DET:NRR *C/EMEB:DET:NRR*D/DET:NRR '*RPB:ADM

RJKiessel TGScarbrough JANorberg JERlchardson TechEd

01/14/92 01/09/92 01/13/92 01/29/92 01/14/92

IN 92-XX

February xx, 1992 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact the

technical contact listed below or the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical contact: Thomas G. Scarbrough, NRR

(301) 504-2794 Attachments:

1. Inspection Findings Pertaining to the Recommendations Contained In

Generic Letter 89-10

2. Inspection Findings Pertaining to Other MOY Areas

3. List of Recently Issued NRC Information Notices

Document Name: GL 89-10 INSPECTION RESULTS IN

  • SEE PREVIOUS CONCURRENCES

D/DOEA:NRR *C/OGCB:DOEA:NR11! -

CERossi CHBerlinger -0

02/ /92 01/31/92 A

  • OGCB:DOEA:NRR *EMEB:DET:NRR *C/EMEB:DET:NRR*D/DET:NRR *RPB:ADM

RJKiessel TGScarbrough JANorberg JERichardson TechEd

01/14/92 01/09/92 01/13/92 01/29/92 01/14/92

IN 92-XX

January xx, 1992 This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact the

technical contact listed below or the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical contact: Thomas G. Scarbrough, NRR

(301) 504-2794 Attachments:

1. Inspection Findings Pertaining to the Recommendations Contained In

Generic Letter 89-10

2. Inspection Findings Pertaining to Other MOV Areas

3. List of Recently Issued NRC Information Notices

Document Name: GL 89-10 INSPECTION RESULTS IN

  • SEE PREVIOUS CONCURRENCES ---- -'11/

D/DOEA:NRR C/OGCB:DOEA:N Zg;

CERossi HBerlinger to

01/ /92 / 0lL1/92

  • OGCB:DOEA:NRR *EMEB:DET:NRR *C/EMEB:DET:NRR D/DE tAJg*RPF.ADM

RJKiessel TGScarbrough JANorberg JER i d d q TechEd

01/14/92 01/09/92 01/13/92 Ad 01// 01/14/92

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical contact: Thomas G. Scarbrough, NRR

(301) 504-2794 Attachments:

1. Inspection Findings Pertaining to the Recommendations Contained In

Generic Letter 89-10

2. Inspection Findings Pertaining to Other MOV Areas

3. List of Recently Issued NRC Information Notices

Document Name: GL 89-10 INSPECTION RESULTS IN

D/DOEA:NRR C/OGCB:DOEA:NRR

CERossi CHBerlinger

Ol/ /92 01/ /92 OGCB:DOEA:NRR EMEB:DET:NRR C/EMEB:DET:NRR D/DET: NRR RPB:ADM

RJKiessel TGScarbrough JANorberg JERichardson TechEd 1Miain 91

01/ /92 01/ /92 01/ /92 01/ /92 01/jq/92

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical contact: Thomas G. Scarbrough, NRR

(301) 504-2794 Attachments:

1. Inspection Findings Pertaining to the Recommendations Contained In

Generic Letter 89-10

2. Inspection Findings Pertaining to Other MOV Areas

3. List of Recently Issued NRC Information Notices

Document Name: GL 89-10 INSPECTION RESULTS IN

D/DOEA:NRR C/OGCB:DOEA:NRR

CERossi CHBerlinger

01/ /92 01/ /92 OGCB:DOEA:NRR EMEB:DET:NRR C/EMEB:DET:NRR D/DET:NRR RPB:ADM

RJKiessel L TGScarbrough JANorberg JERicharoson TechEd JIMahl97

01/fl/ 92 01/ /92 01/ /92 01/ /92 01//q/92