ML20211P177

Advises That Review of Util 861017 Response to IE Bulletin 85-003, Motor-Operated Valve ..., Incorporating Recipient Generic Program,Indicated Need for Addl Info.Nrc Comments Encl for Preparation of Revised Submittal Via Util

ML20211P177
Person / Time
Site:	Callaway
Issue date:	02/19/1987
From:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Charbonneau A MOVATS, INC.
References
IEB-85-003, IEB-85-3, NUDOCS 8703020309
Download: ML20211P177 (4)

Text

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FEB 101987 A. G. Charbonneau, President M0 VATS Incorporated 2995 Johnson Ferry Road Marietta, Georgia 30062

Dear Mr. Charbonneau:

My staff has recently completed its review of Union Electric Company's October 17, 1986, response to IE Bulletin 85-03, " Motor-0perated Valve Comon Mode Failures During Plant Transients Due to Improper Switch Settings," for the Callaway Plant. As you know, this response contained your generic program for satisfying the requirements of the bulletin.

The review of this response indicates the need for additional information before the program to assure motor-operated valve operability can be approved. j The specific coments have been forwarded to Union Electric Company via the appropriate NRC regional office. In addition, in the interest of expediting resubmittal of the plan, which has potentially generic implications to a number of other facilities, a copy of these comments is enclosed for your considera-tion in preparing your revised submittal via Union Electric Company. 4 Sincerely, i

bright %s.3 syr e Q krdan Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement

Enclosure:

As Stated Distribution:

JMTaylor, IE RWStarostecki, IE ELJordan, IE SASchwartz, IE l RLBaer, IE AWDromerick, RJKiessel, IE JGPartlow, IE BKGrimes, IE JAAxelrad, IE EWMerschoff, IE FCCherny, NRR HABailey, IE 00Rothberg, NRR PRWohld, RII TKoshy, RI SARichards, RV GASchnebli, RII TFWesterman, RIV PDR EDCSLid DEPER R/F EGCB R/F RJKiessel, R/F DEPER:IE 1:IE D E IE DD:DEPER:IE D- R:IE RJKiessel:bt romerick RLBaer SASchwartz ELJ rdan 02/g/87 81/g/87 g1/f/87 OJ/ /87 OWg/87 O

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3 REQUEST FOR ADDITIONAL INFORMATION (RAI) RE:

Review of Responses to Action Item e of IE Bulletin 85-03 Licensee: Union Electric Company Unit: Callaway 1 1901 Gratiot Street Date of Response: 5-19-86 St. Louis, Missouri 9-19-86 10-17-86 Respondent:

Donald F. Schnell Vice President, Nuclear The information provided in your responses to Action Item e of IE Bulletin 85-03 was found to be deficient in some areas. Please provide the additional information requested by the following questions:

1. How is the calculated delta P load listed in Table 2 of Attachment B of your response of 10-17-86 added to the stem thrust signature without delta P in order to obtain the unseating thrust for a given valve?

In particular, if a constant delta P load is used, at what point of the signature without delta P is the delta P adder applied in order to determine the value of unseating thrust (Tu)?

Note: Please refer to the sketch on the last page for clarification of Question 1. . -

2. Is Valve 27 of Table 2 of Attachment B of your response of 10-17-86 .

meant to have a Size 1 operator? It appears to be grouped incor-rectly with Size 00 operators.

3. Why are valves HV-5, -7, -9 and -11 of the AFW System excluded from the list of valves for which bulletin actions are required, particu-larly in view of the observations that they are safety-related MOVs and that they could be left closed inadvertently?

Per Page 1 of Enclosure 2 of your response of 10-17-86, these valves are taken to be exceptions to the WOG methodology because they are used for flow control purposes at Callaway. The possible problem that the system would be inoperable if these MOVs were left closed inadvertently should be addressed.

4. Is valve stem drag caused by the packing checked in accordance with maintenance procedures?

5. Is data available to justify the following statement at the bottom of Page 4 of Enclosure 2 of your response of 10-17-867 "Since cracking thrust peak does not occur on the closing cycle, actuator thrust capacity will not be exceeding during this initial phase of valve travel in the closed direction and need not to be tested for this capability."

The following items should be addressed in considering the validity of the foregoing statement:

a) Has the effect of different torque switch settings for opening and closing been taken into account?

b) Has the effect of the torque switch bypass settings for opening been taken into account?

c) Has the effect of end pressure on the valve stem (piston effect) been considered?

6. A continuing program for flow and pressure testing of at least some motor operated valves is needed in order to provide assurance that the methodology and empirical formulas, as outlined, are acceptable.

This program should be explicitly outlined by M0 VATS Inc. The lack of test data to support the MOVATS empirical formula concerning closure against flow is of particular concern.

7. Recommendations should be made by MOVATS regarding the frequency for each test or verification. If the M0 VATS recommended schedule is not followed by a licensee, an explanation should be provided. Any conflicts with ASME Section XI testing should be addressed.

8. In Table 2 of Attachment B to the October 17, 1986 letter from Union Electric Co. the notation "NC" is undefined. Also, an explanation should be provided for blank entries. It is also noted that several actual values are very close to calculated. Since the MOVATS formu-las include a factor which, in the NRC discussions with M0 VATS, was represented as being quite conservative, the closeness of the values should be explained.

9. On page 4 of Attachment B to the October 17, 1986 Union Electric Co.

submittal, the formula for thrust against flow includes a differen-tial pressure term. The precise definition of what is meant by differential pressure should be explained because differential pressure will vary until the valve closes.

10. A plot which compares actual vs. computed thrusts for gate valves in the open direction is included in Attachment B to the October 17, 1986 Union Electric Co. submittal. No plot was submitted for the close direction. This should be explained or the plot should be furnished.

11. The method used to arrive at the empirical formulas, including each of the numerical factors would be explained in detail.

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