ML20057D558
| ML20057D558 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/28/1993 |
| From: | Storz L CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9310040362 | |
| Download: ML20057D558 (4) | |
Text
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I CENTERIOR U
ENERGY
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' 300 Mod: son Avenue Louis F. Sforz Toledo, OH 43652-0001 Wce President-Nuclear 419 249 2300 Davis-Besse
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Docket Number 50-346 License Number NPF-3 Serial Number 2176 September 28, 1993 l
United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 i
Subj ect:
Response to NRC Generic Letter Number 89-10, Supplement 5,
" Inaccuracy of Motor-0perated Valve Diagnostic Equipment" Gentlemen:
I Generic Letter (GL) 89-10, Supplement 5 (Log Number 4013) requested that licensees reexamine the motor-operated valve (MOV): test programs and identify measures taken or planned to account for diagnostic testing equipment uncertainties.
In addition, GL 89-10, Supplement 5 requested that licensees evaluate the schedule necessary to analyze and respond to the subject information. The attachment to this letter i
provides the requested response.
Should you have any questions regarding this matter, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at a
(419) 249-2366.
Very truly yours, vrc~, f' 8 e v-b NKP/dle cc:
J. B. Hopkins, IGC Senior Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board r-,-
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l 9310040362 930928
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CleMand Dectnc illam;nanrg Toledo f dison
4 Docket Number 50-346 License Number NPF-3 Serial Number 2176 Enclosure Page 1 j
i RESPONSE TO GENERIC LETTER 89-10, SUPPLEMENT 5 FOR i
DAVIS-BESSE NUCLEAR PlJEh FTATION l
UNIT NUMBER 1 i
This letter is submitted pursuant to 10 CFR 50.54(f).
Enclosed is Toledo Edison's response to Generic Letter 89-10, Supplement 5 (Serial Number 2176), " Inaccuracy of Motor-Operated Valve Diagnostic Id d By:,
Vice President [-Ju}tlear L. F. Storz
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Sworn and subscribed before me on the 28th day of September, 1993.
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Notary of /the Public
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NOTNI
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Docket Number 50-346
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License Number NPF-3
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Serial Number 2176 Attachment Page 1 TOLEDO EDISON RESPONSE TO GENERIC LETTER 89-10, SUPPLEMENT 5 Item 1: Vithin 90 days of receipt of this letter, all licensees are required to notify the NRC staff of the diagnostic equipment used to confirm the proper size, or to establish settings, for MOVs within the scope of GL 89-10.
Toledo Edison Response:
For Motor-Operated Valves (MOVs) within the scope of Toledo Edison's Generic Letter 89-10 test program, the Valve Operation Test and Evaluation System (VOTES), manufactured by.
Liberty Technologies, is the diagnostic test system used for MOV testing.
In the previous MOV testing program at Davis-Besse, under the guidelines of NRC Bulletin 85-03, the MOVATS system was used for diagnostic testing.
Item 2: Within 90 days of receipt of this letter, licensees are required to report whether they have taken actions or plan to 3
take actions (including schedule and summary of actions taken or planned) to address the information on the accuracy of MOV diagnostic equipment.
Toledo Edison Response:
Toledo Edison initiated Potential Condition Adverse to Quality Report (PCA0R) 92-0405 in response to the 10 CFR Part 21 notification made by Liberty Technologies on October 2, 1992.
The Part 21 notification identified that two new factors can affect the thrust values obtained with VOTES equipment. Those factors involve 1) the possible use of improper stem material constants, and 2) the failure to account for a torque effect when the equipment is calibrated by measuring strain of the threaded portion of valve stem. As a result of PCAOR 92-0405, MOV test data for those valves tested using the V0TES system was reevaluated using the guidance provided by Liberty Technologies.
The reevaluations necessitated retesting of 8 valves that could be susceptible to the above concerns due to their thrust values being above the calculated target thrust range.
Four valves were retested during the eighth refueling outage (Spring 1993) and their switch settings were adjusted to an acceptable value.
For the remaining four valves, TE has determined that although the current thrust settings are above the calculated target thrust range, they are belov the maximum thrust limit for the valves. Therefore, these valves vill perform their intended function and retesting these valves during their next scheduled maintenance activity is acceptable.
In addition, the procedures governing MOV thrust calculations and MOV testing (EN-DP-01082 and DB-ME-09302) have been revised to address VOTES system inaccuracies as described in the 10 CFR Part 21 notification.
Docket Number 50-346 License Number NPP-3 Serial Number 2176 Attachment Page 2 Similarly, PCA0R 91-0381 and PCA0R 92-0104 vere initiated in response to MOVATS system uncertainties as described in
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information received by Toledo Edison on August 23, 1991 and in a 10 CFR Part 21 notification made by ITI-MOVATS on February 28, 1992. As a result, MOV test data for those valves tested with MOVATS, but not yet retested with VOTES (approximately 50 valves), was reevaluated to account for the uncertainties described in the notifications. The reevaluation was accomplished using guidelines provided by ITI-MOVATS and concluded that the affected MOVs remained capable of performing their intended safety functions.
Since MOVATS is no longer used at Davis-Besse to test MOVs, no additional actions (e.g., procedure changes) were required.
All valves within the scope of the Generic Letter 89-10 program vill be tested using the VOTES equipment as part of the program.
Since the evaluations and actions taken in response to the information contained in Generic Letter 89-10, Supplement 5 have been completed, no change to the scheduled completion date for the Generic Letter 89-10 initial test prograiu as a direct result of actions requested in Generic Letter 89-10, supplement 5 is necessary.
However, the actions described above, as well as those taken in response to other issues relating to MOV testing have diverted significant resources from the MOV testing program. As a result, Toledo Edison is currently reevaluating the Generic Letter 89-10 program and testing scope, based on the guidance contained in proposed NRC Generic Letter 89-10, Supplement 6 (58 FR 39243). Toledo Edison vill inform the NRC of any changes to commitments regarding the MOV program shou?
it be necessary and justified using the Generic Letter 89-10, Supplement 6 guidelines.
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