ML17059A516
| ML17059A516 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/03/1994 |
| From: | Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| References | |
| GL-89-10, NUDOCS 9411150258 | |
| Download: ML17059A516 (98) | |
Text
November 3, 1994 Docket Nos.
50-220 50-410 Hr. B. Ralph Sylvia Executive Vice President Nuclear Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093
SUBJECT:
MOTOR-OPERATED VALVE MEETING
Dear Hr. Sylvia:
This refers to the public meeting conducted in King of Prussia, Pennsylvania on October 26, 1994.
The meeting was held to discuss motor-operated valve (MOV) issues with Region I licensees.
Special emphasis was placed on the expectations for completion and the process for closure of Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance."
The meeting was attended by 86 individuals, including those representing your organization.
Copies of presentations are attached, as is a list of 21 questions that were submitted to the NRC prior to the meeting, and discussed during the panel session.
In accordance with Section 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
We appreciated the responsiveness and turnout for this meeting, and will continue to communicate our expectations regarding the verification of HOV design basis capability.
Should you have any questions concerning any of the topics raised, we will be pleased to discuss them further with you.
Sincerely, Attachments:
l.
Attendees 2.
Agenda 3.
Licensee Presentations 4.
NRC Presentations 5.
Panel Session guestions Eugene H. Kelly, Chief Systems Section Division of Reactor Safety 9411150258 941103 PDR'DOCK 05000220 P
November 3, 1994 Hr.
B. Ralph Sylvia cc w/encl:
L. Storz, Vice President Nuclear Generation C. Terry, Vice President - Nuclear Engineering M. HcCormick, Vice President, Safety Assessment
& Support R. Abbott, Unit I Plant Hanager K. Dahlberg, Unit 2 Plant Manager D. Wolniak, Manager, Licensing (Acting)
J.
- Warden, New York Consumer Protection Branch G. Wilson, Senior Attorney M. Wetterhahn, Winston and Strawn
- Director, Energy
& Water Division, Department of Public Service, State of New York C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law State of New York, SLO Designee K. Abraham, PAO (2)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
p
November 3, 1994 Mr. B. Ralph Sylvia bcc w/encl:
Region I Docket Room (with concurrences)
W. Dean, OEDO (WMD)
B. Norris Nine Hile Point T. Harsh, 5RR D. Brinkman, NRR H. Campion, RI DRS File (2)
DOCUHENT NAME:
A: MOVHTG.REP To receive a copy ofths document, indicate in the boxt 'C' Copy without attachment/enclosure
'E' Copy with attachment/enclosure "N'
No copy OFFICE RI/DRS RI/DRS RI/
RI/
RI/
NAME Bower Kell DATE 11/02/94 ll/7 /94M ll/
/94 11/
/94 ll/
/94 OFFICIAL RECORD COPY
ATTACHMENT I ATTENDEES New York Power Authorit K. Kinglsey
- f. Martsen R.
Green J.
Cameron A. Halliday A. Decker K. Eslinger Licensing Engineer Corporate MOV Coordinator Indian Point 3 JAF/Lead MOV Engineer JAF/Manager Program Manager Site MOV Coordinator aine Yankee Atomic Power Com an D. Whittier S. Nichols B. Moulton D. Hakkila S. Nichols Manager Corporate Engineer Yankee Atomic Nuclear Power A. Parker J. Callahan Audit Supervisor Lead Systems Engineer Du uesne Li ht Com an C. Cluster S. Loehlein E. Coholich DgE Director Comp. Engineering Engineering Supervisor Sr. Licensing Supervisor Vermont Yankee Nuclear Power T. Trask MOV Coordinator North Atlantic Ener Service Cor oration G. Sessler P. Searfoorce M. Makowicz Sr. Project Engineer HOV Project Manager
r
Attachment 1
GPU Nuclear B.
Elam D. Distel D. Hassler.
R.
Zimmerman J.
Tabone D.
Roumes J.
Correa E. Showalter P.
Walsh T. Carroll J. Chartorina Boston Edison Maintenance Engineering Director Corporate Licensing Licensing Plant Engineering Engineer Lead Electrical Engineer Plant Engineering Director MOV Engineer Mechanical Engineer B. Sullivan H. Lenhart T. White J. Jerz Sr. Licensing Engineer Safety Analysis Engineer Project Manager Public Service Electric
& Gas S. Gallegly C. Hanges R. Lewis F. Higgins S. Haginnis R. Sandquist PECO Ener HOV Engineer Licensing Engineer Sr. Staff Engineer Sr. Staff Engineer Project Manager MOV Engineer K. Graffe G. Stathes D. Cronomiz S.
Bobyack B. Carsky
'C. Sellers Licensing Mechanical Engineering Branch Manager Erin Engineering Rochester Gas 8 Electric K. Huller HOV Program Coordinator Consolidated Edison D. Hinshaw T. DeDonato C.
Laverde J.
Lamm Engineer Engineer System Engineer
Attachment 1
Baltimore Gas 8 Electric B. Rudell J.
Riedel B. Nowicki.
K. Cunningham J.
Osborne G.S. Project Management HOV Project Manager Maintenance Engineer HOV Engineer Northeast Utilities T. Hurray B. Harris Licensing Penns lvania Power L Li ht J. Gutshall M. Rose K. Anderson Valve Maintenance Supervisor Sr. Project Engineer Project Engineer Nia ara Mohawk Power Cor oration C. Fischer R. Main J. Halusic J.
Banyan N. Kollengode Technician HOV Coordinator Unit 2 Engineer Project Manager U.S.
c ear Re ulator Commission B. Kane J. Wiggins G. Kelly L. Prividy B. HcDermott F.
Bower H. Buckley P. Drysdale A. Wang H. Rathbun C. Poslusny D.
Wessman T. Scrabrough PA De artment of Deputy Regional Administrator Deputy Director Chief Systems Section Sr. Reactor Engineer Reactor Engineer Reactor Engineer Reactor Engineer Sr. Reactor Engineer PM Haddam Neck, NRR Mechanical
- Engineer, NRR NRR NRR NRR Environmental Services R. Maiers D. Ney Bureau of Radiation Protection Bureau of Radiation Protection
Attachment 1
NUS Cor oration S. Katradis Mechanical Staff Engineer State of New Jerse D. Zannons Nuclear Engineering Program
S'1
Attachment 2
AGENDA MOTOR-OPERATED VALVEMEETING 26 OCTOBER 1994 S:00 A.M.
S:15 A.M.
8:30 A.M.
9:00 A.M.
9:30 - 9:45 A.M.
9:45 - 10:15 A.M.
Welcome and Opening Remarks by William Kane, Deputy Regional Administrator, NRC Region I Keynote:
"Expectations for Completion" by James Wiggins, Director, Division of Reactor Safety, NRC Region I "UtilityPerspective" by James Riedel, MOV Project Manager, Baltimore, Gas 4 Electric Co. (BGRE)
"Process for Closure" by Richard Wessman, Chief, NI&,Division of Engineering Break "Closure at Calloway" by Thomas Scarbrough 10:15 - 11:30 A.M.
Breakout Sessions 11:30 - 1:00 P.M.
Lunch 1:00 -1:30 P.M.
"UtilityPerspective" by Steven Maginnis, MOV Project Manager, Public Service Electric & Gas Co.
(PSERG) 1:30 -2:30 P.M.
2:30 -2:45 P.M.
2:45 -4:15 P.M.
4:15 -4:30 P.M.
Feedback Break Questions and Answers Panel Session Closing Remarks by Eugene Kelly, Chief, Systems Section, Division of Reactor Safety
Attachment 3
CALVERT CLIFFS IVIOV PROJECT STRENGTHS:
MANAGEMENT ATTENTlON:
TOP LEVELCOMMITMENT COGNIZANT YET ALLOWEDPROJECT MANAGER FLEXIBILITYAND AUTHORITY PEOPLE:
PROJECT TEAM METHODOLOGY KNOWLEDGEABLE& DEDICATED LONG TERM INVOLVEMENTBY KEY MEMBERS IN-HOUSE MAINTENANCE-OWNERSHIP QUALITYVERIFICATION
0 CALYERT CLIFFS MOY PROJECT STRENGTHS:
COMMVNICATION WITH IN DVSTRY MUG EPRI INPO ASSIST VISIT ALLOWED US TO STAY CURRENT ON TECHNICAL ISSUES, EFFORTS
& PROGRESS REVIEW & ASSESS STRENGTHS &
WEAKNESSES EVALUATE ALL INDUSTRY / NRC CONCERNS OE, PART 21, INFO. NOTICES, INSPECTIONS VENDOR TECHNICAL UPDATES
CALVERT CLIFFS MOV PROJECT I
STRENGTHS:
RESPONSE
TO " BEST AVAILABLE"i INDUSTRY DEVELOPS ENTS ACKNOWLEDGED:
HIGHER VF
.20 COF ACCURACIES / TSR TORQUE LOSSES ROL SPRING PACK RELAXATION LUBRICATION DEGRADATION INCORPORATED RESULTS INTO OUR SIZING /SETTING METHODS CAUTIOUS APPROACH ON TORQUE CONTROL EXTENSIVE EFFORT IN DEVELOPING A DECISION TREE FOR LIMIT OR TORQUE CONTROL
0
CALVERT CLIFFS MOV PROJECT STRENGTHS:
HARDWARE UPGRADE VS "PENCIL SHARPENING" MODIFIED EQUIPMENT TO IMPROVE DESIGN CAPABILITY OVERHAULED ALL PROGRAM MOVs TORQUE SWITCH / SPRING PACK TESTING NO HESITATION TO REPLACE UNDESIRABLE PERFORMANCE MARGIN TO ABSORB "UNKNOWNS" AND INDUSTRY "SURPRISES "
0
CALVERT CLIFFS MOV PROJECT PROJECT STRENGTHS MANAGEMENT SUPPORT PEOPLE COMMUNICATION WITH INDUSTRY
RESPONSE
TO "BEST AYAILABLE"/
INDUSTRY DEVELOPMENTS HARDWARE UPGRADES VS "PENCIL SHARPENING"
CALVERT CLIFFS IVIOV PROJECT CLOSURE ISSUES:
MAINTAIN STRONG PROGRAM VALIDATE ASSUMPTIONS RECONCILE TWO - STAGE APPROACH PERIODIC VERIFICATION
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES:
MAlNTAIN STRONG PROGRAM MANAGEMENT COMMITMENT DESIGN BASES CONTROL COMPREHENSIVE MAINTENANCE PROGRAM "NORMAL PLANT PROCESS CONTROLS"
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES:
VALIDATEASSUMPTIONS VALVE FACTOR DIAGNOSTIC ACCURACY COF MOTOR TORQUE ROL TSR EXTRAPOLATION OF LESS THAN DESIGN TESTING LUBE DEGRADATION SPRING PACK RELAXATION
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES:
VALIDATION METHODS EVlDENCE EXISTS TODAY VALVE FACTOR PLANT SPECIFZC DIAGNOSTIC ACCURACY TESTING COF MOTOR TORQUE INDUSTRY GROUPS TESTING ROL VENDOR TESTING TSR EXTRAPOLATION OF TEST DATA EPRI JVDGEMENT NOW LUBE DEGRADATZON SPRING PACK RELAXATZON SUPPORTED BY MONITORING &
EVALUATION
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES:
RECONCILE TWO-STAGE APPROACH COMPARISON APPLICABLE TEST RESULT IN HOUSE OUTSIDE
( EPRI - UTILITIES)
EPRI PPM STATIC ONLY (NO MATCH)
MARGIN PRA
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES:
PERIODIC VERIFICATION:
TESTING AT DESIGN CONDITIONS GIVES DIRECT INDICATION OF PERFORMANCE
... BUT AT WHAT COST?
IMPACT PLANT SAFETY ECONOMIC IMPACT
CALVERT CLIFFS IVIOV PROJECT CLOSURE ISSUES PERIODIC VERIFICATION CONSIDERATIONS MARGIN PRA RISK RANKING HIGH MED LOW LOW MARGIN MED HIGH
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES:
CAN OTHER PRACTlCES GIVE ADEQUATE lNDICATtON OF PERFORMANCE OR REASONABLE ASSURANCE OF PERFORMANCE.?
AGGRESSIVE / COMPREHENSIVE MAINTENANCE PRACTICES TRENDING OF KEY PERFORMANCE PARAMETERS EPRI PPM ADVANCED DIAGNOSTIC TECHNIQUES i.e. MCC-MTR PWR MONITORING DATA SHARING WITHIN THE INDUSTRY
CALVERT CLIFFS MOV PROJECT OBSERVATIONS:
UTILITIES SEEMED TO BE CHASING A MOVING TARGET.
RESEARCHING IN PARALLEL WITH COMPLYING.
INDUSTRY USING PC BASED DIAGNOSTIC EQUIPMENT TO ANALYZE EQUIPMENT DESIGNED WITH A SLIDE RULE.
ARE WE VICTIM OF "DIMINISHING RETURN" ?
DID MARKED IMPROVEMENT IN SIZING/SETTING CONTROLS 5 DIAGNOSTICS ACHIEVE THE GOAL OF IMPROVED SAFETY?
EXORBITANT NUMBER OF INDIVIDUALRED EFFORTS AND NUMEROUS EQUATIONS TO REACH "JUSTIFICATIONS ".
WHICH HAD LEAD...
VENDOR TECHNOLOGY OR INDUSTRY NEED?
CALVERT CLIFFS MOV PROJECT LESSONS LEARNED:
INTER-INDUSTRY ( UTILITIES8( NRC) COMMUNICATION IS INFORMATIVE AND ESSENTIAL.
USE OF" PRA" METHODOLOGIES CAN BE MORE FULLY UTILIZED.
AS NEW ISSUES EMERGE....
MORE EMPHASIS ON UP-FRONT DETERMINATION AND AGREEMENT ON WHAT NEEDS TO BE DONE.
Attachment 4
PROCESS FOR CLOSURE OF STAFF REVIEW OF GENERIC LETTER 89-10 PROGRAMS AND PERIODIC VERIFICATION OF MOV DESIGN-BASIS CAPABILITY RIGHARn H.
WEssMAN
- CHXEF, MECHANICAL ENGXNEERING BRANCH OFFXCE OF NUCLEAR REACTOR REGULATXON U.S.
NUCLEAR REGULATORY COMMISSXON
PROCESS FOR CLOSURE OF STAFF REVIEW OF GENERIC LETTER 89-10 PROGRAMS PURSUANT TO 10 CFR 50.54(F),
GL 89-10 STATES THAT LICENSEES SHALL NOTIFY NRC 1N WRITING WITHIN 30 DAYS AFTER COMPLETION OF GL 89-10 DESIGN-BASIS VERIFICATION.
NRC STAFF MEMORANDUM DATED JULY 12,
- 1994, DESCRIBES THE PROCESS FOR CLOSURE OF THE STAFF'S REVIEW OF THE DESIGN-BASIS VERIFICATION PORTION OF LICENSEES'L 89-10 PROGRAMS.
WHEN A LICENSEE NOTIFIES NRC OF COMPLETION OF ITS GL 89-10
- PROGRAM, NRR PROJECT MANAGER WILL SET UP DISCUSSION BETWEEN NRR TECHNICAL STAFF AND REGION STAFF TO DISCUSS CLOSURE OF NRC STAFF REVIEW OF GL 89-10 PROGRAM.
FOLLOWING THOSE DISCUSSIONS, NRR PROJECT MANAGER WILL NOTIFY LICENSEE OF ANY NECESSARY INFORMATION TO CLOSE GL 89-10 OR SET UP TELEPHONE CONFERENCE TO DISCUSS CLOSURE OF STAFF REVIEW BY INSPECTION OR LICENSEE SUBMITTAL.
UPON SATISFACTORY COMPLETION OF NRC STAFF REVIEW, STAFF WILL CLOSE GL 89-10 REVIEW THROUGH LETTER FROM NRR PROJECT MANAGER OR COVER LETTER OF INSPECTION REPORT.
SUPPLEMENTAL INSPECTION GUIDANCE FOR CLOSURE OF STAFf REVIEW OF GL 89-10 PROGRAMS 04.04 SELECT SAMPLE OF MOVs FOR DETAILED REVIEW FROM THE POPULATION OF MOVs IN THE GL 89-10 PROGRAM.
LICENSEE IS EXPECTED TO HAVE VERIFIED DESIGN-BASIS CAPABILITY OF EACH MOV IN ITS GL 89-10 PROGRAM.
LICENSEE SHOULD HAVE AVAILABLE SPECIFIC STATUS FOR EACH GL.89-10 MOV.
PWR LICENSEE MAY DEFER CONSIDERATION OF VALVE MISPOSITIONING.
STAFF REVIEW MAY BE CLOSED IF LICENSEE COMMITS TO CONSIDER MISPOSITIONING IN THE EVENT THAT STAFF DETERMINES THIS RECOMMENDATION REMAINS APPROPRIATE.
04.05 VERIFY THAT LICENSEE HAS PERFORMED DESIGN-BASIS REVIEWS OF SAMPLED MOVs.
INSPECTORS WILL ASSESS THE PROGRESS BEING MADE BY LICENSEES IN ADDRESSING PRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
SUPPLEMENT 6 TO GL 89-10 PROVIDES INFORMATION ON PRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
SUPPLEMENTAL INSPECTION GUIDANCE (CONTINUED) 04.06 VERIFY THAT LICENSEE HAS ADEQUATELY SIZED SAMPLED MOVs.
INFORMATION ON SIZING AND SETTING PROVIDED IN APRIL 30,
04.07 VERIFY THAT LICENSEE HAS DEMONSTRATED DESIGN-BASIS CAPABILITY OF SAMPLED MOVs.
INSPECTORS WILL VERIFY IMPLEMENTATION OF LICENSEE ACTIONS IN RESPONSE TO SUPPLEMENT 5 TO GL 89-10 ON MOV DIAGNOSTIC EQUIPMENT ACCURACY.
INSPECTORS WILL ASSESS ADEQUACY OF LICENSEE'S TREATMENT OF MEASUREMENT ERROR IN THE ANALYSIS OF TEST DATA AND TORQUE SWITCH SETPOINT ANALYSIS.
SUPPLEMENT 6 TO GL 89-10 PROVIDES INFORMATION ON DEMONSTRATION OF MOV DESIGN-BASIS CAPABILITY, INCLUDING GROUPING.
04.08 VERIFY THAT THE LICENSEE HAS ESTABLISHED A METHOD FOR PERIODIC VERIFICATION.
t:DETAILS ON A FOLLOWING SLIDE]
SUPPLEMENTAL INSPECTION GUIDANCE (CONTINUED) 04.09
.VERIFY THAT LICENSEE HAS ANALYZED MOV FAILURES AND HAS EFFECTIVE CORRECTIVE ACTION
- PLAN, AND THAT LICENSEE TRENDS MOV FAILURES.
INSPECTORS WILL CONSIDER LICENSEE RESPONSE TO NRC INFORMATION NOTICES, INDUSTRY TECHNICAL AND MAINTENANCE UPDATES, AND 10 CFR PART 21 NOTICES.
04.10 VERIFY THAT THE LICENSEE IS MEETING PROGRAM SCHEDULE.
SUPPLEMENT 6 TO GL 89-10 PROVIDES GUIDANCE FOR LICENSEES THAT CANNOT MEET GL 89-10 SCHEDULE COMMITMENTS.
04.11 VERIFY QUALITY ASSURANCE PROGRAM IMPLEMENTATION IN DESIGN CONTROL AND TESTING.
PREVIOUS I SPE TIO I E
INSPECTORS WILL REVIEW RESOLUTION OF PREVIOUS INSPECTION ISSUES, SUCH AS JUSTIFICATION FOR THE GL 89-10 PROGRAM ASSUMPTIONS (VALVE FACTOR, STEM FRICTION COEFFICIENT, LOAD SENSITIVE BEHAVIOR, AND OTHERS)
PERIODIC VERIFICATION OF MOV DESIGN-BASIS CAPABILITY FOR GL 89-10
- CLOSURE, LICENSEES ARE EXPECTED TO HAVE A LONG-TERM PLAN FOR PERIODIC VERIFICATION THAT DEMONSTRATES THAT DEGRADATION OF MOV DESIGN-BASIS CAPABILITY WILL BE IDENTIFIED.
LICENSEES MAY USE PRA CONSIDERATIONS TO PRIORITIZE MOVs IN ESTABLISHING PERIODIC VERIFICATION FREQUENCY.
LICENSEES MUST HAVE CONFIDENCE THAT SAFETY-RELATED MOVs WILL REMAIN OPERABLE UNTIL NEXT SCHEDULED DESIGN-BASIS VERIFICATION TEST.
NRC STAFF IS WORKING WITH THE OPERATIONS AND ELPP ACCEPTABLE METHODS EE OF THE ASME BOILER AND PRESSURE VESSEL CODE TO DEV TO VERIFY MOV DESIGN-BASIS CAPABILITY THROUGH PERIODIC TESTING.
EXAMPLES OF ACCEPTED PERIODIC VERIFICATION PLANS fOR GL 89-10 CLOSURE ARE (1)
DYNAMIC DIAGNOSTIC TESTING, OR (2) STATIC DIAGNOSTIC TESTING WITH MARGIN BASED ON PLANT-SPECIFIC DYNAMIC TESTING.
AFTER CLOSURE OF THE STAFF'S REVIEW 0
- PROGRAMS, LICENSEES MAY ADJUST THEIR COMMI PERIODIC VERIFICATION OF MOV DESIGN-BASIS CAPABI WITH ADEQUATE JUSTIFICATION.
CLOSURE OF NRC STAFF REVIEW OF GENERIC LETTER 89-1'0 PROGRAMS Thomas G. Scarbrough lVlechanical Engineering Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
STATUS OF GENERIC LETTER 89-10 CLOSURE STAFF COMPLETED OUR REVIEW OF THE GL 89-10 PROGRAM AT THE CAI LAWAYNUCLEAR POWER PLANT.
OTHER NUCLEAR PLANTS THAT HAVE NOTIFIED THE STAFF OF THE COMPLETION OF THE DESIGN-BASIS CAPABILITYVERIFICATION PORTION OF THEIR GL 89-10 PROGRAMS INCLUDE:
4 COMANCHE PEAK 1 and 2 CRYSTAL RIVER FARLEY I and 2 FORT CALHOUN HARRlS HATCH 1 and 2 HOPE GREEK PALO VERDE 3 POINT BEACH 1 and 2 PRAIRIE ISLAND 1 and 2 ROBINSON SOUTH TEXAS 1 and 2 TURKEY POINT 3 WATERFORD BASED ON AGREEMENT BETWEEN THE LICENSEE AND NRC STAFF, FORT CALHOUN IS SUBMITTING INFORMATIONTO JUSTIFY CLOSURE OF THE STAFF REVIEW OF ITS GL 89-10 PROGRAM.
SOUTH TEXAS AND WATERFORD HAVE UNDERGONE GL 89-10 CLOSE-OUT INSPECTIONS AND THE STAFF IS NEARING CLOSURE OF OUR GL 89-10 REVIEW.
TMI AND MAINE YANKEE INITIALLYNOTIFIED THE STAFF THAT THEY BELIEVED THAT THEIR GL 89-10 PROGRAMS WERE COMPLETE, BUT SUBSEQUENT INSPECTIONS REVEALED THAT ADDITlONALWORK WAS NECESSARY.
THESE LICENSEES ARE SUBMITTINGSCHEDULE EXTENSION JUSTIFICATIONS.
PRINCIPAL LICENSEE ACTIONS FOR CLOSURE OF STAFF REVIEW OF GL 89-10 PROGRAMS IVIOV DESIGN-BASIS CAPABILITY LICENSEE JUSTIFIES DESIGN-BASIS CAPABILITYFOR EACH MOV IN GL 89-10 PROGRAIVl AND HAS ESTABLISHED A PROCESS FOR OBTAINING FURTHER INFORMATION WHERE NOT SATISFIED WITH JUSTIFICATION FOR CERTAIN IVlOVs.
PRESSURE LOCKING AND THERlVIALBINDING LICENSEE DEMONSTRATES PROGRESS BEING MADE TO RESOLVE CONCERN ABOUT POTENTIAL PRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
PWR VALVEMISPOSITIONING PWR LICENSEE CONSIDERS VALVEMISPOSITIONING, OR COMMITS TO CONSIDER VALVEMISPOSITIONING IF STAFF DETERMINES THAT THIS RECOMMENDATION REIVIAINS APPROPRIATE.
PERIODIC VERIFICATION OF MOV DESIGN-BASIS CAPABILITY LICENSEE ESTABLISHES LONG-TERIVl PLAN FOR PERIODIC VERIFICATIONTHAT DEMONSTRATES THAT DEGRADATION OF DESIGN-BASIS CAPABILITYWILL BE IDENTIFIED.
EXAMPLES OF ACCEPTABLE PERIODIC VERlFlCATION PLANS FOR GL 89-'t0 CLOSURE ARE (1) DYNAMlC
DIAGNOSTIC TESTING, OR (2) STATIC DIAGNOSTIC
- TESTING WITH MARGIN BASED ON PLANT-SPECIFIC DYNAMICTESTING.
LICENSEE ACTIONS (confinued)
JUSTIFICATION OF PROGRAM ASSUMPTIONS LICENSEE JUSTIFIES ASSUMPTIONS USED IN THE GL 89-10 PROGRAM, SUCH AS A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
VALVEFACTOR (INCLUDINGAREA ASSUMPTION)
STEM FRICTION COEFFICIENT LOAD SENSITIVE BEHAVIOR MARGINS FOR STEM LUBRICATIONDEGRADATION AND SPRINGPACK RELAXATION MOTOR PERFORMANCE FACTORS
('I) MOTOR RATING (2) EFFICIENCIES USED IN OPEN AND CLOSE
. DIRECTIONS (3) APPLICATION FACTOR (4) POWER FACTOR USED IN DEGRADED VOLTAGE CALCULATIONS BASIS FOR EXTRAPOLATIONMETHOD OF PARTIAL D/P THRUST MEASUREMENTS TORQUE SWITCH REPEATABILITY USE OF LIMITORQUE, KALSI, OR OTHER SOURCES FOR INCREASING THRUST AND TORQUE ALLOWABLE LllVllTS EQUIPMENT ERROR POST-MAINTENANCE TESTING, ESPECIAlLY VALVEPACKING ADJUSTMENTS GROUPING OF MOVs TRENDING OF MOV PROBLEMS.
LICENSEE ACTIONS (continued)
RESOLVE GL 89-10 INSPECTION FINDINGS LICENSEE RESOLVES FINDINGS FROM PREVIOUS GL 89-10 INSPECTIONS.
IN GENERAL, MOST SIGNIFICANT GL 89-'10 INSPECTION CONCERNS HAVE BEEN:
('I) STATUS OF DYNAMICTESTING;
"(2) TEST ACCEPTANCE CRITERIA; (3) OPERABILITY/REPORTABILITYDETERIVIINATIONS; (4) FEEDBACK OF TEST RESULTS; AND (5) EVALUATIONOF POTENTIAL FOR PRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
OTHER LICENSEE ACTIVITIES FOUND TO NEED IIVIPROVEMENT:
(1) VALIDATIONOF ASSUMPTIONS IN MOV SIZING AND SETTING CALCULATIONS; (2) JUSTIFICATION OF MOV GROUPING FOR TESTING PURPOSES; (3) VERIFICATION OF EXTRAPOLATION METHODS FOR TEST DATA; (4) EVALUATIONOF DIAGNOSTIC TRACE ANOMALIES; (5) INVOLVEIVIENTOF QA IN VERIFYING TEST DATA AND ANALYSES ACCURACY; (6) JUSTIFICATION FOR METHOD TO PERIODICALLY VERIFY DESIGN-BASIS CAPABlLITY; (7) CORRECTIVE ACTION IN RESPONSE TO MOV
PROBLEMS; AND (8) POST-MAINTENANCETESTING FOLLOWING ACTIVITIESTHAT MIGHT AFFECT MOV PERFORMANCE UNDER DYNAMICCONDITIONS.
'I~
LICENSEE ACTIONS (continued)
ADDRESS CURRENT MOV ISSUES AND CONCERNS LICENSEE RECOGNIZES AND HAS PLAN TO ADDRESS CURRENT MOV ISSUES AND CONCERNS, SUCH AS
+
ACTUALTORQUE OUTPUT OF LlMITORQUE ACTUATORS LOWER THAN ANTICIPATED.
+
REDUCTION IN DC AND AC MOTOR SPEED DURING OPERATION UNDER DEGRADED VOLTAGE, DIFFERENTIAL PRESSURE, AND HIGH AMBIENT TEMPERATURE CONDITIONS.
+
ENSURING THE CAPABILITYOF MOV TO RETURN TO SAFETY POSITION FOLl OWING TESTING IF IVIOV IS ASSUMED TO BE OPERABLE DURING TESTING.
EVALUATIONOF POTENTIAL ADVERSE EFFECTS OF MOTOR STALL AND THERMALOVERLOAD TRIP, INCLUDINGSTRUCTURAl AND MOTOR DAMAGE.
+
CHAFING OF WIRES INSIDE LIMITSWITCH COMPARTMENT CAN CAUSE LOSS OF FUNCTION.
+
GLOBE VALVETHRUST REQU1REMENTS FOR PUMPED FLOW APPARENTLY CONTROLLED BY SEAT OR GUIDE AREAS.
+
INDUSTRY GLOBE VALVEBLOWDOWN TESTING SHOWED SIGNIFICANTLYHIGHER THRUST REQUIREMENTS THAN PREDICTED.
l I
+
INDUSTRY AND NRC-SPONSORED GATE VALVE BLOWDOWN TESTING SHOWED SOME VALVES TO HAVE UNPREDICTABLE BEHAVIOR.
/
CALLAWAY GL 89-'I 0 PROGRAM GL 89-10 PROGRAM SCOPE:
150 lVIOVs DYNAMICALLYTESTED:
'I03 MOVs DESIGN-BASIS CAPABILITYOF MOVs NOT DYNAMICALLY TESTED BASED ON GROUPING WITH OTHER TESTED IVIOVs AT CALLAWAYAND OTHER SOVRCES.
PERIODIC VERIFICATION:
MOVs STATIC DIAGNOSTIC TESTED USING DIAGNOSTICS EVERY 5 YEARS.
STATIC MARGIN FOR VALVEFACTOR DEGRADATION (SEPARATE AND DISTINCT FROM OTHER UNCERTAINTIES) FOR RISING-STEM MOVs INITIALLY SET AT 25% WITH SAMPLE DYNAMICTESTING TO JUSTIFY AT NEXT REFUELING OUTAGE.
STATIC MARGIN FOR AGE-RELATED DEGRADATION FOR QUARTER-TURN MOVs TO BE DETERMINED BASED ON SAMPLE DYNAMICTESTING AT NEXT REFUELING OUTAGE.
DYNAMICTESTING PERFORMED IF STATIC MARGIN FALLS BELOW ESTABLISHED CRITERIA.
PRESSURE LOCKING AND THERMAL BINDING OF GATE
VALVES:
LICENSEE PERFORMED INITIALEVALUATIONOF ALL SAFETY-RELATED MOTOR-OPERATED GATE VALVES.
ADDITIONALEVALUATIONWILLBE NECESSARY.
CALLAWAY'GL 89-10 PROGRAM (confinued)
NRC LETTER NOTIFYING LICENSEE OF CLOSURE OF STAFF REVIEW OF CALLAWAYGL 89-10 PROGRAM FORWARDED ON JUNE 8, 1994.
LETTER INDICATES LICENSEE'S PLANS TO CONDUCT THE FOLLOWING ACTIVITIESTO ENSURE THAT ASSUMPTIONS USED IN VERIFYING GL 89-10 MOV DESIGN-BASIS CAPABILITIES REMAIN VALID:
'1.
EVALUATEJUSTIFICATION FOR DESIGN-BASIS CAPABILITYOF 18 MOVs AS ADDITIONALINDUSTRY INFORMATION BECOMES AVAILABLE.
2.
CONTINUE TO ASSESS USE OF LINEAR EXTRAPOLATION OF IVIOV PERFORMANCE DATA.
3.
CONTINUE TO EVALUATEPRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
4.
PERFORM PERIODIC MOV PERFORMANCE VERIFICATION BY DYNAlVIICTESTING GATE AND GLOBE MOVs WHEN MARGIN IS I ESS THAN 25 PERCENT AFTER REQUIRED THRUST ADJUSTED FOR UNCERTAINTIES. FOLLOWING NEXT REFUELING OUTAGE, PROVIDE STAFF WITH DYNAMICTEST-
.BASED INFORMATION CONFIRMING 25% STATIC MARGIN FOR GATE AND GLOBE VALVES AND ESTABLISHING MARGIN FOR AGE-RELATED DEGRADATION FOR BUTTERFLY VALVES.
FORT CALHOUN GENERIC LETTER 89-10 PROGRAM GL 89-10 PROGRAM SCOPE:
29 MOVs DYNAMICALLYTESTED:
20 MOVs DESIGN-BASIS CAPABILITYOF MOVs NOT DYNAMICALLY TESTED BASED ON GROUPING WITH OTHER TESTED MOVs AT FORT CALHOUN AND OTHER SOURCES.
PERIODIC VERIFICATION:
INSPECTION REPORT 94-06 STATES THAT LICENSEE'S PLAN FOR PERIODIC VERIFICATION INCLUDES DYNAMICTESTING.
PRESSURE LOCKING AND THERMALBINDING OF GATE VALVES:
LICENSEE EVALUATEDGL 89-10 MOVs AND FOUND NONE SUSCEPTIBLE TO PRESSURE LOCKING.
ADDiTIONALEVAI UATION WILLBE NECESSARY.
LICENSEE PREPARING SUBMITTALTO SUPPORT CLOSURE OF STAFF REVIEW OF FORT CALHOUN GL 89-10 PROGRAM
WATERFORD GENERIC LETTER 89-10 PROGRAM GL 89-10 PROGRAIVI SCOPE:
66 MOVs DYNAIVllCALLYTESTED: '4 IVIOVs DESIGN-BASIS CAPABILITYOF MOVs NOT DYNAMICALLY TESTED BASED ON GROUPING WITH OTHER TESTED MOVs AT WATERFORD AND OTHER SOURCES.
PERIODIC VERIFICATION:
MOVs STATIC DIAGNOSTIC TESTED USING DIAGNOSTICS EVERY 5 YEARS.
STATIC MARGIN FOR VALVEFACTOR DEGRADATION (SEPARATE AND DISTINCT FROM OTHER UNCERTAINTIES) FOR GATE MOVs INITIALLYSET AT 25% WITH SAMPLE DYNAIVIICTESTING TO JUSTIFY AT NEXT REFUELING OUTAGE.
DYNAIVIICTESTING PERFORMED IF STATIC MARGIN FALLS BELOW ESTABLISHED CRITERIA.
LICENSEE PREPARING RESPONSE TO CLOSE-OUT INSPECTION REPORT ON PERIODIC VERIFICATION (INCLUDING GLOBE AND BUTTERFLY VALVES) AND POST-MAINTENANCE TESTING.
PRESSURE LOCKING AND THERIVIALBINDING OF GATE VALVES:
LICENSEE DETERMINED THAT 8 GATE VALVES WERE POTENTIAL SUSCEPTIBLE TO PRESSURE LOCKING AND
C Ee
~V~~UATED THEIR CAPABILITYTO OVERCOME THIS CONDITION. STAFF DID NOT REVIEW CALCULATIONS FOR TECHNICALMERIT. LICENSEE PERFORMED PRELIMINARYEVALUATIONOF THERMALBINDING.
ADDITIONALEVALUATIONWILLBE NECESSARY.
4
Attachment 5
QUESTIONS FOR REGION I MOVMEETING With respect to Supplement 5,
how would an accuracy related Part 21 issued today affect completion schedules for GL 89-10?
Liber'ty CSB 031 Addendum came late in the game why can't this be tracked as part of our continuing program?
How are technical disagreements to be handled?
If the NRC disagrees with a technical utility position and call them "not done" after they have closed their program by letter, what happens?
What if the NRC/Utility agree to disagree on a technical issue?
Is the NRC more interested in whether a utility has addressed all operability. concerns (ex: diagnostic equipment error), or are they more interested'n the completion of 'documentation called "HOV Program."
Does the NRC intend on applying a performance based regulatory philosophy toward the MOV Program?
Or does the NRC intend on applying the more traditional
- approach, which focused more on documentation than performance?
Is the NRC requiring "dynamic testing" for post maintenance testing of HOVs when valve repair is performed?
Please identify where the requirement is specified.
Is performance trending required for completion and closure of GL 89-10?
If so, then please indicate where the requirement is specified.
Concerning LSB assumptions, since LSB is not generic to every HOV, does it make sense to account for even when it is not seen on a
DP test, or-should we assume more than is seen on a
DP to static test comparison.
Concerning HOVs where Stellite 6 disk to seat facets are involved If DP effect is obvious and can be quantified on a less than max expected DP test, what if any is the minimum percentage that an extrapolation can be performed from the MEDP, considering that Stellite U, in many cases gets better with pressure increase.
Since most utilities have already undergone two inspections (i.e.,
Phase I, Phase I followup, Phase II) of their 89-10 Program, is it expected that a "closure" inspection will again cover test program implementation
- issues, or will the focus be on post-testing design basis capability of valves.
The BWR experience has been that a relatively small percentage of their 89-10 valve population can be tested at near
(>80X) design basis pressures.
What is the NRC's point of view on conservative boundary valve factors for valves in which credible DP testing could not be performed.
questions for HOV Meeting 10.
What is the NRC's point of view on new information (i.e., vendor service bulletins) and industry issues as it pertains to 89-10 Program testing completion and program closure.
ll.
In the enclosure to J.
E. Richardson's memorandum of April 30, 1993 (Guidance for Inspections of Programs in Response to Generic Letter 89-10), the staff noted the Limitorque position (from their September 17, 1992 letter to Cleveland Electric) that:
Run efficiency can be substituted for pull-out efficiency where the application involves a close safety function with no potential of the actuator stopping at any point during the close stroke.
Testing performed by TU Electric (as presented by Hr. Bill Black at the 3rd Pump and Valve Testing Symposium) seemed to confirm that the combination of motor stall at 80X voltage and run efficiency resulted in an actuator stall torque output which was reasonably well predicted by the standard Limitorque equation.
However, this may have been due to lower gear train efficiency combined with.greater than nameplate torque capability.
Is the staff working with INEL and Limitorque to verify the assumed gear train efficiencies?
Is it the staff's position that if a licensee proposes to take credit for greater than nameplate motor torque capability based on industry test programs (such as the current Commonwealth Edison program) then lower gear train efficiencies must also be applied?
12.
In his March 31, 1993 memorandum, Hr. Carl H. Berlinger (Chief of the NRR Electrical Engineering Branch) replied to questions from the Mechanical Engineering Branch concerning degraded voltage capability of HOVs.
guestion 2 concerned whether less than locked rotor current could be used to evaluate voltage drop and available motor terminal voltage at degraded voltage conditions.
In his reply Mr. Berlinger stated:
The locked rotor current shall be used to calculate the motor impedance at standstill condition (emphasis added).
The AC motor terminal voltage (bus voltage minus voltage drop due to cable impedance and over load heater resistance) is calculated as shown below:
V =V,xZ /(Z+Z.+R)
Where:
V Vb Z.
Z.
R Motor terminal voltage Bus voltage Motor impedance at standstill (emphasis added)
Rated voltage / <3 x locked rotor current Cable impedance Over load heater resistance
(
guestions for HOV Meeting Hy question concerns the standstill condition noted above.
If we are concerned with an MOV with a closed safety function with no potential of the actuator stopping (such as the case for run efficiency) do licensees need to consider locked rotor current?
If a licensee does not need to demonstrate standstill motor capability, it should be reasonable and justifiable to demonstrate motor capability at rated start torque current and calculate available motor terminal-voltage based on start torque current.
13.
15.
In the enclosure to J.
E. Richardson's memorandum of April 30, 1993, the staff also noted the example calculation for DC motor torque shown in the Limitorque Maintenance Update (LHU) of August 17, 1988 (also known as LHU 88-1).
Similar text is included in Enclosure 1 to Supplement 6,
however, the specific reference to the example calculation in LHU 88-1 was deleted.
Does this represent a change in the staff position concerning the analysis of DC MOVs?
I believe that a new Maintenance or.
Technical Update from Limitorque may clarify the analysis of the torque.
capability for DC motors.
I have attached an endorsement (provided to Pennsylvania Power 8 Light) by Hr.
P. Hcguillan, Limitorque Corporation representative, of the LMU 88-1 method (item 2).
This endorsement is qualified by the fact that the uncertainties of the generic motor curves must be considered and that no credit can be taken for more than rated motor start torque.
Can licensees use the LHU 88-1 method with the above qualifications?
Do you know if Limitorque's pending update concerning DC motors will change their position?
Does the NRC intend to impose on the industry the EPRI conclusions and/or recommendations relative to performance prediction, load sensitive
- behavior, valve factors, etc. or will utilities be expected to review EPRI's work and apply it as the utility evaluates it to be appropriate?
What role will Probabilistic Safety Assessment have in closure determination?
16.
What "lessons learned" in the GL 89-10 issue by NRC will be transferred to other NRC issues?
17.
18.
19.
Based on the results of the significant amount of testing that has been performed, we believe there is adequate justification to accept linear extrapolation to design condition.
Does the NRC agree?
Why or why not?
If not, what plausible scenarios exist to justify linear extrapolation?
Supplement 6 identifies similarities that should be considered when assessing "grouping."
Have additional characteristics or parameters been identified since Supplement 6 was issued?
What activity from the licensee constitutes completion of GL 89-10 program:
When testing is completed?
When analysis/calculations are revised?
C,
questions for MOV Meeting 20.
What is the frequency of repeat dynamic test?
Mould static tests suffice?
21.
What.is NRC's position regarding removal of valves from the program based on the Saul Levy study?
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