ML20245L537

Advises That CRGR 890309 & 20 Revs to Generic Ltr on motor- Operated Valves Fully Satisfy Committee Recommendations. Matter Closed

ML20245L537
Person / Time
Issue date:	03/29/1989
From:	Conran J Committee To Review Generic Requirements, NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	Baer R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20245L355	List: ML20245L351 ML20245L537
References
NUDOCS 8905080068
Download: ML20245L537 (9)

Text

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Ma rch 29,1989 i

MEMORANDUM FOR:

Robert L. Baer, Chief 1

j Engineering Issues Branch, Division of Safety Issue l

Resolution, RES I

FROM:

James H. Conran CRGR Staff, AEGU

SUBJECT:

CRGR RECOMMENDAlf0NS ON MOV GENERIC LETTER The CRGR completed their. review of the RES-sponsored Generic Letter on MOVs at Meeting No.158.(see Minutes attached).

Subsequer.tly, 'as recomended by the Committee in these minutes, CRGR staff and RES staff coordinated closely in modifying the proposed letter to accomodate the Comittee's recommendations.

A revised version of the generic letter _ reflecting the RES response to CRGR's recommendation in this matter was transmitted by memorandum dated March 9, L

1989, R.W. Heuston to E.L. Jordan; a further revised version reflecting i

CRGR/RES staff ciscussion ef. the March 9 RES response was transmitted by 5520 on March 20, 1989.

The purpose cf ttis meccrar.due is to document my determination, as the cogni-zant CRGR staff mescer in this matter, that the revisions in effect following the CRGR/RES staff interactions referred to above fully satisfy the Comit-f' tee's recommendatfor.s in this satter.

(Subsequently, one other minor change l

was requested anc r. ace tc the wording at the top of page 6 of the March 20 revision.) Except for the formal closure memorandum from the sponsoring e

Office Director to the CRGR Chairman (required by the CRGR Charter for all l

CRGR review items that result in recommendations), this matter is considered closeo.

I unoerstand that we will receive that final closure memorandum fros; the Director, RES shortly, following your planned meeting with ACES on this itel.

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James H. Conran

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CRGR Staff, AE0D 4

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E.L Jordan C.J. Heltemes 1

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March 28, 1989 MEMORANDUM FOR:

Victor Stello, Jr.

Executive Director for Operations FROM:

Edward L

'ordan, Chainnan Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 158 1

4 The Cocnittee to, Review Generic Requirements (CRGR) met on Wednesday, February 22, 1989 from 12:00-6:00 p..T..

A list of attendees for this meeting is l

attached (Enclosure 1 ).

The following items were addressed at the meeting:

)

l 1.

R. Rcbinscn (RES) and C. Jchmon (RES) briefed the Comittee on the PETS program (procedures for evaluating technical specifications) which is used to estimate the risks asso:iated with prcposed tech spec changes.

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1 The briefing provided the staff's analysis of possible cuinulative effects of multiple relaxations of plar.t technical specifications on equipment surveillance intervals and allowable outage times (cor:sistent with the objective of reducing on-line testing). The Comittee comended the staff en the quality of the briefing and the close coordination

)

apparent among the various cognizant staff in assessing this issue, and 1

further stated that the staff's method for tracting the cumulative a

l effects of the tech spec improvement program appeared satisfactory.

A l

copy of the briefing slides used by the staff is included as Enclosure 2.

l In addition, the Comittee considered topical report WCAP-10271 l

Supplement 2. " Evaluation of Surveillance Frequencies'.and Out of Service Times for the Engineered Safety features Actuation System," and determined that the staff's approvM was adequate and additional CR6R review was not needed.

I i

1.

W. Mi'iners (RES) and F, Cherny (RES) soresented for CRGR review a proposed generic letter on repinement of components constructed to ASME Section III requirements. The Cceittee recomended in favor of issu'ing the proposed generic letter, subject to several modifications which are to be coordinated with the CRGR staff.

This matter is discussed in.

3.

R. Baer (RES) and O. Rothberg (RES) presented fer CRGR review a proposed generic Ictter en periodic testing and surveillance of safety-related motor-operated valves. The Comittee recomended in favor of issuing the proposed generic letter, subject to several modifications which are to be coordinated with the CRGR staff. This matter is discussed in Enclosure 4.

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In accordance with the E00's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response, which is required within fiv.e working days after L

receipt of these sinutes, is to be forwarded to the CRGR Chairman and if there is disagreement with CRGR recommendations, to the ED0 for decisionmaking.

i Questions concerning these meeting minutes should be referred to Jim Conran l

(492-9855).

Original Sign 4f 8'f3 l

B Q h

• dan Edward L. Jordan, Chairman Conmittee to Review Generic Requi rements

Enclosures:

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As stated cc w/ enclosures:

Commission (5) j l

SECY l

' Office Diri:ctors I

Regional Administrators CRGR Members Olstribution: w/o enclosures Central FITe-PDR-(NRC/CRGR) l E. Rossi f

R. Robinson C. Johnson R. Minners

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F. Cherny

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R. Baer-v>~

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0. Rothberg S. Treby W. Little M, Lesar P. KaQmbi (w/ enc.)

CRGR CF (w/ enc.)

l CRGR SF (w/ enc.)

M. Taylor (w/ enc.)

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E. Jordan (w/ enc.)

l J. Heltemes (w/ enc.)

l-J. Conran (w/ enc.)

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C. Sakenas (w/ enc.)

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3/]Lf89 DATE : 3/c'-/89

3/ /89 0FFICIAL RECORD COPY

E w w,u e.0 1 Meet 4 oP6

, to the Hinutes of CRGR Meeting No,158 Proposed Generic Letter on Motor-Operated Valves February 22, 1989 TOPIC y

R. Baer (RES) and O. Rothberg (RES) presented for CRGR review a (revised) proposed generic letter to provide guidance to licensees on periodic testing-and surveillance of ' safety-related motor-eperated valves (NOVs) and position-

. changeable NOVs.

(CRGR considered an earlier version of this proposed letter at Meeting No.148.) Copies of the briefing slides used by the staff to guide the staff's presentation and the discussions with the Comittee at this 4

meeting are enclosed { Attachment 1).

i BACKGR00hD The documents submitted for CRGR review in this matter were transmitted by memorandum dated March 9,1989, R. W. Houston to E. L. Jordan; the review package included the following documents:

1.

Revised draf t Generic Letter -(uncated), " Safety-Related Motor-Operated Valve Testing and Surveillar.ce," and enclosure:

1

' Attachment A

" Summary of Comen Motor-0perated Valve Deficiencies, Hisaojustments, anc Degradec Ccncitions" CONCLUSIONS / RECOMMENDATIONS As a result of their review of this c.atter inclucing the discussions with the 1

staff at Meeting Nos. ~148 ano 158, the Cosmittee recommended in favor of -

i.

issuing the revised generic letter, subject to the following additional changes discussed at this meeting:

^

l 1.

.For improved clarity ano ease of reacing, civice tne proposed letter o

into three main shetict.s '(e.g., Eackgrour.c cr Ciscussion, Requested or f

Recomended Actions, anc? Requ#ed Actions or Reporting Requirements),

end move the long explanatory narrative at page 5 of the letter into l

the ncw Background or Discussion section.

2.

At page 1 of the nroposed letter, in the next to last sentence of the '

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first paragraph, change.the word "cust" to 'should."

3.

Revise the paragraph fFat begins at the bottom of page 1 of the generic letter and continues on page 2 to indicate more clearly that, although Section XI stroke and stroke-timing tests alone are not sufficient to i

provide assurance of H0V-operability at design basis conditions, as i

l recuired by the regulations, (a) they are a useful tool to complement other tests to provide verification of fiOV operability; (b) they can provide indication of valve degradation; and (c) they provide ralve l.

exercise and some measure of on-demana reliability MOV operability.

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i 4

Nove the second paragraph ou page '2 to follow the paragraph beginning I

with the words " Surveillance, adjustment, maintenance and repair of safety-related MOVs...", and combine with that paragraph. Change the last sentence of the resulting (combined) paragraph to read as follows:

"The results of these efforts may be useful...in developing an effective program."

Revise the second sentence of the new combined paragraph to read as follows:

"The following recommended actions are intended to be consistent with NRC's Maintenance Policy Statement as published..., which indicates that maintenance.should be applied to other MOVs connensurate with their importance to safe operation of the fa ci li ty. "

j finally, delete the lone sentence that follows the second paragraph on page 2, as. origin &lly written.

j 5.

Delete Footnote 3 at the bottom of page 2 of the proposed generic letter.

6.

At page 3 of the proposed generic letter, revise the last sentence of the

.,f first paragraph to end with the words "..such as the FSAR."

j 7.

In the second-sentence of paragraph c. on page 3 of the prcposed letter, replace the.words "... if practical..." with the ;hrase "...unless precluded by existing plant configuration...*.

/

Delete the last two sentences on page 3 (and the carryover to the top of 8.

page 4) of the proposed letter.

J 9.

Modify the third sentence of the second paragrapn on page 4 ci the proposed letter for consistency with the wording revisions ir, item 3 above.

J 1,0._

Delete paragraph i on page 4 of the proposed letter.

/ 11. End the sentence 1., paragraph 9 of the propos(d ietter af te tne words

"...for the NOV. "

L j12. Move the serond and 7.hird sentences in paragraph g (at ths. bottom of page 4 of the proposed letter) to paragraph c, and mocify as r.ecessary to blend with that paragraph.

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13. At page 6 of the proposed letter under paragraph h, modify to read as T'

foilows:

"The program developed by the licensee should allow for identifi-1 cation to the extent practical of such conditions, if present."

14.,

Modify and siinplify the proposed documentation requirements in paragraphs i and j on page 6 of the proposed letter.

State the documentation requirements 'in a rnore "results oriented" format that more clearly conveys NRC's expectations as to when the various phases of the overall licensee effort ar! to be started and completed, u

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15. flove the last sentence (at,out licensees sharing infonnation) in paragraph j of the proposed letter to the Background or Discussion section of the

.i final revised form of the letter, and expand on the thought involved by j

reorienting it toward licensee use of the NPRDS data base. AE00 will assist NRR in developing the revised wording.

la the wording at the bottom of page 6 and top of page 7 of the proposed letter, remove references to alternative schedules.

16. Combine paragraphs k and 1 of the proposed letter, and modify the 1

wording to place emphash on licensees getting started with the actions recommended in this generic letter (e.g., require demonstration of an ongoing program within one year).

j

17. Nove paragraph n cf the praposed letter into the new Background or Discussion section of the final the etter that is issued.,

18.

In the first sentence of paragraph 4 in the proposed letter, replace the word "whether* with the word "that."

Insert t.he word " technical" in 4

front of the woro " explanation" in the second sentence of that paragraph.

19.

In the second paragraph on page 8 of the proposed letter., change the first setitence to read:

"this. generic letter supersedes the recommendations contained in l

Eulletin 85-02 and its supplement."

Also, modify the beginning of the third senterce to read:

"The information which was or would have been submitted to NRC..."

20. Delete paragraph p on page 8 of the proposed letter, i

All changes to the proposed letter are to be coordinated with the CRGR staff prior to final issuance of tise revised generic letter.

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i Industry Implementation Cost A conservative (the word " conservative" is used in the context that assumptions were made so as to give high costs) esWate of industry cost to implement the proposad generic letter on M0V testing Mas developed using cost information and data obtained from industry and BNL.

The costs were developed on a per reactor unit basis (for conservatism, no savings were anticipated for multiple unit sites).

Resulting estimates are presented in Table 1 and are $1,192,000 per weit for the initial prograni and $17R,000 per year per unit foi the continuing p t> gram. 13ased on 127 reactor units, a conserv3tive estimate of the total industry 1:nplementation cost was $613,000,000 in4:luding an additional cost I 6

$37,500,000 for prototype testing.

The best estimate benefit is 1.04 x 10 person-rem (NUREG CR/5140). Without considering any offsetting cost savings l

(e.g., in reduced valve maintenance, reduced replacement of valve actuators, or

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isiproved plant avaf bability) the cost benefit ratio would be $590/ person-rem.

Tne basis for the individual cost elements shown in Table 1 are discussed in j

'the fcliewing paragraphs.

1.

I r.i ti a l P ~>g ra t

a.

Obtaining Vendor Data - The estimate of $63,000 is based on the actual l

cost ineurmd by the Davis-Besie plant, a single unit facility.

b.

Diacnostic Eauipment - The estimate of $300, BOO was the cost of pu-chasing two diagnostic systems. According to the NUMARC presenta-tion, this cost includes the maintenance cost of tMs equipment during the initial pmgram.

Training - The cost estimate was based on the training (.srogram cost t

c.

summa 5v p-ovided by the San Onofre Generating Station SONGS). The number of ;eeple trained was reduced somewhat from the number used by 40NGS to reflect a single-unit site rather than a 3 unit site 3 but i

the hourly rate used in these calculations was assumed higher than i

those use': ty SONGS.

The training costs was calculated as fc,llows:

Duration of training - 64 hrs.

Personnel to be trained and hourly rate 2 engineers 0 $60/hr.

1 craft supervisor 0 $50/hr.

I 6 craftsman 0 $40/hr.

1 QA person 0 $40/hr.

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Total labor cost for people to be trained was therefore $28,800. The cost for the instructor was based on ou consultant at $100/ hour.

Therefore, the total cost for the. training program was calculated to be $35,200.

d It should be noted that all the hourly rates were those used by NUMARC in their presentation for the ACRS.

d.

Engineering - The engineering costs to set up the program and to search records to determine the design basis information for the MOVs was estimated at 2 man-years of engineering effort. Based on

$60/ man-hour, and a full 2080 hours0.0241 days <br />0.578 hours <br />0.00344 weeks <br />7.9144e-4 months <br /> / year (no vacations, no holidays),

this resulted in a cost of $249,600.

I It is questionable whether the cost of obtaining the data needed to determine the differential pressure that the H0Vs may be called upon to open or close against during a design basis accident or, transient should be charged against this program.

This information is absolutely essential in order for the licensees to maintain safety-related valves, l

independent of the proposed program described in the generic letter.

i However, to develop a conservative cost estimate, engineering. time to i

obtain this data was included in the costs presented in Table 1.

I e.

Testing o,f Valves The initial program contemplates that testing of all the safety-related MOVs in the plant will be done once during a five-year period. Several sources of data were used to develop an estimate of the costs of performing this program, including NUMARC, BNL, and discussion with diagnostic equipment suppliers.

The NUMARC estimates are Lased on a relatively large crew, including i

engineers, craf tsmen (mechanical and electrical), craft supervision, and support from quality control, planning, operations, and health physics personnel. Additionally, consultant services of the diagnostic.

equipment supplier are included. There is agreement among the utilities l

and the diagnostic equipment suppliers that the actual testing of a HOV, including attaching the diagnostic equipment is 3 to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

(BNL used 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in preparing NUREG/CR-5140). However, industry representatives point out that the testing of cafety-related vie /es are subject to operating constraints.

Safety-related systeau can be taken out of service only for limited time periods without requiring a plant shutdown, typically 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for most PWR safety-related systems and '7 days for isost BWR safety-related systems. Even when the plant is shutdcwn, some operational constraints apply. Therefore, industry representatives assert that the highly trained personnel i

r needed te perform MOV testing have a relatively low utilization rate.

l To develop a conservative cost estimate, the crew size essentially identical to that used in the NUMARC estimates was assumed.

It was further assumed that this crew would have a utilization rate of roughly 50%. That is, the crew could test one MOV per shift.

If no MOV is 2

j f

I to be available for testing because of operational constraints, this should be known in advance with reasonable planning, and the crew could be assigned other duties (e.g., valve maintenance on non-safety related MOVs, or preventative maintenance activities on cthef equip-ment). The crew composition used to develop testing costs for the l

initial program, and their Sourly rates are listed below for the l

testing of a single MOV:

1

$ 384 Engineer 6.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 0 $60/hr.

=

l Craft Supervisor 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 0 $50/hr, 400

=

Craftsman 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> 0 $40/hr.

1200

=

}

Support Personnel (Operations,QC,

Planning, Health Physics) 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> 0 $40/hr.

840

=

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Diagnostic Consultant 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 0 $100/hr.

800

=

Total Cost.

$3624/ valve This represents more than 9 people being charged for the entire shift i

for testing one MOV, i

f The industry estimate of 150 safety-r91ated HOVs per plant was used, yielding a total testing cost of the initial program of $543,600 per plant.

f.

Prototype Testing In addition to the individual plant programs, as described above, it is recognized that an industry prototype test prograrh may be necessary.

The nuinber of prototype test series that might be needed was estimated ta vary from 75 to 150.

Based on NRC experience for a test series 4

for two valves the cost per MOV was $250,000 including some first-i time costs. However, for the purpose of this estimate, no subtraction was made for first-time costs and the $250,000 per valve was multiplied l

by 150 MOVs to o":tain a total cost of $37,500,000.

2.

Continuing Program 4.

Mainten,xnce of Diagnostic Equipment - An annual cost of 20% of the Tuitiaf procurement <fost was used, that is, $60,000 per year, b.

Training - A two-day retraining program each year for the same personnel listed in item Ic., above, was assumed. The cost would be

$8800 per year.

c.

Diagnostic Testing - The proposed generic letter recomends that a diagnostic retest of each valve be performed at about a five-year interval to assure continued operability of the M0V.

Diagnostic testing af ter significant maintenance is also recommended.

However, periodic testing at differenti61 pressure is not recommended for

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retesting..Further, a separate full diagnostic testing of a valve would.not be neesssary if it had been tested after niaintenante duritig the previous 5-year pefied. Using the industry estimate of 150 safety-related MOVs per unit, nominally 30 velves would need to be subjected to diagnostic retest per year. To eccount for valves tested after maintenance, this number was increased to 45 per year for the purposes of estimating costs. There should be no " waiting" time associated j

with post-maintenance testing since the MOV is already out of service 4

for maintenance and testing is necessary anyway before returning the MOV to operation. However, for additional conservatism, the same test rate of one valve per shift was used.

The crew composition, listed below, for M0V testing for the i

contir.uing program was reduced from that used in item le., above, becaose testing at differential pressure is not required.

$ 384 Engineer 6.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 0

$60/hr.

=

400 Craft Supervisor 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 0

$50/hr.

=

960 Craftsmen 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 0

$40/hr.

=

400 Support Personnel 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 0

$40/hr,

=

(0perations,QA, P16nfiing,

Health Physics)

Total Cost

$2244/ valve This reduced size represents more than 6 people being charged f-or. the entire shift for testing a single MOV.

Robert L. Baer 4/18/89.

4

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i Table 1 Industry Implementation Costs 1

(Conservative Estimate) l Initial Program Per Plant Obtaining Vender Data 63,000 Equiprnent -(purchase &

maintenance of 2 diagnostic systems) 300,000 Training 35,000 Engineering i

Obtain Design Basis data and Plan Program 250,000 Testing of 150 valves 544,000 Subtotal

$1,1.92,000/ plant or $151,400,000 for 127 plants

ototype Testing 37,500,000 Total

$180,900,000 Per Plant Continuin; Program Per Year

..aintenance of Diagnostic w

Equipment

$ 60,000 j

Periodic Retecir,ing 9,000 I

Diagnostic Testing of 45 valves /p,

101,000

$170,000 Total Industry Cost = 5170,000/ plant /yr, x 127 plants x 20 yrs. = $431,800,000 lotal industry Cost (Entire Prugrain)

$612,700,000

=

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