ML20197D904

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Forwards Response to NRC 860407 Request for Addl Info Re TMI Item II.E.4.2(6) Concerning COP Sys Isolation Valves. Resolution of Issues Should Be Reflected in Next Sser
ML20197D904
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 05/13/1986
From: Devincentis J
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To: Noonan V
Office of Nuclear Reactor Regulation
References
TASK-2.E.4.2, TASK-TM SBN-1049, NUDOCS 8605150095
Download: ML20197D904 (16)


Text

_-

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SEABROOK STATION Engineering Office

__) b_ __

8 May 13, 1986 l

Put2c Service of New Hampshire SBN-1049 T.F.

B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Mr. Vincent S. Noonan, Project Director PWR Project Directorate No. 5

References:

(a) Construction Permita CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated April 7,1986, " Request for Additional Information from Seabrook Regarding TMI Item II.E.4.2(6)", V. Nerses to R. J. Harrison

Subject:

Request for Additional Information; C0P System Isolation Valves

Dear Sir:

Enclosed please find, as Attachment 1, our respense to information requested in Reference (b) regarding the C0P System Isolation Valves.

We believe the enclosed addresses the Staff's concerns regarding the C0P valves, and request that the resolution of the issue be re-flected in the next supplement to Seabrook's SER.

Very truly yours, John DeVincentis Director of Engineering Enclosures cc: Atomic Safety and Licensing Board Service List f

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1 Seabrook Station Construction Field Office. P.O. Box 700 Seabrook, NH O3874 '

l Diane curren E quire Calvia A. Conneg' Narmon & Weiss City Nanager 2001 S. Street, N.W.

City Nall Suite 430 126 Daniel Street Washington, D.C.

20009 Portsmouth W 0380,1 Sherwin E.1bek Esq.

Stephen E. Norrill, Esquire Office of the Executive Legal Director Attorney Ceneral U.S. Nuclear Regulatory Commission George Dana Bisbee, E, squire Tenth Floor Assistant Attorney General i

Washington, DC 20555 Offlee of the Attorney General 25 Capitol Street i

Robert A. Backus, Esquire Concord, W 03301-4397 116 Lowell Street P.O. Box 516 Mr. J. F. Nadeau Nanchester, NN 03105 Selectmen's Office r

10 Central Soad Philip Ahrens Esquire Rye, W 03870 Assistant Attomey General Department of The Attorney General Mr. Angie Nachiros Statehouse Station #6 Chairman of the Board of Selectmen kugusta NE 04333 Town of Newbury Newbury, MA 01950 l

Nes. Sandra Cavutis Chairman, Board of Selectmen Mr. William S. 1.ord EFD 1 - Box 11$4 Board of Selectase Rennsington, EN 03827 Town Hall - Friend Street l

Amesbury, MA 01913 j

Carol S. Sneider, Esquire Assistant Attorney General Senator Cordoe J. Numphrey Department of the Attorney General 1 Fillsbury Street

)

One Ashburton Place,19th Floor Concord, W 03301 Boston, MA 02108 (ATTN: Norb Boynton)

Senator Cordon J. Humphrey N. Joseph Flynn, Esquire U.S. Senate Office of General Counsel Washington, DC 20510 Federal Beersency Management Agency g (ATIN: Tom Burack) 500 C Street SW '

Washington, DC 20472 t

Richard A. Nampe. Esq.

Nampe and Mc51cholas Paul McEachern. Esquire 35 Pleasant Street Matthew T. Brock, Esquire Concord, NH 03301 Shaines & NcEachern 25 Naplewood Avenue Donald I. Chick F.O. Box 360 Town Manager Portsmouth, W 03401 Town of Exeter j

10 Front Street Gary W. Holmes, Esq.

Exeter. EN 03833 Holmes & Ells 47 Winnacunnet Road Brentwood Board of Selectmen Hampton, NH 03841 RFD Delton Road Brentwood, NH 03833 Nr. Ed Thomas FEMA Region I Peter J. Mathews, Mayor 442 John W. McCormack PO 4 Courthouse City Hall Boston, MA 02109 Newburyport, MA 01950 Stanley W. Enowles, Chairman Board of Selectmen P.O. Box 710 North Hampton, NH 03862

. - _ ~

SBN-1049 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI

References:

1.

J. DeVincentis, Director, Engineering and Licensing, Public Service of New Hampshire, New Hampshire Yankee Division letter to G. W. Knighton, Chief, Licensing Branch 3, Division of Licensing U. S. Nuclear Regulatory Commission, Seabrook Station Units 1 and 2.

Response to RAI 271.12; Containment Purge and Vent Valve Operability.

SBN-889, NRC Accession N, 8511110156, November 6, 1985.

2.

Operability Demonstration of tNb-PSI C0P Valves for Public Service Company of New Hampshire, et al, performed by Stearns - Roger Manu-facturers, Inc., Job No. 62483, United Engineers and Constructors, Inc. (UE&C) Foreign Print No. FP-97786-01, January 22, 1985.

3.

Nuclear Seismic and LOCA Analysis, performed by Posi-Seal International, Inc. Report No. 28988SL - 001, UE&C Foreign Print No. FP-93610-03, August 22, 1985.

4.

Posi-Seal Technical Bulletin No. 2, dated June 1982.

5.

Crane Technical Paper No. 410, 1976.

Questions and Responses:

I 1

1.

Identify the accident event and sequence which will produce the peak containment pressure used in qualif ying the valves.

Cite the specific FSAR sections, tables and figures associated a.

with this worst case event:

Response

FSAR paragraph 6.2.1.1 describes the design basis accident (LOCA).

The worst case accident is a double-ended pump suction rupture (DEPS). Section 15.6.5, " Loss of Coolant Accidents Resulting from a Spectrum of Postulated Piping breaks within the Reactor Coolant Pressure Boundary" describes the Reactor Coolant System Accident Analysis for the LOCA. Detailed accident conditions are given in Section 6.2.1.3.

Figure 6.2.7 shows the Containment Pressure Response for the (DEPS). This figure will be updated in the next FSAR revision to the new value indicated in response Ib below.

b.

Indicate the maximum containment pressure and temperature af ter I

event initiation:

Response

Maximum containment pressure and temperature occur af ter valve closure, about 3600 seconds af ter the break. Maximum pressure from Figure 6.2.4Lis 49.6 psig. Maximum temperature for the (DEPS) is 270*F from Figure 6.2-5.

This figure will be updated in the next FSAR revision to this value.

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+

Prge 2 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI c.

Identify the minimum values of pressure and temperature which initiate containment isolation:

Response

At the present time, the minimum value of containment pressure which initiates containment isolation is 4.3 + 1.5 psig. Temperature is not a criterion for actuation of the C0P valves.

d.

Identify the maximum allowable closing times for valves COP-V-1,

-2,

-3, and -4:

Response

The maximum allowable closing time for these valves is 2.0 seconds.

Table 6.2-83, " Containment Isolation System Design Information" of Seabrook's Technical Specifications identified this time.

This is the stroke time from the moment the C0P valve receives actuation signal up to 100% close position of the C0P valve. This time, plus I second (.6 sec. signal process time rounded to 1 sec.) is used to determine a mass loss from containment to the outside, for Radio-logical doses to the Public.

e.

Describe the technical basis for using 17 psig as the containment pressure due to a LOCA event (page 17 of Reference 3).

If appro-priate, submit a copy of UE&C Change Order 23 dated October 18, 1982

( Do cument (e) of Reference 3).

Response

For the determination of the LOCA initiated pressure to be used for qualification of the subject valves, the (double ended hot leg LOCA) curve from FSAR Figure 3.11(B)-1 (Sht. 1) was used. The closure signal was assumed to be generated at a containment pressure of 7.4 psig (5 psig setpoint plus 2.4 psig tolerance).

This value has changed since Ce valve testing, see response Ic.

The value, however, for testing.; acceptable because it is conservative. A delay of 0.6 seconds was assumed for signal actuation and processing, and a closure time of 2.0 seconds was assumed for the valves.

This resulted in a nominal containment pressure of 15.7 psig.

An additional 1/2 second margin was allowed for conservatism and the value was rounded out to 17 psig, see Figure 1.

It was thought that the overly con-servative test value would not result in increased test cost, diffi-culty or damage to the valve, whereas a test conducted to marginal requirements would be subject to criticism of its adequacy.

Actual testing of the valves was completed using 20 psig minimum for static testing prior to and af ter flow testing.

For flow testing each valve, pressure at each valve ranged f rom 17 psig for one case to 23 psig with average number of test cases of 19 psig. For flow testing of both valves simultaneously, pressure ranges from 17 psig for one case up to 29 psig with an average number of test cases of 24 psig.

We have provided herewith a copy of the referenced change order.

Page 3 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI 2.

It is not clear whether the valves have successfully passed the leak tests reported in Table 1 of Reference 2.

a.

Describe the purpose of the leak tests, as well as the basis for acceptance:

Response

The leak test was intended to identify any damage or distoration of the valve seal which might result from the high flow rates and turbulence associated with the flow tests.

It was not intended that there be a quantitative basis for acceptance or rejection, but only to determine what ef fects, if any, the high flow ranges would have on the valve seals.

b.

Describe the corrective action taken to address the laakage reported in Table 1.

If known, describe the cause of the leak.

Response

The leakage was obviously caused by entrapment of debris on the seal grease, followed by embedment of the debris in the seal material when the valves closed.

Particles of rust and metal chips, from the test set up, were observed to fly from the exhaust end of the test pipe upon initial pressurization. We believe the rust and metal chips originated from an aceumulator and piping which was located in an outdoor environment. Exam-ination of the valves disclosed rust and chips embedded in the EPR seals following the first valve closure.

For subsequent tests, no visible particulate was observed exiting the exhaust of the test pipe.

The observed leakage has been determined to have negligibl e affect to the overall operability of the valves.

See further discussion in item 2c.

c.

Explain why the tests were not repeated despite leaks observed at valves COP-V-1, 2, and 3.

Response

The same two valves (S/R No. 101 & 102) were used during testing of both piping configurations.

The leakage testing was performed around the seat of the tested valves using a soap solution.

This leakage was low, however, it was not quantified in the test report.

Since the test, we have quantified the leakage observed during testing and have determined it was minimal, less than 1 standard cubic feet per hour.

Embedded particles in the valve seat were observed to be the valve leakage locations.

As stated in Item 2a, the purpose of the test was to identify any damage or dis-tortion of the valve seal due to high flow and turbulence which would cause valve closure and seating problems.

Page 4 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI Therefore the tests were not repeated and the observed leakage has been determined to have a negligible ef fect to the overall operability of the valves.

d.

Confirm that the leak test results do not adversely affect the

~

validity of the flow tests reported in Table II and III, Ref-erence 2.

Response

The criteria used to determine whether or not the valves were fully closed was the valve stem position, as indicated on the test charts.

The presence or absence of leakage had not im-pacted on the valve closure rate or valve position, and did not enter into the test evaluation.

3.

There are several anomalies which were not addressed in Seabrook submittal, References 2 and 3.

a.

Valves COP-V-1 and -4 were tested with their stems 45* of f vertical (Drawings 23167-1 and -2 of Reference 2).

Justify the test configuration.

Confirm that the flow test results simulate the worst case condition for valves COP-V-1,

-2,

-3, and -4:

Response

C0P valves V-1 and -4 were mounted with their stems 45' off vertical in order to simulate the actual mounting configuration existing at Seabrook.

The two Unit 1 valves are mounted exactly as shown on the test set-up drawings in order to avoid interfer-ence with structural features outside Containment.

The C0P valves are installed so that normal flow is in the pre-i ferred direction, as indicated on the valve drawings.

Normal flow for line 9312 is from inside Containment (COP-V-3 and -4) and for line 9311 is f rom outside Containment (COP-V-1 and -2).

LOCA flow, of course, would be from inside Containment; therefore, the test was set up with COP-V-3 and -4 in the preferred direction and with COP-V-1 and -2 in the non-preferred or reversed flow direction to simulate the actual valve configurations at Seabrook.

The flow tests were intended to be conducted with initial pressure and flow higher than would actually be experienced during a LOCA.

The flow medium was cool dry air, which is denser than the warm air-steam mixture resulting f rom a LOCA, and so the thrust on the valve disc would be expected to be greater than under LOCA condi-tions.

b.

Confirm that the failure of the upstream pressure transducer (Section 2.4.4 Reference 2) does not invalidate interpretation of the test:

Pige 5 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI

Response

The upstream pressure transducer was intended as a back-up for the downstream transducers in the event that the later were damaged or their accuracy af fected by valve closing turbulence.

The loss of the upstream transducer did not af fect interpre-tation of the test.

c.

Calibration of the strain gage assemblies in Section 2.5.1 Reference 2, o ly to 150 ft-lb, although the maximum value of 223 ft-lb was reported in Table II.

Confirm that the calibra-tion technique is capable of determining the 223 f t-lb value.

Response

The strain gages were constantan foil with a polyimide carrier.

They were selected to provide readings in the 100 foot-pound range for torque, which was within the expected range during valve closure.

Constantan is a copper-nickel alloy of approximately 55-45 per-cent composition.

The strain sensitivity of these alloys is linear over a vide range of strain and does not change as con-stantan goes plastic.

Recalibration of the strain gages after completion of the tests showed that the strain gages were still linear and had not been damaged by the higher torques experienced af ter closure of the valves.

Chart Number 1 (attached) shows a graph of the strain gage calibration data, and the 223 foot-pound data was extrapolated using such a linear chart.

4.

Reference 1 identifies the maximum torque developed by the valve at LOCA pressure (17 psig) as 2,568 in-lbs. in the preferred flow direc-tion.

However, Table II of Reference 2 and Addendum A of Reference 3 list the maximum torque as 223 f t-lbs (2,676 in-lbs).

Clarify the apparent discrepancy.

Response

Analysis of the charts for runs 3A, 3B, and 3C (three consecutive runs testing the same valve) indicates a high frequency noise on the torque trace. This amounted to about imm peak to peak.

If you factor this noise out, the trace reads somewhat lower at the peak. The highest reading would be about 214 ft-lbs or 2,568 l

in-lbs (torque, uncorrected for noise). The value used from Reference 2 for the Reference 3 analysis is conservative.

l Pzga 6 ATTACHMENT 1 4

C0P VALVE TEST - RESPONSE TO RAI 5.

The stresses presented in Addendum A of Reference 3 incorporate result of the actual LOCA flow tests (2,676 in-lbs) into the seismic analysis.

The torque output of the valve actuator with the valve fully closed is l-3,260 in-lbs (Reference 1).

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a.

Provide the actuator torque output versus valve opening angle in tabular or graphic form.

Compare the actuator output with the -

i maximum torque required to operate the valves.

1

Response

l See Table 1 for valve angle versus actuator torque comparison.

The actuator output torque is 3,260 in-pounds with the spring extended.

The actuator output is about sixteen percent higher than the maximum torque registered during the test.

b.

As discussed on page 7 of Addendum A, leakage of valve COP-V-4 was reduced by allowing the valve disc rotation to be stopped by the actuator stop rather than by the valve body stop.

Indi-cate whether the arrangement is representative of the as-built configuration at Seabrook.

Confirm that the valve internals will not be overstressed by the maximum actuator torque.

j

Response

i i

The normal adjustment for these valves, and the procedure to be used at Seabrook is to adjust the valve disc stop screw to con-tact the disc after the actuator stop bolt has been set for leak-4 tight closure.

These adjustments are normally made at the factory and are checked by the site Startup group.

The adjustment that was made to valve 101 (COP-V-1) was in the nature of an experiment, and was not typical of the Seabrook as-built configuration.

The j

design of the valve internals contains sufficient margin to ensure l

that no over-stress condition will occur, as indicated by Reference 3 ( Addendum A dated June 25, 1985). See Attachment 2 for comparison i

j of calculated and allowable stresses.

i l

6.

There are several responses in Reference I which need to be clarified.

1 a.

Response 1 to. Attachment I states that valves COP-V-1,

-2, -3, and l

-4 are maintained partially open during normal operation.

Describe j

the normal position of the valves in terms of opening angle.

De-scribe how the normal valve position is maintained.

(For example, is the valve blocked to a maximum opening angle)? Compare the as-built plant configuration with the configuration used to perform j

the flow tests and stress analyses, and justify any discrepancies.

1 i

4

Pr.ge 7 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI

Response

Valves COP-V-1,

-2,

-3, and -4 are normally open during con-tainment purge. They can be fully open or shut.

There is no basis for the statement that they are maintained partially open.

This response should be amended to delete the work " partially".

4 The test configuration simulated the as-built plant configuration.

b.

Describe the technical basis for determining that the sonic flow j

condition occurs at 29 psig.

(Reference 1, Response iE to Attach-ment 1).

Provide the derivation of the maximum valve torque re-quired for this condition.

J

?

Response

?

To determine the sonic flow condition through the COP isolation valves the following derivation was used:

Two 00P isolation valves are in series, normally 100% open.

Assume upstream valve remains 100%, downstream will be closing.

4 i

For Critical Flow:

(Reference 4) l

]

PC = Fg XT P1 Where l

PC is critical flow difference pressure PC=P1-P2 1

P1 = Upstream pressure (psia) i P2 = Downstream pressure (psia)

Kg = Ratio of specific heats factor =

K/1.40 for air F

=1 XT = Rated pressure drop ratio of valve factor To determine XI (Reference 5)

For Butterfly valves Sizes 2" to 8" K = 45 f T' Where K is resistance coefficient or velocity head loss i

fT is friction factor in a zone of complete turbulence 1

PJgs 8 ATTACHMENT 1 COP VALVE TEST - RESPONSE TO RAI l

fT for 8" line =.015 (Appendix A to Reference 5)

K = 45 (.015) = 0.675 for one butterfly valve 100% open KTotal for 2 COP isolation valves - 2 x.675 = 1.35 From Appendix A to Reference 5 for a K of i

I 1.35, P =.564 = XT Pg P1 - 12.1 psia (Denver Barometric Pressure) = P1 (.564) l P1 = 12.1 psia = 27.8 psia (For Denver) j 1

.564 I

t For the downstream condition of 12.1' psia (Denver), the sonic flow will occur when an upstream pressure is about 35.1 psia.

This value supercedes information submitted during the simulated LOCA testing of the C0P valves, the maximum pressure that was available during full flow, was 23 psig (35.1 psia). The test run was at this pressure, closing COP-V-4 with flow in the preferred direction. The maximum torque recorded was 223 foot-pounds, or i

2,676 inch-pounds.

These tests allowed us to verify our judgement that the maximum torque required for valve closure under LOCA conditions is the result of seating friction plus operator inertia forces.

The effects of aerodynamic forces on valves of this size is negligible i

when compared to the seating force.

I c.

Valve leaks were reported in Table 1 of Reference 2.

On page 7 l

of Addendum A to Reference 3, the following. statement was made.

l "This leakage (of valve COP-V-4) was attributed to foreign matter i

which became embedded into the seal. This foreign matter could have increased the. torque".

It is not. clear that sealing integ-l rity will be assured by the response given in Reference 1, Attach-ment 2 (Demonstration). Describe the technical basis Eto support

]

the conclusion that the use of debris screens as well as the in-service inspection of the valve assembly will be sufficient to preclude the buildup of corrosion products or debris that could j

" lock up" the valve stem or damage the sealing surfaces.

Response

i j

The debris screens are used to prevent entry of large objects or missiles which could block open the valves and prevent their

[

closure in the event of a LOCA, and their design is typical of-what exists at other facilities.

1 i

i i

1

^

P:ga 9 ATTACHMENT 1 C0P VALVE TEST - RESPONSE TO RAI The buildup of corrosion products from corrosion of valve parts is unlikely, because the valve stem and disc are stainless steel.

The seat is Tefzel, which is not subject to corrosion. Corrosion products within the attached piping (carbon steel pipe) would be small because the piping is in an enclosed environment. Rust flakes, which if loosened by an accident could possibly deposit on the valve seats.

Leakage as tested (see Item 2c) would be negligible, within 3%

of Technical Specification limits for allowable leakage. Periodic leak tests of the isolation valves will be conducted as part of 1

the 10CFR50 Appendix J.

Type C leak tests, to quantify seat wear leakage, gasket leakage, etc.

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ATTACHMENT 1 (Continuad)

Table 1 C0P VALVE OPERABILITY TEST CLOSING TORQUE VS. VALVE ANGLE VALVE ANGLE (DEGREES)

TORQUE (FT.-LB.)

e 0

(Full Open)

- 65 10

- 55 20

- 30 30

- 10 40

- 5 50 5

60 15 70 20 80 185*

82 223*

83.5 (Full Closed) 135

  • Ihese values include inertia forces.

Reference:

RUN 3A COP-V-4 LINE 9312 Preferred direction (Highest indicated torque value from Table II of the S&R Test Repo rt F.P.

97756-01).

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TABLE 2 COMBINED LOCA AND SEISMIC STRESSES (PSI) 8" - 150 Class Valve with a Matryx 26062-SR60 R2ference &

Actuator Bracket Bracket Valve Stem Disc Pin Bolt Bolt Neck Item No.

Calc.

Allow.

Calc.

Allow.

Calc.

Allow.

Calc.

Allow.

Calc.

Allow.

Calc.

Allow.

Unit i 11473 Item 22 & 23 11294 37500 18769 37500 1145 20550 14480 26250 23331 52500 21699 52500 i

NOTE:

(1) Just the stresses for 11473 Iteme 22 & 23. Unit 1 are given since this represents the worst case. The valve necks for the valves to be used on Unit 2 are more substantial.

(2) The allowable stresses are based on 1.5 times the allowables given in Section III of -the ASME Boiler and Pressure Vessel Code.

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gg ggg CHANCE CRDER ocon.v e m m NO.

23 October 18, 1982 he N2 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al c/o United Engineers & Constructors Inc. Agents W

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P.O. Box 700 KEo No M M

Seabrook, New Ha=pshire 03874 Eo sY MMM THIS CHANGE oRCER IS 185UED AS A SUPPLEMENT To AsovE ORDER oR Posi Seal International Inc.

7HE TER S AND CONDITIONS oF

    • ** O Routes 49 and U.S. Highway 95 THE SAiD oRoER oR CONTRACT suvEn M North Stonington, CT.

D6359 SHALL REMAIN IN FULL FORCE AND EFFECT ExcEPT AS SPECiFiCALLv SEI.ER NoTED HEREIN.

NET AMOUNT oF ORDER oR CONTRACT PREVIOUS To THIS CHANGE Es t SUPPLEMENTING THE A8ovE PURCHASE ORDER oR CONTRACT You ARE AUTHORIZED AND DIRECTED UNDER THE TERMS THEREoF To.

Add Dynamic Torque Coefficient Test Report requirement to valve 4 (8 inch slze)' "line Item Number 37, valve numbers 1 and 2-COP-V001,I,'3..and 2

f f

Analysis will contain the following:

1) Maximum allowable pressure differential across the valves in the fully open and fully closed portions based on the actuators supplied.

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2) The expected pressure in the containment at the time the pilot solenoid valve receives signal to; close the present valve would be 17 PSIG with a corresponding temperature of 2250F. The maximum containment temperature under LOCA i Conditions is 3750F.

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3) Provide calculations indicating maximum valve torque requirements with the valve in the open position and also in the closed position.
4) Provide calculations indicating torque ratings of the actuators demonstrating that

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the combined torque developed by the valve is below the actuator rating.

ADD:

f AMOUNT oF FoR THIS CHANGE oROER NET AMOUNT oF ORDER oR CONTRACT To DATE MN

.a....

kTTAcHN\\eMT I

(e x h we.4)

Form No. 441.,

WM Sqhm CHANGE CRDER ACCT. NO.

NO.

23 a con.tructora m October 19, 1982 Page 2 of 2 p,o, go.

PUBLIC SERVICE COMPAhT OF NEW HAMPSHIRE, et al c/O United Engineers & Constructors Inc. Agents KEO NO.

i REO BY PURCHASER THIS CHANGE OROER 18 ISSUED AS I

A SUPPLEMENT TO A80VE ORDER OR CONTRACT.

DATED THE TERMS AND CONDITIONS OF Posi Seal International Inc.

THE SAID ORDER OR CONTRACT SMALL REMAIN IN FULL FORCE AND SUYER EFFECT EXCEPT AS SPECIFICALLY i

S E ER NOTED HEREIN.

NET AMOUNT OF ORDER OR CONTRACT PREVIOUS TO THIS CHANGE

)

JUPPLEMENTING THE ABOVE PURCHASE ORDER OR CONTRACT YOU ARE AUTHORIZED AND DIRECTED UNDER THE TERMS THEREOF TO l

REASON: The analysis is required due to additional engineering requirements to provide assistance and information for NRC RAl 271.12 (Operability Qualification Of Purge and Vent Valves).

SHIPMENT:

ACCOUNT NO.

AMOUNT OF addition FOR THIS CHANGE ORDER I

NET AMOUNT OF ORDER OR CONTRACT TO DATEEst PUBLIC SERVICE COMPAh7 0F NEW Ge#4m NO. 23 Ul M.neto,8."()Ql N HAMPSHIRE, et al a con Agents SIGN AND RETURN THE ACCEPTANCE COPY OF THIS ORDER October 19, 198 BY ArrussewT I (t a +'4) sORIGINATOR