JAFP-12-0121, Resolution of NRC GL 96-05 for Valves Outside the Scope of the Joint Owners Group Periodic Verification Program for MOVs

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Resolution of NRC GL 96-05 for Valves Outside the Scope of the Joint Owners Group Periodic Verification Program for MOVs
ML12270A135
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 09/25/2012
From: Chris Adner
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
JAFP-12-0121
Download: ML12270A135 (7)


Text

JAFP-12-0121 September 25, 2012 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject:

Resolution of NRC GL 96-05 for Valves Outside the Scope of the Joint Owners' Group Periodic Verification Program for MOVs James A FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

References:

1.

Generic Letter 96-05, Periodic Verification of Design Basis Capability of Safety-Related Motor Operated Valves, dated September 18, 1996

2.

Entergy letter, 180-Day Response to Generic Letter 96-05: Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, JPN-97-011, dated March 17, 1997

3.

GE document, BWR Owners Group Program on Motor-Operated Valve (MOV) Periodic Verification, Topical Report NEDC-32719/MPR-1807 revision 2, dated July 1997

4.

NRC letter, Safety Evaluation Report on Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, dated December 4, 1998

5.

NRC letter, Final Safety Evaluation on Joint Owners Group Program on Motor-Operated Valve Periodic Verification Program (TAC NOS. MC2346, MC2347, and MC2348), dated September 25, 2006

6.

BWROG-TP-09-033, Rev. 1, BWROGs Generic Methodology for JOG MOV Periodic Verification (PV) Program - Category D MOV Evaluations, issued December 22, 2009

Dear Sir or Madam:

By Reference 2, James A. FitzPatrick Nuclear Power Plant (JAF) informed the NRC of JAFs intent to follow the Joint Owners' Group (JOG) Periodic Verification Program for Motor Operated Valves (MOV) as outlined in Topical Report NEDC-32719 [Reference 3] in response to NRC Generic Letter 96-05 [Reference 1]. In response to Reference 2, the NRC issued the Safety Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Chris Adner Licensing Manager

JAFP-12-0121 Page 2 of 3 Evaluation [Reference 4] stating that the Staff considers the JOG Program on MOV periodic verification as an acceptable industry-wide response to Generic Letter 96-05, with conditions described in the Safety Evaluation. The results of the JOG program were reviewed and approved by the NRC in a Final Safety Evaluation, dated September 25,2006 [Reference 5].

The final SE accepted the JOG proposed six years implementation schedule. The NRC expected licensees to notify the NRC of deviations from the JOG program (including the implementation schedule) in accordance with the commitments made in response to GL 96-05, including the periodic verification of the design basis capability of JOG Class 0 valves.

By this letter, Entergy notifies the NRC that JAF will complete implementation the JOG Periodic Verification Program by the end of JAF's current Refueling Outage (R020). Some MOVs within the program are receiving Engineering evaluation to come in compliance with the program prior to entering the next power cycle. The safety-related functions of these valves are not required in the current Plant Mode (5). Therefore, JAF is extending the implementation schedule until the end of R020.

Secondly, in accordance with the NRC Safety Evaluation [Reference 5] dated September 25, 2006, Entergy notifies the NRC that two safety-related MOVs have been identified as Class D.

The design basis capability of the Class 0 valves identified in Attachment 1 will be tested using the alternate method of the guidance BWROG-TP-09-033 [Reference 6]. This approach complies with the NRC requirement to ensure design basis capability of the valves to perform their safety-related function and meets the intent of NRC guidance described in the Safety Evaluations [References 4 and 5].

The Regulatory Commitments identified in Attachment 2 update existing commitments

[Reference 2]. Should you have any questions regarding this letter, please contact Chris Adner, Licensing Manager, at (315) 349-6080.

Chris Adner Licensing Manager CAlmh Attachments 1:

2:

cc: Next page Summary of Class 0 Valves Regulatory Commitments

JAFP-12-0121 Page 3 of 3 cc:

Mr. William Dean Regional Administrator, Region I U. S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 Resident Inspectors Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093-0136 Mr. Mohan Thadani Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

JAFP-12-0121 ATTACHMENT 1 Summary of Class D Valves (1 Page)

JAFP-12-0121 Summary of Class D Valves Page 1 of 1 Valve No.

Safety Function Alternate Method Frequency 27MOV-120 Containment exhaust to standby gas treatment isolation valve BWROG-TP-09-033 As required by the program 27MOV-121 Containment exhaust to standby gas treatment valve BWROG-TP-09-033 As required by the program

JAFP-12-0121 ATTACHMENT 2 Regulatory Commitments (1 Page)

JAFP-12-0121 Regulatory Commitments Page 1 of 1 This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

TYPE (Check one)

COMMITMENT ONE-TIME ACTION CONTINUING COMPLIANCE SCHEDULED COMPLETION DATE (If Required)

Implement a MOV Periodic Verification Program in accordance with Joint Owners Group (JOG) Program on MOV Periodic Verification Topical Reports, NEDC-32719/MPR-1807 revision 2 and MPR-2524.

Implement an alternate method for GL 96-05 Class D valves in accordance with BWROG-TP-09-033.

X The end of JAF RO20