ML20029C842
| ML20029C842 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/27/1994 |
| From: | Frizzle C Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CDF-94-52, GL-89-10, MN-94-40, NUDOCS 9405020001 | |
| Download: ML20029C842 (5) | |
Text
a MaineYankee RYOfp[f[ME.CT RidlTI'5INCCj5 72 Chindes O Fnnte Edmon Dnve Proscent and Augusta, Maine 04336 Chief Ewcutive OfScer (207) 622 4868 April 27, 1994 MN-94-40 CDF-94-52 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:
Document Control Desk Washington, DC 20555
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo dated June 28, 1993: Inaccuracy of Motor-Operated Valve Diagnostic Equipment (Generic Letter 89-10, Supplement 5)
(c) MYAPCo Letter to USNRC dated February 1, 1990 (MN-90-15)
(d) USNRC Letter to MYAPCo dated March 8, 1994 (Generic Letter 89-10, Supplement 6)
(e) MiAPCo Letter to USNRC dated September 27, 1993 (MN-93-88)
Subject:
Generic letter 89-10, Supplement 6, "Information on Schedule and Grouping, and Staff Responses to Additional Public Questions" Gentlemen:
Generic letter 89-10, Supplement 6 (Reference (d)), states that as a minimum, the staff expects all licensees to have their Motor Operated Valves (MOVs) set up with the best available industry data by the original completion date accepted by the staff, whether or not all testing has been completed. If a licensee does not believe that it can meet its current schedular commitment for verifying the capability of MOVs within the scope of GL 89-10, additional information is required to evaluate the licensee's justification for extending the GL 89-10 test program for capability verification and to establish appropriate audit / inspection plans and schedules.
In response to Reference (b), Maine Yankee in Reference (e) stated we would notify the NRC in writing by July 28, 1994 that we have completed the requirements of items a. through h. of the original generic letter. We further stated that two additional refueling outages will be required to finish revising the original test reports, determine any required changes and complete these changes during the outage of the MOV's next scheduled test. The need for additional time was a direct result of the Liberty Technologies Part 21 issued in October 1992.
j Subsequently, Liberty Technologies issued Customer Service Bulletins CSB 031 Addendum and CSB 032 on February 25, 1994, and March 14, 1994, respectively. These CSBs have significant impact on the Maine Yankee MOV program.
Initially, a design basis evaluation was performed to validate continued operability of all MOVs. New work is required to rework all the best-fit-straight-line (BFSL) data to curve fit using the new criteria, revise acceptance criteria accordingly, develop the technical evaluation which documents each valve's capability to meet its design basis, and then conduct any additional testing because the previous BFSL calibrations were not adequate.
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bid lllO liikCC UNITED STATES NUCLEAR REGULATORY COMMISSION MN-94-40 At.tention: Document Control Desk Page 2 l
Maine Yankee, in making our original commitment to complete the Generic letter 89-10 program by June 28, 1994, never envisioned the quantum changes in industry data that would evolve during the course of the three outage program. The original scope i
of work less some dynamic test results and scheduled program revision feedback in switch setting calculations will be completed by June 28, 1994.
However, in order to ensure our valves are set up with the best available industry data, additional time is required.
The additional time required continues to be the same two additional refueling outages we identified in Reference (e).
Consistent with the reporting requirements of Reference (d), the following information is provided:
l NfLC Item (1):
The completion status of the licensee's GL 89-10 program as of the current commitment date.
Maine Yankee Response:
The original three outage testing program is complete. All valves were setup using the best available industry data that existed at the time of valve testing.
All valves were statically tested and, where practical, dynamically tested.
See attached Tables 1 and 2.
The detailed technical evaluation of the test data is not complete due to the continuing and evolutionary development of test data analysis requirements.
NRC ltem (2):
For those MOVs whose capability will not be verified by dynamic testing by the current commitment date:
(a) for each valve: the valve type, size, safety function, design-basis differential pressure and flow, and the available valve factor (or similar capability measure), and a discussion of the relative risk significance of the valves involved; (b) confirmation that the functionality of these MOVs has been established using the best available information; and (c) the schedule for completing both the MOV testing and any needed corrective actions.
liqine Yankee Response:
(a)
See attached Table 2.
(b) All valves have been tested as indicated in the attached tables.
A bounding design basis evaluation of the two recent Liberty Technologies CSBs has established all valves are operable.
(c) Any additional dynamic MOV testing and needed corrective actions will be completed by April 28, 1997.
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-[kkil!HC IU!iCC UNITED STATES NUCLEAR REGULATORY COMMISSION MN-94-40 Attention: Document Control Desk Page 3 We trust that this information is satisfactory.
Please contact us should you have any questions.
Very truly yours, b ^<
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,f Charles D. Frizzle President and Chief Executive Officer CDF/ jag Attachment c:
Mr. Thomas T. Martin Mr. E. H. Trottier Mr. J. T. Yerokun Mr. Clough Toppan Mr. Patrick J. Dostie STATE OF MAINE Then personally appeared before me, Charles D. Frizzle, who being duly sworn did state that he is President and Chief Executive Officer of Maine Yankee Atomic Power Company, that he is duly authorized to execute and file the foregoing response in the name and on behalf of Maine Yankee Atomic Power Company, and that the statements therein are true to the best of his knowledge and belief.
Notary Public ti: Am a :~;r~my Na;;y; IlYCClf 's., a,, _,;., i{ j,7;g L:\\94mn\\9440
TAllLE I DYNAMIC (IN SITU) TEST SUMMAltY MOV #
DESIGN BASIS IN SITU TEST YEAR OF LAST TEST OPENING DP CLOSING DP SYS FLOW OPENING DP CLOSING DP SYS FLOW CH M 1 66 66 560 56 56*
247 1993 CH M 87 67 67 560 56 56*
230 1993 CS N-1 195 195 3700 200*
0 1992 CS-M 2 195 195 3700 200*
0 1992 CS M 91 40 40 4000 41.5*
O 1990 CS M 92 40 40 4000 41.5*
O 1990 HSI-M 11
?600 2600 285 NOTE 4,6
- 2530 336 1993 HSI M 12 2600 2600 285 NOTE 4,6
- 2542 336 1993 HSI-M 21 2600 2600 285 NOIE 4,6
- 2520 350 1993 HSI M-22 2600 2600 285 NOTE 4,6
- 2437 347 1993 HSI-M 31 2600 2600 285 NOTE 4,6
- 2545 331 1993 HSI M 32 2600 2600 285 NOTE 4,6
- 2545 331 1993 HSI-M 41 2600 2600 850 NOTE 4,6
- 2550*
762 1993 HSI-M 42 2600 2600 850 NOTE 4,6
- 2525*
770 1993 HSI M-50 66 213 850 176*
176*
2267 1993 HSI M 51 66 213 850 176*
176*
1870 1993 HSI-M-54 215 215 850 190*
190 740, NOTE 2 1992 HSI M 55 215 215 850 190*
190 740, NOTE 2 1992 LD-M 2 2420 2420 913 2240 2240*, NOTE 6 90 1993 LSI M 40 20 20 10000 25 1.7*
2350 1993 LSI-M 41 20 Zu 10000 2.2*
2200 1993 1
PCC-M 43 105 105 4170 102*
102 5875 1990 616 98.9 98.9*
6290 1992 I
PCC-M 90 105 105 g
PCC-M 150 105 105 616 104 104*
3600 1993 PCC-M-219 104 104 2100 94.8 94.8*
6700 1992 PR M-16 2410 2410 2632 2248 2248*
NOTE 3 1981 PR M-17 2410 2410 2632 2248 2248*
NOTE 3 1981 RC M 15 2511 2511 50 2560*
2560 75-100 1990 RC M-25 2511 2511 50 2550*
2550 75-100 1990' RC M 35 2511 2511 50 2499*
2499 75 100 1992 SCC-M-165 105 105 4170 102*
102
>6000 1990 SIA-M 53 213 213 1400 190+, NOTE 1 190+, NOTE 1
- 350 1992 SIA M 54 213 213 1400 190+, NOTE 1 190+, NOTE 1
- 350 1992
- = Required stroke direction for safety function DP in PSID; Flow in GPM NOTES 1 -
Similar line up as HSI-M-54/55, except min. flow line closed to produce pump dead head - gauge oscillation precluded obtaining a pressure reading.
NOTES 2 HSI M-54 and HSI M 55 also were stroked during CP test of HSI-M-50 and HSI M 51. Therefore, they have performed satisfactorily at flows greater than their design basis, NOTES 3 Full flow test at 2248 psig. Refer to Tech. Eval. 428 91.
NOTES 4 -
These valves are tested near design basis every cycle.
NOTES 5 -
Five pound downstream pressure assumed (possible O to 8) for HSI M-11,12,21,22,31.
NOTES 6 -
System energy aids in required valve stroke direction L:\\94mn\\9440
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a TABLE 2 VALVES NOT DYNAMICALLY TESTED MOV VALVE VALVE SIZE SAFETY dp FLOW AVAILABLE MFG TYPE FUNCTION VALVE FACTOR CONTINUOUS /
ONE TIME CS M-66 ANCII. DAR GATE 8"
OPEN-m>
15 PSID 1000 GPM 1.6/3.2 CS-M-71 ANCII. DAR GATE 8"
OPEN m.
15 PSID 1000 GPM 1.6/3.2 MS-M-255 ANCll. DAR GLOBE 4"
OPEN m.
940 PSID 6867 GPM 00 PR-M-89 CONVAL Y GLOBE 1"
OPEN-ma 2200 PSID 53 GPM cc PR-M-90 CONVAL.
Y GLOBE 1"
OPEN.mu 2200 PSID 53 GPM co RC-M-54 CONVAL Y GLOBE 1"
OPEN.mu 2200 PSID 42 GPM oo RC-M-56 CONVAL Y GLOBE 1"
OPEN.ma 2200 PSID 42 GPM 00 SL-M 29 VELAN Y GLOBE 1.5" CLOSE 2585 PSID 300 GPM 1.79/2 SL-M-40 VELAN Y GLOBE 1.5" CLOSE 2585 PSID 300 GPM 1.79/2 SL-M-51 VELAN Y GLOBE i.5" CLOSE 2585 PSID 300 GPM 1.79/2 NOTE 1:
Maine Yankee recognized that with valves such as these, the flow assists the MOV with its safety function and thus diagnostic testing is not necessary.
The NRC confirmed this in Supplement 6, Enclosure 1, Page 3 by saying "In response to a specific question, if a MOV is pulled closed by flow (such as a globe valve with flow over the scat), the Licensee could justify that the MOV does not need to be included in the GL 89-10 test program for the closing direction."
NOTE 2:
In situ static testing for these valves was assessed to be unnecessary based on installed capability (' including degraded voltage), maintenance testing, and periodic static tests that envelope all other test situations (other than degraded voltage).
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