ML20057E764
| ML20057E764 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 10/05/1993 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9310130128 | |
| Download: ML20057E764 (4) | |
Text
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10 CFR 50.54 (f) 10 CFR 2.204(b)
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PHILADELPHIA ELECTRIC COMPANY 1
1 NUCLEAR GROUP HEADQUARTERS j
955-65 CHESTERBROOK BLVD.
October 5, 1993 WAYNE, PA 19087-5691 Docket Nos.
50-277 (215) 640-6000 50-278 t
50-352 50-353 i
License Nos.
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STATION SUPPORT DEPARTMENT DPR-56 NPF-39 i
NPF-85 f
U.
S.
Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3
}
Limerick Generating Station, Units 1 and 2 Response to Generic Letter 89-10, Supplement 5, f
" Inaccuracy of Motor-operated Valve Diagnostic Equipment" l
Dear Sir:
l l'
As an integral part of Philadelphia Electric Company's (PECo's) Generic Letter (GL) 89-10, " Safety-Related Motor Operated Valve Testing and Surveillance 10 CFR 50. 54 ( f) " Program, for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3,- and Limerick Generating Station (LGS), Units 1 and 2, PECo'is relying on motor operated valve (MOV) diagnostic equipment to provide i
information on the thrust required to open or close valves as well as the thrust delivered by the motor actuator.
l The NRC has recently become aware of new information on the accuracy of MOV diagnostic equipment and as-a result raised a generic concern regarding the reliability of the data provided by-the MOV diagnostic equipment..
On the basis -of.
this new information, the NRC issued GL-89-10, Supplement
- 5..
GL 89-10, Supplement 5,
contained two (2)
Reporting Requirements which required' licensees to submit a written-response pursuant to 10 CFR t
- 50. 54 (f) and 10 CFR 2.204(b).
PECo. received GL 89-10, Supplement 5,
on July 7, 1993.
j Restated below are the two (2) Reporting Requirements followed by PECo's response.
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REPORTING REQUIREMENT 1 i
Within 90 days of receipt of this letter, all licensees are f
required to notify the NRC staff of the diagnostic equipment used to confirm the proper size, or establish settings, for MOVs within the scope of GL 89-10.
PECo RESPONSE l
PECo currently uses tne Liberty Technologies Valve Operation l
Test and Evaluation System (VOTES) to establish switch settings for MOVs within the scope of GL 89-10 for both PBAPS, Units 2 and 3, and LGS, Units 1 and 2.
Prior to the use of l
VOTES, PECo used the ITI-MOVATS diagnostic system.
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REPORTING REQUIREMENT 2 l
i Within 90 days of receipt of this letter, licensees are l
required to report whether they have taken actions or plan to l
take actions (including schedule and summary of actions taken
(
or planned) to address the information on the accuracy of MOV i
diagnostic equipment.
l l
PECo RESPONSE
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PECo has taken actions to address the information on the accuracy of MOV diagnostic equipment.
As previously stated, PECo currently uses the Liberty Technologies VOTES MOV j
diagnostic testing equipment. The information contained in the Liberty Technologies October 2,
- 1992, 10 CFR Part 21 notification was evaluated by PECo.
Subsequent to the 10 CFR Part 21 notification, PECo personnel l
participated in a Liberty Technologies seminar and training l
session conducted for the purpose of providing guidance to j
l licensees regarding the information contained in the 10 CFR i
l Part 21 notification.
Upon completion of the seminar, PECo reviewed previous LGS and j
PBAPS VOTES data using the revised Liberty Technologies methodology. That review utilized the VOTES 2.3 software, the revised valve material constants, the revised. effective valve l
stem diameters and motor operator torque correction factors where appropriate.
The results of the above review were analyzed for impact on valve operability and discrepancies were addressed using PECo's corrective action process. No in-operable valves were identified.
In addition to the above review, PECo is currently reviewing all previous PBAPS and-LGS test data for potential extrapolation errors and trace i
anomalies.
Again, the results will be analyzed for impact on l
valve operability and dispositioned as above.
t 1
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GL 89-10, Supplement 5 Responso October 5, 1993 PBAPS, Units 2 and 3 Page 3 LGS, Units 1 and 2 PECo will continue to monitor further evaluations by Liberty Technologies regarding overall VOTES system accuracy and is aware of ongoing best fit straight line and curve fit error, and open force extrapolation evaluations. PECo has contracted Liberty Technologies to provide yearly maintenance and service for the VOTES equipment.
The contract provides updated software and technical information as it becomes available.
As a result of the contract, PECo is currently using Version 2.31 of the VOTES software which automatically applies a torque correction factor.
As stated in the response to Reporting Requirement 1, prior to the use of the VOTES equipment, PECo used the ITI-MOVATS MOV diagnostic system.
After the May 18, 1992, issuance of the Nuclear Management and Resources Council (NUMARC) guidance on the use of ITI-MOVATS diagnostic equipment, PECo retested on a priority basis, the PBAPS and LGS MOVs within the scope of GL 89-10 using the MOVATS data, NUMARC guidance and VOTES equipment.
The re-testing of all high priority MOVs (i.e.,
MOVs with torque switches set below the manufacturer's calculated minimum value), and all medium priority valves (i.e.,
MOVs that were suspect based on diagnostic test results but with torque switches set above the manufacturer's calculated minimum values), at both LGS and PBAPS is considered complete.
Low priority MOVs (i.e.,
MOVs with acceptable evaluated i
diagnostic test results and switch settings) are being l
retested in accordance the PECo's GL 89-10 schedule.
In the event new applicable MOV diagnostic equipment inaccuracy information becomes available, it will be processed similarly to the October 2, 1992, Liberty Technologies 10 CFR Part 21 notification for evaluation and disposition.
If you have any questions concerning this submittal please contact us.
Sincerely, G. A.
Hunger, Director Licensing Section
Attachment:
Affidavit cc:
T. T. Martin, Administrator, Region I, USNRC W.
L.
Schmidt, Senior Resident Inspector, PBAPS N.
S.
Perry, Senior Resident Inspector, LGS 1
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COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CHESTER 1
l i
G.
R. Rainey, being first' duly sworn,-deposes and says:
l That he is.Vice President:of Philadelphia Electric Company; the applicant herein; that he has read the attached' response to i
NRC-Generic Letter 89-10,-Supplement'~5, " Inaccuracy of Motor-Operated Valve Diagnostic. Equipment," and knows-the contents-j thereof; and that the statements and matters set forth therein
~ 'are true and correct'to the-best of his knowledge, information l
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and belief..
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. I A4 ce-President-
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Subscribed and sworn to j
-before me this day.
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