ML20078G758

Documents Util Commitments Re Periodic Verification & post-maint Testing for Motor Operated Valves in Scope of GL 89-10

ML20078G758
Person / Time
Site:	Waterford
Issue date:	11/11/1994
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-10, W3F1-94-0174, W3F1-94-174, NUDOCS 9411160167
Download: ML20078G758 (11)

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e Entstgy Operations,Inc.

= ENTERGY ao sem e Kdlona LA 70006 b 504 739 6774 R. F. Burski Dma Mrear CalE*y Va'erbrc 3 W3F1-94-0174 A4.05 PR November 11, 1994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 50-382/94-23 Generic Letter 89-10, " Safety-Related Motor Operated Valve Testing and Surveillance" Gentlemen:

This letter documents Waterford 3 commitments related to periodic l verification and post-maintenance testing for motor operated valves in the l scope of GL 89-10. The commitments are attached as Appendices A and B, respectively. These commitments are the same in text as the commitments proposed by Waterford 3 to the NRC during the inspection. This letter also provides Appendix C which is the post maintenance DP test matrix discussed in the Appendix B commitment. The post maintenance matrix delineates which maintenance activities require post-maintenance differential pressure testing of motor operated valves.

In response to the NRC interest on gate valves, the following information is provided. Waterford 3's periodic verification program for gate valves ensures that a 25% margin above the validated valve factor is maintained to justify periodic static testing. If the valve factor margin cannot be maintained at 25% or above, then periodic differential pressure (DP) l testing or valve / actuator modification is required. The results from the required periodic DP testing will be used to validate the acceptability of the 25% allowance for valve factor degradation. Additionally, one gate I

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i NRC Inspection Report 50-382/94-23 Generic Letter 89-10, " Safety-Related Motor Ooerated Valve Testing and Surveillance" W3F1-94-0174 Page 2 November 11, 1994 valve from liquid service and one gate valve from steam service will be periodically DP tested to validate the methodology. A minimum of two periodic DP tests, at least one refueling outage apart, on each gate valve selected is required to validate the methodology. Periodic static testing l will be performed on all GL 89-10 MOVs, including gate valves, once every 5 years. Also, all GL 89-10 MOVs are stroked at least every 18 months during routine preventative maintenance tasks.

Waterford 3 has a small population of 29 gate valves in the GL 89-10 scope.

As previously discussed with members of the NRC staff, we have determined that DP testing for 9 of the 29 gate valves is either impractical or provides no meaningful data. Twenty (20) gate valves were considered candidates for validation purposes. The selection of 2 out of 20 gate valves is considered an adequate sample size. The EPRI MOV Performance Prediction Program indicates that valve factor degradation is more of a concern on valves that are stroked a significant number of times under differential pressure. Both of the gate valves chosen for periodic DP testing are stroked under DP during quarterly surveillance testing.

Waterford 3 believes the two gate valves chosen will provide meaningful data for validation of our methodology.

Please contact me or Robert J. Murillo (504) 739-6715 should there be any questions regarding this submittal.

Very truly yours,

) ,b .

f.lhM R.F. Burski Director Nuclear Safety RFB/RJM/tmm

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NRC Inspection Report 50-382/94-23 Generic Letter 89-10, " Safety-Related Motor Operated Valve Testing and Surveillance" W3F1-94-0174 Page 3 November 11, 1994 cc: L.J. Callan, NRC Region IV M.F. Runyan, NRC Region IV C. Myers, NRC Region IV i T.F. Westerman R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office l

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1 Appendix A

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4 ADDendiX A Periodic Verification Commitment Attachment to W3F1-94-0174 The proposed Waterford 3 periodic verification program included static testing for periodic verification of globe and butterfly valves without exception and for gate valves provided sufficient margin is available to account for degradation which may not be discerned during static testing.

The periodic verification program requires periodic differential pressure testing of one gate valve from liquid service and one gate valve from steam service to validate the gate valve methodology. Diagnostic testing under static conditions may be an acceptable approach for periodic verification of globe valve capability; however, until further justification is provided through in-plant or industry testing, at least one globe valve will be ,

periodically differential pressure tested in accordance with the generic letter requirements.

There are only 6 butterfly valves in the Waterford 3 GL 89-10 MOV Program, 4 of which are impr acticable to test under near design basis differential pressure conditions. The remaining 2 butterfly valves are proposed to be periodically verified via normal operations. If the percentage of MEDP attainable during normal operations is sufficient, diagnostics will not be required. Otherwise, diagnostic testing under differential pressure conditions will be utilized to periodically demonstrate design basis ,

capability for at least one butterfly valve unless further justification is provided through in-plant or industry testing.

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Appendix 8 1

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1 ADDendix B <

Post-Maintenance Testina Commitment i Attachment to W3F1-94-0174 The Planning'Information Guide Notebook (PIGN)'is'used by maintenance

, planners when preparing work packages. The matrix attached to the PIGN

- delineates the type of post-maintenance. follow-up testing to be performed, .

including which corrective and preventive maintenance work scopes require diagnostic testing. Currently, the matrix does not address the potential need to perform differential pressure testing following maintenance activities. The matrix will be updated to specifically address those maintenance activities which may affect the validated valve factor or other dynamic performance characteristics, thus requiring differential pressure testing. Required post-maintenance testing after. specific maintenance activities, including but not limited to valve internal visual inspections, relapping the seats, and disc replacement, will be addressed in the PIGN.  !

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Appendix C i

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- Anoendix C PIGN POST MAINTENANCE DPTEST MATRIXI Attachment to W3F1-94-0174 RISING & RISING / ROTATING STEM GL 89-10 MOVs2 U DETERENTIAL-; / STATICT

MAINTENANCE ACTIVITO PRESSURES ~ sTEST) yJUSTIFIC TIONL TEST GATE GLOBE GATE GLOBE VALVE BODYc Intemal Inspection No No Yes Yes No adverse affect on dynamic performance characteristics Valve Replacement 4 YES5 YES Yes Yes Re-establish baseline dynamic performance characteristics Guide Rail / Track No N/A Yes N/A Improved disc / guide friction; no Honing, Stoning, etc. significant tolerance changes Guide RailfTrack Machining or YES5 N/A Yes N/A Re-establish gate valve baseline Weld Buildup & Finishing dynamic performance characteristics to Original Dimensions Body / Bonnet Flange No No Yes Yes No affect on dynamic performance Surface Finishing characteristics Body / Bonnet Flange No No Yes Yes No affect on dynamic performance Weld Buildup & Finishing characteristics BONNET Bonnet No No Yes Yes No affect on dynamic performance Disassembly or Replacement characteristics Body / Bonnet Flange No No Yes Yes No affect on dynamic performance Surface Finishing characteristics Body / Bonnet Flange No No Yes Yes No affect on dynamic performance Weld Buildup & Finishing characteristics Bonnet Gasket No No Yes Yes No affect on dynamic performance Replacement characteristics STEM -

Stem Polishing No No Yes Yes No affect on dynamic performance characteristics Stem Replacement 4 No No Yes Yes Stem friction affects discernable during static testing Stem Lubrication No No Note 3 Note 3 Stem friction affects discernable during static testing STEM-TO-DISC CONNECTION ?

Stem to Disc Disassembly No No Yes Yes No adverse affect on dynamic performance characteristics Connection Machining No No Yes Yes No adverse affect on dynamic performance characteristics Connection Weld Repair No No Yes Yes No adverse affect on dynamic performance characteristics

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i Appendix C - 1 PIGN POST 51AINTENANCE DPTEST N1ATRIXI Attachment to W3F1-94-017_4 I

RISING & RISING / ROTATING STES1 GL 89-10 Af0Vs2 i

ADIFFEREhTIAL s :5TATIC s . . _ _ _ _ _ _ . . _ . . . .

MA'INTENANCE"ACTIVITYJ PRESSUREi TEST ,

(JUSTIFICATIONj TEST GATE GLOBE GATE GLOBE 1

gylSC i Dise Removal / Reinstallation No No Yes Yes No adverse affect on dynamic performance characteristics Disc Reorientation YES5 N/A Yes N/A Re-establish gate valve baseline dynamic performance characteristics Dise Replacement4 YES5 No Yes Yes Re-establish gate valve baseline dynamic performance characteristics Guide Rail / Track No N/A Yes N/A Improved disc / guide friction; no Honing, Stoning, etc. significant tolerance changes Guide Rail / Track Machining or YES5 N/A Yes N/A Re-establish gate valve baseline Weld Buildup & Finishing dynamic performance characteristics to Original Dimensions Dise Face No No Yes Yes Improved seating surface friction Stoning, lapping, etc.

Dise Face Machining or YES5 No Yes Yes Re-establish gate valve baseline Weld Repair & Finishing dynamic performance characteristics Disc Edge Machining No N/A Yes N/A Improved valve factor and guide-to-(Beveling. Chamfering, etc.) seat transition SEATE ,

Seat Replacement 4 YES5 No Yes Yes Re-establish gate valve baseline dynamic performance characteristics Seat Stoning, Lapping, etc. No No Yes Yes Improved seating surface friction Seat Machining or Weld Repair YES5 No Yes Yes Re-establish gate valve baseline

& Finishing dynamic performance characteristics

' YOKE =

Yoke Disassembly No No Yes Yes No affect on dynamic performance characteristics Yoke Clamp No No No No No affect on static and dynamic Removal / Replacement performance characteristics Stem Clamp N/A No N/A No No affect on static and dynamic Removal / Replacement performance characteristics Stem Clamp Key N/A No N/A No No affect on static and dynamic (Anchor / Darling) performance characteristics Removal / Replacement Stem Clamp Key (Velan) N/A No N/A Yes Actuator removal required i Removal / Replacement l Bushing Replacement4 N/A No N/A Yes Stem friction affects discernable l (Target Rock) during static testing i ACTUATORY  !

All Maintenance No No Note 3 Note 3 Affects discernable during static l testing i

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. Appendix C PIGN POST MAINTENANCE DPTEST M ATRIXI Attachment to W3F1-94-0174 Page 3 of 3 ROTATING STEM GL 89-10 MOVs l DIFFERENTIAL. 7 STATIC':

MAINTENANCE ACTIVITY - ' PRESSURE J eTEST1 ijUSTIFICATION : i sTESTa VALVEl Internal Inspection No Yes No adverse affect on dynamic performance characteristics Valve Replacement 4 YES Yes Re-establish baseline dynamic performance characteristics Seat (T-ring) Replacement 4 No Yes No adverse affect on dynamic performance characteristics l Disc Replacement 4 No Yes No adverse affect on dynamic performance characteristics Stem Replacement 4 No Yes No adverse affect on dynamic performance characteristics Bushing / Hearing Replacement No Yes No adverse affect on dynamic performance characteristics Shaft Key Replacement No Yes No adverse affect on dynamic performance characteristics Disc to Shaft Connection (Pin) No Yes No adverse affect on dynamic Replacement performance characteristics ACTUATOR / IIBC UNIT:

All Maintenance No Note 3 Affects discernable during static testing NOTES;

1. DP testing for the following MOVs is either impracticable or will provide no meaningful data; therefore, Post-Maintenance DP testing requirements are not applicable.

HAM ll3A,B CAR 201 A,8 MS 120A,B SI331A,B HAM 133 CVC 183 MS 408 SI332A,8 CVC 507 MS 416 SI602A,B

2. The following motor operated gate valves have been selected for periodic DP testing to validate the periodic testing method for all Generic letter 89-10 gate valves. All maintenance performed on these MOVs must be reviewed by the MOV Coordinator for possible affect on the validation process.

MS 401 A and SI 120A or (B)

3. See PIGN Post-Maintenance Static Test Matrix.

4. All part replacements mtat be like-for-like; otherwise, post-maintenance test requirements must be established by the MOV Coordinator and Design Engineering to ensure compliance with Generic letter 89-10.

5. If plant conditions do not permit differential pressure testing, Post-Maintenance DP testing for gate valves _

may be deferred for up to one refuel or 18 months if setpoints, based on either 1) a 0.6 valve factor or, 2) the EPRI gate valve model, can be achieved during post-maintenance static testing. An " Engineering Input" is required for deferring Post-Maintenance DP testing for gate valves.

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