ML20248H120
| ML20248H120 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20248H118 | List: |
| References | |
| GL-89-10, NUDOCS 8910110179 | |
| Download: ML20248H120 (210) | |
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0%G1NAL UNITED STATES NUCLEAR REGULATORY COMMISSION
-. z. 4-m . am am an um . . sm an - am as sm as am ma se . so mm as as sa mm as . am ma ns - as um an am an - a In the Matter of: )
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WORKSHOP ON GENERIC LETTER 89-10 ) ;
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Pages: 1 through 200 l
Place: Chicago, Illinois Date: September 18, 1989
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I HERITAGE REPORTING CORPORATION onseint Reporters 1220 L Street, N.W., Suke 600 Wasidnston, D.C. 20005 p1<>; _;, , ,
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? 1 UNITED STATES NUCLEAR REGULATORY COMMISSION .
In the Matter of: )
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WORKSHOP ON. GENERIC LETTER 89-10 )
Monday September 18, 1989 Salon =#4' O' Hare Marriott 8535 W. Higgins Road Chicago, Illinois The-above-entitled matter came on for hearing, pursuant to notice, at 10:00 a.m.
BEFORE: THOMAS G. SCARBROUGH, CHAIRMAN Mechanical Engineering Branch Office of Nuclear Reactor. Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 PANEL:
TAD MARSH JEFF JACOBSON DICK KIESSEL 4 TED SULLIVAN TOM MARTIN
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EBQGEERIEEa 2 MR. MARSH: Good morning. My name is Tad Marsh.
3 I'.m the Branch Chief of the Mechanical Engineering Branch in 4 the Office of Nuclear Re' actor Regulation. I'd like to 5 welcome you here this morning to discuss Generic Letter 6 89-10, which, as you know, is related to motor operated 7 valves.
8 I have a short presentation this morning. The.
9 main part of our presentation will be handled by Mr. Tom 10 Scarbrough.
11 I'd like to begin by introducing the members on 12 the table. Mr. Ted Sullivan is to my immediate right. He 13 is the Section Chief responsible for in service testing and 14 valves. Mr. Tom Scarbrough is to his right. Here is a 15 responsible Engineer for motor operated valves. Mr. Jeff 16 Jacobson to his right is in the Division of Reactor 17 Inspection and Safeguards. And to his right is Mr. Dick 18 Kiessel who is in the Division of Operating Events and 19 Analysis.
20 These public meetings are intended to provide a 21 means for the staff to describe to you to give to you the i 22 basis for the generic letter as well as our intent and its j 23 implementation. However, the main purpose of these meetings 24 are to hear and.to respond to questions from you about the 25 generic letter and its intend and any problems that there Heritage Reporting Corporation (202) 628-4888
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3 1 may be in its. implementation.
2- We had similar meetings ~to these in the generic 3 letter 89-04 for those of you that are familiar with it.
4 ;That letter was related't'o in service testing. We found we 5 had four meetings around the country'and we had'a number of 6 questions about the generic' letter, what it-related to and 7 how it was to be implemented, the. time frames involved. H 8 Those meetings were successful so we wanted to do this 9 again.
s 10 We found that there was enough need for.a dialogue 11 between the two organizations that they were very 12 beneficial. . We've . seen a number of -- I'm sure you have too 13 -- a number of motor operated valve problems through the 14 years. These problems have been related to a variety of 15 aspects. They've been due to-a torque switch, torque switch 16 by passes, limit switchLsettings and other problems. We've 17 also seen difficulties with damage from operations and wear 18 'from thermal overload to the motor.
19 The causes of these problems have been varied and 20 have included a lack of coordination between plant 21' organizations, inadequate engineering analysis, weak 22 training programs at the plant, weak procedures and 23 insufficient in service testing criteria and implementation.
24 _ Operating experience has shown that motor operated 25 valves can.and do severe plant transients and can be a true Heritage Reporting Corporation (202) 628-4888 l
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'l impactLof plint safety.
2: For example, and. one .I'm sure 'you' re familiar with 3 the' Davis-Besse loss of feed water event. There have been 4 .others; Katawba. A loss of inabilityLto isolate.all feed 5 water. And Millstone, inability to stop' safety injection.
6- Generic Letter 89-10 will help provide confidence 7 to motor operated valves currently in use. We'll be able to
- 8 . operate and have the system perform its designed safety 9 function.
10 But 89-10, together with the in serving testing 11 requirements is not enough. More changes need to take 12 place. And we'll hear some description of those changes 13- today.
14 I'd like to take just a minute to describe to you 15 things that are going on within the NRC related to motor 16 operated valves and things that are going along within.the 17 industry with respect to motor operated valves. With 18 respect to the Office of Nuclear Reactor Regulation, some of 19 these offices -- organizational titles -- may not have much 20 meaning to you and they shouldn't. The main intent here is
- 21. to show you the spectrum of activities that are going on 22 within the NRC.
23 Let me start by describing or recalling to you 24 Bulletin;85-03:_ This, of course, was followed by Generic 25 Letter 89-IV. Bulletin 85-03 related to switch settings for Heritage Reporting Corporation (202) 628-4888
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1 motor operated valves on a selected number of high pressure 2 systems at P and BWR's. Generic Letter 89-10, the subject 3 for this meeting is, of course, an extension to 85-03. ,
1 4 Generic Letter 89-04 rel'ates to in service testing. That 5 generic letter covers a spectrum of pump testing, valve 6 testing issues as well as programmatic issues. Pressure i
7 Isolation Valve Program.
8 For those of you who aren't aware, there's an 9 ongoing concern within the NRC with respect to Event V's 10 within PWR's and selected BWR's. There have been a few 11 pilot inspections around the country. This has been aimed 12 mainly at the information gathering viewpoint. It's in 13 response to valve problems and human factors issues.
14 In the Office of Research there are a number of 15 issues being studied. Generic Issue 87 relates to the 16 failure of high pressure coolant injection steam supply line 17 without isolation, valve performance programs and the aging 18 research program. With respect to Generic Issue 87 there 19 has been some excellent and detailed tests that have taken l 20 place at Idaho through the sponsorship of EG&G. I think 1
21 you're going to hear more about that today.
22 The Office of Analysis and Evaluation of 23 Operational Data -- that's AEOD -- has performed a number of 24 case studies._ This is just one.
SECY papers have been 25 presented with inspector valve problems. This is only meant i
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1 to'sho.w you,Ccertainly not'in complete form, but it'is meant y_
2- to'show you-that the agency has under way a number.of 3 'activitiesLaimed at. valve related problems. From the 4 . regulatory perspective,'from the research perspective'and 5- also from the evaluation.of operational data. And I-think 6 : you .can: see just by this small number, 'of. which this is just 7 a sample, that the agency continues to be concerned about 8 valve problems and-is pursuing them in a number of 9 perspectives-.
10 Likewise, there is a variety of activities going 11- on'throughout the industry: EPRI has published technical i- 12 repair. guidelines for Limitorque.SMB-000. There are 13 follow-on technical guidelines being prepared. An i 14 application guideline is being prepared.
15 INPO has performed plant visits. They have 16 published in October of last year key elements for a j 17 comprehensive MOV program.
18 NUMARC is preparing guidelines for implementation 19 of 89-10, this generic letter. There are a number of 20 efforts under way to improve and to develop new signature 21 tracing techniques. Likewise, motor operated valve 22 operator's designers are working towards improvements to 23 overcome difficulties in that aspect.
24 e And2IEEE has a maintenance good practices 25 guideline published.
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7-1 The ASME is working on their part'on. valve related 2 problems in three areas, three standards.
3 OM-08 which has just been approved by the BNCS is 4- a standard that relates'to motor operated valve electrical 5 function.
.6 OM-10 which we just approved and will be 7 referenced shortly within the regulation relates to valve 8; testing in general; check valves, motor operated valves, 9 pneumatics, hydraulics, the full spectrum of valves..
10 And QME-1 relates to the design standards
.11 associated with the valves.
.12 I want to again highlight to you the various 13 organizations and the various ways in which valve problems 14 are being pursued through the industry. I want to also-15 highlight to you that, although they're being pbrsued on a 16 number of fronts, they're not very coordinated.
17 There needs to be, in my opinion, coordination 18 between the various activities to ensure that with the end 19 goals -- that is standards and design and implementation --
20 are all coordinated.
21 I'd like to just spend a minute on the 22 presentation format for the meeting today. I have just 23 about finished with this short introduction part. Tom 24 Scarbrough is going to take the brunt of the presentation 25 material te-lling you about the generic letter. Its Beritage Reporting Corporation (202) 628-4888
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8 1 development, its text of content and its implementation.
2 We'll then begin what I think is the most important phase of 3 the meeting which is the answering of questions that you 4 have.
5 As you know, in the Federal Register memos we 6 asked for questions to be forwarded to us through the 7 Project Manager so that we could be prepared for them and 8 have responses ready. We got a variety of questions for all 9 three meetings. What I'd like to do after we're through 10 with the presentation material is to start by reading the 11 question to you -- the ones that we've received -- and 12 giving the responses to them.
13 We'd like to go through all of those questions in 14 that way. If you have questions related to our answer or 15 related to the initial question, please give us your ,
16 questions, but I ask that you write them on the cards that 17 you find in the back on the table. And on the card I ask l 18 that you put your name, the question and the organization so j 19 that we may have it for record purposes and we can have it 20 there to focus on properly for answering.
21 After we've gone through the questions that we 22 have received before this meeting and given you the answers, 23 we'll then open the questioning up to the general floor.
24 That again will be in the card format. If you have 25 questions, please put it on the cards and pass it up Heritage Reporting Corporation (202) 628-4888 )
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1 1- forward, put your hand up, we'll get the' question and we'll 2 then go forward that way.
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3- I think we're going to have time enough for all of
.Our experience at these meetings is that j 4 your questions.
5 there.is enough time to go to 5:00 today to answer all the 6 questions that you may have. If we do not have time, we 7 intend on answering all of your questions. So if there is 8 not time enough for us to get to your cards, it will be 9 answered in the meeting summary.
10 You'll see that we are taking transcripts of the 11 meeting and we intend on putting the transcripts together 12 with the meeting summary for all three in publishing the 13 meeting summary. And our intent, as I say, is to answer all 14 the questions that you may have.
15 We don't have a schedule for you today other than 16 a rough plan to take a break around the lunch time -- say 17 12:00 -- and then take a break in the mid afternoon .
18 depending upon what the timing may be for the need of a 19 break. We can sort of sense when people need a break. And 20 to finish it around 5:00. That's all I have prepared for 21 you. Is there any questions that you have for me before I
.22 turn it over to Tom Scarbrough?
23 Yes, sir.
24 y UNIDENTIFIED: You mentioned the meeting summary 25 information. How can we get that?
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,i 10 1 MR: MARSH: _.I failed to ask you to all please sign 2 in the back the register. There are books in the back where 3 I-asked you to sign, put your name, your organization; and-4' if you're not a licensee', put your address and if you're a 5 -licensee, we know your address. The intent is to send all 6 participants, all attendee's in the meeting, the meeting 7 minutes; as well as'to send them to all licensees in general 8- for those licensees that aren't here. So you will be 9: receiving them through the mail as soon as they are 10 finished.
11 The next question, I'm sure, is when?
12 Well, the last generic letter meeting that we had, 13 89-04 -- I said it should take a couple to three weeks.
14 Well, it's been two months now and we're looking at the 15 meeting minutes very carefully. I don't want to 16 overemphasize the import of the meeting minutes but I do 17 want to say that because they are written and because they 18 do respond in a written way to questions that you may have, 19 they are construed to be agency positions. And so we want 20 to be very careful about what we write. So we are looking i
21 at that in a very careful sense. That means going through 22 our formal review process. So that means I think a similar 23 time frame for these meeting minutes. I'd say a couple to 24 three months.___I wish we could process them more quickly 25 than that but they do have the need for being carefully l
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2-11 1 scrutinized'to make sure we do respond properly to your 2 questions.
3 Yes, sir.
4 UNIDENTIFIED: If the meeting minutes are going to 5 be out in two or three months, do you plan on extending.the 6 deadline for the generic letter?.
7 MR. MARSH: The question was, if the meeting 8 minutes are going to'be out in two.or three months, do you 9 plan on extending the deadline for the generic letter?
10 No, we.do not.
11 .The questions that you' hear today, you should act' 12 on if you need that type of guidance. If you feel you need 13 the need for further clarification, contact your project 14 manager. They'll get in touch with us.
15 You shouldn't wait for the formal meeting minutes.
16 We published these meetings in the Federal Register. We 17 hope'there is as much attendance as possible. And that we 18 ' don't anticipate any changes when the meeting minutes are 19 published. You should be able to go with the guides that 20 you hear today. We are, of course, staying within the 21 bounds of the generic letter in questions that you may ask.
22 If you ask questions that we think are beyond the 23 generic letter for which formal agency review hasn't been 24 given, then we have to be very careful about that. But we 25 don't anticipate going beyond the generic letter in this Beritage Reporting Corporation (202) 628-4888 ]
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12 1 type of discussion. And if so, we'll highlight that to you.
2 Okay?
3 Any other questions?
4 All right. I'd like to turn it over to Tom 5 'Scarbrough who is going to give a presentation on the 6 background of the' generic letter and its technical content.
7 Thank you.
8' MR. SCARBROUGH:. What I'm going to try to do is 9 give a brief overview of the generic letter and then 10 specific questions we'll handle when we start going through 11 the questions we've received in the mail.
12 I thought we'd first talk about the background, a 13 little bit about Generic Letter 89-10 and where it came 14 from. The impetus of this effort started with basically 15 Davis-Besse during the event that occurred in June of 1985 16 there.
17 They had a complete loss of feed water where an 18 operator error by inadvertently resetting the control system 19 to the steam generator level system caused the auxiliary 20 feed water isolation valves to shut. He quickly realized 21 this error and went to reset and tried to reopen them and 22 they would not reopen against the high DP that existed 23' across the valves.
24 Theyg_ ended up sending someone down there to 25 manually open them. But that took like sixteen or seventeen Beritage Reporting Corporation (202) 628-4888
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13 1 minutes later.
2 In both in 85-03 which was issued in November of 3 '85, that event was the main concern. 85-03 asks that
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4' utilities develop a program to ensure that are were proper 5 switch settings for certain types of systems -- MOV's and 6 certain types of systems, high pressure injection,-emergency 7 feed water, reactor isolation cooling and to set up a 8 program to test those MOV's under the design basis 9 conditions. And'each plant was given about two years to 10 complete that program.
11 There was a supplement that was issued in April of 12 '88 which clarified two aspects of 95-03. One was that all 13 . safety related MOV's in those selected systems should be 14 included in the program. And the other was that MOV's that 15 may not have been classified as safety related, a 16 maintenance type of valve, or an MOV that was in there that 17 'was not considered safety related and it was normally in its 18 safety position. It should be able to recover from 19 repositioning.
l 20 Once responses for 85-03 began arriving, it was l
l 21 realized that there was a much larger possibility of MOV's l 22 not being able to operate on designed basis, conditions that 23 had been assumed initially. The results revealed that about 24 8% of the MOV's_wo_uld have failed to perform their intended 25 function under the designed basis conditions which was much Heritage Reporting Corporation (202) 628-4888
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1 1 greater than-has been assumed in any of the typical PRA's, 2 NUREG 1150, for example, that had been performed up to that 3 time.
4 And it was als'o discovered that other problems 5 were occurring in MOV's that hadn't been realized up to that 6 point. To evaluate the cost effectiveness of extending the 7 bulletin 85-03 program to all safety related MOV's the NRC 8 contracted with Brookhaven to perform a probabilistic risk i
9 assessment to determine the qualitative need for that 10 extension. That PRA found a favorable dose reduction in 11 dollar savings by extending it to all safety related MOV's.
l 12 And Brookhaven also had several qualitative arguments for 13 the expansion.
14 About the same time that decision was made to 15 expand 85-03 some results came in from some tests that were 16 performed in regard to generic issue 67, which is failure of 1 17 HPCI -- High Pressure Cooling Injection seam line without 18 isolation, being conducted by research, contracted to EG&G 19 of Idaho. The tests were on motor operated valves in the 20 Reactor Water Cleanup system -- RWCU.
I 21 And it revealed that, among other things, that the 22 valve thrust equation needed to be re-examined. and the 23 amount of thrust that was necessary to close an MOV under 24 full lying flow was much greater than had been anticipated.
25 They also found some other things. The stem factor was a Heritage Reporting Corporation (202) 628-4888 l
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o 15 ll ' function'of load which not had been considered to be a 2 constant up to that point. Because of this the decision was 3- made to expand 85-03.
4- Now, additiona'l tests are currently under way in 5 Germany.under this same generic issue contract. And we've 6 had some very preliminary results. They're over the phone 7 from Germany, so all we have are very third hand 8 information. But up to this point the results are 9 confirming the earlier studies performed by EG&G the thrust 10 is much great to-close the valve under full flow conditions 11 than they had anticipated.
12 I'll briefly talk about the scope of the generic 13 letter. That's one of the major changes from 85-03 as I'm 14 sure you're aware. 85-03 covered around 25 to 30 Mov's in 15 each plant whereas generic letter 89-10 addresses about 100 16 to 150. The main areas are safety related MOV's and 17 position changeable MOV's and that's any MOV in the safety l 18 related system that cannot be blocked from inadvertent 19 operation.
20 We're going to talk more about what we mean by i 21 blocking inadvertent operation in the questions. That's 22 been a theme that we've seen in several of the questions and 23 we'll address that in detail when we come to that question.
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24 I thought I would just summarize the major points 25 of the genaric letter. It may be easier to recognize the Heritage Reporting Corporation (202) 628-4888
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16 1 activities that are recommended to be performed in this 2 matter.
9 3 First, review and document design basis for a MOV 4 operation. That's the same as 85-03. There is no change 5 there to words. They're almost identical.
6 Establish and implement a program to review and 7 revise methods for selecting and setting switches.
8 Demonstrate MOV operable by testing a designed 9 basis, differential pressure and/or flow. And document 10 where designed basis testing cannot be performed with 11 description of any alternative testing.
12 Now we start to get into areas where we're 13 differing from 85-03. We're going along a different path 14 now.
15 Prepare procedures to ensure that correct switch 16 settings are determined and maintained.
17 The generic letter emphasizes in that section that 18 Section 11 of the ASME code stroke time testing is not 19 oriented toward verification of switch' settings. So 20 additional measures will be needed -- such as diagnostics --
21 to ensure that the settings are proper.
22 Analyze and document MOV failures and corrective 23 action and periodically eramine MOV data every two years for 24 trends. .-Thisz is a major change from 85-03 because now we j
25 have a continuing program. Whereas, 85-03 was a more or l
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1 less a one shot operation.
2 I thought I'd just summarize the schedule in the 3 generic letter. The prograta description and achedule for 4 plants with operating licanses within a year or one 4
5 refueling outage, whichever is later. And plants with 6 construction permits, one year or before the operating 7 license is issued. The initial program is allowed five 8 years for operating licensees or three refueling outages.
9 And for construction permit holders within five years before 10 the operating license is issues. And then the verification 11 of switch settings every five years or three refueling 12 outages.
13 Reporting advised NRC within six months whether or 14 not the generic letter will be met or any modifications of 15 the schedule that's proposed by the generic letter. Notify 16 the NRC of any changes to the commitments along the way.
17 And then after the initial five year program is complete, 18 notify the NRC that you're complete with that phase.
19 Now, there are a number of activities that are 20 going to be performed by the NRC in support of the generic 21 letter.
22 First, the workshops which is why we're here 23 today. Technical guidance to the staff. We're in the 24 process of preparing a what we call a temporary instruction.
l 25 It's an inspection manual chapter for the generic letter to Heritage Reporting Corporation (202) 628-4888 n ,
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18 1- provide guidance to the inspectors in their regions and 2' headquarters on how to go about insuring that the generic T 3 letter is properly implemented.
4 Audits of program descriptions. We plan to I 5 perform some audits of the program descriptions next year 6 and see how things are going. See if there are any problems 7 in implementation, understandings that aren't cleared up 8 here and provide additional guidance in that regard. Once i
9 the programs get under way from audits and inspections of 10 the implementation of the generic letter and provide 11 additional guidance on how that implementation is 12 progressing.
13 Also, the last one there is important. And that 14 is review of industry testing. We've emphasized to NUMARC 15 and EPRI the need for generic industry testing in this area 16 that individual licensees can employ in complying with the 17 generic letter. There is allowances made in the generic 18 letter for prototype testing and we're encouraging the 19 industry. We've written a letter to NUNARC -- through 20 NUMARC to EPRI -- asking that testing be performed to 21 results and to the concerns for MOV design and qualification 22 and along the same thought to perform industry wide testing 23 that can be used by the licensees.
24 .As Tad mentioned, we have several activities that 25 are going on right now within NRC. Not all of them directed Heritage Reporting Corporation (202) 628-4880
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19 1 to Generic Letter 89-10 but all of them trying to improve 2- the performance of motor operated valves.
3 One-is a rule change that we're working _.on right 4 now to clarify.the scope' of. testing,'the need for insuring 5 that a testing is a proper means'of judging the condition of 6 the valve and its operability.
7 Improving IST criteria.
8 Working with ASME in the OM-10 area. To improve 9- the criteria ~that are established for in service testing.
10 The stroke time of tests does not tell you much about the 11 . condition of AC valves. AC' motor operated valves. And 12 we're working in that area.
13 Regulatory guides on in~ service to provide 14 guidance on acceptable in service testing methods. Design 15 and qualification of motor operated valves evaluate the 16 valve, thrust equations. We're working to get EPRI to 17 perform some more tests in that area. NRC is performing a 18 limited scope research effort there but that needs 19 additional attention.
20 Thermal overload protection. We' re in the process f 21 of trying to resolve that issue. There is a new IEEE
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22 standard which is being considered now for approval within 23 the industry. That's P-741, which has some information on 24 thermal overload protection devises and it -- which may be 25 beneficial dn resolving that issue.
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20 1 That's basically what I was going to talk about 2 now. We're going to go through each question and respond to 3 it and expand on many of the things I've just touched upon 4 here. But I wanted to set the stage for what we're going to 5 do next. And with that, if there aren't any questions on my 6 overview we'll proceed with the questions.
7 Thank you.
8 UNIDENTIFIED: Do you have any more copies of 9 that?
10 MR. SCARBROUGH: We're going to get some more 11 made. Could I have a show of hands how many people didn't 12 get any. In that case we'll have the business office make 13 up a number of copies and after lunch everyone will get 14 their own.
15 We've assembled the questions in no particular 16 order of importance. It was mostly what was lying on my 17 desk when I started to sort them. The first one we're going 18 to talk about is the question submitted by Wisconsin Public 19 Service Corporation, the Kewanee Plant.
20 Jeffrey Bergmann. Is he her-' 0) great. Thanks 21 Jeff. Okay. I just want to know 11,' cu' re here.
22 How we'll work this is I'll start and read the 23 question, give the answer that we worked up in consensus 24 process ourselves and several other member in the NRC and 25 then I'll rely on my colleagues to fill in and supplement my Heritage Reporting Corporation (202) 628-4888
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! '21 1_ answer where#they see fit. And on certain questions I'll 2 direct'it' straight to them.. 'I 3 -
MR. MARSH: L One thing I'd like to emphasize is,
.this may be a. bit awkwar'd to begin with. Bear,with us. we 5 .may have to caucus amongst ourselves. We may'have to tell s 6 you that we're not sure about the answer and we'rel going to.
7' have to'get together over a break to discuss it amongst
-8 ourselves so bear with us. It is all in the vein'of giving
~9 you the best answer that we can. So with that.
.10 MR. SCARBROUGH: Okay. Question No. 1.
11 "If various MOV's fall under the below criteria, which 12 are listed, do we have to Delta P test them?"
13 (a), Four or more data points'from valve of.same 14 type,. manufacturer, orifice diameter and stem diameter.
15 And I think we need to mention briefly about the 16 philosophy in the 89-10. We're not following the same 17 sampling arrangement that was provided in 85-03 and the 18 guidance there. We're not allowing extrapolation of 19 pressures.
20 Part of the problem with 85-03 and the results 21 that we've seen from the testing in Idaho and EGGG is that 22 that's not a very reliable extrapolation. How we envision 23 the use of applying data from one MOV to another MOV that's 24 being considered f.or operability is, if you have identical 25 motor operated valve assemblies and you test the prototype Beritage Reporting Corporation (202) 628-4888 1
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22 1 outside the plant and you test it at a low load, fully i
2 instrumented,' test it at a' full DP, fully' instrumented, and 3 then you test the MOV in the plant at low load, fully e '4 instrumented, you can apply that one to'one.
5 The four data points, we're not. going.to have for 6 that same plant 90% confidence and things of that nature.
7 That was part of the 85-03 program. So we' re going to have 8 -- it's more simple in that regard.
9 How, (b.) of this question says:
10 " Twenty or more data points from valves of the same 11 type. Now, we're getting into non-identical MOV 12 assemblies. And if you're going to use, or if you plan 13 to use similar non-identical MOV's, it is going to be 14 much more difficult to. justify the extrapolation?"
15 And that's going to be part of the process that 16 the licensee is going to have to perform in assuring that 17 the testing that is done on those valves is extrapolative or 18 applicable to the valve that's being considered for 19 operability.
20 MR. JACOBSON: Let me just clarify a little bit 21 what Tom said. Basically that is, we're going to be a lot 22 stricter on what we're going to accept for prototype testing 23 than we were for Bulletin 85-03. Basically, unless you have 24 a very good documented approach as to why something else 25 would be acceptable, we're going to look for data on i i
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23 1 identical' valves with identical actuators. And that means 2 more than just the same manufacturer and size. We want it 3 actually identical.
4 Now, we realiz'e in a lot of cases the actuators 5 may be somewhat different. And it is possible that those l
6 differences can be accounted for calculationally such as 7 different gear ratios or something of that nature. But for L 8 the valve especially, we are going to be very strict on 9 using data from similar valves, if you call it that. We're 10 going to be looking for identical valves. I think we're 11 going to get to-the other point that I was going to mention 12 in the next question or the one after that.
13 MR. SCARBROUGH: The next question is:
"Does a Delta P test below the maximum have to include
~
14
,15 two dynamic test pressures or one dynamic test 16 pressure, one static condition and extrapolation?"
17 And I think this is just what we mentioned in the 18 first question, is that we're not looking at extrapolations I' 19 of pressures. We're looking at a full DP test either on the 20 valve that's in question on another valve that's identical 21 to it, a different train in the plant or an identical valve 22 that's prototyped outside the plant in another plant. EPRI 23 testing -- another utility -- but full DP testing. I'm not 24 looking at extrapolation of pressures.
25 Row, the third question. Jeff is going to handle Heritage Reporting Corporation (202) 628-4888 l-l FLj
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2 MR. JACOBSON: The third' question ~ reads:
3- "If; Train A of an MOV is tested, does. Train B have to E 4 be tested also?"
'5. Now, basically, it is the same answer that ar long 6' as'the valves are identical and the actuator differences, if 7 any, can be accounted for as well, then you would not to 8 have to do a full DP test on both valves.- However, you
.9 would have to do a limited DP test on at least both the
~10 valves and then you could use the full DP data:from the one 11J that you did test. So if one of them always has to be 12 tested at the. maximum calculated DP under your design basis, 13 the other valve would have to be tested at some lower 14 achievable value so you can assure yourselves that that 15 valve-is' performing similarly to one that was actually 16 tested.
17 Another point I'd like to bring out in this same 18 ' area is that if you're going to be-using data taken from 19 another plant or somebody else, you have to insure 20- yourselves that that data is validated data and treated like 21 an Appendix B type of data. You can't just take data from 22 somebody and accept it without thoroughly verifying that 23 it's good data.
24 ,-_Do you have a question?
25 UNIDENTIFIED: Would that mean then that say on a Heritage Reporting Corporation (202) 628-4888
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1 charging system where you might have three pumps that 2 historically you've put out maybe fifty more pounds than the.
I 3 other two, that you would have to test that train with the' !
4 pump that's putting out a little more pressure independently.
5 aof the other two trains?
l 6 MR. JACOBSON: Well, what we're saying -- and ,
7 nothing we're saying here cannot be changed with a good 8 justification. These are just general guidelines I think 9 that we' re throwing out and there's~ going to be exceptions 10 to anything we say.
11 But in a case where you had three identical valves 12 you' re talking about in different trains and one train the 13 pump happened to be putting out fifty pounds more, we would 14 I guess like that any one of the three valves be tested at 15 that highest pressure. You wouldn't necessarily have to 16 test the valve that's in that train as long as all three 17 were identical.
18 UNIDENTIFIED: Thank you.
19 MR. MARSH: Let me amplify a little on that. And 20 I want to say something that probably needs to be said in 21 general. But although these are guidelines that we're 22 giving you and we're trying to answer specific questions, 23 then we're not going to be able to answer all the specific 24 questions at this point. And it's going to be up to you to 25 justify questions of that sort when we come to you and look Heritage Reporting Corporation 1 (202) 628-4888
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1 at your specific valves and applications. If we find that i i
l 2 there are some differences in pump performance and you l 3 haven't been able to test through some difficulties of your j 4 own, the valves in the t' rain where the pump is getting a 5 high pressure, you're going to have to say why. Why and why 6 not. How does your analysis for that lower point train 7 cover those valves that are in the higher capacity pump 8 trains. There may be justification. It depends upon how 9 applicable one train is to the others. In general, one 10 tests the most restricted train. In general. But, there 11 may be situations that you have for justifying.
12 That doesn't mean that the exception should be the 13 rule. It just may mean there may be specific situations 14 where you aren't able to. And it's up to you to justify the 15 analyses on the tests that you have done.
16 MR. JACOBSON: Could you step up to the mike if 17 you have another question.
18 UNIDENTIFIED: What I'm hearing is essentially the 19 guideline is to tell the utilities to go out and Delta P 20 test the design basis acts and conditions every valve that 21 is covered by the bulletin.
22 The part that gives us great pause is that I would 23 say on an average probably only thirty to forty percent of 1
24 those valves can be tested period. Line break valves can't 25 be tested at all. That's addressed in the generic letter.
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27 1 :And the.other thing is, how do you prototype test a valve-
. 2' .that-hasn't been built for the last fifteen years and nobody 3 has.any outside of what's installed in your plant?
4 MR. JACOBSON: 'Well, to answer the first part of 5 your question in that you're saying there are certain valves 6 in the plant that cannot be tested at the designed pressure 7 due to whatever reason, that is why we have allowed 8 prototype testing as an alternative means. Now, I think 9 you're saying that that may be impractical due to the fact 10 that there is no substitute valves or whatever of the same 11 type available.
12 UNIDENTIFIED: There are no identical valves 13 available to prototype test other than what's in the plant.
14 MR. JACOBSON: Well, I think in that case you're i
15 going to have to come up with the best story yo'u can in 16 terms of similar valves or limited DP testing on the valves 17 that you do have and we' re going to review it on a case by 18 case basis. But in general, the guidelines that we're 19 putting out are what we want to see. Now, we realize that 20 there may be some extreme cases where they're impracticable 21 to meet. We'll have to look at those.
22 UNIDENTIFIED: Well, I guess all I'm trying to say 23 is, it's not extreme. The majority of the plants that 24 you're going tp_out and look at are going to be in that 25 condition. - The valves that are unable to be prototypically Heritage Reporting Corporation (202) 628-4888 i
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j 28 1 tested because they don't build them any more, the designs 2 have changed by the manufacturers.
3 MR. JACOBSON: Well, if they don't build them any 4 more, there must be some' spares in the country somewhere.
5 UNIDENTIFIED: Well, for example, right now if I 6 go out and buy replacement valves for a lot of the valves I 7 have in my plant, I get a new design.
8 MR. JACOBSON: Yeah, but I mean, there are other 9 ways you can get these types of valves.
10 MR. MARSH: This is an excellent opportunity for 11 industry coordination. An excellent opportunity to work 12 through some larger group that oversees valve types, valve 13 applications. Those that are available, those that can be 14 prototyped tested, those that can be in situ tested.
15 I realize that in your plant you may a valve which 16 was manufactured a long time ago and hasn't been 17 manufactured for quite a while but I can't believe that that 18 valve doesn't exist in similar application in another plant.
19 MR. JACOBSON: And if there are cases where the 20 valve is just not available anywhere, then we'll have to 21 look at it on a case by case basis but I think there are a 22 lot of sources for getting this information if the industry 23 could pull together. And that's going to be the key to 24 resolving a lot of these problems is that the plants are 25 going to ha_ve to share information. You can't expect each Heritage Reporting Corporation (202) 628-4888
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i 29 1 utility to run a series of prototype testing on their own.
2 It's just impracticable.
3 UNIDENTIFIED: Thank you.
4 MR. MARSH: I'm not sure how satisfactory an 5 answer that was to you.
6 UNIDENTIFIED: Other than totally unsatisfactory, 7 fine. I mean, I think, I just feel like you don't 8 understand the breadth of the problem from the standpoint 9 of, for example, you're talking about a code valve. The 10 distance in the stem, for instance, are not code parts. The 11 manufacturer can change those without even changing your 12 drawings. You don't even have to be notified of that.
13 So how in the world am I supposed to even tell if 14 you want an identical valve, what it is, unless I tear them 15 all apart. Are you going to tell me that I have to 16 disassemble or I have to establish a data base for the 17 industry to know by partner number what valves are in what 18 plants?
19 MR. MARSH: I'm sure you are aware of the problem 20 as well. You' re aware of the regulatory and safety problem 21 as well. And it is very difficult for us to say, no problem 22 just because the valve is not manufactured any longer it 23 doesn't need to be tested. We're looking for you and the 24 industry _as a__whole to answer this technical question. We 25 can't say there doesn't need to be any test on valve because Heritage Reporting Corporation (202) 628-4888 nj
30 1
'l it is not manufactured any more. j i 2 UNIDENTIFIED: ROh , I didn't say that there 3 shouldn't be anything done because it is no longer 4 manufactured but you were very specific in saying identical ,
5 valves. And I'm just saying that you're going to find out 6 there is a large incidence of valves that you.can't' 7 prototype test because they aren't available any more.
8 MR. JACOBSON: Well, you'll have to come up with 9 the best information or proposal that you can based on 10 what's available. Now, if the best you can do is similar 11 valves or.some lower differential pressure testing on the 12 valves that you do have, then we'll have to look at that on 13 a case by case basis. But generally, what we threw out is 14 what we' d like to see. We realize there are going to be 15 times when that can't be done.
16 MR. MARSH: I think your plant is just gone 17 through a large examination of valves as a result of the 85-18 03. I think I've heard that in a couple of different 19 meetings. And I've also heard that as a result of that 20 examination you had to replace a large variety of valves.
21 UNIDENTIFIED: No, that's not true. We're 22 replacing two valves.
23 MR. MARSH: Okay. Because of body problems 24 because of the . inability to withstand --
25 UNIDENTIFIED: Because of the inability to --
i l
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1 again, an old design -- the wedge ears.on the gate valves
- 2. are most likely to fail in the.open direction. And'because
'3 of the thrust required to close it'we ended up with a
'4- . cycling fatigue problem'with the wedge. S'o we're changing 5 now.with a different design. But again, they don't make the 6 old ones that we've got anymore.
7 MR. MARSH: Did you see whether that valve was in 8 any other plant? Could you go to an industry data base.and 9 find out whether.the valve had not been manufactured any 10 longer?
11 UNIDENTIFIED: Not to the detail of finding out as
-12 to identical valves. It'is a 600 pound, 6 inch Velan gate 13 valve. But you have to essentially go back to the purchase 14 order number with Velan to find out what drawing revision it 15 was done to. ,And even that'sometimes is difficult. We have 16 some valves that we physically had to tear apart and look at I
17 the numbers that were etched into the parts internal to the 18 valve before they could tell us when it was even built.
19: MR. SCARBROUGH: Well, this sounds like a very 20 good effort to be undertaken by the MOV Users Group. This 21 is something that they can pool all the resources under 22 various utilities together to find out what valves are out 23 there and what valves aren't. To me that would be a main 24 goal of the MOV_ User's Group.
25 MR. JACOBSON: What are your thoughts on your 1
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32 1 alternate approach? You said what we said was unacceptable 2 but you would agree that something needs to be done. What 3 do you feel --
4 UNIDENTIFIED: Well, maybe unacceptable isn't a 5 correct word. Impossible comes to mind. Nothing is 6 impossible if you got enough time and enough money. But i 7 impractical to the extreme is where I come from.
8 What we're trying to do and what we've done is 9 we've done a lot of type testing based on type, size, 10 orifice diameter, that type of thing. And then the way we 11 look at it is you don't attempt to essentially calculate 12 exactly how much the valve requires to close it. You 13 attempt to bound the limiting conditions.
14 For example, the INL testing that was done at 15 Wylie showed about a .5 friction factor. Well, if you can 16 -
you got 6 inch gate valves in that ball park, then you 17 should be able to go ahead and do that. Now, there are 18 other valves in the industry -- currently Duke has had some 19 problems with certain types of valves because the valve 20 guide -- the internal guide design -- of that information is i
21 published. So that gives you a different set of rules to 22 live with. One of the valves that was tested at INEL has 23 excess of what appears to be guide clerks that causes )
I 24 difficulties. .
{
25 Part of the difficulty I'm having with this is Heritage Reporting Corporation (202) 628-4888 n_
33 1 the generic letter itself says if you got a valve in a line 2 break condition which is essentially that testing has been 3 done. It is being done right now. That's do be done at a 4 calculational basis. Because it is recognized that we can't 5 do that.
6 So if that's allowed under the generic letter, 7 then how is it that we can't use the same philosophy with 8 the rest of the design basis testing. It does not require 9 when you go prototypical to test a valve for line break 10 conditions.
11 MR. JACOBSON: Well, you just said something that 12 the calculational method is allowed in the generic letter?
13 UNIDENTIFIED: Essentially, the generic letter 14 says for line break conditions you're not required to test.
15 And that only makes sense because it is physically 16 impossible in the plant without doing damage. But there is 17 no real requirement for you to go prototypically test line 18 break conditions per the generic letter as it's written i
19 either. l 20 MR. JACOBSON: That's correct. However, I think l 21 it says in the letter that you have to use the best data 22 available -- words of that nature.
23 UNIDENTIFIED: Well, it tells you to use a two 24 stage approach.____ It tells you to use the best is that 25 available now until more comes available down the road.
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34 1 MR- JACOBSON: I think what we're saying is that 2 if.that's the last resort, we're certainly not going'to I-3 Laccept just using a .2 valve factor flat out which'nas the 1
4 common practice in the past. Now, something like you're E 5 saying with using a .5 and you've got test d.sta that bound f
6 that, we.would look at that. We can't say if that is going 7 to be acceptable or not but if you can -- the more data the 8 industry gets in this area, the better the data becomes. !
9 But right now what we see is that the data that's out there 10 is not very good. We've seen a lot of different data. And 11 we really would be uncomfortable with somebody using data 12 unless it's from an identical valve.
13 Now, as the industry, if they get together and as 14 the data base grows, so forth and so on, the data may get to-15 be better and we would look at that.
16 UNIDENTIFIED: Well, I guess the only thing I 17 would say is, don't hang your hat on identical valves either 18 .because depending upon the condition of the valve, you'll 19 find different test results from two valves that came out of 20 the lot.
21 MR. JACOBSON: That's one of the reasons why we're 22 saying that even with identical valves you have to do at 23 least some testing on both valves. Maybe not the full DP 24 but you have to_do_a lower than full DP test on both valves.
25 UNIDENTIFIED: I just think that you're going to Heritage Reporting Corporation (202) 628-4888 t - -- ------_-. _ _ _ m
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!> 35 1 -find that there is a lot of less testing that can be done v
2 than what you appear to be indicating you want to see at 3 this particular point at least in the plant.
4 MR. MARSH: Ok'ay. Thanks.
5 UNIDENTIFIED: Thank you.
6 MR. MARSH: We do want to stay within the 7 . guidelines of the questions. Okay. We do want to stick to 8 the music that we've got here. And I don't want to cut you 9 off but if you-could hold on to see where some of these 10 questions go, you may get some of these things answered. So 11 if you got to, go ahead, but let's stick to the music for a 12 bit. Thanks.
13 MR. SCARBROUGH: We did ask for questions. I want 14 to get Mr. Bergmann's questions answered and everyone else's 15 written. questions,-give them the courtesy of trying to 16 finish their questions.
17 The next one, No. 4.
18 "What does prototype MOV consist of?"
19 The first preference when you come to prototype, 20 my definition of a prototype is an identical MOV assembly, 21 an identical valve an actuator. But, of course, that may 1
22 not be always possible.
23 If you are going to justify a non-identical MOV, i
24 then you'll haya to perform additional tests and make sure l 1
25 that the various factors are considered. Rate of loading of Heritage Reporting Corporation (202) 628-4888 l
36
' l- the. actuator-has been found to cause differences in 2 responses. That will have to be considered.
3 One aspect, when we talk about prototype, the
- 4. valve.itself has to be identical, the valve. That is the 5 cornerstone. Whether or not you have the same actuator on 6 .it, motor, that you can justify differences there. But
!- 7 wie're looking for an identical valve.
8 Number 5 was clarified on Page 5, Section F, 9 Paragraph 4 explained for place modified and overhauled.
10 And let me read the whole sentence. This is the repeating 11' design basis testing sentence.
12 " Testing of MOV at design basis conditions need not be 13 repeated unless the MOV is replaced, modified or 14 overhauled to the extent that the licensee considers 15 that the existing test results are not representative 16 of the MOV and its modified configuration."
17 The sentence was written to allow flexibility and 18 to provide that the licensee make that justification. If 19 the licensee considers that the testing requires -- that is 20 required after this modification or overhauling can be done 21 at a low DP that can identify any differences that might 22 occur. The packing load of some type. Then that can be 23 justified.
24 f Bututhe , attempt there was to allow flexibility for 25 the licensee to determint, when additional testing is Heritage Reporting Corporation (202) 628-4888
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2_ Now, the sixth question.. Mr. Kiessel:is going to
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3 handle that.one for us.
4 MR. KIESSEL: 'he T question reads:
5 "Can we make'a decision not to do a complete diagnostic 6 test following an MOV packing adjustment or maintenance 7 if various indicators taken from the MCC have not 8 changed considerably and the required thrust is below 9 the actuator maximum initially?"
10 The answer is yes, but. And in here again it will 11 depend upon your program. .Your program is going to have to 12 be able to demonstrate that what you observed with that MCC
'13 test is sensitive enough to detect changes of a magnitude 14 that would adversely affect the valve.
15 And by that sensitivity we mean all of the 16 instrumentation error that not only is involved in the MCC 17 test but establishing what the base line values are for that 18 MCC. The question also at the end where it says, where the 19 required thrust is below the actuator maximum initially. ,
20 This, of course, would assume that there is no torque or 21 thrust limiting device in the actuator. If there is, then I 22 really what we're talking about is what is the maximum or 23 actual -- what torque or thrust can be delivered based on 24 the torque switch setting.
25 MR. SCARBROUGH: Thanks, Dave.
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38 1 The' final question submitted by Wisconsin Publ'ic l 2 Service was', No. 7.
t 3 "Will the meeting minutes for the workshops be L
4 available to the ut'ilities?"
5 And the answer is, yes. Tad mentioned that' l
b 6 earlier. The transcripts will be placed in the PDR for your l'
- l. 7 review. Then the minutes themselves will be a compilation 8- of all three meetings. And there won't be a meeting minutes 9 for. Chicago'and -- it will be compilation. And the minutes 10 will focus on the most important questions and responses.
11 That's it for Kewanee. Did Mr. Bergmann have any 12- questions he wanted to mention on these right now? We have 13 many others to go through.
14 MR. MARSH: I wondered. Is this gentlemen that 15 I -- held off for just a minute. Did any of these answer 16 your question?
17 UNIDENTIFIED: No.
18 MR. MARSH: Okay. Why don't you go ahead and let 19 us have your question.
20 UNIDENTIFIED: During the development of the 21 generic letter, a large part of the motivation was that the 22 diagnostic testing was being used at a substantially reduced 23 differential pressure and extrapolating upward.
24 _ And the thrust of the generic letter in this area 25 was that the further you have from the design basis Beritage Reporting Corporation (202) 628-4888
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j ' 39 1 condition on-the DP, then-the more error the extrapolation 2 .would have in it. And so it seems to me that an identical 3 valve is the valve that you're using. And if you can 4 establish a differentia 1' pressure that is sufficiently close
- 5. to the design basis differential pressure, then the l
l 6 extrapolation should be possible. And if you can establish 7 the behavior of the thrust required curve, then you should 8 reasonably except within some adding into the differential 9 pressure input to the thrust required curve a methodology to 10 do testing at lower than maximum DP and approach these 11 valves that way rather than doing prototype testing.
- 12. MR. SCARBROUGH: Yes, the extrapolation of 13 pressures was from like a low DP to a full design basis DP.
14 There is flexibility in there. If you're very close to your 15 design basis DP, then a few pounds or 50-pounds -- I don't.
16 think we have a number -- and you can see that extrapolation 17 there'is slight and would easily accomplish the operability 18 cf the MOV. I don't see that there would be a problem there 19 because it is sufficiently justified.
20 MR. MARSH: It seems to me the key is you being 21 able to justify extrapolation. That means that you're going 22 to have to know the characteristic of the valve as a j 23 function of differential pressure.
24 c UNIDENTIFIED: Well, I submit that when you're 25 doing this type of testing that you're going to develop this Beritage Reporting Corporation (202) 628-4888
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/ 1 behavior because'in a large number of plants the valves are 2' typically supplied by.one major supplier. And you have a L ,
'3 large arena'of testing to do for various sizes and types of 4 valves. You ought.to be' ableLto work out that behavior.
- 5. MR. JACOBSON: I think if you.could show us the L
.6 data and how ik ves arrived at we would lookfat it. What-
- 7 .we're
' saying is, in general, we want the pressure to 8: ' envelope . what' s' ' required.
9 Now, if you can't do that, we're going to have to 10 'look at it. And from what we've seen now, we've heard'a lot 11 of uncertainties'when you start extrapolating data and we 12 just have a bad feeling about that right now. We haven't 13' seen;the data to prove otherwise. Now, if the industry can 14' get together and get a good data base together and work out 15 :some of these problems,,we're going to willing to listen to 16 them.
17 UNIDENTIFIED: Well, I would agree with you that 18 extrapolation from distant differentials has got to be in an 19 inexact science. But at the same time the generic letter
.20 speaks to doing the extrapolation. And I think that's an 21 approach that I would follow.
22 MR. JACOBSON: There's another problem that I've 23 seen in the field in this area and that is people are trying 24 to set their v34ve,s up to work at unrealistic pressures just 25 because it da in some document in the plant.
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41 1- For instance, I was at one plant and due to the 2 fact that they didn't know what the real' differential 3 . pressure was going to be on the valve, they just used the 4 design pressure of the p"iping. Now, that.was ridiculous 5 because there was no way that that valve was ever going to 6 see that much pressure. And they were saying, well, we 7 can't do a full DP test because we can't achieve those 8 conditions.
9 And I think maybe if some of the plants did a 10 little more work in that area, some of those pressures could 11 come down and they may be a little more achievable in doing 12 the design basis testing.
13 UNIDENTIFIED: Well, I suppose that's okay. But 14 if you have a bound that is within the capability of a 15 valve; i.e, the valve is not going to be damaged and it can
'16 withstand the actuator doing its job, then the case is 17 bounded and the exact value that occurs within that boundary 18 is immaterial. The valve is going to function according to 19 the device.
20 HR. JACOBSON: Well, that's true as long as you 21 can do the test. What I'm saying is, if the only reason you 22 can't do a full DP test is because your value is 23 unrealistically high, it may be a better idea to bring that 1
24 value down to;a_ realistic number than try to justify some a
25 other type vf extrapolation.
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l 42 1 UNIDENTIFIED: Yes, but you can see a situation 2 where you might have 25 valves all of the same manufacture body style, same -- what you would call an identical 3
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l 4 valve -- had the same torque switches, et cetera, then you 5 could base your settings on the highest DP valve.
6 MR. JACOBSON: That's fine as long as you can do 7 the test.
8 UNIDENTIFIED: And you could test that one valve.
9 I can't see a limitation for doing a prototype test outside i 10 of the plant. I think you could do a prototype test inside 11 the plant.
12 MR. JACOBSON: Well, unless there is no valve 13 available.
14 UNIDENTIFIED: Well, your description of a 15 prototype test says that it's an outside test.
16 MR. JACOBSON: Well, it could be an inside test, 17 too.
18 UNIDENTIFIED: Well, okay. I would like to --
19 MR. SCARBROUGH: Yeah. That's in situ. Prototype 20 -- at least my definition - prototype is something that's 21 outside the plant. In situ, sure, if you want to have 22 identical trains -- test the valves in one train and apply 23 it to the other train, that could be justified. There's no 24 problem with that.
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43 1 at the full differential pressure for the one outside the i
2 plant or the one inside the plant that happens to be in the 3 other train. So if you have ten valves in your plant and 4 you want to test one, and they're all identical, and you 5 want to test one out of the ten at the highest pressure and 6 use that to envelope the other nine, I don't think we would 7 have any problem with that. But if you can't achieve that 8 pressure, it may be a better idea to look at the pressures 9 and try to bring them down if that's possible.
10 UNIDENTIFIED: Agreed. But at the same time, you 11 may be able to envelop eight of them, okay. And then you 12 have to work on two.
13 MR. JACOBSON: Okay.
14 UNIDENTIFIED: I'm satisfied.
15 MR. SCARBROUGH: Why don't we go on to the next 16 set of questions we've received from the Perry Nuclear Power 17 Plant.
18 Is Mr. Chattergee here?
19 UNIDENTIFIED: I'm here from Ferry.
20 MR. SCARBROUGH: Oh, you're from Perry. That's 21 fine.
22 These questions are rather long so bear witt me 23 while I read them. Question No. 1.
24 "More clarification is necessary for the definition of 25 a safety related system. Is it a system that contains Beritage Reporting Corporation (202) 628-4888 L
44 1 one or more safety related valves or one that has all 2 safety valves? Is it that set of valves that are fed 3 by class 1-E power or those valves which have automatic 4 positioning for saf'ety?"
5 And I believe the answer there is quite simple.
6 The generic letter is not trying to create a new set ofl 7 safety related or anything in that regard. The FSAR should 8 define the safety related systems and in some cases actually 9 it specifies safety related valves. That is where you'll 10 find the systems that are addressed. -You've identified the 11 safety related systems and those valves in those systems are 12 the ones that are covered by the generic letter.
13 MR. MARSH: Did we answer the intent of the 14 question? Where's the gentleman with the question? Did we 15 answer your question?
16 UNIDENTIFIED: Well, I think we have some unique 17 situations where we have safety related systems but not 18 safety related valves as the operator. The operator is not 19 considered safety related.
20 MR. JACOBSON: Are they blocked out?
21 UNIDENTIFIED: It depends on your definition of 22 blocked out. They are not physically blocked.
23
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25 Lf they're blocked out and you've got a safety Heritage Reporting Corporation (202) 628-4888 re
45 1 related valve because it's in a pressure boundary but it 2 performs no safety function, I assume., so the actuator is 3 non-safety related?
4 UNIDENTIFIED: Yes.
.5 MR. JACOBSON: Is that the case? If it is blocked 6 out, then we would say that that's okap. You don't have to 7 worry about it. And we're going to talk about what's 8 considered to be blocked out.
9 MR. MARSH: .The key thoughLas I think what Mr.
10 LScarbrough has said is, we're not redefining the term safety 11 related for the plant. It is as you have described it for 12 yourselves for which you have documentation, for which the 13- valve is or is not on your cue list itself.
14 I understand there is questions about whether the .i 15 body is in a safety related class but whether the operator 16 is or is not. We're going to hear more about that. But it 17 really relates back to the plant's safety analyses whether 18 .that now was or was not taken credit for as supplemented by 19 the position changeable definition for the generic letter.
20 MR. SCARBROUGH: We're going to talk more about 21 the case by case approval questions at lunch so we'll have 22 more clarification of that later.
23 Question No. 2.
24 "Is;it a_4 rue _ statement that all position changeable 25 valver by your definition are safety related or could i
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1 -there be non-safety related' valves'instead from non-2 safety power? How are ASME Section 11 valves with'non-3' safety operators handled? Explain?"
4 This gets into'the question of position s 5- changeable. And the.way it is worded in the generic letter j 6 is a little awkward. But its not as awkward as it may l 7 . appear.-- All MOV's in a safety related system must be in the 8 program unless -- two things. Operation is not relied on or 9 needed in an. accident situation.- That means, that the 10 operable aspect.
11 An. example would be.a pressurized spray valve.
12 The pressurized spray valve could be open or shut in an 13 accident and it is not considered, it doesn't matter, it's 14 never relied on, it won't affect the accident one way or the 15 other, then it doesn't need to be a program. If it is ever 16 relied on in the design basis or in some emergency operative 17 procedure, then it is in the program.
18- The other way to remove something from being in 19 the program is have it blocked from operation. And we have 20 a more detailed explanation of what we mean by that coming 21 up so bear with us.
22 But that.is basically the answer to the question 23 about position changeable. It's MOV's in safety related 24 systems.; Whether_or not you call it safety related or you 25 don't call dt safety related and 'it's a maintenance type of Heritage Reporting Corporation (202) 628-4888
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47 1 valve or a test type.of valve, if it's an.Mov in a safety 2- related system, you get to rest it. And there's ways to 3 remove it from the program once you get to that point.
4' The third ques' tion was:-
5 "What is the relationship, if any, between that-set of I
-6 in service test valves detailed in Generic Letter 89-04 7- and those safety related interchangeable valves 8 detailed in 89-10? Are they the same set? Is one set 9 more than the other?"
10 MR. MARSH: More important.
11 MR. SCARBROUGH: Yes. More important than the 12 other?
13 'There.is no direct relationship in terms of 14 applicability or instituting the programs in Generic Letter 15 89-10 and 89-04. They aren't inter-related documents in the 16 sense that they were written together. The sets of MOV's 17 covered by those generic letters overlap because Generic 18 Letter 89-10 applies to safety related systems. Those among 19 our valve intake related systems. And Generic Letter 89-04 20 addresses testing of ASME code and it talks about the scope 21 of in service testing.
22 So there's an overlap there because the subject
'23 that they're covering is the same basic subject -- testing.
24 But there is no reason to be concerned about the inter-25 relationship of the two generic letters. We treat them Heritage Reporting Corporation (202) 628-4888
48 1 separately when you're trying to implement a program.
2 Now, the fourth question.
3 MR. MARSH: Let me just -- before you go on. Let 4 me make sure that the gentleman understands our answer about 5 89-04 and 89-10 and the scope differences and the class 6 component and safety related. We are talking about, as Tom 7 says, valves that do overlap. Section 11 talks about Class 8 I, II and II components and they have a specified function l 9 of setting down the reactor, et cetera. And safety related 10 valves in most cases are class valves. Class I, II and III.
11 But in some cases they are not class valves. And we also 12 talk about position changeable valves in this particular 13 generic letter. That is different than the IST program.
14 The IST program does not discuss position 15 changeable valves. It talks about active valves which have 16 to change a position, have a specified function of shutting 17 down the reactor.
18 So, the simple answer to the question is that the 19 89-04 set of valves is a smaller set that the 89-10 set of 20 valves but there is overlap between the two. And I would 21 not want to say which one is more important than another.
I 22 They' re both inportant sets of valves and there are testing 23 requirements for both. Is that clear, sir? Okay.
24 ,.MR._SCARBROUGH: Okay. The fourth question.
25 Jeff, do you want to do that.
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'1 49 1 MR- JACOBSON: The fourth question reads.
2 "The generic letter states that, no change to the 3 existing plant design basis is intended and none should 4' be inferred." "Is'it not a fact that analyzing a valve 1 5 which is out of the design basis position be changed to 6 that design base?"
7 That's the first part of the question.
8 "This statement seems contradictory to the analysis you 9 are asking us to perform. BWR design does not require 10 that an cperator recover from the inability to 11 ~ reposition a mispositioned valve because of redundant 12 reversed backup systems available; i.e., single 13 failure. Includes operator error of valve 14 mispositioning."
15 Okay. Let me try to verify a little bit about 16 what we meant by all of that. When we said that no change 17 to the existing design basis is intended or referred, what 18 we meant was that we're not requiring you to analyze any new 19 scenarios or anything of that nature.
20 However, we realize that this disposition thing 21 may not have been considered before. But we are asking that 22 you consider it now. And just because you have redundant 23 trains is not a reason that you don't have to consider it.
24 You don't design a_ fault into your system. You might have a 25 valve in there that's mispositioned that could not be able Heritage Reporting Corporation (202) 628-4888
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T _- 5 0 l' to be' returned. And you can't use:that as your single 2 failure is:what we're saying now.- You have to be able to 3 ' ensure'that mispositioned valve can be returned to a safe-
, 4 position.
5 MR. SCARBROUGH: This came up in 85-03 and that L '6. was'one reason ~for the supplement.to 85-03 and there was a' F'
i 7- ' clarification by Ed Jordan, Director.of AEOD on, .yes, this 8 type of single failure is intended.to be placed into the 9 program.and that we understood that some plants thought the 10 . single failure handled it but because of the concern for 11 safety:it was being required that position changeable be 12 considered.
13 MR. MARSH: It really is an extension to the 14 licensing basis. In other words, it isn't something new and .
15 different in many respects because most cases plant safety 16 analyses did not assume that the valves were in the 17 incorrect position initially. Safety analyses normally-18 assume the valve of the system is lined up, ready to go, and 19 the first thing that happens is the initiating event 20 followed by a single act of failure which means a valve 21 which is required to change position thereafter. Not that 22 the system is initially in the incorrect position. That is 23 not a classical safety analysis assumption. In some cases 24 it is bu% in nest _ cases it is not.
25 MR. SCARBROUGH: The fifth question Dick Kiessel 1 1 Heritage Reporting Corporation (202) 628-4888
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51 1 is going to handle.
2 MR. KIESSEL: "Is it not true that if we analyze
.31 for a mispositioned valve we need only to analyze it to 4 reposition it back'into.its design base position and 5 not analyze the effect this mispositioning will have on 1
-6 upstream and downstream valves?"
7 In essence, yes, because we're assuming that with 8 your ability to recover.the mispositioned valve you have
~
9 been restored to normal' pressures to the valves upstream --
10 , the downstream of it. And, therefore, then they should 11 function properly.
12 MR. SCARBROUGH: Okay. The sixth question..
13 MR. MARSH: Before we go. 'On five, I think we 14 answered the intent of the question. But was there 15 something -- let me ask it this way. Is there something 16 that's being omitted because of the answer to the question?
17 In other words, is there a hydraulic transient on valves I
18 downstream or upstream that is beyond their current i
19 capability that would not have to be analyzed because of the l
20 answer that was given? 1 21 . UNIDENTIFIED: I think the answer was appropriate 22 to the question.
23 MR. KIESSEL: Okay. Now, bearing in mind we were 24 not trying to_buil_d new scenarios but in a subsequent ,
l 25 question from Perry you start talking about multiple Heritage Reporting Corporation (202) 628-4888 i
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f i- .mispositioning of the same valve from what I understand?
2 ; UNIDENTIFIED: Right.
3 MR. KIESSEL: 'And we'll'_get.to that one later on.
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4' And th's answer gets changed around.a:little bit.
5: MR. SCARBROUGH: In general, just to add. If L .
6: -during'your analysis.of generic 89-10.you discover that.
7' there is a reportable situation according to the 8 regulations, you need to: report it. And that is covered
.9- .under the regulations under 50.72 or 50.73 under reporting.
- 10. conditions in the. plant which may be of urgent safety. And 11 'that is handled separately in that generic letter. You.
12 should be aware of that if you do something.
13 Question No. 6.
- 14. - "It is not perfectly clear that butterfly valves are 15 included in this set of valves since the 85-03 letter 16 required only rising stem. valves."
17 That's.the first half of the question.
18 Butterfly. valves are in the program. They are 19 covered by generic letter 89-10.
20 "Are sluice gates considered valves?"
21 That's an interesting question. But if it has a 22 motor operator on.it and if the licensee considers that that 23 sluice gate is performing a safety related function, then it 24 should be_in the, program.
Now, the licence may justify --
25 form some sort of analysis just by that not being in the Beritage Reporting Corporation (202) 628-4888 L
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53 1 program and that will be put to rest by the NRC on a case-l 2 by-case basis.
1 3 But the concern there -- in terms of dampers in J i
4 another question which I' don't think came up at this 1 5 meeting. But in another package of questions at the 6 Rockville meeting was are our dampers in the program? And i 7 the answer is yes, dampers are in the program. And our 8 management decided that if it had a safety related function 9 and it looked like a valve, a damper would be part of the 10 program. So under that same philosophy sluice gates would 11 be part of the program.
12 MR. JACOBSON: Do you have a question?
13 MR. KIESSDL: Before we go on to the question, I' d 14 like to interject one thing. And that is that this question 15 starts off on an erroneous assumption that 85-03 only 16 applied to rising stem gate valves. It applied to all 17 valves in the effected systems. Whether they were globe 18 valves, gate valves or whatever kind of valves. I'think the 19 problem is that most of the diagnostic systems that have 20 been developed to date are really geared around rising stem 21 gate valves. But that's no basis for saying that the 22 bulletin itself is limited to those valves.
23 HR. JACOBSON: Do you still have a question in the 24 back? . ___
25 UNIDENTIFIED: We were told at the ACRS meeting Heritage Reporting Corporation (202) 628-4888 ct
54 l' .that dampers were not included'in the scope of the generic i 2 letter. <
i 3 MR. JACOBSON: You weren't.
4 UNIDENTIFIED: "Yes, we were. We were told that 5 ' systems that ventilation systems were not included in the 6 -scope of the generic letter. Now, we're not talking about l 7 the containment of purge valves. We're talking about 8 dampers.
9 MR. JACOBSON: Do they have motor. operators on 10 them?
11 UNIDENTIFIED: They may have motor operators on
'12 them.
13 MR.-JACOBSON: They have valves and motor 14 operators?
-15 UNIDENTIFIED: Right.
16 MR. SCARBROUGH: We'll clarify that in the 17 meeting.
- 18. Our understanding is that dampers are in, and our 19 management has said that dampers are in. We can check the 20 transcript of the ACRS meeting and if something else was 21 said, we'll have to address that. But I was not aware that 22 they had been told that dampers were out.
23 Who said it?
24 ,MR.J ACO_BSON: Who said it? Do you know?
25 MR. MARSH: It doesn't matter. The guidance that Heritage Reporting Corporation (202) 628-4888
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-1. we're:giving-is that dampers are in. Okay. That's the 2 guidelines you got. Dampers are in. That's the guidelines 3 that our management.has given us. That's what we want to 4 .tell this group'right he're.
5 UNIDENTIFIED: Now, we were talking about 6- different types of dampers. There are butterfly valves used 7 as dampers and there are like venetian blind type-dampers.
8 And we were. told that dampers or valves ~in system use as 9 dampers were not included in the scope of the generic 10 letter.
11 MR. MARSH: We will try to clarify that before the 12 end of the day. But it.is our information here that dampers 13 of that sort, butterflies and venetian blinds are in. If 14 they perform a safety function, if you've got an operator on 15 it that's the subject of this problem, it was in. ,
i 16 I don't know what the ACRS process entailed but This is in our I 17 this is a different process we're in now. >
18 generic letter. Not a Commission approved document for ACRS 19 approval. This is specifically a different process by )
i 20 itself. It is my impression and I think it is everyone's 21 here that dampers, whether it is venetian blind type or 22 butterfly type or whatever else, are in the program. Okay?
23 UNIDENTIFIED: Okay. It may be difficult to test.
24 ;-MR.;KIES.SEL: Are you perhaps confusing -- I 25 remember there was discussion at ACRS on this and the staff j Heritage Reporting Corporation 1 (202) 628-4888 l
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-56 1 did say that you did not have to include those dampers that i 2 were used solely for pressure balancing to make sure that
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3 you get.the proper amount coming out of the right hand vent j 4 and opposed to the left ' hand vent.
5 UNIDENTIFIED: Right. We weren' t talking abc<- F 6 those. We were talking about safety related dampers.
7 MR. KIESSEL: Okay. So you're talking about -- ,
- )
8 UNIDENTIFIED: Safety related dampers that receive J t
9 a safety actuation.
10 MR.'KIESSEL: That do have to function.
11 UNIDENTIFIED: Right.
12 MR. KIESSEL: To the best'of my knowledge it has 13 always been our position that they are included.
14 UNIDENTIFIED: Mr. Marsh, I have one more 15 question. Did you say that consideration for mispositioning 16 is an extension of your licensing basis?
17 MR. MARSH: To the extent that that the term 18 licensing bases that was used, as I understand it in the 19 discussions with the ACRS through the management chain, were 20 that no new accident scenarios were being added to the 21 plants licensing bases, okay?
22 UNIDENTIFIED: All right.
23 MR. MARSH: But that mispositioning of valves as 24 an initial conditi.on was probably not thought up initially 25 and it is expressly in this program. So you can use Heritage Reporting Corporation (202) 628-4888 O
57 1 whatever words - you got to be careful about licensing 2 bases. That's what -- I want to be careful about that.
3 It's an extension perhaps of valves that were considered in 4 the plant's safety analy' sis.
5 UNIDENTIFIED: The confusion is that in the 6 generic --
7 MR. MARSH: The generic letter talks about not 8 extending the plant's licensing bases, i
9 UNIDENTIFIED: Right. I believe it is Item E. !
10 MR. MARSH: And I think what we're trying to say 1
11 is that what that meant was accident transients, abnormal 12 occurrence scenarios are not being added. We're not adding 13 new steam generator tube rupture scenarios to plants for 14 which there may not have been initial licensing bases.
15 We're not adding new feed steam line breaks for'those plants 16 for which it was not considered initially. So the set of 17 accidents and transients that fall within the FSAR's aren't i
18 the same. We're not changing those. But if a plant relied 19 upon a system configuration and there is a valve in that 20 system that can be mispositioned, then this generic letter 21 says, ensure that it's got the proper torque, the proper .
22 qualifications, the proper ratings to get it into the 23 system.
l 24 c Because _the genesis of the whole generic letter 25 was a mispositioning of valves. That's the whole purpose {
l l
4 Heritage Reporting Corporation (202) 628-4888 ,
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hd 58, l- 1 85-03 happened. .That's exactly why we started down the path .l
~2 and that's why we issued supplement l'. Because we wanted to i
3 make sure that with 89-10 it was clear that the 4 mispositioning valves was expressly inappropriate.
5 UNIDENTIFIED: Thank you.
6' MR. SCARBROUGH: The next question is a 1
7 significant' question.
8 "Can you give some examples for blocking inadvertent 9 operation of a valve? Is using a key' switch in the 10 control room considered a blocking device?" 4 1
The 11 We've had several questions on this.
12 . philosophy.in terms of blocking -- mispositioning is to 13 prevent inadvertent operation. Inadvertent operation. You 14 need to prevent this inadvertent operation both electrically 15 and mechanically.
16 Electrically you can do it by several ways. You 17 can rack out the circuit breakers. That's one way. You can 18 have a key lock switch in the control room. This key can 19 not always be in the key lock. That's defeating the whole 20 purpose of the key lock. That a key has to be separate.
21 But you can use a key lock switch.
22 You also need if you're blocking it in the control 23 room, you have to make sure that it's blocked electrically 24 also locally. _So whatever method you use to block 15- electrically-y you have to block the control room f d
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1 mechanically:
2 You have to block it mechanically. You can use a 3 hand wheel chain if you wanted to. You can use a safety 4 seal. One of these little seals they use on railroad cars, 5 box cars. Or you can have a locked door. You can have the 6 valves or -- these particular valves in a small room and you 7 can lock that door to prevent people'from just wandering in 1
8 and changing position of the valve. That's okay.
9 The key is that you want to make the operator 10 either the control room or in the plant think before they 11 change position of that valve. Juui a little tag, a little 12 paper. tag sometimes doesn't handle that. Sometimes those 13 tags end up in the sump. So you need something that is a.
14 little more positive than that. Okay. That is what we mean 15 by blocking inadvertent operation. Okay. Was there any 16 questions on that? Yes, sir.
17 UNIDENTIFIED: Well, at our plant, Waterford, my 18 interpretation of blocking in a sense is that, for instance, 19 we feed our valves through the motor control centers. And 20 what we do is we trip the breaker and we have a cable with a 21 lock on it which prevents you in the control of them 22 operating and you can't look and trip the breakers I'm 23 assuming. I mean, you can't look and applied power to the .
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- 24 valve and cause_it_to operate. I was wondering if that was j j
25 acceptable? I l
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_ 1- MR: SCARBROUGH: On the surface that would be 2: acceptable from an electrical point of view. .I' don't know 3 whatfa mechanically active valve itself whether that could' 4 be overridden and you co'uld'still close the valve.
5 MR. JACOBSON: Couldn't you close it manually by a 6- hand wheel?
7 UNIDENTIFIED: Manually.. I think we put a' chain 8 on it -- on the hand wheel.
-9 MR. JACOBSON: Oh, .you changed'it?
10 UNIDENTIFIED: Yeah. A chain hand wheel.
11' MR. SCARBROUGH: That' sounds fine..
12 UNIDENTIFIED: I'm assuming that you said it had 13 to meet electrical and mechanical requirements. In the 14 electrical aspect it was just that we tripped the breaker 15 and then we put a cable through the handle at the remote 16 control center with a box.
17 MR. JACOBSON: Well,-it's manual -- it's 18 prohibited from reclosing the breaker, right?
19 UNIDENTIFIED: Right.
20 MR. JACOBSON: Because you got a lock.
21 UNIDENTIFIED: A lock, right.
22 MR. JACOBSON: The key here is that it has to be 23 mechanically and electrically blocked. I guess another way
'24 to mechanically _ block them might be to remove the hand wheel 25 altogether.-
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61 1 MR. MARSH: Yes, sir.
2 MR. KONSTANTINOU: I'm Nick Konstantinou with 1
3 Commonwealth Edison. How are you going to address manual 4 ' valves if you are now considering mechanical locks and 1 5 electrical at the same time?
l E
6 MR. KIESSEL: Now, you're saying how can we l
l 7 address --
8 MR. KONSTANTINOU: Are you addressing manual 9 valves with this generic letter?
10 MR. KIESSEL: No , we're not.
11 MR. KONSTANTINOU: If you're not addressing the 12 manual valves -- I mean, somebody can inadvertently operate 13 the manual valve.
14 HR. KIESSEL: I agree wholeheartedly but this 15 generic. letter in this proceeding bulletin were limited 16 motor operated valves. I mean, we could -- you also have 17 the same problem with your hydraulic valves and your air 18 operated valves. That they could be mispositioned or they 19 could be improperly si=ed.
20 Give us time. We'll get to them.
21 (laughter.)
22 But right now we're just working on the MOV's.
23 Yes, sir.
24 UNIDENTIFIED: A number of valves have lock out
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62 1 signals can be reset and the valves are still available. If 2 you end up having to both electrically and mechanically 3 isolate a valve from usage, then the valve is essentially 4 unavailable later on as'the accident progresses. It seems 5 to me that a large number of valves only have electrical 6 isolation ar,a that's a good feature. I would have to 7 develcp that on a case by case basis. I thought in general 8 you would like to have your equipment available for whatever 9 transpires down the road. Operators are not in the habit of 10 running down to an MOV and operating it inadvertently.
11 That's a big leap in faith.
12 MR. MARSH: Right. It seems to me that valves 13 that are only electrically interlocked or for which there 14 are only electrical measures, interlocks or pressure 15 switches or safety injection recirculation signals or 16 whatever else, that -- for which you don't want to provide 17 mechanical airlock because you want that valve to be 18 available. They ought to have the right type of evaluation 19 to ensure that they can operate should it be mispositioned 20 because it may very well be that they are mispositioned )<
21 accidentally by the electrical signal during the phase where 22 you want it to be available.
23 For a Sump recirculation valve -- is electrically 24 mispositioned_.at-the wrong time in the event. That can be 25 very deleterious to pumps that taking their suction from the Heritage Reporting Corporation (202) 628-4888
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-1 RWST. You sure don't want to lock out mechanically that 2 valve either because that would mean that you don't have 3 some suction available to you.
4- So that means'that you ought to test, evaluate, 5 ensure that if it is mispositioned, that you can reposition 6 it properly. We don't want.to put the plant in an unsafe 7 condition by this position. It's not an intent to lock out 8 valves. To put the plant -- to have valves become 9 unavailable or sources unavailable.
10 -UNIDENTIFIED: Okay. Well, then I would ask that 11 you modify your position int he last question'to provide the 12 appropriate interlock; i.e., perhaps just a key lock switch 13 on the board to -- because.the boards -- the safety systems 14 are checked on a periodic basis for proper alignment and a 15 number of things can happen. One iu you can pull the 16 breakes out and in effect eliminate positien indicating.
17 And, therefore, checking the board doesn't help anymore for 18 your electrical valves.
19 MR. MARSH: Let us chew on that. I think the i
20 basic intent of position changeable and we're moving power 21 and mechanical devices was not to include valves that have a 22 legitimate reposition in subsequent portions of an accident.
23 MR. SCARBROUGH: Right. That's the whole idea 24 behind the mispositioning and probably why the generic 25 letter starts off with safety related valves -- valves that Heritage Reporting Corporation (202) 628-4888 i
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i-i 64 1- have a safety function are in the program. Now, you get to 2 this other set in here is called position changeable. They 3 don't really have a safety function. You don't really care.-
4 All you want to do is ma'ke sure that'they're inadvertently 5 placed in the wrong position.
6 Blocking is one means of making sure it does not 7 ' inadvertent 1y'be placed in the wrong position. And that way 8 you don't have to worry about it and it's out of the 9 program. You don't need to have to perform any tests to 10 make sure you can get it back into the proper position.
11 That's where the blocking comes in. It's not -- any valve 12 that has a safety function -- blocking is inapplicable, 13 That whole issue is inapplicable.
14 UNIDENTIFIED: Well, there are a number of valves 15 that also, even if you did operate them, don't have an 16 effect on the safety system. And you can find it in the 17 HPSI.
18 MR. JACOBSON: Well, they can do that analysis.
19 MR. SCARBROUGH That's what we talked about 20 earlier when we talked about a valve -- an example of -- a 21 pressurized spray valve, if that is such the case, where the 22 operation of the valve one way or the other doesn't make any 23 difference at all in any scenario or any accident. You 24 know, if_it's operability is of no consequence whatsoever, 25 then it can- be excluded that way. But all we're talking I
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65 1 about hsre is if it's a' position changeable valve, it has no 2 safety function, what can I do to remove it from the program 3 so that I don't have to perform any DP testing.
4 MR. KIESSEL: All right. I have one question for 5 you. Are you implying that you have modified your valves in 6 some matter so that if you mechanically blocked it, you 7 cannot electrically operate?
8 UNIDENTIFIED: No. No, I'm not implying that.
9 I'm implying that there are cases that I could think of that 10 I might want to remove the valves from being inadvertently 11 mispositioned by controlling the motor operator by taking 12 the capability of operating the motor operator to be a two 13 step process. One, that the reactor operator or whoever is 14 on the boardo would have to go to the shift supervisor to 15 got a key to' operate the valve. 1 dren' t think it's a j 16 logical extension to say that if the valve han a hey lock 17 switch on it and it's in the off or do not operate kind of 18 position that an operator is going to go down to the f
-19 coard -- I mean down to the valve and operate it manually, 20 That's illogical.
21 MR. KIESSEL: I agree. But also it's illogical l 22 for plants to operate misaligned. But they do.
23 UNIDENTIFIED: Well, yes. But your safety related 24 systems in general _are being checked on every shift. ;
i 25 MR. KIESSEL: Yes. But also we've also seen a (
)
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,l' number of' cases where.several. people have written offLand
-2' approved and it's gone'for more-than'just one shift. It's F ;3 gone for perfected periods of. time where valve alignments
'4 -have been sworn and atte'sted to that they've been verified 5 as being proper and then we find out they weren't really 6 that way.
- 7. UNIDENTIFIED: Well, I would suggest that we
.8 attack 1that problem and not the problem of taking such 9 conservative action that it makes equipment' unavailable.
- 10. MR . KIESSEL: I still. don't see why.the equipment 11 is unavailable.
~
12 UNIDENTIFIED: Well, you got'a-key lock on the
- 13. motor or on the valve itself and a' key lock on the control 14- board, then you've taken an additional step which!I believe 15 is unnecessary.
1 16 MR. KIESSEL: Well, very simple. Datoonstrate the 17 valve can function. And-then'you.can take all those locks.
18 off.
19 MR. JACOBSON: You can't write a valve out of your 20 program if it has a safety function just because it has a 21 lock on it or if it's blocked. The point is you can do this 22 on valves that have no safety function. So if they have no 23 safety function, then we really don't care whether they're 24 operable or no.t. Now, if you need that valve for operating 25- purposes and you don't want to block it out, then you're l
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1 67 l going to have to do the calculations and everything or the 2 testing necessary to show that if it's mispositioned it can 3 be put back in its right position. But there's-no intent 4 here to block out safety' valves.
5 UNIDENTIFIED: No.
6 MR. JACOBSON: I don't really.see what we're 7 getting at.
8 UNIDENTIFIED: There are numerous systems and 9 valves that give you additional capability beyond that 10 minimum sect that provides the safety related functions and 11 safety systems. And if you get into an accident, you'd like 12 to have as much available to you as you can.
13 MR. KIESSEL: Agreed. Now, perhaps then this 14 would be a. good time to clarify what we mean by the design 15 basis scentrAos. Wn' ra not talking e. bout just ensuring that 16 those valves will eparate for the first few seconds or 17 mie.utes of the accident scenario. We' rs talking about 18 including in the set of valves that must be demonstrated 19 that they can functien. All those valves that are called i 20 out for the full scenario all the way down to cold shutdown 21 and keeping the plant there. We' re also talking about the l'
22 valves that are in the emergency operating procedures.
23 So that I find it very difficult to think of many 24 valves that an cope _rator might like to use at some point way l 25 down in the future that haven't been addressed in those t
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68 1 documents and credit hasn't been taken for them.
2 UNIDENTIFIED: Well, I think I can develop some 3 but I don't think I can do it extemporaneous 1y. There are 4 different valves that ma'ke, for instance, taking gland seal 5 leakage and sending it to where you don't want it on the 6 HPSI and where you want it to go. And that capability would 7 go away. That's not a safety related function. That's 8 something that you have available to you for non-accident 9 testing.
10 MR. JACOBSON: 'But would mispositioning that valve 11 cause a problem in your other system?
12 UNIDENTIFIED: I don't believe so.
13 MR. JACOBSON: Well, then it wouldn't be 14 addressed?
15 UNIDENTIFIED: Yeah.
16 MR. CACCESON: These are only valvan that if 17 they' r.e elspor:itioned could effect the safety system. So if 16 it's just a valve and the balance of plar.t and its 19 repositioning has no effect on anything safety related 20 or --
21 UNIDENTIFIED: The question really wasn't whether 22 the valve is going to effect the outcome of the safety 23 analysis. The question was really that if 1 put in an 24 electrical interlock for a valve that is an electrical 25 valve, isn't that sufficient as opposed to putting in both Heritage Reporting Corporation (202) 628-4888 rL
69 l l
1- an electrical and a mechanical interlock? j i
2 MR. JACOBSON: Tho' answer is no.
i
]
-3 MR. KIESSEL: But, again, you said that putting a i
4 mechanical block will no't prevent you from operating the j 5 valve. electrically. So why are you bringing it back up?
6 UNIDENTIFIED: What I said was that the electrical 7 interlock,would require at least a two step process. That 8 an-operator and the person that's controlling that 9 interlock; namely,. shift supervisor, would have to get 10 :together to agree to operate that valve. And that the 11 assumption then is that the valve is in its r3ght position 12 all the time because it is not something that an operator 13 would just inadvertently go and do.
-14 MR. MARSH: Okay. We understand the question.
15 We've give you a cut. We'll chew more on it. And we'll 16 come back. Okay?
17 Thanks. Yes, sir.
18 UNIDENTIFIED: I guess I'm going to confuse this 19 whole diccussion. The second paragraph, recommended action 20 says, any MOV in a safety related system that is not blocked 21 from inadvertent operation from either the control room, the ;
22 motor control center or the valve shell should be considered 23 of being capable of mispositioning.
24 c MR.;NARS_H: So your point is the generic letter i 25 only allows- for electrical or mechanical --
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1 UNIDENTIFIED: It says right here. Either place.
2' MR. MARSH: Okay.- Thank you. We'll take a look t
9 3 at that too.
4' I don't want t'o be short with you. There are lots 5 of times -- what is exactly said -- what is exactly meant --
6 needs to be thought about in these kinds of questions.
7 Okay. And if what the letter says exactly and what the 8 staff technically means, needs to be clarified. That's the 9 purpose of the meetings. To understand what the problems 10 are and what the right thing to do is. That's the reason 11 we'll tell you our best shot. If we need to think about 12 something more careful and come back to you, that's what 13 we're going to do. Okay?
14 MR. SCARBROUGH: The next question was No. 8.
15 "Is it possible to have the clock reset until such time 16 that all utility questions are answered?"
17 Tne short answer is no. The five year period was 18 prepared and thought about and determined to allow questions 19 such as these in these meetings in time to set up a program.
20 So there is a six month delay right off the back which is 21 allowed in the generic letter itself. So it has already 22 extended it six months beyond that. But these type of 23 considerations were taken into account when the five year 24 program was de_termined and that's what we have, 25 Question No. 9. Recommended actions states and Heritage Reporting Corporation (202) 628-4888 l
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- l- 1this-is"a quote,' "NRC: envisions as a part of.a good v
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L2 maintenance program, remaining BOP.'-- balance of plant --
3 ~ valve should be considered, et cetera."
4 The question l's:
5 - "Does this statement infer that base line periodic-
- -m 6 .- testing on all MOV's. constitutes a' good program?"
7 And the answer is,'yes. It's'one part of a good 8 program. Now, the second part of the question is:
9 "Are the valves outside of the scope of Generic Letter 10 89-10 subject to periodic audits?"
11- And in general', Appendix A of Part 50 covers 12- compliment of. board and safety and requires testing of those' 13 compliments. But'ths' NRC is currently not planning to' apply 14- Generic Letter 89-10, the balance of plant. That's up to 15 licensee where licensee feels it would be in its best 16 interest to expand the scope of 89-10 to other valves.
'1 */ Question 10.
' 18- "Regarding containment air systems MOV's, is the DP 19 testing to be done with containment at design 20 pressure / vacuum? If so,'how is this to be 21 accomplished?"
22 And the answer there is, the full DP testing is 23 where possible in MOV's. Where it isn't possible from a 24 plant safety. consideration then the licensee should develop 25 an alternative. One thing that should be clear is we're not Beritage Reporting Corporation (202) 628-4888
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72 i i suggesting that plants be put in an unsafe condition due to 2 testing. If you can't do it in plant safely, there's other 3 means. There's prototype outside the plant or EPRI testing 4 or sharing data among th'e licensees. But we're not asking 5 for any unsafe conditions to be initiated in the plant.
l 6 Eleven is:
)
7 "ALARA, as low as reasonable achievable consideration 8 for test personnel justifiable for reasons for not 9 doing full flow DP testing what, if any, would be the 10 cutoff point for a man REM per valve?"
11 And whether or not you the licensee decides that 12 ALARA considerations prohibit the in situ testing of the 13 valve, there still must be some demonstration of operability 14 of the MOV outside the plant. In a test facility or using 15 data that's provided. That's the licensees consideration.
16 If ALARA factors deem that you cannot test that valve, you 17 can test one that's identical or one that's similar if you 18 justify its applicability to that valve.
19 MR. MARSH: I think we ought to give the same 20 answer here that we gave in the 89-04 answer with respect to 21 ALARA.
22 ALARA alone is not sufficient justification for 23 not performing a test on a valve. ALARA in combination with 24 other plant specific safety perspectives may be 25 justification depending upon the particular justification.
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1 73 1 It.is very difficult and I wouldn't want to give a cutoff 2 beyond which'something-should be done below which something ,
3 shocid not be done. That's not appropriate here.
l 4 MR. SCARBROUGH': Number 12. Regarding line break 5 scenarios. It's a two part question.
6 "What criteria should be used to determine whether or 7 not a particular valve should meet line break 8 criteria?"
9 That's in the FSAR. There's no change. And I 10 think we said it several times. There's no change in design 11 basis events. There's a line break vent in the FSAR that 12- has to be considered. If there isn't one associated with 13 that MOV, then that doesn't have to be considered. Then 14 you're looking at maximum flow during a normal accident 15 situation. You're not creating a new type of line break.
16 "Is it a conservative assumption to say that valves
-17 outside of the containment are not subject to the line 18 break scenario since credit can be taken for the 19 containment isolation valves functioning as per design 20 to maintain integrity during a down stream or up stream 21 pipe break."
22 And this is along the same lines of, if credit is 23 taken for an MOV to shut -- in the situation of a line 24 break -- then g_ou must demonstrate its operability for that 25 scenario. lf not, then you're looking at accident -- the Heritage Reporting Corporation (202) 628-4888
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74 j 1 ;FSAR type of accident situations operating under full flow 1
2 full DP. But we're not going beyond the events that are 3 analyzed in your FSAR.
4- PR. MARSH: It' asks if it is a conservative-5 assumption to say that valves outside the containment are 6 not subject to the line break scenario. Now, that's not 7 conservative'from the standpoint of assuring safety systems 8 performed in function. Obviously, the most conservative 9 would be to qualify valves that in any way could be relied 10 upon even if there were multiple' failures contained in 11 isolation valves. But from the standpoint of new accident 12 scenarios, we're not creating new ones. It must be 13 demonstrated that the containment isolation valves can 14 perform their function though.
15 MR. SCARBROUGH: The next question Jeff is going 16 to handle.
17 MR. JACOBSON:- The question is regarding post 18 verification of valve operability. There are several parts 19 to this question. The first part.
20 "What does the NRC envision as adequate verification 21 for approving operability following maintenance on the 22 valves?"
23 Frankly, we don't really have a vision in this 24 area. I think__1f _I envisioned something I' d probably be out 25 marketing it right now. Basically, the goal here is to come Heritage Reporting Corporation (202) 628-4888
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75 1 up with something and it may be out there now. I don't 2 know. That you can use to verify that the maintenance that 3 you did has not affected the performance of the valve.
4 We're not going to say a motor current trace alone might be 5 acceptable or -- we want you to respond to that question.
6 It's really for the industry to come up with something that 7 they can use. And if you can't use something, then you're 8 going to have to repeat the testing. The idea is to try not 9 to do that. j 10 He's got some examples here. Example of valve has 11 had the following work performed on it. The stem packing 12 was adjusted to correct leakage and the operators torque 13 switch was replaced for EQ reasons. Certainly those are two 14 types of maintenance that would require some testing. At 15 least a low DP to verify that if you have an increase of 16 thrust requirements on the valve, for instance, and if you 17 have, you have to account for a change in torque switch 18 setting, whatever. Just replacing a torque switch alone 19 probably isn't going to change the thrust required on the 20 valve. But it may change the thrust available from the 21 actuator because torque switches can have some differences 22 between them due to unbalancing and so forth and so on.
23 So you certainly should verify that the thrust 24 output of your actuator at the point of torque switch trip 25 is not changed. And how you do those things is up to you.
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76 1 But those are the type of things that we would like to see.
2 Let's see.
3 "Does the valve require diagnostic testing and full DP 4 test to satisfy operability requirements?"
5 Again, you de not have to do a full DP test if you 6 can justify the results you got at some lower value to show 7 that you really didn't change any of the requirements from 8 the actuator valve.
9 "NUMARC is developing a post maintenance checklist.
10 Will this list be acceptable to the NRC for determining 11 retest requirements? If not, please provide ~an 12 acceptable list."
13 Well, first of all I don't think we've seen the 14 NUMARC list. And I think it is going to have to be on a 15 specific basis. There's too many different types of things 16 that you can do to that valve or actuator to come up with a 17 list of what would be acceptable and what wouldn't be 18 acceptable. You're just going to have to look at the type 19 of maintenance performed and decide what, if anything, that 20 could affect it and then verify that you haven't affected it 21 or if you have, that you're still okay. We're not going to 22 give anybody any specific lists.
23 MR. SCARBROUGH: Okay. The next question. Dick 24 Kiessel is going to take that one.
25 MR. KIESSEL: Regarding valve recovered from
\
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b 77-1 mispositioning scenario.
'2 "An injection valve was in.the wrong position 3 initially. The operator cycles about to the correct 4 lineup and then rea'lizes he'has made an error in 5 judgment. He then depositions the valve again after 6' noticing large pressure transients in the pump 7 discharge pressure caused by Waterhammer, et cetera.
8 Are multiple strokes of the valve to be analyzed for 9 where the possibility for large pressure transients in 10 the system are possible making the design basis data 11 invalid?"
12 Let me rephrase the question the way I interpreted 13 it and then answer it and then ask the person who wrote the 14 question to tell me where I was wrong.
15 Simply stated, I view the question as asking, 16 must you consider multiple repositioning of the valve?
17 If that is the simple question, the answer is, no.
18 We're only looking for the one repositioning.
19 The problem I run into here is that there may be a 20 more complex question being asked and that is that, do we 21 have to give the operator the ability to do anything he 22 wants in the plant? In other words, recycling this valve 23 that initially I'm led to believe is not normally used or 24 envisioned as being L _
used in the safety scenario. The way it 25 is being dascribed it's beginning to sound an awful lot like Beritage Reporting Corporation (202) 628-4888
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- 1. a belt that is planned on being used routinely in the safety 2 scenario. If that is the case, then that valve had better 3 be capable of handling the multiple function. Also, the 4 system had better be cap'able of handling the multiple 5 functioning of that valve.
6 If these pressure transients that are induced by 7 multiple functioning of the valve have not been previously 8 considered in the design of the system, then the regulations 9 dealing with finding of unanalyzed safety concerns come into 10 play and.you start making those kind of analyses.
11 The Generic Letter 89-10 itself will not require q 12 you to make these analyses but your licensing commitments 13 will. Now, did I answer the question?
14 UNIDENTIFIED: I didn't write the question. I'm i
15 here as a representative. I think you answered my multiple 16 mispositioning but what about multiple scenarios?
17 MR. KIESSEL: Okay. If it is a multiple scenario 18 or if a valve is called on to be used multiple times during 19 the recovery from the accident then, yes, the valve must be 20 demonstrated capable of functioning at those various times.
I 21 And the system which is located, it better be designed to 22 handle the effects that multiple positioning of the valve 23 will result in. If not, then you go back to the drawing 24 boards and let-us_know through the 50.53, 50.52 type of 25 group. -
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l 79 1 MR. SCARBROUGH: There's two remaining questions 2 here in the package from Perry and I think I'll just answer 3 them together.
4 Fifteen. -l 5 "Have the long term affects of thermal stress to the 6 reactor vessel caused by the DP testing been thought of 7 by-the NRC?" This may create additional action to be 8 performed as a result of the testing.
9 Sixteen was:
10 "By using the normal accident suction source that's 11 pressurable for the injections to the vessel this will 12 result in the injection of " dirty water" to the vessel 13 raising plant radiation levels, coolant conductivity, 14 et cetera. This practice is contradictory to normal 15 good operating procedure, is it not?"
16 And I guess as a general answer to this and all 17 the ones like this is, if the testing is going to cause a 18 safety concern or a significant concern in the operability 19 of the plant, then the licensee has the flexibility to 20 choose an alternative demonstration of operability of the-21 valve under design basis condition testing outside the plant 22 and design basis extrapolating to the valve, applying that 23 information to the MOV that's under consideration.
24 .And I_think that's the answer to both of those.
25 So if there are any questions on the Perry package, we can Heritage Reporting Corporation (202) 628-4888
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80-1 handle those now. ,
2- . UNIDENTIFIED: 'If testing increased and.under the. .j 3 new safety question does it have to be analyzed under.the 1 4
,: 4. 50.597 !
5- :MR.-MARSH: Absolutely. Every plant.is 6 responsible under 50.59 to evaluate the safety _of their 7' plant caused'by' test or changes of procedures. Whatever 8 else. That is a regulation that is incumbent upon you to 9 follow.
10 I think we've -- that's the morning. We need to 11 get together and have some lunch.. We're going to do some 12 thinking.- We talked about some of the questions that we've 13 got. I'd like to reconvene at -- let's do 1:15. That will 14 give us a chance.to make sure we get through our process 15 here. Thanks very-much. We'll be back.
16 (Whereupon, at 12:05 p.m., the meeting was 17 recessed for a lunch break, to be' reconvened at 1:05 p.m.)
18 19 20-21 22 23 i
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?3 MR. MARSH: We have said through the answering of 1 4 a lot of questions that'something would have to be thought 5 about, reviewed or evaluated on a case by case basis. And I 6 want to clarify what is meant by the NRC will consider a 7 case by case basis.
8 I do not want to leave you the impression, 9 however, is that there will be an NRC review process 10 associated with alternatives to the recommendation in the
- 11. generic letter. That is not the intent. If you read the 12 generic letter carefully, specifically the reporting i 13 departments, and if you've been following the process with 14 the CHER or the ACRS. This generic letter is not to have a 15 protracted or in any way NRC review prior to some !
16 alternative being found acceptable or not. We've spelled 17 out the recommendations, we're holding these workshops, we 18 think that is guidance enough for licensees to develop their 19 programs sufficiently. Now, if under the 50.59 process you 20 find that something is overdue safety question, and for that 21 you need a license and amendment. That's another question.
22 That, of course, would entitle you to an NRC review. But 23 absent to finding of an overdue safety question, NRC is not 24 going to review and approve specific programs for 25 alternatives to meet the 89-10 letter. Is that contrary to Heritage Reporting Corporation (202) 628-4888 RU
i 82 l 1- your impression? Did anyone think there was going to be a 2 review and approval process associated with the MOV testing 3 programs? If you did, can I see some kind of show so I can 4 get a feeling? Because'that was not the intent. The brunt '
5 of the work associated with the regulatory compliance is 6 going to be done at the inspection and audit phase not at 7 the up front program review phase. Okay. We had some other 8 things that we needed to clarify for you. And we've d one 9 .some of them in discussion and some thinking over lunc.'
10 time. And we've got some answers. Tom.
11 MR. SCARBROUGH: On the mispositioning question.
12 The words in the generic letter, any MOV in a safety related 13 system that is not blocked from inadvertent operation from 14 either the control room, motor control center or the valve 15- itself to be considered capable in this position'. To 16 prevent inadvertent operation that's electrically 17 mechanical. Generic Letter 89-10 the intent has been 18 presented on how to interpret that sentence is blocking it 19 electrically and mechanically. And we've given you several 20 examples of how to go about blocking inadvertent operation.
21 And so I won't repeat those. But that is the interpretation 22 of that sentence in Generic Letter 89-10. The other point 23 on dampers. It's our understanding that dampers are in the 24 program. That it'_s been dictated by NRC management.
If in 25 Section L af the generic letter, if your dampers are such Heritage Reporting Corporation (202) 628-4888
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1 that it cannot meet the schedule of the generic letter, then 2 you can supply a technical justification for extending that 3 schedule for the dampers. So that is how to accommodate I
4 dampers in the program. Now, I put a number of copies of my 5 slides on the back table that -- I don't know if t hey' re all 6 gone or if everyone got a copy but at the break if you run 7 out, we'll get you some more made from the business office.
8 So just check the back table and if you run out, we'll get 9 some more made. That's no problem. Okay. So I think that 10 was the three questions we had to resolve at lunch time.
11 MR. MARSH: I have one more. One gentleman asked 12 me what the NRC thought was an approved locking device on a 13 mechanical component because Tom mentioned a kind of box 14 cars and one gentleman thought we meant something 15 specifically in a box car in mind. We know there are 16 several different ways of mechanically locking equipment 17 over applying, does it need to be changed? You can use some 18 device like a little cut tab or some way to just clearly 19 indicates whether this valve has been dispositioned. It's 20 basically an indicating and to some extent preventative type 21 of advice but not a chain and lock necessarily. Go ahead.
22 MR. KIESSEL: During the lunch break it was 23 pointed out to me that there might have been some 24 misunderstanding as to what I meant by the EOP.
I meant it 25 within the context that if a valve is in the program, either Heritage Reporting Corporation (202) 628-4888 I
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84 1 because it is a safety related valve or because it is 2 mispositionable, that when looking at -- I take that back.
3 If the valve is in the program because it is safety related, j 4 in looking to try to determine what are the conditions under 5 which that valve will be used, you should consider the .
6 entire accident scenario and, if necessary, going into the 7 EOP's. I did not mean to imply that simply because a valve 8 was mentioned in the EOP's that it had to be put into the ;
9 program even though it was an EOP valve or something like 10 that.
11 MR. SCARBROUGH: Okay. The next set of questions 12 received are from Illinois Power.
13 I don't have a name but is there anyone from 14 Illinois Power here? Great.
15 The first question:
16 "What does functional as used in the definition of 17 safety related, mean -- it will maintain pressure 18 boundary or active as a must change position? i 19 And the reference is to the first footnote in the 20 generic letter which repeats the safety related definition l
21 that's found in the regulations. The functional aspect of j i
22 that is that it could be either a pressure boundary or at 1
23 the FSAR as we said earlier defines which systems are safety l 24 related.c And that_ is how you should go about determining 25 what valver should be considered to be in the program and Heritage Reporting Corporation (202) 628-4888 l
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l 85 1 which ones aren't.
H . 2 And the second' question Jeff is going to-take.
3 MR. JACOBSON: Okay.
4 "The schedule does not allow for population 5 discrepancies between plants. PWR 6 has nearly 300 L 6 safety related MOV, 3 outage schedules impracticable."
7 Well, I think we took that into consideration in 8 allowing the five year time period to complete the generic 9 letter. Initially, we were looking for times much shorter 10 than that. And I think we compromised on the five years.as 11 it is. And we took into account that there are differences 12 in numbers of valves from plant to plant. And I'll point 13 out that I've seen plants do this a lot quicker than three 14 outages for just as many valves so it is not practical if 15 one puts the resources and the effort behind it. It may be 16 impracticable with the staffing at your plant right now or 17 trying to do it without extending any outages or anything of 18 that nature. But it is not an impractical thing to do.
19 MR. SULLIVAN: I'd like to comment on one aspect 20 of this question. I guess it's kind of a question. I'll 21 read it again.
22 It says, the schedule does not allow for 23 population discrepancies between plants. BWR 6 has nearly 24 300 safety related MOV's (.ASME Class I, II and III) are 25 three otben schedules impracticable. I want to comment on Heritage Reporting Corporation (202) 628-4888
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I this just to-reiterate what was mentioned this morning that 2 the set of safety related MOV's is not limited to ASME Class 3 I, II and III safety related valves. There may be, 4 depending on the plant,'probably would be, non-code class 5 valves that are safety related.
6 MR. SCARBROUGH: Okay. That's all the questions R 7 we had from Illinois Power.
8 The next set is Tennessee Valley Authority and we 9 received two letters with questions from TVA.
10 Is there anyone from TVA here? Okay. If there 11 aren't, we'll go on to other things. But they had mentioned 12 that they would be sending two or three people to each 13 location. That's why -- are you TVA.
14 UNIDENTIFIED: Yes.
15 MR. SCARBROUGH: Oh, we're going to start your 16 questions now. Okay. There's two letters. One was dated j 17 September 8th and the other one was September 12th. We'll 18 start with the September 8th ones first. Okay.
19 The first question was:
20 "Is the NRC requiring a licensee to address modes of 21 MOV operation outside the design basis?"
22 The answer there is, yes, because it a position 23 changeable could be outside design basis for certain plants.
24 But that's already been addressed by NRC management and 25 appropriate- review has been undergoing for that type of Heritage Reporting Corporation (202) 628-4888 C
1 87 IL ' situation. So that is - you could say that that is outside 2 the design basis. In terms of events as we said, only
~
3 events have to be considered inside the design basis. No-4 extra pipe brace and thilngs of that nature.
l l
5 Question No. 2. Dick is going to handle that for 6 us.
7 MR. KIESSEL: The question is:
8 "When a valve has its torque switch by-passed until the 9 last 2-3% from a design basis standpoint of travel in 10 the closed direction, can the valve be considered 11 closed if it trips out on thrust?"
12 And the answer is yes or no. If the valve is in 13 its seat and if it is capable of meeting its leak tightness 14 requirements, then it is closed. If it can't or it doesn't 15 meet its leak tightness requirements or it is not in its 16 seat, it is not closed.
17 MR. JACOBSON: In other words, you cannot assume 18 that the valve is closed for our purposes just because the 19 torque switch is by-parsed to the last 2-3%.
20 MR. SCARBROUGH: The next question was:
21 "Does Generic Letter 89-10 supersede Bulletin 85-037 22 Elaborate on the extent of the term supersede. Are the 23 commandments for 85-03 still monitored by the NRC?"
24 2'GeneV1'c Letter 89-10 does supersede 85-03. It 25 states that directly on the last pages in the generic Heritage Reporting Corporation (202) 628-4888
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a, 88 il letter. .It.li expected that licensees follow up on the
,. , 2 . commitments in.05-03 those valves because those were 3 considered the most important and that's why 85-03 was 4 written to emphasize those. And we would encourage those to 5 be completed as soon as possible. We believe what you 6 should do is state the schedule what your remaining 85-03 7 valves are and when you're going to have those completed in 8 your letter for Generic Letter 89-10. And you can discuss' l.
! 9 those with yourt project manager on what your schedule for 10 those valves are.
11 The fourth question was:
L 12 "Concerning the KWU alliance testing in Germany,-how 13 would the results of the testing be shared with the 14 utilities, industry groups and the NRC/ and will the 15 NRC entertain feedback from this test?"
16 These are the tests that I assume are concerned 17- here -- the ones that are taking place at this very minute 18 in Germany as a follow-up to the tests that were conducted 19 by EGGG widely last year.
20 In terms of the ones that have been completed last 21 year, Phase I Report by EGGG has released. I don't have the 22 number here with me but I can get it for you. In Phase II 23 which is undergoing right now it is likely that they will 24 have a report-miso. But the current testing that is going 25 on in Germahy is very limited to the scope and it is not Beritage Reporting Corporation (202) 628-4888
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, 1 likely that it is going to be a tremendous help in meeting !
l 2 the schedule in 89-10. It is not intended to obtain a full 3 feedback on test _results that are upcoming. They are.not 4 going to be set out for review and comment. That nature.
5 It will be more for a report. There may be a meeting.
6 There was a meeting February 1st of this year on the first i
7 phase of the test and tilat's what's planned at this time.
8 And the last question Jeff is going to make.
9 MR. JACOBSON: "Can DP testing be waived on a case liO by case basis for actuators with no torque switch in 11 the control circuit?"
12 Simply, the answer to that is no. The reason is 13 the whole purpose of this generic letter is really to 14 confirm two things as well as some other things. And the 15 two big things in my mind are, 1; what is the thrust 16 requirements of the valve, the thrust or torque requirements 17 of the valve in question? And 2; whether the actuator that 18 is attached to it is set up to deliver that amount, thrust 19 or torque?
20 Now just because the torque switch is wired out of 21 the circuit and the actuator you haven't answered either one 22 of those two questions. You don't know what your thrust 23 requirement is and you don't know whether your actuator is 24 able to meet that requirement. You may not worry as much 25 about where the torque switch is set at but you still have Beritage Reporting Corporation (202) 628-4888 n
p 90 1 to verify that the actuator under design basis conditions F
2 caul deliver the required thrust for the particular valve .in 3' question or torque in the case of the butterfly valve.
4 The second par't of this question:
5 "This waiver would be based upon requiring a certain 6 margin between the calculated' thrust.value required for 7 operation under maximum DP conditions and the actuator 8 thrust rate of the appropriate margin for each type 9 valve could be established upon plant specific and 10 industry experience."
11 First of all, the margin between the calculated 12 thrust value require -- first of all we're saying that we're 13 uncertain in the calculational methods that'have been used 14 up until this time. And calculating what,the thrust 15 requirements are for any particular valve. So unless there 16 is some big change-in that area, we really don't have a lot 17 of faith in the old calculational. method. That's why wo 18 were requiring the DP test.
19 Now,.if somebody would come up with some methods 20 and this is all in the future, I guess we'd be looking to 21 look at that. If you could come up with a calculated method 22 that was shown to be accurate and then apply appropriate 23 margin, then that would seem like that would be an 24 acceptable approach. But as it is right now, we don' t
& : c- :
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91 1, faith in the-calculational methods.
2 MR. SCARBROUGH: Just to give you the report 3 number for the first phase of the Idaho tests conducted at 4 Wylie it's -- the report' number is SSR-8547 and it was 5 issued in July of this year and according to the NRC contact 6 for that report it is supposed to be placed in the public 7 document room. So you can either contact EG&G to obtain a 8 copy of it or go to the public document room.
9 That's the first set. Does that answer ' the 10 questions from TVA for that set? Do you have any questions 11 on what we just answered or any clarifications that you 12 need?
13 UNIDENTIFIED: I want to go back to the previous 14 one. Could you reiterate what you just said please?
15 MR. JACOBSON: She wants us to say again what we 16 said on the last part of 5.
17 MR. SCARBROUGH: Okay. What part in particular 18 were you unclear about?
19 UNIDENTIFIED: The -- you were talking about the 20 margin.
21 MR. MARSH: What margin could be used?
22 UNIDENTIFIED: Right.
23 HR. MARSH: What we're saying is right now we do 24 not know of. a . calculational method that is acceptable so you 25 really can't do it that way.
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92 1- However, in the future if one developed and -l 2 appropriate margins were added to calculated values that (
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3 -that may be acceptable. But right now we don't have any 4 faith in the old calcula'tional method that is being used.
5 MR. SCARBROUGH: Why don't we go on to the next 6 set of TVA questions, 7 "Does NRC have a preferred diagnostic system?"
8 And the answer is, no. There is no preferred 9 system that NRC has. I think that.would be up to the 10 licensees to determine which one they had confidence in.
11 The second question Jeff is going to take.
12 MR. JACOBSON: Okay.
13 "The generic letter states, ' licensees should ensure 14 that any. testa conducted using diagnostic techniques 15 along with in situ tests conducted at conditions less 16 severe than design basis conditions will be applied 17 appropriately to ensure design basis operability to 18 safety related MOV's.' What does applied appropriately 19 mean? Can we add a margin above the required thrust to 20 open or close the valve in order to compensate for 21 testing in less severe conditions?"
1 22 First of all, we're saying that less severe 23 conditions can be done as long as the prototype is done at 24 the full. &condition.
r ec -- :
And we talked a little bit about that 25 this morning whether on the prototype testing a lower DP l Heritage Reporting Corporation (202) 628-4888 i
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1 ..would be1 acceptable.an'd generally 1 we'said, no. We ' d -llike
- 2. ' you:to envelope the envelope the'DP in the_ prototype test.
F: 3- And then'on the valve-in your plant you could show.
'4 similarity by.doing a te"st~atl lower differential pressure. ]
5' Does that answer that quection fully?
The third question was:
u 6 MR. SCARBROUGH:
7 "What are some examples of;when differential pressure q
-l 8 lor flow testing cannot practicably be performed?"
9 And I think we touched upon this. It's where 10 there is'a concern for plant safety when you're going to be.
11 injecting non-safety related water into the system or 12.~ something of that nature. When you have a concern that 13 you're putting the plant into an unsafe condition. And a 14 licensee should make that determination. But you still have 15 to demonstrate operability of that MOV. Either by a prototype test and a full DP and apply that to justification 16-17 to the Mov in question or a full DP test on another train.
18 It starta to demonstrate operability just'on that 19 particular valve, it just not be feasible or practical to 20 perform the test itself.
21 Okay. That's all the TVA questions. Was that 22 satisfactory?
23 MR. CONROY: My name is Pat Conroy. I'm with 24 Indian Point Three New York Power Authority. My question 25 pertains to._the issue of the prototype test. Now, if we do Heritage Reporting Corporation (202) 628-4888
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94 11 a. prototype test either-in the plant or someone else'at 1
2 another plant or in a test facility or whatever under full
-3 flow conditions worst caso design basis conditions. Then I 4- have a number of. additional MOV assemblies that are of the 5 exact same model and make and everything.
6 My question is, why is it not sufficient to do a 7 static. test and then adjust the thrust requirement based on 8 differences perhaps in packing loads that are measurable?
9 Why' is it necessary to do a partial DP test if the prototype 10 test has been~done at full DP?
11 HMR. JACOBSON: Well, I think what we meant by 12 partial DP is something less than full DP. Static may be 13 acceptable. In most cases to have some DP on the valve to 14 establish how it is working.
15 'MR. CONROY: But you've got to be.able'to 16 correlate.
17 MR. JACOBSON: Yeah.
18 MR. CONROY: You got to be able to correlate 19 prototype to this. In other words, on the prototype 20 component you need two tests. You do a full flow test at 21 the full DP and you'd also do a lesser DP test so that you 4
22 correlate the results of the prototype after the in situ 23 plant.
124 MR. JACOBSON: Now, if you feel that a test that's 25 static cond4tions is enough to ensure similarity in the Heritage Reporting Corporation (202) 628-4888
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'l functioning of the two valves --
2'- MR. CONROY: With prototype' data to back that up.
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3 MR. JACOBSON: That's.what I'm saying,. yeah.. Then i" -4 that would probably be acceptable. However, it is always 5 better to have some DP on the valve. 'The more'there is the 6 closer you are to your. design condition.
-l 7 MR. CONROY: But you would view that as acceptable ;
8 to do a status test and'then take credit for the prototype
- 9. test at full DP?
10 MR. JACOBSON: If you had the data to back that )
11 up.
12 MR. CONROY: Thank you.
13 MR. MARSH: Are you saying no DP? You want a !
I 14 valve stroke without any DP and try to correlate that to the 15 characteristics of the prototype test with no DP7 I'm not !
16 sure you can show that the friction factors are going to be -l' l
17 the same. ;
)
18 MR. CONROY: What I'm saying is that if I have a l 19 prototype test done at full DP, what I'll probably end up ;
20 doing is adjusting the torque switch to see at what minimum j 21 thrust the thing will fully work under that maximum expected l 22 DP out in the plant. Now I go out in the plant and there's 23 an identical equipment, same exact valve, same exact j 24 operator with ossibly like you guys were talking about 25 maybe diffarent gear ration in the operator, but I don't l Beritage Reporting Corporation (202) 628-4888 l
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96' L l1- even want'to-get into that. Assume that the' valve assembly E
2 in the plant is identical to the prototype what I'm saying.
3' -is, why'can't I go to the installed equipment at the plant 4 and based on the prototype test with no DP whatsoever, 5- static. conditions, set the torque switch to' achieve some
-6 thrust;with an adjustment as appropriate to' account for some
- 7. margin 1perhaps and additionally to. account for differences 8 in the packing' load that could have existed between the
' 9 installed valve-and the prototypically tested valve.
10 MR. MARSH: Greg, just hold on a second.
11 (whereupon, there was a discussion off the 12- record.)
13 MR. JACOBSON: Okay. A little more clarification 14 on that. I think we feel in general you can't just buy off 15 on that.that you can do a static test. However, if you-have 16 data that shows that for a particular type of valve that'a 17- static test is representative that the valves are similar, 18 then I think that would be acceptable.
4 19 For instance, you have a valve when you do the 20 prototype testing and let's say you do a number of tests and 21 you show that as long as they function similarly at static 22 head that they're going to function the same at a higher DP.
23 You have some test results to back that up. And that would 24; be acceptable.__ But just going out blind, for instance, 25 you've got gne valve when you do the prototype test and then Beritage Reporting Corporation 4 (202) 628-4888 1 1
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97 1 you do it at.no DP and then you go to your plant and you do 1
2 .that at no DP, we wouldn't accept that without any i
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3 clarifying data to support that because we feel that at zero /
4 DP.you may not really be showing the effects that we're ,
5 worried about which is the valve factor and stuff. You 6 really don't have a lot of friction going on there at zero 7 DP. And that's what we're worried about, the valve factor 8 in which there's a friction between the guides and 9 everything. It really only comes into play when you start 10 . putting the DP across the valve. So unless there is some DP 11 you're really not verifying that the two are similar.
12 Now, the amount of DP that you would need to use 13 for any particular valve I guess would have to be on a case 14 by case basis. There is probably more people that are more 1S expert in this area than I am. .
16 MR. SCARBROUGH: Why don't we go on to the next 17 set of questions here. This came in from --
18 MR. JACOBSON: He had a question.
l l 19 MR. SCARBROUGH: Oh, I'm sorry.
1 20 MR. WOELD: My name is Peter Wohld with the 21 Chicago Nuclear Corporation.
22 I have a question on the differential pressure 23 testing. I have seen some correlation between the friction 24 factor og opening the friction factor and closing. Are you 25 going to accept a differential pressure test on an opening Heritage Reporting Corporation (202) 628-4888 l
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i 1 instrumented-to find out what the friction factor is to show 2 adequacy in the closing direction or is that still an open 3 question?
4 MR. JACOBSON: Are you talking the stem factor or l
l 5 the friction factor in the valve?
L 6 MR. WOHLD: The friction factor of the seat l
7 against the disk.
8 MR. JACOBSON: I would say in general that we 9 would.not want to accept just data in one direction 10 especially if there is something out there that says it' 11 could be different for both directions.
12 MR. WOHLD: I don't know if that question has been 13 answered but there are a lot more valves that can be tested 14 under an opening condition with a small jockey pump as
. 15 opposed to differential pressure against the closing that 16 requires a large flow.
17 MR. JACOBSON: So you're talking more about the 18 actual testing in the plant as opposed to a prototype test, 19 right?
20 MR. WOHLD: Right.
21 HR. JACOBSON: Prototyping can open and close no 22 problem I would assume but the ones that you're testing in 23 the plan you're saying you may be able to achieve full DP in 24 one direction,_however, not in the other direction?
25 MR. WOHLD: Correct. There are a lot more Heritage Reporting Corporation (202) 628-4888 i,
l l 1 99 1 opportunities to test in the open direction versus closed.
2 MR. JACOBSON: And typically in the closing 3 direction it requires more thrust than the opening, too, j 4 right?
5 MR. WORLD: That's true. If there is a 6 correlation between opening and closing to get an acceptable 7 test.
8 MR. JACOBSON: I don't know that we specifically 9 addressed that amongst us, have we?
10 MR. SCARBROUGH: We have a question coming up 11 later which kind of touches upon the opening and closing 12 operability issue and we'll see if that shecs further light 13 on that issue and discuss it again then.
14 The next set of questions came in from the Nuclear 15 Management and Resources Council known as NUMARC'. I won't 16 read you the whole letter but I will read you the portions 17 in terms of questions.
18 "Regarding position changeable valves it is our 19 interpretation that any position changeable valve in a 20 safety related system should be included in the MOV 21 program to ensure that it will operate under service 22 conditions for which it was intended. Hispositioning 23 of position changeable valves need not be considered 24 unlass mi, positioning is part of the overall plant 25 design-basis."
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100 1- -And I think we said this before and we'll say it 2 again. Mispositioning must be included whether or not it 3 was discussed in the design basis. It may be outside the
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'4 design basis for a particular plant but that's been 5 considered and addressed, evaluated and approved as 6 necessary by NRC management. The second part was regarding 7 degraded voltage.
8 "It is our interpretation that the effects of degraded 9 voltage upon MOV operation is only being considered if 10 degraded voltage is part of the overall plant design 11 basis."
12 And in general degraded voltage should have been 13 one of the factors considered in the design basis. What we 14 consider degraded voltage is the lowest voltags before 15 shutdown is required and then subtracting off cable drops.
16 But in general degraded voltage must be considered and it's 17 not really considered outside the design basis because it's 18 one of the aspects that should have been in the design basis 19 in the first place.
20 MR. JACOBSON: Let me clarify about the degraded 21 voltage issue a little bit. Basically what we want to see 22 for-your particular Mov in question you're going to do a 23 review to show all the times that its needed to operate in 24 different. accident scenarios or whatever. Now, you should 25 have a particular voltage associated with those particular seritage Reporting Corporation (202) 628-4888 sg
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5 1- . accident scenarios.
.2 For instance, inLone' scenario it may be receiving 3 85% voltage and have to stroke the valve at a certain 4 differential pressure. You can use the 85% voltage scenario 5 there. In another. scenario it-might have 90% voltage but 16 require more' differential pressure.
7 So you can either,use.the worattin both cases.
8 which would envelope everything or you can look at it on the 9 specific basis. I know a lot of plants are designed such 10 -that they just spec.80% voltage'for everything. Some-other 11 plants .have gone and actually calculated what the actual 12 voltage is going to be at a. particular MOV during any 13 particular accident scenario. And if you use that, that's <
, 14 acceptable too. But it is unacceptable to just' assume that 15 you're going to have 100% voltage-on your MOV unless you've 16 got some data that can back.that up.
17 Now, whether the original design basis or not got 18 that detailed I frankly doubt it but certainly it-should 19 have been in the design of these actuators. Somebody should 20 have spec'd out what the voltage range was that these things 21 were supposed to be required to operate under. And there is 22 a lot of uncertainty in what Limitorque or somebody else may 23 have used in degraded voltage calculations if no voltage was 24~ given to;them __. _
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102 1 the story that-they used 100% and then I've also heard the 2 story that they used 90%. Now, if you look at their
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3 calcu1ations, the calculations have an application factor in
< 4 there'which is like .9 t'erm which pretty much would allow 5 90% and I think that's where that comes from.
6 But really that's not why that's in there. They.
7 put the 90% in there for some margin in their calculation.
8 So if you now say they're okay for 90%, you just. wiped out 9 the margin that Limitorque put in their calculation. What 10 it all boils down to is that you should really use.the 11 lowest voltage that you are assuming and then plug that into 12 the calculatic7 13 Do you have a question?
14 MR. PITTMAN: Yeah. My name is Mark Pittman from 15 Virginia Power. Since we have to consider degraded voltage 16 and we have ts consider inadvertent mispositioning of the 17 valve do we have to take both of them together, degraded and l 18 mispositioning?
19 MR. JACOBSON: I would say yes if the valve --
20 MR. PITTMAN: Isn't that a double failure?
21 MR. JACOBSON: Degraded voltage is not a failure, p 22 That's what you expect the voltage to be at any given time.
1 23 That's not as a result of a system failure. You have an 24 event and the moltage is going to be at a certain level 25 calculated $ hat way where you calculate the lowest that it Beritage Reporting Corporation (202) 628-4888 a
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2 MR. WALLACE: Dave Wallace, Fitzpatrick, New York 3 Power Authority. I think at least the way I interpreted 4 that was if you consider mispositioning an event now, your 5 batteries versus DC valves weren't sized for it. That's 6 kind of like a double whammy. In other words, the battery 7 duty for DC valves might not have considered mispositioning.
8 MR. JACOBSON: Okay. You're saying now you may 9 have done a review of where your particular valves, and 10 let's say the valve is only needed in the first few seconds 11 of the accident, you' re saying the battery voltage would be 12 high. But now due to the mispositioning you got to look 13 further downstream and the voltage may not be as high and 14 that could get you into trouble?
15 MR. WALLACE: Yeah.
16 MR. JACOBSON: Is that what you're talking about?
17 MR. WALLACE: Exactly, yeah.
18 MR. JACOBSON: Well, I guess that's the case if 19 our position is that you have to be able to reposition a 20 mispositioned valve you would have to assure yourselves that 21 that could be done at any time. And in order to do that you 22 would have to look at your lowest voltages associated with 23 that valve.
In classical licensing kind of review 24 j MR.ppRSH:
25 time frames:in the licensing review of that type of problem, Heritage Reporting Corporation (202) 628-4888
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1 if you found -that because of the battery voltage and because 1
2 of mispositioning, if a valve had to be repositioned in a 3 certain time frame to make sure that its voltage was 4 adequate you would have'to automatically reposition it. You 5 have to have a device on it which would drive it to the open 6 position.
7 MR. WALLACE: That's different case though.
8 MR. MARSH: Well, if an operator has to take--
9 MR. MALLACE: If it was designed that way, you're 10 right.
11' MR. MARSH: Well, we're trying to look at the 12 design from an overall perspective now. And if that 13 component has to be repositioned in such a time frame so.you 14 have right voltage, that's a problem.
15 MR. JACOBSON: I would think there's n6t going to 16 be many valves -- I may be wrong -- that are going to come 17 into this case. I don't know of that many valves that are 18- going to come under this mispositioning category in the 19 first place. Most valves that are not in a safety related 20 system really aren't going to affect the safety related 21 system, isn't that true?
22 Do you have any specific examples?
23 MR. PITTMAN: We do have a case where I have some 24 of our egntainment spray valves at 80% voltage we can --
25 MR. JACOBSON: What kind of valves are these? I'm Beritage Reporting Corporation (202) 628-4888 s
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'2 MR. PITTMAN: Containment spray. We can go shut 3 no trouble at all but if we inadvertently positioned them 4 shut to go back open at'80% of voltage, we would have some 5 difficulty based on our valve factors.
5 MR. JACOBSON: You're saying it requires more 7 thrust to open these valves?
8 MR. PITTMAN: In this particular case, yes.
9 MR. JACOBSON: Because the DP is higher?
10 MR. PITTMAN: Right.
11 MR. JACOBSON: And there not going open?
12 MR. PITTMAN: And it still does seem like a double 13 failure to me.
14 MR. JACOBSON: These valves are only needed at 15 what time or are they needed throughout the accident?
16 MR. PITTMAN: That would be outside of my field of 17 expertise.
18 MR. MARSH: Are these DC valves or AC valves?
20 MR. HARSH: And how did you get into degraded 21 voltage in the first place? Is it just because the diesel 22 is fully loaded?
23 MR. PITTMAN: That would be it.
24' Well, that's not a failure.
g MR. EARSH:
25 MR. PITTMAN: But it would kick right back up Heritage Reporting Corporation (202) 628-4888
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2~ MR. MARSH: I don't think_that's a failure.
3 MR. JACOBSON: No, that's a normal --
4 MR. MARSH: -Th'at's just a fully loaded diesel, t 5 That's everything that's operating normally.
6 MR. JACOBSON: I guess, you know, I don't see:
7 where that's any different. If the valve ---that's really.
8 not-a case of mispositioning. . That's a safety related valve 9 that you have to look at in both the open and closed l 10 direction, right?
11 MR. PITTMAN: But if you indirectly closed it, 12 then you got to come back.open.
13 MR. JACOBSON: Well, the generic letter says that' 14 all the valves have to be looked -- all the safety related 15 valves, you have to look at both the open and closed 16 direction. Establish a DP in both the open and closed 17- direction regardless of mispositioning.
18 MR. PITTMAN: 100% voltage is not the problem.
19 MR. JACOBSON: Yeah, but you don't normally have 20 100% voltage in these accidents, right?
21 MR. MARSH: Pete.
22 MR. WOHLD: In the one design that I'm familiar 23 with, the low voltage that was assumed for the valves was 24 the lowest dip,on ,the diesel as it came up to power. Now, i
25 the emergenpy core cooling valves are not shed from the bus-Beritage Reporting Corporation (202) 628-4888
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! I so those are loaded automatically as soon as the diesel 2 breaker closes. So you get a fairly low voltage requirement 3 on those valves.
4 There is proba'ly b a tendency to order all the 5 valves in a plant to that same voltage requirement or think 6 of it as applying to every valve. I think if you recognize 7 that there might be some relief so that, for instance, on 8 the position changeable valves you would not assume that 9 coincident with the lowest dip of the diesel but you could 10 take credit for.the full voltage output of the diesel 11 generator which is probably set for 100% when it is 12 continuously running.
13 MR. JACOBSON: Yes. Many plants have chosen just 14 for sake of ease to envelope everything with the lowest 15 voltage they'll ever see on the diesel like you said. But 16 you don't really need to do that. If you can go back and 17 calculate the times that this valve may be needed and look 18 at what the voltage is going to be at that particular time, 19 you can use that voltage. I know even though if you throw 20 out those dips usually you do come up with a voltage that is 21 lower than 100% due to cable drops, so forth and so on. It 22 all depends on the plant. But I've seen a lot that even the 23 steady state voltage is -- maybe 90% or so.
24 MR. MOHLD: Could you agree to throw out the 25 lowest dip sf the diesel for the position changeable valves?
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108 1 MR- MARSH: Let's ponder that, okay?
2 MR. JACOBSON: Yeah, we'll look at that.
3 Especially if that dip is only for a few seconds we can look 4 at that because one can'say maybe that even if it stalls in 5 two seconds and you get the voltage back it would be okay.
6 We'll look at that some more.
a 7 MR. KIESSEL: Before we get to your question let !
8 me just interject something.
9 Just a moment or two ago Jeff mentioned that he 10 had to consider a maximum DP flow conditions for the valves 11 in both the open and closed direction. While Jeff was 12 saying that I noticed Clive Callaway was sitting there 13 violently shaking his head, no. I think we have a basic 14 misunderstanding.
15 And let me read you the words out of Action Item 16 A.
17 " Review and document design basis for the operation of 18 each MOV. This documentation should include the 19 maximum differential pressure expected during both the 20 opening and closing of the MOV for both normal 21 operations and abnormal events to the extent that these 22 MOV operations and events are included in the existing 23 approved design basis."
24 .Now _l.think that clearly states that we look at 25 it in both; directions. It's entirely possible that you can Heritage Reporti.ng Corporation )
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3 -MR. MARSH: Clive, we' re going to get to this. We
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4 got a specific question on opening versus closed and thrust 5 requirements. Let's get to that point.
6 MR. SCARBROUGH: That's on the very last set of 7 questions.
i 8' NUMARC. Here's another question from NUMARC.
Regarding design basis reviews, 9
10 "It is our interpretation that a licensee may perform a 11 design basis reconstitution of a MOV application based t
12 on actual design and operational parameters of the 13 system in which the MOV is located rather than 14 reconstruct original procurement documents. In many 15 cases of the valve vendor a loan no longer exists or 16 procurement documents and specifications have not been 17 retained by the AE or other procurement entities thus 18 reconstructing the original designing if procurement 19 information is not possible."
20 The simple answer to that is, that we prefer to 21 reconstruct the operational requirements for that MOV.
22 There is no need for licensees to use the original 23 procurement documents. And, in any event, those original 24 documentg would{_t be acceptable without validation in any 25 event. So ve prefer that you look at the MOV and what it Heritage Reporting Corporation (202) 628-4888 I
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i E 110 1 really needs to be able to operate against in determining 2 the need for testing that MOV.
3 The last NUMARC question here was:
4 " Referring to alternatives to design basis testing in
.5 Item F, we interpret that what is meant by appropriate 6 design basis test results on other Mov's concludes test 7 results could come from tests performed by other 8 utilities or organizations. For example, EPRI and not 9 just-from ones home facility."
10 And that is absolutely correct. It's one thing 11 we're very much emphasizing is the need to have industry 12 wide testing. =We've already sent a letter to EPRI asking 13 them to do some work in this area. And we've talked to 14 NUMARC about it. We've talked to everyone who will listen 15 to us about it -- is that you can use test results from EPRI 16 or from other facilities if it is appropriate -- appropriate 17 valves -- and you justify that application of that 18 information from one plant or from one testing source from 19 another.
20 Clive, that was your questions. Would you.like us 21 to expand on any of those? Not right now. Okay. Fine.
22 Thank you. Okay.
23 The next set of questions was from Detroit Edison, 24 Fermi 2. And l do,n't know if I have a name on it. No, I 25 don't. Detroit Edison, are they here? Great.
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- l. 1 The first question. These are rather long too, so 2 bear with'me while I read them. l 3 Page 2 of Paragraph 1 of Generic Letter 89-10 states 4 Section'11 tested a' lone is not sufficient to provide 5 assurance of MOV operability. Compliment. operability l
6- is defined under the technical operations of each )
7 operating plant. Does this statement in the generic 8 letter mean that the staff intends to rewrite this 9 standard technical specifications with regard to in {
10 service testing for Mova?
11 And we don't have any current intent to' change the 12 standard technical specifications in this area. I'm not 13 even sure'if it's really necessary. But there is a rule 14 change as I mentioned in the opening presentation that's in 15 progress right now which may address MOV operability.
16 That's our intent. So we may see this type of information 17 associated with that rule but I don't foresee at this point 18 a standard text spec change needed with this generic letter.
19 Question 2.
20 "Page 2, Paragraph 1 reference GDC 1, 4, 18 and 21 of 21 Appendix A to tendency of our Part 50. The 22 relationship of assuring MOV design basis operability 23 is understood with regard to quality standards, 24 programs y records maintenance and also qualification 25 to environmental conditions imposed by normal operation Heritage Reporting Corporation j (202) 628-4888
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1 maintenance testing or:possiblyfaccidents. However,,
L2 amd these are .the questions, a. By reference of:GDC 18 F- 3 'does a staff attend'that Generic Letter 89-10 extend 4 Lthe definition"for' inspection andl testing of electric
~5 power. systems to' compliment supply by that systems; 6_ .i.e., MOV's?
7 And the generic -letter does - not establish
'8; requirementsffor electric power systems. It's concerned' 9 with MOV operability. And we weren't going beyond that MOV 10 -except:in'what we just talked about, degraded voltage, where 11 . power.needs to be supplied to MOV but we're:not extending-I 12 ' Generic Letter 89-10 to electric power systems as a rule.
13 MR. JACOBSON: Let me add to that. You may have 14 to look at your electric power systems as part'of the design 15 basis review in order to figure out what the voltage is 16 going to be at the actuator. So we're not requiring you do 17 any specific testing or anything in your electric power 18 systeam but you may have to do some fairly detailed review 19 in order to figure out what the voltage'is going to be at 20 the actuator during the conditions that you need to operate 21 the MOV's.
22 MR. SCARBROUGH: Thanks, Jeff.
23 okay the second -- the Part'B of that question 24 was: ,1 _._g____
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'l- Generic Letter 89-10 extend the NUREG 0800 Standard 2 Review Plan, Section 7.1 definition of a protection 3 system to include MOV's which have control circuitry.
4 that responds to'an'E$FAS actual signal."
5 Similar to what we just talked about with the 6 power system, there's no requirement in 89-10 for safety 7 ' actuation systems. We're only addressing MOV's. i 8 Does that Janswer your question?. Okay. j 9 Question 3 was:
'I 10 "Page 2 states that testing conducted as part of'the 11 resolution of Generic Issue 87 indicated the presence L 12 of mechanisms and loads not previously accounted by MOV 13 sizing equations.- Further it stated that the purpose 14 of the test is to confirm valve operability under l 15 design basis conditions and to identify any causes of 16 failure." " (a. ) Was failure of MOV's performed in the 17 initial test series a result of common mode failure as 18 was the concern identifying 8 volts in 85-03?"
19 And the answer is, yes. Part of the problem that 20 arose from the test u. Idaho which these are referring to 21 about by EG&G and WyAAe reveal that there was a concern for 22 the basis equations and whether or not the equations were 23 valid. And that is a common mode.
24 2 Part_JL of that question was:
~
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25 "Coult the failure of MOV's to perform in the initial
)
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114 y 1 test series be symptomatic of a design weakness due to 2 the type of valve selected to perform the isolation 3 function for the piping design'to mitigate break flow?"
4 And that's pos'sible that could be because they did 5 find that there was some clearances in'the design --
6 clearances in between the seat and the disk that were 7- causing some movement there that was~ increasing the 8 thrusting to close it. But I wouldn't call that a designed 9 weakness. That..could be just a simple QA within che' specs 10 .of design. .So it is possible.
11 MR. JACOBSON: In addition, those valves were 12 representative of what is in the plants today. So'if it is l 13 a designed weakness in our test, it is also a design 14 weakness out there in the field. Those were picked because 15 they were representative of similar valves that tre 16 installed in the plants in the same function.
17 MR. MARSH: By the last part of that question did
- 18- you mean to ask us if the break flow that we're using during 19 the tests was beyond that which you'd experienced during 20 this postulated break? I don't really understand the last 21 part of your question where it says, or was it a generic 22 weakness of the piping design to mitigate break flow. I 23 don't understand what you mean by that?
24 ; MR. JACOBSON: Do you mean if it was a smaller 25 pipe you wogidn't have as much flow?
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7 MR, MARSH: Okay. We don't know what that means 2 either.
3 MR. SCARBROUGH: Okay. Part C of that question 4 was:
5 "If the test results tend toward a conclusion favoring 6 (b.) the above, what is the relationship of the test 7 series being conducted to the issue of MOV command load 8 failure during plant transients due to improper 9 switching?"
10 It appears that it is more related to (a.). It is 11 a more of a common mode. I guess the distinction between 12 (a.) and 03.) is that a. is a command mcde applicable to the 13 -
generically across the MOV's and 03.) would be some sort 14 of problem with the valves selected for the test. And from 15 what we've seen, it is not specifically related to the 16 valve. It is related to both. So it is even more than (a.)
17 or (b.). (a.) or (b.) it's (a.) and (b.)
18 The fourth question was:
19 "Page 2, Paragraph 4 notes that in situ MOV testing of 20 design based conditions may not be practical.
21 Experience reported by Simmons KWU indicates that any 22 testing may actually be detrimental to the ultimate 23 capability of an MOV to perform its safety function.
24 If a.sim4 tar result is obtained from the second series 25 of INEL tests, (a.) will the staff reanalyze the Heritage Reporting Corporation (202) 628-4888 1
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116 1 failure-rate in safety related MOV's responded in the 2 design basis event as a result of in. situ testing?
3' And'the answer there is, no. Some testing is 4 required to ensure operability. If design basis testing 5 would damage the MOV, then the MOV may not be adequate for 6 its function. And if you're concerned about damage to the i
7 plant, then there's'other means. You can use prototype or 8 some data base that you could find that is applicable. But 9 in terms of not having any testing, that's not an option.
10 Part B:
11 "If a reanalysis shows a significant adverse 12 consequence under A above will the staff revise 13 recommended action to C and F in the generic letter?"
14 No, we don't plan to revise the generic letter 15 because the generic letter allows alternatives to in situ 16 testing if it's found that that testing is not practical or, 17 for example, if it could cause a safety problem in the 18 plant.
19 Part C is:
20 "Should licensees be best advised not to undertake 21 extensive DP testing until issues regarding MOV test 22 conditions require MOV actuator slaing, MOV valve 23 degradation phenomenon and sensitivity and MOV testing 24 systems au:sy resolved. Instead to respond primarily on 25 PartsmA, B and G of the generic letter and place my i
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117 v-1 primary-emphasis on establishing and/or maintaining 2 good actuator maintenance programs."
3 No. There is not going to be a delay in the 4 schedule for 89-10. The 85-03 results led to'the need for 5 89-10 and so we're at the point where some testing is needed 6 to_ confirm that the valves are operable. Now, use of 7 prototype testing would resolve many of the concerns listed 8' in that question but, again, if_there's-a problem with plant 9 safety then you can use an alternative.
10: Good programs for ensuring MOV switch settings as 11 referred to in the question are already included in the 12 generic letter. So we feel that 85-03 identifies and 13 significant concerns with operability of the safety related 14 valves in general. And that is what 89-10 is intended to 15 direct.
16 The fifth question was:
17 "The distinction between safety related and position 18 changeable valves is not clear since all valves in a 19 safety related; i.e., quality level one system are 20 generally also quality level one compounds. The 21 distinction appears to be that safety related MOV's are 22 those with a design basis event active function and 23 position changeable MOV's are those not expected to 24 change sty _te during the design basis event. Does the 25 staff: concur with this notation or have some Heritage Reporting Corporation (202) 628-4888
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118 1 alternative clarification on these terms?"
2 And that is one interpretation. But I think there 3 is.a simpler way to look at it. And that way -- the way 4 it's in the question can'cause you problems. And we 5 mentioned that before.
6 So that you want to identify all your safety 7 related systems and all MOV's in those systems or associated 8 in those systems such as a boundary type of MOV that may not 9 be officially in that system but it provides an isolation 10 function or a boundary function for that system must be 11 considered. If an MOV has no safety function and can be 12 prevented from inadvertent mispositioning, then it doesn't 13 have to undergo the design and review and testing. That is 14 what I consider the easiest way to interpret the 15 relationship between safety related position changeable in 16 the generic letter. I think the other way that's opposed 17 here in the question can cause you problems.
18 MR. JACOBSON: I think there's a basic problem in l 19 the way different utilities classify things as safety 20 related. It's not uniform. Some utilities may, as in this l 21 example, have everything in a safety related system as 22 safety related. Other utilities may call certain components l- 23 in a safety related system non-safety related if they don't 1
l 24 perform a,safaty f_ unction.
\
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1~ particular ut.ility the response.to this question.would be 2 different. But from our standpoint we're saying that if
^
3 it!s 1n a safety system'and it'is not blocked from
-1 l
4 inadvertent operation, t'han it is considered to be safety 4 5 related whether it's' active,. passive.or whatever. That's 6' the simplest way-we can put.it.-
7 MR. MARSH:' Okay. Great.
8 MR. SCARBROUGH: Okay. The next question was,-if 9 position-changeable MOV's are considered under the system --
10 MR. JACOBSON: You got a question? I'm sorry. j 11 UNIDENTIFIED: I'd like to take you back to 12 . question 1 which was the question about operability. I 13 ~think the intention of the author was, are you changing the 14 definition from the tech specs and what do you have to do to'
-15 demonstrate operability? I would-submit that this. process 16 that we're going through -- the testing for Generic Letter 17 89-10 is a design validation process and not an operability 18 demonstration because the operability demonstration is 19 defined in the technical specification that you complete 20 your IST test and all the components sub-components for a 21 system and its support systems are what you require for 22 operability. And that occurs on a regular basis. So if 23 you're saying that this is an operability demonstration, 24- then it'a;goingto have to occur on a periodic basis as 25 coincident with the technical specification requirements.
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.1- MRP SCARBROUGH: That's true.- Usually a 2~ ' continuing program -- I'm wasn't intending that operability
- '3 Loe:somehow defined along with the standard tech specs or i
- 4- even considered as defin'ed in the standard tech specs. My 5 definition or my use of operability in this case'was the 1
6 simple acknowledgement when you perform the test that it 7 will'open~it.or shut it for both as needed. Okay. It's the 8 Webster's definition of operability and not a standard toch 9 .sec definition.
H10 UNIDENTIFIED: I understand that. Also I wanted, 11' _ was it clarified because the question comes up all the time
- 12. .when we're. talking about these things is whether or not we 13 areLnow having an additional requirement placed on us 14 because the shift operating authority has the responsibility 15 for declaring what's operable and what's not operable and 16 they do it through a standard regiment. You know, it's 17 defined in the technical specification and although they may 18 not actually perform the required testing, they require it 19 at the appropriate time and on the basis of the results they 20 declare equipment operable or inoperable. So what we're 21 trying to clarify is whether or not there's an additional 22 requirement being made that's outside of the technical 23 specification that will have to be worked in?
24 ; MR. SCARBROUGH: I would think that if you 25 performed the testing that's in Generic Letter 89-10 and i
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[" l' you're able to adjust MOV's so that they can operate under t
2 its design basis condition, then it's operable. If you find
'3- that there is-absolutely no way of adjusting that MOV such-4 .that it will function un' der the design basis condition --
5 UNIDENTIFIED: Then it's inoperable. We agree 6 with that but at the point that you go in and you establish 7 this what'I'would prefer to think of as a pre-operability B test,.then in order to return your system to service and.
9 you've done major work on a sub-component, then you doLthe 10 operability required demonstration from the toch specs which
- 11. refers you back into the IST program.
12 MR. MARSH: The letter acknowledges -~~and you're
! 13 aware of the weaknesses in the in service. testing program 14 for the operability calls. So you're question is basically, 15 is there a new operability criteria to use Mov's beyond in 16 service testing? Is it associated with the generic letter?
17 The answer is, yes, it is. That's the reason we put the 18 generic letter out. Because it does replace the in service 19 testing requirements. It does supplement with the generic 20 letter testing frequency. And if those tests aren't 21 performed or if they are performed and the valves fail these 22 tests, t.en the valve should be declared inoperable and 23 unable to perform its function and the appropriate LCO 24 should be...ente _ rad.,
25 UNIDENTIFIED: And if you have an 18 month Seritage Reporting Corporation (202) 628-4888
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122 1l frequency on-some_particular valve test demonstration for 2 operability then this process you' re saying would be - 1
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- l. 3 . repeated on an 18 month' basis? j j
Th'at's correct, l 4' MR. MARSH:
5- ,
MR. JACOBSON: But that process may not. include-
.6 - full DP testing.
7~ MR. MARSH: That's correct. We didn't. imply that-I' 8 the valve is to be' full flow tested every five years..
9 UNIDENTIFIED: I. thought that.
10 'MR. MARSH: No. Not full flow testing. No.
11 There is'a. periodic retesting that's in the generic letter.
12 MR. JACOBSON: The periodic rotesting isLonly to 13 verify _that'it hasn't changed. 'We're not requiring you do 14 periodic' full scale DP testing.
15 MR. MARSH: Okay? -
16 UNIDENTIFIED: I think part of the confusion comes 17 'from the same problem that you run into -- these tests for 18 the most part are going to be fully instrumented with some 19 sort of diagnostics. The problem is that that is 20 essentially an intrusive test. I can go out and full flow 21- Delta P, test this valve to my heart's content'but when I
- 22. take that equipment off of it and I button it back up I 23 still have to do an operability test per Section 11 per my 24 toch specs before I can return that valve to service. That 25 Delta P teet that's been done for whatever reason is not an Heritage Reporting Corporation (202) 628-4888
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123 1 operability test. LThat's a design verification test but it 2 will perform its intended function. The true' operability 3 test comes when I walk away from it and operations tests it 4 for the tech specs. That's not to say whether Section 11 is
_5 sufficient or insufficient but the wording as far as 6 operability testing needs to be done carefully because it is 7 not really an operability test. -That valve isn't operable.
8 MR. JACOBSON: We' re not saying to delete the 9 other test. What we' re saying is that you' re not required 10 to repeat this test at the same interval that you may be 11 required to repeat this other operability test that you're 12 talking about. However, if you do maintenance or anything 13 of'that nature on the valve, you have to follow the guidance i 14 in the generic letter which means you may have to do some 15 diagnostic work to prove that nothing's changed. ,
16 UNIDENTIFIED: That may be true but that's still 17 not the operability test.
18 MR. JACOBSON: We're questioning semantics.
19 UNIDENTIFIED: No. It's not semantic:. It's the 20 code. It's the law.
21 MR. JACOBSON: Okay. But what we' re saying is, 22 you do not have to repeat the full DP test at 18 month 23 intervals if that's what's required by the operability test.
24 However, _you still,have to do the other test.
25 UNIDENTIFIED: You have to do the testing in 1
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124 1 accordance wrth the Generic Letter 89-10 but it's not an 2 operability test.
3 MR. JACOBSON: Okay. We can call it anything you 4 like. We can call it fu'11 DP testing.
5 UNIDENTIFIED: What happens if that test fails?
6 MR. MARSH: I think that's the point. It's 7 inoperable. If you fail in the 18 month test or 89-10, if 8 you find that the switch settings are all messed up,'they 9 have changed significantly, that valve is inoperable.
10 UNIDENTIFIED: U-huh. But conversely, if I have 11 diagnostics hooked to that valve and I'm into the limit 12 switch compartment and everything else and then I do the 13 test and everything is fine and I take that equipment off 14 there and walk away from it, my resident inspector is going 15 to jump up and down on me because I haven't done'a post 16 maintenance test to declare the valve operable per Section 17 11 of my tech specs. So that testing that you're doing for 18 89-10 could be considered designing verification or post 19 maintenance testing whatever you want to call it. But the 20 true operability testing is still per our tech specs.
21 MR. JACOBSON: It's part of it.
22 MR. MARSH: Wait a minute. I think we need to be 23 clear here. If you fail the 89-10 test that you perform 24 every 18,montbgp the valve is inoperable. That means that 25 if you find the switch settings are not correcting set, Heritage Reporting Corporation (202) 628-4888
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I 125 1 they've changed significantly --
2 (Whereupon,.there was a brief discussion off the 3- record.)
4 MR. MARSH: Why don't we caucus ourselves here to 5 make sure there is no doubt between the operability clause 6 int he 89-10 issue, okay?
7 MR. KIESSEL: Let me just make sure we're talking 8 about he tech spec IST type minimal requirement you got to 9 do it once every refueling outage time.
10 UNIDENTIFIED: Or it could be quarterly.
11 MR. KIESSEL: And quarterly if yon can get at it.
12 UNIDENTIFIED: It serves as a slow basis for 13 operability.
14 MR. KIESSEL: Within the operability of the tech 15 ' specs, yes, agreed.
16 MR. JACOBSON: The generic letter says ever five 17 years for periodic testing per the generic letter. And what 18 we're saying is if you fail that test, it would have to be 19 declared inoperable.
20 MR. KIESSEL: Until such time that as 50.55 AEOD 21 gets changed still stay the code is written.
22 MR. SCARBROUGH: We're going to hurry up and 23 finish with Fermi and then we're going to take a break. The 24 tech spec; requirements for operability every 18 months is 25 what's required by tech-spec Section 11. The good old stoke Heritage Reporting Corporation (202) 628-4888
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.1 - time. That operation. That's done. That's operability.
'2' Once the initial -- or when the initial DP tests are 3 performed under 89-10 you determine whether or not that 4 valve will operate under a full flow full DP condition. If 5 you find that through all of your methods and you're not' 6 able to make that valve be operable or-able to perform its 7 safety function under its design basis condition, that valve l 8 is not going to work. And you got to call it that. And 9 it's not going to work just as if you walk out there in the l'0 plant and you saw it was broken in half. It is, therefore,
- 11 declared inoperable according to the tech specs and you 12 enter the LCO. The same way with once your program gets 13 started every five years -- roughly, every five years you 14 have a validation of the switch settings according to 15 Generic I.etter 89-10. If at that time at every five year 16 internal when that five year rolls around, you look at it, 17 you say, things have changed, it's not going to work now, 18 it's now inoperable. The same as if you found it 19 disassembled or broken. Something is wrong within the 20 plant. What -- the tech specs are still there. Every 18 21 months. Whatever that requires. The good old Section 11 22 testing. You do that. Okay. Declare it inoperable if it 23 doesn't work. Then it lay it on 89-10. This is another way 24 of goingg put augi checking if the valve will work. And if 25 you find out it does work, you're alright. You find out Beritage Reporting Corporation (202) 628-4888
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'1, when'you do'E9-10. testing or.' evaluation that it won't work, L
.2 you have to. declare it inoperable according to tech specs.
3 l
3 Number six. .If the position changamble MOV's arel considered. )
4 ;under system single fail'ure analyses for the license design 5 basis, can they be excluded per Part E of the. written ,
6 actions? If not, why not? I think we answered this,.but'
- '7 'it's not. Position changeable to this positioning is 8- considered beyond design basis. The single. failure analyses 1
- , was not intended to pick up that type of situation. -This.is L 10 laid on. top of the normal single, failure -- major single 11 failure assumed in an event. This is what has been 12 addressed by NRC management in its evaluation that this is 13 laid on top.of the single failure analysis as-formed for all 14 design basis _ events. So it is because of the concern for a 15' very quick operation, inadvertent action by the operators 16- that they caused the valve to get into the wrong position.
17 #7. What is meant by the statement, NRC envisions that part 18 of a good maintenance program, the MOV's and the balance'of 19 the plant should be considered or included in the program.
20 Okay. What's recommended there is that licensees review the 21 balance of the plant and include MOV's it considers 22 important. And from a either safety situation or from an 23 operabilities plant availability situation the NRC does not 24 contend to thia time the balance of plant MOV's in terms of 25 Generic Let_ter 89-10 but if a specific problem occurs that's I
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128 l' always a possibility. But there is_no intent'at the current I
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1 2 . time to get involved in balance of plant MOV's in terms of 3 intent. Question 8 is, what guidelines does the:NRC expect 4 licensees to use with re' gard to. assessment'of balance of 5 plant MOV's according to safety? And it is.the same' answer.
6r Whatever the licensees consider important. We feel Generic 7 Letter 89-10 would help improve the confidence that that
- 8. valve will operate when its called upon and that there-may 9 be- balance of plant MOV's that likewise could benefit _ from 10 that program. That's strictly what the licensees call' in:
11 terms of what they consider being more important in terms of 12 plant availability. Okay. The ninth question Dick Kiessel 13 will handle.
14 MR. KIESSEL: Okay. The question reads, several 15' reports have indicated to us that the implementation of an 16 extensive MOV testing program and subsequent equally 17 extension corrective maintenance effort was a direct result 18 of past neglect on our maintenances practices. However, the 19 majority of MOV' degradations appear to be detectible and 20 correctable under a maintenance program of sufficient 21 resources in' quality without the expansion of mandatory 22 testing imposed by the generic letter. What specific 23 benefits does the staff expect licensees to obtain from this 24 expansiog of testing? It's exactly that. That more 25 comprehensive preventive program. But it's a little more Heritage Reporting Corporation (202) 628-4888
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1 than that. It's a design verification to start off with. !
l 2 First of all, will the valve, the way it was designed, 1
3 really do what it was supposed to do? And the next question l i
4 is, is the valve being k'ept that way?- And unfortunately, 1 5 there are a few members of the industry that have to be 1 6 brought up to this level. And we're applying this across 7 the board. If you're one of the good guys and are way ahead 8 of the game, then you've saved yourself a lot of time and 9 effort now.
10 MR. SCARBROUGH: Okay. The next question 11 was -- does that answer your question? We haven't had much 12 dialogue with you. We're sort of just giving out answers. j 13 UNIDENTIFIED: Everything is okay.
14 MR. SCARBROUGH: Okay. This is the tenth 15 question. Page 4, Paragraph 1 states, when determining the 16 maximum differential pressure or flow for position changing 17 of there, the fact that MOV must be able to recover from 18 this positioning should be considered. If the license plant 19 design basis analyses assume that a disposition valve is not 20 recoverable as part of a plant transient accident event 21 response, is this consideration excludable under the j l
l 22 guidelines of Recommended Action E? And the answer there 23 generally is no because of the single failure concern. The l 24 mispositioninggim laid on top of -- if that was the reason 25 for why yow excluded the single failure criteria, then no.
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1 130 I L -l 1 MRt MARSH: I'm having a little trouble I
'2 . understanding what you mekn by this specifically and how it
~
3 relates back to your single failure question on Page.3 1
4 there? Can you clarify'that? I personally would be f 5 surprised if single failure analysis assumes this
- 6 positioning of valves in the first place. And second if the V .
l L 7 plants analysis'did assume the mispositioning was an initial 8 consider and it was not recoverable at all, then I'm not 9 sure what type of analysis it was that was done in the first 10 place. Can you or anybody else clarify this question?
11 UNIDENTIFIED: I thir.R it concerns us that we are 12 talkilig about double failure.
13 MR. JACOBSON: You want to take credit for single 14 failure for mispositioning, is that what you're saying?
15 UNIDENTIFIED: Yes.
16 MR. MARSH: A single failure is something active 17 that must change it's position and it's presumed not to 18 change. That's a single failure. For a pump that fails or 19 a diesel that fails or something that is active and fails.
20 Not operator closing of valves and then not being able to 21 reopen it. That's not single failure. But if that had been 22 assumed in some type of licensing analysis then I think it 23 needs to be looked at.
24 MR._SCARBROUGH: Okay. I think the next question 25 Jeff will bake that one.
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1 131 c .1- MRi JACOBSON: Okay. Regarding recommended Action
- 2. F,,what kind of documentation does the staff expect for.
3 licensee records for actual test method explanations and f
i 4' descriptions?. I guess b'asically you're asking what type of !
5 documentation you should have. And the basic answer is that 6 it should be detailed, auditable, such that our inspectors 7 can go in there and verify that the appropriate analysis and 8 so forth was done. I' d say similar to what you had done for 9 your EQ audits. You should have the documentation available 10 and it should support any assumptions that are made, so 11 forth and so on. We don't want to see unverified 12 assumptions when we go out there. For instance, if you have 13 a differential pressure associated with your valve of 1,000 14 pounds, we'd want to see where that comes from. We don't-15 just want to see a number there that's not validated. As
-16 far as the testing goes, we would expect to see records from 17 the testing that was done. And the more auditable the-18 better. Do'you have a question?
19 HR. CONROY: Yeah. I have an additional part to 20 that as far as record keeping goes. Is there any 21 requirement or recommendation either explicit or implicit in 22 the generic letter pertaining to performing and documenting 23 as found conditions of an MOV assembly that's within the 24 scope of.the generic = = . -
letter?
25 HR. JACOBSON: Are you talking about conditions Beritage Reporting Corporation (202) 628-4888 R
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i 132 1 found during-the initial design?
2 MR. CONROY: Yes. Conditions found during initial ]
3 testing. .
1 MR. JACOBSON: Initial testing? i 4
5 MR. CONROY: Right.
6 MR. JACOBSON: I don't think there is anything in 7 the generic letter that speaks to that specifically.
8 However, if in the course of your design review you find 9 discrepancies that would fall into other regulatory areas 10 where you would be required to report that you should do 11 that. I don't know of any specific program that we've asked 12 you to set up in terms of recording as found data for this 13 design. Do you want to add to that?
14 MR. KIESSEL: Yeah. However, we do ask you to set 15 up a program of trending.
16 MR. CONROY: Yeah.
17 MR. KIESSEL: And in my mind in order to trend I'd 18 like to know the as complications. So, yes, it is implied 19 that you're going to have to record as found conditions.
20 Otherwise, you're not going to have a basis to do your 21 trending. Your simply trending on as like conditions.
22 MR. CONROY: Well, it depends on what your 23 starting point is. For instance, if you' re going to go out 24 and you'_re going to call that your base line, then your 25 starting point from the base line would be what you set the Beritage Reporting Corporation (202) 628-4888 g
W 133 1 valve up to meet the design requirements that you determine 2 and. verify per your generic letter activities.
3 MR. KIESSEL: Yeah. And before you set your base 4 'line I'm not really worried about. But it's on your i
'S subsequent testing that as found becomes important in my l
6 mind.
7 MR. CONROY: No , I agree with that.
8 MR. KIESSEL: Okay.
9 MR..JACOBSON: Yeah. There's not specific 10 requirements for what was there before you did your design.
11 Okay? I think I've got question-12 too. Regarded 12 recommended Action E by high initial current needed for the 13 operation of the MOV is the staff referring to the motor 14 terminal voltage drop as a result of motor in rush current 15 only? The answer to that is, when you look at the voltage 16 on the MOV you should be -- when you caleclate what the 17 voltage is going to be at the MOV you should be-using the 18 starting currents to figure out the voltage drops on the 19 . associated cabling on the motor control centers. And also 20 you should be looking at those currents in terms of your 21 thermal overloads if they' re in the circuit and not using 22 normal run currents to size your thermal overloads. So 23 there are a couple cases that I know anyway that currents 24 are usedjin tha ca,1culations. Do you have a question?
25 UNIDENTIFIED: Ensuring the proper thermal Heritage Reporting Corporation (202) 628-4888
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134 1 overload sizing was mentioned in the Generic Letter 89-10.
2 In certain cases either selection may limit the operation 3 time of limited duty motors in order to ensure adequate 4 protection for the motor due to high locked rotor currents.
5 Should the emphasis be for allowing a full cycle of the 6 valve or for complete protection of the motor,-which one has 7 priority?
8 MR. JACOBSON: Well, I think you need to clarify
.9- yourself a little bit on -- you said that protection will 10 not allow -- I think what you're saying is, in order to have 11 adequate protection you can't ellow full cycling of the 12 valve and I really don't understand that. If this overload 13 is sized properly you should be able to fully cycle the 14 valve and protect it as well.
15 UNIDENTIFIED: That's not necessarily trus. You 16 could find thermal overload sizing that will protect your 17 motor but it won't allow a full cycle of the valve.
18 MR. JACOBSON: What would it allow?
19 UNIDENTIFIED: It will allow a partial cycle of i
20 the va3ve. Maybe even one stroke in an open or closed 21 direction. If you'rt strictly allowing that thermal 22 overload to protect the motor --
23 MR. JACOBSON: I find that -- do you know specific 24 examples becausa I_'ve looked at this and I can't imagine how 25 you would have that occurring because in order to -- when Beritage Reporting Corporation (202) 628-4888
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you do the thermal overload sizing you're usually looking at 2
the locked rotor currents on the motor and those only occur 3
for a very small fraction of time in your stroke cycle.
4 UNIDENTIFIED: That's correct.
5 MR. JACOBSON: So really it is kind of negligible '
6 when you're talking about repetitive cycles because you'd be 7
repetitive cycles but it would only be at the normal running 8
current of the motor where you should be getting into your . L 9 thermal overload trip range.
10 UNIDENTIFIED: You'll get into your thermal 11 overload trip range when you have a valve that has a 12 relatively long stroke time.
You know, valves with a short 13 stroke time, the running current isn't going to be present _
14 for a very long period of time. So they don't usually trip 15 your thermal overload or cause it to trip. But if you have 16 a valve that has a long stroke time, it may cause the 17 thermal overload to trip and stop your valve from cycling or 18 from operating. If you're sizing it based on locked rotor 19 currents.
20 HR. JACOBSON: I think if that's the case, you've 21 got the wrong thermal overload in there because examples 22 I've looked at you shouldn't get into that problem.
23 UNIDENTIFIED: Well, if you say that you have the 24 wrong thermal. overload, you'd have to upsize the thermal 25 overload and it may not protect your motor at the locked Heritage Reporting Corporation (202) 628-4888
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k I i .. .I l l 136 1 rotor current for the period of time that you have that-
- 2' locked rotor current.
3 MR. JACOBSON: I think there's difference 4 characteristics for the overloads as well.
5 UNIDENTIFIED: That's correct.
6 MR. JACOBSON: More than just different sizes.
7 UNIDENTIFIED: The currents though are generally.
8 the same. There's a set of curves that you'll get, time ;
9 current relationships for each one of the overload heater i 10 sizes that you can select. And you can come up with 11 instances where you have a long cycle time on a valve and if 12 you size a thermal overload for the locked rotor current, 13 then the valve cycling time may be limited.
14 MR. JACOBSON: I think what you -- I think what's 15 happening here is that you're using the locked rotor current 16 for the entire valve size stroking.
17 UNIDENTIFIED: No.
18 MR. JACOBSON: No?
19 UNIDENTIFIED: No. Ten seconds.
20 MR. JACOBSON: I think that our position would be 21 that you have to ensure that the valve can be stroked. I 22 think you're going to have very limited circumstances --
23 cases when this is going to be a problem.
24 g UNIDENTIFIED: That's correct.
25 MR. JACOBSON: And in those limited cases our Heritage Reporting Corporation (202) 628-4888 g
1 137
' l' positionsLare out there in the. reg guys and so forth and 2 what that says is that the overload should be sized _in a
- - 3 conservative direction to allow the valve the stroke.
4 That's our position.
5 UNIDENTIFIED: Okay. So.the. priority then is to 6 allow a complete cycle of the valve over protecting the 7 motor.
8 MR.'JACOBSON: Yeah. -The priorities try to get
.9 was that will do both. And in most cases that can be done.
10 Now, if there's a specific example where that can't be done, 11 we want the valve to.be able to stroke.
12 MR. SCARBROUGH: Okay. The next question was 13 regarding Recommended Action, Third Paragraph, what type of
'14 documentation does the staff expect licensees to have when 15 justifying the acceptability of an MOV function without 16 repeating design basis testing?. The initial problem I had 17 with that question was that Paragraph r is discussing 18 initial testing and not repeating testing, repeating design l
19 basis' testing. And there needs.to be some type of initial !
20 design basis testing. So what you'll need there and I'm 21 just interpreting the question, is that if you have a 22 prototype and you've performed design basis testing on that i
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23 valve, you also would perform no load or low load DP testing 24 and then perform some low load DP testing on the valve in 25 the plant in question and then apply that with proper Beritage Reporting Corporation (202) 628-4888 ,
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1 justification to the DP across to the MOV that's in 2 ' question. Can-you interpret that question a little bit or 3 ' explain that question a little bit to us? Is that where 4 we're heading?
5 MR. JACOBSON: You want to know what we're going L 6 to require you to do in lieu of full DP testing, right?
7 UNIDENTIFIED:- Yeah.
8 MR. JACOBSON: Well, what we said previously was 9 that you' re going .to have to look at that depending on the 10 maintenance and we can't be specific in that right now.
11 MR. SCARBROUGH: Yeah. That's after you have 12 maintenance or things of that nature.
13 MR. JACOBSON: But whatever route you choose you 14 should have it documented why you chose to do whatever 15 testing that-you did.
16 MR. SCARBROUGH: Okay. Question 14.in this pack 17 is, if licensee characterizes valves into different groups 18 such as 12 inch and 600 pound gate valve with the same type 19 of operator and perform DP testing on one of them under 20 actual system operating mode, does the licensee need to 21 perform DP testing on other valves in the same group? This 22 is -- I think we've talked about this. If MOV assemblies 23 are in a group and you're going to apply one from the other j 24 they nee 4 to ba_ identical or if they' re not, you need to 25 have a just;ification for applying them of same -- the valves seritage Reporting Corporation (202) 628-4888
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1 definitely needed to be the same identical valves if you're 2 going to have them 'in the smne group. But you still must 3 perform the low load diagnostic testing on MOV's to show 4 that they're all set up properly. So you can do it that 5 way. But you're going to have to justify more than just -
6 that they're all 12 inch valves or all 600 pound gate
' ~ ' ' ~ " " ^i
,7 valves. There's got -to be more justification than that.
8 Because that's something that's being seen in the INO tests 9 is that it's not easily applicable from one type of valve to 10 another. Question 15 was, can we take credit for DP testing 11 performed on high ANSI rating and DP MOV's for lower ANSI 12 rating valves in the same category; i.e., if a 600 pound 13 rating gate valve is tested at a certain DP, do we need to 14 test a 300 pound rating gate valve with a lower DP? Okay.
15 The answer is, you will need to do that testing.' You can't 16 take credit for extrapolating 600 pound valves and 300 pound 17 valves. The valves have to be identical. Working with 18 actuators, the motors, you know, there's some flexibility in 19 there to properly justify it but if there's one thing Idaho 20 tests -- the INEL tests are indicating is that the 21 difficulty in extrapolating data from one valve to another 22 and even from the same valve to an identical valve, there's 23 some problems there. So -- but definitely it has to be the l
24 same valve..
And.,t_ hat's it for Detroit Edison, Fermi 2.
Any l 25 questions on the Fermi questions or responses to them? If l
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[
L1 .not, we can. take a break and come back around three. It is i 22 , ten'to.three now.
+y .
3- (whereupon, there was a short recess.)
4 MR. SCARBROUGH': Why don't,I clarify one aspect
- 5 that.was brought to my attention after our -- during our 6 break. On the'very last question in the Fermi package-
'7 concerning the 600 pound rating and the 300 pound rating, 8 and our answer was no, that we were concerned about 9 extrapolating different valves. Extrapolating the data from 10- different valves. It was brought to my' attention that some 11 valve manufacturers have identical valves which have 12 different ratings on them. And I didn't read that from that
'13 . angle. If the valve is identical, and it's only the 14 manufacturers paperwork that makes it a different valve, 15 then that's pretty readily justified that you use data'from 16 valve to another. But, if it's truly an identical valve, 17 .then that comes of the tune of an identical valve and the 18 600 and 300 pound rating is just a paper rating. So I just 19 wanted to clarify that because that was brought to my.
20 attention during the break.
21 MR. JACOBSON: Let me add something there. You 22 better make sure that if there is a difference in the rating 23 that it is just paper and that there isn't some reasoning 24 behind that. J{veseenthisproblemcomeupinotherareas 25 where people think they're identical and they're really not.
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141 1 It may be a question that they only tested the valve at a 2 lower pressure and that's why its rated that way. Well, 3 that may be okay. But there may be some differences in the 4 internals or so forth. 'If they are of a different rating, 5 you have to assure yourself there really isn't any.
6 MR. JACOBSON: If he certifies to you that there's 7 no differences and he's an approved vendor and so forth, 8 then you can probably live with that.
9 MR. SCARBROUGH: Okay. Why don't we go on to the 10 next set of questions. It comes from D. C. Cook. And there 11 is two packages. The first one was signed by Barney 12 Bradley. I don't know if he is here or the D. C. Cook 13 people are here? Oh, there they are. Okay. The first 14 question was, rather than testing all MOV's in situ in 15 design basis conditions even if such a test could be 16 duplicated for similar valves, is it acceptable to apply a 17 comparison with appropriate design basis test results 18 obtained from another reference base line MOV? If so, what 19 type of documentation is required? Okay. It is acceptable 20 to use identical MOV's and apply the results from one Mov to 21 another where you justify that application for the prototype 22 whether in plant or in a laboratory design basis test and 23 then a low load type of test in the lab and then some type 24 of reduced preasure test on the MOV in the plant to make 25 :
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1- sure the valves are set ~up not only identically in --
2 physically,.but also they're set up in the same manner.
3 'Something that you'should be aware of and should be re -
f 4_ cognizant of and account ~ for is the orientation of the MOV.
S' If it's a vertical MOV that's in the plant and'it's a 6- horizontal MOV that you're testing in the laboratory you 7 should be aware of that and ensure that the results are 8 interchangeable. They may not be.' You have to include 9 degraded voltage' calculations in your testing if you don't 10 actually include it as part of the test. Instrument 11 inaccuracies. Okay. The margin. You're going to have to 12 account for that. If you have different actuators but 13 identical valves, then you're becoming more difficult than 14 identical MOV assemblies.
1 15 MR. JACOBSON: Let me just give you a brief 16 envision of how I see you doing this. If you're going to do 17 the prototype testing and you want to compare the results of 10 what you got in the prototype to something in the plant, 19 you're still going to have to do all the calculations and 20 everything on the one in the plant because most likely the 21 prototype you're going to do that at full voltage and you're 22 going to try to envelope the differential pressure and so 23 forth. And what you're going to get out of that is you're 24 going to;.figura out how much thrust is required for my valve 25 at any particular differential pressure. Then you have to seritage Reporting Corporation (202) 628-4888 gj
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.143 1 take-that thrust.that you got.in the prototype and somehow g -2 validate that the one I've got in the plant is going to 3 require the same amount of thrust at the same D.. And that's 4 were you get into', well, do you do it at-low DP.or no DP.
5- And then after you do that you're going to have to validate 6 that-your actuator as it's set up can deliver that required 7 thrust'under all your. design conditions which include 8- degraded voltage and so forth and so on. So you're always 9 going to have to do all the calculations-and everything for 10 the ones in.the plant. Are there any questions on that?
11 UNIDENTIFIED: There are a lot of things here that 12- I think I'm hearing'between the lines. Are we talking about 13 pipe sizing, pipe configurations, valve orientations, stem 14 orientations,. temperatures, all these things have to be 15 considered.
16 MR..JACOBSON: Anything that could affect the 17 operation has to be considered. Put it that way. And if we 18 haven't thought of something yet, we may think of it in the 19 future. So, if you know of something, it's a good chance 20 that we're going to find out about it. So, you know, 21- orientation if it's one degree different, I don't think 22 that's going to be a problem. But certainly if the one in 23 the prototype test was vertical and the one in the plant is 24 horizontal and_the_re's going to be different loading effects 25 and so forth on the disk and everything, it's going to Beritage Reporting Corporation (202) 628-4888 l
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i 144 :f 1! perform' differently and you're going to have to account for
, 2. that- If the temperature that your particular actuator has 3 to work, say it's an EQ actuator, it's an inside containment 4 .and'it has to work'at 34'O degrees,11tlis probably' going to.
5 ; deliver less thrust at 340 degrees than it would at 120 6 -degrees. You're going to have to account.for that. And 7: that typically hasn't been up until now.
8 MR. MARSH: We don't want you to misunderstand.
9 We don't have aJlist.of:hid items that we know about that 10 you may not-know.about. That's not.where we're coming from.
11 There are concerns that have been expressed in a number of
'12 different ways about valve operations and various tests.
13 EG&G test, the friction factor determinations, if the size 14 happens to be a factor in so far as it affects. fluid flows 15 or temperature of the fluid, the pressure of the' fluid is 16 important. Those are know parameters that are important.
17 Those are~ unannounced. There's nothing veiled here. That 18 if-we know about parameters'that you need to know'about, 19 we'll tell you. It's nothing something that we're going to 20 spring on you.
21 MR. SCARBROUGH: Okay. The next question here 22 was, are analytical methods and extrapolations to design 23 basis conditions an acceptable alternative test method 24 without over $geting at design basis conditions or must 25 hardship be overcome to stimulate this type of test? And in Heritage Reporting Corporation (202) 628-4888
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145 1 general DP testing should be performed. That is the whole 2 purpose of the generic letter. But there are special
- 3. circumstances where you may perform a lower pressure' test 4 and extrapolate -- I thi'nk Jeff talked about that. Where 5 you have a grossly oversized valve which there is no way we 6 could ever possible see the thrust requirements -- that it 7 is able to perform that. So there are special -- there's
.8 exceptions to every rule but in general the whole purpose of 9 the generic letter was to perform DP testing wherever it's 10 possible and practical. Okay. -That's it for D. C. Cook #1.
- 11. D. C. Cook #2. The first one was, what constitutes position 12 changeable valves and satisfactory blocking of these valves?
13 MR. MARSH: I think we talked about that before 14 today.
15 MR. SCARBROUGH: Okay. Let's go on to #2. If 16 there are, for example, four valves from the same vendor 17 must all four valves be tested or can one be tested and 18 results applied to the others? How about similar valves, 19 similar applications but from different vendors? Okay. I 20 think we talked about that before. The same vendor alone is 21 an unacceptable criteria. That -- I think we made that 22 -clear. You need to look at -- identical is what we're 23 looking at first and if it's not identical, then you're 24 going to havejtg have justification for applying the test 25 results from one valve to another. Okay #3. What sort of Heritage Reporting Corporation (202) 628-4888
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146 1 correlation between tested and non-testable valves, if l 2 necessary, what level of DP between the valves is 3 acceptable? And I think we've already addressed that in 4 terms of testable -- the tested valves and the non-tested 5 valves. The ones that are in the plants that you're 1
6 extrapolated or applying the data from tested valves one to l
7 another. I think we covered that. The fourth question --
l 8 MR. JACOBSON: Excuse me. They all have to be 9 tested. It's just that some don't have to be tested at full 10 DP.
11 MR. MARSH: Yeah. We do understand that all 12 valves need to be tested and the interval was discussed in 13 the generic letter. We're just talking about prototype 14 testing.
15 MR. JACOBSON: Yeah. They have to be tested, you 16 have to validate the switch set and there's other things we 17 haven't been talking about here such as the limit switch 18 settings and torque switch settings that are also part of 19 this. I guess we've been concentrating on thrust 20 requirements. But even with the prototype you're going to 21 bave to do some test on all the valves in the plant.
22 MR. SCARBROUGH: Okay. The fourth question Dick 23 Kiessel was going to handle.
24 g MR. EIESSEL:
Okay. How is NPRDS usage envisioned y 25 to satisfied Item H, Generic Letter 89-107 Since NPRDS only Heritage Reporting Corporation (202) 628-4888 {
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147 1 contains failure data, are you indicating that it should be 2 modified to include useful MOV data as.well? Can other 3 systems besideo NPRDS be used? For example, Nuclear Network 4' or.the MOV Users Group? ^ First of all, the goal in that 5 section of Item H was to try and encourage the industry to 6 work together to develop a large data base that could be 7 used for predictive maintenance, for testing intervals, this 8 type of setup. How the industry does this is completely up 9 to them. We've mentioned NPRDS because it already has a 10 running start. At least theoretically it has all of the l 11 MOV's listed in it. It does have some failure data. By the i 12 absence of that failure data you can also maybe conclude 13 that there is some success data. I don't know. Whether or 14 not that failure data is complete enough to be used for 15 industry trending, again, I don't know. But the' bottom line 16 is to try to get the industry to work together to produce 17 this type of data ao that you can have the information 18 necessary to do meaningful predictive maintenance.
19 MR. SCARBROUGH: Okay. Thanks, Dick. I just want 20 you to know that there are 50 more copies of the handouts on 21 the back table so that should cover everybody hopefully.
22 But if not, let us know and we'll get some more made.
23 Question 5. Can a valve which is considered safety related 24 be exempped fjggy the test program if it can be demonstrated 25 that the consequences and failure of MOV is not safety Heritage Reporting Corporation (202) 628-4888 C
148 1 significant? - That's a difficult question since it is safety 2 related. According to some definitions of safety related 3 that means.it has a safety function. But if a valve has no 4 significance in terms of'the operation of that system one 5 way or another. If it's a branch line or something we 6 talked about before, the pressure of a spray valve which in 7 terms of the overall safety of the plant during the accidert 8 scenario makes no difference whether it is open or closed, 9 then you can remove it from the design, review and the test 10 program. And that's something that the licensee will have 11 to consider in determining whether or not that valve is 12 truly -- has no safety significant whatsoever and not relied 13 on in any way. The sixth question was, on Page 4 of the 14 generic letter, Item C, it is stated that testing a design 15 basis condition is not recommended where such testing is 16 precluded by the existing plant configuration. Please 17 provide further details on what is meant by this phrase.
18 For example, some system lineups may be possible which allow 19 valve testing, but these lineups may not be considered 20 normal. If you have to violate your tech specs or your 21 procedures to perform a test and you place the plant in an l 22 unsafe condition or unusual condition that could lead to an 23 unsafe condition, then you have the flexibility of using 24 prototypg testing or using a test on a different valve in l
25 the plant. .But from what we've seen, the plant personnel Heritage Reporthg Corporation (202) 628-4888 l
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I 149 1 can normally-use their ingenuity to come up with some sort u
2 of scheme to test that valve. And if not, then there's 3 flexibility built in the generic letter for those cases and 4 you would need to just perform the low load or no load 5 reduced pressure DP testing on the valves and'make sure it 6 was set up the same way as your prototype. And the seventh 7 question Jeff is going to pick up.
8 MR. JACOBSON: Okay. For Item I-2 of the generic 9 letter, please advise what level detail the NRC expects for 10 the program description? Is this a broad overview or is a 11 detailed description necessary? I think you' re referring to i 12 the description.of the program that you have to send in when 13 -- this is the first year?
18 MR. KIESSEL: You don't have to send it in, you ;
15 have to complete it.
I 16 MR. JACOBSON: Okay. You have to complete it. !
17 It's talking about the description of your program. And I q 18 would say ganara11y that's a pretty general description. I J 19 think we're planning on doing some audits to look at these 20 programs just to make sure you're going in the right 21 direction but we don't really expect to see any real 22 detailed type of program. Whatever you think is necessary l 23 to complete the program basically. We're not going to be !
l 24 harping so much on these program descriptions. Where it is
- ___ _ j 25 going to come down is when we actually go out and audit the l l
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150-l' implementation =of your program and find out whether or not
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2 you're meeting the intent of the generic letter. The
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3 program is just a means to get you there.
4 MR. SCARBROUGH' Okay. The next one was a letter l
l 5 that we had from Commonwealth Edison. There are some L
6 Commonwealth' Edison people here I know. Okay. The first 7 question was, Generic Letter 89-10 states that it is not 8 clear that tests of an MOV at lower moderate pressure 9- differentials can be directly extrapolated to determine 10 correct switch setting at design basis conditions. In situ 11 or prototype testing is considered the most accurate. If a 12 valve is successfully tested at the maximum ~ flow condition 13 .that is obtainable in the system configuration in which the.
14 valve is required to normally operate, could test results be 15 extrapolated.to more severe design basis conditions? And 16 this again raises the issue of extrapolating pressure and 17 some answers as you generally know, it is not normally 18 acceptable to extrapolate pressures from a normal operating 19 condition all the way up to a design basis condition.
20 1. The valve factors have been found through part of the 21 Idaho testing change with pressure. And so that's where the 22 concern for extrapolating pressures has occurred. Now, we 23 have talked about there's exceptions to that. But in 24 general that it the answer. Question 2 is, is there a 25 percentage $xE design basis flow differential pressure at Seritage Reporting Corporation (202) 628-4888
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151 1 which it is acceptable to extrapolate test results if 100% {
i 2 design basis flow cannot be obtained? No , we don't have a 3 percentage in mind. If it's not appreciable - you know, 4 appreciable flow, whatever that is -- then probably there is 5 room there. Just as long as you have margins in your test 6 and maybe there is a possibility of using that result to f 7 qualify or demonstrate operability of your MOV. But 8 generally, no. We're not talking about large extrapolations 9 of test results. The third question was, what other Mov's 10 in the balance of plants be considered from inclusion in the 11 program. And the answer to this is it's up to the licensee.
12 There's no requirement or plan to extend 89-10 to balance 13 plant valves. That's up to the licensee to determine what 14 valves they feel would be beneficial to have them in the 15 program. And the fourth question Dick is going to take.
16 MR. KIESSEL: Item K of the generic letter gives 17 relief for those units in refuel within six months of the 18 letter date. This doesn't provide any relief for those 19 units that are in refuel January 1990 through June 1990.
20 Item I requires a description of schedule for Items A 21 through H within one year of the letter date. It is 22 believed that the intent is bringing the testing program 23 after June 1990 and then meet the three cycle or five year 24 interval - It_ mill _be extremely unlikely that a f
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152 1 1990. . Is. it -acceptable to start testing in June 19907 2 Unfortunately,-when we wrote the generic letter we did not 3 envision a linkage between the six month delay and the one 4 . year to develop the program. The six month delay was put in 5 simply to give people a running start at the generic letter 6 and not to penalize someone who happened to have been in a 7 refueling outage on the day the generic letter was issued.
8 I have a great deal of sympathy for you, unfortunately, we 9 drew a line and you, unfortunately, are just on the other 10 side of the line. I can blow the case for saying, okay, 11 fine, we'll include January 1990 but then what about the 12 plants that start their refueling in February of 1990? I 13 realize you're going to be perhaps hard pressed to get your 14 program. The six months was envisioned for you to have a 15 running start on getting some of the data that you would 16 need before you started doing your testing. Not necessarily 17 to get a full program completely established and in place 18 prior to that time.
19 MR. JACOBSON: Okay. Number five. Is it 20 acceptable to prioritize the type of testing to be performed 21 on an MOV based on the percentage of actuator valve capacity 22 that calculations indicate as being used? As an example, 23 could an MOV that is utilizing only 50% or less of its rated 24 capacity in ag design basis analysis be tested at a lower 25 than design _ basis flow differential pressure condition? I l
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153 1 think here is a case where we're going to have to look at
'2 this on a' case by case basis too. If you have an. actuator 3 that calculationally using the standard equations is 4 oversized by a factor of' five or a factor of ten, then I ~
5 think .you'd probably have a pretty good case for not having 6 to do a full DP test.. However, if it's only marginally 7 oversized,.I think that that's not a good reason not to do 8 the full DP test. I've seen examples where the actuator was 9 probably capable of 1,000 pounds thrust and it was set up 10 for 1,000 pounds thrust and the valve can handle 1,000 11 pounds thrust but only 100 was really required because of 12 the low DP requirement. And in those cases I think we'd be
- 13. willing to probably accept something lower than full DP.
11 4 But unless it is really oversized I think we're going to 15 stick to our full DP requirements.
16 MR. SCARBROUGH: Okay. The next question was #6.
17 Once an MOV has been successfully tes.ed under design basis 18 differential pressure conditions does it have to be tested 19 under the same design basis conditions every five years or 20 three cycles? And the answer there is, no. There is no 21 design basis testing required every five years or three 22- cycles unless there is some sort of modification described l
23 in the generic letter and we talked about that before where-24 it is modified replaced or modified in some manner. Then 25 you'd have.to consider the extent of that modification and Besritage Reporting Corporation (202) 628-4888
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I o 154 1 whether or not full DP testing is not required. You must 2 verify your switch settings by some sort of diagnostic means
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3 every five years. So that's where the five year continuing i.
I 4 effort comes into play.* That's beyond the stroke time and 5 that's discussed in the generic letter. Question seven was, 6 is it acceptable to dete.rmine the type of post maintenance 7 test required based on the type of maintenance performed in 8 the MOV? And that's, yes. You can use your own judgment on 9 the type of maintenance that was performed and if it's a 10 very minor maintenance that you can just use a simple no 11 load DP test with diagnostics. That would be acceptable.
12 It's up to the licensee to justify what type of post 13 maintenance test is performed. The second part of that 14 question was, does the valve require a full in situ design
'15 basis retest.after any type of maintenance? The' answer is, 16 no. It depends on the maintenance. The next question was, 17 what constitutes a design basis review? Explain the 18 elements involved? And just briefly, you determine the DP 19 and the flow under accident conditions, you look at all-the 20 operation in accident scenarios, whether or not it is needed 21 for opening and closing, what are the worst case flow in DP-22 that will be seen, degraded voltage, what's degraded voltage 23 as we defined earlier, temperature conditions. And design 24 basis is goin gto be a living document in the sense that if 25 you find later down the road that the design basis had Heritage Reporting Corporation (202) 628-4888
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155 1 changed somehow, then you need to go back and update that 2 design basis. It's changed, okay, for that valve. If
~
3 you're reconstituting your design basis like some plants 4 are, you can make a best guess as to what the worst case DP 5 flow will be on that valve and then when the worst 6 reconstitution is complete and updated and determine whether 7 or not you're high or low and go from there. So there is 8 some flexibility in that respect. Just an update on status 9 here. We' re about halfway through Commonwealth and then we 10 have a few questions from Duans Arnold and then we'll go to 11 the handwritten questions. Question #9. The next one is, 12 Item H of the generic letter says each MOV failure must be 13 documented. What constitutes an MOV failure? And really I 14 don't see the difficulty in that question. Any time that 15 the MOV fails to operate when called upon or when it's 16 identified or discovered that there's a problem with Mov, I 17 -- maybe I'm reading too much in that question, but it seems 18 to me that it should be a very simple type of question.
19 MR. MARSH: I'm a little reluctant tc define 20 exactly what we mean by failure tco because tiaat may very 21 well be something that you have to define. Make your own 22 judgments about. And if I provided a list, then sure as 23 heck we' re going to miss something and you would find that 24 we wouldnft hava t_o report it. There would be difficulties.
25 So you know what failures are for valves. We can give you Heritage Reporting Corporation (202) 628-4888
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L 156 i some examples but don't loom at that as being the all 2 inclusive list.
3 MR. JACOBSON: I' d include, for instance, a 4 premature thermal overload trip. That's a failure that 5 should be reported. It should documented. Such shows that 6 maybe the motor is drawing more current than what you 7 assumed.
8 MR. MARSH: Look at Attachment A of the generic 9 letter. It has a summary of common motor operated valve 10 deficiencies with suggestions in degraded conditions if you i 11 want a starting point.
12 UNIDENTIFIED:- Thermal overload is covered by toch 13 specs?
14 MR. JACOBSON: What tech specs?
15 UNIDENTIFIED: (Inaudible.)
16 MR. JACOBSON: Maybe your plan but not all plans.
17 MR. SCARBROUGH: Okay. The next one was Item H.
18 Question #9, Itam H of the generic letter --
19 MR. KIESSEL: We've been there.
20 MR. SCARBROUGH: We've been there. Okay. (10 21 then. The NRC states that it will be providing new guidance 22 based on the design basis. There will be testing being 23 conducted at INEL. What is the schedule for the testing?
24 How soonjafter;tes_ ting, inclusive testing, will results be !
25 released? drhe test is only going at this moment. As I Heritage Reporting Corporation (202) 628-4888 1
a,
w 157 1: mentioned, the first phase has been released earlier this 2 year of this summer. Probably next year some time before
'3 they will be able to release.the report.on'the current tests
, 14 that are ongoing.. But t' hey-are'very limited in scope. So.I Lt
!A 5 would not wait for those tests. They are only going to more l
6- .or.less confirm what--we already know.
7 MR. JACOBSON: Is there a' method for determining 8 . thrust requirements'for butterfly MOV's? I think that's a 9 . trick question because I don't think trust is used for 10 butterfly MOV's. If I'm not mistaken your interested in.
11 torque. And I think there are current methods for doing "12 that.
13 .MR. SCARBROUGH: Dick has the next question.
14 MR.lKIESSEL: Is it possible to establish a 15 national -- and here he has parenthetical -- federal data 16 -base of MOV.models and manufacturers that have been tested 17 at design basis conditions? Would this be an acceptable 18 demonstration of operability for generic letter MOV's that 19 must operate under the same conditions? In answer to your 20 question about national or federal, I'm not' aware of any 21 funding in NRC's budget that covers such a data base.
22 That's why we're strongly encouraging that you, the 23 industry, get together to establish this data base. The 24 second part of the question, yes, provided the valves in 25 your data base envelope, the design conditions for which Heritage Reporting Corporation f (202) 628-4888 )
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158 1 you're going-to apply.it to the same valve'in your plant, l
2 then, yes, it is a perfectly base provided, of course, that ]
I 3 you can run the correlation to show that your valve is the i f
4 same and you've taken ca're of all the other little 5 idiosyncrasies with reduced voltage and minor operator 6 variances and you can demonstrate that your valve is at 7 least' set up as conservatively as the one that was tested.
8 So, unfortunately, we can't help you on the data place but
'9 please-start going on it.
10 MR. SCARBROUGH: Okay. Question #13 is rather 11 long. Edison believes that the following could have an 12 impact of meeting the schedule on recommended actions of the 13 generic letter. And there's a long list of things. a.
14 Limitorque being requested for operator data in design 15 review by the entire industry, b. Establishment of a 16 controlled data base. c. Design review by the AE. d.
17 Training of utility or contract personnel, e. Procedure 18 development. f. Lack of test equipment in house. g. Lack 19 of vendor test support for increased scope of MOV program.
20 h. Industry sponsored program to ensure MOV diagnostic test 21 results. i. The NRC MOV performance testing under full 22 scale blowdown results could create a need to revise our 23 diagnostic methods. j. Critical path program development.
24 k. The s,urveil]_ance intervals may be adjusted based on 25 documented -history and trending. 1. It may not be possible Beritage Reporting Corporation (202) 628-4888
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1 to test a large population of valves under design basis in l l
- 2. the time frame of a ten week outage is estimated that the )
3 window for full flow and differential pressure testing is 4 around two to four weeks. A realistic estimate for 5 completion rate is five valves per week. Then the question 6 is, will the NRC be flexible on alternate schedules and ,
7 actions? Will the NRC notify the licensee if alternate 8 proposals are accepted? Okay. These mini reasons here 9 constituted by five years was allowed. There was a 10 discussion of three years at one time and because of these 11 and other reasons, five years was arrive at as a compromised 12 figure. If -- the licensee should explain any modifications 13 to the schedule when it's amidst its letter as indicated in 14 the Generic Letter 89-10. On the schedule it should expla'.n 15 its schedule and justify what it feels will be necessary to 16 complete a program. NRC will respond to any requests in 17 the -- as a result of the generic letter to -- if you have a 18 schedule that's different from Generic Letter 89-10. But 19 there isn't any plan to have a generic schedule change or 20 notify licensees in general of a different schedule. That 21 would be handled through individual responses to a request 22 to have a different schedule.
23 MR. JACOBSON: Let me just add to that that many 24 of these reasons I don't feel are justification for 25 extending the time frame. For instance, you're saying you Heritage Reporting Corporation (202) 628-4888
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1 only have a ten week outage. Well, it may be necessary to l 2 extend the outage in order to complete this testing. We 3 realize.that. Some plants have been down for several months 4 as a result of doing some MOV reviews. Some plants have j i
5 been shut down in order to do MOV reviews. So it's -- we j 6 consider it to be a very serious problem and we understand 7 that it may extend some outages in order to complete the 8 testing. And that's one of the reasons why we gave five 9 years.
10 MR. SCARBROUGH: Jeff, you have the next question.
11 MR. JACOBSON: Oh, okay. Some test programs have 12 indicated that the MOV degrades a. performance that will be 13 directly reflected in motor current. After design basis 14 testing is completed is stroke time and motor current 15 testing. adequate to verify acceptable operation? Okay. The 16 answer to that is, yes, it would be acceptable if you can 17 show that by stroke time and motor current testing you can 18 verify that the MOV hasn't degraded. I'm not that familiar 19 with the current techniques in that area whether they're 20 acceptable or not at this time. However, if it can be shown 21 that they are, then that would be an acceptable method.
22 MR. SCARBROUGH: Okay. That's all the questions l 23 that we had from Commonwealth. Is there any amplification 24 that you would like us to provide on these answers or should 25 we go on to Du5be ' Arnold? Just three questions here. #1 Heritage Reporting Corporation
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161 1 was, Item'E of Generic Letter 89-10 states that no change to l
2 the existing plant design. basis is intended and none should 3 be inferred. The generic letter, however, requires that. i
.- 4 valves be able to recove'r from inadvertent mispositioning.
L 5 These two statements clearly conflict and that the BWR 6 design basis door not require an operator to recover from 7 valve mispositioning. This is considered a single failure 8 and is-accounted for by the first and redundant backup
! 9 systems. Therefore, why is recovering from mispositioning 10 required when it is clearly not within the design basis of 11 safety systems. I believe this has already been addressed 12 with BWR owners through the NRC management that it was a 13 concern for inadvertent mispositioning of MOV's and they're 14 in the program. That is a management position and that is 15 the answer. #2 was, in reference to Question 1 above is it 16 necessary to calculate opening and closing differential 17 pressures for valves whose safety functioning is only in one 18 direction. It is open or closed. Or for passive valves 19 which do not change position already in their proper safety 20 position. Okay. We touched upon this and this is the 21 general answer to it. MOV's must be able to open or close 22 or both depending on the safety function or required safety 23 position. All MOV's need not be tested in both directions 24 unless it!s relied on in the design basis or anywhere in 25 emergency operating procedures. If it is, it must be able Heritage Reporting Corporation (202) 628-4888
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1 to operate in that direction. So that is how you can j
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l 2 determine if you' re going to have to test open, test closed !
1 3 or test both. You can use the worst case for that 1
4 direction. Now, a conservative approach would be to go 5 ahead and test in both directions and then you don't have to 6 worry about trying to justify whether it is open or closed 1
7 or whether it be change in procedures down the road and have {
8 to come back and do the test over again. But you're -- that 9 is the answer on testing open or testing closed or testing 10 both. Okay. Is there any questions on that? Yes.
11 UNIDENTIFIED: I guess by that response then we 12 don't have to assume that these safety related valves can be 13 mispositioned and you won't have to recover these.
14 MR. SCARBROUGH: That's a good point.
15 MR. KIESSEL: Well, we've already demonstrated 16 that it can do its safety function.
17 UNIDENTIFIED: Right. But if it goes to its 18 safety function and then in the course of the scenario it 19 gets mispositioned, would you have to then show that you 20 have to recover it.
21 MR. KIESSEL: Are you saying that it is now 22 experiencing more severe conditions?
23 MR. JACOBSON: You're saying later on in the 24 scenario --
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25 MR. ~kiESSEL: Later on in the scenario it is Heritaga Reporting Corporation (202) 628-4888
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- 1. seeing different conditions? I think you picked the worst h 2 conditions under which that valve was required to function.
3 UNIDENTIFIED: So then you're saying it couldn't
^
4 be mispositioned.
h 5 MR. JACOBSON: Normally you'would calculate in 6 your accident scenario when'it is used. You' d look at the 7 conditions then is what you're saying and now it may be 8 later on and someone dispositions it and the conditions may 9 be more sever, you're asking whether_you have~to use those 10 more severe conditions.
11 MR. SCARBROUGH: If you never need it 12 again -- if you still need it try and get it back out.
13 MR. JACOBSON: Yeah. We would say, yes. You have 14- to be able to show that at any time the valve is needed that 15 it could be put in its correct position. Now, if it's not 16 needed after the initial cycling and somebody dispositions 17 it later on and it's of no consequence then you wouldn't 18 have to figure that out.
19 UNIDENTIFIED: Okay. Thank you.
20 MR. SCARBROUGH: Another question.
21 MR. GUOKAS: My name is Stan Guokas. I'm from 22 Point Beach Nuclear Plant and my question is, the designs 23 basia says that we're supposed to go through and calculate 24 opening and closing thrusts for all motor operated valves, 25 not just sa,,fety related. Does that calculation that design Heritage Reporting Corporation (202) 628-4888
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I 164 l 1 documentation apply to all motor operated valves in the 2 plant? j l
3 MR. JACOBSON: No, no, no. Safety related and j l
4 position changeable, j I
5 MR. GUOKAS: And position changeable. So blocked i 6 valves are excluded from that also.
7 MR. JACOBSON: If it's blocked, then you can throw 8 it out of the program is what we said. If it meets our 9 criteria for being blocked.
10 MR. GUOKAS: Okay.
11 MR. MARSH: We're not requiring that you calculate 12 or do tests on all MOV's. It is only for safety related 13 MOV's and only those in addition that are position 14 changeable, okay?
15 MR. GUOKAS: Okay.
16 MR. JACOBSON: And those are the ones that could 17 affect the safety system, okay?
18 MR. GUOKAS: Yes.
19 MR. SCARBROUGH: Okay. The third question, the 20 background section of Generic Letter 89-10 states that 21 Section 11 testing alone is not sufficient to provide 22 assurance of MOV operability in design basis conditions.
23 Section D of the generic letter states that correct switch 24 settings;are to_be_ maintained throughout the life of the 25 plant and that stroke time testing is not sufficient to do Heritage Reporting Corporation (202) 628-4888
U 165 1 this. Does this mean that additional operability 2 requirements; i.e., in addition'to closure time verification 3 need to be added to the technical specifications? If so, 4 what criteria should be'used in your trace analysis? I 5 think we've discussed this. This is -- we' re not talking 6 about. changing the tech specs. We're talking about this 7 89-10 is-laid on top of the current tech spec requirements.
8 It's a different way of looking at operability of the MOV.
9 And we have a rule change that's being worked on which 10 addresses this whole issue of MOV operability which may come 11 up later. But I think we've already discussed this. And I 12 don't want to cause confusion by adding to it. Okay. Well, 13 that ends our submitted in advance questions and we do have 14 a few handwritten questions that we've received so far.
15 MR. JACOBSON: Okay. This one is from Bob Ryan of 16 Movats. Please clarify a response made in the morning 17 session. If a valve has been full DP tested in Train A and 18 identical valve is in Train B, must the valve in Train B be 19 subjected to a full DP test if it is practical or can credit 20 be taken for the valve tested in Train A and a lesser DP 21 test performed on the -- or no DP test at all? Okay. Our 22 position, I believe, is that you do not have to do the full 23 DP test of the Train B valve if it is identical to the Train 24 A valve.c You_can .do a lower differential pressure test or 25 one at no lead if you can show that's applicable to Heritage Reporting Corporation (202) 628-4888 na
166 1 establish similarity. We agree that the way the generic 2 letter reads it may imply that'you have to do the full DP
- 3. testing unless it is impracticable. However, if you got 4 identical valves in diff'erent trains you can do the one --
5 it allows prototype testing or testing of similar valves.
6 MR. SCARBROUGH: Does that answer the question.
7 UNIDENTIFIED: Yes, it does. Thank you.
8 MR. MARSH: What's the general sense here. We can 9 take a few minute break and look at the questions that we've 10 got before we answer or we can -- what would you prefer as 11 an audience? Okay. We prefer a break. Let's take a ten 12 minute break please.
13 (Whereupon, there was a short recess.) ,
14 MR. SCARBROUGH: Okay. What we're going to do is, 15 I think Jeff has a couple of questions there. I think he'll 16 start off and answer those.
17 MR. JACOBSON: Okay. From New York Power 18 Authority, Fitzpatrick. What specific additional 19 documentation and record keeping is required by Paragraph H7 20 Let me look at Paragraph H. Okay. You're talking about 21 documenting failures.
22 MR. WALLACE: The second paragraph, Periodic 23 Testing and Review.
24 MR. JACOBSON: Periodic review, trending. I don't l
-25 know whah add b onal documentation would be required.
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I 167 1 Certainly for documenting failures it should be using -- I 2 guess you could use your procedures you've already got, non--
3 conformance reports or whatever. Document the failure and 4 have an. engineering eval'uation for it. We certainly don't 5 want to see failures just documented and then not evaluated 6 like we've seen at'some plants. And we don't want to see 7 failures go undocumented.
8 MR. WALLACE: In the review process itself. It 9 says every two years or every refueling outage periodically 10 examine.
11 MR. SCARBROUGH: I think you're looking for trends 12 there. I think you can use some sort of data system like 13 APRDF! or -- and examine not only the failures in your plant 14 but also the ones in other plants. I think that's what 15 we're looking for. I don't think we have anythi'ng firm in 16 mind here. We need a document -- that you're looking for 17 trends and many times you see the same type of failure. You 18 have to keep resetting the torque switch or something that 19 keeps popping up. But I think it will be readily apparent.
20 MR. JACOBSON: I think some utilities already have 21 trending programs in place and certainly we would encourage 22 you to work this into that. You don't need a whole program 23 just for this if you've already got something that would 24 handle it. I_ thin _k we' re pretty flexible in what we' re 25 going to look for in that area. We're not looking for L Heritage Reporting Corporation (202) 628-4888
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168 1 anything specific.
2 MR. MARSH: If I'm not mistaken there is an EPRI l 3 standard on trending, is anybody aware of that? EPRI or an 4 in post standard on at l' east recommendations for trending 5 programs might help a bit.
6 HR. JACOBSON: Okay. The second question.
7 MR. KIESSEL: Before you go on. I got one that's 8 related to it. Okay. And this is a repeat of a previous 9 question but just make sure that we got everything down.
10 Again, from New York Power Authority. This time, Indian 11 Point Three. Is there any requirement either implicit or 12 explicit in Generic Letter 89-10 to perform and document the 13 as found tested condition of an MOV assembly within the 14 scope of the subject generic letter? And I think we went 15 over this before. On the initial setup there is nothing 16 required explicitly or implicitly although I just out of 17 curiosity I'd love to know what the important condition was 18 but I don't think we can hang you by the thumbs for not 19 having it there. However, on the subsequent testing, the 20 testing every five years or post maintenance type testing 21 and there we're starting to get into the trending and you're 22 going to have to have the information then.
23 MR. JACOBSON: Let me add a little something that 24 we haven't talked about up until now. In during the course of your reviesk,~'if you find out that you've got a serious
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1 problem in your plant, let's say you start doing your design 2 review next month and you do a'little sample of some DP 3 . testing and you find out that for some reason all your 4 valves are so far unders'ized or you're having to set all 5 your torque switches up, you've got an immediate problem, an 6 immediate safety concern, then you do not have five years in 7 order to address that problem. I was at a plant recently 8 where they had that very same situation and they're in 9 somewhat a bit of trouble now because that was their 10 philosophy. Well, we were going to wait five years and the 11 generic letter and this and that. If you've got a safety 12 problem in tiie plant that you know of, you're obligated to 13 act on it immediately. You do not have five years to wait.
14 Okay. The second question from New York Power Authority.
15 Please clarify the need to perform partial DP testing on MOV 16 assemblies that have been prototypically tested under full 17 DP conditions for identical equipment. Other than 18 adjustments in switch settings to account for possible 19 differences in packing load, why is static testing non-20 sufficient? Well, status testing may not be sufficient 21 because we want to make sure that other factors involved in 22 the thrust of the valve are similar. I guess a packing 23 load, for instance, is one of the requirements for thrust in 24 the equation the packing load can be verified at static DP 25 or no DP. Eowever, there are a lot of other things Heritage Reporting Corporation (202) 628-4888
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170 1 involved. And even if the valve is identical, there may be 2 some subtle differences that may come out if you do it at a 3 lower DP. Maybe the clearances or something are different.
4 I know a lot of these va'1ves are not made to such standards 5 that we might have expected. There may be some differences 6 between the valves. And we can't. establish total similarity 7 by doing a test at low DP but certainly we can find out more 8 than what we would at no DP conditions. But basically it is 9 because there are several factors involved and that we feel 10 that in doing a test that at least some DP is going to give 11 us a little more assurance that the valves really are 12 similar even though they may have been designed the same way 13 and built the same way. Okay. And the third question.
14 Ensuring the proper thermal overload sizing is mentioned in 15 the Generic Letter 89-10. In certain cases either selection 16 may limit the operating time of limited duty motors in order 17 to ensure adequate protection. Should the emphasis be 18 allowing full cycle of the valve or for complete protection 19 of the motor? I think we already answered this question.
20 In those specific cases I think you should try to make sure 21 the valve be able to cycle. That's it on me.
22 MR. KIESSEL: This is from Con Power. Consumers 23 Power? The generic letter in our discussion has not 24 specifically required diagnostic testing. Certain valves 25 have to demonstrate both DP testing per tech specs or other Heritage Reporting Corporation (202) 628-4888
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l 171 1 requirementar If maintenance is performed on a valve and i
2 the procedures and work practices ensure correct assembly, j 3 is it correct to assume that a successful full DP test is 4 okay for our facility ve'rsus performing a diagnostic test? !
i 5 Yes, it is. However, when you -- if you don't have the j i
6 diagnostic test, you're losing insight into the valve and )
l 7 its functioning. We're also depriving data from -- data '
8 base that we're trying to encourage everyone to set up.
9 But, hey, if you can do the full DP test and that's the way 10 you want to do it, great. You don't have to put anything 11 on. Just show the valve will function at the worst 12 condition. Okay. New York Power Authority, Indian Point 13 Three. With regard to the issue of position changeable 14 MOV's it is noted that Indian Point Three has a number of 15 safety related MOV's that are normally de-energized; i.e.,
16 breaker open and locked at MCC. Certain of these MOV's are 17 required to be de-energized and their positions changed for 18 recirculation based local. The licensing basis of the plant 19 requires these MOV's to be maintained de-energized for 20 normal operation precisely due to immense positioning 21 concerns. Please clarify the need to consider 22 mispositioning of these MOV's under the generic letter. It 23 appears that this would contradict the original intent of 24 the licensing basi,s requirement.
I think for this type of 25 valve we have to look at it as a two phase operation.
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L 172 1 During that period of time where it is required to be locked 2 out, mispositioning is not a question and it would not have 3 to be addressed. Provided, of course, there also is a 4 mechanical lock on the v'alve. Now, for the second phase.
5 Once this valve has been racked back in, then we start the 6 whole nine yards again on that valve and you would then look 7 at the design bases under which it is going to be operating 8 and be able to recover any mispositioning of the valve at 9 that point and time. Did that your question? Do you follow 10 me?
11 MR. CONROY: Well, as far as the mechanical lock.
! 12 Okay. The only thing is with the mechanical lock. Now, 13 these valves are in certain areas that aren't accessible, ;
14 for instance, during accident conditions, so it is 15 impossible to put a mechanical lock on them. That's why 16 they are only electrically locked out. However, there are 17 things such as alarms that would alert the control operators 18 to a mispositioned valve. You know, they're normally de-19 energized, they feed into a common alarm that tells you that 20 they're not in their safe position for instance. But it's 21 impossible to put a mechanical lock on because the valves 22 are not accessible when they have to be re-energized and 23 repositioned later on.
24 MR. KIESSEL: Yeah, but having a mechanical lock 25 on the valv,es should not prohibit an electrical --
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I 173 1 MR. CONROY: Are you talking about a chain -- a t 2 handwheel -- or rather, a chain? j 3 MR. KIESSEL: Yeah. Or removing the handwheel or 4 what do you call them, safety seal? Okay. ,
i 5 MR. CONROY: So I guess this is getting back to 6 the blocking in terms of the either/or and you're still 7 maintaining that an electrical and mechanical blocking is 8 required?
9 MR. KIESSEL: That's right. Because in my mind 10 one of the worst situations that you might encounter is the 11 bout that is electrically blocked by having something racked 12 out down the MCC and it is not mechanically blocked and low 13 and behold somebody comes along and twiddles the valve for 14 you inadvertently during the operation.
15 MR. CONROY: So in other words, we can't take 16 credit for the fact that we have an audible alarm for that 17 instance or the fact that the lineups are checked during a 18 shift -- every shift. That type of thing.
19 MR. KIESSEL: Simple alignment checks I don't find 20 that much warmth with. The alarm can't even come close and 21 I think that would be a good case -- it is a good item for 22 bringing up on a case by case.
23 MR. MARSH: But keep in mind this is not in terms 24 of the operator itself. It's just a seal or something that 25 is meant to,be a deterrent for somebody going in Heritage Reporting Corporation (202) 628-4888 I - - - - - - - -. I
L-174 1 inadvertently and closing it. It is not in my mind a real l
.2- difficult to put on -- a Limitorque handwheel. It is just a 3 piece of wire with a lead seal ~on it.
4 MR. CONROY: I' agree in that sense but it does 5 pose certain problems in terms of just making it an 6 inconvenience during an outage, for instance, when you have 7 to stroke the valve now and you got to clear that lock and 8 that type of thing.
9 MR. MARSH: It's meant to. That's the point.
10 It's meant'to be a control over mispositioning of the valve.
11 MR. CONROY: But do you feel that we could 12 investigate your taking credit for that alarm in lieu of a 13 lock?
14 MR. MARSH: Does the alarm always have to be 15 available? Is it always there.
16 MR. CONROY: Yes. This is a tech spec requirement 17 to have these valve de-energized.
18 MR. KIESSEL: Well, what about the alarm?
19 MR. CONROY: Well, the alarm -- it's not a tech 20 spec requirement to have the alarm. There's an alarm 21 response procedure naturally that covers anything like that.
I 22 I don't believe there's a tech spec requirement for the 23 alarm to be operable if that's what you mean.
24 MR. JACOBSON: Is it a safety related circuit, the l 25 alarm? .
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ll 175 1 MRi CONROY: Yes.
-2' MR.. MARSH: For the alarm?
3 MR. CONROY: Yes.
4 MR. JACOBSON: 'We'd probably consider'that I would
[ 5 -think'.
6 MR..CONROY: Okay. What about the -- if the
. 7 ' room -- in other words, most of these places that these:
8 valves are in you can't just -- nobody can just walk in.
9 -You either have to-have.an HP entry point, that type-of 10 thing. j 11 bm. JACOBSON: Well, HP is not -- we said'before 112 if the room was locked with a key and it required some 13 special permission to.get into, then that.would be okay.
14 That would be considered acceptable for the mechanical 15 blocking. The valve is inaccessible. There's always 16 exceptions. I mean, you could have a valve that's in a 17 1,000 MREM area that nobody's going to go near, right? And 18 I think that probably would be a good case for not expecting 19 someone to inadvertently operating them. We'll have to look
- 20. at them.
21 MR. KIESSEL: Okay. The final one I have is from 22 Point Beach and it reads, Page 4 a. requires review in 23 document design basis for each MOV. Should this applied to 24 BOP valves? The way the generic letter is constructed right 25 now it's not a strong recommendation to apply to BOP valves.
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l 1 The licensees are encouraged to extend a similar program 1 2 that they would apply to the safety related valves to BOP 3 valves. But, again, we're not going to hold.your feet to 4 the fire if you do not.'To blocked valves? No, blocked 5 valves are not required provided again you have this 6 mechanical and electrical blocking. And then the second 7 part of the question. Can you explain what form / outline you 8 envision for the two year review program.
9 MR. JACOBSON: I think we already talked about 10 that.
11 MR. SCARBROUGH: We're' going to be flexible on 12 that.
13 MR. JACOBSON: Okay. I've got one more question 14 here'from Indian Point New York Power Authority. Okay.
15 This is a long one. Whereas, the INEL test data indicates l 16 that the historical valve factors utilized in MOV sizing 17 calculations may be un-conservative, it is also apparent 18 that use of a .2 co-efficient of friction in the stem factor 19 is ultra conservative. The higher stem factor that will 20 result from a use of a .2 friction co-efficient versus say a 21 .15 friction co-efficient, the stem factor, will ultimately 22 result in a higher design torque requirement. Thus, for 23 those MOV's designed with a friction co-efficient of .2, h
l 24 thrust margin;is- a.vailable which may be able to compensate 25 for a higher than design valve factor. Please comment. I l
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177 1 think our comment there is that it may be that some stem 2 factor assumptions may have been conservative. I don't 3 think we have the data to back that up right now. Now, if 4 that data does become available, certainly that would give 5 you some margin to play with. If you design for an 6 overconservative stem factor you've got some extra margin 7 there. But still it doesn't account for the valve factor.
8 Maybe the stem factor was really .15 and you used .2. We've 9 seen valve factors as high as .5 and .6 where .2 was used.
10 So you're talking of the difference of three to one for the 11 valve factor and maybe 150 or at most two to one for the 12 stem factor. So certainly you get some added margin maybe 13 in using conservative stem factors but I don't think it's 14 enough to compensate for the uncertainties in the valve 15 factor.
16 MR. CONROY: Even in light of the valve factor 17 being limited to the DP component in the thrust whereas the 18 stem factor would apply to the entire ball components making 19 up the thrust.
20 HR. JACOBSON: Well, in many cases the DP 21 component is the majority of the thrust requirement so for 22 high DP valves it maybe the DP component is 90-95% of your 1
l 23 total thrust requirement.
24 _.MR._CONRpY: Okay. Because in the preliminary 25 INEL report- they did indicate that the .2 was -- they felt Heritage Reporting Corporation (202) 628-4888 l
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178 1 that_that was extremely conservative.
2 MR. JACOBSON: Well, I don't know about extremely 3 conservative. I know we -- I've seen some data that show .1 4 to .15 as being a more m'eaningful number which would mean it 5 is-oversized by maybe 130% -- or 30%. But that's not nearly 6 as much as we've seen in variations of valve factor. In any 7 case, if you can justify that, that you used an oversized 8 stem factor that will give you so much added margin to play 9 with. But you're going to have to justify your stem factor 10 and your valve factor. There may be cases where .2 is 11 inadequate for a stem factor. If you got a severely 12 degraded stem or I don't know -- maybe some weird materials 13 out there that .2 isn't even enough. I don't think we've 14 done enough research in that area yet to bound that problem.
15 MR. SCARBROUGH: That was some of the results 16 coming out of the Idaho teste last year was that the stem 17 factor changed below and that may be one of the other 18 additional prime risks that they're looking at right now.
19 But that was one of the considerations. That was addressed 20 at the February meeting with Idaho. The.last question that 21 we have without a name. We'll read it anyway. The generic 22 letter states that MOV operability should be ensured in all 23 safety related fluid systems. How do motor operated dampers 24 in HVAC systems apply?
25 HR. kIESSEL:
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.1 change the rules.
2 MR. SCARBROUGH: I think. I don't have my 3 dictionary here with me but my understanding of fluid, it 4 can be liquid or gaseous". But on the' serious side in terms 5 of dampers. Dampers are in the program. That's what we've 6 been told. When you -- if you have a major problem with 7 meeting the schedule in five years if you include dampers, 8 explain that in your sixth month letter that comes in by 9 justification or a different schedule and that will be 10 considered at that time. But that's our understanding.
11 MR. JACOBSON: I want to just clarify one point 12 that I thought I brought out several times and I had another 13 question during the break and that is that all valves, all 14 safety related valves and position changeable valves that 15 are not blocked out that are in this program, are going to 16 require some form of a test. It may not be full DP but 17 they're all going to have to be tested in some manner.
I 18 just want to make sure everyone understands that because I 19 had another question where someone did.
20 MR. KONTANTINOU: Maybe you could explain why?
21 MR. JACOBSON: Why?
t 22 MR. KONTANTINOU: Yes.
I 23 MR. JACOBSON: Because you need to do the testing 24 for various reasons. One is to establish similarity between 25 the prototype test that you may be taking credit for. The l
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180 1 other is to establish that you've got'the correct limit 2 switch and torque switch settings on-the valve in the plant.
3 There's no way to do that without some type of diagnostic
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4 testing. No way I know of anyway.
5 MR. WOHLD: I've'got a question on the balance of 6 plant systems and valves.
On the definition of safety 7 related and design basis events it goes dLown here to talk 8 about external events and I don't know if you want to shed 9 any light on that today or not but an example that comes to 10 mind is, for instance, is a condensed or water box break 11 that can cause flooding. If you don't stop it it can come 12 into the auxiliary building and damage say shutdown 13 equipment or damage the capability to maintain a shutdown.
14 And I know that in the past a lot of these pipe break 15 studies took credit for non-safety related valves to 16 mitigate the failure of a non-safety related system. This 17 came up in the ACRS meeting sometime.
18 MR. JACOBSON: You're talking about flooding 19 analysis?
20 MR. WOHLD: Basically, and I'm going back ten 21 years or so, is pipe breaks outside containment included 22 both safety related and non-safety related systems. And 23 pipe breaks at that time could be mitigated by non-safety 24 related valves even though they had a safety related 25 implication, So the inclusion of external events in your Beritage Reporting Corporation (202) 628-4888
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181 1 design basis adds.a lot of valves I don't think are 2' recognized.
3 MR. SCARBROUGH: There may be a concern in that 4 area.- The limit of gene'ric letter is only safety related.
5 That's as far as we go at this point and only encourage 6 bale.nce of plant. If it is discovered that there are 7 certain valves that are relied on for some sort of event 8 that aren't in the program, they may be on some sort of 9 enforcement proceeding.
10 MR. JACOBSON: They should be safety related. I 11 don't really understand. If.the valve is being taken credit 12 for in a design basis accident scenario, then that valve 13 should be safety related I would think.
14 MR. WOHLD: In your definitions here safety 15 related refers to anything that's required to handle a 16 certain set of events. And amongst these events down here 17 are external events in natural phenomenon.
18 MR. JACOBSON: Well, those events are only to the 19 extent that they were included in the original design basis.
20 So if there is some other event, then that's what we meant 21 when we said we weren't extending the design basis, is that 22 we were only including those events that were included in 23 the original design basis.
24 ;- MR._ MARSH: But external events, design basis acts 25 is a naturai phenomenon, are covered by the definition of i
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.1 those-design basis events for which these valves and systems
-2 have to function.
3 MR. JACOBSON: I mean there are external events 4 that are in the design b' asis, right.
5 MR. MARSH: I think that's the point. The 6 definition of phenomenon or the definition of design basis 7 events covers not only accidents and transients and Chapter 8 15 analysis, but also covers the external events in natural-9 phenomenon that is covered by the scope of this letter as 10 well.
11 MR. WOHLD: Which does get into balance of plant 12 and "non-safety related valves".
13 MR. MARSH: Well, right now-if there are safety 14 related components that are needed to mitigate the 15 consequences of external events and natural phenomenon, 16 they're covered by a letter. If they're non-safety related 17 components, they're not covered.
18 MR. WOHLD: Okay.
19 HR. MARSH: So we took a cut at the safety related 20 point and I think there were various oscillations when~we 21 went to -- beyond design basis and balance of plant valves, 22 we were pulled back to the safety related compliments alone.
23 So right now as I understand it only to safety related 24 valves.
25 NR. WOHLD:
That's more of a restrictive set i
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183L 1'1 :though than what you've defined here inuthe generic' letter I 2 -think.
.. 3' MR. MARSH: Well, that'sttrue.
4 MR. SCARBROUGH': Well, we were sayingLwhat design 5 basis events are -- are advanced conditions of normal 6- operations including transients, design base act, external U '7 events. So those are what the design basis events are. 'But 8 in-terms of:the MOV's that are within the program-arelthe.
9 ones that are in safety related systems. My understanding.
10 .is'that's what's represented to the NRC management and 11 that's limited the scope of the generic letter.
12 ,
MR. WOHLD: Okay. The example.that comes.to mind 13 -is the. condenser water box break. If you were required to 14 close the circ water discharge valve to prevent further
- 15. flooding in the building --
11 6' MR. SCARBROUGH: Is that a safety related valve 17 though?
18 MR. WOHLD: No.
19 MR. SCARBROUGH: Then it's not included is what 20 we're saying.
21 MR. WOHLD: To me it is included by a definition.
22 MR. MARSH: Was it your understanding that when 23 these went through the ACRS and went through the CHER that 24 plant valves which were required to mitigate external 25 events, flooding events, were to be included in this generic Heritage Reporting Corporation (202) 628-4888 n_
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1 -letter, is that your understanding?
2 MR. WOHLD: That's what I understood.
I 3 MR. MARSH: Okay. We'll seek further j 4 clarification of that bu't right now the letter and as the 5 NRC has constructed and published it, it is confined-to just 6 safety related components that are there to -- as the 7 footnote one says, it is bounded by design basis events 8 described in footnote two. And footnote two says, normal l
9 events including anticipate operational occurrences, design 10 basis accidents, external events and. natural phenomenon. So-11 it means only those safety related components that are 12 needed to mitigate the consequences of two. Footnote two.
13 I don't think the water box discharge valve is covered by 14- that. I don't think it is a safety related component.
15 MR. WOHLD: Okay. Thank you.
16 UNIDENTIFIED: I have a question. Item F. It 17 says each licensee shall make in writing within six months 18 of the date of this letter. What kind of detailed info are 19 you looking for in that writeout? Do I have to give the 20 radius listing and the schedule commitment.
21 MR. JACOBSON: Why don't you answer that, Tom?
22 MR. SCARBROUGH: I didn't quite catch all of the 23 question there but I think what we're looking for is can you 24 meet the five year schedule that's in here -- basically what 25 valves are going to be included?
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185 1 MR. JACOBSON: No. He just has to say if they're
- 2. going-to meet the intent?
3 MR. SCARBROUGH: If you're going to meet the 4; intent, you can'do it with basically one sentence. You're 5 going to meet the schedule. Period. Good bye.
6 UNIDENTIFIED: One page saying that we'll meet all 7 your requirements.
8 MR. KIESSEL: Right. It only gets longer if you 9 say, no, you can't meet the schedule. Then you're going'to 10 have to identify why and when you are and what your 11 alternative schedule is.
12 UNIDENTIFIED: Because what we experienced on the 13 response on the 85-03 bulletin we sent the response to the 14 NRC and they came back that it is inadequate. .
15 MR. KIESSEL: That's right. Because with 85-03 we 16 asked you for a summary of your program. And if we couldn't 17 make any sense out of it you got those kind of questions 18 back. With the generic letter we're not asking you for.the 19 program. We're not asking you for a summary of the program.
20 All we're asking you is for a commitment that you will meet 21 the program and the schedule as outlined above. And if 22 you're not going to meet it, give us the justification and 23 the alternative schedule that you're going to meet and then 24 we'll get.back to you.
25 UNIDENTIFIED: Thanks.
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'l MR. SCARBROUGH: Is that it for the questions? Do 2 we have any more? Sure.- Go ahead.
3 MR. CONROY: I have just a question that is kind 4 of pertaining to the thrust calculations and things like 5 that. The flow path, if you will, that is specified in the 6 generic letter which is basically the same as in 85-03 with 7 respect to how you proceed on this thing, review and 8 document the design basis being the first thing. Establish 9 the correct switch settings. Then go out in the field and 10 set the switches up and test the thing. This type of thing.
l 11 In light of the work that has been done by INEL and KWU 12- obviously we all have a big concern about the original 13 sizing equations. What are we supposed to do where it says, 14 establish the correct switch settings until we know more 15 about these tests? Like each utility is going to end up I'm 16 sure contracting with Limitorque, contracting with DUVAL 17 manufacturer, getting design data, verifying that design 18 data. Part of that verification will be verifying the 19 operator sizing. But you're going to come out with a number 20 -- a thrust number -- and basically that's probably the only 21 switch setting, if you will, that's going to be difficult at 22 best to estimate. What do you recommend as an interim step 23 for that?
24 ;-MR.2JACOBSON: Well, first of all there is nothing 25 in the letter that specifically says you have to do the L
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li things in that order < They all have to be done within five u i
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Okay. Now, if an order'to establish the. switch f 3 settings, you need to do some' prototype testing oriso for
- 4. it, thenfit;would'seem t'o be prudent to do that first. In o 5 order.to establish an accurate thrust number, thrust
'6 . required number, if you're not going to do a full'DP test.on 7 your valve, you're going to have to do some prototype 8' testing or you're going to have to test'the valve-that 1
L 9 .you've got. You know,.you can if you want, you can go ahead 10 and use the calculated number knowing that you may have to 11 change it when you go back and do the full DP test or the.
12 . prototype test.
13 .MR. KIESSEL: Jeff, can I read the words out of 14 the generic letter that answers it. If such test 15 information is not available -- the valves you're talking 16 about'where we've shown that the design equation has got 17 some problems -- and the local methods and extrapolations to 18 design basis condition based on the best data available may 19 be used until test data that design basis conditions become 20 available to verify operability in the MOV. If this two 21 stage approach is followed, it should be accomplished within 22 the schedule outlined in Item I and would allow for MOV 23 testing and surveillance to proceed without excessive delay.
24 In other,words e_giye it your best ahot now if you need it to 25 meet your scheduling requirements and then when the test Heritage Reporting Corporation (202) 628-4888
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i I 188 1 data comeslback'in from the industry testing that supports 2 or identifies that valve, then-unfortunately you're going to 3- hr;ve to go back and make sure that you're at least as f4 conservative.
5 MR. CONROY: Okay. For operators where I have a 6 lot of margin available that doesn't give me a problem. On
- 7. the other hand if.I just go ahead and put a .5 valve factor.
~
8 in some of these equations for a'particular MOV assembly, I 9 .may.end up in the next higher order size operator.
10 MR. JACOBSON:- That's why you need to do the 11 differential pressure testing or the prototype testing on.
12 those, valves. We're really not saying you have to do 13 anything in any certain order. You have to do it all within 14 five years. Now, I think you'd be foolish to wait until the 15 fifth year - you'd be foolish to use a .2 valve factor and 16 set everything up and then in the fifth year hope that 17 you're going to go validate all that information because 10 you're going to wind up changing out a lot of actuators 19 potentially at the end and that's not going to be 20 scceptable. Now, if you have a lot of margin in a 21 particular valve, then it may be you can go ahead and use 22 the .5 valve factor or whatever is the best available data.
23 But the key to it is you're going to have to do the testing 24 or the prototype or whatever is necessary to validate those 25 numbers in a time frame in order to allow everything to be Heritage Reporting Corporation (202) 628-4888
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1- done within five years. j 1
2 MR. KIESSEL: Also, I think we're talking.of a J 3 narrow population of valves. .The INEL test concentrated on 4 some very severe applica' tion valves. The RCW Reactor Water 5 Cleanup System and the indications that we've seen in 6 literature and from some of the other discussions it implied 7' 'that really what you're -- you're running into these i
8 phenomenons when you're starting to talk about closing high ;
9 flow rates particularly if you're starting to get into fluid 10 systems when you're starting to approach two phase or you 11 can get the two phase as you're doing your throttling on the 12 valve. So we've narrowed the population down. On the other 13 valves that are behaving with cold water, the modest 14 pressures across them, a. There should be a lot of data out 15 there available; and b. There shouldn't be any big surprises 16 waiting to bite you. So I think hopefully within that time 17 frame the industry can come together with some programs that 18 can provide you that data. And you can make conservative 19 assumptions until that time.
20 MR. JACOBSON: In the best world what we would 21 have is that a calculated value should be close and you 22 really shouldn't have to change them when you go back and do 23 your testing, however, today we have a lot of uncertainties 24 so you may have to rearrange how you want to approach the problem 6btil Yhe time when we get really good at our 25
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190 1 calculations.
2 MR. KIESSEL: When they get good at their 3 calculations.
4 MR. SCARBROUGH: Any other questions out there?
5 None. Okay, l 6 MR. MARSH: We had a question'just a few moments 7 ago that we may have not quite answered correctly related to 8 the importance of as found information. And we answered 9 that it really was not important and it was only important 10 from the standpoint of trending. I want to clarify that a 11 little bit. I think it is something that really it is 12 obvious to you that is important. As found information is 13 important from the standpoint of deportability from a 50.72 14 and 50.73 standpoint. If you find that a system is not able 15 to perform its safety function then you're into that level 16 of reporting in 50.72 and 50.73. I think the question 17 really came from 85-03 because that asked you to report on 18 the as found condition of valves. This generic letter is 19 different from the bulletin. It doesn't ask for that level 20 of information. So here you would as found information for 21 trending purposes and also for reportable purposes. It was 22 for information that has got to be provided in response to 23 each generic letter.
24 MR. JACOBSON: There was a lot of people I think
' ~ ~
25 that did not report things that should have been reported .
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191 L 1' when they did their 85-03 review and I would. hope that's not L 2 going to be'the case now. If you find out that these--valves 3 'weren't operable due to low torque switch settings or under I
4 size actuators or whatever, you have to do the appropriate 5- reviews to determine whether that's a reportable event or 6 not. Just because it did not fail in the plans does not 7 mean it was not inoperable. I think that's a distinction 8 you need to make.
9 MR. PITTMAN: Excuse me. With that deportability 10 issue we're getting right back to the operability testing
- 11 that if all your operability tests all along have declared 12 it operable and now 89-10 has come in and that's the new 13 yard stick, do I hear you saying that we're taking this new ;
14 yard stick when the problem has never been brought out 15 before and since we haven't been DP testing and you're only 16 going to DP test after you've recalculated your values, 17 readjusted your limit switches and corrected the problem, I 18 don't know what we would be reporting.
19 MR. KIESSEL: Okay. Let's take - give me an 20 example.
21 MR. PITTMAN: What we did is that we wrote 22 deviations against ourselves, plant deviations just to track 23 but did not find reportable events because we were always in i
24 compliance withuwhat the rules were and what the laws were ;
25 at that time.
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192 1 MR. KIESSEL: Okay., In other words -- well,- the 2- tech spec defines operability by you walk in the controlling 3 and' push a button, if it cycles within a certain amount of 4' time,. bingo, you're happ'y, right? Okay. . What happens if 5 you walk out into the plant and you discover that the 6 operator has fallen off the top of the valve but it's 7 still -- now it.is still meeting its stroke time testing 8 because it's matched to lights and you're telling me that's.
9 not a reportable condition because you still met the push 10 button and the lights changed within the proper amount of 11 time. Okay. What I'm getting at is you've gotten 12 additional information. That additional information is 13 beyond what you're using in the tech specs to define 14- operability. But if that information tells you that the 15 valve would not function when called on to perfo.rm its 16 safety function, then you fall in under, that valve is not 17 operable. It would not meet its safety function. It's a 18 one way street.
19 MR. SCARBROUGH: We've got some further 20 clarification here.
l 21 MR. MARTIN: My name is Tom Martin. I'm from 22 Region Three and I'd like to add some clarification to that.
23 It is important here not to mix up your surveillance 24 requirements with these additional testing that would be 1.
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193 1- surveillance test, you're basically saying that that valve 2 is operable. Yes, if it passes those surveillance tests.
3 But you're not saying that system is functional for all
- 4 possible configuration tihat it may be called to operate 5 under. There is an important distinction there. You're 6 not -- that we don't mix up the testing under the generic
-7 letter with the tech spec testing. I agree with what Dick' 8 said as-far as his embellishment on that. But is that 9 clear? I seem to get the feeling that we're -- you feel 10 like we're-adding an additional requirement somehow.
11 MR. PITTMAN: I'm just saying, if you go out there 12 and you count the valves and the strokes, and the strokes
-13 are all lost, use your calculations. We have now reported 14 that this thing was inoperable.
15 MR. JACOBSON: Was?
16 MR. PITTMAN: It wasn't because you got a fudge 17 factor in there that --
18 MR. JACOBSON: Well, you can take that into 19 consideration, okay? But just because it passed a stroke i
20 test does not mean.it's operable from this standpoint. It 21 means it's not inoperable. But you didn't prove the design 22 by the stroke test. If you go out in your plant and now you 23 find out there's a design defect in a component out there ;
24 that may very well not have been made apparent by any type
.- ..=- l 25 of surveillance test.
You may have been doing design basis !
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1 reconstitution or something and found out that the. design 2 was improper which would be the case here and now it's 3 inoperable. That's reportable. It's got to do.with the 4 design. It's not meant'to penalize your for not recognizing 5' that it-was inoperable in the past. Sie understand that you 6 did every. test that --
7 MR. PITTMAN: Well, it's the same if it's operable 1
or inoperable. l 8
9 MR. JACOBSON: Well, if the design calculations 10 show that it would not work, that's all we've got.
11 MR. MARTIN: There's an element of judgment 12 involved in this. It would be close enough so that you 13 cannot say definitively that it was inoperable. You still 14 may take the prudent course of action and replace the valve 15 operator without perhaps --
16 MR. PITTMAN: I accept that analogy. It's the 17 operator's fault. If my va).ve is stroking all along and my 18 plant has run-for ten years that valve that's stroking has 19 performed its functions and all of a sudden I go out because 20 I've got new calculations, a new valve practice and I find 21 out I'm a little bit short.
22 MR. MARSH: We all know that the stroke contest 23 does not demonstrate operability. The stoke contest is just 24 one small measure. It doesn't really demonstrate the valve
' ~
25 was able to pe form a safety function. So we all understand i
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k 195 1l .that. We understand'the tech specs rely upon that. We 21 understand its shortcomings. The clear cases if.you want to 3 do a full differential pressure test and you find the valve 4 doesn'.t stroke, that sho'uld be clear in everyone's mind that
'5l -l valve is inoperable'and it gets reported in that way. The 6 fuzzy point comes.in if you.do'a calculation. And you're 7 not sure if.the valve is operable or not.
8 MR. JACOBSON: I think you're going to have to 9 make a judgment. What we're saying..is you just'can't write 10 it-off.
11 MR. MARSH: What I was trying to say was that as 12 found data is important data and it is to be used for 13 deportability purposes if you make to make that call. And 14 we can't say clearly yes or no.
15 MR. CONROY: Can I just clarify something here.
16 When you say as found data. Now, typically when we're going 17' to out and do our initial base line test on a generic letter 18 valve, we're not going to up'and do the test to-the valve.
l L
19 There's certain things slated to be done on that valve. 1 20 Certain preventive maintenance. Maybe it has a white torque 21 switch that has to be changed out. Maybe you want to go 22 from a two or a four rotor limit switch wiring I
23 configuration. Perhaps it's scheduled for a grease l 24 changeout. Okay. Those things are going to be -- in other l 25 words, w[wanYiobeabletodothosethingsbeforewedo Heritage Reporting Corporation (202) 628-4888
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-- the full flos DP test. Maybe the stem has to be lubed.
2 What I.was talking about when I was talking about as found i
3 before is that we don't have to go out and before we do 4 anything to the assembly, do an as found test.
i 5 MR. MARTIN: No. It's -- the first-point you tell
~
6 me you have sufficient information available I'll tell you 7 that valve is not operable. I'm not saying that you must go 8 out at this point and go to full flow testing. That's the ,
i
.9 part of the program that you have to develop in a five year 1
10 time period.
11 MR. JACOBSON: If during your design basis review 12 though, for instance, you find out that it is grossly 13 undersized by calculation --
14 MR. CONROY: That's a different story.
15 MR. JACOBSON: We're not saying you have to go out 16 and run a whole thing to establish an as found condition in 17 order to make this determination. But in the course of your 18 program, if you run across it, then you have to address it i
19 appropriately.
20 MR. CONROY: ~But just typically realize you will 21 do certain work on the assembly before you go to set up your 22 full flow testing. ,
l l
23 MR. JACOBSON: Sure.
24 _-MR._KIESSEL: I agree. But also there -- very 25 possible thb other case where you don't have to do any major l'
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197 mods.to the valves and you're simply going out'to make sure
~
'1' !
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2 .that it is properly and you discover.that it wasn't set y 3 properly. l 4 MR. CONROY: I don't think on any of our valves a 5 base line test would -- all base line tests would be done 6 after -- you know, for instance, especially with the four 7 rotor limit switch design, you know, after all.that was 8 done, for obvious reasons. It is just the trend to increase 9' the bypass setting.
10 MR. MARSH: Okay. Pete.
11 MR. WOHLD: As far as the reporting requirements 12 go, if it's a maintenance item or something and you go out 13 and test the valve with diagnostics, usually that's done 14 when the plants shut down any way and there is no reporting 15 requirement when you fix it and there is no LCO exceeding.
16 So most of these problems will ever be reported. For a :
i 17 design problem it is a different thing.
18, MR. JACOBSON: You're saying just because the 19 plant is in an outage they don't have to abide by 50.72 or 20 37 21 MR. WOHLD: It's -- what I understand from the 22 reporting requirements, if you go out and find a valve is 23 broken, if you fix it within the LCO --
l 24 MR. JACOBSON: No. It's if it was at any time l
25 whileyohwer operating inoperable, not just at the time l
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198 1 you happen to find it.
2 MR. WOHLD: Well, you declare it inoperable when )
1 3 you find it. l
)
4 MR. MARSH: ThIat too. l 5 MR. JACOBSON: That too. But if you found that 6 for the last five years although you never found this out, 7 the valve was seriously undersized, was not available to 8 perform a safety function, and tomorrow it's going to be 9 fixed, that is reportable to 50.72.
10 MR. WOHLD: I'm not talking about a seriously 11 undersized valve. Let's say it wasn't -- the grease died 12 two weeks earlier. You just found it now. You slap some 13 grease on it, no LCO was violated.
14 MR. JACOBSON: Well, you have to look at the 15 problem and determine if, at any time, that you were 16 operating whether or not this component was inoperable due 17 to the problem that you discovered.
18 MR. WOHLD: I don't think the evaluation is that 19 sophisticated normally.
20 MR. JACOBSON: Well, yeah. In the case of the 21 grease I think we're going a little too far. But certainly 22 if you find a major problem during an outage, just because 23 you're in an outage doesn't mean it's not reportable.
24 MR. MARTIN: I'd like to clarify something too on 25 the reportabil hy.~ We're not saying here that if you find Heritage Reporting Corporation (202) 628-4888 l
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1 that your torque switch should have been set at 3 or 2 1/2 2 and it was originally set at-2, that you should j 3 automatically report that as the valve not being functional.
4 I think in one of those cases there is going to be some very 5 close calls that you want to get a little conservative 6 posture as far as your valve being capable of performing its 7 intended function. But however, when you know that there's 8 a significant measure of increase that you have to apply the 9 valve by changing the operator or the valve is significantly 10 undersized or you feel confident that it would not have 11 performed its intended function, then that's a different 12 ball game. We'd like to know about that. I think that we i 13 expect to see a few of those things as part of this program.
14 And we -- otherwise, you know, we -- this effort may not 15 have been -- may not have even been necessary. I don't 16 know. But we're not looking for the stuff in the grass.
17 We're looking at the fairly significant issues that appear 18 to be beyond the just the minor adjustment in the torque 19 switch setting.
20 MR. MARSH: That's fine. Thanks Tom. I think 21 we've run the course. I think we've worn each other out.
22 It's a draw. Thank you very much for your attendance. I 23 think it's been useful. Stay tuned for the meeting minutes 24 and you shouldzall.-- please make sure that you have signed 25 in the back- too. Make sure that we have your name and Heritage Reporting Corporation (202) 628-4888
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address. :Thank you~.
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1 2- - (Whereuponi . the _ hearing concluded at 5 :10. p.'m. ) -
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Heritage Reporting Corporation "
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.y 1-- REPORTER'S CERTIFICATE
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2-Eo 3 DOCKET NUMBER:
, 6 9- 4- CASE' TITLE: WORKSHOP ON GENERIC LETTER 89-10 5 HEARING DATE: September.18, 1989 6 LOCATION: Chicago,-Illinois 7
8 I hereby certify that the proceedings and evidence.
9 are contained fully and accurately on the tapes and notes 10 reported by me at the hearing in the above case before the 11 . United States Nuclear Regulatory Commission.
12 i 13 Date: /g[fy 14 l ': < 15 16 I!
(/ 0 17 Official Reporter ACME REPORTING COMPANY, INC.
18 1220 L Street, N.W.
Washington, D.C. 20005 19 l ~.
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GENERIC LETTER 89-10 SAFETY-RELATED MOTOR-OPERATED VALVE TESTING AND SURVEILLANCE l
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f BACKGROUND 6/9/85 - ppy;S~BESSE EVENT a
11/15/85 - BULLETIN 85-03 04/27/88 - SUPPLEMENT 1 TO BULLETIll 85-03 l
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, SUPPORT FOR EXPANSION 0F BULLETIN 85-03
' RESPONSES TO 85-03 REVEALED MORE:MOVs THAN EXPECTED WOULD NOT.0PERATE. UNDER DESIGN BASIS CONDITIONS? AND' ADDITIONAL MOV, DEFICIENCIES.
LNUREG/CR-5140, "VALUE-IMPACT ANALYSIS FOR EXTENSION-0F
- NRC-BULLETIN 85-03 TO COVER ALL SAFETY-RELATED MOVs."
II FULL-SCALE-BLOWDOWN TEST RESULTS PERFORMED AS PART OF
. GENERIC ISSUE-87 ,
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SCOPE OF MOV GENERIC LETTER SAFETY-RELATED MOVS POSITION-CHANGEABLE MOVs (1.E. ANY MOV IN A SAFETY-RELATED SYSTEM THAT IS NOT BLOCKED FROM INADVERTENT OPERATION FROM CONTROL ROOM, MOTOR CONTROL CENTER, OR THE VALVE ITSELF) e N
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SUhMARY-0F GENERIC LETTER POSITIONS REVIEW..AND' DOCUMENT DESIGN BASIS FOR MOV OPERATION ESTABLISH AND IMPLEMENT PROGRAM TO REVIEW AND REVISE METHODS FOR SELECTING AND SETTING SWITCHES DEMONSTRATE MOV OPERABLE BY TESTING AT DESIGN BASIS DIFFERENTIAL PRESSURE AND/0R FLOW DOCUMENT WHERE DESIGN BASIS TESTING CANNOT BE PERFORMED WITH DESCRIPTION OF ALTERNATIVE TESTING PREPARE PROCEDURES TO ENSURE THAT CORRECT SWITCH SETTINGS ARE DETERMINED AND MAINTAINED ANALYZE AND DOCUMENT MOV FAILURES AND CORRECTIVE ACTION
- PERIODICALLY EXAMINE MOV DATA (EVERY 2 YEARS) FOR TRENDS
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~ GENERIC LETTER SCHEDULE PROGRAM' DESCRIPTION AND SCHEDULE 0L: WITHIN 1 YEAR OR 1 REFUELING OUTAGE, WHICHEVER
'IS LATER cpi WITHIN 1 YEAR OR BEFORE OL IS' ISSUED, WHICHEVER
'IS LATER.
ACCOMPLISH' INITIAL PROGRAM OL: WITHIN 5 YEARS OR 3 REFUELING OUTAGES, WHICHEVER
,IS LATER.
CP: .WITHIN.5 YEARS OR BEFORE OL IS ISSUED, WHICHEVER IS LATER
> m- VERIFY SWITCH SETTINGS EVERY 5' YEARS
.0R 3 REFUELING OUTAGES, WHICHEVER IS LATER REPORTING REQUIREMENTS ADVISE NRC WITHIN 6 MONTHS THAT GENERIC LETTER WILL BE MET OR ANY MODIFICATIONS
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NOTIFY NRC 0F CHANGES TO COMMITMENTS NOTIFY NRC WITRfN 30 DAYS AFTER INITIAL 5-YEAR ,
PROGRAM ACCOMPLISHED 1
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I NRC ACTION TO SUPPORT MOV GENERIC LETTER i
WORKSHOPS TECHNICAL GUIDANCE TO NRC STAFF AUDITS OF PROGRAM DESCRIPTIONS AUDITS AND INSPECTIONS OF PROGRAM IMPLEMENTATION REVIEW 0F INDUSTRY TESTING a
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BEYOND GENERIC. LETTER 89-10 h
RULE' CHANGE -(10 CFR.;50.55A) a -- .
IMPROVEMENT 0FLISTTCRITERIA m: - REGULATORY GUIDE (s) ON IST DESIGN AND QUALIFICATION OF:MOVs THERMAL OVERLOAD PROTECTION a
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