ML19347F477

Further Answer to Ucs 810303 Motion That Record Be Reopened to Consider Power Operated Relief Valve Block Valve Test Results.Motion Irrelevant to Disposition of Ucs Contention 5.Certificate of Svc Encl

ML19347F477
Person / Time
Site:	Three Mile Island
Issue date:	05/11/1981
From:	Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19347F473	List: ML19347F472 ML19347F477
References
NUDOCS 8105190356
Download: ML19347F477 (11)

Text

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gj

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% 9 In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S FURTHER ANSWER TO THE UNION OF '

CONCERNED SCIENTISTS' MOTION FOR BOARD ORDER ON BLOCK VALVE TEST RESULTS On March 3, 1981, UCS filed a motion for a Board order to reopen the record to consider PORV block valve test results. The motion was opposed by Licensee and the NRC Staff in written answers, supported by affidavits, filed on March 13 and 23, 1981, respectively. Licensee amended its answer on April 9, 1981. On April 22, 1981, at the invitation of the Board, UCS filed " Union of Concerned Scientist's Reply to Met Ed and Staff Submissions on Valve Testing" including the Affidavit of Robert D. Pollard.

Licensee herein submits its further response to the UCS motion, with the Boe.rd's leava. Tr. 20,304.

While the debate over the UCS motion to a great extent has degenerated into a factual dispute ever the similarities and dissimilarities between the TMI-1 block valve and those tested to date by EPRI, Licensce believes it is essential for the Board to assess the UCS motion in the context of the issues which the Board must decide.

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l First, it is clear that the motion has no relevance for the Board's resolution of UCS Contention No. 5. That con-tention asserts that the PORV and the block valve should be classified as equipment important to safety and required to meet safety-grade design criteria. Licensee and the Staff have both taken the position, in testimony already in the record, that the PORV and its block valve were not designed

o fulfill a safety function and are not required to mitigate s

design basis loss-of-coolant accidents, so that the PORV and block valve are not components important to safety. Correa et al., ff. Tr. 8746; Jensen, ff. Tr. 8821. UCS has presented testimony in support of its contention. Pollard, ff. 9027.

This contention involves a dispute over the purposes and functions of the PORV and block valve, and the resultant design criteria which should be applied. It is not a dispute about the current performance characteristics and capabilities of the TMI-l PORV block valve.

UCS Contention No. 6 was abandoned by the Union of Concerned Scientists on Jul*. 31, 1980. The Board subsequently decided to retain and pursue on its own the issues raised in the contention. Consequently, an evidentiary record was compiled on the issue of qualification testing for " reactor coolant system relief and safety valves" only because the Board, in'its discretion, elected to explore the subject.

UCS presented no direct testimony on the contention retained I

by the Board.

_3 In response to Board Question UCS-6, Licensee and the Staff presented testimony describing the EPRI program plan for the performance testing of PWR safety and relief valves, and Licensee's participation in the program. The witnesses also described why, given the design and operational experience of these valves as well as the consequences of failure (i.e., the block valve is not required to prevent or mitigate the consequences of a design basis accident), it was safe to restart TMI-l prior to completion of the test program.

Correa et al., ff. Tr. 8746; Zudans, ff. Tr. 8824.

Neither section 2.1.2 of NUREG-0578 nor the former UCS Contention 6 call for the performance testing of PORV l

block valves. There was no failure of the PORV block valve during the TMI-2 accident. The NRC Staff, in its TMI Action Plan Requirements, has recommended PORV block valve qualifi-catior , with a schedule of July 1, 1982, for plant-specific submittals of test data and results. See NUREG-0737, II.D.l.

This raises no presumption that the TMI-l PORV block valve, l which was reviewed and approved by the Commission when it issued an operating license for this plant, will not perform its intended function.

Testing of block valves is not yet formally included in the EPRI Program Plan. See NRC Staff Answer to UCS Motion for Board Order on PORV Block Valve Test Results, March 23, 1981, at 2. Neither Licensee nor the Staff attempted to respond to Board Question UCS-6 with the position that pre-liminary test results from EPRI confirm the intended performance

capability of the TMI-l block valve. Nevertheless, because EPRI has tested some block valves, UCS would now have this Board -- ahead of EPRI, the industry and the NRC Staff --

attempt to jump in at the vary inception of a testing program and assess the significance of the tests already conducted and their applicability to TMI-1. We see no reason why, if this course were pursued, the hearing would not remain in session throughout the test program in order to reassess continuously the implications of each test experiance. This is not necessary, however, in order for.the Board to answer its own question UCS-6. Licensee pointed out the favorable implications of the EPRI tests to date only in response to this UCS motion -- which painted a wholly one-sided view of the tests in an effort to launch the Board on an endless and extremely complex investigation with no real purpose.

Licensee is content to rely here on its testimony describing l

the role and functions of the PORV block valve, as well as the Csvorable operating experiency to date of valves of the l

same type as the TMI-l block valve -- which UCS has neither countered nor addressed in its motion snd supporting papers.

l l

See Affidavit of Gary T. Urquhart, attached to Licensee's Answer, Etc., of March 13, 1981.

l Nevertheless, in order to assist the Board in f

assessing the statements and arguments made, and the con-clusions reached, in Mr. Pollard's affidsvit, Licensee l

l encloses an NRC Staff memorandum, dated April 9, 1981, summarizing a Staff meeting, on March 20, 1981, at which

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a UCS representative was present (S. Sholly), with EPRI, Westinghouse, VEPCO and Duke Power on the testing of block valves (Enclosure 2). Mr. Pollard's affidavit, at 1 1.e, states that he reviewed slides presented at this meeting.

Licensee's comments on the Pollard Affidavit E.re provided in Enclosure 1 to this Answer.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE n :__ k.

Thomas A. Baxter Counsel for Licensee 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1090 Dated: May 11, 1981 I

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LIC 5/11/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE i I hereby certify that copies of the foregoing " Licensee's Further Answer to the Union of Concerned Scientists' Motion for Board Order on Block Valve Test Results" with Enclosures 1 and 2 were served this llG; day of May, 1981 by deposit in the U.S.

mail, first class, postage prepaid, to the parties identified on the attached Service List.

/d _ _ , .

Thomas A. Baxf.er

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

Docket No. 50-289

~

METROPOLITAN EDISON COMPANY )

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Isvin, Esquire CN 4 m=n Assistant Cbunsel Atcmic Safety and Licensing Pennsylvania Public Utility Cmmissicn Board P.O. Box 3265 U.S. Nuclear Regulatory Cmmission Harrisburg, Permsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire

• Dr. Walter H. Jordan Robert Adler, Esquire

,' Atanic Safety and Licensing Assistant Attorney General Board Panel 505 Executive House 881 West Outer Drive P.O. Box 2357 Oak Ridge, Tennessee 37830 Ma M ahurg, Pennsylvania 17120 Dr. Linda W. Little John E. Minnich Atmi.c Safety and Licensing Chairman, Dauphin Osunty Board Board Panel of Camissioners j 5000 Hernitage Drive Datphin Cbunty Courthouse Raleigh, North Carolina 27612 Front and Market Streets smMahurg, Pennsylvania 17101

• • James R. 'Iburtellotte, Esquire Office of the Executive Imgal Director Walter W. Cohen, Esquire U.S. Nuclear Regulatory remn4==4em Cbnstmer Advocate Washington, D.C. 20555 Office of Cormsner Advocate 1425 Strawberry Square Docketing and Service ? action Harrisburg, Pennsylvania 17127 office of the Secretary U.S. Nuclear Regulatory Ccrimission Washington, D.C. 20555 Hand delivered to Chai=ran Smith.

• • Hand delivered to Mr. Cutchin.

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Jordan D. Cunningham, Esquire Robert Q. Pollard 2320 North Secend Street 609 2 ntpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 21218 Ms. Iouise Bradford d1auncey Kepford

'IMI ALERT Judith H. Johnsrud 315 Peffer Street Envirorsnental Coalition cm Nuclear Power Harrisburg, Pennsylvania 17102 433 Orlando Avenue State College, Pennsylvania 16801 Ellyn R. Weiss, Esquin Har:ren & Weiss Marvin I. Ie cs 1725 Eye Street, N.W., Suite 506 6504 Bradford Terrace Washington, D.C. 20006 Pb41=Aalphia, Pe.wrylvania 19149 Steven C. Sholly Marjorie M. Aanodt Unicn of hmed Scientists R. D. 5 1725 Eye Street, N.W., Suite 601 Coatesville, Pennsylvania 19320 Washington, D.C. 20006

'Ihomas J. Germine, Esquire Gail Bradford Deputy Attorney General ANGRY Division of Iaw - Rocm 316 245 West Pbf1adelphia Street 1100 Raymond Boulevard York, Pennsylvania 17404 Newark, New Jersey 07102 William S. Jordan, III, Esquire Harmon & Weiss '

1725 Eye Street, N.W., Suite 506 Wash W a , D.C. 20006 l

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ENCLOSURE 1 g org W- J

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1. In 12a, Mr. Pollard states that in July, 4,5 Y, a Westinghouse block valve model 3GM88 equipped with a ROTORK l operator set at 110 ft-lbs and tested in-line with a Control Components PORV would not close against full steam flow.

( Mr. Pollard fails to report that after changing to a Limitorque SE 10-15 operator, at a revised setting of 175 ft-lbs, the valve was successfully cycled 21 times against full flow. See Attach-ment 3 to Enclosure 2.

2. In 1 2b, Mr. Pollard states that in August, 1980, an Anchor Darling block valve equipped with an unspecified operator and tested in-line with a Fisher PORV would not fully close against full steam flow and significant wear patterns were observed at the disc / seat interface. Mr. Pollard fails to report that after modifications the valve was retested and, while it still exhibited some seat leakage, it was successfully cycled 21 times against full flow. See Attachment 3 to Enclo-sure 2.

3. In 1 2c, Mr. Pollard states that a test prior to October 27, 1980, revealed that a Rockwell valve had a body to bonnet seal problem. Mr. Pollard f 11ed to report that the seal problem, which does not affect operability, was discovered during an initial test (pressurization of loop);

and that after modification the valve was successfully l cycled 21 times, using a Limitorque SMB-00-10 operator.

l See Attachment 3 to Enclosure 2.

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4. In 1 2d, Mr. Pollard states that on January 12, 1981, Westinghouse block valve model 3GM99 equipped with a Limitorque operator model SMB-000-10 would not close fully against full steam flow. As discussed in the EPRI letter attached to the original UCS motion, prior to testing this valve EPRI had received information that it was sized such that it would not be able to close against full flow. The valve was cycled twice on January 12, 1981, and, as predicted, it did not fully close against full flow. The valve was originally equipped with a Limitorque SMB-000-10 operator.

Attachment 3 to Enclosure 2. Mr. Pollard, at 1 4 of his affidavit, claims this operator is identical or similar to the one used at TMI-1. The TMI-1 block valve, however, has an SMB-00-10 operator. Affidavit of Jcmes H. Correa, April 8, 1981, at 1 3 (attached to Licensee's amended answer of April 9, 1981). Mr. Pollard also fails to report that after modifica-tion with an SB-00-15 operator, the Westinghouse valve was successfully cycled 21 times against full flow. See Attach-ment 3 to Enclosure 2.

-S. In 1 2e, Mr. Pollard states that Velan block valve model C2345 S/N-24302, equipped with a Liminorque actuator model SMB-00-15 experienced galling on one of the disc guides. While some galling indications on one of the disc guides were observed when the valve was disassembled and inspected after the test, Mr. Pollard fails to report that the valve was successfully cycled 21 times against full g-- ---w.seg y y'-- ---- g - y,mm.+^.ar-+-*-m-- -i-e wwe*y* m-

flow, with zero seat leakage throughout. See Attachment 3 to Enclosure 2.

6. In 1 5, Mr. Pollard states that the block valve /

motor operator combination at TMI-l has not been tested. This is not determinative. The valve failures were caused by too low of a torque capability on the valve operator. Enclosure 2 (Staff memo by Engle) at p. 3. The output torque for the TMI-l block valve, however, is correct. Affidavit of James H. Correa, April 8, 1981, at 1 5.

7. In 1 13, Mr. Pollard states that Licensee and the Staff are unwilling to accept the applicability of unsuccessful tests of a similar or identical motor operator but different valves. However, there have been no unsuccessful tests of the motor operator identical to the one installed at TMI-l (SMB-00-10). See Attachment 3 to Enclosure 2.

8. In his affidavit, Mr. Pollard fails to report the testing of Velan valve model B10-3054B013M (.M O) with a Limitorque SMB-00-10 operator, which was cycled 21 times against full flow with no anomalies and zero seat leakage.

l He also fails to report the testing of a Borg Warner valve

! with a ROTORK operator, which was successfully cycled 21 l

times against full flow. See Attachment 3 to Enclosure 2.

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UNITED STATES

! Y: 4-(, 3 NUCLEAR REGULATORY COMMISSION wAsMmorow, p. c. zosse tFg j

. )(, - April 9, 1981

'6ocket No. 50-339 .

p g T. M. Novak, Assistant Director @ g 5 MEMORN!DUM FOR:

for Operating Reactors Division of Licensing ..

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THRU:

Robert A. Cl ark, Chief .. i. ' ' Q~i v, A m

%"sy W-y gj Operating Reactors Branch #3 k' o. e,ctr3,r,e.

Divison of Licensing j' FROM: Leon Engle, Project Manager -

Operating Reactors Branch #3 Division of Licensing

SUMMARY

OF MEETE.?G WITH ELECTRIC POWER RESEARCH INSTITUTE,

SUBJECT:

WESTINGHOUSE' CORPORATION, DUKE POWER COMPANY, AND THE VIRGINIA ELECTRIC AND POWER COMPANY REGARDING THE TESTING OF BLOCX YALVES.

20, 1981 regarding the A meeting was held in Bethesda, Maryland on MarchA list of attendees is provided subject as noted above.

Introduction:

Full scale qualification testing of Power Operated Relief Valves (PORV) is specified in NUREG-0737 " Clarification of TMI Action < Plan Requirements".

The testing of the PORY is to be completed by July 1,1981.

The requirement for full-scale qualification testir.g of PORY block valves is to be completed by July 1,1982. This requirement was first femally indentified in Item II.D.1 of NUREG-0737. The p,rpose u of the block valve testing is to provide empirica'. evidence that block valves located between the pressurizer and each PORY can be operated, closed and opened for fluid conditions expected under operating and accident conditions.

By letter dated December 15, 1980, the PWR Owners Group notified the NRC that it would not commit to implement a block valve test program until .tbe Since then, PORY test program, due July 1,1981, had been completed.

discussions between the NRC staff and the Owners Group have resulted in a verbal commitment from the Group for the establishment of a bi ack valve' test It is program. The completion date for this ' test program is July 1,1982.

presently anticipated that-the Owners Group will be submitting a block valve test program to the NRC in May,1981.

Anticipating the requirement for a formalized block valve testing program, the Electric Power Research Institute (EPRI) made provisions at the Marshall Test Facility for the installation of bloc' valves between the facility steam source and the PORY's. Since no fomal block valve test program was in place, EPRI obtained seven different block valves which were tested in July,1981 in order to provide base-line data on block valve closure.

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