View source for JPN-97-011, Provides 180 Day Response to GL 96-05, Periodic Verification of Design Basis Capability of Safety Related Movs

{{Adams
| number = ML20137A547
| issue date = 03/17/1997
| title = Provides 180 Day Response to GL 96-05, Periodic Verification of Design Basis Capability of Safety Related Movs
| author name = Knubel J
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000333
| license number = 
| contact person = 
| document report number = GL-96-05, GL-96-5, JPN-97-011, JPN-97-11, NUDOCS 9703200368
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 6
}}

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    #> NewYorkPower                                                                              2"L"1"L-4# Authority                                                                                 c*""- o"-
March 17,1997 JPN-97-011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

==Subject:==
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 180 Day Response to Generic Letter 96-05: Periodic Verification of Design-Baala_ Capability of Safety-RelateiMotor-Oprated_ Valves

==References:==
: 1. NRC Generic Letter 96-05, T. T. Martin, NRC to Operating Ucensees,
                               " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," dated September 18,1996.
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: 2. BWR Owners' Group Licensing Topical Report, NEDC-32719, "BWR                      l Owners' Group Program on Motor-Operated Valve (MOV) Periodic                    I Verification," dated March 1997.

==Dear Sir,==

This letter provides the 180 day response requested by Generic Letter 96-05 (Reference 1). The letter requested licensees to submit a summary description of their Motor-Operated Valve (MOV) Periodic Verification program.
The Authority is participating in the joint Westinghouse and BWR Owners Group (JOG) to develop a MOV Periodic Verification program for NRC review / approval. A Ucensing Topical Report describing sach a program (Reference 2) was submitted to the NRC on March 7,1997.                l The Authority plans to implement a MOV Periodic Verification (PV) program for the FitzPatrick           l plant as described in this report. This program will supersede the current FitzPatrick MOV PV           I program that was developed in response to Generic Letter 89-10. A summary description of the new program is provided in Attachment 1.
The static testing portion of the program will commence during the next refueling outage (RFO 13 - estimated to start late 1998) for high risk / low margin safety-related MOVs.
MOVs will be subject to static testing at intervals of one to six cycles (not to exceed 10 years) based on the test criteria presented in the Topical Report. As permitted in the Topical Report, the safety significance ranking needed to detemiine static testing frequency for the FitzPatrick MOVs will be based on plant specific criteria and the results of the Individual Plant Examination. The dynamic testing portion of the program will be developed in conjunction with other utilities. The schedule for dynamic MOV testing at the FitzPatrick plant will be             i submitted to the NRC prior to the start of the next refueling outage.
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The commitments made by the Authority in this letter are listed in Attachment 2. If you have any questions, please contact Ms. C. D. Faison.
Very truly yours, 1
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                                                                      /                              i J. Knubel                             l Senior Vice President &
Chief Nuclear Officer STATE OF NEW YORK COUNTY OF WESTCHESTER Subscribed and sworn to before me                                                               !
this/7 4 day of /KAto4,         1997.
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Attachments: as stated                                                                          ;
1 cc:     Regional Administrator                                                                  I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Ms. Karen Cotton, Acting Project Manager Project Directorate 1-1 Division of Reactor Projects-l/II U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 Office of the Resident Inspector U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093

l a      .                                    Attachment 1 to JPN-97-011 Motor-Operated Valve Periodic Verification Program Summary Description i
~
James A. FitzPatrick Nuclear Power Plant
(                                                                                                                         l
                                                                                                                           )
i This summary description of the proposed FitzPatrick Motor-Operated Valve (MOV)
Periodic Verification Program is consistent with the BWR Owners' Group (BWROG) Ucensing Topical Report (Reference 1) that describes the program developed by the joint Westinghouse and BWR Owners' Group. The FitzPatrick MOV Periodic Verification (FV) Program may be revised to reflect Owners' Group changes to the referenced Topical Report and/or further j                   guidance from the NRC. The current PV program, which will be superseded with the new PV program, is also described below.                                                                      l
,                            The program is intended to verify on a periodic basis that safety-related MOVs j                   continue to be capab!e of performing their safety functions within the current licensing bases of the facility. ine valves covered by this program are consistent with the Generic Letter 89-10 scope of valves. The program addresses potential degradation that can result in (1) the increase in thrust or torque requirements to operate the valves, and (2) the decrease in the output capability of the motor actuator. Plant procedures will be developed to control the MOV PV Program. The three basic elements of the proposed PV Program are as follows:
i e        Interim Static Test Program
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* Dynamic Test Program
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* Test Data Evaluation, Analysis & Resolution Interim Static Test Program The objective of this program is to ensure MOV setups remain consistent with the Generic Letter 89-10 criteria while providing additional margin for valve degradation that may occur during the five year period in which the Joint Owners' Group (JOG) PV dynamic test program is being performed. The interim Program involves static testing (no flow or dP in the pipeline) of MOVs on a frequency based on safety significance and functional capability.
The safety significance is determined using plant specific criteria and the results of the individual Plant Examination. An expert panel review, that includes consideration of deterministic insights, will be performed for the plant specific MOV rankings to assure that an acceptable frequency of testing is established for the least risk-significant valves. The results of this review will_ be incorporated into the FitzPatrick MOV PV program prior to the start of the next refueling outage.
The functional capability is based on valve margin (difference oetween available thrust or torque capable of being delivered by the actuator and the required thrust or torque demanded by the valve under design basis conditions). The available actuator output, and required

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Attachment 1 JPN-97-011 Page 2 of 3 valve, thrust and torque are adjusted as needed for several factors that incWe test equipment inaccuracy, torque switch repeatability, rate-of-loading, spring pack relaxation, stem lubricant degradation, and seat degradation. The MOV static test frequency criteria is presented in the following table.
MOV Static Test Frequency Criteria Risk Category                         Low Margin         Medium Margin                                High margin MOVs              MOVs                                         MOVs High Risk                             1 Cycle           2 Cycles                                     3 Cycles Medium Risk                             2 Cycles            4 Cycles                                    6 Cycles
* 4 Low Risk                           3 Cycies           6 Cycles
* 6 Cycles *
* Not to exceed 10 years.
Where:            Low Margin < 5%
Medium Margin a 5% to < 10%
High Margin 210%
The risk and margin criteria used in the above table are preliminary and are based on judgement and experience developed from the GL 89-10 programs. The justification of the specific margin categories is to be confirmed in the JOG PV dynamic test program described below. Accordingly, the program approach is considered " interim" until confirmation is achieved.
JOG PV Dynamic Test Program The objective of this program is to determine degradation-related trends in the differential pressure (dP) thrust and torque under a range of operating conditions, and to use the results of this testing to adjust the interim PV program if warranted. A JOG Committee will select the valve candidates for dynamic testing (flow and dP in the pipeline) based on the potential MOV degradation mechanisms and a valve mix that is representative of the different valve types, manufacturers, sizes, orientation, dP stroke history, environment, materials, and fluid parameters. The dynamic testing is planned to be completed within five years of its initiation.

Attachment 1 JPN-97-011 Page 3 of 3 Three tests of each valve candidate will be planned during the five year program (three consecutive refuel outages). The dynamic tests will be performed by the utilities participating in the program in accordance with a JOG developed test specification listing the pertinent requirements. FitzPatrick is participating in this program, and a description of the valves and test schedule will be submitted to the NRC prior to the start of the next refueling outage.
Sharing of industry resources through the JOG PV Program permits a larger population of valves and potential degradation conditions to be covered which should provide better insights into the degradation mechanisms. The joint program also ensures a uniform approach which recognizes the lessons leamed from across the industry.
Test Data Evaluation. Analysis. and Resolution The test results will be evaluated after each test by the Authority and shared with the Owners    ;
Group committees (BWROG PV Steering Committee and WOG PV Core Group). If                          l degradation / anomalies are found, the testing utility will determine the root cause/ degradation rate and make a judgment if corrective action is warranted. The test results will be applied to the group of valves it represents as deemed appropriate.
As described in Reference 1, when the information received by the Owners Group committees         !
indicates that a potential large degradation rate has been observed for a valve or class of valves, the committees will make a decision if immediate further evaluation or modification of the program or interim criteria is required. If action is determined to be needed, the            ;
committees will communicate this information to the Authority. Additionally, the Owners Group     j committees will perform the same assessment on an annual basis of all data received.
At the conclusion of the dynamic test program phase (5 years), the Owners Group committees will determine the final program criteria based on their evaluation of data throughout the 5 year program.
Current PV Proaram The current MOV PV program, as described in Reference 2, includes (1) the re-verification of switch setting adequacy every third refuel outage, (2) as-found and baseline VOTES testing to support stem coefficient of friction assumptions and stem cleaning / lubrication preventive maintenance frequencies, and (3) periodic dynamic test verification on a frequency based on the valve risk / margin criteria. Portions of this program were performed during the last FitzPatrick refuel outage (RFO 12). This program will be superseded by the program described above, effective with the next refuel outage (RFO 13).
References
: 1. BWR Owners' Group Licensing Topical Report, NEDC-32719, "BWR Owners' Group Program on Motor-Operated (MOV) Periodic Verification," dated March 1997.
: 2. James A. FitzPatrick Nuclear Power Plant Generic Letter 89-10 Motor-Operated Valve Program Plan, JAF-RPT-MULTI-00746, Rev.11, October 31,1995.
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Attachment 2 to JPN-97-011 Summary of Commitments Number                      Commitments                           Due Dates JPN-97-011-01 Implement a MOV Periodic Verification        Valve testing in accordance program in accordance with BWR Owners'       with new program will Group Ucensing Topical Report, NEDC-         commence during RFO 13.
32719, dated March 1997.
JPN-97-011-02 Perform an expert panel determinisite review Prior to start of RFO 13.
of the plant specific MOV rankings and incorporate results into the MOV PV program.
JPN-97-011 03 Submit a schedule for performing the         Prior to start of RFO 13.
dynamic valve testing associated with the MOV PV program.
JPN-97-011-04 Develop plant procedures to control the new  Prior to start of RFO 13.
MOV PV program.
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