ML20100F826

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Forwards 180-day Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves
ML20100F826
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 02/13/1996
From: Hutchinson C
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-95-07, GL-95-7, GNRO-96-00011, GNRO-96-11, NUDOCS 9602220188
Download: ML20100F826 (18)


Text

.

" ENTERGY I"' LPM"*" '"*'

o Pori G!bson, M3 39150 '

Td 601437 2800 C. R. Hutchinson vu Prescent amws Gwvj Ce# tiuclear Darm February 13, 1996 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C.

20555 Attention:

Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Generic Letter 95-07, 180 Day Response GNRO-96/00011

. Gentlemen:

Pursuant to Generic Letter 95-07, " Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves", Grand Gulf Nuclear Station is submitting the 180 day required response (attached). The Generic Letter required licensees to provide written response regarding the following specified information:

1.

The susceptibility evaluation of operational configurations and further analyses performed in response to (or consistent with) the requested actions, as well as, the criteria for determining susceptibility to pressure locking or thermal binding; 2.

The results of the susceptibility evaluation and any further analyses including a listing of the susceptible valves identified; 3.

The corrective actions, or other dispositioning, (including schedule) for the valves identified as susceptible to pressure locking or 1'

thermal binding.

Please contact Rita Jackson at (601) 437-2149 if you have questions regarding this submittal.

Yours truly,

/~~

J/rrj attachments:

1.

GGNS GL 95-07 180 Day Response

)

'A 2.

Affirmation j

cc: (See Next Page) k 9602220188 960213 PDR ADOCK 05000416 P

PDR i

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February 13, 1996 GNRO 96/00011 Page 2 of 3 1

cc:

Mr. J. E. Tedrow i(w/a).

Mr. R. B. McGehee. (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. J. W. Yelverton (w/a)

Mr. L., J. Callan (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 washington, D.C.

20555 4

4 J

i I

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February 13, 1996 GNRO-96/00011 Page 3 of 3 l

bcc t -

Mr. D. G. Bost (w/a) l Mr. C. A. Bottomiller (w/a) l Mr.' J. L. Burton (w/a)

Mr. R. W. Byrd (w/a)

L Mr. R. B. Collins (w/a) l

-Mr. L. F. Dale (w/a) l Mr. L. F. Daughtery (w/a) l l'

Mr. J. G. Dewease (w/a)

Mr. M. A. Dietrich (w/a)

Mr. C. M. Dugger (w/a)

Mr. J. B. Edwards (w/a)

Mr. R. T. Errington (w/a)

Mr. C. C. Hayes, Jr. (w/a) l Mr. M. J. Meisner (w/o)

Mr. W. R. McCain (w/a)

Mr. R. V. Moomaw (w/a) l Mr. D. L. Pace (w/a) l Mr. R. L. Patterson (w/a)

Mr. D. E. Smith (w/a)

Mr. R. J. Wright (w/a)

File (LCTS/RPTS) (w/a)

L File (Hard Copy) (w/a)'

File (NS&RA) (w/a)

File (Central) (w/a) ( 20 )

l 1

I

Entergy Operations, Inc.

Grand Gulf Nuclear Station Generic Letter 95-07 180 Day Response Evaluation of Gate Valves For Thermal Binding And Bonnet Overpressurization l

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INTRODUCTION Generic Letter 95-07, Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves, was issued August 17,1995. He NRC staff requested a preliminary evaluation of pressure locking and thermal binding of safety-related power-operated gate valves and, subsequently, a more detailed evaluation and resolution of the issue.

Within 180 days of the date of the generic letter, licensees were to perform the following actions:

1. Evaluate the operational configurations of safety-related power-operated gate valves in its plant to identify valves that are susceptible to pressure locking or thermal binding;
2. Perform further analyses as appropriate, and take needed corrective actions (orjustify longer schedules),

to ensure that the susceptible valves identified in I are capable of performing their intended safety function (s) under all modes of plant operation, including test configuration.

The NRC requested that within 180 days ofissuance of the generic letter each licensee also submit the following infonnation:

1. The susceptibility evaluation of operation configurations and further analyses performed in response to (or consistent with) the requested actions, as well as, the criteria for determining susceptibility to pressure locking or thermal binding.
2. The results of the susceptibility evaluation and any further analyses including a listing of the susceptible valves identified.
3. The corrective actions, or other dispositioning, (including completion schedule) for the valves identified as susceptibic to pressure locking or thermal binding.

SCOPE Prior to Generic Letter 95-07, Grand Gulf Nuclear Station (GGNS) evaluated the installed safety related 4

gate valves using industry information available at that time. As a result of the initial evaluation, eight valves were modified to climinate the potential of pressure locking preventing the valves from opening:

E12F004A, E12F004B, E12F042A, E12F042B, E12F042C, E21F005, E22F004, and E22F015.

i The issuance of Generic Letter 95-07 provided additional guidance, and subsequently an additional review was performed. It was determined that of 82 power-operated candidate valves,18 were within the scope of Generic Letter 95-07 (safety function to open and susceptible to pressure locking). There were no valves

- susceptible to thermal binding. These 18 susceptible valves were evaluated and procedure changes were made for two valves to remove the pressure locking potential susceptibility. The remaining 16 susceptible valves were evaluated using the analytical calculation methodology. Non-conformance documentation was

' initiated for seven valves, it was determined by calculation that the pressure locking phenomena would not

. affect valve operation or result in exceeding any motor, valve or actuator limitation for the remaining nine valves.

page 2 of 14

i The evaluations encompassed all system modes of operation which are within the plant's design basis. The f

evaluations were completed through review of prccedures, system design basis documents, system flow diagrams, surveillance testing and maintenance evolutions. Each valve evaluated was categorized under l

hydraulic locking, boiler effect or thermal binding, as Not Susceptible, Non Priority Susceptible or Priority Susceptible. The difference between Non-Priority and Priority Susceptible is whether the valve has a safety function to open. As stated during the NRC sponsored workshop on Generic Letter 95-07 held at Region IV, valves without an active safety function to open (Non-Priority) are not considered part of the scope of GL 95-07.

TilERMAL BINDING AND BONNET PRESSURIZATION EVALUATION CRITERIA Provided below are the criteria used for screening the valves for thermal binding, hydraulic locking and boiler effect. Attached Figures 1,2, and 3 provide the review logic used when evaluating the 82 candidate valves.

Thermal Hindine Evaluation Criteria (Figure 1)

Piping Thermal Expansion Loads are generally not significant and, in fact, are not discussed as a failure mechanism in SOER 84-7 or AEOD/S92-07. In addition, no documented industry gate valve failures have ever been attributed to this failure mechanism as documented in Information Notice 92-26, SER 20-84, SER 77-83 and SER 8-88. Therefore, review of gate valves for piping thermal expansion loads was not necessary.

Valve Thennal Expansion Loads (Stem Elongation) may create a closing force which can contribute to thermal binding. This closing force will tend to drive the disc more tightly into the seat, and on cooling the Thermal Contraction Load (Body Contraction) effects may be increased. These phenomena were evaluated concurrently using the following dermed criteria.

A.

System Temperature: Valves located in systems with operating temperatures of 200 F or less were exempt from consideration. 200 F was chosen as the dividing point between a hot and cold system, based upon past evaluations of thermal binding for the Limerick Generating Station, the Perry Nuclear Power Plant and the Susqueharma Steam Electric Station. INPO confirmed the acceptability of the 200 F dividing line during the Susquehanna evaluation. The line temperatures that were used during this evaluation are the maximum service condition values specified in line lists supplemented by Process Diagrams and System Flow Diagrams (SFD),

B.

Disc Configuration: The disc configuration of each gate valve was detennined by looking at the appropriate valve drawing.

Double disc type gate valves are not susceptible to thermal binding. The wedging mechanism between the discs collapses as the stem rises allowing the discs to move imvard away from the seats, which permits the discs to be raised regardless of the system temperatures.

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C.

Potential for Movement: Power operated valves that have the power removed from them, or are in some other way disabled or locked in position were not considered for thermal binding since they are not expected to functionally chans positions during plant operation. Keylocked valves, however, were included in the evaluation since it is easy to disengage the keylock and operate the valve. Status of the valve was determined through review of the P&lDs and System Operating Procedures.

D.

Valve Function: Thermal binding occurs when valves are closed hot and allowed to cool before being re-opened. Plant procedures, system design criteria and system operating instructions were reviewed to determine the valve functions and system operating modes. The safety-related gate valves that have a safety function to open were identified. Valves that do not have a safety function to open are not within the scope of GL 95-07 and will not afTect design basis pl.mt safe shutdown if they are bound shut.

Ilvdraulic Locking Evaluation Criteria (Figure 2)

Gate valve hydraulic locking phenomenon was evaluated using the following criteria.

A.

Disc Configuration: As stated in the thermal binding discussion above, the disc configuration of each valve was detennined by review of the valve drawings. Solid-wedge gate valves were exempted from consideration for hydraulic locking, as it is not possible for the faces of a solid wedge to be pushed in opposite directions against both seating surfaces.

B.

Bonnet Relief: Valves _with an open bonnet drain connected to an open piping path, a bonnM relief valve or a hole through either one side of the valve bridge or the valve disc were exempted from consideration for hydraulic locking, as any pressure that leaks into the bonnet area will have an escape path to prevent hydraulic locking. The existence of an open bonnet drain path was confirmed by use of the P&lDs, valve drawings, or plant walkdowns.

C.

Potential for Movement: Power-operated valves that have the power removed, or are in some other way disabled or locked in position were exempted from consideration for pressure locking, since they are not expected to functionally change positions during normal operation.

Keylocked valves were included in the evaluation since it is easy to disengage the keylock and operate the valve. Status of the valve was determined through review of the P&lDs and System Operating Procedures.

D.

Valve Function: Hydraulic locking can occur when a closed flex-wedge or double-disc gate j

valve is required to open and a differential pressure condition exists between higher pressure fluid in the bonnet cavity and lower pressure in the process line. Plant procedures, system design criteria and system operating instructions were reviewed to determine valve functions.

The safety-related gate valves that have a safety function to open were designated on the i

evaluation sheets. Valves that do not have a safety function to open are not in the scope of GL 95-07 and will not affect design basis plant safe shutdown if they are bound shut.

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E.

Line Pressure: If the pressure in the piping upstream or downstream of the valve is greater than

)

or equal to the pressure in the valve bonnet, the line pressure will offset the pressure trapped between the faces of the disc. This will result in a maximum differential pressure across a single face of the valve disc, which for motor-operated valves was analyzed in the existing Generic Letter 8910 maximum expected differential pressure (MEDP) calculations. The upstream and downstream piping pressures at opening were determined using the plant procedures, system hydraulic calculations and the appropriate MEDP calculations.

Holler Effect Evaluation Criteria (Figure 3)

Gate valve bonnet boiler effect phenomenon were evaluated using the following criteria.

A.

Gas Systems: Valves which are part of gas systems were not considered for liquid entrapment (Boiler Effect) if their valve stems are oriented above the horizontal. It is highly unlikely that the valve bonnet would contain liquid in these orientations. Unless the bonnet contains a significant amount ofliquid, it is not possible to build up the high pressures in the bonnet that would arise from heating an incompressible fluid.

B.

Bonnet Relief: Valves with an open bonnet drain connected to an open piping path, a bonnet relief valve or a hole through either one side of the valve bridge or the valve disc were exempted from consideration for boiler effect hydraulic locking, as any pressure that leaks into the bonnet area will have an escape path to prevent hydraulic locking. The existence of an open bonnet drain path was confirmed by use of the P&lDs, valve drawings, or plant walkdowns.

C.

Potential for Movement: Power-operated valves that have the power removed, or are in some other way disabled or locked in position were exempted from consideration for pressure locking, since they are not expected to functionally change positions during normal operation.

Keylocked valves were included in the evaluation since it is easy to disengage the keylock and operate the valve. Status of the valve was determined through review of the P&lDs and System Operating Procedures.

D.

Valve Function: Boiler effect occurs when a fluid-filled or partially filled bonnet is heated. The resulting pressure may inhibit the valve from re-opening. Plant procedures, system design criteria and system operating instructions were reviewed to detennine the valve functions. The i

safety-related gate valves that have a safety function to open are so designated on the evaluation sheets. Valves that do not have a safety function to open are not in the scope of GL 95-07 cad will not affect plant design basis safe shutdown if they are bound shut.

E.

Valve Heat-up: Valves which have water in their bonnets experience the boiler effect phenomenon only when the trapped water is heated. For this criteria to apply, the valve must be in the closed position when the heat source is applied. The potential heat sources that must be considered for this evaluation are as follows.

Normal ambient conditions: Normal ambient conditions,75 F to 95 F, are typically not expected to cause bonnet pressurization since the normal ambient temperature swings are small enough and gradual enough not to cause binding. If binding were to occur, the bound conditions would become apparent during periodic system surveillance testing and the problem valves would be corrected.

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e Accident ambient conditions: Accident ambient conditions potentially impact the fluid if they elevate the area temperature around a closed valve for a significant period of time (several hours) before the valve must open Valves which are required to open within minutes of an accident would not be impacted by the elevated ambient conditions and are so designated on the evaluation sheets.

Accident ambient conditions were determined from Technical Standards and their associated sources.

Fluid Temperatures: If the closed valve is located in a stagnant branch of a hot system, there is the potential that the heat will conduct through the fluid and/or the.

l piping. As the distance from the hot piping increases, the heat lost to the atmosphere increases and the potential for bonnet pressurization decreases. Based on thermal gradient calculations for similar nuclear power plant applications,20 feet was used as the cutoff, beyond which the heat input to the bonnet will be insignificant. This 20 foot distance must be outboard of another closed valve, a vertical drop of piping, or a restricting orifice so as not to create convection currents in the fluid.

Maximum theoretical valve intemal pressure due to " boiler effect" can be determined by the Bulk Modulus of Elasticity equation (Reference Standard llandbook for Mechanical Engineers, Eighth Edition, Page 3-35) or by interpolation of specific volume data from the Steam Tables:

4 Pressurem = 319,000[(Vre,- Vre) + V%)

Where: Vre = Specific Volume of water at the hot temperature as found in the Saturated Steam Table (Temperr.ture).

Vrw = Specific Volume of water at the cold temperature as found in the Saturated Steam Table ('lemperature).

Maintenance Activity Evaluations Maintenance activities that require valve closure for system / component isolation could potentially result in gate valves binding shut; for example, thermal binding following system removal from service and subsequent cool down, or hydraulic locking following hydrostatic testing.

Daring the maintenance activity the system would generally be out of service and normal valve operation is i

not required. liowever, following completion of the maintenance, normal valve operation would be demonstrated prior to returning the system to sersice as a part of the maintenance activity restoration, where a potential exists for gate valve pressure locking or thermal binding. This would be especially true for hydrostatic test boundary valves that have a safety function to open.

page 6 of 14 1

Detailed evaluations for valves that may be used for maintenance boundary valves are not considered justified on a valve by valve basis, since the possibilities are enormous, and were not included in the review.

Additionally, detailed evaluations and justifications are not required for manual valves that are provided only to support system / component maintenance. These valves, when repositioned for maintenance must be restored to their nornul position for system return to service and, if bound shut, would be identified and the condition corrected.

9 GGNS CALCULATIONAL METilODOLOGY A calculational rnethodology (also known as hub calculation) was developed by GGNS based on "first principle" analysis (i.e. forces applied and basic trigonometric evaluation of valve discs / seats) as suggested in NUREG/CR-5807 " improvements in Motor Operated Gate Valve Design and Prediction Models for Nuclear Power Plant Systems". Rese calculations were used to evaluate valve opembility under combination loading of pressure locking and LOCA conditions.

4 On December 28 and 29,1992, Wyle Labs perfomied pressure lock testing on a 14" - 900 # flexible wedge gate valve. The test simulated the accident conditions associated with the LPC1/LPCS Injection Valves (IE12F042A, 1 E12F042B and 1E21F005). One of the goals of the teet was to substantiate the calculational methodology and l

results which were used in the operability resolution of a GGNS material non-conformance report (MNCR). The MNCR stated with accident conditions, required thrust to open the referenced injection valves would be 82,645 lbs., 87,724 lbs., and 76,822 lbs, respectively. The variance in opening thrusts is attributed to the differences in the as-tested static opening thrust values. By utilizing the results of the Wyle test, the GGNS calculation yields 87,297 lbs required to open the test valve vs. 87,000 lbs noted during the test. His value is based on infomation (90,000 lbs closing,55,000 lbs static opening,452/1080/320 psig accident conditions test pressures) prosided in the trip report after witnessing the Wyle test. As evidenced by these results, one could conclude that the mediodology used in detemtining operability of the low pressure injection valves is acceptable and sound. This methodology was presented during a NRC public workshop on February 4,1994 (summarized in NUREG/CP-0146).

To further validate this methodology, Entergy Operation, Inc. sites have reviewed dynamic test data from their GL 89-10 programs. Review of the data suggests that the hub analysis is conservative in its ability to estimate total required thrust for pressure loading conditions. Therefore, the hub analysis was used as the standard methodology to estimate tluust requirements for pressure locked valves. His methodology was the basis for decisions on valve / actuator acceptability, in determining the potential operability of a valve, or the need for modifications.

i EVALUATION RESULTS If a valve was determined to be susceptible to themial binding or pressure locking and was within the scope of Generic Letter 95-07 (open safety func: ion) it was daignated as a PRIORITY valve. The classification of a valve as being susceptible to pressure locking or thermal binding may not necessarily imply a nonconforming condition.

Procedure changes were made during the review that climinated pressure locking susceptibility for two (2) valves.

Four (4) non-conformance documents were initiated for seven (7) PRIORITY valves as a result of the resiew and evaluation. Operability detenninations were made for the non-confonnances as required by plant procedures.

Typically this would consist of a determination if a problem exists, documentation of the problem, determination of operability, and resolution of the problem. It was determined that nine (9) other PRIORITY valves were susceptible, even with procedure changes. However, corrective action documents were not required as the valves would open to perfonn their safety functions when in a pressure locking scenario. Eight valves were modified prior to Generic letter 95-07.

page 7 of 14

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A summary of the results of the review anxi evaluation of the thermal binding / pressure locking susceptible valves is contamed in Table 1. Actions that have been taken are also identifxx! in the Table. De complete review and evaluation for the valves is available in documentation at GGNS.

4 CORRECTIVE ACTIONS / SCHEDULES 4

The 82 evaluated valves and a summary of evaluation results are provided in Table 1.

The following summarizes the corrective actions necessary for the 18 valves identified as PRIORITY valves.

Procedure changes were made during the review that eliminated pressure loclang susceptibility for two (2) of the 18 PRIORITY valves: E12F027A and E12F027B, RHR System Shutoff Valves.

i Four nonconformance documents were initiated for seven (7) of the 18 PRIORITY salves as a result of review e

and evaluation. Le operability of these valves was detemuned in accordance with appropriate plant procedures.

Four of these valves will be nxxiified prior to December 31,1996:

E12F024A - RHR A Test Retum to Suppression Pool E12F024B - RHR B Test Retum to Suppression Pool E51F013 - RCIC Injection Shutoff Valve E5IF031 - RCIC Pump Suction from Suppression Pool ne odx:r three of these seven valves will be modified prior to June 30,1998:

E12F004C - RHR Pump C Suction from Suppression Pool E12F0064A - RilR A Minimum Flow Valve E12F0064B - RHR B Minimum Flow Valve ne importances of GGNS safety related motor operated valves were evaluatal in an Engineering Report. He evaluation methodology utilized in this report was that developed by the BWR Owners Group and documented in BWROG Topical Report NEDC 32264. The GGNS IPE results provided the basis for the evaluation.

j

. Valves E12F064A & B and E12F004C are all ranked low in this evaluation. His indicates that the overall J

contribution to GGNS core damage frequency or large release from these vah es is low and that failure of the valves would not significantly change the outcome of the accidents considered in the IPE.

He remaining nine (9) Priority vahrs have no action planned it was determined by calculation that the pressure locking phenomena would not affect valve operation or result in exceeding any motor, valve or 3

actuator limitation. %ese nine valves are:

E12F028 A and E12F0288 - Containment Spray Valves E12F064C - RHR C Minimum Flow Valve P41F064A - SSW Inlet to Control Room A/C A P4IF064B - SSW Supply to CR A/C and ESF Rm Coolers B P41F081 A - SSW Outlet from Control Room A/C.A P41F081B - SSW Retum from CR A/C B & ESF RM Coolers B j

P4IF237 - SSW Inlet to ESF Room Coolers A P4 IF238 - SSW Outlet from ESF Room Coolers A 1

At the completion of this program, GGNS will have modified 15 valves with a safety related function to open as a result of pressure locking concems. GGNS plans to continue to monitor industry information related to this issue and to rcevaluate its position as tx:cessary.

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THERMAL BINDING REVIEW LOGIC FIGURE 1 Is No REVIEW SYSTEM OPERATING TEMP AND 00*F OR GREATERS VALVE DATA YES u

!s VALVE YES IN POSITI on uAvE PowEm REMOVED 7 NO u

YES Is VALVE THE DOUBLE

?

DISK TYPE?

NO u

NO Is VALVE NO VALVE IS NOT DoEs CLOSED THEN VALVE cLosE wnILE SUSCEPTIBLE NOT N TO C001' m m UP7 TO THERNAL IEvaluate Stess TREN REQUIRED TO BUDDG Elongation) opuut YES YES VALVL IS NOT SUSCEPTIBLE TO THERMAL BINDING PRIORITY VALVE NO NON-PRIORITY VALVE DOES VALVE PERFC SUSCEPTIBLE TO AN AcrIVE SAFETY SUSCEPTIBLE TO THERNAL BINDING ITNCTION TO OPEN' THERHAL BINDING "GL95-07" page 9 of14

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5 HYDRAULIC LOCKING REVIEW LOGIC Figure 2 t

Is vnys REVIEW SYSTEM Tus FLsx wsDos or NO AND DoUzLa D!sK TYPs?

VALVE DATA YES 1r Is vuva 14CKsD IN POSITION YES on uAva Powan a

RzHOVsD?

NO 1r IS VALVE PROVIDED WITH AN YES OPEN BONNET DRAIN?

a NO 1r-1 rs vuva NO U

REQUIR D To oPzH DURIHo A DP CoHDITIoW?

YES 1r VALVE IS NOT IS PIPING SUSCEPTIBLE PRESSURE PRIOR TO YES TO HYDRAULIC OPENING ;!: BONNET LOCKING PRESSURE?

NO 1r PRIORITY VALVE NON-PRIORITY VALVE YES oss vnym Psaronw No SUSCEPTIBLE TO O

AN AcTIvs sArsTY SUSCEPTIBLE TO HYDRAULIC LOCKING CT!oH To CP:N?

HYDRAULIC LOCKING "GL95-07" page 10 of 14

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BOILER EFFECT REVIEW LOGIC Figure 3 I

y,Lyg,[TOFA m srs e YES I

VALVE DATA sYsTEN?

IS NO NO VALVE INSTALLED ABOVE HORIZONTAL If OSITION VE KED I YES POSITION OR HAVE POWER REMOVED 7 NO 1

1r IS ALVE PROVID YES NITH A NORMALLY OPEN BONNET DRAIN?

NO 1r 1r-VALVE IS NOT IS VALVE IN SUSCEPTIBLE CINITY OF A HEAT so NO NHICH COULD HEATUP TO BOILER MCT BONNET FLUID?

YES 1r PRIORITY VALVE NON-PRIORITY VALVE OES VAL SUSCEPTIBLE TO

-YES PERNRN AM ACTIVE NO SUSCEPTIBLE TO BOILER EFFECT SAFETY WNCTION BOILER EFFECT "GL95-07" TO OPEN7 page 11 of 14 l

TABLE 1 HL-Hydraulic Locking BE-Boiler E&ct VAINE TYPE TIIERMAL PRESSURE PRIORITY ACTION TAKEN TO PLANNED NUMilER BINDING IDCKING VALVE ACTION B21F016 MOV X

HL/BE NO N/A NONE B21F019 MOV X

HL/BE NO N/A NONE B21F065A MOV X

HL/BE NO N/A NONE B21F065B MOV X

HL/BE NO N/A NONE B21F098A MOV X

NO N/A NONE B21F098B MOV X

NO N/A NONE B21F098C MOV X

NO N/A NONE B21F098D MOV X

NO N/A NONE B21Fil3 AOV X

NO N/A NONE B21Fil4 AOV X

NO N/A NONE E12F004C MOV HL YES MNCR 95/0270 modify ley 6/98 E12F006A MOV X

HL/BE NO N/A NONE E12F006B MOV X

HL/BE NO N/A NONE E12F008 MOV X

HL/BE NO N/A NONE E12F009 MOV X

HL/BE NO N/A NONE E12F024A MOV BE YES MNCR 95/0286 modify by 12/96 E12F024B MOV BE YES MNCR 95/0286 modify by 12/96 E12F027A MOV HL/BE YES PROCEDURE NONE CHANGE l

E12F027B MOV HIJBE YES PROCEDURE NONE CHANGE E12F028A MOV HL YES None - Acceptable NONE E12F028B MOV HL YES None-Acceptable NONE E12F049 MOV HL NO N/A NONE E12F064A MOV HL/BE YES MNCR 95/0287 modify by 6/98 E12F064B MOV HIJBE YES MNCR 95/0287 modify by 6/98 E12F064C MOV HL YES None - Acceptable NONE E12F094 MOV HL/BE NO N/A NONE E12F096 MOVj HL/BE NO N/A NONE page 12 of 14

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VAINE TYPE TIIERMAL PRESSURE PRIORITY ACTION TAKEN TO PLANNED NUMBER BINDING LOCKING VALVE ACTION E12F394 MOV HUBE NO N/A NONE E22F012 MOV HL NO N/A NONE E51F013 MOV HL YES MNCR 95/0285 modify by 12/96 E51F031 MOV BE YES MNCR 95/0285 modify by 12/96 E51F059 MOV HL NO N/A NONE E51F063 MOV X

BE NO N/A NONE E51F064 MOV X

NO N/A NONE E51F068 MOV X

NO N/A NONE E51F077 MOV X

NO N/A NONE 1

G33F001 MOV X

HL NO N/A NONE

]

G33F004 MOV X

HL NO N/A NONE I

G33F028 MOV HL NO N/A NONE G33F034 MOV HL NO N/A NONE G33F039 MOV X

HL NO N/A NONE j

G33F040 MOV X

HL NO N/A NONE l

G33F053 MOV X

HL NO N/A NONE G33F054 MOV X

HL NO N/A NONE G33F100 MOV X

HL/BE NO N/A NONE G33F101 MOV X

HL NO N/A NONE G33F106 MOV X

H11BE NO N/A NONE G33F250 MOV X

HUBE NO N/A NONE G33F251 MOV X

NO N/A NONE G33F252 MOV BE NO N/A NONE G41F029 MOV HL NO N/A NONE G41F044 MOV HL NO N/A NONE i

PilF075 AOV HL NO N/A NONE P4 t F064A MOV HL YES None - Acceptabic NONE i

P41F064B MOV HL YES None - Acceptable NONE P41FONIA MOV HL YES None-Acceptable NONE P41F081B MOV HL YES None-Acceptable NONE page 13 of14 i

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VAINE TYPE

TIIERMAl, PRESSURE PRIORITY ACTION TAKEN TO PLANNED i

NUMHER HINDING LOCKING VAIXE ACTION P41F155A MOV HL NO N/A NONE P41F155B MOV HL

'NO N/A NONE P41F237 MOV IIL YES None-Acceptable NONE F4iF238 MOV IIL YES None-Acceptable NONE P42F066 MOV HL NO N/A NONE P42F067 MOV HL NO N/A NONE P42F068 MOV HL NO N/A NONE P42FI17 MOV ill NO N/A NONE P45F061 AOV HL NO N/A NONE P45F062 AOV HL NO N/A NONE P45F067 AOV IIL NO N/A NONE P45F068 AOV HL NO N/A NONE I

P45F098 AOV HL NO N/A NONE P45F099 AOV HL NO N/A NONE P45F273 MOV HL NO N/A NONE P45F274 MOV HL NO N/A NONE P60F001 AOV IIL NO N/A NONE P60F003 AOV ill NO N/A NONE P60F004 AOV HL NO N/A NONE P71FI48 AOV HL NO N/A NONE P7IF149 AOV HL NO N/A NONE P7IF150 AOV HL NO N/A NONE P72F121 MOV HL NO N/A NONE P72F122 MOV HL NO N/A NONE P72F123 MOV HL NO N/A NONE l

i page 14 of 14

J+

.+de BEFORE THE UNITED STATES NUCLEAR REGUIATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 l

IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.

1 AFFIRMATION I, C. R. Hutchinson, being duly sworn, state that I am Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi l

Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this 180 Day Response to Generic Letter 95-07; that I signed this application as Vice President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and co ect t t t of my knowledge, infonnation and belief.

e C. R.'Hutchinson STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBCD AND SWORN TO before me, a Notary gublic, in and for the County i

and State above named, this 13 %

day of Td..

.m 1996.

Q (SEAL)

N a b, n It h. Yu n _.

Q Notary Public Q My conmission expires:

ham l.,x n g 199 4

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