ML17177A394

Discusses Review of Util Responses to Generic Ltr 89-10, Suppl 3, Consideration of Results of NRC-Sponsored Tests of Motor-Operated Valves

ML17177A394
Person / Time
Site:	Dresden, Quad Cities, LaSalle
Issue date:	04/16/1992
From:	Barrett R Office of Nuclear Reactor Regulation
To:	Kovach T COMMONWEALTH EDISON CO.
References
GL-89-10, TAC-M77772, TAC-M77773, TAC-M77781, TAC-M77782, TAC-M77794, TAC-M77795, NUDOCS 9205150197
Download: ML17177A394 (8)

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.0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 April lb, 1Y92 Docket Nos. 50-237, 50-249 50-254, 50-265 and 50-373, 50-374

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Mr. Thomas J. Kovach Nuclear Licensing Manager Commonwealth Edison Company-Suite 300 OPUS West III 1400 OPUS Place Downers Grove, Illinois 60515

SUBJECT:

RESPONSE TO GENERIC LETTER 89-10, SUPPLEMENT 3: "CONSIDERATION OF THE RESULTS OF NRC-SPONSORED TESTS OF MOTOR-OPERATED VALVES" (TAC NOS.{'(\\77772,tril7773, fr'.77794,(n77795,ft177781 ANDt7!77782}

Generic Letter (GL} 89-10, Supplement 3 (GL Supplement) was issued to Bo~ling Water Reactor (BWR) licensees on October 25, 1990.

The GL Supplement refocused licensee GL 89-10 activities by placing a number of containment isolation motor-operated valves (MOVs) on a high priority. These containment isolation MOVs are located in the steam supply line for the Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) turbines, the supply line for the Reactor Water Cleanup (RWCU) systems, and isolation condenser lines, as applicable. The staff requested this reprioritization based on receiving the results of NRC sponsored dynamic MOV tests performed by Idaho National Engineering Laboratory (INEL}.

The INEL dynamic testing of typical 6-and 10-inch flex-wedge motor-operated gate valves indicated that several of the historic design assumptions regarding MOV behavior utilized in actuator sizing were not conservative.

This GL Supplement required licensees to provide the NRC staff with:

(a) the criteria applied in determining whether any deficiencies exist in MOVs within the scope of the GL, (b) the identification of any MOVs found to have deficiencies, and (c) a schedule for any necessary corrective action within 120 days from issuance.

The staff has completed its review of the GL Supplement and request for additional information responses that Commonwealth Edison Company (CECo) provided for the Dresden, Quad Cities and LaSalle stations. The results of the staff's review are provided below.

Dresden Units 2 and 3 On December 12, 1990, and March 11 and 21, 1991, CECo submitted a description of its response to Supplement 3 to GL 89-10 for Dresden, Units 2 and 3, for NRC staff review.

From April 15 through May 1, 1991, the NRC staff conducted an inspection of the program being developed at Dresden in response to (l\\I GL 89-10 (Inspection Reports -5~~237/91011 and 50-249/91010).

In a submittal

~rv 1 D NBC FILE CENTER COPY.

Mr. Thomas April 16, 1992 dated September 5, 1991, you responded to staff questions related to the generic letter supplement.

In these submittals you indicated that the Unit 2 Isolation Condenser (IC) MOVs 1301-1 and 1301-2 and RWCU MOV 1201-1; and the Unit 3 IC MOV 1301-2 and RWCU MOV 1201-1 had been determined to be deficient and that modifications were required to these MOVs.

You also considered Unit 2 IC MOV 1301-4; and Unit 3 IC MOVs 1301-1 and 1301-4 to be deficient, but only planned long-term modifications.

Based on our review of CECo's submittals, the NRC staff considers all of the above identified MOVs to need modification to provide confidence that they will be capable of performing their des1gn basis function to isolate containment in the event of a pipe break downstream of these valves. For the other MOVs within the scope of Supplement 3 to GL 89-10, the NRC staff considers it appropriate for CECo to address those MOVs as part of its GL 89-10 program and schedule, unless further information dictates accelerated action.

Quad Cities Units 1 and 2 On December 12, 1990, and March 11, 1991, CECo submitted a description of its response to Supplement 3 to GL 89-10 for Quad Cities, Units 1 and 2, for NRC staff review.

In a submittal dated September 5, 1991, you answered staff questions in response to the GL Supplement.

From December 9 through 19, 1991, the NRC staff conducted an inspection of the program being developed at Quad Cities in response to GL 89-10 (Inspection Reports 50-254/91022 and 50-265/91008).

In these submittals, CECo indicated that the Unit 1 RWCU MOVs 1201-2 and 1201-5; and the Unit 2 RWCU MOVs 1201-2 and 1201-5 had been determined to be deficient and that modifications to those MOVs were required.

Based on our review of CECo's submittals, the NRC staff considers the above identified MOVs to need modification to provide confidence that they will be capable of performing their design basis function to isolate the containment in the event of a pipe break downstream of these valves. With respect to the other MOVs within the scope of Supplement 3 to GL 89-10, the NRC staff considers it appropriate for CECo to address those MOVs as part of its GL 89-10 program and schedule, unless further information dictates accelerated action.

LaSalle Units 1 and 2 On December 12, 1990, and March 11, 1991, CECo submitted a description of its response to Supplement 3 to GL 89-10 for LaSalle, Units 1 and 2, for NRC staff review.

In a submittal dated September 5, 1991, CECo answered staff questions on its response to the GL Supplement.

In these submittals, CECo indicated that the Unit 1 RCIC MOV F063 and RWCU MOV FOOi; and the Unit 2 RCIC MOV F063 and RWCU MOV FOOi had been determined to be deficient and to require modifications.

Based on the information provided, the NRC staff also considers the Unit 1 RCIC MOV F064 and the Unit 2 RCIC MOV F064 to be deficient, although you indicated that those MOVs had been taken out of service. Based on our review of CECo's submittals, the NRC staff considers the above identified MOVs (except those confirmed to be taken out of service) to need modifications to provide confidence that they will be capable of performing their design basis function to isolate the containment in the

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Mr. Thomas April 16, 1992 event of a pipe break downstream of these valves.

With respect to the other MOVs within the scope of Supplement 3 to GL 89-10, the NRC staff considers it appropriate for CECo to address those MOVs as part of its GL 89-10 program and schedule, unless further information dictates accelerated action.

In accordance with GL 89-10, Supplement 3, your September 5, 1991, submittal provided a schedule for modifications to these high priority containment isolation valves based on the outage schedule for all three stations at the time of your letter. The schedules for all the stations are beyond the 18 month schedule requested in Supplement 3 to GL 89-10.

The staff has reviewed these schedules and find them acceptable, contingent upon the condition stated below.

It is requested that the NRC receive written notification of any significant schedule changes {slippages greater than 4 months) and when implementation of the valve modifications is completed for each plant.

Since Dresden and Quad Cities have a number of high priority containment isolation valves that are deficient which will not be modified within the time period requested by GL 89-10, Supplement 3, that are located in piping systems that are susceptible to intergranular stress corrosion cracking {IGSCC}, the staff's acceptance of your proposed schedule is contingent upon CECo's confirming, within 45 days of receipt of this letter, the following information:

All piping systems susceptible to IGSCC that contain MOVs identified by GL 89-10, Supplement 3, either:

(1) have area temperature monitoring capable of detecting a leak, or (2) are visually inspected by physical walk-down at least once per day, or (3) have been, or will be, subjected to a qualified 100% volumetric examination of service sensitive weldments in affected piping locations not suitable to be addressed as described in items (1) or (2) above.

It is the staff's understanding, based on the information contained in your March 11, 1991 response, that LaSalle does not have IGSCC susceptible piping in the RCIC or RWCU systems and, therefore, this requirement is not applicable.

The NRC staff is planning to perform inspections of your GL 89-10 program in the future.

The scope of these inspections will include:

(1) the structural limits of each MOV in light of the increased thrust and torque requirements based on industry experience and research testing, (2) the reduction in thrust delivered by the actuator that may occur as a result of the "rate of loading" phenomenon, (3) the reduction of motor output that may occur as a result of

Mr. Thomas high ambient temperature, (4) the capability of the valves to satisfy any leakage limits associated with the safety analyses when closing under design basis conditions (particularly where the torque switch is set assuming low valve factors, but is bypassed for a significant portion of the valve stroke},

(5) the justification for the assumed stem friction coefficient, (6) the justification fQr the assumed differential pressure under which the MOVs may be called upon t6 operate in light of the intent of GL 89-10, (7) the inaccuracy of Mov* aiagnostic equipment in measuring delivered torque or thr.u.st,

(~) the assumed minimum* voltage available to the motor as compared to your licensing commitments, and (9) the closing stroke time under design basis co'ndi(ions in.re.lat.ion to technic.al specifications or safety analyses (particularly for* de motors).* In addition to your own MOV tests, CECo will be expected to monito~ ftie MOV tests* performed* by other organizations for information on the t6rqu~ and thrust required to operate your valves under design basts ~onditi-0ns.. ~ In~addition, you will be expected to take action to

-. ensure MOY o~erabil i ty, where those: t~sts raise questions regarding the

.**required torque *or* thrust estimates. 'With respect to the review of the NRC-spons.ored *MoY tes'ts by th~ EfectriC. Power Research Institute ( EPRI), the NRC

• s,taff agrees *with the: ev*aluat1on by' the Idaho National Engineering Laboratory

~(INEL) provided in EGG7SSR~~9926 ~November 12, 1991), "Evaluation of EPRI

'Draft'.Repo.rt NP-?926.: Review_.of NRC/INEL Gate Valve Test Program."

OFC NAME DATE During'inspeCtions o('the GL 89-10 program, the NRC staff will confirm CECo's assumptions an'd c.. als;ulations for MOVs within the scope of Supplement_ 3 as well as the other MOVs within the scope ~f GL 89-10.

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If you have ahy:que~tions regarding this issue or letter please contact' the Project Manag~r assighed to the respective plant.

cc:

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Docket File (50-237, NRC & Local PDRs B. Boger R. Barrett B. Siegel OGC 15Bl8 PDIII-2 Gray File(3)

R. Elliott 11-2 Sincerely, Richard J. Barrett, Director Project Directorate 111-2 Division of Reactor Projects 111/IV/V Office of Nuclear Reactor Regulation 50-249, 50-254, 265, 50-373, and 50-374)

PDIII-2 r/f(3)

J. Zwolinski C. Moore(3)

L. 01 sh an ACRS(lO)

P-315 B. Clayton, Riii Pl-22 T. Gody, Jr.

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104/16/92 !R~~r 2

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Mr. Thomas J. Kovach Conunonwealth Edison Company cc:

Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. C. Schroeder Plant Manager Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 U. S. Nuclear Regulatory Conunission Resident Inspectors Office Dresden Station Rural Route #1

'Morris, Illinois 60450 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Regional Administrator Nuclear Regulatory Commission, Region III 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Robert Neumann Office of Public Counsel State of Illinois Center 100 W. Randolph Suite 11-300 Chicago, Illinois 60601 Dresden Nuclear Power Station Unit Nos. 2 and 3

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Mr. Thomas J. Kovach Commonwealth cc:

Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. 0. Box 4350 Davenport, Iowa 52808 Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. Richard Bax Station Manager

~uad Cities Nuclear Power Station 22710 206th Avenue North

~ordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission 22712 206th Avenue North

~ordova, Illinois 61242 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, Illinois 61201 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Robert Neumann Office of Public Counsel State of Illinois Center 100 W. Randolph Suite 11-300 Chicago, Illinois 60601 Quad Cities Nuclear Power Station Unit Nos. 1 and 2

Mr. Thomas J. Kovach Commonwealth Edison Company cc:

Phillip P. Steptoe, Esquire*

Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 West Randolph Street Suite 12 Chicago, Illinois 60601 Resident Inspector/LaSalle, NPS U. S. Nuclear Regulatory Commission Rural Route No. 1 P. 0. Box 224 Marseilles, Illinois 61341 Chairman LaSalle County Board of *Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Attorney General 500 South 2nd Street Springfield,* Illinois 62701 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Robert Neuman Office of Public Counsel State of Illinois Center 100 W. Randolph Suite 11-300 Chicago, Illinois 60601 LaSalle County Station Unit Nos. 1 and 2 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street Chicago, Illinois 60601 Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. G. Diederich LaSalle Station Manager LaSalle County Station Rural Route 1 P. 0. Box 220 Marseilles, Illinois 61341