ML17286A910

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Discusses Weaknesses in WNP-2 MOV Program,Per Generic Ltr 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance. Current Program Does Not Appear to Make Adequate Use of Industry Knowledge & Experience
ML17286A910
Person / Time
Site: Columbia 
Issue date: 06/28/1991
From: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Mazur D
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
GL-89-10, NUDOCS 9107100287
Download: ML17286A910 (4)


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/p UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIALANE,SUITE 210 WALNUTCREEK, CALIFORNIA94596 June 28, 1991 Docket No. 50-397 Washington Public Power Supply System P. 0.

Box 968 3000 George Washington Way Richland, Washington 99352 Attention:

Mr. D.

W. Mazur Managing Director

SUBJECT:

WEAKNESSES IN WNP-2 MOTOR OPERATED VALVE PROGRAM OBSERVED DURING NRC INSPECTION (INSPECTION REPORT 91'-16 SIMS ISSUE GL-89-10)

An NRC inspection was conducted at WNP-2 during the period of May 20 through June 21, 1991,'o evaluate the adequacy of Supply System actions to assure the reliability of motor operated valves (MOVs).

Our inspectors reviewed the program that you have developed in response to NRC Generic Letter GL 89-10, "Safety-Related Motor Operated Valve Testing and Surveillance."

Generic Letter GL 89-10 provides recommendations for licensees to develop and implement programs to ensure that MOVs will operate properly under design basis conditions.

The NRC is evaluating licensee implementation of GL 89-10 provisions in two parts:

an initial inspection focussing on the adequacy of program definition and a subsequent inspection following licensee implementation of revised MOV settings based on design basis valve testing.

The results oF our initial MOV program inspection were discussed with Mr. J.

Baker and other members of your staff during an exit meeting on June 7,

1991.

A detailed inspection report will be forwarded to you in the near future.

How v r, the inspection,id'entified a number of concerns which we consider warrant your prompt attention.

In particular:

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Your current MOV program does not appear to make adequate use of industry knowledge and experience.

2)

Increased management commitment appears necessary to ensure the quality of MOV technical work, and to ensure timely implementation of the MOV test program.

3)

Increased guality Assurance oversight appears necessary to ensure DropeI trending and evaluation of MOV-related deficiencies, and to ensure timely completion of commitments.

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A brief discussion of examples of observed deficiencies in these areas follows:

d As discussed in GL 89-10, industry experience and research demonstrate that using industry standard equations may not be conservative, in predicting MOV performance.

In establishing sufficient margin to ensure NOV performance, GL 89-10 recommends consideration of recent industry insights on parameters affecting design basis oper'ability.

Where feasible, safety-related MOVs are to be tested at maximum design conditions to demonstrate design basis operability.

In this regard, the inspectors noted that WNP-2 continues to use a

design methodology based on the old industry standard equations and valve factors, which do not conservatively account for certain factors affecting actuator performance.

This places heavy emphasis on the design basis testing portion of the program.

Although, based on current analysis and testing results, WNP-2 MOVs are considered to be operable, incorrect design methodology may significantly reduce available design margin an'd potentially impact valve operability.

The inspectors cautioned that fai lure of an MOV to perform its safety function under design basis test conditions would impact not only the ope'r'ability of the "failed" NOV, but also all other NOVs which use the same design methodology.

The inspectors noted that WNP-2 does not participat'e in the Region V NiOV users group.

Some of the deficiencies observed at WNP-2 have already been addressed at other Region V nuclear plants.

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~dd Your NOV program appears to lack depth in personnel.

At present only one engineer, a newly assigned NOV Coordinator, is fully dedicated to the program, and most of his efforts have focused on problems encountered during the current outage.

According to your NOV program description, approximately 30K of the GL 89-10 NOV des,ign basis testing was to have been completed by the time of the NRC inspection.

However, the inspectors noted that none of these tests have been performed, nor have testing procedures been developed.

Need for

~lm roved iLA Overs~iht of Program Activities Although two years of the five-year WNP-2 MOV program have

passed, no comprehensive licensee audit of the program has been performed, nor is it clear that identified problems have been brought to the attention of senior management.

gA spot checks have identified significant findings which should have alerted licensee management to NOV program inadequacies.

Furthermore, our inspection identified several areas (e.g.,

testing, seismic and environmental considerations) that appear to deviate from commitments you made in response to GL 89-10.
Also,

,the inspectors noted that many MOV actuator deficiencies have only been dealt with at the maintenance level, without providing adequate documentation, trending or engineering evaluation.

In view of the importance of maintaining your five-year MOV program aligned.

with your stated objectives, we urge you to reflect on the current direction of the program, and to promptly assess the need for improvements in the areas discussed above.

You are requested to specifically address the concerns noted in this letter in your response to NRC Inspection Report 91-16.

In accordance with 10 CFR 2.790(a),

a copy of this letter will be placed in the NRC Public Document Room.

Should you have any questions concerning this

letter, we wil,l be please to discuss them with you.

S

erely, J.

B. Martin Regional Administrator CC J.

M. Baker, LlNP-2 Plant Manager A. G. Hosier, HNP-2 Licensing Manager G.

D. Bouchey, Director, Assurance 5 Licensing G.

E.

Doupe, Esq.,

HPPSS A. Lee Oxsen, Deputy Managing Director State of MA M. H. Phillips, Esq.

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