ML18040A366

Informs That Entire Attachment to Ltr NMP2L 1862 Dtd 990421, Should Be Replaced with Entire Attachment Being Sent with Present Ltr

ML18040A366
Person / Time
Site:	Nine Mile Point
Issue date:	06/04/1999
From:	Abbasi A NIAGARA MOHAWK POWER CORP.
To:	Mcknight J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9906140123
Download: ML18040A366 (15)

Text

I CArZaoaZ REGULAT Y INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9906140123 DOC.DATE: 99/06/04 NOTARIZED: NO FACIL:50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha 05000410 DOCKET I AUTH. NAME AUTHOR AFFILIATION ABBASI,A.

RECIP.NAME Niagara Mohawk Power. Corp.

RECIPIENT AFFILIATION dimly MCRMTGRT,J. Records Management Branch (Document Control Desk)

SUBJECT:

Informs that entire attachment to ltr NMP2L 1862 dtd 990421, should be replaced with entire attachment being sent with C present ltr. i A

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES'TTR RECIPIENT COPIES ID CODE/NAME ENCL ID CODE/NAME LTTR ENCL LPD1-1 LA 1 l 1 LPD1-1 PD "1 1 0 HOOD,D 1 1 INTERNAL: ACRS 1 ~ENTER 1 1 NRR/DE/EEIB 1 1 NRR/DE/EMCB 1 1 NRR/DE/EMEB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NRR/SPSB JUNG,I 1 1 NUDOCS-ABSTRACT 1 1 OGC/RP 1 0 EXTERNAL: NOAC NRC PDR 1 .1 D

'E h 'l NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.'TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 14

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Your November 21, 1996, submittal states that the RCIC-steam-exhaust-to-suppression-pool valve, 2ICS~MOV122, is susceptible to thermal binding. It also states that no corrective action is required because the valve would be declared inoperable and a Technical Speci/cation (TS) action statement would be entered. Please clarify when the valve would be declared inoperable (i.e., the instant the valve closed or when the valve failed to open?).

The relationship of this valve to Reactor Core Isolation Cooling (RCIC) System operability and Technical Specification actions needs to be clarified. During surveillance testing, or any other situation that would require this yalve to be closed, prior to closing the valve the RCIC system is declared inoperable due to the function of this valve as a turbine exhaust pathway.

Once the RCIC System is declared inoperable, the plant is in a 14 day action statement. At the end of this action statement, if the valve is not reopened, a plant shutdown is required.

Therefore, the situation under which the valve is subject to thermal binding (i.e., closed) is the same situation which requires entry into the shutdown action statement due to RCIC System Technical Specification requirements.

You performed calculations for numerous valves to demonstrate that they could operate without pressure locking. If additional calculations have been performed that change the November 21, 1996 results regarding the valves listed below, then provide those calculations.

You evaluated the following valves as having adequate actuator capacity to overcome pressure locking scenarios at the specific point of operation during an accident; therefore, you plan no modjiication for pressure locking mitigation:

2CSH*MOV101 High Pressure Core Spray (HPCS) Pump Suction Isolation 2CSL*MOV107 Low Pressure Core Spray (LPCS) Pump Minimum Flow Bypass Isolation 2ICS*MOV121 Reactor Core Isolation Cooling (RCIC) Steam Supply Outboard Isolation 2ICS*MOVI22 RCIC Steam Exhaust to Suppression Pool 2ICS*MOV129 RCIC Pump Suction Isolation 2ICS*MOV128- RCIC Steam Supply Inboard Isolation

...9906140123

2RHS*MOV4A/B/C Residual Heat Removal (RHR) Loop Pump Minimum Flow Isolation 2RHS*MOV115 Service Water (SW)/RHR Containment Flooding Cross Tie 2RHS*MOVI16 SW/RHR Containment Flooding Cross Tie Isolation 2SWP~MOV1 7A/B SW to Spent Fuel Cooling (SFC) Heat Exchanger Isolation 2SWP~MOVI8A/B SFC Heat Exchanger Isolation 'WPom 2SWP*MOV2IA/B SW Spent Fuel Pool Makeup Isolation 2SWP*MOV66A/B SW Return Isolation From Diesel Generator (DG) Cooler 2SWP*MOV67A/B SW to Control Room Chiller Isolation 2SWP*MOV94A/B SW Return From HPCS DG Cooler Isolation Regarding the methodology used for these calculations, discuss:

2.1 Minimum margins that should be applied between calculated pressure-locking thrust and actuator capability, 2.2 Any diagnostic equipment accuracy requirements, and 2.3 Methodology limitations.

2.4 Is this methodology used forflexible and/or double disk gate valves?

2.5 How did you validate this methodology?

In November 21, 1996, Niagara Mohawk Power Corporation (NMPC) indicated that twenty three (23) valves have adequate actuator capacity to overcome the applicable pressure locking scenarios. This was based on the methodology used by NMPC at that time. NMPC has re-evaluated (see Enclosure 1 for a revised calculation and Enclosure 2 for the calculation disposition) these 23 valves as described below:

I (1) Eight (8) valves meet the Commonwealth Edison methodology plus an additional 20% margin.

(2) One (1) valve has already been modified to meet the Commonwealth Edison methodology plus an additional 20% margin.

(3) Three (3) valves meet the Commonwealth Edison inethodology, but not the additional 20% margin and will be modified. However, the methodology used to determine the pressure increase in the bonnet is very conservative. Iffurther evaluation of the valve(s) confirm(s) that modification(s) is (are) not required, NMPC will notify the Staff.

(4) Six (6) valves do not meet the Commonwealth Edison methodology and will be modified. However, the methodology used to determine the pressure increase in the bonnet is very conservative. If further evaluation of the valve(s) confirm(s) that modification(s) is (are) not required, NMPC will notify the

0 (5) Five (5) valves have been further evaluated and have been determined not to be subjected to pressure locking or thermal binding at the time when they are required to operate to fulfilltheir safety function. Therefore, no modification is required.

These five categories of the 23 flexible wedge gate valves are discussed in greater detail below.

2ICS*MOV122, 2ICS*MOV128, 2SWP*MOV17A/B, 2SWP*MOV18A/B, 2SWP¹MOV94A and 2SWP¹MOV67A These valves have a positive open thrust margin using the Commonwealth Edison methodology plus an additional 20% margin.

2SWP*MOV67B This valve's normal position is either open or closed and was modified during RFO6 providing sufficient opening thrust margin to satisfy the Commonwealth Edison methodology plus an additional 20% margin.

2SWP¹MOV66A/B These are normally closed valves with an active safety related function to open and permit service water return flow from the respective Emergency Diesel Generator.

These valves are capable of opening against the temperature induced pressure locking force using the Commonwealth Edison methodology, but not sufficient to account for the additional 20% margin. These valves will be modified prior to the end of Refueling Outage 7 (RFO7) to if provide additional margin. However, further evaluation of the valve(s) confirm(s) that a modification(s) is (are) not required, NMPC will notify the Staff.

2SWP¹MOV94B This is a normally closed valve with an active safety related function to open, allowing service water return flow from the respective Emergency Diesel Generator.

This valve is capable of opening against the temperature induced pressure locking force using the Commonwealth Edison methodology, but not sufficient to account for the additional 20%

margin. 'i his valve will be modified prior to the end of RFO7 to provide additional margin.

However, if further evaluation of the valve confirms that a modification is not required, NMPC will notify the Staff.

2CSL¹MOV107 This is the Low Pressure Core Spray (LPCS) pump minimum flow valve. It is a normally open valve which is required to close for maximizing injection fiow after pump flow is established greater than the required minimum flow. The valve will be modified prior to the end of RFO7 to meet the Commonwealth Edison methodology plus an additional 20%

margin. However, if further evaluation of the valve confirms that a modification is not required, NMPC will notify the Staff.

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2RHS*MOV4A/B/C These are the minimum flow valves for the three Residual Heat Removal (RHR) pumps. They are normally open valves which remain open during pump start and must close to maximize injection flow into the reactor. After closure, these valves may have to reopen for other system functions. These valves will be modified prior to the end of RFO7 to meet the Commonwealth Edison methodology plus an additional 20% margin.

However, if furtherevaluationof thevalve(s) confirm(s) thatamodification(s) is(are) not required, NMPC will notify the Staff.

2RHS*MOV115 and 2RHS*MOV116 These valves are positioned in series and are n'ormally closed. They open to provide an RHR intertie with Service Water in case containment flooding is required. These valves will be modified prior to the end of RFO7 to meet the Commonwealth Edison methodology plus an additional 20% margin.'owever, if further evaluation of the valve(s) confirm(s) that modification(s) is (are) not required, NMPC will notify the Staff.,

2ICS*MOV121 This is the RCIC outboard containment isolation valve. This is a normally open valve with an active safety related function to close upon an isolation signal (RCIC line break). Once closed, there is no design basis requirement that the valve be re-opened. No valve modification is required.

I 2ICS*MOV129 This is the RCIC suction valve from the Condensate Storage Tank (CST). It is a normally open valve with an active safety related function to close for transferring suction from the CST to the suppression pool. Once the valve is closed and the suction transfer is accomplished, there is no design basis requirement that the valve be re-opened. No valve modification is required.

2SWWMOV21A/B These are normally closed valves with an active safety related function to open and provide Service Water makeup to the spent fuel pool. The ambient temperature at the location of these valves will be sufficiently reduced such that the pressure locking conditions no longer exist when the valves are required to function. No valve modification is required.

2CSH*MOV101 This is the High Pressure Core Spray (HPCS) suction valve from the CST Tank. It is a valve which is normally open with an active safety related function to close for transferring HPCS pump suction from the CST to the suppression pool. Once the valve is closed and the suction transfer is accomplished, there is no design basis requirement that the valve be re-opened. No valve modification is required.

Any diagnostic equipment accuracy requirements The random measurement uncertainty for the static unseating thrust is assumed to be no more than +/-15%.

Methodology limitations.

The Commonwealth Edison pressure locking methodology is valid for all flexible'edge gate

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valves.

The methodology was used on flexible gate valves. There are no double disk gates subject to pressure locking conditions.

How did you validate this methodology?

NMPC used the NRC endorsed Commonwealth Edison methodology including a 20% margin.