ML20117J473
| ML20117J473 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/03/1996 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, TAC-M75643, TAC-M75644, NUDOCS 9609100346 | |
| Download: ML20117J473 (28) | |
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Cs ARLEs II. CnosE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 September 3,1996 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Final Response to NRC Generic Letter 89-10; Safety-Related Motor-Operated Valve Testing and Surveillance (TAC Nos. M75643: M75644)
REFERENCES:
(a)
Letter from Mr. J. G. Partlow (NRC) to Mr. G. C. Creel (BGE), dated June 28,1989, Safety-Related Motor-Operated Valve Testing and Surveillance (Generic Letter No. 89-10)- 10 CFR 50.54(f)
(b)
Letter from Mr. G. C. Creel (BGE) to NRC Document Control Desk, dated December 28, 1989, NRC Generic Letter No. 89-10; Safety-Related Motor-Operated Valve Testing and Surveillance The purpose of this letter is to forward our final response to Nuclear Regulatory Commission Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance (Reference a). The generic letter identified concerns with motor-operated valve (MOV) performance, including weaknesses in MOV sizing, maintenance and testing methods. Reference (b), our initial response to the generic letter, notified the NRC of our schedule to meet its recommendations.
In response to these concerns and the recommended actions in the generic letter, Baltimore Gas and Electric Company begaa an extensive effort to review the performance requirements of our MOVs.
Significant improvements have been implemented at Calvert Cliffs in the way MOVs are sized, maintained and tested. Our increased understanding of MOV capability and performance issues has been reflected in revisions to, and creation of, engineering and maintenance procedures and standards. The combination of enhancing MOV personnel training, improving the MOV personnel qualification program and employing comprehensive monitoring and testing techniques for MOVs provides further assurance that our MOVs are capable of operating imder normal and design basis conditions.
The valves in the scope of our Generic Letter 89-10 Program are listed on page 23 of the Attachment.
Throughout this letter they are referred to as the " Program MOVs". We have overhauled and performed l
significant modifications to each of the Program MOVs. Their design basis requirements have been reviewed and affirmed. We confirmed that they are capable of meeting their design basis requirements.
9609100346 960903 PDR ADOCK 05000317 P
PDR A
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l Document Control Desk September 3,1996 Page 2 Our seven-year effort to address the recommended actions of the generic letter has cost $14 million and involved virtually every department, process and program at Calvert Cliffs. As a result, the reliability of critical plant components has been improved. Since we have applied the improvements in analysis of MOV performance and maintenance to key balance of plant MOVs, we have increased assurance that the plant will perform as designed.
Calvert Cliffs has established a program for ensuring MOVs are set and maintained so that the MOVs will operate as required during normal and abnormal conditions. We will continue to monitor advances in methods and techniques of maintaining and evaluating MOVs. We will implement, as appropriate, those which we determine improve our Program.
Attachment (1) contains our detailed response to the actions requested in Reference (a).
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Ve truly 'ours,
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for C. II. Cruse Vice President - Nuclear Energy CHC/JMO/dtm
Attachment:
Baltimore Gas & Electric Company's Final Response to Generic Letter 89-10: Safety-Related Motor-Operated Valve Testing and Surveillance cc:
D. A. Brune, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate I-1, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. H. Walter, PSC l
Document Control Desk Septemher 3,1996 Page 3 bec:
G. C. Creel R. E. Denton P. G. Chabot J. R. Lemons P. E. Katz R. P. Heibel OSSRC Secretary T. J. Camilleri l
K. R. Eser l
S. B. Haggerty L. S. Larragoite j
K. R. Neddenien M. G. Polak J. M. Osborne l
J. M. Riedel l
File 06.04 (GL 89-10)
Electronic Docket File i
l CHC/JMO/jmo/ dim NRC 96-049 I
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ATTACIIMENT BALTIMORE GAS & ELECTRIC COMPANY'S FINAL RESPONSE TO GENERIC LETTER 89-10:
SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE
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i Calvert Cliffs Nuclear Power Plant Units 1 & 2 September 3,1996
KITACHMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE BACKGROUND On June 28, 1989, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 89-10,
" Safety-Related Motor-Operated Valve Testing and Surveillance." The purpose of this GL was to extend the scope of the program outlined in NRC Bulletin 85-03. In Bulletin 85-03, the NRC recommended that licensees develop and implement a program to ensure that valve motor-operator switch settings (torque, torque bypass, position limit, overload) for Motor-Operated Valves (MOVs) in several specified systems are selected, set and maintained so that the MOVs will operate under design basis conditions. Generic Letter 89-10 expanded the scope of Bulletin 85-03 to all safety-related MOVs, as well as all position changeable MOVs. Specifically, the NRC recommended that licensees develop a program that would,
" provide for testing, inspection and maintenance of MOVs so as to provide the necessary assurance that they will function when subjected to design basis conditions that are to be considered during both normal operation and abnormal events within the design basis of the plant."
Since the issuance of GL 89-10, seven additional GL Supplements have been issued. These Supplements reDect the complexity and dynamics of responding to the issues presented in GL 89-10.
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OVERVIEW OF BGE's ACTIONS TO RESPOND TO GL 89-10 In a letter dated December 28,1989, Baltimore Gas and Electric Company (BGE) notified the NRC ofits intent to implement the recommendations of GL 89-10 and complete such action within the schedules specified in the GL. The Calvert Cliffs scheduled completion dates coincided with the 1996 Refueling Outage and 1997 Refueling Outage, Units 1 and 2, respectaJy.
Our initial investigation indicated considerable actions were required to address the rather large and complicated scope of the GL. We recognized that comprehensive process controls would be necessary to ensure an appropriate response to GL 89-10 issues. The decision was made by plant management to apply a " project methodology," and subsequently, the MOV Project was created. The project methodology utilizes acquired expertise and support structure to define the problem, analyze corrective measures and options, secure necessary resources and execute appropriate response actions. To allow this to occur in an effective and expeditious manner, the Projects Section has a direct line path to management.
The most important aspect of the Project effort was the early recruitment of the necessary team members.
The MOV Project Team consisted of representatives from Design Engineering, Plant Engineering, Operations, Maintenance, Projects, and Planning and Scheduling.
One of the considerable strengths of the MOV Project was full management commitment. Site management, including the Vice President-Nuclear Energy Division, was committed to assuring Calvert Cliffs responded to MOV issues in appropriate and effective fashion. Baltimore Gas and Electric Company recognizes the role site management has in ensuring a continuously effective MOV Program.
A primary example of management commitment to the MOV project was the early formation and continued support of a dedicated MOV Component Engineer and MOV Maintenance Group.
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6 ATTACHMENI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 l
SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE Following is a brief description of actions taken by BGE. These actions are categorized to specific areas ofinterest.
Design Basis Review A design basis review has been performed on all safety-related Calvert Cliffs MOVs as requested by item "a" of the GL. In addition to these, design basis review of all Balance of Plant MOVs has also been perfonned. This review has determined the maximum differential pressures each l
MOV will be required to operate against during both normal and abnormal conditions. The reviews are documented as formal pressure calculations controlled by Calvert Cliffs Design Engineering Standards. The BGE Mechanical Engineering Unit has reviewed and approved all l
pressure calculations and maintains responsibility of these calculation.s.
These pressure l
calculations have incorporated appropriately conservative inputs and are used as input for determining the operational requirements for Calvert Cliffs MOVs.
Establishment of Switch Settings Correct torque switch settings were determined and documented under formal BGE calculations.
i These " Thrust Calculations" were prepared, controlled and maintained under Design l
Engineering Standards. Thrust calculations evaluate both capability as well as limitations of the MOV, as detailed by the vendor " weak link analysis." The Babcock & Wilcox Motor-Operated Valve Evaluation computer program was used in determining the required stem thrust. The program utilizes the industry standard equation for gate valves of:
Required Thrust =- [(Ase) x (DP) x ( )] + [(Ast) x (LP)] + PL where:
Ase = valve seat / orifice area DP = design basis differential pressure Ast = valve stem area @ packing LP = design basis line pressure
= valve / seat factor PL = packing load If adequate margin exists, the same equation will apply to both gate and globe valves.
Otherwise, the piston effect factor for globe valves will be incorporated as:
i Required Thrust = [(Ase) x (DP) x ( )] + [(Ast) x (LP-DP)] + PL This program has been independently reviewed and approved by BGE. Conservative inputs are i
used to develop an appropriate " Thrust ' Window" (see page 5). For example, the industry i
practice of using a valve factor value of 0.3 for gate valves was initially replaced with a more appropriate value of 0.5. This value has been further increased based on the results of site testing to a value of 0.7, and is used as a standard for those MOVs unable to be tested at design basis conditions. A stem friction coefficient of 0.2 is used to increase margin in establishing the
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necessary thrust requirements. The thrust window is further adjusted by a 10% (15% where unable to test at design basis conditions) factor for Rate of Loading (load sensitive behavior),
and a 5% (10% if margin allows) factor to compensate for stem lube degradation and spring pack relaxation.
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i A'IIACIIMENI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPER ATED VALVE TESTING AND SURVEILLANCE Further conservatism is factored into the thrust calculations, in that for many cases, several valves are bounded by one calculation. Input to these calculations are based on the most conservative values of the valves. If each MOV has been independently evaluated, many MOVs would show substantially more margin.
Additional factors, such as using the Limitorque established pullout efficiency as opposed to running efficiency and the adjustments for reduced voltage and increase temperature effects on motor capability, are also incorporated.
MOV Modifications A significant amount of component modification has been performed as a result of the design review effort and the required thrust windows established by the thrust calculations. Over 220 modifications have been performed on GL 89-10 Program MOVs. These included:
valve work - replacement cf valve wedges / disc and stems; and I
> operator work - replacement of motors, gearing and spring packs.
Included in the imprevements of MOV performance and reliability is the installation of four-train limit switches in all Program MOVs. This change supports the increased assurance MOVs will function as required by allowing torque switch bypass duration to be adjusted to provide full operator capability to position the valve.
Verifbation of Switch Settings Verification of correct switch settings has been accomplished through a combination of dynamic and static testing and evaluation of MOV performance characteristics. All Program MOVs have been statically tested. Where practicable to do so, we tested all Program MOVs under design basis conditions. As a result,60% of Program MOVs have been tested dynamically. Test results have been fed back into associated thrust calculations and have been used to develop bounding values for Calvert Cliffs MOVs.
l MOV Overhauls All GL 89-10 Program MOVs have been inspected, overhauled and assembled under enhanced maintenance procedures by qualified personnel. These procedures have incorporated " lessons learned" concerning deficiencies and degraded conditions which have been identified by the NRC, Industry Notices and Calvert Cliffs operating experience data.
Process Controls Actions in response to GL 89-10 have been directed and controlled by a formal Project Plan.
This document defined the scope of the GL 89-10 Program, identified the organizations involved in this effort, and established responsibilities for implementing the necessary actions. This Plan controlled all work associated with MOVs at Calvert Cliffs until the Project transitioned to a
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Plant Program. Transition to a Plant Program occurred in phases allowing for complete incorporation of Project objectives and results into normal plant processes. Plant Engineering 1
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1 AIIACHMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE Section Guideline 15 " Motor Operated Valve Program" now defines the process and delineates responsibilities for Calvert Cliffs MOVs.
The " Program Owner" is the MOV Component Engineer. lie serves as the Calvert Cliffs technical expert and is responsible for overseeing the administrative, maintenance and testing aspects of the MOV Program.
Motor-operated valve maintenance is performed by the MOV Unit within the Electrical &
Controls Section. The Unit is staffed by a dedicated supervisor and qualified MOV technicians.
Technicians receive specialized training in MOV maintenance and the use of diagnostic test equipment, including advanced diagnostic training.
Calvert Cliffs utilizes the Liberty Technologies' computer-based Valve Operation Test and Evaluation System (VOTES) and the Babcock & Wilcox Nuclear Service Company's " THRUST 2" spring pack testing system to monitor and assess critical MOV performance characteristics.
Engineering and Maintenance procedures have been prepared or revised as necessary to ensure appropriate instruction exists to determine, set and maintain the MOV capable of operating as required.
Critical performance characteristics are monitored for indication of degrading capability. Conditions which can potentially degrade MOV performance are identified and tracked under the Calvert Cliffs MOV Trending Program.
Periodic Verification Calvert Cliffs has developed a plan for periodically verifying the capability of Program MOVs based on a combination of dynamic diagnostic testing and static diagnostic testing, along with an additional qualification factor. A margin-based method incorporating the results of dynamic testing conducted at Calvert Cliffs is used to establish an initial bin / category of testing. Each MOV is further evaluated based on its relative safety significance to the plant (see page 24).
Through this two part analysis, the appropriate method and frequency of testing to ensure capability is determined.
Continuing Efforts Calvert Cliffs has established a program for ensuring MOVs are set and maintained so that the MOVs will operate as required during normal and abnormal conditions. This includes evaluation of MOVs with low margin to assess ways to increase margin. Modification activities are in progress which will result in increased capability for several MOVs.
The MOV Program ensures continuous monitoring of MOV performance both at Calvert Cliffs and throughout the nuclear industry. We will continue to monitor advances in methods and techniques of maintaining and evaluating MOVs. We will implement, as appropriate, those we determine improve our Program.
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KIIACIIMEMI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE i
MOV TIIRUST WINDOW i
l Survivable Limits
- Based on:
Valve allowable l
Operator torque x 1.1 Operator thrust x 1.1 Torque switch repeatability (or Kalsi)
Test equipment accuracy l
u MAX TT a
(maximum total thrust) l Inertia Control Switch Trip Based on: Motor at reduced voltage &
loss from elevated temperature i
Spring pack capability Operator torque Torque switch repeatability Operator thrust Test equipment accuracy Valve allowable CST max m
(control switch trip max) l T min (minimum thrust req'd)
Torque switch repeatability Test equipment accuracy Rate ofloading Stem lube degradation / spring pack relaxation l
i Minimum required thrust (from standard industry equation) 5
KIIACIIMEMI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE GENERIC LETTER ITEMS:
Review and document the design basisfor the operation of each MOV to include the marimum a.
differentialpressure expected - opening or closing during normal and abnormal events.
BGERespanse Complete design basis reviews have been performed on all Calvert Cliffs Nuclear Power Plant (CCNPP) motor-operated valves to establish maximum line pressure & differential pressures expected. From this review, the maximum system pressure and differential pressures were determined. To ensure a complete review of design basis conditions, this determination included the review and evaluation of system and operating parameters identified and defined by:
CCNPP Updated Final Safety Analysis Report CCNPP Emergency Operating Procedures CCNPP Abnormal Operating Procedures e
CCNPP Operating Instructions e
CCNPP System O&M / P&lD Drawings e
CCNPP Technical Specifications e
Equipment performance data e
These reviews were perfonned and are documented under BGE Mechanical Calculations controlled by BGE Design Engineering Standards. Conservative inputs were used to ensure added performance margin. For example:
Head loss through piping was not used to reduce pressures; Interfacing systems (pumps and piping cross-connects) were included in determining e
maximum pressure; Valve position was considered as full closed, resulting in the greatest differential e
pressure; In systems with recirculation valves, the calculations were based on the recirculation valves being closed, thereby applying maximum pressure to the subject valve; For valves in a series configuration, each valve was evaluated as though it is the first of e
the pair to close thereby incurring the highest intet pressure; and Where analysis predicts maximum upstream pressure to exist but not simultaneously with minimum downstream pressure, each pressure condition is used to determine maximum differential pressure affecting the valve (the use of this non-simultaneous conditions produces a conservative value for differential pressure).
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ATTACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR OPERATED VALVE TESTING AND SURVEILLANCE l
b.
Based on the resultsfrom Item a, establish the correct switch settings (torque, torque bypass, position limit & overload).
IlGFlespone Appropriate switch settings have b:en determined through a series of comprehensive and I
coordinated actions. Thrust calculations performed and documented under BGE Mechanical Calculations, established the operating " thrust window." This window was determined through evaluation of the required operational parameters established by the associate pressure calculation. The Babcock & Wilcox Nuclear Technologies computer based program " Motor Operated Valve Evaluation" was used to evaluate MOV configuration and calculate design parameters.
This program was verified by independent calculation under BGE Design Engineering Standards. Further evaluation was performed incorporating margin to compensate for anticipated loss of operator motor performance from reduced voltage conditions and l
temperature effects. For added conservatism, pullout efficiency was used instead of running efficiency to calculate motor capability. Thrust calculations apply other conservative standards to compensate for additional factors. Diagnostic inaccuracy is combined with torque switch repeatability values as a square root sum of squares error. The resultant value is further adjusted directly by factors for rate ofloading, stem lubrication degradation and spring pack relaxation.
In response to industry testing, valve factor assumptions of 0.5 for gate valve and 1.1 for globe valves were used as calculation standards. In cases where dynamic testing indicated a higher value, the associated calculation was revised to reflect the tested value and the thrust window adjusted accordingly. Statistical analysis of the results of dynamic testing at Calvert Cliffs has been used to further increase conservatism in switch settings. From this testing, a confidence level of 95% has been used to establish a standard value for valve factor of 0.7 for gate valves.
As an additional measure of conservatism, a stem thread coefficient of friction of 0.2 is used in determining MOV capability.
Open and closed torque switches are bypassed for approximately 75% and 95% of the stroke, respectively. This standard set up gives added assurance the operator will position the valve as required by applying full motor capability during the bypass condition duration.
Settings for overload heaters for Program MOVs have been evaluated under BGE's response to the Electrical Distribution System Functional Inspection. Overloads have been sized to preclude premature trip. In concert with any MOV modification affecting motor performance, the overload setting is reviewed and adjusted accordingly.
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1 ATIACRMENI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE Switch settings should be changed to those established in response to item b. The Af0Vshould c.
be demonstrated to be operable by testing at design basis differential pressure and/or flow.
Where testing at design conditions is notpracticable, describe alternatives used to verify correct settings.
RGEResponse Switch settings for all GL 89-10 Program MOVs have been based on the review and evaluation of design basis requirements, as determined in response to GL 8910 item b, and have been confirmed by in-situ testing. Where necessary, component modifications have been performed on those MOVs which showed limited capability, as determined through evaluations of required thrust. In addition, all operators on Program MOVs have been inspected, overhauled and assembled by qualified personnel under enhanced maintenance procedures.
Each torque switch and spring pack are individually tested to determine their performance characteristics for suitable matching to the MOV and to establish a baseline for on-going condition assessment. The Babcock & Wilcox Nuclear Service Company's "TilRUST 2" spring pack testing system was used for this testing, and developed a detailed profile of each spring pack / torque switch set, allowing for distinct control over torque switch trip.
All Program MOVs have been tested under static conditions. The Liberty Technologies' VOTES is used to monitor, measure and confirm critical MOV perfortnance characteristics.
Calvert Cliffs established the position to test dynamically all MOVs at design basis conditions that were practicable to do so. As a result,60% of CCNPP Program MOVs have been tested dynamically. Of these tests, approximately half were greater than or equal to 78% of design basis differential pressures.
Where testing at design basis conditions is not practicable, alternative methods are used to verify the correct switch settings are used. These methods consist of:
Comparison of test results on similar MOVs; Application of statistical analysis of the results of dynamic tests at Calvert Cliffs; and Application of the EPRI Performance Prediction Model (PPM) (the PPM was run by e
MPR Associates, the primary developer of the PPM).
d.
Prepare or revise procedures to ensure that the correct settings are determined and maintained throughout the hfe of the plant. These procedures should include provisionsfor monitoring Af0V performance to ensure switch settings are correct.
BGEResponse As previously noted, determination of appropriate switch settings is controlled by BGE Design Engineering Section Standards and verified by comprehensive Maintenance Procedures. Thrust windows are established by formal Thrust Calculations which are prepared and maintained under 8
ATTACIIMEEE l
BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10
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SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE i
l Design Engineering Section Mechanical Engineering Standards. The calculations are maintained current via a formal controlled document and revision process.
l Critical component performance parameters are measured, evaluated and matched to the j
individual MOV's design requirements. Spring pack and torque switch function is tested using computer based test equipment. Comprehensive procedures control the performance of this testing and include evaluation and acceptance criteria. This process ensures important MOV components are appropriately suited to the MOV's design requirements.
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Periodic monitoring and maintenance of critical MOV performance characteristics, including limit switch, torque switch and torque switch by-pass switches is through an established preventive maintenance system tailored to MOVs. In addition, VOTES testing is performed to verify proper MOV operation and confirm correct switch settings following any maintenance or modification activity which may have affected MOV performance.
l Valve Operation Test and Evaluation System tests are conducted under detailed procedures
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which contain required acceptance criteria. The design thrust window is included in the j
acceptance evaluation to ensure MOV capability to operate, as required under design basis conditions, is maintained.
Design basis review should include an examination ofpertinent design and installation criteria e.
that were used in choosing the particular MOV. The review should include the effects on MOV i
performance ofdesign basis degraded voltage.
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IlGE Respanie I
As noted in response to item a, a complete review of the design basis of each MOV within the i
GL 89-10 Frogram, as well as balance of plant MOVs, have been performed. Included in this j
review was an examination of all pertinent construction and installation specifications. All design basis requirements and operation requirements were re-validated through review of all design related, as well as operationally-based, procedures, specifications and standards.
This review included an analysis of the affects of degraded voltage on MOV performance.
Expected motor capability reduction has been accounted for by using degraded voltage at the MOV motor terminals. In addition, motor capability has also been determined by incorporating the effects of torque loss due to temperature.
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AHACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE f.
Documentation of explanations and the description of actual test methods used for accomplishing item c should be retained as part of the required recordsfor the Af0V. Testing degraded voltage conditions may be impracticable to perform in-situ. Switch settings should accountfor the situation where a valve may be called upon to operate at design basis differential pressure.
Testing of Af0Vs at design basis conditions need not be repeated unless the Af0V is replaced, modiped or overhauled to the extent that the existing test results are not representative of the Af0 Vin its modspedconfiguration.
BGEResnanse The capability of Program MOVs to operate as required under design basis conditions is evaluated, established and documented under a " Capability Package" (see page 23). This document describes the method used to verify correct switch settings and is maintained as a permanent record.
Dynamic tests performed on Program MOVs were directed and documented by formal test procedures. Engineering Test Procedures controlled all dynamic testing and contain the test results and acceptance criteria. These procedures are maintained as permanent life-time records under the Calvert Cliffs Quality Assurance Program.
As previously noted, as a result of certain MOVs being not practicable to test at design basis condition, alternative methods have been used. All Program MOVs have been set according to the best available information. This includes:
Actual dynamic test results; Comparison to similar valves; and e
The use of conservative statistical application of Calvert Cliffs dynamic test results to e
MOVs which were not practicable to test under design basis conditions.
These methods have established the necessary assurance that the MOV will function as required under all design basis conditions.
Calvert Cliffs concurs with the position that testing under design basis conditions need not be repeated unless the MOV is altered in such a way to render the existing test results invalid.
Conditions which may impact the existing test results have been identified and are used to assess the need for subsequent design basis testing.
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ATTACIIMENI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE g.
A number of dejiciencies, misadjustments, and degraded conditions were discovered by licensees, either as a result of their efforts to comply with Bulletin 85-03 or from other experiences. A list of these conditions is includedin Attachment A to the GL DGE Response Calvert Cliffs has reviewed the list of deficiencies, misadjustments and degraded conditions as i
presented by in the GL. Criteria to preclude conditions such as those identified by the list have been incorporated into site procedures and standards. The MOV Trending Program has incorporated these items into our continuous monitoring of conditions which affect MOV performance.
h.
Each Af0Vfailure or corrective action taken, including repair, alteration, analysis, test and surveillance, should be analy:ed orjustified and documented. It is suggested that these Af0V l
data should be periodically examined as part of a monitoring andfeedback effort to establish trends of Af0V operability. These trends couldprovide the basisfor a licensee revision of the testingfrequency established to periodically verify the adequacy of Af0V switch settings. For this monitoring andfeedback effort, a well -structured and component-oriented system ( e.g. the Nuclear Plant Reliability Data System is needed to capture, track and share the equipment history data.
BGE Respanse Motor-operated valve failure, corrective action and test results are analyzed and documented by qualified MOV personnel.
The MOV Trending Program establishes the process for comprehensive monitoring and assessment of MOV performance. Results of MOV testing are reviewed and evaluated by a qualified MOV engineer. Data from these evaluations is entered into the MOV trending database. T rending data is reviewed after each refueling outage.
Calvert Cliffs has created an enhanced version of the Nuclear Plant Reliability Data System based on the criteria established by the technical subcommittee of the MOV Users Group. A report is generated on a monthly basis identifying any MOV problems and failures. This report is updated by the Reliability Engineering Unit and evaluated by the MOV Component Engineer.
The MOV Component Engineer is responsible for the review, evaluation and determination of any adverse trends in the performance of MOVs at Calvert Cliffs. This determination is documented in a semi-annual report on MOV performance.
The results of this trending process are used to assess the quality of maintenance practices and, if I
necessary, initiate changes to procedures and practices and frequency of MOV testing.
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ATTACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE i
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Each licensee with an operating license should complete all design basis reviews, analysis,
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verifications, tests, and inspections that have been instituted in order to comply with Items a through h withinfive years or three refueling outages of the date of this letter.
ILGE Resprue Calvert Cliffs' actions in response to the items a through h of GL 89-10 have been completed within the prescribed time frame. As indicated in the December 28, 1989 letter from Mr.G.C. Creel to the NRC Document Control Desk, associated actions on Unit I were scheduled for completion at the end of the 1996 Refueling Outage. Associated actions for Unit 2 were scheduled for completion at the end of the 1997 Refueling Outage.
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The programfor the verification of the procedures outlined in Item d, as well as other tests or surveillance that the owner may chose to use to identify potential Af0V degradation or misadjustment, wA as those described in Attachment A, should be implemented after maintenance or uujustment, (including packing adjustment) of each Af0V, and periodically l
thereafter. Tl: rurveillance interval should be based on the licensee's evaluation of the safety l
importance ofeach Af0V as well as its maintenance andperformance history. The surveillance interv-1 thould not exceedfive years or three rejheling outages, whichever is longer, unless a longer interval can bejustifiedfor anyparticular A10 V.
BGE.Respone l
Calvert Cliffs has an established program which 03ows for the verification and assurance that actions needed to maintain MOVs capable of operating when required are appropriate and maintained. Maintenance or modification activities which can affect the performance of the MOV are assessed to determine the appropriate action needed to verify the MOV remains capable of performing as required. Formal direction has been established for the determination for the necessary post-maintenance test following any activity which can affect MOV performance.
Surveillance intervals for periodically verifying that switch settings remain correct are based on an analysis of the safety importance (see page 24), performance capability and history of the particular MOV. The Calvert Cliffs Periodic Verification Program describes the process and establishes the appropriate surveillance interval. In general, static testing using the VOTES diagnostic test equipment in conjunction with select dynamic testing is performed at a interval of six years. Where analysis has determined conditions warrant, a surveillance interval not to exceed ten years has been estaVished.
i Surveillance testing is controlled by the Preventive Maintenance Program. Its sequence logic has VOTES testing performed to approximately one-sixth of the Program valves each year. This logic allows for continuous monitoring of MOV performance to enable identification of degrading conditions.
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ATTACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE k.
In recognitior f the necessityforpreplanning. refueling outages that start within six months of the date of this letter need not be counted in establishing the schedule to meet the time limits recommendedin items iandj.
RG1 Response As noted in the BGE response to item i., the schedule for completing actions associated with GL 89-10 was established as the end of refueling outages in 1996 and 1997 for Units 1 and 2, respectively. This schedule is consistent with the guidance contained in the GL.
l.
Each licensee shall advise the NRC in writing within six months of the date of this letter that the above schedule and recommendations will be met.
BGE Response Baltimore Gas and Electric Company responded in writing within the time frame described by the Letter. By letter dated December 28,1989, Mr. G. C. Creel to the NRC Document Control Desk, the planned schedule and commitment to implement the recommendations of GL 89-10 was submitted.
m.
Each licensee shall notify the NRC in writing within 30 days after the actions described in the firstparagraph ofItem 1. have been completed.
BGE Resumiss Actions in response to the first paragraph of Item i have been completed for Calvert Cliffs Units 1 and 2 with the completion of refueling activities of Unit 1. Although Unit 2 actions were originally slated for completion during the 1997 refueling outage, all actions needed in response to the first paragraph Item i have been completed.
13
ATIACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE GL 89-10 June 13,1990 SUPPLEMENT 1:
"RESULTS OF TIIE PUBLIC WORKSIIOPS" This supplement to GL 89-10 includes the opening remarks by NRC representatives and the responses provided by the NRC staff to all significant questions that were discussed during three NRC held public workshops concerning GL 89-10.
This supplement was prepared to assist licensees and permit holders in development programs that will provide assurance of MOV operability under design basis conditions.
BGE Respanse As stated above, this supplement presented the results of three public workshops held to discuss GL 89-10. The supplement presents sixty questions asked by attendees of the NRC staff at those workshops, provides clarification to the recommendations of the GL, and describes methods for licensee response to the those recommendations.
Baltimore Gas and Electric Company MOV Project personnel attended one of the workshops.
The issues and responses frora the NRC staff have been reviewed by the Project personnel and incorporated as appropriate into the Calvert Cliffs response to the GL, GL 89-10 August 3,1990 SUPPLEMENT 2:
" AVAILABILITY OF PROGRAM DESCRIPTIONS" This supplement extended the date licensees and permit holders were required to have made available l
their GL program description from June 28,1990, to January 1,1991. The schedule for completing of l
recommended actions a through h of the GL remained unchanged.
l BGE Response The Calvert Cliffs' MOV Project Manual outlining the actions to be taken in response to the recommendations of GL 89-10 was initiated and available on July 13,1990.
Calvert Cliffs has completed all actions in response to recommended actions a through h of the GL within the schedule requested.
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14
AITACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE G L 89-10 October 25,1990 SUPPLEMENT 3:
" CONSIDERATION OF TIIE RESULTS OF NRC-SPONSORED TEST OF MOTOR-OPERATED VALVES" This supplement describes actions requested of Boiling Water Reactors (BWR) licensees in response to the results of NRC-sponsored MOV tests of steam supply lines of High Pressure Coolant Injection and in the supply lines for Reactor Water Cleanup systems at BWRs. The results of this testing were to be considered in prioritizing actions on GL 89-10 Program MOVs. Additionally, all licensees and construction permit holders were requested to consider the applicability of this information to other MOVs within scope of GL 89-10.
BGE Responss Calvert Cliffs is a Pressurized Water Reactor and consequently a written response to this supplement was not required. The findings and conclusions obtained from the results of the NRC-sponsored testing of MOVs were reviewed and considered applicable to the Calvert Cliffs GL 89-10 Program. All Calvert Cliffs Program MOVs were prioritized based on their safety function and their potential of exhibiting minimal capability margin resulting from the revised thrust calculations. The findings and conclusions were incorporated into the design baris verification and dynamic testing plan for GL 89-10 MOVs.
GL 89-10 February 12,1992 SUPPLEMENT 4:
" CONSIDERATION OF VALVE MISPOSITIONI.NG IN BOILING l
WATER REACTORS" This supplement provided notification to licensees that the NRC staff, following a review of the issues concerning mispositioning of valves from the Control Room for BWRs, no longer considers the recommendations for inadvertent operation of MOVs from the Control Room to be within the scope of GL 89-10 for BWRs. Additionally, it indicated that the NRC will perform a similar review for PWRs.
BGE_Respanse Calvert Cliffs is a Pressurized Water Reactor. As such, this supplement did not directly affect our GL 89-10 Program.
l A
i 15 i
M ACHMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE i
i GL 89-10 June 28,1993
' UPPLEMENT S:
" INACCURACY OF MOTOR-OPERATED VALVE DIAGNOSTIC EQUIPMENT" This supplement requested licensees to reexamine their MOV programs and to identify measures taken or planned to account for uncertainties in MOV diagnostic equipment inaccuracy. Licensees were required within 90 days of receipt of the letter 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.
Report whether they have taken actions or plan to take actions (including schedule and summary of actions taken or planned) to address the information on the accuracy of MOV diagnostic equipment.
BGE Respenst Baltimore Gas and Electric Company has used the Liberty Technologies' VOTES System for MOV testing and diagnostics. Liberty Technologies issued a 10 CFR Part 21 report on October 2,1992, concerning increased diagnostic inaccuracies associated with stem torque I
effects and stem material constants.
All MOVs within the scope of GL 89-10 which had been tested using VOTES were evaluated l
based on the information contained in the Liberty Technologies' October 2,199210 CFR Part 21 report and the VOTES version 2.3 software. All MOVs were confirmed operable.
In a letter dated September 29,1993, BGE notified the NRC of our response to this supplement and the status of our MOVs.
l l
4 t
1 4
I
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16
l KI]'AClIMEEI' l
BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE GL 89-10 MARCII 8,1994 SUPPLEMENT 6:
"INFORMATION ON SCHEDULE AND GROUPING, AND STAFF RESPONSES TO ADDITIONAL PUBLIC QUESTIONS" In this supplement, the NRC staff further clarifies the positions on the schedule for completing the MOV testing to verify design basis capability recommended in GL 89-10 and the grouping of MOVs to establish valve setup conditions. The staff responses to other general public questions and a list of the recently issued NRC GLs are also provided in the enclosures to this supplement.
IlGLResnonse The completion of Calvert Cliffs' actions in response to GL 89-10 were planned to meet the schedule and have been completed within the original schedule as submitted by BGE to the NRC.
Calvert Cliffs has incorporated the "MOV Grouping" method for several Program MOVs that were not practicable to test at design basis conditions. We have reviewed the items identified as I
important considerations by the NRC staff and have incorporated them as appropriate.
l The MOV Project has reviewed the questions and NRC staff responses to questions on the GL l
and Supplements, and have taken them into consideration in the development of our GL 89-10 l
Program.
G L 89-10 JANUARY 24,1996 SUPPLEMENT 7:
" CONSIDERATION OF VALVE MISPOSITIONING IN PRESSURIZED-WATER REACTORS" In this supplement, the NRC removed the recommendation that MOV mispositioning be considered by
(
PWR licensees in responding to GL 89-10, as was done for BWR licensees in Supplement 4.
HGE. Response Originally, the MOV Project incorporated the effect of a mispositioning event into the determination of required thrust when adequate margin was available to incorporate the higher pressures without performing modifications. However, after Supplement 7 was issued, we deleted consideration of mispositioning pressures in our thrust determinations.
4 17
ATTACHA M BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE MOV Valve Informabon Actuatorinformation Design Line Thrust Required Field Evaluation Number System / Function Manufacturer Type Size Manufacturer Type / Size Motor Delta P Pressure Bare
- T min
- Margin Methed 140V-0269 Chemical and Volume Control System to Velan Globe 2 in Lmtorque SMB1000 5 ft b 0
2488 3974 4952 23.3 Comparison High Pressure Safety injection Header 1-MOV-0399 Shutdown Cooling Heat Exchanger Velan Globe 2 in Limitorque SMB1000 5 ft b 210 210 2367 3162 43.8 Cuny.M Rec 2culation 1MOVM03 Power-Operated Relief Valve Block Velan Gate 2.5 in Limitorque SMB1000 5 ft Ib 2282 2285 6622 8%3 7.8 Companson t-MOV-0405 Power-Operated Relief Valve Block Velan Gate 2.5 in Limitorque SMB / 000 5 ft b 2282 2285 6622 8134 3.8 Comparison 1-MOV-0501 Chemicaland Volume ControlSystem; Vetan Gate 4 in Limitorque SMB / 00 7.5 ft b 139 145 1740 2012 30.0 Statistical Volume Control Tank Outlet isolation 140V-0504 Chemcal and Volume Control System; Velan Gate 3 in Limitorque SMB100 5 ft b 105 139 1376 2187 16.5 Statshcal/ DP Reactor Coolant Make-up to Volume Control Tank 1-MOV-0508 Chemcal and Volume Control System; Velan Gate 3 in Limitorque SMB100 7.5 ft Ib 154 148 1342 1874 8.3 StatisticPlIDP Boric Acid Tank to Charging Pump, Bypass 1-MOV-0509 Chemeal and Volume Control System; Velan Gate 3 in Limitorque SMB / 00 7.5 ft b 138 138 1711 2397 3.0 StabstcallDP Boric Acid Tank to Charging Pump, Bypass 1-MOV-0514 Chemcal and Volume Control System; Vetan Gate 3 in Lmtorque SMB / 00 7.5 ft Ib 154 148 1393 2113 32.9 StatisticallDP Boric Acid Pump to Charging Pump 9-MOV-0615 Low Pressure Safety injection; Looo Velan Globe 6 in Lmtorque SMB/2 60 ftIb 35 245 6080 8313 304.8 Dynamic Test isolation,11 A 1-MOV-0616 Hgh Pressure Safety injection; Loop Velan Globe 2 in Lmtorque SMB / 00 25 ftIb 1269 1282 4074 8621 37.8 Dynamic Test isolation,11A, Normal Header 140V-0617 Hgh Pressure Safety injection; Loop Velan Globe 2 in Limitorque SMB /00 25 ft b 2723 2723 5842 13818 1.3 Dynamic Test Isolaton,11 A, Attemate Header
,140V-0625 Low Pressure Safetyinjectan; Loop Velan Globe 6 in Limitorque SMBI2 60 ft b 35 245 6080 8313 304.8 Dynamic Test isolation,11B 1-MOV-0626 Hgh Pressure Safety injection; Loop Velan Globe 2 in Limitorque SMB / 00 25 ft b 1269 1282 4574 10699 1.6 Dynamic Test isolabon,11B, Normal Header 1-MOV-0627 High Pressure Safety injecbon; Loop Velan Globe 2in Lmtorque SMB / 00 25 ftIb 2723 2723 5842 13818 1.3 Dynamic Test isolabon,118, Alteres Header 1-MOV-0635 Low Pressure Safetyinjecton; Loop Velan Globe 6 in Limitorque SMB!2 60 ft b 35 245 6080 8313 304.8 Dynamic Test isolabon,12A 1-MOV-0636 High Pressure Safety injection; Loop Velan Globe 2in Limitorque SMB / 00 25 ft b 1269 1282 4574 10699 1.6 Dynamic Test isolation,12A, Normal Header i
18
ATTACIIMEE BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE MOV Valve Informabon ActuatorInformahon Design Line Thrust Required Field Evaluation Number System / Function Manufacturer Type Size Manufacturer Type / Size Motor Delta P Pressure Bare
- T min' Marqin Method 1-MOV-0637 High Pressure Safety injection; Loco Velan Globe 2 in Limitorque SMB!00 25 ft b 2723 2723 5842 13818 1.3 Dyname Test Isolabon,12A, Altemate Header 1-MOV-0645 Low Pressure Safety injection; Loop Velan Globe S in Limitorque SMB/2 60 ft b 35 245 6080 8313 304.8 Dynamic Test isolation.12B 1-MOV-0646 High Pressure Safety injection; Looo Velan Globe 2 in Limitorque SMB / 00 25 ftIb 1269 1282 4574 10699 1.6 Dynamic Test isolation,12B Normal Header 1-MOV-0647 High Pressure Safety injection; Loop Velan Globe 2 in Limitorque SMB / 00 25 ft Ib 2723 2723 5842 13818 1.3 Dynamic Test isolation,12B, Attemate Header 1-MOV-0651 Shutdown Cooling Retum isolation Velan Gate 12 in Limitorque SMB/3 100 ftIb 256 256 "51347 "51347 25.1 EPRI PPM 1-MOV-0652 Shutdown Cooling Retum isolation Velan Gate 12 in Limitorque SMB/3 100 ftIb 253 253 "51347 "51347 24.1 EPRI PPM 1-MOV-0653 High Pressure Safety injection; Header Velan Gate 4 in Lmtorque SMB/00 25 ft b 0
1300 3930 7406 35.0 Dynamic Test Cross Connechon Valve 1-MOV-0654 High Pressure Safety injection; Header Velan Gate 6 in Limitorque SMB/0 40 ftIb 43 43 5709 7807 97.7 Dyname Test Isolation Valve 1-MOV-0655 Hsh Pressure Safety injechon; Header Velan Gate 4 in Limitorque SMB!00 25 ft b 0
1300 3930 6351 57.4 Dynamic Test Cross Connechon Va!ve 1-MOV-0656 High Pressure Safety injection; Heaoer Velan Gate 6 in Lmtorque SMB/1 60 ft tb 259 301 6331 8752 16.3 Dyname Test isolation Valve 1-MOV-0658 Low Pressure Safety injechon Supply to Velan Gate 12in Limitorque SMB/0 40 ft b 0
43 4304 8025 84.1 Dynamic Test Shutdown Cooling Heat Exchanger 1-MOV-0659 Safety injection to Refueling Water Tank Velan Gate 4 in Limitorque SMB/00 10 ftIb 1252 1283 6751 8410 9.0 Dynamic Test Mini Flow Retum isolation 1-MOV-0660 Safety injechon to Refueling Water Tank Velan Gate 4 in Limitorque SMB/00 7.5 ft Ib 1252 1283 6751 8938 5.0 Dyname Test Mini Flow Retum isolation 1-MOV-0662 Shutdown Cooling Recirculabon Valve Velan Gate 4 in Limitorque SMBM0 10 ftIb 469 510 1514 1514 411.3 Statistical / DP 1-MOV-0663 Shutdown Cooling Recirculation VaM l
Velan Gate 4 in Limitorque SMB/00 10 ft b 469 510 1594 1594 385.4 StabshcallDP 1-MOV-2080 Instrument Air Supply To Containmer t Anchor D Gate 2 in Limitorque SMB/000 5 ftIb 156 155 1170 1790 21.0 Statistical / DP 1-MOV 4415 Main Steam isolation Bypass Vahe Rockwell Globe 2 in Limitorque SMB!000 5 ft Ib 1115 1100 4880 6080 5.5 Comparison 1-MOV-4052 Main Steam isolation Bypass Valve Rockwell Globe 2 iri Limitorque SMBM00 5 ftIb 1115 1100 4880 6080 7.9 Comparison 1-MOV-4142 Refue!ing Water Tank Outlet Valves Velan Gate 18 in Limitorque SMB/0 40 ftIb 17 17 4520 6792 81.5 Stabstical 1490V-4143 Refueling Water Tank Outlet Valves Velan Gate 18 in Limitorque SMB/0 40 ft Ib 17 17 5020 8133 8.5 Statistical 1-MOV-4144 Containment Sump Outlet isolabon Velan Gate 24 in Limitorque SMB/2 60 ftIb 22 22 "22483 "22483 105.8 EPRI PPM 1-MOV-4145 Containment Sump Outlet Isolation Velan Gate 24 in Limitorque SMB/2 60 ftIb 22 22 "22483 "22483 105.8 EPRI PPM 1-MOV-4516 Steam Generator Feedwater Isolabon Velan Gate 16 in Limitorque SMB/2 80 ft Ib 275 275 "27275 35699 0.6 EPRI PPM 1-MOV-4517 Steam Generator Feedwater Isolabon Velan Gate 16 in Limitoraue SMB/2 80 ftIb 275 275 "26151 36986 17.8 EPRI PPM 19
ATTACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-PELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE MOV Valve Informaton Actuator informabon Design Line Thrust Required Field Evaluation Number System / Function Manufacturer Type Size Manufacturer Type / Size Motor Delta P Pressure Bare
- T min
- Margin Method 1-MOV-5462 Containment Normal Drain isolation Velan Gate 4 in Limitorque SMB/00 10 ftIb 50 50 1376 2276 101.0 Statistical 1-MOV-5463 Containment Normal Drain isolation Velan Gate 4 in Limitorque SMB/00 10 ftIb 50 50 1376 2013 69.8 Statistical 1-MOV-6900 Hydrogen Purge Containment Isolation Velan Gate 4 in Limitorque SMB!00 5 ft b 21 6
814 1192 86.4 StatisticallDP 1-MOV-6901 Hydrogen Purga Containment isolation Velan Gate 4 in Limitorque SMB/00 5 ft b 21 6
378 554 332.5 StatishcallDP 1-MOV-6903 Hydrogen Purge Containment Replacement Velan Gate 4 in Lunitorque SMB!00 5 ftIb 21 6
823 1424 108.4 StabsbcallDP Air Isolation.
2-MOV-0269 Chemical and volume Control Syvem to Velan Globe 2 in Limitorque SMB / 000 5 ftIb 0
2488 3974 5439 11.7 Comparison Hioh Pressure Safety injection Header 2-MOV-0399 Shutdown Cooling Heat Exchanger Velan Globe 2 in Lrnitorque SMB / 000 5 ftIb 210 210 2367 3591 26.2 Cwryabui Recirculation 2-MOV-N03 Power-Operated Relief Valve Block Velan Gate 2.S in Limitorque SMB / 000 Sitib 2282 2285 6622 9042 2.2 Companson 2-MOV-0405 Power-Ope ated Rehef Valve Block Velan Gate 2.S in Limitorque SMB / 000 S ftib 2282 2285 6622 7580 2.6 Ccmpanson 2-MOV-0501 Chemcal and Volume CondolSystem; Velan Gate 4 in Limitorque SMB100 7.5 ft Ib 139 145 1740 2012 37.0 Stabshcal Volume Control Tank Outlet Isolation 2-MOV-0504 Chemealare Volume Control System; Ve!an Gate 3 in Limitorque SMB100 5 ftIb 105 139 1376 2381 42.2 StabshcallDP Reactor Coolant Make-up to Volume Control Tank 240V-0508 Chemical and Volume Control System; Velan Gate 3in Limitorque SMB / 00 7.5 ft Ib 154 148 1342 2037 36.6 Statistical / DP Boric Acid Tank to Charging Pump, Bypass 240V-0509 Chemical and Volume Control System; Velan Gate 3 in Limitorque SMB100 7.5 ft Ib 137 137 1338 2031 37.9 Statistical / DP Boric Acid Tank to Charging Pump Bypass 2-MOV-0514 Chemeal and Volume Control System; Velan Gate 3 in Lrnitorque SMB / 00 7.5 ft Ib 154 148 1393 2113 46.9 Statistical / DP Boric Acid Pump to Charging Pump 240V-0615 Low Pressure Safetyinjection; Loop Velan Globe 6 in Limitorque SMB/2 60 ftIb 35 245 4580 6262 437.4 Dynamic Test isolation,11 A 240V-0616 High Pressure Safety injection; Loop Velan Globe 2in Limitorque SMB / 00 25 ft Ib 1269 1282 4574 10699 1.6 Dynamic Test Isabtion,11 A, Normal Header 2-MOV-0617 High Pressure Safety injection; Loop Velan Glooe 2 in Limitorque SMB100 25 ftIb 2723 2723 5842 13818 1.3 Dyname Test isolabon,11A, Altemate Header 2-MOV-0625 Low Pressure Safety injechon; Loop Velan Globe 6 in Limitorque SMB/2 60 ftIb 35 245 6080 8313 304.8 Dynamic Test Isolation,11B 2-MOV-0626 Hgh Pressure Safety injection; Loop Velan Globe 2in Limitorque SMB / 00 25 ftIb 1269 1282 4574 10699 1.6 Dynamic Test Isolabon,11B, Normal Header 2-MOV-0627 High Pressure Safety injecbon; Loop Velan Globe 2 in Lrnitorque SMB / 00 25 ft b 2723 2723 5842 13818 1.3 Dyname Test Isolation,11B. Attemate Header 20
A'ITACIIMEbT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE MOV Valve Information Actuator Information Design Line Thrust Required Field Evaluation Number System / Function Manufacturer Type Size Manufacturer Type / Size Motor Delta P Pressure Bare
- T min
- l Margin Method 2-MOV-0635 Low Pressure Safety injection; Loop Velan Globe 6 in Limitorque SMB/2 60 ft b 35 245 6080 8313 304.8 Dynamic Test isolation,12A 2-MOV-0636 High Pressure Safety injection; Loop Velan Globe 2 in Limitorque SMB / 00 25 ft b 1269 1282 4574 10699 1.6 Dyname Test isolation,12A, Normal Header 2-MOV-0637 High Pressure Safety injection; Loop Velan Globe 2 in Limitorque SMB / 00 25 ftIb 2723 2723 5842 13818 1.3 Dynamic Test isolation,12A, Altemate Header 2-MOV-0645 Low Pressure Safety injection; Loop Velaa Globe 6in Limitorque SMB/2 60 ftIb 35 245 6080 8313 304.8 Dynamic Test 1solabon,12B 2-MOV-0646 High Pressure Safety injection; Loop Velan Globe 2 in Limitorque SMB / 00 25 ftIb 1269 1282 4574 10699 1.6 Dynamic Test isolabon,12B Normal Header 2-MOV-0647 High Pressure Safety injection; Loop Velan Globe 2in Limitorque SMB / 00 25 ftIb 2723 2723 5842 13818 1.3 Dynamic Test isolation,128, A!!emate Header 2-MOV-0651 Shutdown Cooling Retum Isolation Velan Gate 12 in Limitorque SMBl3 100 ftIb 256 256 "47758 "47758 33.5 EPRI PPM 2-MOV-0652 Shutdown Cooling Retum isolation Velan Gate 12 in Limitorque SMBl3 100 ft Ib 253 253 "51347 "51347 24.1 EPRI PPM 240V-0653 High Pressure Safety injection; Header Velan Gate 4 in Limitorque SMB/00 25 ftIb 0
1300 3930 5863 29.5 Dynamic Test Cross Connechon Vane 2-MOV-0654 Hsh Pressure Safety injection; Header Velan Gate 6 in Limitorque SMB/0 40 ft Ib 43 43 5709 7807 32.2 Dynamic Test isolation Vane 2-MOV-0655 High Pressure Safety injection; Header Velan Gate 4 in Lmtorque SMB/00 25 ftIb 0
1300 3930 6928 18.9 Dynamic Test Cross Connecton Valve 2-MOV-0656 High Pressure Safety injection; Header l
Velan Gate 6 in Lmtorque SMBl1 60 ftIb 259 301 5831 9457 90.3 Dynamic Test Isolaticn Vahe 240V-0658 Low Pressure Safety injection Supply to l
Velan Gate 12in Limitorque SMBl0 40 ftIb 0
43 4304 6383 262.2 Dynamic Test Shutdown Cooling Heat Exchanger 240V-0659 Safety injection to Refueling Water Tank i
Velan Gate 4 in Lmtorque SMa00 10 ftIb 1252 1283 7126 8722 8.3 Dyname Test Mini Flow Retum isolation 4
2-MOV-0660 Safety injection to Refueling Water Tank j Velan Gate 4 in Limitorque SMa00 10 ftIb 1252 1283 6876 9094 3.3 Dynamic Test Mini Flow Retum Isolation i
2-MOV-0662 Shutdown Cooling Reorculation Vane i
Velan Gate 4 in Limitorque SMB/00 10 ft b 469 500 1855 1855 337.3 Statistical / DP 2-MOV-0663 Shutdown Cooling Recirculation Valve 8
Velan Gate 4 in Limitorque SMB!00 10 ft Ib 469 500 2197 2197 277.9 Statistical / DP 240V-2080 Instrument Air Supply To Containment
! Anchor D Gate 2 in Limitorque SMB/000 5 ft Ib 156 155 1170 1790 16.0 StabsbcallDP 2-MOV-4045 Main Steam isolation Bypass Valve i RockweR Globe 2 in Limitorque SMB/000 5 ft b 1115 1100 4880 6080 12.6 Comparison 240V-4052 Main Steam isolation Bypass Vane I, Rockwe8 Globe 2in Limitorque SMa'000 5 ft Ib 1115 1100 4880 6080 5.4 Comparison 240V-4142 Refueling Water Tank Outlet Valves Velan Gate 18 in Limitorque SMB/0 40 ftIb 17 17 4520 7175 31.7 Statistical 240V-4143 Refueling Water Tank Outlet Valves b Velan Gate 18 in Limitorque SMB!0 40 ftIb 17 17 4520 7175 76 6 Statistical 21
ATTAClIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 i
SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE i
[
Valve information ActuatorInformaton Design Line Thrust Required Fie!d Evaluation Number System / Function i Manufacturer Type Size Manufacturer Type / Size Motor Delta P Pressure Bare
- T min
- Margin Method 2-MOV-4144 Containment Sump Outlet isolation Velan Gate 24 in Limitorque SMB/2 60 ft Ib 22 22 "22483 "22483 105.8 EPRI PPM 2-MOV-4145 Cuimwat Sump Outlet isolation i
Velan Gate 24 in Limitorque SMB/2 60 ft Ib 22 22 "27385 "27385 70.0 EPRI PPM 2-MOV-4516 Steam Generator Feedwater Isolation i
Velan Gate 16 in Limitorque SMB/2 80 ft Ib 275 275 "28258 34228 24.6 EPRI PPM 2-MOV-4517 Steam Generator Feedwater Isolation L Velan Gate 16 in Limitorque SMB/2 80 ft tb 275 275 "30761 40262 2.9 EPRI PPM
'2 MOV-5462 Containment Normal Drain isolation Velan Gate 4 in Limitorque SMB/00 5 ftIb 50 50 1370 2013 44.8 Statistical l
2410V-5463 Containment Normal Drain isolation i
Velan Gate 4 in Limitorque SMB/00 5 ftib 50 50 867 1268 29.6 Stabshcal 2440V-6900 Hydrogen Purge Containment isolatsi i
Velan Gate 4 in Limitorque SMB/00 5 ftIb 21 6
733 1080 170.9 Statistical / DP 2-MOV-6901 Hydrogen Purge Containment isolation i
Velan Gate 4 in Limitorque SMB/00 5 ftIb 21 6
691 1012 215.8 Statistical / DP 2-MOV-6903 Hydrogen Purge Containment Replacement Velan Gate 4 in Limitorque SMB/00 5 ftIb 21 6
1546 2262 63.4 Statistical / DP Air Isolation l
- DEFINITIONS:
j 1.
Thrust Required Bare: Force cale:ilated from standard Industry gate valve equation T min: Minimum i.irust determined by raising bare thrust to incorporate effects of:
- test equiement accuracy
- torque twitch repeatability
- rate of Icading
-lubricatica degradation and spring pack relaxation 2.
Field Margin Close direction - Itsrgin expressed as a percentage between T min and thrust at torque switch trip Open direction - rrgrcin expressed as a percentage between T min and MOV output 3.
Evaluation Method Comparison:
evaluation based on test results of similar MOVs Statistical:
evaluation based on statistical analysis of Calvert Cliffs dynamic testing Statistical / DP: evaluation based on statistical analysis of Calvert Cliffs dynamic testing and in-situ DP test less than design basis conditions EPRI PPM:
evaluation based on the EPRI Performance Prediction Model
" Thrust values calculated by EPRI PPM 22
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AII'ACIIMENT BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE CAPABILITY PACKAGES MOVs under the scope of GL 89-10 have been divided into 22 groups. Group definition was based on considerations identified in GL 89-10, Supplement 6.
These capability packages document the evaluations performed and support verification that each GL 89-10 Program MOV is capable of operating when required under normal and abnormal design basis conditions.
It should be noted that this grouping of MOVs was to support documentation of operability and was not used to reduced dynamic testing.
GROUP NUMBER APPLICABLE MOVs 1
1 & 2-MOV-616,626,636,646 2
1 & 2-MOV-617,627,637,647 3
1 & 2-MOV-269 4
1 & 2-MOV-399 5
1 & 2-MOV-4045,4052 6
1 & 2-MOV-2080 7
1 & 2-MOV-403,405 8
1 & 2-MOV-504,508,509,514 9
1 & 2-MOV-501 10 1 & 2-MOV-662,663 11 1 & 2-MOV-659,660 12 1 & 2-MOV-5462,5463 13 1 & 2-MOV-6900,6901,6903 14 1 & 2-MOV-653,655 15 1 & 2-MOV-615,625,635,645 16 1 & 2-MOV-654 17 1 & 2-MOV-656 18 1 & 2-MOV-658 19 1 & 2-MOV-651,652 20 1 & 2-MOV-4516,4517 21 1 & 2-MOV-4142,4143 22 1 & 2-MOV-4144,4145 23
ATTACLIMENI BALTIMORE GAS & ELECTRIC COMPANY RESPONSE TO GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE RISK CATEGORIES HIGH RISK MEDIUM RISK LOW RISK LOW-LOW RISK 1/2-MOV 403 1/2-MOV 405 1/2-MOV 617 1/2-MOV 627 1/2-MOV 269 1/2-MOV 399 1/2-MOV 501 1/2-MOV 504 1/2-MOV 4144 1/2-MOV 4145 1/2-MOV 637 1/2-MOV 647 1/2-MOV 615 1/2-MOV 625 1/2-MOV 508 1/2-MOV 509 1/2-MOV 616 1/2-MOV 626 1/2-MOV 635 1/2-MOV 645 1/2-MOV 514 1/2-MOV 662 1/2-MOV 636 1/2-MOV 646 1/2-MOV 653 1/2-MOV 655 1/2-MOV 663 1/2-MOV 654 1/2-MOV 651 1/2-MOV 652 1/2-MOV 4516 1/2-MOV 4517 1/2-MOV 656 1/2-MOV 658 1/2-MOV 659 1/2-MOV 660 1/2-MOV 6900 1/2-MOV 6901 1/2-MOV 4045 1/2-MOV 4052 1/2-MOV 5462 1/2-MOV 5463 1/2-MOV 6903 1/2-MOV 4142 1/2-MOV 4143 1/2-MOV 2080 24
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