AECM-85-0149, Forwards Rev 0 to App a of Spec MP&L-M-189.1, Max Stroke Times for Power Actuated Valves, Providing Max Allowable Stroke Time Values for All Power Operated Valves Subj to Inservice Testing & Addl Relief Requests

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Forwards Rev 0 to App a of Spec MP&L-M-189.1, Max Stroke Times for Power Actuated Valves, Providing Max Allowable Stroke Time Values for All Power Operated Valves Subj to Inservice Testing & Addl Relief Requests
ML20128K621
Person / Time
Site: Grand Gulf  Entergy icon.png
Issue date: 06/28/1985
From: Dale L
MISSISSIPPI POWER & LIGHT CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20128K626 List:
References
AECM-85-0149, AECM-85-149, NUDOCS 8507110085
Download: ML20128K621 (4)


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MISSISSIPPI POWER & LIGHT COMPANY

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Helping Build Mississippi hiB&HalMdB P. O. B O X 164 0, J A C K S O N, MIS SIS SIP PI 39215-1640 June 28, 1985 NUCLEAR LICEN$ LNG & SAFETY DEPARTMENT U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.

20555 Attention:

Mr. Harold R. Denton, Director

Dear Mr. Denton:

SUBJECT:

Grand Gulf Nucicar Station Units 1 and 2 Docket Nos. 50-416 and 50-417 License No. NPF-29 File: 0290/M-189.1 IST Pump & Valve Program - Maximum Stroke Times & Additional Relief Requests AECM-85/0149 Mississippi Power & Light (MP&L) submitted the Grand Gulf Nuclear Station (GCNS) Unit 1 Pump and Valve Inservice Test (IST) Program to the NRC on August 26, 1983. During a working meeting conducted on November 27, and 28, 1984 between MP&L and members of your staff to discuss the program, the NRC staff requested that MP&L provide a list of maximum allowable stroke time values for all power operated valves subject to inservice testing. MP&L's response to the NRC staff's request is provided in Attachment 1 to this letter. MP&L has also identified the need for three (3) additional relief requests (Attachment 2) to Specification MP&L M-189.1 Rev. O.

These relief requests are in addition to those provided in MP&L letter AECM-85/0121 dated June 17, 1985.

Attachment I describes two methodologies which were utilized in calculating the maximum allowable stroke time values. The maximum value was computed by a statistical method (Method 1) when there was sufficient data to ensure a statistically valid base.

In the case where a " normal" range could not be determined, a slightly larger margin was added to the average stroke time (Method 2).

For some of the subject valves listed in Attachment 1 the maximum allowable stroke times utilized are the maximum isolation times in CGNS Technical Specification Tables 3.6.4-1 and 3.6.6.2-1.

The maximum allowable stroke time for the valves listed in Attachment 1 and the relief requests provided in Attachment 2 to this letter will be incorporated into the CGNS IST program by commercial operation, which is presently scheduled for July 1, 1985.

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AECM-85/0149 Page 2 If there are any questions, please contact this office.

'Yours truly, L. F. Dale Director KED/MLC/JGC:dem Attachment cer Mr. J. B. Richard (w/a)

Mr. O. D. Kingsley, Jr. (w/a)

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

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

Mr. G. B. Taylor (w/o)

Mr. R. C. Butcher (w/a)

Mr. James M. Taylor, Director (w/a)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 Mr. Herb Rockhold (w/a)

EG&G Idaho, Inc.

P.O. Box 1625 Idaho Falls, Idaho 83415 J0P14AECM85061401 - 2

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.9 Contained herein are maximum allowable stroke time values for all power 6

operated valves subject to inservice testing.

The " Safety Position" indicates the position to which the valve must be stroked and timed.

Based on ASME Section XI, IWV-3417, an increase in stroke time of 50% for quick acting valves or an increase of 25% for slower valves is well within acceptable limits since no immediate action is required. Therefore, the maximum stroke times have been computed as follows.

Method 1 For groups of valves where sufficient data exists to ensure a valid statistical base, the maximum is computed by the greater of adding 3 standard deviations to the mean 02) to define the normal range and then adding 10% to that normal range or a 10% increase beyond the Code " alert" values (1.35 1 for stroke times exceeding 10 seconds and 1.6 R for stroke times less than or equal to 10 seconds). The " alert" values of the Code will be observed.

The mean (Y) is not subject to frequent change, but is subject to periodic updating as the database grows.

Method 2 The " normal" range cannot always be determined for a group or for

' individual valves or the valves may not follow the trends discussed above.

In this case, a slightly larger margin is added to the average stroke time by use of the following formula.

2 Maximum = 2.058R - 0.0272 for x lecs than or equal to 26 seconds This is derived from the relationship in Figure 1.

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Y (MULTIPLIER) 1.35- -

2 26 X(AVERAGE STROKE TIME)

FIGURE 1

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This method avoids overlap which occurs with the range method of Section XI.

The maximum for valves with average stroke times of greater than 26 seconds is (1.35)R.

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Regardless of which method is used, the following rules apply.

' ' i) Maximum $E Analytical Requirements

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.ii) Maiiiiiium "$i""

TeEhnical" Specific'tions *'

a iii) Maximum $i (1.25) R (Design Specification Value) 1

  • Note: In cases where the Technical Specifications are more conservative than the methods described above, the Technical Specification limit will be used unless a Technical Specification change is made.
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MP&L plans to use Method I wherever possible in the future as more is learned about valve behavior, and information is gathered for each specific valve and actuator combination.

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