3F0190-01, Forwards Response to Generic Ltr 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance. Util in Process of Reviewing & Documenting design-basis for Facility safety-related & Position Changeable motor-operated Valves
| ML20042D404 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/02/1990 |
| From: | Beard P FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 3F0190-01, 3F190-1, GL-89-10, IEB-85-003, IEB-85-3, NUDOCS 9001090096 | |
| Download: ML20042D404 (5) | |
Text
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< January 2,fl990 3F0190-01 t
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- U.S. Nuclear Regulatory l Commission
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Subject:
Crystal-River Unit 3
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- Docket No. 50-302 l,
Operating License No'.,DPR-721
' Safety-Related Motor-Operated!. Valve::'(MOV) Testing
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- and ' Surveillance -(Generic Letter 89-10). -
di 10.CFR 50;54 (f)
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Dear. Sir':
NFldrida9 Power? Corporation 1 (FPC) is submitting the response to N:
~ Generic Letter'89-10(requested in,your June 28,'d responses.
1989 letter..The'
- attachment (to. this. letter provides ~ the'- detaile FPC plans to,icomplete. the Lactions; describedi bya the end - of ? Refuel 9 l
iwhich!is within-the time frame required by;the Generic, Letter.
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FPC does not' plan.to.re-test 17 motor operated valves previously testedi:inJaccordance with NRC IE Bulletin 85-03 during the-initial xtest1programH described - in Generic Lettert.89-10 but will include n
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1them:in a continuing-MOV surveillance' program.
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ShouldLthere be any-~ questions, please contact this office, ik
'Sjncerely, o,
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.: Beard, Jr.
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Senior.Vice President f4 Nuclear 1 Operations
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GENERAL-OFFICE: 3201 Thirty fourth Street South P.O. Box 14042
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STATE OF FLORIDA COUNTY OF.PINELLAS
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M.. Beard, Jr. states that he ' is the Senior Vice President,
. Nuclear. Operations for Florida Power Corporation; thet he is authorized-on the part of said company to sign and fils with the Nuclear Regulatory Commission the information attached hereto; and
.that all such statements made-and. matters set forth-therein are P!.
true end correct to the best of his knowledge, information, and-L belief.
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P. M. Beard, Jr.
Senior Vice President Nuclear Operations r
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Subscribed and sworn to before me, a Notary Public in and for the
' State and. County above named, this.2nd day of January 1990.
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' Notary Public, State of F{g.rida at Large, ne:tc w i: cr r.cn n
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My Commission Expirns:
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-January.2, 1990-
.3F0190-01_
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ATTACHMENT k t'
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1 FPC ; has reviewed ~ the generic. letter and itemized ' our responses below.
.FPC is developing an MOV test program utilizing the
-recommendations of the generic letter to the extent possible.
It h
is our-intent to' develop a program which assures that MOV's will J"
l function when required.
There are approximately 100 MOV's in the p-
.FPC~ test program.
' FPC. is presently planning -- to-meet the schedule requirements to L,
' complete: the initial ~ valve test program within three (3) refueling l;j outages.. ' However, tne industry is in the process of developing MOV testing methods and additional-information discovered during this process.regarding DP testing, similarity of valves, database use, j
. degraded. voltage and other considerations could cause unforseen L
-delays in ecmpleting the. initial test program.
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~ The following responses are provided'to your recommended actions E-(Items a through h) and-schedule (Itens i through k) in the generic L
' letter.
Exceptions and clarifications are provided ).s-.necessary.
Item a' FPC is in the process of reviewing and documenting r
l the design-basis for CR-3 safety related and position changeable Mov's.
This effort is' ongoing and will be completed with tM initial MOV test program.
The documentatich " & esses the maximum differential pressures expec,,.
.'or each MOV whether under normal or abnormal operatL n, and in the open or closed direction, whicheve.- is greater.
Itera b The MOV test program will include provisions to establish the correct switch settings.
Methodologies to select and set proper switch settings are developed from sources such as the DP testing performed in accordance with IEB 85-03, FPC's program utilizing consulting services to provide MOV data, and other vendor / utility data for j
similar valves as this data becomes available.
Insitu DP testing is intended to be used where practical. Maintenance procedures will be reviewed
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and revised as necessary to maintain current 4
information.
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January: 2~,
1990:
A '3F0190-017 jg.
4 ATTACHMENT w%
^ Itsem c
.FPC will' document any cases where design-basis OP and/or~ flow -testing cannot'-be performed
'in-accordance - with the1 FPC ~ MOV test program.
The documentation will describe the alternative testing performed.. As a minimum,.thece valves : will be stroke tested at no-pressure or sio-flow conditions
'to. verify.that the' valve 11s operable.
FPC intends to remain actively involved within the industry to 9.ti; i
. provide continued - enhancement; of our' program, o,,
consideration of line breaks =is'not.:a part of tbc.
CR-3^ design-basis or of1the MOV test program.
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Item d.
Procedures will be reviewed and revised as necessary
.to-include-revisions-to: switch settings for applicable MOV's. - The MOV test program will include.
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-provision to monitor MOVl performance.
Item e^
FPC has undertaken a separate effort to review the degraded voltage effects on electrical equipment.
'The results of this effort will be factored into
- the ciOV t est program.-
--I t e m - f The FPC MOV program will include the maintenance of historical data which willLinclude actual testing and maintenance performed on each MOV.
MOV testing a
N will be performed as described above and. on MOV's
- which have%en replaced, modified, or undergone
- overhaulf if it is determined that the existing test results are no longer valid.
a Item a FPC will review the list of discrepancies, included with Generic Letter 89-10 as Attachment A,
and consider them in the development of the MOV valve test; program.
E Item h The FPC MOV test program data system will review those MOV's tested during an outage..
After the completion of the outage, the historical database i
will be updated and reviewed for information and trend purposes.
Trending information wul ne fed back into the MOV test program as deemed necessery.
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- January 2, 1990:
ATTACHMENT schedule item-i FPC plans to complete the initial testing of all the MOV 's' ' ati CR-3 within the~ three refueling outage schedula, providing the test program can be applied to all lof the1MOV's; as described above.
This testing program 11s dependent on the availability of i the necessary-- documentation. for each MOV and the
- e
' ability to actually perform the; test as: recommended without undue. stress to the MOV's or plant systems..
' Item i-FPC's present plan is-to surveil each MOV on a three (3) refueling outage schedule.
This-schedule is dependent on MOV history and industry guidelines and:-
will be. modified accordingly.
Jtem'k-The present FPC MOV testing schedule is to complete the initial Mov testing of all Mov's bylthe end of o
- the third refueling (Refuel 9) with exceptions'as
= described above.
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