ML17261A903

Provides 6-month Response to Generic Ltr 89-10 Re safety- Related motor-operated Valve (MOV) Testing & Surveillance. Program Will Be Expanded to Include MOVs in safety-related Sys Not Blocked from Inadvertent Operations

ML17261A903
Person / Time
Site:	Ginna
Issue date:	12/28/1989
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson Office of Nuclear Reactor Regulation
References
GL-89-10, IEB-85-003, IEB-85-3, IEB-89-010, IEB-89-10, NUDOCS 9001040147
Download: ML17261A903 (6)

Text

ACCELERATED DI UTION DEMON TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9001040147 DOC.DATE: 89/12/28 NOTARIZED: NO , DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G I 05000244,'R AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Informs Generic NRC of Ltr 89-10.

util plans to address recommendations of '

,j DISTRIBUTION CODE: A064D COPIES RECEIVED:LTR + ENCL SIZE- pl TITLE: Response to Generic Ltr 89-10, "Safety-Related MM)V Testing & Surveill I

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244

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RECIPIENT COPIES RECIPIENT COPIES .A ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-3 LA 1 0 PD1-3 PD .1' 'D JOHNSON,A 1 1 D

INTERNAL: NRR ROSS,T 1 1 'Rg/sB - CMB 9H 1 1 NUDOCS-ABSTRACT 1 1 EG FILE S EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 I

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NOTE TO ALL "RIDS" RECIPIEYIS:

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PI-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISIRIBUTION 'OOM LISIS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 10 ENCL . 9

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G I iZZZiiul ZiiWSI G~ ~ GG ~G GG IIII III IIIIIIIII ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 December 28, 1989 'TELEPHONE AREA CODE Vla 546-2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson Project Directorate I-3 Washington, D.C. 20555

Subject:

Response to Generic Letter 89-10 (6 Month)

Safety-Related MOV Testing and Surveillance R.E. Ginna Nuclear Power Plant Docket No. 50-244 G

Reference:

(1) RG&E letter dated July 8, 1988 from R.E. Smith to C. Stahle, ".IE Bulletin 85-03 Report Summarizing Program'ompletion" (2) NRC letter dated May 23, 1989 from J.P. Durr to R.C.

Mecredy, "Inspection 50-244/89-05" (3) Toledo Edison letter dated April 22, 1987 from Joe Williams to USNRC, "Davis Besse MOV Reliability Improvement Program"

Dear Mr. Johnson:

Generic Letter 89-10 requires each licensee to notify the NRC within 6 months of the date of the letter of any date or recommendation specified in Generic Letter 89-10 that will not be met. The purpose of this correspondence is to inform the NRC of Rochester Gas and Electric Corporation's (RG&E) plans to address the recommendations of Generic Letter 89-10.

RG&E intends to meet the recommendations of Generic Letter 89-10 with a program similar to that submitted to the Staff by Reference 1 and subsequently approved by the Staff by Reference 2. The Program will be expanded to include MOVs in safety-related systems that are not blocked from inadvertent operation from either the control room, motor control center, or the valve itself. The following safety-related systems will be included in the Program:

High Head SI Injection Mode Low Head SI Injection Mode High Head SI Recirculation Mode Low Head SI Recirculation Mode Auxiliary Feedwater Standby Auxiliary Feedwater Containment Spray Component Cooling Water SI and RHR Pump Cooling; Sump Recirculation Cooling Service Water Non-essential Load Isolation 9001040147 391223 PDR ADOCK 05000244 6 PDC

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MOVs in the above systems will be tested at design pressure when practical. The design pressure may be hydrostatically developed.

If full pressure testing cannot be achieved, an explanation of the constraints to full pressure testing will be documented along with a description of the alternate method used to ensure MOV operability. Typically, for such cases, partial pressure testing will be performed and the results conservatively extrapolated to the design basis conditions. Experience in setting MOVs based on simulated design conditions indicates that extrapolation from less-than-design pressure test results can provide conservative and reliable MOV settings when suitable signature analysis diagnostic techniques are employed (Reference 3). This is to be expected because the forces at work to constrain valve stem motion are primarily linear, i.e., friction. Partial pressure testing would be performed as near to design pressure as practical since the accuracy of torque settings based. on testing at less-than-design pressure is improved. as the test pressures approach design pressure. Use of partial pressure testing and extrapolation of test data as an alternate method when design conditions cannot be achieved practically will consider uncertainties on required stem thrust associated with test measurements as well as non-linear influences such as fluid dynamic effects caused by low subcooling of the working fluid relative to the velocity pressure losses through the valve. Another .alternative to testing an MOV at full design pressure may include reviewing existing test data of an identical MOV and applying the test results as appropriate.

In-plant MOV data will be trended periodically upon completion of preventive maintenance and diagnostic testing activities. In addition, if corrective maintenance performed warrants a retest, the results, shall be included in the trending program. Therefore, MOV trends will be examined, as a minimum following regularly scheduled surveillance or more often as dictated by maintenance history. Industry MOV data will be reviewed, as information is received for affects on RGGE's MOV program.

Valve testing will be scheduled based on plant conditions which allow development of the specified differential pressure and isolation of equipment when required. Some valves can be tested during normal plant operation. Others can and must only be tested during shutdown conditions. It is intended to complete the Program within five years from the date of the letter, however, testing of valves that require a shutdown may not be completed until the following Spring Refueling Outage. Our intent is not to extend outages for the sole purpose of performing MOV testing.

doubtful that the state Public Service Commission would deem this It is to be a prudent action. In addition, should prototypical type testing become necessary, our program cannot be completed until appropriate equipment and facilities become available.

becomes necessary, a list of affected valves, if Ifandthisa any, targeted schedule for prototype testing; will be provided as is required.

The Program will demonstrate the operability of selected MOVs.

The Program will not address motorized dampers since these devices are not explicitly described in Generic Letter 89-10.

Very truly yours, Robert C. Mec y General Manager Nuclear Production RWEK070 Enclosure zc: Mr. Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector