IR 05000440/1992018
| ML20126K853 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/05/1993 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Stratman R CENTERIOR ENERGY, CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 9301070271 | |
| Download: ML20126K853 (1) | |
Text
_
- - _ - _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ - _
_
_.
JN!i 5 in3 Docket No. 50-440 Centerior Service Ccmpany ATTN:
Mr.
R. Vice President Nuclear-Perry c/o The Cleveland Electric Illuminating Company 10 Center Road Perry, OH 44081
Dear Mr. Stratman:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NO.
50-440/92018(DRS))
_
This will acknowledge receipt of your letter dated December 7, 1992, in response to our letter dated November 5,
1992, transmitting a Notice of Violation associated with Inspection Report No. 50-440/92018(DRS).
This report summarized the results of the review of the Perry Motor Operated Valve (MOV)
Program at your Perry N.1 clear Power Plant.
We have reviewed your corrective actions and have no further questions at this time.
These corrective actions will be examined during future inspections.
Sincerely, c h, ;,4 a LmJ d 0 0 I'
'ho g j 7g
Hubert J.
Miller, Director Division of Reactor Safety See Attached Distribution
-
RI I Rill P'II RI.i j
'
O Ih VW[-
Jac] son Cj R plo41 jk Hu er Lanksbury o
01/04/93 01/' /93 01/5'/93 01/6 /93 1(T RIII RIII j(
rp6 gWI j n.
(RjiI
.
Martin Miller
'01/3 /93 01/G /93 01/$/93 9301070271 930105 l
j PDR ADOCK 05000440
\\
l f
)
a PDR
<
l
. _ _ _ _ _
_. _...
'
.
t
-
.
.
Centerior Service Company
JAfl 5' EG3 Rigiribution cc:
F.
R.
Stead, Director, Nuclear Support Department David P..Igyarto, Plant Manager Kevin P.
Donavan, Manager, Licensing & Compliance Section-S.'F.
Kensicki~, Director, Perry
_ Nuclear-Engineering Dept.
H. Ray Caldwell, General-Superintendent, Nuclear-
_
operations cc w/ltr dtd 12/07/92:
DCD/DCB_(RIDS)-
!
OC/LFDCB J.
Hall, LPM,.NRR T.
Scarbrough, NRR Resident Inspector,--RIII Terry J.
Lodge, Esq.
James R. Williams, State of. Ohio Robert E. Owen, Ohio Department.of Ilealth A. Grandjean, State of Ohio, Public Utilities Division W. Hodges, RI A. Gibson, RII S.
Collins, RIV.
K.
Perkins, RV
..
e
-
-
.
-
.
.
_.
.- _
.
-
.'
.
. CENTERIOR ENERGY
-
PERRY NUCLEAR POWER PLANT Mail Address, g 4 $ggg PO BOX 97 ROAD PERnY, OHIO 44081 VICE PnESIDENT. NUCLEAR jo CEN (216) 259 37J7 December 7, 1992 PY-CEI/NRR-1581 L U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D.C.
20555 Perry Nuclear Power Plant Docket No. 50-440 Reply to Notice of Violation
,
Gentlemen This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/92018 dated November 5, 1992. The report identifies areas examined by Region III inspectors from August 25 through October 1, 1992.
This letter also acknowledges your request that Perry provide an updated Generic Letter (GL) 89-10, Supplement 3 response which addresses NRC concerns identified during the referenced inspection. The requested GL 89-10, Supplement 3 response vill be transmitted to the NRC under a separate cover.
It is recognized that improvements to the Perry MOV Program are needed to appropriately implement GL 89-10 requirements. A plant staff reorganization was recently completed in order to provide a more proactive approach to resolving issues involving MOVs and to improve the ability to focus resources.
This reorganization combined personnel f rom the MOV testing organization t ith design group personnel responsible for design basis and test results evaluations.
The newly formed group vill re-analyze assumptions utilized in establishing MOV program attributes. Actions vill be taken to correct any deficiencies identified during this reviev. The group vill also conduct a detailed review of weakness identified in Inspection Report 92018 and recommend appropriate actions for implementation. Ve believe the changes vill result in an overall improvement in the Perry MOV Program.
If you have any question, please feel free to call.
Sincerely,
'~
,/
R. A, Stratman RAS:RVG:ss Attachments cc NRC Project Manager NRC Resident Inspector p.
NR" Region III
- _--f 87
[f
,1,l-
.
a, g y.-
-
c
[JEC 10 W
, nr o u t
$
'
-q e.
. -
~
,
,
._
. - - ~. -
.
. -.. - -
.
'
PY-CEI/NRR-1581 L
..
Attachment 1
'
,
Page 1 of 6
= *
.
Respcnse To Notice of Violation
- Due to the dissimilar nature of the examples described in the Notice of Violation under-sections 1.a. 1.b, and 1.c the reasons for the respective violation examples and the associated corrective actions vill be addressed separately.
50 440/92018-01A Restatement of the a.
n erion V, requires that activities affecting quality 10 CFR 50, Appendix
shall be prescribed by documented instructions, procedures, or dravings, of a
,
type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures,
.
or drawings shall include appropriate quantitative or qualitative acceptance
.
criterie for determining that important activities have been-satisfactorily H
accomplished.
Contrary to_the above, as of September 3, 1992, the combination of a generic instruction and the design drawing used for setting the shutdown coolir.g suction valve limit svitches did not have the necessary level of detail to
,
ensure appropriate-limit switch settings and contributed to the failure of the.
RHR system "A" pump to start on demand on May 5, 1992.-
Reason for the-Violation
~
The program deficiency described above vas previously identified by perry-personnel and reported to the NRC in-Licensee Event Report-(LER)92-012 dated June 4, 1992.
.
The inappropriate limit switch setting resulted in a loss of the Shutdown Cooling Mode of the Resident-Heat Removal (RHR) system and a violation of.
- -
Technical Specification 3.9.11.2 Action a.
The cause for the event, as stated in LER 92-012, was a program veakness..The identified weakness-involved a lack of detailed guidance for properly adjusting'the third and fourth train rotor limit switches for limitorque valve operators.
Technicians who experienced difficulty over the previous years in setting this--
!
type of limit switch had resolved their problems vith engineering personnel on
<
an as needed basis and did not document any generic concerns._ Therefore no procedural remedies were pursued.
Corrective Actions Taken and Results Achieved The corrective actions detailed In LER 92-012 consisted of the.following
-
steps. The RHR pump suction valve limit svitch which_ initiated the event described in LER 92-012'vas reset satisfactorily following--the-event.
Engineering personnel performed'an evaluation to determineLvhich_four'. train
.
rotorftype positioners'used'in_ control / interlock applications vere subject to
.i
. potential previous misadjustments. The appropriate valve limit svitches were subsequently re-adjusted.
.
-4-w E.,
a.
.r-re - - w.. ne m --
w-ei+--a.-
-n.
-. $Ei i m
,w.--
-a-,,----e..
..-.-,..em
...~,.w..e--,
- -, - -, s e---
-
c.
++.v
'.m h m'-t-
'
-
-
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
_
.
PY-CEI/!1RR-1581 L Attachment 1
-
Page 2 of 6
'
.
.
Additionally, the associated design drawings used for setting limit switches i
on four train rotors vere revised to incorporate enhanced guidance. These i
j drawing revisions vere verified complete on August 24, 1992. Generic Electric Instruction (GEI)-0014, "Limitorque Limit / Torque Switch Adjustment," vas also
'
revised. The procedure revision, which included appropriate detailed guidance, became effective on September 15, 1992.
Actions to Avoid Further Violations A memo vill be distributed to remind site personnel to initiate procedure changes when problems are identified.
Date Vhen Full Compliance Vill Be Achieved Full compliance with the cited 10 CFR 50, Appendix B criterion was achieved on September 15, 1992 upon implementation of the referenced revision to procedure gel-0014.
50-440/92018-01B Restatement of the Violation 10 CFR 10, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Perry Administrative Procedure (PAP)-201, " Conduct of Operations," Revision 6 through 8, dated October 22, 1990 and April 21, 1992, respectively, stated
"Since safety-related MOV fuses are substantially oversized by design, trouble-shooting should normally be initiated in response to blown MOV main power fuse events."
Contrary to the above, as of September 3,1992, troubleshooting steps had not been taken to address HOV main line fuse failures that occurred in April 1991 and May 1992 (MOVs 1B21-F0065A/B).
Reason for the Violation Administrative Procedure PAP-0201 delineates the responsibilities of the Control Room Unit Supervisor (US) vith regard to determining whether trouble-shooting vill be required prior to replacement of blown fuses.
If the US determines that blevn fuses may be replaced without trouble-shooting, PAP-0201 requires that a Blovn Fuse Replacement Checklist be completed to document the replacement of the correct fuse size and type.
For the motor operated valves (MOVs) referred to in Violation 50-440/92018-01B (1821-F0065A/B), the cause vas known prior to fuse replacement. The blovn
_
. _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _
-
_ _ _ _ _ _ _ _ _ __
_ _ _ _ _ _
_
_ _ - _ _ _ _ _ _ _ _ - _ _ _
l PY-CEI/NRR-1581 L
Attachment 1
'
Page 3 of 6
'
fuses vere replaced utilizing a Blovn Fuse Replacement Checklist in each instance since the apparent cause for the fuse failures had been determined and no trouble-shooting was deemed necessary.
In addition to the Blovn Fuse Replacement Checklist, PAP-0201 also requires the initiation of a Vork Request for the purpose of trending fuse replacement f requency, when no trouble-shooting is required.
PAP-0905, "Vork Order Process," includes the specific instructions for processing Blovn Fuse Vork Orders. These instructions previously included a requirement to investigate the cause when it was determined that the fuse had blovn within the previous thirty days or an incorrect fuse vas installed. Since the blovn fuses discussed in the Notice of Violation had an occurrence frequency of greater than a year no investigation was required. This apparent veakness in the blown fuse administrative process contributed to the failure to further
~
investigate the cause of the blown fuses.
C3rrective Action Taken and Results Achieved PAP-0905 has been revised to remove the "30 day" criteria vhen reviewing for indications of trendable/ recurring fuse failures and to require a troubleshooting vork order be initiated for any main line fuse failures involving safety-related HOV fuses. These steps vill assure that an investigation is performed and corrective actions taken when appropriate to address MOV blown fuse failures.
Actions to Avoid Further Violations A reviev vill be conducted to determine whether other trendable conditions, similar to those noted in violation 92018-01B, exist. Appropriate actions vill be taken to address any recurring problems identified during this review.
Date Vhen Full Compliance Vill Be Achieved Full compliance with the 10 CFR 50, Appendix B, Criteria V vas achieved on
-
December 3, 1992, upon approval of the described revisions to PAP-0905.
50-440/92018-01C Restatement of the Violation 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or dravings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, ss of September 3, 1992, the licensee did not have an adequate procedure with appropriate acceptance criteria to evaluate data from design basis differential pressure testing to ensure that the MOVs could perform their design basis functions.
- _ _ _ _ _ _ _ _ _
_ _ _ - _ - _ _ _ _ _ -
.
.
-
-
--
- - -.._- - - -. - - - - - - _ -.
_,
.
.
-
.
'
PY-CEI/NRR-1581 L
,
Attachment 1
Page 4 of 6
.
Reason for the Violation Perry participates in several industry groups involved in the development of guidance associated with HOV test programs.
Perry has performed evaluations
.
of MOV Program test results on a case-by-case basis while reviewing applicable
'
industry recommendations regarding acceptance criteria for evaluating differential pressure testing. No generic guidance for evaluating the referenced test results has been developed.
Corrective Actions Taken and Results Achieved
,
Perry is currently participating with the Boiling Vater Reactors Ovner's Group (BVROG) to complete a position paper on differential pressure testing
_
,
acceptance criteria. A draft position paper recently issued by the group is under evaluation for incorporation into the Perry HOV program.
Actions to Avoid Further Violations Perry vill develop a procedure with appropriate acceptance criteria for evaluating data from design basis differential pressure testing prior to January 1, 1993.
No additional differential pressure testing is anticipated prior to that date.
Data Vhen Full Compliance Vill Be Achieved
,
Full Compliance with the cited 10 CFR 50, Appendix B criterion vill be by January 1, 1993, upon approval and implementation of the referenced procedure for evaluating test results.
-50-440/92018-02 Restatement of the Violation.
10 CFR 50, Appendix B, Criterion III requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design
'
basis, as defined in 10 CFR 50.2, are correctly translated into-specifications, drawings, procedures, and instructions. These measures-shall included provisions to assure that appropriate quality standards are specified and included in the design documents and that deviations f tom such standards are controlled.
Contrary to the above, as of September 3,1992, an inappropriate equation (Limitorque's " stall thrust" equation) vas used in calculations to evaluate the design basis capability of safety-related H0Vs and resulted in at at least two inoperable valves (the outboard. reactor core isolation cooling and-reactor i
vater cleanup containment-isolation valves) going undetected until appropriat:
l calculations were performed in response to the NRC inspection.
Reason for the Violation-L Stall torque is one of several values calculated to determine the approximate loads the operator and the valve may experience under a stall condition.
Calculation of this value is required since Perry utilizes a by-pass torque
-
l~
i
. _.
-
'
'
PY-CEI/flRR-1581 L I
Attachment 1 Page 5 of 6
-
switch design for at least 95 percent of the stroke.for safety related valve in close direction and does not utilize the torque switch in the open direction.
During the close cycle, the HOV is running at the rated speed and the inertia of the drive train adds significantly to the transfer of thrust into the valve seat. This control circuitry allovs the valve operator to exert torque / thrust up to and including stall torque for design basis event conditions. Other parameters such as pull-out torque / efficiency were also evaluated for the purpose of determining loads experienced by the valves during operation.
'
Per discussion with motor the manufacturer, Reliance Electric, any MOV motor should be capable of producing the stall torque shown on the associated motor performance curve when required.
Stall efficiency and run efficiency for most of the H0Vs are the same including the Supplement 3 HOVs. Our own limited static testing has demonstrated that Limitorque's stall efficiency values may be conservative. Test results have shown an increase of torque and thrust over what is calculated.
The degraded voltage calculation uses highly conservative locked rotor current for deriving voltage at the motor terminal. This is the current-that produces the highest motor torque (stall torque) and the greatest voltage drop.
As noted during the NRC insp m ion, Perry engineering personnel vere aware of information provided by Limitorque and the Electric Pover Research Institute (EPRI) which recommended against using stall efficiency to evaluate HOV capability. However, since there was additional' industry and site specific information available to justify use of the stall equations, Perry engineering personnel believed that it was appropriate to use stall torque equations as a means of measuring MOV performance.
It is recognized that the use of the_ stall efficiencies for sizing applications is considered to be improper. The use of stall efficiency in HOV capability equations has therefore been discontinued.
'
Actions Taken and Results Achieved Perry performed a preliminary evaluation to determine the reduced voltage
,
capability of valves included in the GL 89-10' program based on the following
'
equations pur Limitorque letter dated September 17, 1992 from Limitorque and found that the H0Vs are acceptable.
l-1)
Capability in the opening direction (Hotor Start Torque) X (Overall Ratio) X (Pullout Efficiency) X
]
-(Application Factor) X (Reduced Voltage Factor)
2) _ Capability in the closing direction (110L of Hotor Start Torque) X (Overall Ratio) X (Run Efficiency) X (Application Factor) X (Reduced Voltage Factor)
All future MOV capability evaluations vill be performed using the above equations.
-
'.
~
I
'
, PY-CEI/NRR-1581 L.
Attachment 1
-
Page 6 of 6
..
Actions to Avoid Further Violations Since use of th'e referenced stall thrust equation has been discontinued, no additional corrective actions are deemed necessary to preclude similar violations.
Date Vhen Full Compliance Vill Be Achieved Full compliance with the cited 10 CFR 50, Appendix B criterion was achieved upon discontinuation of the use of the referenced stall thrust equation.
_
S.
-
_.-.__m__-_____-
. _ _.... _ _ _ _. _ _ _
_. _ - _ _ _ _ _. _....
._
_.. _ _ _ _.. _ _ _ -