ML17158A558
| ML17158A558 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/03/1994 |
| From: | Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| GL-89-10, NUDOCS 9411150451 | |
| Download: ML17158A558 (49) | |
Text
November 3, 1994 Docket Nos.
50-387 50-388 Mr. Robert G.
Byram Senior Vice President - Nuclear Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
SUBJECT:
MOTOR-OPERATED VALVE MEETING
Dear Mr. Byram:
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 (HOV) 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.
Me appreciated the responsiveness and turnout for this meeting, and will continue to communicate our expectations regarding the verification of MOV 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 questions Eugene M. Kelly, Chief Systems Section Division of Reactor Safety 9'411150451 941103 PDR ADOCK 05000387 P
~
,PDR
November 3, 1994 Mr. Robert G.
Byram cc w/encl:
H.
G. Stanley, Vice President Nuclear Operations J.
M. Kenny, Nuclear Licensing G. T. Jones, Vice President Nuclear Engineering M. M. Urioste, Nuclear Services Manager J.
M. Finnegan, Supervisor, Nuclear Compliance H. D. Woodeshick, Special Office of the President J.
C. Tilton, III, Allegheny Electric Cooperative, Inc.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2)
NRC Resident Inspector Commonwealth of Pennsylvania
November 3, 1994 Mr. Robert G.
Byram bcc w/encl:
Region I Docket Room (with concur rences)
K. Gallagher, DRP W. Dean, OEDO C. Poslusny, Project Manager, NRR J. Stolz, PDI-2, NRR M. Shannon, ILPB DRS File (2)
DOCUMENT NAME:
A: MOVMTG.REP To receire a copy ofthis document, indicate in the boxt 'C' Copy without attachment/cnclosute "E'
Copy with attachment/cndosutc
'N' No copy OFFICE RI/DRS NAME Bower RI/DRS Kell RI/
RI/
RI/
ll/
/94 OFFICIAL RECORD COPY DATE 11 02/94 11/9 /94 ll/
94 ll/
94
ATTACHMENT I ATTENDEES New York Power Authorit K. Kinglsey F. Hartsen R.
Green J.
Cameron A. Halliday A. Decker K. Eslinger Licensing Engineer Corporate MOV Coordinator Indian Point 3 JAF/Lead HOV 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 H. Makowicz Sr. Project Engineer HOV Project Manager
Attachment 1
~CPU B.
Elam D. Distel D. Hassler.
R.
Zimmerman J.
Tabone J.
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 M. Lenhart T. White J. Jerz Sr. Licensing Engineer Safety Analysis Engineer Project Manager Public Service Electric
& Gas S. Gallegly C.
Manges R. Lewis F. Higgins S. Maginnis R. Sandquist PECO Ener MOV 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
& Electric K. Muller MOV 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 MOV Project Manager Maintenance Engineer MOV Engineer Northeast Utilities T. Hurray B. Harris Licensing Penns lvania Power
- 8. 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 MOV Coordinator Unit 2 Engineer Project Manager U.S. Nuclear Re ulator Commission B. Kane J. Wiggins G. Kelly L. Prividy B. McDermott F.
Bower H. Buckley P. Drysdale A. Wang H. Rathbun C. Poslusny D.
Wessman T. Scrabrough PA De artment of Deputy Regional Administrator
'eputy 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 Mechanica1 Staff Engineer State of New averse D. Zannons Nuc1ear Engineering Program
Attachment 2
AGENDA MOTOR-OPERATED VALVEMEETING 26 OCTOBER 1994 8:00 A.M.
S:15 A.M.
S:30 A.M.
9:00 A.M.
9:30 - 9:45 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 & Electric Co. (BG&E)
"Process for Closure" by Richard Wessman, Chief, NIW, Division of Engineering Break 9:45 - 10:15 A.M.
"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.
(PSE&G) 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 NIOV PROJECT STRENGTHS'ANAGEMENT ATTENTION:
TOP LEVELCOMMITMENT COGNIZANT YET ALLOWEDPROJECT MANAGER FLEXIBILITYANDAUTHORITY PEOPLE:
PROJECT TEAM METHODOLOGY KNOWLEDGEABLE8c DEDICATED LONG TERM INVOLVEMENTBY KEY MEMBERS IN-HOUSE MAINTENANCE-OWNERSHIP QUALITYVERIFICATION
CALVERT CLIFFS MOV PROJECT STRENGTHS:
COMMUNICATION WITH INDUSTRY MUG EPRI INPO ASSIST VISIT ALLOWED US TO STAY CURRENT ON TECHNICAL ISSUES, EFFORTS 5 PROGRESS REVIEW 5 ASSESS STRENGTHS 8(
WEAKNESSES EVALUATE ALL INDUSTRY / NRC CONCERNS OE, PART 21, INFO. NOTICES, INSPECTIONS VENDOR TECHNICAL UPDATES
CALVERT CLIFFS IVIOV PROJECT STRENGTHS'ESPONSE TO " BEST AVAILABLE"/ INDUSTRY DEVELOPMENTS 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
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 "
CALVERT CLIFFS IVIOV PROJECT PROJECT STRENGTHS MANAGEMENT SUPPORT PEOPLE COMMUNICATION WITH INDUSTRY
RESPONSE
TO "BEST AVAILABLE"/
INDUSTRY DEVELOPMENTS HARDWARE UPGRADES VS "PENCIL SHARPENING"
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES'AINTAIN 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:
VALlDATlON METHODS EYI DENCE EXlSTS TODAY VALVE FACTOR PLANT SPECIFIC DIAGNOSTIC ACCURACY TESTING COF INDUSTRY GROUPS MOTOR TORQUE TESTING ROL VENDOR TESTING TSR EXTRAPOLATION OF TEST DATA EPRI JUDGEMENT NOW LUBE DEGRADATION SPRING PACK RELAXATION 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
CALYERT CLIFFS MOY 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 MOV PROJECT CLOSURE ISSUES'ERIODIC VERIFICATION CONS I DE RATlONS MARGlN PRA RISK RANKING HIGH MED LOW LOW MARGIN MED HIGH
CALVERT CLIFFS MOV PROJECT CLOSURE ISSUES'AN OTHER PRACTICES GIVE ADEQUATE INDICATION 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 & DIAGNOSTICS ACHIEVE THE GOAL OF IMPROVED SAFETY?
EXORBITANT NUMBER OF INDIVIDUALR & D EFFORTS AND NUMEROUS EQUATIONS TO REACH "JUSTIFICATIONS".
WHICH HAD LEAD...
VENDOR TECHNOLOGY OR INDUSTRY NEED?
CALVERT CLlFFS MOV PROJECT LESSONS LEARNED:
INTER-INDUSTRY ( UTILITIES& 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 REVlEM OF GENERIC LETTER 89-10 PROGRAMS PERIODIC VERIFICATION OF MQY DESIGN-BASIS CAPABILITY RICHARD H.
CHESSMAN CHXEF I MECHANICAL ENGINEERXNG BRANCH OFFXCE OF NUCLEAR REACTOR REGULATXON U.S.
NUCLEAR REGULATORY COMMXSSXON
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 IN WRITING WITHIN 30 DAYS AFTER COMPLETION QF 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 (cowvxwvco) 04.06 VERIFY THAT LICENSEE HAS ADEQUATELY SIZED SAMPLED MOVs.
INFORMATION ON SXZING AND SETTING PROVIDED IN APRIL 30,
04.07 VERIFY THAT LICENSEE HAS DEMQNSTRATED DESIGN-BASIS CAPABILXTY OF SAMPLED MOVs.
INSPECTORS WILL VERIFY IMPLEMENTATION OF LICENSEE ACTXONS IN RESPONSE TO SUPPLEMENT 5 TO GL 89-10 ON MOV DXAGNOSTXC EQUIPMENT ACCURACY.
INSPECTQRS 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 DEMQNSTRATION QF MOV DESXGN-BASIS CAPABXLITY, INCLUDING GROUPXNG.
04.08 VERXFY THAT THE LICENSEE HAS ESTABLISHED A METHOD FOR PERIODIC VERIFICATION.
EDETAILS ON A FOLLOWING SLIDE3
SUPPLEMENTAL INSPECTION GUIDANCE (CONTXNUED) r 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 IS 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 MAINTENANCE COMMITTEE OF THE ASME BOILER AND PRESSURE VESSEL CODE TO DEVELOP ACCEPTABLE METHODS TO VERIFY MOV DESIGN-BASXS CAPABILITY THROUGH PERIODIC TESTING.
PLES OF. ACCEPTED PERIODIC VERIFICATION PLANS FOR GL 89-10 CLOSURE ARE (1)
DYNAMIC DXAGNOSTIC TESTING, OR (2) STATIC DIAGNOSTIC TESTING WITH MARGIN BASED ON PLANT-SPECIFIC DYNAMXC TESTING.
AFTER CLOSURE OF THE STAFF'S REVIEW OF GL 89-10 S
LICENSEES MAY ADJUST THEIR COMMITMENTS TO PROGm ERIFICATION OF MOV DESIGN BASIS CAPABILITY WITH ADEQUATE JUSTIFICATION.
CLOSURE OF NRC STAFF REVIEW OF GENERIC LETTER 89-l0'PROGRAMS t
Thomas G. Scarbrough Mechanical 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 CALLAWAYNUCLEAR POWER PLANT.
OTHER NUCLEAR PLANTS THAT HAVE NOTIFIED THE STAFF OF THE COMPLETION OF THE DESIGN-BASIS CAPABILITY.VERIFICATION PORTION OF THEIR GL 89-10 PROGRAMS INCLUDE:
COMANCHE PEAK 1 and 2 CRYSTAL RIVER FARLEY I and 2 FORT CALHOUN HARRIS HATCH 1 and 2 HOPE CREEK 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 PROGRAIVIS WERE COMPLETE, BUT SUBSEQUENT INSPECTIONS REVEALED THAT ADDITIONALWORK WAS NECESSARY.
THESE LICENSEES ARE SUBMITTINGSCHEDULE EXTENSION JUSTIFICATIONS.
PRINCIPAL LICENSEE ACTIONS FOR CLOSURE OF STAFF REVIEW OF GL 89-10 PROGRAMS lVIOV DESIGN-BASIS CAPABILITY LICENSEE JUSTlFIES DESIGN-BASIS CAPABILITYFOR EACH MOV IN GL 89-10 PROGRAM AND HAS ESTABLISHED A PROCESS FOR OBTAINING FURTHER INFORMATION WHERE NOT SATISFIED WITH JUSTIFICATION FOR CERTAIN MOVs.
PRESSURE LOCKING AND THERMAL BINDING 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 RECOMIVIENDATIONREMAINS APPROPRIATE.
PERIODIC VERIFICATION OF IVIOV DESIGN-BASIS CAPABILITY LICENSEE ESTABLISHES LONG-TERM PLAN FOR PERIODIC VERIFICATIONTHAT DEMONSTRATES THAT DEGRADATION OF DESIGN-BASIS CAPABILITYWILLBE IDENTIFIED.
EXAMPLES QF ACCEPTABLE PERIOD1C VERIFICATION PLANS FOR GL 89-10 CLOSURE ARE ('t) DYNAMIC
DIAGNOSTIC TESTING, OR (2) STATIC DIAGNOSTIC TESTING WITH MARGIN BASED ON PLANT-SPECIFIC DYNAMICTESTING.
LICENSEE ACTIONS (continued)
JUSTIFICATION OF PROGRAIVI ASSUIVIPTIONS 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 STEIVI LUBRICATION DEGRADATION AND SPRINGPACK RELAXATION MOTOR PERFORMANCE FACTORS (I) IVIOTOR RATING (2) EFFICIENCIES USED IN OPEN AND CLOSE DIRECTIONS (3) APPLICATION FACTOR (4) POWER FACTOR USED IN DEGRADED VOLTAGE CALCULATIONS BASIS FOR EXTRAPOLATION METHOD OF PARTIAL D/P THRUST MEASUREMENTS TORQUE SWITCH REPEATABILITY USE OF LIMITORQUE, KALSI, OR OTHER SOURCES FOR INCREASING THRUST AND TORQUE ALLOWABLE LIMITS EQUIPMENT ERROR POST-MAINTENANCE TESTING, ESPECIALLY VALVEPACKING ADJUSTMENTS GROUPING OF MOVs TRENDING OF MOV PROBLEMS.
LICENSEE ACTIONS (continued)
RESOLVE GL 89-'IO 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/REPORTABILITYDETERMINATIONS; (4) FEEDBACK OF TEST RESULTS; AND (5) EVALUATIONOF POTENTIAL FOR PRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
OTHER LICENSEE ACTIVITIES FOUND TO NEED IMPROVEMENT:
(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) INVOLVEMENTOF QA IN VERIFYING TEST DATA AND ANALYSES ACCURACY;
{6) JUSTIFICATION FOR METHOD TO PERIODICALLY VERIFY DESIGN-BAS)S CAPABILITY; (7) CORRECTIVE ACTION IN RESPONSE TO WIOV
PROBLEMS; AND (8) POST-MAINTENANCETESTING FOLLOWING ACTIVITIESTHAT MIGHT AFFECT MOV PERFORMANCE UNDER DYNAMICCONDITIONS.
LICENSEE ACTIONS (continued)
ADDRESS CURRENT IVIOV ISSUES AND CONCERNS LICENSEE RECOGNIZES AND HAS PLAN TO ADDRESS CURRENT MOV ISSUES AND CONCERNS, SUCH AS
+
ACTUALTORQUE OUTPUT OF I IMITORQUE 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 FOLLOWING TESTING IF MOV IS ASSUMED TO BE OPERABLE DURING TESTING.
+
EVALUATIONOF POTENTIAL ADVERSE EFFECTS OF lVIOTOR STALL AND THERMALOVERLOAD TRIP, INCLUDINGSTRUCTURAL AND MOTOR DAMAGE.
+
CHAFING OF WIRES INSIDE LllVIITSWITCH COMPARTMENT CAN CAUSE LOSS OF FUNCTION.
+
GLOBE VALVETHRUST REQUIREMENTS FOR PUMPED FLOW APPARENTLY CONTROLLED BY SEAT OR GUIDE AREAS.
+,INDUSTRY GLOBE VALVEBI OWDOWN TESTING SHOWED S!GNIFICANTLYHIGHER THRUST REQUIREMENTS THAN PREDICTED.
+
INDUSTRY AND NRC-SPONSORED GATE VALVE BLOWDOWN TESTING SHOWED SOME VALVES TO HAVE UNPREDICTABLE BEHAVIOR.
CALLAWAY GL 89-10 PROGRAM GL 89-10 PROGRAM SCOPE:
160 MOVs DYNAMICALLYTESTED:
103 MOVs DESIGN-BASIS CAPABILITYOF MOVs NOT DYNAMICAILY TESTED BASED ON GROUPING WITH OTHER TESTED MOVs AT CALLAWAYAND OTHER SOURCES.
PERIODIC VERIFICATION:
MOVs STATIC DIAGNOSTIC TESTED USING DIAGNOSTICS EVERY 6 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 CRlTERIA.
PRESSURE LOCKING AND THERMAL BlNDING OF GATE
VALVES:
LICENSEE PERFORMED INITIALEVALUATIONOF ALL SAFETY-RELATED MOTOR-OPERATED GATE VALVES.
ADDITIONALEVALVATIONWILLBE NECESSARY.
CALLAWAYGL 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 lVIOV PERFORMANCE DATA.
3.
CONTINUE TO EVALUATEPRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES.
4.
PERFORM PERIODIC MOV PERFORMANCE VERIFICATION BY DYNAMICTESTING GATE AND GLOBE MOVs WHEN MARGIN IS LESS 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 DEGRADATI ON 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 94-05 STATES THAT LICENSEE'S PLAN FOR PERIODIC VERIFICATION INCLUDES DYNAMICTESTING.
PRESSURE LOCKING AND THERMAL BINDING OF GATE VALVES:
LICENSEE EVALUATEDGL 89-'IO MOVs AND FOUND NONE SUSCEPTIBLE TO PRESSURE LOCKING.
ADDITIONALEVALUATIONWILLBE 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 PROGRAM SCOPE:
56 MOVs DYNAMICALLYTESTED:
44 MOVs 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 DYNAMICTESTING TO JUSTIFY AT NEXT REFUELING OUTAGE.
DYNAMICTESTING 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 THERMAL BINDING OF GATE VALVES:
LICENSEE DETERMINED THAT 8 GATE VALVES WERE POTENTIAL SUSCEPTIBLE TO PRESSURE LOCKING AND
EVALUATEDTHEIR CAPABILITYTO OVERCOME THIS CONDITION. STAFF DID NOT REVIEW CALCULATlONS FOR TECHNICAL MER!T. LICENSEE PERFORMED PRELIMINARYEVALUATIONOF THERMALBINDING.
ADDlTIONALEVALUATIONWILLBE NECESSARY.
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?
Liberty 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 in the completion of documentation called "MOV 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 MOVs 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 MOV, 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 MOVs 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.
guestions 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 x Z / (Z.
Where:
V.
V, Z.
Z.
R
+ Z, + R)
Motor terminal voltage Bus voltage Motor impedance at standstill (emphasis added)
Rated voltage / v'3 x locked rotor current Cable impedance Over load heater resistance
questions for MOV Meeting My question concerns the standstill condition noted above.
If we are concerned with an HOV 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 demon'strate standstill motor capability, it should be reasonable and justifiable to demonstrate motor capability at rated star t 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 LMU 88-1).
Similar text is included in Enclosure 1 to Supplement 6,
- however, the specific reference to the example calculation in LMU 88-1 was deleted.
Does this represent a change in the staff position concerni.ng 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 Mr. P. Mcguillan, 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?
questions for HOV Heeting 20.
What is the frequency of repeat dynamic test?
Would static tests suffice?
21.
What is NRC's position regarding removal of valves from the program based on the Saul Levy study?