BECO-92-044, Forwards Rev to 910226 Response to Suppl 3 to Generic Ltr 89-10 Per motor-operated Valve Insp Conducted on 920309-11. Valve Will Operate Under Design Basis Conditions,Based on Review of Inel Test Results

Forwards Rev to 910226 Response to Suppl 3 to Generic Ltr 89-10 Per motor-operated Valve Insp Conducted on 920309-11. Valve Will Operate Under Design Basis Conditions,Based on Review of Inel Test Results

ML20101A099
Person / Time
Site:	Pilgrim
Issue date:	04/14/1992
From:	Richard Anderson BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BECO-92-044, BECO-92-44, GL-89-10, NUDOCS 9204200205
Download: ML20101A099 (6)

Text

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BOSTON EDISON Woom t uma, nner sunon Horky Hs Road P4 W J'h. Manachusetts 02300 Roy A. Anderson April 14, 1992 Senior Vice Freudent - Nucloat BEco 92- m ,

U.S. Nuclear Regulatory Commission Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 Rftyjjjon to GL 89-10. Supolement 3. Resconse

He are submitting a revision to our Generic Letter (GL) 89-10, Supplement 3, response (Boston Edison Company Letter 91-022, dated February 26, 1991) to address concerns raised during the NRC GL 89-10 Motor Operated Valve (HOV) inspection conducted March 9-13, 1992. Also, other changes have been made to the previous submittal to reflect current plant configuration. This revision supercedes our previous response in its entirety.

During the inspection, the NRC Inspection Team noted the Idaho National Engineering Laboratory (INEL) test results published in Information Notice (IN) 90-40 had not been extrapolated to a higher thrust to account for Pilgrim l

Nuclear Power Station (PNPS) differential pressure that was higher than the l tested configuration for Reactor Hater Cleanup System (RHCU) Valve H01201-5.

He have reviewed NUREG/CR-5406-EGG-2i69, "BHR Reactor Water Cleanup System Flexible Hedge Gate Isolation Valve Qualification and High Energy flow Interruption Test." From this review, we determined it is unnecessary to extrapolate to a higher thrust because the thrust published in IN90-40 was obtained after a series of tests had been performed that appeared to damage the valve. He reviewed data from all the tests performed on this valve and determined the most applicable test to use for comparison was test eleven (11) from the phase 1 test results. Test 11 demonstrates the valve will close with a valve factor less than 0.5; however, to provida additional design margin, we evaluated H01201-5 using a 0.5 valve factor. In addition to reviewing the mechanical design parameters, we reviewed the GL 89-10, Supplement 3. DC l

operated valves to determine the voltage available at the valve motor during design basis blowdown conditions (i.e., pipe break outside containment;, and we concluded they will develop the required torque / thrust at the minimum expected voltage using Limitorque speed-torque curves applying a 10% margin.

Enclosed as Attachment ! is our revised GL 89-10, Supplement 3, response documenting the design parameters used as a basis for our conclusions, further evaluation will be performed in accordance with our GL 89-10 HOV program to address other design aspects of valve operation stated in NRC Letter dated February 18, 1992, to Boston Edison Company.

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BOSTON EDISON COMPANY Page 2 Also, as part of this submittal, we are revising our Long Term Program submittal (BECo letter 92-022 Dated February 28, 1992) regarding GL 89-10.

This is necessary to clarify which HOV's were reviewed and retested to account for H0 VATS inaccuracies. Only IEB 85-03 priority I HOVs and GL 89-10, Supplement 3, HOVs were reviewed. However, during our GL 89-10 HOV Program Inspection, other safety-related HOV's tested using H0 VATS were evaluated against H0 VATS document "!TI H0 VATS Equipment Accuracy Summary" ERS.0, Rev. 3, to ensure there was sufficient margin to account for H0 VATS inaccuracies for all safety-related valves. Attachment 2 is included as part of this letter to revise page 32 of the LTP. ,

In conclusion, based on our review of the INEL test results for applicability l to RHCU H01201-5, we conclude the valve will operate under design basis conditions. Also, page 32 of the LTP has been revised to clarify which HOVs were reviewed to address H0 VATS inaccuracies. Should you have any questions

• regarding this submittal please contact our Licensing staff.

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R. A. Anderson BRS/ cab /6946 cc: Mr. R. Eaton, Project Manager Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Mail Stop: 1401 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, HD 20852 U, S. Nuclear Regulatory Conaission Region I 475 Allendale Road King of Prussia, PA 19406 Senior NRC: Resident Inspector Pilgrim Nuclear Power Station

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! ATTAlliMENT 1. REVISIO!LR As requested by GL 89-10, Supplement 3, BECo has reviewed and evaluated HPCI Valves 2301-4 and 5, RCIC Valves 1301-16 and 17, and RHCU Valves 1201-2 and 5 to determine if deficiencies exist relative to test results given in Information Notice (IN) 90-40.

The result of the evaluation is each valve in question will develop the required torque to close and isolate flow in the event of a design basis pipe The motor-operated valves in break. Table I summarizes the results and data.

question (2301-4 and 5, 1301-16 and 17 and 1201-2 and 5) are unique because they are normally open at 100% reactor power and provide a direct path for reactor coolant outside the primary containment. In the event of a pipe break they hust be able to close to mitigace flow of primary water and steam to +he Reactor Building. Other motor-operated valves are normally closed at power or have check valves to prevent back flow of primary water / steam and would not be required to close under pipe break conditions at full reactor pressure.

In addition to reviewing the mechanical design parameters, we reviewed the GL 89-10, Supplement 3. DC operated valves to determine the available voltage at the valve motor during a design basis pipebreak and concluded the valve operato s will develop the rnquired torque at the minimum expected voltage.

This evaluation is based on usina Limitorque speed-torque curves applying a 10% margin.

1. HPCI Valve 2301-4 Velan (Gate) 8" SMB-2-60 (AC) Torque Switch 1 rip Available = 32924#

Not tested by NRC, Idaho Nuclear Engineering Laboratory (INEL) tests Since this valve was not tested by INEL, we compared similarities of PNPS valves to valves used in the NRC tests. IN 90-40 concluded a valve factor of 0.3 did not bound the required thrust. Ten tests were done on Velan 6" -

and 10" valves. Nine were done with hot water or steam and the valve factors were 0 43 to 0.56. One test was in cold water and the valve factor was 0.63. This test was not included in the evaluation since it was not near operating conditions. The thrust at torque switch trip obtained from static diagnostic testing of 2301-4 was evaluated at degraded voltage conditions. He concluded the th.ust is sufficient to overcome a valve factor of greater than 0.6. Therefore, the valve factor for 2301-4 is acceptable and the valve will perform its safety function.

2. HPCI valve 2301-5, Velan (Gate) B" SMB-1-60 (DC) Torque Switch Trip available - 31225#

Not tested by NRC. INEL tests An evaluation similar to 2301-4 was applied to the 2301-5 valve. The thrus^ is sufficient to overcome a valve factor of greater the 0.6 using the thrust at torque switch trip obtained from static diagnostic testing and evaluating it at the minimum expected DC voltage. Therefore, the valve factor is acceptable for 2301-5 and the valve will close and isolate flow in the event of a design basis pipe break.

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3. RCIC 1301-16 Hestinghouse (Gate) 3" SMB-000-10 (AC) Torque Switch Trip available = 5380#

Not tested by NRC, INEL tests An evaluation similar to 2301-4 was applied to the 1301-16 valve. The thrust is sufficient to overcome a valve factor of greater than 0.6 using 4 the thrust at torque switch trip obtained from static diagnostic testing and evaluating it at degraded voltage con ( .. Therefore, the valve factor is acceptable for 1301-16 ahd the t ;11 perform its safety function.

4. RCIC 1301-17 Velan (Gate) 3" SMB-000-5 (DC) Torque Switch Trip ava11able-6687#  !

Not tested by NRC, INEL tests l An evaluation similar to 2301-4 was applied to the 1301-17 valve. The thrust is sufficient to overcome a valve factor of greater than 0.6 using the thrust at torque switch trip obtained from static diagnostic testing and evaluating it at the minimum opected voltage. Therefore, the valve factor is acceptable for 1301-17 and the valve will close and isolate flow in the event of a design basis pipe break.

5. RHCU 1201-2 Ha1 worth (Gate) 6" SMB-00-15 (AC) Torque Switch trip available - 18044# 1 INEL test required 13000# thrust at about 1135 psi delta pressure.

1201-2 was evaluated by comparing the available thrust at Torque Switch I Trip (18044#) against the required thrust in the INEL tests (13000#). The available thrust is greater than the required thrust; thus, 1201-2 will perform its safety function.

6. RHCU 1201-5 Anchor / Darling (Gate) 6" SMB-0-25 (DC) Torque Switch Trip available - 17059#

INEL Test 11, 13000# at 1135 psi delta pressure The Phase 1 INEL tests (NUREG/CR-5406, Volume 2) indicate the required thrust to close 1201-5 would be about 23000# at 1135 psi. BECo does not believe this test applies to Pilgrim because the valve appeared to be damaged. Test 11 of the same test series indicated about 12000# was required at 1000 psi to close the valve. Test 11 was chosen because it did not end with N2 flow and the qualification degradation to the valve would have aircady occurred. BECo used the calculated thrust value using-0.5 valve factor (14526#) as the required thrust which is more conservative than Test 11 interpolated to 1135 psi (about 13000#). The valve factor is greater than 0.5 and the valve will close and isolate flow in the event of a design basis pipe break.

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. . ATTACHMENT 2 l Page 1 of 1 EClifDU.LLIL

- Diagnostic testing of H0-1201-2, 1201-5, and 4010A was conducted during  ;

RfD #8. In addition to this testing, we completed diagnostic testing on i the remaining GL 89-10, Supplement 3 HOVs (4 valves) and on another 10 )

safety related HOVs.

- Development of a Program Plan is complete. '

l Progress and Summary of Changes - August 1991 to February 1992

- Design basis re "vs of HOVs continue to support our commitment to begin testing in Rf0

- Testing is on schedule to begin in Rf0 #9 (completion within 3 refueling outages).

- Procedures are in preparation describing design basis review methodology, control of ivitch settings, and degraded voltage analysis. Additionally, a Nuclear Orgaatration Procedure establishing our HOV program is in final review.

- The schedule for static testing of HOVs has been accelerated and some testing will be done during our mid-cycle outage prior to RF0 #9.

- IEB 85-03 Priority 1 and GL 89-10, Supplement 3. H0VS tested using H0 VATS test equipment were reviewed and have been retested using more accurate diagnostic test equipment or been evaluated to ensure there is sufficient margin.

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