ML20083N425

Comment on Proposed GL Re Pressure Locking & Thermal Binding of safety-related power-operated Gate Valves

ML20083N425
Person / Time
Site:	Brunswick, Robinson
Issue date:	04/27/1995
From:	Rogan R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR15799 60FR15799-00011, 60FR15799-11, NUDOCS 9505230079
Download: ML20083N425 (2)

Text

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CP&L l

Corolino Power & Light Company l PO Box 1551 c All Foyetteville Street Mall l

• Raleigh NC 27602 $ }'2 )

April 27,1995 5 "2

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File: X-X-1107 Serial: NL& RAS-y-Ofb

.N N Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission I\OO$

Washington, DC 20555 ggggc

Dear Sir:

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Subject:

Comments on Draft Generic Letter on Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves (60 FR 15799, March 27, 1995)

The enclosed comments on the subject draft Generic Letter are submitted on behalf of Carolina Power & Light Company (CP&L).

CP&L believes that the timetables proposed in the draft Generic Letter are unrealistic and will not allow licensees to perform effectively the actions requested. The 60-day period allotted to perform the requested evaluation of all safety-related power-operated gate valves should be extended at least six months, and the 180-day period programmed for taking corrective action should be extended to at least one refueling cycle after completing the evaluation to allow the performance of corrective actions during scheduled shutdowns.

A more detailed discussion of our position is provided in the enclosure.

Sincerely, J

l R. E. Rogan Manager Nuclear Licensing and Regulatory Affairs FAE/jbw Enclosure c: Mr. C. Calloway (NEI)

Mr. W. R. Campbell Mr. H. W. Habermeyer, Jr.

Mr. K. R. Jury Mr. J. C. Presley Mr. L. S. Rowell 9505230079 950427 I PDR I&E MISC PDR l (n:\nsd\nis\nria\2362nria) 2003e

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COMMENTS ON DRAFT GENERIC LETTER PRESSURE IDCKING AND THERMALBINDING OF SAFETY-RELATED POWER-OPERATEDGATE VALVES

1. Sixty (60) days is viewed as an extremely short period of time in which to do a

" preliminary" evaluation of all power-operated gate valves, since there are likely to be in excess of 100 such valves at a nuclear plant. This is especially true if the pressure locking and thermal binding phenomena have not been encountered during routine operation or surveillance testing. Six(6) months is proposed as a more reasonable time frame in which to complete this review. Guidance provided in Generic Letter 91-18 should be utilized during operability determinations when required. The basis for this position is that appropriate operating procedures and surveillance requirements presently exist and provide an adequate confidence level in safety-related valves.

Unsatisfactory results would dictate appropriate actions and steps to be taken.

2. One hundred eighty (180) days is a relatively short period of time to implement corrective actions because it does not take into account the possible need for plant shutdowns to facilitate necessary modifications. If shutdowns are required, it is better to utilize planned refueling outages to effect the needed corrective actions. It is recommended that at least one (1) refueling cycle after completion of the evaluation be permitted to plan and implement appropriate corrective actions, l

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