Part 21 Report - 1995-024

ACCESSION #:  9501200336

                                                 TELEPHONE (816) 727-2600
                                                     POST OFFICE BOX 3339
                                                         JOLIET, IL 60434
CRANE                    NUCLEAR OPERATIONS

CRANE VALVES             104 NORTH CHICAGO STREET      JOLIET, IL 60431

January 12, 1995


Document Control Desk
U.S. Nuclear Regulatory Commission 
Washington, DC 20555

SUBJECT:       FINAL REPORT ON 10 CFR PART 21 EVALUATIONS

REFERENCES:    Analytical Support Requested by Companies Utilizing Crane
               Valves with Motor Operators

Ladies or Gentlemen:

I.   Final Report

As outlined in Our May 16, 1994 Interim Report, an evaluation was
undertaken with respect to a potential 10 CFR Part 21 reportable concern. 
The evaluation has been completed and this is our Final Report on the
matter.

II.  Background

A number of our customers which utilize Crane valves with motor operators
requested analytical support to determine the required thrust for valves
in essential safety systems that may be needed to bring the plants to a
safe Shutdown.  These requests were in response to NRC Generic Letter 
85-03, November 16, 1985 and supplements.

Crane - Aloyco (now Crane Valves Nuclear Operations) employed a model in
performing these analyses.  Since 1993 customers that requested CVNO to
perform support analyses have specified design conditions which include
parameters that were not analyzed in the original model.  The potential
Part 21 concern arose because the results generated from the original
model appear different than the results from the current model.  The
possibility of different results should not be unexpected because the
current model allows for a more sophisticated analyses in that it
considers additional factors, which were not addressed in the original
model.


CRANE NUCLEAR OPERATIONS
FINAL REPORT ON 10 CFR PART 21 EVALUATIONS                  PAGE 2

III. Results of Evaluation


Original purchase orders, from our various utility customers, were
reviewed to confirm that the analytical information actually supplied was
what was requested.  The review determined that the vast majority, 74
percent of the purchase orders, requested analytical support in order to
perform the required thrust (OTC) calculation.  The model widely used in
the late 1980's considered design pressure, differential pressure,
ambient temperature, operator thrust, and yield stress.  Table I,
attached, depicts the parameters addressed with the original model. 
Approved analyses generated under this model were supplied to the various
utilities.  Following the date that the approved analyses were forwarded
to our customers, they had the CVNO files available for their use and
presumably made such use of them as they deemed appropriate.  Generally,
however, not having heard from most of the utilities regarding the
analyses, CVNO concluded that the analyses as forwarded, were the
analyses each customer expected to receive.  Subsequent to the issuance
of Generic Letter 89-10, June 28, 1989, "Safety-Related Motor Operated
Valve Testing and Surveillance", a few utility customers requested
additional information or a revised analysis which considered design
basis conditions. 

Since 1990, numerous NRC workshops and industry meetings have been held
nation-wide to answer questions concerning the implementation of required
testing, surveillance, and analyses to support the proper operation of
safety-related motor-operated-valves (MOVs).  Since operating licenses
were granted to nuclear plants over a twenty-five year period, each plant
may have different specific approaches to the implementation of new
regulations.  Many utilities have obtained or are working to obtain
additional assurance that each safety-related MOV is and will be
available to properly provide its safety function.

With regard to the Current model employed by CVNO, utilities that
requested CVNO to perform support analyses since late 1993, for the most
part have specified design basis conditions to be used in the analyses. 
Typically they include extended structure mass, extended structure
center-of-gravity, ASME and AISC allowable stress, and dynamics loads, as
requested by the customer.  Table I contrasts the parameters which are
addressed in the different models.  The current model considers bending
moments and torsion loads.  Therefore, analyses employing the current
model can identify the weak link in the valve-motor operator assembly as
a function of design basis conditions.


CRANE NUCLEAR OPERATIONS
FINAL REPORT ON 10 CFR PART 21 EVALUATIONS                  PAGE 3

The concern which prompted the Interim report and our evaluation of the
matter was differences in the results of analytical work for the same
component performed under the original model with results from the
current model.  Given that there are additional factors considered in the
current model, it can be anticipated that there will be some differences
in results, although such differences are not readily predictable. CVNO's
evaluation of this matter, including its review of customer purchase
orders makes it clear that utility customers were provided the analyses
they requested.  As additional directives were announced and as further
consideration was given to the matter, a more sophisticated analytical
approach developed using a model which addressed more factors.

IV.  Conclusion

CVNO supplied its customers with the analyses they requested.  The
customers used the analyses as it suited their purposes.  When further
developments occurred and, as a consequence, the scope of analyses using
the original model came into question, CVNO responded in two ways.  One,
CVNO has been in contact with many utilities and will continue to be
available to discuss with and provide support to any utility customer to
better understand or predict the performance of safety-related MOVs. 
Two, it has provided customers, upon request, with all analysis using the
current model, which as detailed above addresses additional factors. 
Based on its evaluations of this matter, and given the relevant facts and
circumstances, CVNO concludes that data supplied in prior analyses does
not constitute a reportable item under 10 CFR Part 21.

Should you have any questions or request additional information, please
contact me at 815-740-7571.

Sincerely,


Henry G.L. McCullough, P.E.
Manager Engineering/Quality

HGMcC/cs

cc:  Joe Algozine 
     Paul Hundt 
     John Carlson 
     Bruce Harry 
     File

attachment


CRANE NUCLEAR OPERATIONS
FINAL REPORT ON 10 CFR PART 21 EVALUATIONS

Attachment

                                 Table 1

Operating thrust Calc/Maximum thrust Report (OTC/MTR) vs. Seismic Report
(SR)

Feature                             OTC/MTR              SR
Design Temp                            (1)             included
Design Pressure                      included          included
Differential Pressure                included          included
Ambient Temp                         included          included
Extended Structure Mass            not included        included
Extended Structure CG              not included        included
Dynamic Accelerations              not included        included
Operator Thrust                      included          included
Operator Torque                    not included        included
Stress Criteria                    Yield Stress   ASME, AISC Allowable
                                                  stress *_/
Methodology                             (2)       Theory & Calculations

*_/ These values may or may not reflect the design-basis of the valve.

(1)  Early version based calculation on 100 degrees F temperature.

(2)  The level of methodology provided, varied from little methodology to
     required thrust methodology being provided, to both required thrust
     and thrust capacity being provided.


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