GO2-95-080, Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Util Believes That Ability to Justify Actuator Capability by Analysis Should Not Be Restricted to Population of Small Valves

Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Util Believes That Ability to Justify Actuator Capability by Analysis Should Not Be Restricted to Population of Small Valves

ML20083N299
Person / Time
Site:	Columbia, 05000398
Issue date:	04/26/1995
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC
References
FRN-60FR15799 60FR15799-00013, 60FR15799-13, GO2-95-080, GO2-95-80, NUDOCS 9505230014
Download: ML20083N299 (2)

Text

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.o. Box 968

• 3000 George Washington Way e Rkhland, Washington 99352-0968 * (509)372-5000

$ April 26,1995 GO2-95-080 13 11008 Chief

~D%3 M\S5 Rules Review and Directives Branch U. S. Nuclear Regulatory Commission gNi l

Washington, DC 20555 g

Dear Sir:

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Subject:

COMMENTS ON PROPOSED GENERIC LETTER; PRESSURE [OCKING j AND TIIERMAL BINDING OF SAFETY-RELATED POWER-OPERATED ;

GATE VALVES (60 FR 15799) r W g' m

L. N The proposed Generic Letter is intended to ensure that licensees have performed or 'will perform evaluations, analyses and/or corrective actions to ensure that safety-related power-operated gate valves that may be susceptible to pressure locking or thermal binding are capable of performing ,

their safety functions. The Nuclear Regulatory Commission has solicited comments regarding both the technical and regulatory aspects of the proposed Generic Letter.

The Supply System has reviewed the proposed Generic Letter and respectfully submits the following comments:

The proposed Generic Letter section " Requested Actions:"

• Item 1, would require the addressee of the Generic Letter to perform and complete an l evaluation of the operational configurations of all safety-related power-operated gate valves l within 60 days of the Generic Letter. The Supply System recommends that this completion period be extended from 60 days to 120 days.

• Item 2, would require the addressee to implement and complete the guidance provided to complete an evaluation and further analyses, including corrective actions, within 180 days of the date of the Generic Letter. The Supply System recommends that this completion period be extended to one year. 4 These extensions are recommended to provide additional time for the industry and regulatory ]

agencies to refine the criteria for thermal binding susceptibility and operability criteria. i 1

220041 0 9505230014 950426  :

PDR I&E l HISC PDR

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Page Two COMMENTS ON PROPOSED GENERIC LETTER; PRESSURE LOCKING AND THERMAL BINDING OF SAFETY-RELATED POWER-OPERATED GATE VALVES (60 FR 15799)

Additionally, Attachment 2 of the proposed Generic Letter, Item 1, indicates that the staff will consider addressee justification for adequate actuator capability by analysis for small valves.

The Supply System believes that the ability to justify actuator capability by analysis should not be restricted to the population of "small valves."

The Supply System appreciates the opportunity to review and comment on the proposed Generic Ixtter. Please contact me or Mr. Doug Coleman at (509) 377-4342 if you have any questions or would like to discuss our comments further.

Sincerely, deu JV Parrish (Mail Drop 1023)

Vice-President, Nuclear Operations cc: C Callaway - NEI