ML090400610
| ML090400610 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/24/2009 |
| From: | Bone S Division of Policy and Rulemaking |
| To: | Jeffrey Riley Nuclear Energy Institute |
| Tanya Mensah, NRR/DPR, 415-3610 | |
| Shared Package | |
| ML090430444 | List: |
| References | |
| TAC MD3236, TR-103237, Rev 1 | |
| Download: ML090400610 (4) | |
Text
February 24, 2009 Mr. James H. Riley, Director Engineering Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708
SUBJECT:
SUPPLEMENT 4 TO FINAL SAFETY EVALUATION FOR NUCLEAR ENERGY INSTITUTE (NEI) ADDENDA 3, 4, 5, 6, AND 7 TO ELECTRIC POWER RESEARCH INSTITUTE (EPRI) TOPICAL REPORT (TR) 103237, EPRI MOV
[MOTOR-OPERATED VALVE] PERFORMANCE PREDICTION PROGRAM, REVISION 2 (TAC NO. MD3236)
Dear Mr. Riley:
In February 1994, the NEI submitted for U.S. Nuclear Regulatory Commission (NRC) review EPRI TR-103237, Revision 0. In November 1995, the NEI submitted for NRC review EPRI TR-103237, Revision 1. On March 15, 1996, the NRC staff issued a safety evaluation (SE) documenting the NRC staff's acceptance of the EPRI MOV Performance Prediction Methodology (PPM) described in the subject TR, with certain conditions and limitations. The SE addressed the EPRI computer model for globe and butterfly valves and various gate valves, and EPRI hand-calculation models for Anchor/Darling double disk gate valves and Westinghouse Electric Company flexible wedge gate valves. On February 20, 1997, the NRC staff issued Supplement 1 to the SE dated March 15, 1996. This supplemental SE discussed two additional gate valve (WKM parallel expanding and Aloyco split wedge) hand-calculation methods and highlighted other aspects of the TR.
On September 8, 1999, the NEI submitted for NRC review Addendum 1, PPM Version 2.0, and Addendum 2, Thrust Uncertainty Method, to EPRI TR-103237, Revision 2. Version 2.0 of the EPRI MOV PPM described in Addendum 1 to the TR resolves several previous modeling errors and incorporates other improvements to the modeling software. In Addendum 2 to TR-103237, Revision 2, the EPRI describes the development of its Thrust Uncertainty Method that takes into account conservatism in the EPRI MOV PPM to predict a more realistic thrust requirement for closing gate valves. On April 20, 2001, the NRC staff issued Supplement 2 to the SE dated March 15, 1996, concluding that the changes made to the PPM in Addendum 1 to TR-103237, Revision 2, improve the ability of the EPRI model to predict the applicable thrust or torque required to operate gate, globe, and butterfly valves.
On January 5 and December 6, 2001, and June 10, 2002, the NEI submitted for NRC review revisions to Addendum 2 to EPRI TR-103237, Revision 2. These revisions involved the establishment of additional criteria for application of the Thrust Uncertainty Method for gate valves under cold water applications within the scope of the Thrust Uncertainty Method.
J. Riley On September 30, 2002, the NRC staff issued Supplement 3 to the SE dated March 15, 1996, concluding that the Thrust Uncertainty Method developed by the EPRI is acceptable for the prediction of minimum allowable thrust at control switch trip (or flow isolation) for applicable gate valves under cold water applications within the scope of the Thrust Uncertainty Method subject to the applicable limitations and conditions specified in the Thrust Uncertainty Method.
On June 8, 2004, the NEI submitted Addendum 5, PPM Version 3.1 Software Changes, Addendum 6, PPM Version 3.2 Software Changes, and recent PPM error and information notices to TR-103237, Revision 2, for NRC review. Addendum 5 provided PPM Software Version 3.1; updated the PPM to a Window-based application; automated certain manual calculations; adjusted the software to allow more ready use for air-operated valve (AOV) and hydraulic-operated valve (HOV) applications; and incorporated software and documentation improvements. Addendum 6 provided PPM Software Version 3.2; corrected potential non-conservative effects from upstream disturbances; and prevented incorrect use of best estimate butterfly valve torque predictions.
On January 6, 2006, the NEI submitted Addendum 3, An Improved and Validated Method for Predicting Gate Valve Unwedging Thrust Requirements, Addendum 4, Use of Static Closure Data for Determining Stem Stem-Nut Coefficients of Friction at Unwedging, and Addendum 7, PPM Version 3.3 Software Changes, to TR-103237, Revision 2, for NRC review. Addenda 3, 4, and 7 document changes made to the EPRI PPM computer code between Versions 3.2 and 3.3, and also provide improved methods for evaluating gate valve undwedging thrust requirements.
On April 23, 2007, and June 3, 2008, the NRC staff requested that the NEI submit additional information to support its request. The NEI submitted the requested information in letters dated September 27, 2007, and August 7, 2008. By letter dated January 14, 2009, an NRC draft SE for the TR, Supplement 4 to Safety Evaluation Dated March 15, 1996: Addenda 3, 4, 5, 6, and 7 to EPRI TR-103237, Revision 2, was provided for your review and comments. In an email dated January 30, 2009, from Mike Melton, Senior Project Manager, NEI, to Tanya Mensah, Senior Project Manager, NRC, the NEI commented on the draft SE. The NRC staffs disposition of NEIs comments on the draft SE are discussed in the Attachment to the final SE enclosed with this letter.
The NRC staff has found that Addenda 3, 4, 5, 6, and 7 to EPRI TR-103237, Revision 2, is acceptable for referencing in licensing applications as discussed in the enclosed final SE. The final SE defines the basis for our acceptance of the TR.
Our acceptance applies only to material provided in the subject TR. We do not intend to repeat our review of the acceptable material described in the TR. When the TR appears as a reference in license applications, our review will ensure that the material presented applies to the specific plant involved. License amendment requests that deviate from this TR will be subject to a plant-specific review in accordance with applicable review standards.
In accordance with the guidance provided on the NRC website, we request that NEI publish accepted proprietary and non-proprietary versions of this TR within three months of receipt of this letter. The accepted versions shall incorporate this letter and the enclosed final SE after the title page. Also, they must contain historical review information, including NRC requests for
J. Riley additional information and your responses. The accepted versions shall include an "-A" (designating accepted) following the TR identification symbol. If future changes to the NRC's regulatory requirements affect the acceptability of this TR, NEI and/or licensees referencing it will be expected to revise the TR appropriately, or justify its continued applicability for subsequent referencing.
Sincerely,
/RA/
Sheri L. Bone, Acting Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689
Enclosure:
Final SE cc w/encl: See next page
J. Riley February 24, 2009 additional information and your responses. The accepted versions shall include an "-A" (designating accepted) following the TR identification symbol. If future changes to the NRC's regulatory requirements affect the acceptability of this TR, NEI and/or licensees referencing it will be expected to revise the TR appropriately, or justify its continued applicability for subsequent referencing.
Sincerely,
/RA/
Sheri L. Bone, Acting Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689
Enclosure:
Final SE cc w/encl: See next page DISTRIBUTION:
PUBLIC PSPB Reading File RidsNrrDpr RidsNrrDprPspb RidsNrrPMTMensah RidsNrrLADBaxley RidsOgcMailCenter RidsAcrsAcnwMailCenter RidsNrrDci RidsNrrDciCptb SRosenberg (Hardcopy)
ADAMS ACCESSION NOS.
Package: ML090430444 Letter: ML090400610 Final SE: ML090400621 *No major changes to SE input. NRR-043 OFFICE PSPB/PM PSPB/LA DCI/CPTB* PSPB/BC DPR/DD (A)
NAME TMensah DBaxley JMcHale SRosenberg SBone DATE 2/19/09 2/19/09 10/30/08 2/23/09 2/24/09 OFFICIAL RECORD COPY
Nuclear Energy Institute Project No. 689 cc:
Mr. Anthony Pietrangelo, Vice President Mr. Alexander Marion, Acting Vice President Regulatory Affairs for Nuclear Operations Nuclear Energy Institute Nuclear Energy Institute 1776 I Street, NW, Suite 400 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Washington, DC 20006-3708 arp@nei.org am@nei.org Mr. Jack Roe, Director Mr. John Butler, Director Security Operations Support Nuclear Energy Institute Nuclear Energy Institute 1776 I Street, NW, Suite 400 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Washington, DC 20006-3708 jwr@nei.org jcb@nei.org Mr. Charles B. Brinkman Mike Melton, Senior Project Manager Washington Operations 1776 I Street, NW, Suite 400 ABB-Combustion Engineering, Inc. Washington, DC 20006-3708 12300 Twinbrook Parkway, Suite 330 man@nei.org Rockville, MD 20852 brinkmcb@westinghouse.com Dennis Buschbaum PWROG Chairman Mr. James Gresham, Manager Comanche Peak Steam Electric Station Regulatory Compliance and Plant Licensing 6322 North Farm to Marked Rd 56 Westinghouse Electric Company Mail Code E15 P.O. Box 355 Glen Rose, TX 76043 Pittsburgh, PA 15230-0355 Dennis.Buschbaum@luminant.com greshaja@westinghouse.com Ms. Barbara Lewis Assistant Editor Platts, Principal Editorial Office 1200 G St., N.W., Suite 1100 Washington, DC 20005 Barbara_lewis@platts.com