ML081640276

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Draft Supplement to Safety Evaluation for Joint Owners Group Motor-Operated Valve Periodic Verification Program
ML081640276
Person / Time
Site: Boiling Water Reactor Owners Group, PROJ0694
Issue date: 08/14/2008
From: Rosenberg S
NRC/NRR/ADRO/DPR/PSPB
To: Buschbaum D, Coleman D
BWR Owners Group, PWR Owners Group
Honcharik M, NRR/DPR/PSPBPM, 415-1774
References
TAC MD8920, TAC MD8921
Download: ML081640276 (8)


Text

August 14, 2008 Mr. Doug Coleman, Chair BWR Owners' Group Energy Northwest Columbia Generating Station Mail Drop PE20 P.O. Box 968 Richland, WA 99352-0968 Mr. Dennis Buschbaum, Chair PWR Owners' Group Comanche Peak Steam Electric Station 6322 North Farm to Marked Rd 56 Mail Code E15 Glen Rose, TX 76043

SUBJECT:

DRAFT SUPPLEMENT TO SAFETY EVALUATION FOR JOINT OWNERS GROUP MOTOR-OPERATED VALVE PERIODIC VERIFICATION PROGRAM (TAC NOS. MD8920 AND MD8921)

Gentlemen:

By letter dated June 20, 2007, the Joint Owners Group submitted revised pages to topical report (TR) MPR-2524, Joint Owners Group Motor Operated Valve Periodic Verification Program Summary, to the U.S. Nuclear Regulatory Commission (NRC) NRC staff for review. Enclosed for Joint Owners Group review and comment is a copy of the NRC staff's draft supplement to the safety evaluation (SE) for the TR.

Twenty working days are provided to you to comment on any factual errors or clarity concerns contained in the SE. The final SE will be issued after making any necessary changes and will be made publicly available. The NRC staff's disposition of your comments on the draft SE will be discussed in the final SE.

To facilitate the NRC staff's review of your comments, please provide a marked-up copy of the draft SE showing proposed changes and provide a summary table of the proposed changes.

If you have any questions, please contact Michelle Honcharik at (301) 415-1774.

Sincerely,

/RA/

Stacey L. Rosenberg, Chief Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project Nos. 691 and 694

Enclosure:

Draft Supplement to SE cc w/encl: See next page

August 14, 2008 Mr. Doug Coleman, Chair BWR Owners' Group Energy Northwest Columbia Generating Station Mail Drop PE20 P.O. Box 968 Richland, WA 99352-0968 Mr. Dennis Buschbaum, Chair PWR Owners' Group Comanche Peak Steam Electric Station 6322 North Farm to Marked Rd 56 Mail Code E15 Glen Rose, TX 76043

SUBJECT:

DRAFT SUPPLEMENT TO SAFETY EVALUATION FOR JOINT OWNERS GROUP MOTOR-OPERATED VALVE PERIODIC VERIFICATION PROGRAM (TAC NOS. MD8920 AND MD8921)

Gentlemen:

By letter dated June 20, 2007, the Joint Owners Group submitted revised pages to topical report (TR) MPR-2524, Joint Owners Group Motor Operated Valve Periodic Verification Program Summary, to the U.S. Nuclear Regulatory Commission (NRC) NRC staff for review. Enclosed for Joint Owners Group review and comment is a copy of the NRC staff's draft supplement to the safety evaluation (SE) for the TR.

Twenty working days are provided to you to comment on any factual errors or clarity concerns contained in the SE. The final SE will be issued after making any necessary changes and will be made publicly available. The NRC staff's disposition of your comments on the draft SE will be discussed in the final SE.

To facilitate the NRC staff's review of your comments, please provide a marked-up copy of the draft SE showing proposed changes and provide a summary table of the proposed changes.

If you have any questions, please contact Michelle Honcharik at (301) 415-1774.

Sincerely,

/RA/

Stacey L. Rosenberg, Chief Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project Nos. 691 and 694

Enclosure:

Draft Supplement to SE cc w/encl: See next page DISTRIBUTION:

PUBLIC RidsNrrDpr RidsNrrPMMHoncharik RidsNrrLADBaxley PSPB Reading File RidsNrrDprPspb RidsOgcMailCenter RidsAcrsAcnwMailCenter RidsNrrDciCptb RidsNrrDci ADAMS ACCESSION NO.: ML081640276 *No major changes to SE input.

NRR-043 OFFICE PSPB/PM PSPB/PM PSPB/LA CPTB/BC*

PSPB/BC NAME EBowman MHoncharik DBaxley JMcHale SRosenberg DATE 6/12/08 8/13/08 7/29/08 11/19/2007 08/14/08 OFFICIAL RECORD COPY

ENCLOSURE 1

DRAFT SUPPLEMENT TO SAFETY EVALUATION ON JOINT OWNERS GROUP 2

PROGRAM ON PERIODIC VERIFICATION ON DESIGN-BASIS 3

CAPABILITY OF SAFETY-RELATED MOTOR-OPERATED VALVES 4

5

1.0 INTRODUCTION

6 7

In response to Generic Letter (GL) 96-05, "Periodic Verification of Design-Basis Capability of 8

Safety-Related Motor-Operated Valves" (Reference 1), nuclear power plant licensees developed 9

an industry-wide Joint Owners Group (JOG) program on motor-operated valve (MOV) periodic 10 verification. The JOG prepared an initial topical report (TR) describing the program, which the 11 U.S. Nuclear Regulatory Commission (NRC) NRC staff approved in a safety evaluation (SE) 12 dated October 30, 1997 (Reference 2). The NRC staff relied on licensee commitments to the 13 JOG program in closing its review of GL 96-05 programs at the participating nuclear power 14 plants. On February 27, 2004, the JOG submitted the final TR MPR-2524, "Joint Owners' Group 15 Motor Operated Valve Periodic Verification Program Summary" (Reference 3) for NRC staff 16 review. By letter dated September 25, 2006 (Reference 4), the NRC staff approved MPR-2524 17 in an SE that discussed its review of the JOG program on MOV periodic verification described in 18 the final JOG TR. By letter dated December 11, 2006, the JOG issued MPR-2524-A, Joint 19 Owners Group (JOG) Motor Operated Valve Periodic Verification Program Summary 20 (Reference 5), that incorporated the NRC staff SE and JOG responses to NRC staff requests for 21 additional information. By letter dated June 20, 2007 (Reference 6), the JOG provided revised 22 pages to MPR-2524-A, that reflect corrected input design data for a valve tested as part of the 23 JOG program.

24 25 The revised pages to the JOG MOV periodic verification summary TR provided in Reference 6, 26 are the result of a re-evaluation of the design of a butterfly valve (JOG Valve B22.4) tested at a 27 nuclear power plant as part of the JOG program. Following issuance of the Reference 5, the 28 JOG determined that the subject butterfly valve has a double offset disk design rather than the 29 standard symmetric design. Based on its re-analysis, the JOG has revised the applicable pages 30 in the JOG MOV periodic verification summary TR to reflect the corrected maximum bearing 31 friction coefficient and test results for JOG Valve B22.4. In Reference 6, the JOG stated that the 32 revised information had been distributed to the JOG participants with only one nuclear power 33 plant licensee reporting use of this type of butterfly valve.

34 35

2.0 REGULATORY EVALUATION

36 37 The NRC regulations require that components that are important to the safe operation of a 38 nuclear power plant be treated in a manner that provides adequate assurance that they will 39 satisfactorily perform their safety functions. Appendix A, "General Design Criteria for Nuclear 40 Power Plants," and Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel 41 Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR) 42 contain broadly based requirements for these nuclear power plant components. The regulation 43 at 10 CFR 50.55a requires nuclear power plant licensees to implement provisions of the 44 American Society of Mechanical Engineers (ASME) Code for testing of MOVs as part of their 45 integrated surveillance testing (IST) programs. In 1999, the NRC revised 10 CFR 50.55a to 1

incorporate by reference the ASME Code for Operation and Maintenance of Nuclear Power 2

Plants (OM Code). The NRC also supplemented the quarterly MOV stroke-time testing specified 3

in the ASME OM Code by requiring licensees that have the ASME OM Code as their code of 4

record to verify the design-basis capability of MOVs within the scope of the ASME Code on a 5

periodic basis.

6 7

In 1996, the NRC issued GL 96-05 to provide detailed guidance for the periodic verification of 8

MOV design-basis capability in response to MOV performance issues at operating nuclear 9

power plants. In GL 96-05, the NRC staff asked licensees to establish a program, or ensure the 10 effectiveness of the current program, to verify on a periodic basis that safety-related MOVs 11 continue to be capable of performing their safety functions within the current licensing basis of 12 the facility. The NRC staff applied lessons learned from industry and NRC valve testing 13 programs, and MOV inspections at nuclear power plants, in reviewing the industry-wide JOG 14 Program on MOV Periodic Verification developed in response to GL 96-05. In Reference 4, the 15 NRC staff concluded that the JOG Program on MOV Periodic Verification provides an 16 acceptable industry-wide response to GL 96-05 for valve age-related degradation if implemented 17 in accordance with the SE.

18 19 The NRC has reviewed the revised pages of the JOG MOV Periodic Verification Summary 20 Report provided by the JOG in a letter dated June 20, 2007, for consistency with the regulatory 21 evaluation in Reference 4. The NRC staff has determined that the regulatory evaluation for the 22 JOG program continues to be applicable for the periodic verification of the design-basis 23 capability of the MOVs with the revised information in accordance with the GL 96-05 24 recommendations for valve age-related degradation.

25 26

3.0 TECHNICAL EVALUATION

27 28 The revised pages to the JOG MOV periodic verification summary TR provided in Reference 6 29 are the result of a re-evaluation of the design of a butterfly valve (JOG Valve B22.4) tested at a 30 nuclear power plant as part of the JOG program. Following issuance of the TR, the JOG 31 determined that the subject butterfly valve has a double offset disk design rather than the 32 standard symmetric design. With the correct disk design, the JOG reanalyzed the test data for 33 this valve. The JOG determined that the maximum observed coefficient of friction for the 34 butterfly valve bearing made of a Teflon derivative was 0.31 rather than 0.23 specified in the 35 original TR.

36 37 Based on its re-analysis, the JOG has revised the applicable pages in the JOG MOV periodic 38 verification summary TR to reflect the corrected maximum bearing friction coefficient and test 39 results for JOG Valve B22.4. Although the bearing friction coefficient increased when applying 40 the correct disk design, the JOG has not modified the program conclusions regarding the 41 stability of the bearing coefficient of friction for butterfly valves. In Reference 6, the JOG stated 42 that the revised information had been distributed to the JOG participants with only one nuclear 43 power plant licensee reporting use of this type of butterfly valve. The JOG planned to prepare 44 Revision B to MPR-2524 to reflect the revised information.

45 46 Based on sound engineering judgment, the NRC staff considers the re-calculated bearing 47 coefficient of friction for JOG Valve B22.4 to remain a reasonable value for bearing coefficient of 48 friction for the subject butterfly valve. Furthermore, the data from the repetitive tests of 49 Valve B22.4 as part of the JOG program continue to indicate stability of the bearing friction 50 coefficient for this valve although at a higher friction value. Therefore, the NRC staff finds that 51 the re-analysis of the bearing coefficient of friction for Valve B22.4 does not change the 1

conclusions of its review of the JOG MOV Periodic Verification Program discussed in the SE 2

dated September 25, 2006.

3 4

4.0 CONCLUSION

5 6

The NRC staff has reviewed the revised pages from the JOG MOV periodic verification summary 7

TR (Reference 6). Based on its review of the revised pages to the JOG TR, the SE dated 8

September 25, 2006, and this SE supplement, the NRC staff continues to conclude that the JOG 9

program on MOV periodic verification provides an acceptable industry-wide response to 10 GL 96-05 for valve age-related degradation when implemented in accordance with the SE and 11 this supplement.

12 13 As discussed in the SE dated September 25, 2006, licensees are responsible for implementing 14 the applicable conditions in the SE on the JOG program description TR and the findings of the 15 SE (including this supplement) on the JOG TR. Where a licensee that has committed to 16 implement the JOG program as part of its response to GL 96-05 identifies safety-related MOVs 17 or its application that are outside the scope of the JOG program, the NRC staff expects the 18 licensee to notify the NRC staff of its plans for periodically verifying the design-basis capability of 19 those MOVs in accordance with its commitments to GL 96-05.

20 21

5.0 REFERENCES

22 23

1.

NRC Generic Letter 96-05, Periodic Verification of the Design-Basis Capability of 24 Safety-Related Motor-Operated Valves, September 18, 1996. (ADAMS Accession 25 No. ML031110010) 26 27

2.

NRC Staff Safety Evaluation of JOG Topical Report MPR-1807, dated October 30, 1997.

28 (ADAMS Accession No. 9801160151) 29 30

3.

JOG Topical Report MPR-2524 (Rev. 0, February 2004), Joint Owners' Group Motor 31 Operated Valve Periodic Verification Program Summary, February 27, 2004.

32 33

4.

NRC Staff Final Safety Evaluation of JOG Program On Motor-Operated Valve Periodic 34 Verification, dated September 25, 2006. (ADAMS Accession No. ML061280315) 35 36

5.

JOG MPR-2524-A (November 2006), Joint Owners Group (JOG) Motor Operated Valve 37 Periodic Verification Program Summary, dated December 11, 2006. (ADAMS 38 Accession No. ML063490194) 39 40

6.

Revised pages to JOG Topical Report MPR-2524, dated June 20, 2007. (ADAMS 41 Accession No. ML071730468) 42 43 Principal Contributor: T. Scarbrough 44 45 Date: August 14, 2008 46 47

BWR Owners= Group Project No. 691 Mr. Richard Libra Executive Vice Chair, BWR Owners= Group Exelon Generation Co, LLC 200 Exelon Way Mail Code KSA 2-N Kennett Square, PA 19348 Rick.libra@exeloncorp.com Mr. Richard Anderson BWROG, Executive Chair FPL Energy (DAEC)

Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 richard_l_anderson@fpl.com Mr. James F. Klapproth GE-Hitachi Nuclear Energy M/C A50 3901 Castle Hayne Road Wilmington, NC 28401 james.klapproth@ge.com Mr. Joseph E. Conen, Vice Chair Regulatory Response Group BWR Owners= Group DTE Energy-Fermi 2 200 TAC 6400 N. Dixie Highway Newport, MI 48166 conenj@dteenergy.com Dennis Madison, Hatch Vice President Southern Nuclear Operating Co.

11028 Hatch Parkway North Baxley, GA 31515-2010 drmadiso@southernco.com Frederick Emerson BWROG, Project Manager Frederick.emerson@ge.com Mr. Ken A. McCall, Program Manager GE-Hitachi Nuclear Energy M/C F12 3901 Castle Hayne Road Wilmington, NC 28401 kenneth.mccall@ge.com Oscar Limpias Entergy Nuclear Northeast 1340 Echelon Parkway.

Jackson, MS 39213-8202 olimpia@entergy.com Joe Donahue Progress Energy Inc.

410 S. Wilmington St.

PEB 6A Raleigh, NC 27601-1849 joe.w.donahue@pgnmail.com Paul J. Davison Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038 paul.davison@pseg.com Mr. Ted Schiffley Vice Chairman, BWROG Exelon Generation Co., LLC.

Cornerstone II at Cantera 4300 Winfield Road Warrenville, IL 60555 frederick.schiffley@exeloncorp.com Mr. Randy C. Bunt, Chair Regulatory Response Group Southern Nuclear Operating Company 40 Inverness Center Parkway/Bin B057 Birmingham, AL 35242 rcbunt@southernco.com 8/6/08

PWR Owners Group Project No. 694 cc:

Mr. James A. Gresham, Manager Regulatory Compliance and Plant Licensing Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355 greshaja@westinghouse.com Gordon Bischoff, Manager Owners Group Program Management Office Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355 gordon.c.bischoff@us.westinghouse.com 5/12/06