ML17261A634

Forwards Addl Response to IE Bulletin 85-003.Program Compliance W/Bulletin Patterned After Callaway Program & Methodology & Equipment of Movats,Inc Used

ML17261A634
Person / Time
Site:	Ginna
Issue date:	10/09/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
IEB-85-003, IEB-85-3, NUDOCS 8710160070
Download: ML17261A634 (7)

Text

REGULATORY 'RMATION DISTRIBUTION SYS,"I (RlDS)

ACCESSION NBR: 8710160070 DOC. DATE: 87/10/O'P NOTARIZED: NO DOCKET FACIL 50244 Robert Emmet Ginna Nuclear Planti Unit ii Rochesuer G 05000244 AUTH. NAME AUTHOR AFFILIATION KOBERi R. W. Rochester Gas 8c Electr ic Corp.

REC IP. NAME REC IP IENT AFFILIATION KANE> W. F. Region ii Of fice of Director

SUBJECT:

Forwards addi response to IE Bulletin 85-003. Program to comply w/bulletin patterned after Callawag program uses 8c methodology 5 equipment of MOVATSi Inc.

DISTRIBUTION CODE: IE11D COPIEB RECEIVED: LTR ENCL SIZE:

TITLE: Bulletin Response (50 DKT)

NOTES: License Exp date in accordance with 10CFR2i 2. 109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 L* 0 PD1-3 PD 1 BTAHLE) C 1 1 INTERNAL: AEOD/DOA AEOD/D'SP AEOD/DSP/TPAB 1 NRR/DEBT/ADE 1 1 NRR/DEST/ADS NRR/DEBT/MEB 1 NRR/DOEA/EAB .1 NRR/DOEA/GCB 1 1

.RRJDRE EPB 1 1 NRR/PMAB/ ILRB 1 EQ EIL- 02 REB/DE/EIB 1 1 RGN1 FILE 01 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NBIC 1 TOTAL NUMBER OF COP IEB REQUIRED: LTTR 19 ENCL 18

ROCHESTER GAS AND El ECTRIC CORPORATION 8S EAST AVENUE,, ROCHESTE. t, N.Y. 1464g.00P1 ROGER W, KOBER IKL CP<OsC VKK PRKSIDK.'4T 546.2700 KLKCTRICPAODVCTIOR

~ (~ CaaK )ie October 9, 1987 Mr. William F. Kane, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

Request for Additional Information IEB-85-03 "Motor Operated Valve..."

dated November 15, 1985 R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Kane:

Your letter dated September 9, 1987 which was received on September 14, 1987 requested additional information concerning our IEB-85-03 response within 30 days. Attached is our response to your request.

In reviewing our response you will note that the Rochester Gas and Electric program to comply with IEB 85-03 is patterned after the Callaway program and uses the methodology and equipment of MOVATS, Inc. Testing the IEB 85-03 valves will begin soon.

Please inform us if you have any concerns with this approach to satisfying the IEB 85-03 requirements.

Ver truly yours, Roger W. Kober Attachment xc: U.S. NRC Document Control Desk j (original)

Resident Inspector Og60070 875000@

PDR ADOCK 0 o PDR Q

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ATTACHMENT REQUEST FOR ADDITIONAL INFORMATION IE BULLETIN 85-03 NRC Re uest MOVs 826A, 826B, 826C and 826D are shown normally closed in two parallel suction lines leading from the boric acid tanks of the SI System, in Zone G-2 of Drawing 33013-1262, Revision

3. Referring to Table 1 of the response of 05-14-86, note that one of these valves per path is normally open. Please address this apparent discrepancy between the PAID and the response.

~Res onse The purpose of the PaID was to provide the reader with a one line drawing of the system that illustrated the valves, pumps, and piping associated with the system. The revision level of the P&ID provided did not contain information associated with normal valve position. Therefore, the PGIDs provided cannot be used to verify valve position listed in Table 1. Since that time, the PaIDs have been revised to illustrate normal valve position at power. Copies of the revised P6IDs can be provided upon request.

NRC Re uest

2. Has water hammer due to valve closure been considered in the determination of pressure differentials? If not, please explain.

~Res onse The effect of water hammer has not been considered in the determination of valve closure pressure differentials.

Consistent with the Westinghouse Owners Group position (WOG letter OG-87-21, 'dated April 15, 1987 on "Westinghouse Owners Group Safety Related MOV Program Final Report, IE Bulletin 85-03 NRC Comments" ). The conditions necessary to cause steam void class water hammer are considered highly unlikely to exist in the fluid systems impacted by IEB 85-03.

Therefore, water hammer and its possible effects on the determination of maximum fluid differential pressures was not explicitly addressed in the RGaE 180 Day Response to IEB 85-03. In -addition, the effects oi water hammer occur over a very brief period of, time. Superimposing the event requiring actuation of safeguards equipment with the effects of a postu-lated water hammer (in effect assuming both maximum pressures and minimum pressure eifects simultaneously) is unnecessarily restrictive in determining valve switch settings and may lead to settings that could impair valve operability during ndrmal operation. Therefore, it is RG&E's position that this issue need .not be addressed within the context of IE Bulletin 85-03.

Re uest I

3. In addition to resolving the preceding domments, please expand the proposed program for, action items bg c, and d to include the iollowing details as a mi'nimum:

(a) commitment to a tra'ining program for setting switches, maintaining valve operators, using test equipment and interpreting test results, (b) commitment to justify continued operation of a valve determined to be inoperable, and (c) description of a method possibly needed to extrapolate valve stem thrust determined by testing at less than maximum differential pressure.

~Res onse 3a ~ The MOVATS methodology and equipment will be used to ensure operability of the IEB 85-03 Safety-Related Motor Operated Valves. A group of RGaE individuals has been trained by MOVATS in the use of test equipment and interpretation of test results. Individuals have also been trained by LIMITORQUE in maintaining valve operators. A Safety-Related Motor Operated Valve Program patterned after the Callaway program has been developed to provide guidance for switch settings. Initially, the test team will perform under the observ'ation of MOVATS personnel. As more experience and confidence is developed by the RGt'E team, the participation of MOVATS personnel will be reduced to the role of a consultant. The test team retraining will be part of the maintenance training program.

3b. The MOVATS methodology'nd equipment will be used to assess the condition of the designated valves. The Ginna Test Procedures contain a list of degradations that, if found, may result in declaring the valve inoperable until corrected.

If a valve is declared to be inoperable, the limiting condi-tions described in the Ginna Technical Specifications will be applied.

3c The MOVATS methodology will be used to determine the proper

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switch settings for the MOVs. When tests are done at less than maximum difierential pressure, the stem thrust due to the differential pressure will be measured for two partial pressure points. The stem thrust at the maximum differential pressure point will be extrapolated using a linear interpola-tion between the zero point and the test points. This thrust will be added to .the running load to determine .the total thrust at maximum differential pressure. The total thrust will be increased by the appropriate MOVATS measurement uncertainty factor and the MOV switches set accordingly.

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