3F0992-05, Forwards Update to Util 900102 Response to GL 89-10 & Suppls 1 Through 4 Re safety-related MOV Testing & Surveillance. Util Intends to Complete Implementation of MOV Program During Refuel 9,currently Scheduled for Apr 1994

Forwards Update to Util 900102 Response to GL 89-10 & Suppls 1 Through 4 Re safety-related MOV Testing & Surveillance. Util Intends to Complete Implementation of MOV Program During Refuel 9,currently Scheduled for Apr 1994

ML20118A657
Person / Time
Site:	Crystal River
Issue date:	09/18/1992
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0992-05, 3F992-5, GL-89-10, NUDOCS 9209240321
Download: ML20118A657 (9)

Text

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Florida Power COnPOnATION w tw tw a err,w m w ma September 18, 1992 3f0992-05 .

l U. S. Nuclear Regulatory Commission l Attention: Document Control Desk l Washington, D, C. 20555 l Suoject: Safety Relat ed Motor-0perated Valves (MOV) Te. sting and Surveillance

References:

A. NRC to FPC, Generic Letter 69-10 including Supplements 1 through 4 B. FPt to NRC, uated Januar) 2, 1990 (3F0190-01)

C. FPC to NRC, dated April 13, 1992 (3F0492-06)

Dear Sir:

Florida Power Corporation (FPC) is submitting an update to Reference B, our initial response to Generic Letter 89-10 (Reference A). This update is provided to inform the NRC of our current actions to resolve MOV issues cnd how these actions relate to those recommenJed in the generic letter. This letter supersedes Reference B in its entirety. FPC agreed to provide this update in Reference C. our response to Inspectier. Report 92-01. Our schedule -to complete the impletantation of the MOV Program remains ReJoel 9, currently scheduled for April 1994. The Attachment contains action ite ms a ti..ough k from Generic Letter 89-10 and the corresponding updated response from FPC.

Sincerely, me</

P. M/ Beard, Jr.

Senior Vice President Nuclear Operations PMB:LVC Attachments xc: Regional Administrator, Region 11 Senior Resident Inspector NRR Project Manager i jDR209240321 9po9jp p ADOCK 05000fo; ,. Florida Progress Company

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Attachment (1 September 18 199?

3F0992 Page 1.of 1 STATE.OF_ FLORIDA COUNTY OF CITRt$

P. M. Beard, Jr. states that he is the Seni_or Vice President, Nuclear Operations for l Florida T, wer Corporation; that he is auth ized on the part of said company to sign and file sith the Nuclear Regulatory Commission the ir. formation attached hereto; and I

that al'1 such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief,

~ Au;/h l I  :

P. M, 3eard: Jr. '

Senior Vice President.

Nuclear Operations l

Subscribed and omra to before me, a Notary Public in and for the State and County above named, this 18th day of September, 1992.

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// Notary Public l- - i Notary Public, State of Florida at Large, i htary Public, state of Fkwido My Commission Expires: E conwinion in ,n ori.17,19,4 .

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Attachment 2 September 18. 1992

. 3F0992.-05 Page 1 of 7 NRC REQUEST: 4 Item t Review and document the design basis for the operation of each MOV. This documentation should include the maximum differentia! pressure expected during both the opening and closing of the MOV for boti, normal operations and abnormal events, to the extent that these MOV operations and events are included in the existing approved design basis.

FPC RESPONSE:

l Item a. The design-basis review and preparation of differential pressure -(DP) I calculations for all position changeable MOVs has been completed. These I calculations are being reviewed and revised as nncessary to incorporate actual plant conditions and lessons learned from the MOV Program, The l revised calculations will be completed prior to the scheduled DP testing 1 of each valve. Inadvertent operation is included in the design-basis review, however, FPC is not implementing any test requirements for inadvectent operation Nnding the results of the ongoing NRC evaluation for the removal of this requirement.

NRC REQUEST:

Jie d Using the results from item a., establish the correct switch settings.

This will include establishing a program to review and revise, as necessary, the methods for selecting and setting all switches (ie.,

. torque, torque bypass, position limit, overload) for each valve operation (opening and closing). One purpose of this letter is to ensure that a program exists for selectina and setting valve operator switches to ensure high reliability of safety-related MOVs.

FPC RESPONSE:

Item b. An initial evaluation of all valves included in the MOV Program which verifies the correctness of switch settings using the latest available industry information has been completed. Thrust calculations for all MOV Program valves will be revised to reflect current information.

Additionally, the MOV Nogram manual is being revised to incorporate the latest industry information and lessons learned with respect to selecting and setting valve operator switches. Procedures will be reviewed and revised to include the revised switch settings. The M0V program will include the periocic monitoring of MOV performance and adjustment of switch settings.

_ : _ _ _ = ___ _ - _ - - _ - _ - _ _ _ - _ -__ _ _ - ____ _ - _ _

. Attachment 2 September 18, 1992_

. 3F0992.-05 Page_2 of 7 i

NRC REQUEST:

Item c. Individual MOV switch settings should be chang 2d, as appropriate, to those established in response to item b. Whether the switch settings are.  !

changed or not, the MOV should be demonstrated to be operable by testing l it at the design-basis diff erential pressure and/or flow determined in i

response to item a. Testing MOVs at design-basis conditions . is not 1 recommended wherr such testing is precluded by the existing plant '

configuration. A1 explanation should be uocumented for any cases with the design-basis differential pressare or flow cannot practicably be l

performed. This explanation should include a description of the '

alternatives to design-basis differential pressure testing or flow i testing that will be used to verify the correct settings.

Note: This letter is not intended to establish a recomirendation for valve testing for the condition simulating a break in the line containing l the MOV. However, a break i.' the line should be considered in the- -!

analysis described in items a., b., and c. if M0V operation is relied '

on in the design basis.

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! Each MOV should be stroke tested, to verify thac the MOV is operable at L no-pressure or no-flow conditions even if testing with differential-pressure or flow cannot be performed.

FPC RESPONSE:

Item c. Switch settiu of valves tested by the MOV Program have been corrected j as necessary.

All valves that can be tested under dynamic conditions will be tested by the end of Refeel 9 currently scheduled for April 1994. Documentation of valves which can not be insitu tested under design-basi differential i

pressure or flow has been completed. Alternative testing, such as the two-stage approach and prototype testing recommended in item f. of the SL is currently being evaluated in parallel with industry efforts. FPC will participatt in industry efforts to determine acceptable alternative methods for testing. Static testing will be performed on all valves within the MOV Program.

In regards to the Note in item c., FPC analyzed maximum DP conditions for

line breaks assumed in Chapter 14, Safety Analysis, of the FSAR.

l HRC REQUEST:

ltem d, Prepare or revise procedures to ensure that correct switch settings are determined and maintained throughout the life of the plant. These procedures should include icovir ens to monitor MOV performance to ensure the switch settings are correct. This is particularly important if the torque or torque bypass switch setting has been significantly raised above that required.

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. . Attat;hment 2 . September 18, 1992.

. 3F0902.-05 Page 3 of 7 It may become necessary to adjust- NOV_ switch settings because of the effects of wear or aging. Therefore, it is insufficient to merely verify that the switch settings are unchanged from previously established-values. The (witch settings shoulo be verified in i.ccordance with the program schedule (see item j). The ASME Code Section XI stroke-timing test required by 10 CFR Part 50 is not oriented toward verification of switch settings. Therefore, additional measures should be taken to.

adequately verify that the switch settings ensure MOV operability.- The switch settings need not be verified each time the ASME Code -stroke-timing test is performed.

FPC RESPONSE:

Item d. Procedures will be reviewed and revised as necessary to include revisions _

to switch settings and thrust valuct for applicable MOVs to assure switch settings are maintained throughout the life of the plant. -The MOV program will include provisions to periodically monitor M0V performance.

Thcse provisions will include ensuring switch settings are correct and i adjusting switch settings when necessary. The switch settings will be I verified as part of the overall MOV Program. The schedule for accomplishing these activities is provided in item j.

NRC REQUE!T:

Item e. Regarding item a., no change to the existing plant muign is intended and none is inferred. The design-basis review shculd not be restricted to a determination of estimated maximum design-basis differential pressure, but should include an examination of the pertinent design and installation criteria that were used in choosing the particular M0V. For example, the review should include the effects on MOV performance of design-basis degraded voltage, including the capability of _the MOV's power supply and cables to provide the high initial current needed for the operation of the M0V.

FPC RESPONSE:

Jtem em FPC has undertaken a separate effort to review the degraded voltage ef fects on ciectrical equipment. lhe results. af this effort will be factored into the MOV program. Howeve ', testing of MOVs at degraded or over-voltage conditions is not included in the program.

Attachment 2 September 18, 1992

. . 3F0992-05 Page 6 of 7 NRC REQUEST:

Item 1. Each licensee with an operating licente (OL) should complete all design-basis reviews, analyses, verifications, tests, and inspections that have been instituted in order to comply with items a. through h. within five years of three refueling outages of the date of this letter, whichever is later.Each licensee with a construction permit (CP) should complete

- this actions within 5 years of the data of this letter or before the bl is issued, whichever is later.

For plants with an OL, the documentation described in items 1. and 2.

below shoulo be available within one year or one refueling outage of the date of this letter, whichever is later. For plants with a CP, the documentation outlined in items 1. and 2. should be available within one year of the date of this letter or before the OL is issued, whichever is __

later. The documents should include:

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1. The . 3 ;ription and schedule for the design-basis review reconmended in item a. (including guidance from item e-) for all c afety-related MOVs and position-changeable MOVs as described, and

1. The program description and schedule for iteu b. through h for all safety related MOVs and position-changeable MOVs.

FPC RESPONSE:

Item 1. FFC has implemented the MOV Procram which addresses parts 1 and 2 of this item. FPC plans to complete the design-basis re'.>iew and testing of all MOVs contained in the MOV Program by the end of Refuel C with the exception of the testing of those valves considered for i.iternative testing defined in FPC's response to item c.

NRC REQUEST:

ltem_,L The program for the verif cation of the procedures outlined in item d.,

as well as other tests or surveillance toat the owner may choase to use e 1

to identify potential MOV degradations or misadjustments, such as those described in Attach &nt A, should be implemented af ter maintenance or adjustment (including natking adjustment) of each MOV, and periodically thereafter. The surs :llance interval should be based on the licensee's ,

evaluation of the safety importance of each MOV as well as ;is maintenance and performance history. The surveillance interval should not exceed 5 years or three refueling outages, whichever is longer, unless a longer interval can be justified (see item h) for any particular MOV.

FPC RESP 0!iSE:

Jtem.i. FPC's present plan is to surveil all MOVs in the MOV Program within a three (3) refueling outage schecole. Post-maintenance testing is being evaluated in light of MOV history and industry guidelines and will ba modified accordingly.

c . Attachment 2 September'18. 1992 3F0992-05 Page 4 of 7 NRC REQUEST:

J1ern /. Documentation of explanations and the descrip*. ion of the actual- test methods used for accomplishing item c. should be retained as part of the required records of the MOV.

It is also recognized that it may be impracticable to perform insitu M0V testing at design-basis degraced voltage conditions. However, the switch settings established in response to item b. should at -least be established to account for the situation where the valves may be called on to operate at design-basis differential prasare, or flow, and under agraded voltage conditions. If the licensee failed to consider degraded

.oltage, power supply, or cable adequacy .or MOVs in systems covered by Bulletin 85-03, the design review and establishei switch settings for those MOVs should be reevaluated.

Alternatives to testing a particular MOV in-situ at design-basis pressure or flow, where such testing cannot pi acticably be performed, could in:lude a comparison with appropriate design-basis test results on other i

MOVs, either in-situ or prototype. If such test information is not available, analytical methods and extrapolations -to design- W s cond'tlon.,, based on the best data available, may be used until test t.ata at de sign basis conditions become availaie to verify operability of the MOV. If this two stage approach is followed, it should be accomplished within the schedule outlined in item i. ar.d would allow for MOV testing l

and surveillance to proceed without excessive delay.

Testing of MOVs at design basis conditions need not.be repeated unless the MOV is replaced, modified, or overhauled to the extent- that the licensee considers that the existing test results are not representative of the MOV in its modified configuration.

FPC RESPONSE:

Jtem f. Test methods and system configuration during the performance of the l tests are documented in plant procedures and records. Alternative test l methods as previously discussed in item c. are under evaluation. Where insitu dynamic testing can be performed at a pressure lower than the i maximum accident DP, operability will be assured through analytical methodology and extrapolation of test data.

Valves, which under normal operating conditiuns are subject to the maximum expected differential pressure conditions, will have their switch j settings calibrated using diagnostic equipment tt static conditions.

I Operability under maxinum DP conditions is verified through normal I

operational performance Reduced voltage capabilities will be evaluated and documented through analytical methodology.

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Attachment 2 Septembc' 18, 1992 3f0992-05 Page 5 of 7 NRC REQUEST:

ltem h A number of deficiencies, misadjustments, and degraded conditions were discovered by licensees, either as a result of their efforts to comply with Bulletin 85-03 or from other experiences. A list of tnese conditions (including switch settings) is included in attachment A to this letter for licensee review and information.

FPC RESPONSE:

ltem o. FPC has reviewed the list of conditions contained in Attachment A of the Generic letter. Those conditions are being considered in the MOV Program.

NRC REQUEST:

1. tem h. Each MOV failure and corrective action taken, including repair, alteration, analysis, test, and surveillance, should be analyzea or justified and documented. The documentation should include the results and history of each as-found deteriorated condition, malfunction, test, inspection, analgis, repair or alteration. All documentation should be retained and ieperted in accordance with plant requirements.

it is suggested that this MOV data be periodically examined (at least every two years or aftcr each refueling cutage after program implew - tation) as part of a monitor ing and feedback effort to establish trends of MOV operability. These trends could provide the bans for a

. *ensee revision of the testing frequency established to periodically e fy the adequacy of MOV switch settings (see items d. and J.). For tros monitoring and feedback effort, a well-structured and component-oriented system (e.g., the Nuclear Plant Reliability Data System, NPRDS) is needed to capture, track, and share the equipment history data. The NRC encourages the use of the industry-wide NPRDS, appropriatcly modified, for this purpose in vies of the multiple use for these data.

FPC RESPONSE:

Item h. Each MOV failure and corrective action taken will be documented in accordance with the plant Problem Report process.

Data obtained from MOV testing will be reviewed and maintained. This  ;

data will be used to establish a tracking and treacing program which will be in place within the suggested time-frame of two years after Program implementation. FPC plans to co...plete implementation of the MOV Prcgram by the end of Refuel 9.

Attachment 2 September 18, 1992

. ', 3F0992-05 Page 7 of 7c NRC REQUEST:

Item k. In recognition of the necessity for preplannino, refueling outages that start within 6 months of the date of this letto need not be counted in establishing the schedule to meet the time limits reenmmended in items i, and j, FPC RESPONSE:

lism k. The present MOV testing schedule is to complete the initial testing of the MOVs contained in the program by the end of the third -refueling outage (Refuel S) with exceptions as described in item c. Refuel 9 is-currently scheduled for April '994, l

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