ML20005E452

Provides Itemized Response to Recommendations Outlined in Generic Ltr 89-10

ML20005E452
Person / Time
Site:	Yankee Rowe
Issue date:	12/27/1989
From:	Devincentis J YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYR-89-185, GL-89-10, NUDOCS 9001050259
Download: ML20005E452 (7)

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December 27, 1989-BYR 89-185 United-States ~ Nuclear Regulatory Commission Attn:- Document Control. Desk' Washington, DC 20555.

References:

l (a). License No. DPR-3 (Docket No. 50-29)

(b)' USNRC Letter.to Yankee,. Generic Letter No. 89-10, dated June,28, 1989

Subject:

Response to Generic Letter 89-10

Dear Sir:

The'NRC,'in Reference (b), requested that Yankee advise the NRC of its intentions on meeting the schedule and recommendations outlined in the Generic Letter. This information is included in the attached Yankee response to-the

, Generic Letter.

We trust this information is satisfactory; however, if you have any questions, please contact us.

Very truly yours, 4

. YANKEE ATO IC ELECTRIC COMPANY t H./

b J. DeVincentis

'i Vice President

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'Then' personally appeared before me, J. DeVincentis, who, being duly sworn, did state that he is a Vice President of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing document p

in the name and on the behalf of Yankee Atomic Electric Company and that the l(,k statements therein are true to the best of his knowledge and belief, 7

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Generic Letter 89-10 I

' Itemized Response to Recommended Actions

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Generic Letter Item A

-Review and document the. design basis for the operation'of each MOV. This documentation should include the maximum Differential Pressure (DP) expected'

'during both the opening and closing of the MOV for both normal operations and j

. abnormal events, to the e:: tent that these MOV operations and events are included in the existing approved design basis.

..n Yankee Response to Item A The design basis for the operation of each safety-related and.

position-changeable MOV will'be reviewed and documented. The-documentation

-will include the maximum differential' pressure expected during both opening and closing of the MOV for both normal operation and abnormal events, to the extent that ther dOV operations and events are included in an existing approved design basis.

v Generic Letter Item B Using the results from Item A, establish the correct switch settings. This should include establishing a program to review and reviso, as necessary, the methods for selecting and setting all switches (i.e., torque, torque bypass, position-limit, overload) for each valve operation (opening and closing).

One purpose of this letter is to ensure that a program exists for selecting and setting valve operator switches to ensure high reliability of safety-related:

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'MOVs.

Yankee Response to Item B The MOV Program being implemented at YNPS will establish and maintain the correct switch settings for each safety-related and position-changeable MOV.

The program will include the review and revision, as necessary, of the methods for selecting and setting all switches.

Generic Letter Item C Individual MOV switch settings should be changed, as appropriate, to those established in response to Item B.

Whether the switch settings are changed or not, the MOV should be demonstrated to be operable by testing it at the design basis DP and/or flow determined in response to Item A.

Testing MOVs at design basis conditions is not recommended where such testing is precluded by the existing plant configuration. An explanation should be documented for any cases where testing with the design basis DP or flow cannot. practicably be performed. This explanation should include a description of the alternatives to design basis DP testing or flow testing that will be used to verify the correct settings.

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ATTACHMENT A (Continued)'

Generic Letter 89-10 Itemized Response to Recommended Actions Notes. This letter'is not intended to establish a recommendation for valve testing for the condition simulating a break in the line containing the MOV.

-However, a break in'the line should be considered in the analyses described in Items A, B, and C if MOV operation is relied on in the design basis.

Each MOV should be stroke tested, to verify that the MOV is operable at no-pressure orLno-flow' conditions,even if testing with DP.or flow cannot be performed.

Yankee Response to Item C Yankee'will plan on performing full DP testing for setting torque switches.

If performing this. test will violate the plant's Technical Specifications, or' is precluded by existing' plant' conditions, or design basis conditions cannot be achieved, Yankee will utilize the alternative approach described below in l

responseLto Item F.

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Generic Letter Item D Prepare or revise procedures to ensure that correct awitch settings are determined and maintained throughout the life of the plant. These procedures should include provisions to monitor MOV performance to ensure-the switch settings are-correct.- This is particularly important if the torque or torque bypass switch setting has'been significantly raised above that required.

It may become necessary to adjust MOV switch settings because of the effects of wear or aging. Therefore, it is insufficient to merely verify that the switch' settings are unchanged from previously established values.

The switch settings should be verified in accordance with the program schedule (see Item J).

The ASME Code Section XI stroke-timing test required by 10CFR, Part 50, is not oriented toward verification of switch settings.

Therefore, additional neasures should be taken to adequately verify that the switch settings ensure MOV operability. The switch settings need not be verified each time the ASME Code stroke-timing test is performed.

Yankee Response to Item D Yankee will revise procedures to ensure that correct switch settings are determined and maintained. M0V switch settings will be adjusted to compensate for the effects of wear or aging as identified by the surveillance method required in Item J.

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ATTACHMENT A' (Continued)

Generic Letter 89-10 Itemized Response to Recommended Actions Generic Letter Item E

.Regarding Item A. no change to the existing plant design basis is intended and none should be inferred. The design basis review should not be restricted to a determination of estimated maximum design basis DP, but should include an examination of the pertinent design and installation criteria that were used in choosing the particular MOV. For example, the. review should include the i

effects on MOV performance of design basis degraded voltage,-including the i

capability of the M0V's power supply and cables to provide the high initial-current needed for the operation of the MOV.

Yankee Response to-Item E The design basis review of Item A will include a review of the original design specification, and, as necessary, a degraded voltage evaluation will be i

included. Also, Yankee will evaluate the power supply and cables for adequate sizing for the high initial current developed by the MOV.

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Generic Letter Item F Documentation of explanations and the description of actual test methods used L

for accomplishing Item C should be. retained as part of the required records for the MOV.

.i It is also recognized that it may be impracticable to perform in situ MOV testing at design basis degraded voltage conditions.

However, the switch settings established in response to Item B should at least be established to

account for the situation where the valves may be called on to operate at design basis DP or. flow, and under degraded voltage conditions.

If the licensee failed to consider degraded voltage, power supply, or cable adequacy for MOVs in systems covered by Bulletin 85-03, the design review and established switch settings for those MOVs should be re-evaluated.

1 Alternatives to testing a particular MOV in situ at design basis pressure or flow, where such testing cannot practicably be performed, could include a comparison with appropriate design basis test results on other MOVs, either in situ or prototype.

If such test information is not available, analytical methods and extrapolations to design basis conditions, based on the best data available, may be used until test data at des 1 n basis conditions become 5

available to verify operability of the MOV.

If this two-stage approach is followed. It should be accomplished within the schedule outlined in Item I, and would allow for MOV testing and surveillance to proceed without excessive delay. 0678v

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' ATTACHMENT A (Continued) t Generic Letter 89-10 Itemized Response to Recommended Actions

Testing of MOVs at design basis conditions need not be repeated unless the MOV is replaced, modified, or. overhauled to the extent that the-licensee considers Lthat the existing test results are not representative of the MOV in its modified configuration.

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Yankee Response to'I't'em F