ML20106A745

Responds to NRC Re Deviations Noted in Insp Rept 50-346/92-10.Corrective Actions:Licensee Will Continue to Determine Appropriate & Feasible Methods of MOV Testing to Obtain Useful Test Data,Per GL 89-10

ML20106A745
Person / Time
Site:	Davis Besse
Issue date:	09/21/1992
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-995, GL-89-10, NUDOCS 9209290373
Download: ML20106A745 (4)

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CENTEWOR ENERGY

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Donald C. Shotton yg g

\<e P:moent Nxleaf 1oledo OH OM20001 Dah (419)2492X10 Docket Number 50-346 License Hornber NPT-3 Settal Number 1-995 Septembe 21, 1992 linited Stnten Nuclear Regulatory Commission Document Conttol Desk Vashington, D. C. 20555 Subjert: Response to Inspection Report Number 50-346/92010 Gentlement Toledo Edison (TE) has received Inspection Report 92010 (Log Number 1-2721) dated August 20, 1992, and ptovides the following rest.onse.

Deviation 92010-03: Genetic Letter (GL) 89-10, St'pplement 1. Question 37, recommended that motor-operated valves (HOVs) should be tested as close to design basis conditions as practicable and, if necessary, later demonstrate <. operable under design-basis conditions when test data applicable to those conditions becomes evallable. The January 5, 1990, and November 6, 1490, responses to the GL did not take exception to this iceommendation.

Conttatf to the above, as of July 29, 1992, Davis-Besse did not plan to perform differential pressute and flow testing for some HOVs where a diffetential pressure of at least 70%

of design ba is could not be achieved.

Response: Reason fot the Deviation on Jtine 28, 1989 (Log Number 2984), the NRC issued GL 89-10, "Saf ety Related Motor-Operated Valve Testing arid Surveillance", to all licensees of Nuclear Power Plants.

Item e under " Recommended Actions" stated, in part, "the MOV should be demonstrated to be operable by testing it at the d "is"-b"'5" diffarentia n'e"$"' e r"d'or f 2ov d* tera "ed i" 95'001"I iesponse to Item a. Testing MOVs at design-basis conditions is not tecommended where such testing is precluded by the existing plant configuration". Item f of the " Recommended f 9209290373 920921 l () .

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,, .' Docket Number 50-346 License Number HPF-3 Serial Number 1-995 Page 2 Actions" states, in part, " Alternatives to testing a particular MOV in situ at design-basis pressure or flov, where such testing cannot practically be performed, could include a comparison with appropriate design-basis test results on other HOV's, either in situ or prototype. If

, such teet information is not available, analytical me* hods and extrapolations to design-basis conditions, based on the best data available, may be used until test data at design-basis conditions become available to verify operability of the MOV."

In a January 5, 1990 letter (Serial Number 1748), in response to Item e, TE stated that, " Toledo Edison can not test all H0V's under full flow test conditions.

Approximately 40 out of 165 safety related valves have been tested at maximum differential pressure with 10 of these ,

valves being tested under full flow conditions . . . Toledo- ,

Edison is currently evaluating any further flow testing that may be possible. It is expected that only approximately 35%

of the HOV population vill be testable under these conditions."

On June 13, 1990 (Log Number 3260), the NRC issued '

Supplement 1 to GL 89-10. "Recults of the Public Vorkshops."

This letter was issued subsequent to TE's initial response to GL 89-10. The response to question 37 of this letter provided further clarification as to acceptable testing ,

methods for HOVs. No response to this ' letter vas required  !

from Toledo Edison.

On August 8, 1990 (Log Numbet 3300), the NRC staff revieved TE's response to Generic Letter 89-10 and recommended the use of the "two stage" approach for testing of MOVs as described in the GL and GL 89-10, Supplement -1 unless alternative means could be justified. No response to this recommendation was requested, however, TE vas requested to provide a schedule for completion of the HOV testing-program. Toledo Edison provided the requested information by letter dated November 6, 1990 (serial Number 1870).

Based upon the above_coreespondence, TE developed an HOV Program Manual. In the section of the manual entitled

" Testing", TE stated, " Dynamic testing is performed.as close

. to limiting conditions as possible. Davis-Besse has evaluated all of'its Generic Letter 89-10 valves for applicability of-full flow testing. The results of this evaluation indicate that at'the present time approximately 32% of Generi Letter 89-10 MOVs can be tested at 70% of limiting conditions. Although additional valves may be tested, it is felt that test conditions less than 70% of limiting conditions may not yield data that'can be extrapolated."

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., l Docket Number 50-346 License Number NpF-3 l

Serial Number 1-995  ;

p. age 3 -

The 70% criterion mentioned above vas intended to be used as a test scheduling tool by TE. Data obtained from this  ;

testing would be used in analyses to justify whether or not i further testing vas necessary. Additional testing would be scheduled and performed in the event useful data was not i available. This data vould also be used to analytically  ;

assure operability of valves that could not be tested.  ;

Toledo Edison believed this position to be consistent with  !

the approach given by the NRC in GL 89-10 and GL 89-10, ,

Supplement 1 (See NRC response to questions 22, 24-28 and ,

37).

During July of 1992, the NRC conducted its routine safety inspection of TE activities in response to GL 89-10. The inspectors revieved the MOV Ptogram Manual, which identified valves to be differential pressure tested. The NRC inspection team van advised that the initial criterion for testing was based on the ability to achieve a nominal 70% of design basis differential pressure and/or flow. Valves in which this value could not be' achieved would be evaluated after testing of those valves that met the 70% criterion.

At that time, testing of valves that did not meet the 70%

criterion was not scheduled. It was TE's intent to schedule these valves for testing, if necessary, during Cycle 9 and the Ninth Refueling Outage (9RFO) based upon results of testing during the Eighth Refueling Outage (3RFO). This approach is consistent with the "tvo-stage" approach identified by_the NRC in their August 8, 1990 letter (Log Number 3300).

Corrective Actions Taken and Results Achieved By using the prioritization method described above, TE continues to be committed to testing as practicable as stated in its letter dated November 6, 1990 (Serial Number 1870).

The approach to testing described above, and TE's understanding of its commitments with regard to the MOV program vere discussed with Region III Management on August 2),-1992.

Revisions to the_MOV Program Manual _necessary to incorporate the approach to testing described above vere implemented on September 14, 1992.

Corrective Steps To Avoid Future Deviations Toledo Edison vill continue to determine the most appropriate and feasible methods of MOV testing to obtain useful test data. Toledo Edison plans to vork to analytically model the MOVs, with those MOVs believed to have the smallest _ margins receiving highest priority. The

... Docket Number 50-346 License Number NPT-3 Serial Number 1-995 L' age 4 valve manufacturers' dimensional tolerances, or if varranted actual dimensions, vill be input into the analytical model and valve performance vill be verified by testing, where practical. This represents a "tvo-stage" approach using the latest engineering principles as described in Gb 89-10 and '

CL 89-10, Supplement 1. It is anticipated that TE vill }

complete valve testing from which useful data is expected to- i be obtained by the end of 9RPO as originally committed. By this date, adequate technical justificatfor vill be provided i for valves that cannot be tested. Toledo Edison also intends to use data from prototype MOV testing sponsored by the Electric Pover besearch Institute (FPRI) under the valve performance prediction program. The'EPR1 efforts in prototype testing are expected to be completed-in early 1994.  ;

Date Corrective Actions Vill Be Completed Tha cortective steps described above vill be completed by the end of 9RF0, currently' scheduled for the fall of 1994.

Should you have any questions or require additional information, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.

Vety ly youts, I F2(g a NKp/dic cc A. B. Davis, Regional Administrator, NRC Region III ,

J. B. Ilopkins. NRC Senior Project Manager R. K. Valton, DB-1 NRC Resident Inspector ,

Utility Radiological Safety Board -!

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