IR 05000302/1993002

Insp Rept 50-302/93-02 on 930104-08.No Violations Noted. Major Areas Inspected:Adequacy of Licensee Response for Concerns Identified During Generic Ltr 89-10,Phase I MOV Insp Conducted 920106-10

ML20127P659
Person / Time
Site:	Crystal River
Issue date:	01/15/1993
From:	Branch M, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127P651	List: IR 05000302/1993002 ML20127P649
References
50-302-93-02, 50-302-93-2, GL-89-10, NUDOCS 9302020036
Download: ML20127P659 (9)

Text

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. TAN 2 5 m3 4 Report No,t 50-302/93-02  :

Licensee: florida Power Corporation 3201 34th Street, South '

St. Petersburg, FL 33733 Docket No.: 50-302 License No.: OPR-72'

facility Name: Crystal River Unit 3 -

Inspection Conducted: January 4-8, 1993 Inspector: 1 a ,b bMa~ ~~ d '2

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']C~b~ nt ' y Accompanying Inspectors: M. N. Hiller G. R. Wiseman v ,

Approved by: //g,;%/ 1 h<cgp'_ ~

// bW If.Tliirinc G Chief ~ #= r Date TTgned V. Test Programs Section Engineering Branch *

Division of Reactor Safety

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SUMMARY )

Scope:

This announced inspection was conducted to assess the adequacy of th licensee's responses for the concerns identified during the GL-89-10 Phase .Il-Motor Operated Valve Inspection conducted January 6-10,1992,(NRC Inspection-Report No. 50-302/92-01). In addition, a review.of the licensee' corrective action for a previous inspection finding was conducte .

Results: -

In tne areas inspected, violations or deviations were not identifie The-licensee's response to the_GL 69-10 Phase I MOV-Inspection concerns was '

fully satisfactory. The licensee reorganized the Nuclear Plant Technical-Support Department to include a new MOV Group. - The new MOV_ Group has

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responsibility for contro11ir.g the MOV program and implementing the testin In addition, the. system engineers are' now responsible for performing lthe-thrust and differential pressure. calculations specified in GL 89-10.- Overall, '

the licensee's-MOV Program meets the intent of the reJommendations in

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GL 89-10.- IFI 89-28-02, Possible Exposure of d-c Motor Switching. Surges, was- .

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REPORT DETAILS Persons Contacted 1 Licensee Employees '

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• J. Alberdo, Manager, Nucicar Operations

• P. Beard Jr., Senior Vice President Nuclur Operations

• J. Bt:11amy, Compliance Engineer ,

• W. Brewer, Technical Support Supervisor  :

• L. Cecilia, Nuclear Project Engineer 1

'D. Francis, Technical Training Supervisor .

'E. froats, Manager, Nuclear Compliance

• R. Fuller, Senior Nuclear Licensing Engineer

• G. Nainon, Manager, Nucitar Pla,1t Technical Support

• B. Hickle, Director, Nuclear Plant Operation *W. Marshall, Manager, Nuclear Plant Operations

• R. McLaughlin, Nuclear Regulatory Specialist i

• A. Stern, Senior Nuclear Project Engineer

• G. Vaughn, Nuclear Pro,iect Specialist

• R. Widell, Director, Nuclear Operations Site Support

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NRC Personnel

'P. Holmos-Ray Senior Resident inspector

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• Attended exit interview GENERIC LETTER (GL) 89-10 " SAFETY-RELATED MOTOR-0PERATED V'ALVE (MOV)

TESTING AND SURVEILLANCE" (2515/109) .

The Nuclear Regulatory Commission (NRC) Region 11 conducted a Phase 1 MOV inspection during January 6-10, 1992,-of.the Crystal River 3 Nuclear -

Plant (NRC Inspection Report No. 50-302/92 01). This inspection '

examined the licensee's response to Generic Letter 89 10, Safety Related Motor-Operated Valve Testing and Surveillance. The inspectio identified two concerns that requested;the submittal of additional =

information by a written response and eight-other concerns that no written response was requested.- The licensee responded as requested to the two concerns in letter 3F0492 06, dated April.13.-1992' I n -- .

addition, FPC submitted in letter 3F0992-05, dated September 18. 1992,:

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an update to their initial' response to Generic Letter 89-10. The purpose of this inspection was to review the licensee's actions taken .

for each of the concerns identified in the GL 89-10 Phase i MOV

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Inspection report and the responses submitted-in their;1etters. Each  :

concern is listed and discussed belo "

The-first part of each section liits the concern discussed inltlie -

GL 89-10 Phase I M0V Inspection repor The second part discusses the-. .

findings of this inspectio $

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2.a Concerns identified - Written Response Requested (WRR)

Concern 1 (WRR1

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This concern was discussed in Section 3.d of the Phase 1 MOV repor Based on the status of calculations and development of procedures, there was a concern that resource allocation might be insufficient to complete the program on schedule. Licensee personnel indicated there were plans to increase the engineering support to the progra The inspectors verified that the licensee has dedicated adequate resources to the MOV program as stated in their responso lette ho _

following is the listing of those additional resources:

• A senior mechanical engineer was assigned to support the MOV progra s initial responsibilities included writing test procedures for differential pressure tests, in addition, the licensee has_ reorganized the Nuclear Plant Technical Support Department to include-a- new MOV-Grou This new MOV group includes an engineering staff that is responsible for implementing and controlling the MOV program as specified in GL 89-1 * Various system engineers have been utilized to perform the differential pressure calculations. The inspector reviewed 48 calculations that were satisfactorily performed by the system engineer These calculations were initially performed by the NSSS sunlie *

An engineering aid has been assigned to the MOV group to provide additional administrative suppor *

The inspectors verified that a consultant (field engineer) from 111 -

M0 VATS was contracted full time during the 1992. year to support the MOV progra *

The new MOV group has taken responsibility from the Maintenance Department for M0V differential pressure testin *

A senior management MOV Program Oversite Team was established to monitor and assure coordination in implementation of the progra The team members attended the MOV training (M0 VATS) to ensure their understanding of MOV requirement Concern 2 (WRR)

.This concern was discussed in Section 3.d of the. Phase-1 MOV repor A-

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listing of valves scheduled to be design-basis tested revealed that it would be acceptable to test either valve of listed similar pairs rather than test both. This is contrary to recommended action c. of GL 89-10, which indicated that each valve should be' tested at design-basis pressure where practicable. This was further explained in the reply to Question 22 of GL 89-10, Supplement .

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FPC's response to this concern indicated that their evaluation of the

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MOV program concluded that the design basis differential pressure (d/p)

testing needed to be expanded to include all MOVs which can be tested-in place without jeopardizing plant operatian or safety-related system availabilit The inspectors reviewed a listing of valves to be tested and verified that it indicated scheduled d/p testing for 48 of the 84 MOVs within the progra The inspectors reviewed flow diagrams for the Core Flooding (CF), Post Accident-Sampling (CA), feedwater (fW), Decay Heat (DH),-and Makeup and purification (MU) systems to sam)le the completeness of the scope of valves included in d/p testing. Ivirty-six (36) MOVS were excluded from the test program and the evaluation for justification for their exclusion was reviewed. The evaluation for the excluded valves war provided in a September 10, 1992 memo (NPSE92-0429) from Nuclear Plant Systems Engineering to the plant management. This evaluation stated that three categories of valves were justified for exclusion from insitu dynamic d/p testing. These included valves whose performance under dynamic conditions are verified through normal plant operating procedures, valves where static test conditions would be the same as the dynamic conditions except in inadvertent operation, and those valves where the dynamic conditions are adverse to plant safety.

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The inspectors concluded that the licensee has met the commitments in the April 13, 1992, response to NRC report 50-302/92-01 for Concern (2).

Specifically, the licensee performed additional differential pressure tests to evaluate the adequacy of the MOVATS data bas Based on the sample examined, the scope of valves included in the Crystal River d/p test program appeared consistent with the recommendations of GL 89-10..

, 2.b- Concerns identified - No Written Response Requested (NWRR).

LoAcern'1 (NWRR) ,

This concern was discussed in Section 1 of the Phase 1 MOV repor The licensee's letter of response included several statements which resulted in uncertainties regarding its intent to comply with GL 89 10 -

recommendations, .for example, the response indicated that the ability to meet schedule would.be dependant on the availability of necessary documentation, fhe licensee is now halfway through tbo GL 8910 implementation schedule and should be better able to define its ability and intentions with regard to the generic letter recommendation lhe seven statements of concern in Section 1 of the-Phase l M0V report were reviewed by the inspectors to determine if appropriato action was-taken by the license (1) The industry is developing MOV testing methods that could lead to unforeseen delay There was an issue where the accuracy of the_ test equipment for " opening" a valve could be different than for " closing" a valve. This issue was resolved by the test equipment. suppliers.- EPRI L

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has a MOV test program that has not been completed. The licenseo stated i that in certain areas the EPRI data may be needed, for example, testing- l*

the unique valves that have a rotating rising stem. . The licensee also stated it was not their intention to delay the schedule because of these - l two item .

(2) fPC plans to complete the initial testing recommended by the generic  :

letter within the three refueling outage schedulo, but it is dependant-u)on the availability of the necessary documentation for each MOV and .

tae ability to perform the test without. undue stress on the MOV.or plant ,

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FPC responded to thir, concern by letter 3f0992-05 dated September 18, 199 The letter specifically states that FPC plans to complete testing ,

of all MOVs in the program by Refuel 9 with the exception of the testing -

of those valves considered for alternate testing as recommended in item '

f, of GL 89-1 '

(3) Temperature, flow, and seismic effects were not mentioned as design

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basis factors that would be considered (in the design-basis review).

The initial calculations were performed by the NSSS supplier. .Since $

then the calculations were performed by the licensee's system engineers >

where temperature, flow, and seismic conditions were considere (4) In situ differential pressure testing is intended to be used where I practica :

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See paragraph 2.a Concern 2 (WRR) of this inspection repor (5) Consideration of line breaks is not part of the Crystal' River 3 1 design-basis or of the MOV test progra I The inspector reviewed the calculations performed.by the licensee's -i

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system engineers and line breaks were considered where applicabl (6) The response was unclear regarding' actions to be taken in regard to GL 89-10 recommendation item That item recommends that-each MOV'

failure and corrective action taken be analyzed and documented....

See paragraph-2.b Concern 6 (NWRR) of this-inspection repor (7) The response transmittal letter stated that FPC did not plan to re- )

test 17 MOVs previously tested in-accordance with NRC Bulletin 85-0 The licensee s'.ated these MOVs will be tested in accordance with the  !

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- GL 89-10 MOV progra The inspectors considered the. licensee's response'and actions-for these- l seven concerns satisfactory--and appropriat j

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Lo.0cern 2 (NWRR) o This concern was discussed in Section 3.j of the Phase I MOV repor The continuing (refresher) training of maintenance: personnel on ,

!.iinitorque actaators and use of MOVATS MOV diagnostics appeared insufficient, in' that- tt 'aing in the combination was limited to' a tetal ,

of 2 days every 2 to-3 years. -In addition,_ noidiagnosticitraining was

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required for the MOV Enginaer, although he.may perform the diagnostic testing and is responsible to interpret results.-

The inspectors reviewed the latest revisions of the-Training Department-Procedures (TDPs) TDP-306, Nuclear Electrician Training Programi' TDPc 308, Engineer Training Program; and _TDP-309, Nuclear Mechanic Training c Program, These procedures address the refresner training requirements for the MOV program. The )rocedure review indicated that-the electrical personnel have overall mec ianical and electrical maintenance responsibilities for DV actuators. Refresher training _for these-personnel has been uocraded to include 3 days annual special _

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requalification MOV trainin The training personnel indicated that,Ein

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addition to this requalification training, it has been the practice-to conduct refresher training in:MOVAIS diagnostic techniques and limitorque valves jast prior to conducting outage MOV work activities.-

The inspectors verified that the engineers-in the MOV group hadi satisfactarily completed specialized MOVATS training consisting of=  ;

" Advanced Signature Analysis" and'"3000 Data Acquisition instruction"-

during 1992. The inspectors considered this level of training 1to be adequat Concern 3 (NWRM_

This concern was discussed in Section'3.e-of the Phase:1;MOV-report. No-provisions had been made for periodic tests or inspections ofLMOV-thermal overload protection devices to verify their continued

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capabilitiesm do justification'was provided for the omission.. The-

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_ generic letter did not request testt or% inspections of-thermal-overicad The licensee stated that the testing of thereal; overloads was!nnt; '

required, flowever, the decision forf testing thermal overloads is still under consideration. lhe licensee has a preventative maintenance

procedure (PM-122) for testing the thermal _ overloadsc

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Concern 4 DNRR)

ThisconcernwasidiscussidcinSection3'.jofthePhaseIMOVrepor Irl M0 VATS was not on the licensee's approved' vendor' list for--safety-related equipment even;.though it provided information used for-calculations on safety; related _MOV i

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The inspectors verified that ITI M0 VATS was on the'~ approved vendors l list ,

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Concern 5 (hWRR)_

This. concern was discussed in Section 3.h of;the Phase I:MOV repor Important sections of the licensee's GL 89-10 Program Manual and a number of imaortant program procedures were under revision or were.to be revised in tie near futur The inspectors verified that the MOV program manual was' revised to Revision 7, dated April 27, 1992. In addition maintenance procedur MP-4022, Use And Operation Of The Motor Operated Valve Analysis Test System (MOVATS), was also revised to Revision 7 dated April 27, 199 New procedure PT-428, MOV-260 M0 VATS 0/P Testing, Revision.0, was ,

approved April.9, 199 :

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M0_cfJn # (NWRR)

This concern was discussed in Section 3,f of the Phase:1 MOV report.' ;

MOV failure analysis and trending were not-incorporated into the GL 8940 program. However, the licensee had identified equipment ..

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failure analysis and trending'as an area for improvement and had taken actions-to improve performance in this area, The inspectors verified that MOV failures and corrective actions are documented in accordance with the. plant Problem Report-pruces Compliance Procedure CP-lll,- Documenting, Reporting, and Reviewing Problem Reports, section 3.2.10 requires that Problem Report data be input into the Noncompliance Tracking and' Trending System (NTTS) for-trending. Based on the licensee's updated response to GL 89-10, this data will be used to es'ablish a MOV tracking and trending program within two years after MOV Program implementation as suggested in-th G FPC plans to complete implementation of the MOV Program by the end of Refuel 9 currently scheduled for April;199 @ncern 7 (NWJR_)_

Thi_s concern.was discussed in Section 3.e of the: Phase I:MOV. repor_ The licensee indicated that periodic stati' c testing'will'be used to verify centinued capability of MOVs to operate under worst case .

difforential pressure and flow'conditlons. This is not currently >

considered adequate because of the uncertain ~ relationship.between performance of a MOV under static conditions and design-basis condition See paragraph 2.a Concern 2 (tfRR) of this repor The inspectors verified that any design change or modification concerning a' MOV will require the MOV to he' tested under initial; conditions as required in the MOV program and Nuclear Engineering Department procedure NED 235, Design Consideration For (40Vs, Revision'2, dated December 31, 1992, c

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[oncern B lNWRR)

This. concern was discussed in Section 3.c of_the Phase I MOV repor The adequacy of engineering studies which may oe used as a basis for-increasing the rating of Limitorque actuators and their application will require further NRC assessment. NRC review of-this-matter and industry developments are in progress. R!l will evaluate the' licensee's use of such studies in its subsequent inspection of GL 89-10 program-implementatio The issue is still being reviewed by the NRC staff and it will be-addressed during the Phase 11 inspection . Action On Previous Inspection Findings (92702)

(Closed) IFl 89-28-02, "Possible Exposure of.d-c Motors to Switching _

Surges." in a previous inspection, a NRC inspector, while reviewing an elementary diagram for a d-c . cowered motor operated. valve, identified that the motor's shunt field may be vulnerable to switching surges because a path for'the field discharge current had not been provide ]

This item was initially reviewed during a NRC inspection conducted during October-15-18,1991, and discussed in report' 50-302/91-21..This:

inspector had reviewed a completed modification package for installing ,

the field discharge resistors -and concluded that the-package itself was- -

adequate. .This insocctor was informed by the licenseenthat.the modification would ae implemented during the next. refueling outag _

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During this inspection, the inspectort reviewed modificationLpackage FMR- q 90-08 20-01, DC MOV Surge Suppression Device, dated March 15,-1991_and ~

determined it was satisfactory. The inspectors conducted walt down

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inspections of MOVs ASV-5, ASV 204,-- EFV-11, EFV-14, EFV-32, EFV-33,

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FWV-33, FWV 34, FWV-35., FWV-36, MSV-55, and MSV-56?to verify that'th j" shunt. field discharge resistors were installed -in the twelve d-c powered MOV . Fxit Interview 'q The-inspection scope and results were sunnarized'on January.8,1993, with.those persons indicated in paragraph 1. The_ inspectors described: ,

the areas inspected ar.d discussed _ in detail the inspection result Proprietary information is not contained in this report. : Dissenting

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comments were.not received from the license The licensee was informed that IFI'89-28-02,was closed'ou I

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ENG ENGINEERING EPRI tLECTRIC POWER RESEARCH INSTITUTE FPC FLORIDA POWER CORPORATION-GL GENERIC LETTER IFI lNSPECT10N FOLLOWUP ITEM IR INSPECTION REPORT  !

MOV MOTOR-0PERATED VALVE MOVATS MOTOR-0PERATED VALVE ANALYSIS AND TEST SYSTEM NED NUCLEAR ENGINEERING DEPARTMENT NPSE NUCLEAR PLANT SYSTEMS EN0INEERING l NRC NUCLEAR REGULATORY COMHISSION NSSS NUCLEAR STEAM SYSTEM SUPPLIFR-NTTS NONCOMPLIANCE TRACKING AND TRENDING SYSTEM NWRR NO WRITTEN RESP 6NSE REQUIRED

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RII REGION 11 TI- TEMPORARY INSTRUCTION WRR WRITTEN RESPONSE REQUIRED

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