ML20134Q361

Forwards Staff Evaluations Addressing Two Specific Issues, One Involving Acceptability of pre-lubricating Valves Prior to Testing & One Involving Effect of Using Operator Action in Place of Automatic Action

ML20134Q361
Person / Time
Site:	Saint Lucie, Crystal River
Issue date:	11/19/1996
From:	Landis K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Beard P FLORIDA POWER CORP.
Shared Package
ML17309A847	List: ML20134Q361
References
NUDOCS 9612030013
Download: ML20134Q361 (3)

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November 19, 1996 l

Florida Power Corporation l Crystal River Energy Complex L Mr. P. M. Beard, Jr. (SA2A) l Sr. VP, Nuclear Operations i l ATTN: Mgr., Nuclear Licensing  ;

l 15760 West Power Line Street l Crystal River, FL 34428-6708 l

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SUBJECT:

REGULATORY ACCEPTABILITY OF PRE-LUBRICATING VALVES PRIOR TO  :

l TESTING (TIA 96-007) AND USING OPERATOR ACTION IN PLACE OF l AUTOMATIC ACTION (TIA 95-013) ,

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Dear Mr. Beard:

l Enclosed are NRC staff evaluations addressing two specific issues which are provided for your information. One evaluation involved the acceptability of l pre-lubricating valves prior to testing. The second evaluation involved the effect of using operator action in place of automatic action.

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Should you have any questions concerning this matter, please contact me at (404) 331-5509.

Sincerely, 1 Orig signed by Kerry D. Landis l Kerry D. Landis, Chief I l Reactor Projects Branch 3 l_ Division of Reactor Projects l

Enclosure:

As stated

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l Docket Nos. 50-302 i

License Nos. DPR-72 cc w/ encl: l Gary L. Boldt, Vice President  !

Nuclear Production (SA2C)

Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 l i cc w/ enc 1: Continued see page 2

)i OFFICIAL COPY i  !

020045 i  !

9612030013 961119 PDR ADOCK 05000302 l P PDR  !

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! FPC 2 cc w/ encl: Continued B. J. Hickle. Director i

Nuclear Plant Operations (NA2C)

Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 l

L. C. Kelley. Director (SA2A)

Nuclear Operations Site Support Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 R. Alexander Glenn Corporate Counsel Florida Power Corporation MAC - ASA i P. O. Box 14042 St. Petersburg FL 33733-4042 Attorney General Department of Legal Affairs The Capitol Tallahassee FL 32304 j

, t Bill Passetti '

Office of Radiation Control De)artment of Health and lehabilitative Services i 1317 Winewood Boulevard i Tallahassee FL 32399-0700 l Joe Myers. Director Division of Emergency Preparedness 4 Department of Community Affairs 2740 Centerview Drive '

Tallahassee. FL 32399-2100

, Chairman l Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness. FL 34450-4245 l Robert B. Borsum

. Framatome Technologies 1700 Rockville Pike. Suite 525

, Rockville. MD 20852-1631

I FPC 3  :

Distribution w/ encl:  ;

L. Raghavan. NRR l B. R. Crowley. RII  ;

G. Hopper. RII i PUBLIC i NRC Resident-Inspector U.S. Nuclear Regulatory Comission 6745 N. Tallahassee Road {

Crystal River. FL 34428 t

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OFFICE SIGNATURE

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DATE 1 / [4 / 96 11 / / 96 11 / / 96 11 / / 96 11 / / 96 11 / / 96 COPY? (YKjf NO YES NO - YES NO YES NO YES NO YES NO UrPALIAL HLLUKU LUPY UULUMLN1 NAM . . b; \LRYM AL\Lti itK\Lkl1ALI.11 j i

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. mi )

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July 2,1996 l MEMORANDUM TO: Jon R. Johnson, Acting Director Division of Reactor Projects, RII 3

FROM: Frederick J. Hebdon, Director ,

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. Project Directorate II-3 Division of Reactor Projects I/II, NRR i

SUBJECT:

TECHNICAL ASSISTANCE REQUEST (TIA 96-007) REGULATORY ACCEPTABILITY OF LUBRICATING VALVES PRIOR TO SURVEILLANCE -

l TESTING (TAC NOS. M95274 AND M95275)

In a memorandum dated April 12, 1996, as a result of valve stroke timing l practices at the St. Lucie Plants, you requested NRR assistance in evaluating

( the acceptability of lubricating valves prior to the performance of stroke time testing. You also asked NRR to resolve a question as to whether the l

purpose of the stroke time testing was to demonstrate current and past i operability of a valve, current and future operability of a valve, or both.

The Mechanical Engineering Branch (EMEB), NRR, has completed its review of these issues. A discussion of these issues and NRR's response to your questions is contained in the attached memorandum dated June 24, 1996.

Docket Nos.: 50-335 and 50-389 l

Attachment:

As Stated cc w/ attachment: R. Cooper, RI

W. Axelson, RIII 1 J. Dyer, RIV l i

Contact:

L. Wiens, NRR\PDII-3 i 415-1495

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4 June 24, 1996 NEMORANDlM TO: Frederick J. Hebdon, Director Project Directorate II-3 Division of Reactor Projects I/II FRON: Richard H. Wessman, Chief Mechanical Engineering Branch Division of Engineering SU8 JECT:

TECHNICAL ASSISTANCE REQUEST (TIA 96-.007)

REGULATORY ACCEPTABILITY OF PRELUBRICATING VALVES (TAC Nos. M95274/M95275)

In a memorandum dated April 12, 1996 Ellis W. Marschoff, Director, Division of Reactor Projects, Region II, discussed the determination by Region II inspectors t. hat the licensee of the St. Lucia nuclear power plant had lubricated a containment spray flow control valve prior to perfoming stroke time testing under Section XI of the ASME Boiler & Pressure Vessel Code. The t Region II inspectors considered this pre-lubrication to result in a j nonrepresentative test of valve capabilities, i

l Region II requested the Office of Nuclear Reactor Regulation (NRR) staff to respond to specific questions on the acceptability of the licensee's actions in pre-lubricating valves prior to testing. Attached is our response to those questions.

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CONTACT: T. Scarbrough, DE/EMEB l 415-2794 Docket Nos.: 50-335 50-389

Attachment:

As stated cc w/ attachment: J. T. Wiggins A. F. Gibson G. E. Grant Distributinar l Central Files l EME8 RF/ CHROM LWiens RCroteau Valve List DOCUMENT NAME: 6:

r. e.e.sv. . e.w .* ens e \. ne. SCARinnie. 8R00\RHWLU8E

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, NAME TScaNrough RWess [

DATE $/.M96 L/%f96

' 0FFICIAL RECORD COPY

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A1TACitiENT

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REGULATORY ACCEPTABILITY OF PRELUBRICATING VALVES PRIOR TO SURVEILLANCE TESTING j

(TIA 96-007)

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j Technical Assistance Raouant i

j In a memorandum dated April 12, 1996, Ellis W. Merschoff, Director, Division of Reactor Projects, Region II, discussed the determination by Region II inspectors that the licensee of the St. Lucia nuclear power plant had lubricated a containment spray flow control valve prior to performing streks-time testing under Section XI of the ASIE Boiler and Pressure Vessel (MPV)

Code. The Aegion II inspectors considered this pre-lubrication to result in a nonrepresentative test of valve capaht11 ties. Therefore, Region II requested a response to the following questions:

1. Is the practice of lobricating a valve prior to stroke-time testing acceptable under the regulations?

2. Is the purpose of stroke-time testing under ASME Section XI to '

i demonstrate the current and past operability of a valve, the current and future operability of a valve, or both?

Evaluation The NRC mgulations in 10 CFR 50.55a require that nuclear power plant licensees provide valves and pumps within the scope of Section XI of the ASME B&PV Code with access to enable the performance of inservice testing of those valves and pumps for assessing operational readiness as set forth in Section XI of the ASME B&PV Code. Criterion XI, " Test Control," of Appendix 8 to 10 CFR 50 requires that testing be performed under suitable environmental conditions. The current Inservice Testing (IST) Programs at St. Lucie Units 1 and 2 are based on the requirements of Section XI of the ASME B&PV Code, 1986 Edition, with approved relief to certain requirements. Article IWV-1000 of ASME B&PV Code (1986 Edition),Section XI, states that it provides the rules and requirements for inservice testing to assess operational readiness of certain Class 1, 2, and 3 valves in nuclear power plants, which are required to perform a specific function in shutting down a reactor to the cold shutdown condition, in mitigating the consequences of an accident, or in providing overpressure protection. I Subarticle IW-3417 of the 1986 ASME B&PV Code states that, if a valve fails to exhibit the required change of valve stem or disk position or exceeds its specified limiting value of full-stroke time by this testing, the licenses sha11' initiate corrective action immediately with the valve declared  :

inoperative if the condition is not corrected in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Generic Letter '

(GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," in Position 8 indicates that, rather than delaying 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the l' consee should .

make a decision on operability when the data is recognized as being within the required action range. GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming ATTACMENT

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I Conditions and on Operability," provides similar guidance on the timeliness of operability decisions based on test results. IW-3417 also requires that the i

test frequency be increased if a significantly longer stroke time is observed since the last test. Finally, IW-3417 requires that any abnormality or i erratic action be reported. The St. Lucie IST Program Plan identifies no j

differences in interpretation of the NRC regulations or ASME Code when stating I

that the inservice testing in the plan is to be performed specifically to j verify the operational readiness of pumps and valves which have a specific i function in mitigating the consequences of an accident or in bringing the reactor to a safe shutdoun.

' More recent ASME codes and standards have repeated and amplified the importance of evaluating the operability of valves during inservice testing.

For example, Subsection ISTC, " Inservice Testing of Valves in Light-Water Reactor Power Plants," of the ASME Operation and Maintenance (Wic) Code states that it establishes requirements for inservice testing to assess the operational readiness of certain valves and pumps used in nuclear power plants. Subsection i ISTC 4.2.9 requires that the valve be immediately declared l inoperable if the valve exceeds the limiting values of full stroke time.

j Subsection ISTC 4.2.4 also requires that any abnormality or erratic action be-recorded and that an evaluation be made regarding the need for corrective i action.

The NRC regulations, and ASME codes and standards, clearly indicate that the purpose of the inservice testing programs is to " assess" the operational readiness of the valves and pumps. Article IWA-9000, " Glossary," of ASME B&PV Code (1986 Edition),Section XI, defines " assess

• as detemining "by evaluation of data compared with previously obtained data such as operating data or design specifications." More

, University Dictionary defines " assess

• generally, as "to appraise Webster's II New Riverside or evaluate." If maintenance is performed prior to inservice testing that ensures the l capability'of a v&lve or pump to operate properly, the licensee's IST program would be unable to evaluate the operational readiness of the component. 'his i

' is reinforced by the requirement in the ASME Code that, if the stroke-time limits are exceeded, the condition be corrected or the valve be considered inoperable. The St. Lucio IST Program Plan intent "to verify the operational readiness" is more specific regarding the purpose of the. testing to determine j the capability of the valves to perform their safety function.

The ASME Code recognizes that routine preventive maintenance will be performed l by licensees. In some instances, this maintenance may occur shortly esfore a i scheduled test required by a licensee's IST program. The effect of this j aaintenance on the validity of the test to assess operational readiness should

' be evaluated. In Secties 3.5, " Testing in the As-Found Condition," of NEEG-1482 (April 1995) " Guidelines for Inservice Testing at Nuclear Power Picats,' the staff stated that the Code does not specifically require testing i

to be performed for components in the as-found condition except for safety and i relief valves, but does not define as-found even in the context of safety and i relief valves. In NUREG-1482, the staff noted its belief that most inservice i

testing is performed in a manner that generally represents the condition of a j

standby component if it were actuated in the event of an accident (i.e., no pre-conditioning prior to actuation).

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In MC Infomation Notice 96-24 i

Case Circuit 8reakers Before Surv(April 25,1996), "Procenditioning of Molded-eillance Testing," the staff stated that the

! practice of preconditioning molded-case circuit breakers (for example, by j lubricating of the periodic pivot tast.points and manually cycling the breaker) defeats the The staff stated that such preconditioning does not confirm continued operability between tests nor does it prov nfomation on i the condition of the circuit breaker for trending purposes. ide The' applicable j licenseethis correct planned to revisa its procedures before the next surveillance test situation.

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j In ASME Code Case QM-1, " Alternative Rules for Preservice and Inservice

Testing of Certain Electric Motor Operated Valve Assemblies in UR Power

plants (GM - Code - 1995 Edition; Subsection ISTC)," the ASME provides an 1 alternative to the stroke-time testing requirements of the ON Code to assess

the operational readiness of motor-operated valves (MDVs). The code case uses i the same language as the NRC regulations and ASME I In implementing the code case, the licensee is required to detemine the capability of the M0V during inservice testing. The code case requires MOVs to be on cycledintervals.

periodic at least'every refueling cycle with diagnostic testing conducted-The code case allows grouping of MOVs with the t 4 information group. obtained from individual MOV tests applied to other MOVs in the i In Section 3.3, the code case specifically states that maintenance j activities, such as stem lubrication, shall not be conducted if they might i invalidate the as-found condition for inservice testing. The performance of

! maintenance prior to testing would defeat the ability to detamine any

! degradation in the operation of the tested MOV and to apply the test results l i

to other MOVs within the group. This code case is being endorsed (with j 1 certain licensees limitations unrelated in a forthcoming to preconditioning) generic letter. for voluntary use by 1

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) In summary, the performance of maintenance on a component to ensure its pro  :

j operation prior to conducting a test negates the validity of the test in 1

assessing the operational readiness of the component. If the maintenance had 1 not been performed, the component may not have been capable of perfoming its f safety function. Clearly the conduct of maintenance prevents the licensee from assessing if the comp,onent would perform as design, should it be called upon.

Further, important information on trending of operating parameters for i

evaluating degradation would not be available.

} EMEB Resoonse In response to the specific questions from Region II:

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l The performance of maintenance that ensures the capability of a valve to

! satisfy the stroke-time test requirements of the ASME Code provides a i

false indication of the operational readiness of the valve. Therefore, i a licensee activity to lubricate a valve prior to stroke-time testing for the principal purpose of satisfying the test criteria at that

! specific time would not be considered to be within the intent of the NRC i

regulations under 10 CFR 50.55a or Appendix 8 to 10 CFR 50. It is recognized that routine preventive maintenance, such as valve i.

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i i lubrication, alght coincide occasionally with IST program testing.

i those cases, the effect of such maintenance needs to be evaluated to In ensure that the ability to assess operational readiness of the valves and to trend degradation in the valve perfomance are not adversely affected.

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( The NRC regulations, establish IST pro and ASME codes and standards, require licensees to

valves and pumps. grams to assess the operational readiness

! is required to declare the valve inoperable.

test is intended to demonstrate current operability.Therefore, The licensesthe stroke-t I

evaluates past operability since the previous stroke-time testchesed in part on the most current test results. The ASME Code prescribes i comparison of stroke-time test data to previous test data se that i licensees may obtain an indication that the valve should remain operable untti the next test. It is recognized that the stroke-time test is

! limited in its effectiveness and, as a result, the ASME developed an alternative IST approach for MOVs in ASME Code Case 0f06-1.

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