ML20137C228
| ML20137C228 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/14/1997 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-97068, NUDOCS 9703240188 | |
| Download: ML20137C228 (11) | |
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Log # TXX-97068 lllllllll" =
File # 10010.1 L
4 905.2 (clo)
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Ref. # 10CFR50.55a(f) 10CFR50.55a(a)(3)(i) 1UELECTRIC' March 14, 1997 C. Lance Terry Group Mce President U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i DOCKET NOS. 50-445 AND 50-446 RELIEF REQUEST V-8 TO THE UNIT 1/ UNIT 2 IN$ERVICE TESTING PLAN FOR PUMPS AND VALVES i
(1989 EDITION OF ASME CODE. SECTION IX, N0 ADDENDA, UNIT 1 INTERVAL START DATE: AUGUST 13. 1990, FIRST INTERVAL:
UNIT 2 INTERVAL START DATE: AUGUST 3, 1993. FIRST INTERVAL)
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REF:
- 1) NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants," April 1995
- 2) TV Electric letter logged TXX-96055 from Mr. C..L. Terry to NRC dated March 14, 1997 TV Electric is requesting relief in accordance with the requirements of 10CFR50.55a(a)(3)(1).
This request is consistent with the guidelines of NUREG-1482 (Reference 1).
This transmittal submits relief request V-8 (Attached) for your approval.
Reference 2 describes th program for Generic Letter 96-05 which is addressed in the Relief request, and is enclosed for your review.
If you have any questions, please contact Obaid Bhatty at (817) 897-5839.
Sincerely, e,1 %
C. L. Terry I
9703240188 970314 By:
@ b.
PDR ADOCK 05000445 Roger D. Walker G
PDR Regulatory Affairs Manager I
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08:ob Attachment
{
<} f Enclosure cc:
Mr. J. E. Dyer, Region IV Mr. J. I. Tapia, Region IV ggggggggggg Mr. T. J. Polich, NRR Mr. G.
Bynog, TDLR Resident Inspectors, CPSES P. O. Box 1002 Glen Rose Texas 76043
- AttachmenttoTXX-97068
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RELIEF REQUEST N0.
V-8 SYSTEM See attached table VALVE NUMBER See attached table CATEGORY See attached table CLASS See attached table DESCRIPTION See attached table j
BASIS FOR RELIEF As discussed in NRC GL 96-05 stroke time testing of M0V's has been recognized as ari ineffectual method of ensuring MOV operational readiness.
Also as required in NRC GL 96-05 each licensee is to develop a periodic verification program to ensure operational readiness for the life of the plant.
The GL provides guidance on the periodic verification program. As such, the performance of such testing (i.e. exercising each M0V during a fuel cycle, static diagnostic testing and
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confirmatory dynamic testing linked with a preventative maintenance program) will more adequately ensure operational readiness.
TEST REQUIREMENT OM Part 10 para. 4.2.1.4(b),
The stroke time of all power-operated valves shall be measured to at~
least the nearest second." Test intervals are defined in OM Part 10 para. 4.2.1.2.
SUBSTITUTE TEST Motor Operator Valve (MOV) performance will be verified in accordance with the NRC GL 96-05, " Period Verification of Design Basis Capability of Safety-Related Motor Operated Valves" requirement _.
The CPSES program is described in TV Electric response to GL 96-05 under TXX-97055 submitted March 17. 1997.
The CPSES M0V Periodic Verificatiori Program will exercise each M0V once per fuel cycle and statically test each MOV once within a test frequency determined by probabilistic risk assessment and deterministic inputs such as CPSES plant specific equipment history, industry events and manufacturers recommendations.
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Attachment to TXX-97068 Page 2 of 9 System Valve Number Category Class Description Auxiliary Feedwater HV-2480 B
3 Auxfeedwater Pump Emergency Supply Flowpath HV-2481 B
3 Auxfeedwater Pump Emergency Supply Flowpath HV-2482 B ~
3 Auxfeedwater Pump Emergency Supply Flowpath HV-2484 B
3 Condensate System to Condensate Storage Tank Isolation to Preclude Tank Overpressurization HV-2485 B
3 Condensate System to Condensate Storage Tank Isolation to Preclude Tank Overpressurization HV-2491A B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2491B B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2492A B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2492B B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2493A B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2493B B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2494A B
2 Containment Isolation & AFW to Faulted SG Flow Isolation HV-2494B B
2 Containment Isolation & AFW to Faulted SG Flow Isolation m.
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Attachment to TXX-97068 Page 3 of 9 System Valve Number Category Class Description Component Cooling Water X-PV-3583 B
3 Control Room A/C Condenser Cooling Flow Control X-PV-3584 B
3 Control Room A/C Condenser Cooling Flow Control X-PV-3585 B
3 Control Room A/C Condenser Cooling Flow Control X-PV-3586 B
3 Control Room A/C Condenser Cooling Flow Control HV-4512 B
3 Train A to Train B Crosstie Isolation HV-4513 8
3 Train A to Train B Crosstie Isolation HV-4514 B
3 Train A to Train B Crosstie Isolation HV-4515 B
3 Train A to Train B Crosstie Isolation HV-4524 B
3 Non-Safety Loop Flowpath Isolation HV-4525 B
3 Non-Safety Loop Flowpath Isolation HV-4526 B
3 Non-Safety Loop Flowpath Isolation HV-4527 B
3 Non-Safety Loop Flowpath Isolation HV-4572 B
3 RHR Heat Exchanger Cooling Flowpath HV-4573 B
3 RHR Heat Exchanger Cooling Flowpath HV-4574 8
3 Containment Spray Heat Exchanger Cooling Flowpath HV-4575 8
3 Containment Spray Heat Exchanger Cooling Flowpath HV-4696 A
2 Containment Isolation & RCP Thermal Barrier Rupture Isolation HV-4699 B
2 Passive Pipe Break Isolation (Inside Containment)
HV-4700 A
2 Containment Isolation & Passive Pipe Break Isolation (Inside Containment)
HV-4701 A
2 Containment Isolation HV-4708 A
2 Containment Isolation HV-4709 A
2 Containment Isolation & RCP Thermal Barrier Rupture Isolation
Attachment to TXX-97068 Page 4 of 9 System Valve Number Category Class Description Chemical & Volume Control LCV-01128 B
2 ECCS Flowpath Boundary & Isolation of VCT Cover Gas from Charging Pumps
2 ECCS Flowpath Boundary & Isolation of VCT Cover Gas from Charging Pumps' Suction Header (upon low VCT level) & Boron Dilution Flowpath Isolation LCV-0112D B
2 ECCS Injection Flowpath & Boration Flowpath/ECCS Recirculation Flowpath Boundary LCV-0112E B
2 ECCS Injection Flowpath & Boration Flowpath/ECCS Recirculation Flowpath Boundary 8100 A
2 Containment Isolation 8104 8
2 Boration Flowpath 8105 A
2 Boration Flowpath/ECCS Flowpath Boundary & Containment Isolation 8106 B
2 Boration Flowpath/ECCS Flowpath Boundary 8109 B
2 ECCS Flowpath Boundary 8110 B
2 ECCS Flowpath Boundary 8111 B
2 ECCS Flowpath Boundary 8112 A
2 Containment Isolation 8351A B
2 Containment Isolation 8351B B
2 Containment Isolation 8351C B
2 Containment Isolation 8351D B
2 Containment Isolation 8511A B
2 High Head Safety Injection Pump Miniflow Path /ECCS Recirculation Flowpath Boundary
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Attachment to TXX-97068 Page 5 of 9 System Valve Number Category Class Description Chemical & Volume Control 8511B B
2 High Head Safety Injection Pump Miniflot-Path /ECCS Recirculation Flowpath Boundary 8512A B
2 ECCS Recirculation Flowpath Boundary 85128 B
2 ECCS Recirculation Flowpath Boundary Containment Spray LV-4754 8
3 Chemical Additive Flowpath/ Chemical Additive Tank Isolation LV-4755 B
3 Chemical Additive Flowpath/ Chemical Additive Tank Isolation HV-4758 B
2 Sump Recirculation Flowpath Boundary HV-4759 B
2 Sump Recirculation Flowpath Boundary FV-4772-1 B
2 Pump Miniflow Flowpath/ Containment Spray Flowpath Boundary FV-4772-2 B
2 Pump Miniflow Flowpath/ Containment Spray Flowpath Boundary FV-4773-1 B
2 Pump Miniflow Flowpath/ Containment Spray Flowpath Boundary FV-4773-2 B
2 Pump Miniflow Flowpath/ Containment Spray Flowpath Boundcry HV-4776 A
2 Containment Spray Flowpath/ Containment Isolation HV-4777 A
2 Containment Spray Flowpath/ Containment Isolation HV-4782 B
2 Sump Recirculation Flowpath/ Containment Isolation HV-4783
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Sump Recirculation Flowpath/Contdinment Isolation Reactor Coolant 8000A B
1 Post Accident Vent Path / Vent Path Isolation & Reactor Coolant Pressure Boundary 8000B B
1 Post Accident Vent Path / Vent Path Isolation & Reactor Coolant Pressure Boundary
Attachment to TXX-97068 Page 6 of 9 System Valve Number Category Class Description
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Residual Heat Removal FCV-0610 B
2 Pump Miniflow Path /ECCS & RHR Flowpath Boundary FCV-0611 B
2 Pump Miniflow Path /ECCS & RHR Flowpath Boundary 8701A A
1 RHR Flowpath/ Containment Isolation & Reactor Coolant Pressure Boundary 8701B A
1 RHR Flowpath/ Containment Isolation & Reactor Coolant Pressure Boundary 8702A A
1 RHR Flowpath/ Reactor Coolant Pressure Boundary 87028 A
1 RHR Flowpath/ Reactor Coolant Pressure Boundary 8716A B
2 ECCS Injection Flowpath/ECCS Recirculation Flowpath Boundary 8716B B
2 ECCS Injection Flowpath/ECCS Recirculation Flowpath Boundary Safety Injection 8801A B
2 ECCS to Cold Legs Flowpath & Boration Flowpath/ Containment Isolation & Passive Pipe Break Isolation 8801B B
2 ECCS to Cold Legs Flowpath & Boration Flowpath/ Containment Isolation & Passive Pipe Break Isolation 8802A B
2 ECCS to Hot Legs Flowpath/ECCS to Cold legs Flowpath Boundary &
Containment Isolation & Passive Pipe Break Isolation 88028 B
2 ECCS to Hot f.egs Flowpath/ECCS to Cold Legs Flowpath Boundary &
CMtainment Isolation & Passive Pipe Break Isolation 8804A B
2 ECCS Recirculation Flowpath/ Passive Pipe Break Isolation 8804B B
2 ECCS Recirculation Flowpath/ Passive Pipe Break Isolation 8806 B
2 ECCS Flowpath Boundary (during Recirculation) 8807A B
2 ECCS Recirculation Flowpath/ Passive Pipe Break isolation 8807B B
2 ECCS Recirculation Flowpath/ Passive Pipe Break Isolation
Attachment to TXX-97068 Page 7 of 9 System Valve Number Category Class Description Safety Injection 8808A B
2 ECCS from Accumulators to Cold Legs Flowpath 8808B B
2 ECCS from Accumulators to Cold legs Flowpath 8808C B
2 ECCS from Accumulators to Cold legs Flowpath 8808D B
2 ECCS from Accumulators to Cold Legs Flowpath 8809A A
2 ECCS to Cold Legs Flowpoth/ECCS to Hot Legs Flowpath Boundary &
Passive Pipe Break Itolation & Containment Isolation 8809B A
2 ECCS to Cold legs Flowpath/ECCS to Hot Legs Flowpath Boundary &
Passive Pipe Break Isolation & Containment Isolation 8811A B
2 ECCS Recirculation Flowpath/ Containment Isolation & Passive Pipe Break Isolation 8811B B
2 ECCS Recirculation Flowpath/ Containment Isolation & Passive Pipe Break Isolation 8812A C
2 ECCS Recirculation Flowpath Boundary & Shutdown Cooling Flowpath Boundary (during Safety Grade Cold Shutdown) 8812B B
2 ECCS Recirculation Flowpath Boundary & Shutdown Cooling Flowpath Boundary (during Safety Grade Cold Shutdown) 8813 B
2 ECCS Recirculation Flowpath Boundary 8814A 13 2
ECCS Recirculation Flowpath Boundary 8814B B
2 ECCS Recirculation Flowpath Boundary 8821A B
2 ECCS to Cold Legs Flowpath/ECCS to Hot legs Flowpath Boundary &
Passive Pipe Break Isolation 8821B B
2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary &
Passive Pipe Break Isolation
Attachment to TXX-97068 Page 8 of 9 System Valve Number Category Class Description Safety Injection 8835 B
2 ECCS to Cold Legs Flowpath/ECCS to Hot Legs Flowpath Boundary &
Containment Isolation & Passive Pipe Break Isolation 8840 A
2 ECCS to Hot Legs Flowpath/ECCS to Cold Legs Flowpath Boundary &
Containment Isolation & Passive Pipe Break Isolation 8923A B
2 Passive Pipe Break Isolation 8923B B
2 Passive Pipe Break Isolation 8924 B
2 Passive Pipe Break Isolation Service Water HV-4286 B
3 Service Water Flcwpath/ Throttling during Pump Start HV-4287 B
3 Service Water Flowpath/ Throttling during Pump Start HV-4393 B
3 Service Water Flowpath HV-4394 B
3 Service Water Flowpath HV-4395 B
3 AFW Pump Emergency Supply Flowpath HV-4396 B
3 AFW Pump Emergency Supply Flowpath Containment Isolation HV-6082 A
2 Containment Isolation HV-6083 A
2 Containment Isolation HV-6084 A
2 Containment. Isolation HV-4075B A
2 Containment Isolation HV-4075C A
2 Containment Isolation HV-5540 A
2 Containment Isolation HV-5541 A
2 Containment Isolation HV-5542 A
2 Containment Isolation
Attachment to TXX-97068 Page 9 of 9 System Valve Number Category Class Description Containment Isolation HV-5543 A
2 Containment Isolation HV-5562 A
2 Containment Isolation HV-5563 A
2 Containment Isolation LEGEND:
Catagory A - Valves for which seat leakage is limited to a specific maximum amount in the closed positon for fulfillment of their required safety function (s).
Catagory B - Valves for which seat leakage in the closed position is inconsequential for fulfillment of their required safety function (s).
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ENCLOSURE TO TXX 97068 TXX-97055, response _to Generic Letter %-05, " Periodic Verification of Design basis capability of Safety related Motor operated Valves" I
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- Log # TXX-97055 MM File # 10035
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Ref. # 10CFR50.54(f)
T C-GL 96-05 t
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1UELECTRIC*
March 14, 1997 i
C. Lance Terry Gmup Mce President l
U. S. Nuclear Regulatory Commission l
' Attn.:
Document Control Desk Washington..D.C. 20555-0001
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i DOCKET N05. 50-445 AND 50-446 UNITS 1 AND 2 l
RESPONSE:TO GENERIC LETTER 96-05. " PERIODIC VERIFICATION OF l
DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-0PERATED l
VALVES" REF:
1.
TV Electric letter logged TXX-96503 from Mr. C. Lance Terry, to NRC dated November 15, 1996 2.
TV Electric letter logged TXX-97068 from Mr. C. Lance Terry, to NRC dated March 14, 1997 l
3.
TV Electric letter logged TXX-95260 from Mr. C. Lance Terry to NRC dated November 27. 1995 4.
TV Electric letter logged TXX-96371 from i
Mr. C. Lance Terry to NRC dated June 3. 1996 On September'18. 1996, the NRC issued Generic Letter (GL) 96-05. " Periodic l
Verification of Design-Basis Capability of Safety-Related Motor-0perated Valves,"
Pursuant to Section 182a of the Atomic Energy Act of.1954, as amended, and i
10 CFR-50.54(f), this letter provides TV Electric's response to Required j
Response Item 2 in the subject generic letter. The response to Item I was j
submitted via reference 1.
Additionally, via this letter TV Electric is amending the time frame l
stated in Reference 1 for implementation of GL 96-05 recommendations from-i the sixth refueling outage for CPSES Unit 1 and the third refueling outage for CPSES Unit 2. to: the seventh refueling outage for CPSES Unit 1 and i
the fourth refueling outage for CPSES Unit 2.
This extension is required I
to enable development of the MOV periodic verification program described t
below' Because of the extensive nature of the current GL 89-10 program (as described in Section 1.0 below). TU Electric considers this extension is acceptable.
Section 1.0 describes features of the present program.
W
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P. O. Box 1002 Glen Rose Texas 76043 I
N'P OfGD
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Page 2 of 8 NRC GL 96-05 Reauested Actions:-
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Each addressee of tihis generic letter is' requested to o
establish a program. or to ensure the effectiveness of its current program, to verify on a periodic basis that t
safety-related Motor Operated Valves (MOVs) continue to be capable of performing their safety functions within the current licensing bases of the facility.
The program should ensure that changes in required performance resulting from i
degradation (such as those caused by age) can be properly
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identified and accounted for. Addressees that have developed 5
periodic verification programs in response to GL 89-10 should l
review those programs to determine whether any changes are appropriate in light of the information in this generic letter.
NRC GL 96-05 Reauired Resoonse, 3
All addressees are required to submit the following written response to this generic letter:
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'1, Within 60 days from the date of this generic letter, a i
written response indicating whether or not the addressee i
will_ implement the action (s) requested herein.
If the addressee intends to implement the requested action (s).
the addressee shall submit a schedule for completing implementation. If an' addressee chooses not to i
implement the requested action (s)._the addressee shall submit a description of any proposed alternative course
.l of. action. the schedule for completing the alternative course of action (if applicable). and the safety basis for determining the acceptability of the planned alternative course of action.
2.
Within 180 days from the date of this generic letter. or upon notification to NRC of completion of GL 89-10 (whichever.is later), the addressee shall submit a written summary description of its M0V periodic verification program established in accordance with the Requested Actions paragraph or the alternative course of action established by the addressee in response to item 1 above.
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-TU Electric Resoonse:
l Item ~1:
TU Electric intends to implement the actions requested in GL 96-05. The acogram will be implemented during the seventh refueling outage for CPSES Jnit 1 and the fourth refueling outage for CPSES Unit 2.
Item 2:
A summary description'of the M0V periodic verification program established in accordance with the Requested Actions is as follows.
MOV Periodic Verification Proaram 1.0 Backaround NRC Generic Letter (GL) 89-10 recommended that each nuclear power plant establish a program.to demonstrate that safety-related motor-operated valves (MOVs) are capable of performing their design basis functions.
In response, CPSES developed.a program which included i
(1) analysis of MOV design basis conditions and performar.ce requirements, (2) testing to determine and confirm correct MOV operation and switch settings, including margins for performance degradations, and (3) improved maintenance, periodic diagnostic testing, and performance monitoring of MOVs to ensure that MOV i
operability is maintained throughout the life of the plant.
Although GL 89-10 included recommendations for long term periodic verification of MOV performance, GL 96-05 provides current NRC guidance." It is TU Electric's understanding that GL 96-05 supersedes GL 89-10 and its supplements with regard to MOV periodic i
verification.
The CPSES MOV periodic verification program addresses M0V periodic testing intervals, potential actuator and valve performance degradation, assurance of operational readiness over the periodic test interval. M0V performance monitoring and preventative maintenance.
j 2.0 Proaram Scooe The CPSES GL 96-05 program MOV scope is the.same as the previously developed GL 89-10 program M0V scope.
3.0 Testino 3.1 Static Testing l
The periodic verification methodology at CPSES is typically a static i
diagnostic test in which operational readiness under maximum design basis DP conditions is demonstrated by satisfying established l
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TXX-97055 Page 4 of 8 r
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acceptance criter1a. The magnitudes of Rate of Loading factors.
valve factors, and other factors are consistent with the results of extensive baseline testing performed in response to GL 89-10 under L
both static and dynamic conditions.
Maximum postulated valve i
factors have been determined by statistical means for each group of l
rising stem MOVs. Valve groups were determined in the GL 89-10 program and are based on being of the same manufacturer, model and size. Additional margins will be provided for degradation to increase the valve factors beyond the maximum postulated values.
3.2 Dynamic Testing The CPSES MOV program has accounted for the factors necessary to enable periodic MOV diagnostic testing under static conditions-to verify the continued operationel readiness of MOVs under design basis DP conditions. However. CPSES will perform periodic dynamic
-testing of a sample.of MOVs to obtain additional data to ensure assumed MOV performance bounds actual MOV performance.
Several GL 96-05 MOVs will be selected for periodic dynamic testing.
The valves selected will be a mixture of both Unit 1 and Unit 2 MOVs. The selection is based on:
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(1) the ability to perform the dynamic tests without creating an undue risk to plant safety.
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(2) the performance of the individual MOV relative to similar MOVs in previous tests, and (3) the safety significance of the M0V.
Dynamic test results will be extrapolated to all valve groups.
If periodic dynamic test results reveal no significant changes in valve performance, periodic dynamic test requirements will be reevaluated.
Data collected within the first five years will be used to validate assumptions made in justifying periodic static test intervals
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greater than five years. Data collected during and after the first five years will also be used to provide continued confirmation of the adequacy of the overall program.
3.3-Stroke Time Testing Please refer to TV Electric Relief Request V-8 submitted for approval under TU Electric letter (Reference 2). Per relief request V-8 TU Electric proposes to perform (1) periodic static MOV diagnostic testing to the frequencies identified in Section 4.0 and (2) exercising of the MOV once per cycle in lieu of the ASME Section XI required stroke-time testing.
Leak rate testing requirements of l
10CFR50 App., J and the CPSES IST Program Plan will continue unchanged.
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3.4 Joint Owners Group Testing Program
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TU Electric is participating in a joint MOV testing program with the 1
Boiling Water Reactor (BWR) and Westinghouse Owners Groups and will use, if appropriate, results of that program.
4.0 Periodic Static Verification Test Frecuency The maximum interval between static verification tests is determined in two steps:
Step 1. A relative risk assessment will categorize the MOVs into either of two groups: "more safety significant" or "less safety significant." The more safety significant components (MSSC) will be assigned a six year " Maximum Static Test Interval" between diagnostic tests, and the less safety significant components (LSSC) will be assigned a 10 year
" Maximum Static Test Interval" between diagnostic tests. The risk assessment methodology is described in Ref. 3 and 4 which were submitted as part of the pilot plant project on Risk Informed IST.
Step 2.
A deterministic consideration of design margins will take place. This step accounts for factors such as, diagnostic instrumentation uncertainties, actuator repeatability, maximum postulated valve factors, margin for degradation, minimum postulated motor capability to deliver torque to the valve stem, and maximum postulated stem factor changes over the interval between diagnostic tests. The maximum test interval will be reduced from the 6 year or 10 year limit as needed to accommodate the more restrictive design margin.
5.0 Performance Monitorina Proaram For each GL 96-05 M0V CPSES will use MOV performance parameters collected during static diagncstic testing (and dynamic diagnostic testing for those MOVs which are tested under dynamic conditions) to monitor MOV performance.
In addition to monitoring the values of performance parameters, several relationships between performance parameters may be useful in detecting and isolating performance changes, and will also be monitored.
The M0V will be monitored for changes in its performance from baseline tests.
Each MOV's performance will be compared with the typical performance range for similar MOVs. Corrective actioqs will be taken as appropriate.
Values of the measured parameters and their relationships will be compared with the values used in the MOV design calculation.
If test results indicate a revision of the calculation is necessary, the revised calculation will be used to verify that the previously
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Page.6 of 8 1mplemented switch' settings and the motor capabilities of all i
affected MOVs continue to be acceptable-for.~the test interval The periodic test interval will be changed if necessary. These program requirements will provide assurance that the design calculation is appropriately maintained, and that the intervals between periodic verification tests are appropriate for the as-left settings and motor capability.
6.0 MOV Preventative Maintenance Procram Actuator refurbishment including grease changes will be scheduled-to.
ensure grease degradation and component wear are not excessive.
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The adequacy of the maintenance program for actuators, packing, j
valves, and their power sup) lies will be~ monitored.
Improvements will be made where practica)le to increase the reliability of the MOVs.
For-example, valve seat and guide maintenance. butterfly valve elastomer seat and bearing maintenance. packing maintenance stem thread lubrication maintenance.' actuator gearbox and limit switch grease maintenance, and MOV power sup)1y (MCC) maintensnce will be adjusted as needed to maintain a higi level of confidence in l
the. operational, readiness of the MOVs.
-l If valves are disassembled (such.as to replace a. body-bonnet i
gasket), the internals will typically be' inspected. Such inspection.
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1s' intended to identify damage, degradation, or sharp leading edges -
of the gate guides, gate seats, or body seats.
Any sharp leading i
edges will be dulled as.a standard maintenance activity.
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The frequencies of the preventive maintenance ' activities are based on vendor recommendations. industry data, and CPSES specific data.
7.0 EPRI MOV Performance Prediction Methodoloav As an alternative to dynamic testing GL 96-05 states that under certain conditions the EPRI MOV Performance Prediction Program Methodology provides bounding results and may be used in conjunction with static testing alone to meet the recommendations of GL 96-05.
At this time CPSES has not adopted the EPRI MOV Performance Prediction Methodology to determine the required thrusts or torques of installed MOVs.- as CPSES performed. sufficient dynamic testing of each MOV type during GL-89-10 " baseline" testing.
CPSES has grouped similar valves, statistically analyzed the test results, and applied the bounding results of the analyses to all of the valves in the i
group. However. CPSES may elect to use the EPRI methodology at a later date.
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Page 7 of 8 If you have any questions. please contact Obaid Bhatty at (817) 897-5839.
Sincerely.
O, $, %erry C. L. T By:
M Rog'er (T. Walker Regulatory Affairs Manager OB/ob Attachment cc:
Mr. J. E. Dyer. Region IV Mr. J. I. Tapia. Region IV Mr. T. J. Polich. NRR Resident Inspectors, CPSES
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!. to TXX-97055 ~
j, Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Texas Utilities Electric Company
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Docket Nos. 50-445
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and 50-446 (Comanche Peak Steam Electric
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Station, Units 1 & 2)
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I AFFIDAVIT Roger D. Walker being duly sworn, hereby de)oses and says that he is the Regulatory Affairs Manager for Comanche Peat Steam Electric Station of TV Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this Response to Generic Letter 96-05, " Periodic Verification of Design-basis Capability of Safety-Related Motor-0perated Valves".: that he is familiar with the content thereof: and that'the matters set forth therein are true and correct to the best of his knowledge, information and belief.
& h' Rostfr D. Walker Regulatory Affairs Manager STATE OF TEXAS
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COUNTY OF
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Subscribed and sworn to before me, on this I
day of N OA4 A >
1997.
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--~-~._.
CAROLYN L COSENTING I fsNo!$$
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Notary Puplic 2
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