ML17187A467

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Forwards RAI Re GL-95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, in Addition to NRC Ltr Dtd 960402.Response Required within 30 Days
ML17187A467
Person / Time
Site: Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  
Issue date: 06/05/1996
From: Shiraki C
NRC (Affiliation Not Assigned)
To: Farrar D
COMMONWEALTH EDISON CO.
References
GL-95-07, GL-95-7, TAC-M93434, TAC-M93435, TAC-M93441, TAC-M93442, TAC-M93458, TAC-M93459, TAC-M93477, TAC-M93478, TAC-M93509, TAC-M93510, TAC-M93541, TAC-M93542, NUDOCS 9606130056
Download: ML17187A467 (12)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. D. L. Farrar WASHINGTON, D.C. 20555-0001 June 5, 1996 Manager, Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 500 Downers Grove, IL 60515

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 95-07, "PRESSURE LOCKING AND THERMAL BINDING OF SAFETY-RELATED POWER-OPERATED GATE

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vt1'5l VALVES," ZION STATION, UNITS 1 AND 2 {TAC NOS. M93541 AND M93542)

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QUAD CITIES STATION, UNITS 1 AND 2 (TAC Nos*. M93509 AND M93510)'

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BYRON STATION, UNITS 1 AND 2 {TAC NOS. M93441 AND M93442), AND

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BRAIDWOOD STATION, UNITS 1 AND 2 {TAC NOS. M93434 AND M93435),

Lt-><., lri;:1 DRESDEN STATION, UNITS 2 AND 3 (TAC NOS. M93458 AND M93459), LASALLE.._ " 1 1,1 q COUNTY STATION, UNITS 1 AND 2 {TAC NOS. M93477 AND M93478) > 1 ~

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Dear Mr. Farrar:

On August 17, 1995, the NRC issued Generic Letter (GL) 95-07, "Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," to request that licensees take actions to ensure that safety-related power-operated gate valves that ~re susceptible to pressure locking or thermal binding are capable of performing their safety functions.

The staff is reviewing and evaluating Commonwealth Edison's response to GL 95-07 dated February 13, 1996.

Additional information, as discussed in the enclosure~ is requested for the staff to complete its review. This is in addition to the information requested in the staff's letter dated April 2, 1996. This request supersedes the request for LaSalle County Station dated May 20, 1996.

We request that you respond within 30 days.

The information requested by this letter is within the scope of the overall burden estimated in Generic Letter 95-07, "Pres.sure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," which was a maximum of 1.20204 9606130056 6~838~37

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75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> per response. This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires July 31, 1997.

Sincerely,

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~Clyde Y. Shiraki, Project Manager Project Directorate III-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-295_,50-30i, 50-25.4, 50-2&~ 50-324, '50-454, 50-456,'

50-457, 50~23z_, 50-249! 50-373, 50-374

Enclosure:

RAI cc w/encl:

See next page

D. L. Farrar cc:

Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Document Control Desk-Licensing Commonwealth Edison Company 1400 Opus Place, Suite 400 Downers Grove, Illinois 60515 Mr. William P. Poirier, Director Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355, Bay 236 West Pittsburgh, Pennsylvania 15230 Joseph Gallo Gallo & Ross 1250 Eye St., N.W.

Suite 302 Washington, DC 20005 Howard A. Learner Environmental law and Policy Center of the Midwest 203 North LaSalle Street Suite 1390 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950 CoR1110nwealth Edison Company Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 George L. Edgar Morgan, Lewis and Bochius 1800 M Street, N.W.

Washington, DC 20036 Attorney General 500 South Second Street Springfield, Illinois 62701 EIS Review Coordinator U.S. Environmental Protection Agency 77 W. Jackson Blvd.

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Chicago, Illinois 60604~3590 Convnonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010 Kenneth Graesser, Site Vice President Byron Station Commonwealth Edison Station 4450 N. German Church Road Byron, Illinois 61010 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407 Mr. Ron Stephens Illinois Emergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois 62706 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434

Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935 Site Vice President Dresden Nuclear Power Station 6500 North Dresden Road Morris, Illinois 60450-9765 Stat ion Manager Dresden Nuclear Power Station 6500 North Dresden Road Morris, Illinois 60450-9765 U.S. Nuclear Regulatory Conmission Resident Inspectors Office Dresden Station 6500 North Dresden Road Morris, Illinois 60450-9766 Richard J. Singer Manager - Nuclear MidAmerican Energy Company 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303 Brent E. Gale, Esq.

Vice President - Law and MidAmerican Energy Company Regulatory Affairs One RiverCenter Place 106 East Second Street P.O. Box 4350 Davenport, Iowa 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, Illinois 61201 Chairman Grundy County Board Administration Building 1320 Union Street Morris, Illinois 60450 Mr. L. William Pearce Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 U.S. Nuclear Regulatory Convnission Quad Cities Resident Inspectors Office 22712 206th Avenue North Cordova, Illinois 61242 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 U.S. Nuclear Regulatory Commission Resident Inspectors Office LaSalle Station 2605 N. 21st Road Marseilles, Illinois 61341-9756 Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Chairman Illinois Convnerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 LaSalle Station Manager LaSalle County Station Rural Route 1 P.O. Box 220 Marseilles, Illinois 61341

Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street Chicago, Illinois 60601 Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Mayor of Zion Zion, Illinois 60099 U.S. Nuclear Regulatory Co111nission Zion Resident Inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 Station Manager Zion Nuclear Power Station 101 Shiloh Blvd.

Zion, Illinois 60099-2797 REQUEST FOR ADDITIONAL INFORMATION ZION STATIQN. UNITS 1 AND 2. RESPONSE TO GENERIC LETTER 95-07. "PRESSURE LOCKING AND THERMAL BINDING OF SAFETY-RELATED POWER-OPERATED GATE VALVES" I.

ColllllOnwealth Edison's (ComEd's) submittal discusses the potential susceptibility of valves 1(2)Sl9011A,B, safety injection (SI) Pump Discharge to reactor coolant system (RCS) Hot Leg, to pressure locking under certain conditions, and states that a thrust calculation was performed which shows that the motor operated valves (MOVs) are capable of opening under pressure locking conditions. Please provide this calculation for the staff's review.

In addition, ComEd's submittal states that a design change to install a new motor actuator is being reviewed for inclusion in upcoming refueling outages.

Please provide specific information and calculations, if applicable, regarding the increase actuator thrust capability as compared to the thrust requirement under pressure locked conditions.

2.

Regarding valves 1(2)RCSOOOA,B, Pressurizer Power Operated Relief Valve Block Valves, ComEd's submittal states that in a steam generator tube rupture scenario, the valves will be opened as quickly as possible after event initiation prior to significant cooldown.

Has ComEd determined the postulated RCS pressure at the time the valve would be required to open and completed thrust requirement and actuator capability calculations assuming this pressure? If so, please provide these calculations for the staff's review.

In addition, ComEd's.submittal discusses the potential susceptibility of these valves to thermal binding with respect to low temperature overpressurization protection (LTOP).

Commonwealth Edison's submittal states that these valves are not required to perform a safety function prior to implementing LTOP and that the valves are required to open prior to implementing LTOP.

This wording is somewhat unclear.

Please provide a more detailed explanation of the potential susceptibility of these valves to thermal binding.

ENCLOSURE

REQUEST FOR ADDITIONAL INFORMATION OUAP CITIES STATION. UNITS l AND 2. RESPONSE TO GENERIC LEITER 95-07.

"PRESSURE LQCKJMG AND THERMAL B.INDING OF SAFETY-RELATED POWER-OPERATEl GATE VALVES"

1.

Regarding itlhe potential susceptibility of valves 1(2)-2301-3, HPCI Turbine Steam Supply, to thermal binding, Co111110nwealth Edison's (ComEd's) s11ibmittal states. that these valves are closed hot after stroke testing or high pressure coolant injection (HPCI) flow testing and remain hot prior to an initiation signal. Does ComEd have test data, such as t~erature measurements of the valve body while open and later shut, to verify this assertion? If so, please provide these results for the staff~s review.

2.

In Attacheiflt 1 to GL 95-lla, the staff requested that licensees include consideration of the potertial for gate valves to undergo pressure locking or thermal binding; during surveillance testing. During workshops lll>n GL 95-07 in each Region, the staff stated that if the closing amtfi subsequent pressure locking or thermal binding of a safety related p~r operated gate valve during the performance of a test or surveillan:c*e would defeat the capability of the safety system or train, the approp~~ate technical specifications must be followed unless one of the following actions has been taken within the scope of GL 95-07:

I. Verify it1hat the valve is not susceptible to pressure locking or thermall ;binding while closed,

2.

Demonstrate that the actuator has sufficient capacity to overcome these pfhenomena, or

3.

Make appropriate hardl'are and/or procedural modifications to prevent pressuri.e locking and thermal binding.

The staff stated that nomally open, safety-related power-operated gate valves which are closed for test or surveillance but which must be returned tGll the open posi'Uon should be evaluated within the scope of GL 95-07.

In Section 5.2.2, Valve Functional Review, ComEd's submittal states that i nservi ce test.fog ( IST) stroke time testing or other surveillancies which cycle the valve are not to be included in the review. Thijs appears to le. inconsistent with the recoR111endations of GL 95-07.

Pl ea*se discuss hDVi this specific GL 95-07 concern has been addressed.

3.

Through rew*B:ew of operatfanal experience feedback, the staff is aware of instances u~ which licensees have completed design or procedural modificatimis to preclude pressure locking or thermal binding which may have had alll adverse impact on plant safety due to incomplete or incorrect e'waluation of tft*e potential effects of these modifications.

Please describe evaluatiims and training for plant personnel that have been conducted for each design or procedural modification completed to address pott:ential pressure locking or thermal binding concerns.

ENCLOSURE

REQUEST FOR ADDITIONAL INFORMATION BYRON STATIQN. UNITS 1 AND 2. AND BRAIDWOOD STATION. UNITS I AND 2. RESPONSE TO GENERIC LEITER 95-07. "PRESSURE LOCKING AND THERMAL BINDING OF SAFETY-RELATED POWER-OPERATED GATE VALVES"

1.

Regarding valves 1(2)RH8716A/B, RHR Crosstie Isolation, Co111110nwealth Edison's (ComEd's) submittal states that an operability assessment has been completed for these valves which concludes that the valves remain operable and no operability issue exists. Please provide the operability assessment for the staff's review, including any applicable heat transfer, thrust requirement, and actuator capability calculations which may have been performed as part of the operability assessment.

In addition, the licensee's submittal states that corrective actions will be performed in accordance with the operability assessment.

Please explain the corrective actions planned for these valves.

2.

Regarding the following valves:

1(2)RY8000A/B, Pressurizer PORV Isolation 1(2)Sl8801A/B, Charging Pump to RCS Cold Legs Isolation 1(2)Sl8802A/B, SI Pump to RCS Hot Leg Isolation 1(2)SI8840, RHR to RCS Hot Legs Isolation Convnonwealth Edison's submittal states that an operability assessment has been completed for these valves, which concludes that the valves remain operable and no operability issue exists. Please provide the operability assessment for the staff's review, including any applicable thrust requirement and actuator capability calculations performed as.

part of the operability assessment.

3.

Through review of operational experience feedback, the staff is aware of instances in which licensees have completed design or procedural modifications to preclude pressure locking or thermal binding which may have had an adverse impact on plant safety due to incomplete or incorrect evaluation of the potential effects of these modifications.

Please describe evaluations and training for plant personnel that have been conducted for each design or procedural modification completed to address potential pressure locking or thermal binding concerns.

ENCLOSURE

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REQUEST FOR ADDITIONAL INFORMATION DRESDEN STAJIQN. UNITS 2 AND 3. RESPONSE TO GENERIC LETTER 95-07. "PRESSURE LOCKING ANQ THERMAL BINDING OF SAFETY-RELATED POWER-OPERATED GATE VAL.YES"

1.

Valves 2(3)-2301-36, HPCI Suppression Pool Suction, if flexible-wedge, split-wedge, or double-disk gate valves, may be potentially susceptible to thermally-induced pressure locking caused by heat transfer from the suppression pool during a design basis event.

Has the licensee evaluated the potential heat transfer from the suppression pool during a design basis event, and the associated thrust requirement/actuator capability calculations? If so, please provide these evaluations for the staff's review.

2.

Valves 2(3)-2301-3, HPCI Turbine Steam Admission, if flexible-wedge, split-wedge, or double-disk gate valves, may be potentially susceptible to thermally-induced pressure locking if they exist in a configuration which may trap steam condensate.

In addition, these valves, if fl exi.bl e-wedge, split-wedge, or sol id wedge gate valves, may be potentially susceptible to thermal binding if opened for HPCI testing, shut in a hot condition, allowed to cool, and subsequently required to open at a lower temperature. Please discuss the pressure locking/thermal binding evaluation completed for these valves.

3.

In Attachment I to Gl 95-07, the staff requested that licensees include consideration of the potential for gate valves to undergo pressure locking or thermal binding during surveillance testing. During workshops on Gl 95-07 in each Region, the staff stated that if the closing and subsequent pressure locking or thermal binding of a safety related power operated gate valve during the performance of a test or surveillance would defeat the capability of the safety system or train, the appropriate technical specifications must be followed unless one of the following actions has been taken within the scope of Gl 95-07:

1. Verify that the valve is not susceptible to pressure locking or thermal binding while closed,
2. Demonstrate that the actuator has sufficient capacity to overcome these phenomena, or
3. Make appropriate hardware and/or procedural modifications to prevent pressure locking and thermal binding.

The staff stated that normally open, safety-related power-operated gate valves which are closed for test or surveillance but which must be returned to the open position should be evaluated within the scope of GL 95-07.

Please discuss if all valves which meet this criterion were included in the review, and the way in which potential pressure locking or thermal *binding concerns were addressed.

ENCLOSURE

4.

Through review of operational experience feedback, the staff is a~are of instances in which licensees have completed design or procedural modifications to preclude pressure locking or thermal binding which may have had an adverse impact on plant safety due to incomplete or incorrect evaluation of the potential effects of these modifications.

Please describe evaluations and training for plant personnel that have been conducted for each design or procedural modification completed to address potential pressure locking or thermal binding concerns.

REQUEST FOR ADDITIONAL INFORMATION LASALLE CQUNTY STAJIQN. UNITS 1 AND 2. RESPONSE IO GENERIC LETTER 95-07.

  • PRESSURE LQCKING AND THERMAL BINDING OF SAFETY-RELATED POWER-OPERATEP GATE VALVES*

I.

In Attachment I to GL 95-07, the staff requested that licensees include consideration of the potential for gate valves to undergo pressure locking or thermal binding during surveillance testing. During workshops on GL 95-07 in each Region, the staff stated that if the closing and subsequent pressure locking or thermal binding of a safety related power operated gate valve during the performance of a test or surveillance would defeat the capability of the safety system or train, the appropriate technical specifications must be followed unless one of the following actions has been taken within the scope of GL 95-07:

I. Verify that the valve is not susceptible to pressure locking or thermal binding while closed,

2.

Demonstrate that the actuator has sufficient capacity to overcome these phenomena, or

3.

Make appropriate hardware and/or procedural modifications to prevent pressure locking and thermal binding.

The staff stated that normally open, safety-related power-operated gate valves which are closed for test or surveillance but which must be returned to the open position should be evaluated within the scope of GL 95-07.

Please discuss if all valves which meet this criterion were included in the revi~w, and the way in which potential pressure locking or thermal binding concerns were addressed.

2.

Through review of operational experience feedback, the staff is aware of instances in which licensees have completed design or procedural modifications to preclude pressure locking or thermal binding which may have had an adverse impact on plant safety due to incomplete or incorrect evaluation of the potential effects of these modifications.

Please describe evaluati.ons and training for plant personnel that have been conducted for each design or procedural modification completed to

ENCLOSURE

75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> per response. This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires July 31, 1997.

Sincerely, Original signed by:

Donna M. Skay for Clyde Y. Shiraki, Project Manager Project Directorate 111-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-295, 50-304, 50-254, 50-265, 50-324, 50-454, 50-456, 50-457, 50-237, 50-249, 50-373, 50-374

Enclosure:

RAI cc w/encl:

See next page Distribution:

Docket File PUBLIC PDIIl-2 r/f.

JRoe, JWR EAdensam, EGAl RCapra CMoore CShiraki OGC, 015-Bl8 ACRS, T2-E26 LMiller, Rill HRathbun, 07E23 REaton, 014C7 RAssa GDick JStang DSkay RPulsifer DOCUMENT NAME:

G:\\RAI93542.RAI To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE LA: PDII 1-2 NAME CMOORE DATE

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