ELV-02648, Provides Clarification of Response to Generic Ltr 89-19, Request for Action Related to Resolution of Unresolved Safety Issue A-47 - Safety Implication of Control Sys in LWR Nuclear Power Plants

Provides Clarification of Response to Generic Ltr 89-19, Request for Action Related to Resolution of Unresolved Safety Issue A-47 - Safety Implication of Control Sys in LWR Nuclear Power Plants

ML20072S662
Person / Time
Site:	Vogtle
Issue date:	04/08/1991
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-A-47, REF-GTECI-SY, TASK-A-47, TASK-OR ELV-02648, ELV-2648, GL-89-19, NUDOCS 9104160442
Download: ML20072S662 (2)

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ELV-02648 0897 j Docket Nos. 50-424 '

50-425 U. S. Nuclear Regulatory Comission i ATTN: Document Control Desk j Washington, D. C. 20555 Gentlemen:  ;

V0GTLE ELECTRIC GENERATING PLANT i CLAkiflCATION OF RESPONSE TO GENERIC LETTER 89-19 ,

By letter dated March 15, 1990 (ELV-01375), Georgia Power Company (GPC)-

responded to Generic Letter 89-19. Request for Action Related to Resolution of Unresc1ved Safety issue A Safety implication of Control Systems in LWR Nuclear Power Plants. Specifically, GPC stated that plant procedures and  :

Technical Specifications (TS) have been reviewed to ensure that appropriate '

requirements exist to periodically verify operability of the feedwater. isolation function. Furthermore, response time testing and valve stroke testing are performed to ensure that components function within the assumed time intervals.

At the time that this response was submitted, these statements were intended to apply only to the feedwater isolation valves and not the main feodwater regulating valves (MFRVs) anel the bypass feedwater regulating valves (BFRVs).

When the Unit I active valve list, inservice Testing (IST) Program and the TS were originally developed, the MFRVs and BFRVs were deliberately excluded 1 because it was our position that the main feedwater isolation valves and bypass l feedwater isolation valves provided adequate redundancy of isolation capability. '

Therefore. there were no TS or IST Program requirements associated with-these valves. This philosophy was'also applied when the Unit 2 IST Program and TS were developed. During preparation of our response to Generic Letter.89-19, this issue was revisited; however, at the-time we submitted our response, our ,

conclusions relative to the MFRVs and BFRVs were unchanged.

Subsequent to our March 15, 1990 response to the generic letter, we further investigated this issue and, .as a result, have revised our position and included  ;

the MFRVs and BFRVs in the active valve-list and our IST Programs. A Licensing Document Change Request was signed on October 29, 1990 to add the MFRVs<and BFRVs to the active valve list in the FSAR.- A Program Change Request was

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Georgia Power d U. S. Nuclear Regulatory Commission ELV-02648 Page 2 ,

issued on December 11, 1990 to add these valves to our IST Programs.

Furthermore, these valves will be included in future response time testing pursuant to TS surveillance requirement 4.3.2.2 for the feedwater isolation ft.nction. During the interim, the Unit 2 MFRVs and BFRVs and the Unit 1 BrP have been tested and their stroke times are less than or equal to 5 secor This provides reasonable assurance that the overall response time for thi i.e., less tha.

feedwater equal isolation function to 7 seconds). Since the will_

Unit be1within MFRVs requirements cannot be tes(ted at )ower . th;.,

will be stroke-time tested during the next outage which affords tie opportun:t.;

Sincerely, d6N' C. K. McCoy CKM/NJS/gmb xc Georaia Power Comoany Mr. W. B. Shi) man Mr. P. D. Rusiton 1

Mr. S. H. Chesnut NORMS U. S. Delear Reaulatory Commissj2B Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident inspector, Vogtle 700776

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