ML20137C276

Provides Util Required 180-day Response to GL 96-05 Request That Licensees Establish Program,Or Ensure Effectiveness of Current Program,To Verify on Periodic Basis That SR MOVs Continue to Be Capable of Performing Their Safety Functions

ML20137C276
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	03/17/1997
From:	Dewease J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-05, GL-96-5, NUDOCS 9703240205
Download: ML20137C276 (8)

Text

Ent:rgy Oper; tion 3. Inc. i PO. Box 31995 1

= ENTERGY a-soo.us 39286-1995 Tei C41368 5760 Fax 601368 5768 Jerrold G. Dewease I

Voe Prescent Ogeratons Stwort ,

March 17,1997 U.S. Nuclear Regulatory Commission Document Control Desk

, Mail Stop PI-37 l Washington, DC 20555

Subject:

NRC Generic Letter 96-05," Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," 180 Day Response Arkansas Nuclear One Grand Gulf Nuclear Station Units 1 & 2 Docket No. 50-416 Docket Nos. 50-313 & 50-368 License No. NPF-29 License Nos. DPR-51 & NPF-6 River Bend Station Waterford 3 Steam Electric Station  :

Docket No. 50-458 Docket No. 50-382 License No. NPF-47 License No. NPF-38 1

CNRO-97/00004  ;

\ \

J Ladies and Gentlemen:

Generic Letter (GL) 96-05 requested licensees to establish a program, or to ensure the d>

effectiveness ofits current program, to verify on a periodic basis that safety-related motor operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility. The program should ensure that changes in valve performance resulting from degradation can be identified and addressed appropriately.

Specifically, the GL requested, that within 180 days from the date of the letter, or upon notification to the NRC of completion of GL 89-10 (which ever is later), the addressee shall submit a written summary description ofits MOV periodic verification program.

As discussed in the Entergy Operations, Inc. (EOI)'s 60 day response to GL 96-05, dated November 15,1996, EOI has developed a periodic verification program that will ensure long temi design basis capability of the safety-related MOVs within the scope of GL 96-05.

This program is documented in EOI Company Procedure DC-110," Periodic Verification,"

which became effective January 27,1997. A summary of the EOI program is contained in the Attachment.

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Generic Letter 96-05,180 Day Response March 17,1997  ;

. , CNRO-97/0004  ;

- Page 2 of 3  :

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.In response to GL 96-05, a Joint Owners Group (JOG) was established to support - ,

- development of a common approach for establishing an MOV periodic verification

. program. The program provides a basis for addressing the potential degradation in required thrust or torque under dynamic conditions based on shared in-plant test data. EOI is a member of the JOG, in fact, the EOI periodic verification program provided some of the

- basis for the JOG Topical Report (Reference NEDC-32719, approved March 6,1997). . EOI I. plans to continue active participation in JOG activities, including sharing of dynamic valve  !

. test data, to ensure that our programs implement the best industry practices. Consequently, it is expected that the EOI company procedure (DC-110) will be updated upon consideration of future industry lessons learned such as those resulting from the recent  !

NRC review of the draft JOG Topical Report and upon future issuance of the -

corresponding NRC Safety Evaluation Report.

Company Procedure DC-110 establishes general program guidance and methodology to be implemented at each EOI site in site specific programs. As discussed in the 60-day response, the site specific programs will be implemented by the first scheduled refueling outage following this response at each site except for Arkansas Nuclear One and Waterford

3. Due to the proximity of upcoming refueling outages at these sites, their respective programs will be implemented within 120 days after completion of the respective outages. l In accordance with the actions requested by the subject generic letter, provided herewith is EOI's 180 day response. This response represents EOl's position for all four ofits nuclear sites and supersedes any previous commitments to periodic testing made in accordance with the GL 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance" '

program response.

Sincerely,.

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Generic Letter 96-05,180 Day Response March 17,1997

. . CNRO-97/0004 Page 3 of 3 cc:

1 Mr. J. E. Dyer NRC Resident Inspector U.S. Nuclear Regulatory P. O. Box 1051 Commission St. Francisville, LA 70775 Region IV 611 Ryan Plaza Drive, Suite 400 I Arlington, TX 76011-8064 i

Mr. J. N. Donohew NRC Resident Inspector I Office of Nuclear Reactor P. O. Box 310 Regulation London, AR 72847 j U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 Mr. George Kalman NRC Resident Inspector U.S. Nuclear Regulatory P. O. Box 399 l Commission Port Gibson, MS 39150 Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville,MD 20859 Mr. C. P. Patel NRC Resident Inspector  ;

Office of Nuclear Reactor P. O. Box 822 Regulation Killona, LA 70066 U.S. Nuclear Regulatory Commission Mail Stop 13H3  ;

Washington, D.C. 20555  !

Mr. David L. Wigginton U. S. Nuclear Regulatory Commission l Mail Stop 13-H-3 )

One White Flint North )

11555 Rockville Pike Rockville, MD 20859

Attachment To CNRO-97/00004 I l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) j

)  !

Entergy Operations, Incorporated ) 1 Arkansas Nuclear One, Units 1&2 ) Docket Nos. 50-313 & 50 368 Grand Gulf Nuclear Station ) Docket No. 50-416 River Bend Station ~ ) Docket No. 50-458 Waterford 3 Steam Electric Station ) Docket No. 50-382 AFFIDAVIT I, J. G. Dewcase, being duly swom, state that I am Vice President, Operations Support, of .

Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc.,1 am authorized by I Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this

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document; that I signed this document as the Vice President, Operations Support, of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief.

Du a W MLA #

J. G. Dewcase STATE OF MISSISSIPPI COUNTY OF HINDS i

SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and ,

State above named, this l1% day of m a eh ,1997. I (SEAL) _

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Notary Public NOTAnY PLOLC STATE OF M'SSIS$1PPI AT LARG6 "Y '06/20!cN EXPi;CS: A.; gust 10.1997 00NDED THRU HDDEN MAftC41ETT4,ING, '

M.y commission expires:

Attachment To CNRO-97/00004 Page1 of4

SUMMARY

EOI Safety-Related Motor Operated Valve Periodle Verification Program L

In response to Generic Letter (GL) 96-05 " Periodic Verification of Design-Basis Capability l of Safety-Related Motor-Operated Valves," Entergy Operations Inc., (EOI) has established  ;

a standardized program plan common for all four sites for motor-operated valves (MOVs) I that are within the scope of GL 96-05. The program meets the recommendations set forth  !

< in GL 96-05 and is applicable to each EOI nuclear site. l The following description provides a summary of the program plan. .j

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Overview The purpose of the EOI periodic verification program is to establish the framework necessary for implementing EOI/ Industry methodology for periodic verification of GL 96-05 MOVs. This program will be applied at each EOI nuclear site. This methodology implements a risk-based approach to periodic static testing to verify potential degradation in the operating characteristics for MOVs and a shared approach to perfonnance of periodic differential pressure testing to verify the potential for increased thrust or torque requirements for MOVs. This approach, using both static and dynamic testing, provides assurance that valve performance degradation is readily  ;

identified and that test frequencies are appropriate to ensure that valve operability is  !

maintained. I Static Diagnostic Test i

MOVs included in the scope of the 96-05 periodic verification program will be statically tested. The static diagnostic test frequency for MOVs is based, in part, on

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risk significance and setup ratio (i.e., margin). Other factors such as operating conditions, stroke frequency, maintenance history, and operating fluid may alter test i frequency, and increased testing frequency will be considered where appropriate.

The risk significance and setup ratio are used to define a bounding test frequency which can be increased based on the other factors. In establishing risk significance, ,

each EOI site will utilize an expert review and their respective Probabilistic Safety  !

Assessment (PSA) methods to determine risk significance and ranking. )

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_- -_ . ~._ . . . . .. . _ . . _ _ _ _ - - . . . _ - - - - . . . . . .

Attachment To CNRO-97/00004 Page 2 of 4 1

SUMMARY

l The following table provides the risk ranking categories used by EOI along with the j l

assigned point value for each category.

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l Risk Ranking Description Point Value High A single Functional Failure Mode (FFM) 3 results in 100% or greater increase in Core Damage Frequency (CDF) or deemed High by an expert review. ,

Medium No single FFM will result in a 100% 2 increase in CDF, but the combined CDF J

related to all FFMs is greater than 100% or  :

deemed Medium by an expert review.

i Low MOVs that do not meet High or Medium I risk ranking criteria or deemed Low by an expert review.

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Each EOI site will utilize the same approach for calculating setup ratio. Corrections ,

will be made as appropriate for random and bias inaccuracies which may include:

diagnostic equipment inaccuracies, torque switch repeatability, rate ofloading effects, lubrication degradation bias error, spring pack relaxation bias error (when  !

applicable), and reading error. l

, The following matrix provides the setup ratio ranking categories used by EOI along with the assigned point values for each category.

SETUP RATIO RANKING RANKING CRITERIA POINT VALUE HIGH-HIGH 260% 1 i HIGH 2 30% AND < 60% 2 l MEDIUM 210% AND < 30% 3  !

LOW < 10% 4 l

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, Attachment To CNRO-97/00004 Page 3 of 4

SUMMARY

The following matrix provides the results of the combined risk ranking and setup ratio used to determine a maximum bounding test frequency. In addition, the maximum interval between static tests is not to exceed 10 years.

STATIC TEST FREQUENCY MATRIX H(3) 3 Cycles 3 Cycles 2 Cycles 2 Cycles M (2) 6 Cycles 4 Cycles 4 Cycles 3 Cycles- j L (1) 6 Cycles 6 Cycles 6 Cycles 4 Cycles '

RISK T / RATIO

• H-H (1) H (2) M(3) L (4)

If data from the periodic test frequencies established above indicates an adverse trend, then the periodic testing frequency for the impacted MOVs will be reviewed and adjusted as required. Each EOI site will have a program to assess and trend the {

continued functional readiness and capability of MOVs to operate under design )

basis conditions. I l

Periodic Differential Pressure Testing Static testing provides a perspective of the overall readiness and capability of the MOV to operate when required. However, static testing of MOVs may provide limited insight as to changes in the required operating thrust or torque under dynamic conditions. Testing under dynamic flow conditions on a periodic basis may provide additional information for evalua'ing margin, beyond that provided by static testing. l EOI plans to participate in the JOG periodic verification program, including dynamically testing a selection of valves and providing the test results to the JOG.

Criteria established in accordance with the EOI periodic verification program will  !

be used to select and test the candidate valves. Company procedure DC-110 currently only includes differential pressure testing of motor-operated gate valves; however, the procedure will be revised prior to site implementation to include some 1 testing of butterfly and globe valve types as required to support JOG activities l

Each site will be responsible for the evaluation of the data obtained at their respective site. If the performance of any project MOV is unacceptable or degraded to a point where possible performance concerns exist, corrective actions will be taken in accordance with site specific programs.

Additional site specific dynamic testing may be performed when it has been identified via analysis / industry data that a valve has the potential for galling or machining to occur during operation. Dynamic testing may also be performed if

Attachment To CN~RO-97/00004 Page 4 of 4 i - ,

SUMMARY

valve maintenance, based on engineering judgment, may affect the valve performance under the dynamic condition and/or system history indicates that valve factor degradation may be occurring.

EOI will review JOG recommendations and test results as well as other pertinent industry infonnation and will incorporate the results of the review into our periodic verification program as applicable.

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