ML022170131

Request for Additional Information, Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants

ML022170131
Person / Time
Site:	LaSalle
Issue date:	08/15/2002
From:	Macon W NRC/NRR/DLPM/LPD3
To:	Skolds J Exelon Generation Co
Macon, WA, NRR/DLPM/LPD III-2, 415-3965
References
TAC MB5529, TAC MB5530
Download: ML022170131 (5)

Text

August 15, 2002 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB5529 AND MB5530)

Dear Mr. Skolds:

By letter dated June 14, 2002, you submitted Relief Request RV-14 to implement the 1995 Edition and 1996 Addenda of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants, OMa-1996, Subsection Inservice Testing Code, as it applies to motor operated valves, including the Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants." The Nuclear Regulatory Commission (NRC) staff has performed an initial review of your request and finds that it needs additional information to complete its review.

Therefore, please respond to the enclosed request for additional information by September 20, 2002, for the staff to expedite its review. The response date was agreed upon by members of your staff on August 2, 2002. The enclosed questions are unchanged from those sent by e-mail to a member of your staff on July 30, 2002.

Sincerely,

/RA/

William A. Macon, Jr., Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosure:

As stated cc w/encl: See next page

August 15, 2002 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB5529 AND MB5530)

Dear Mr. Skolds:

By letter dated June 14, 2002, you submitted Relief Request RV-14 to implement the 1995 Edition and 1996 Addenda of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants, OMa-1996, Subsection Inservice Testing Code, as it applies to motor operated valves, including the Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants." The Nuclear Regulatory Commission (NRC) staff has performed an initial review of your request and finds that it needs additional information to complete its review.

Therefore, please respond to the enclosed request for additional information by September 20, 2002, for the staff to expedite its review. The response date was agreed upon by members of your staff on August 2, 2002. The enclosed questions are unchanged from those sent by e-mail to a member of your staff on July 30, 2002.

Sincerely,

/RA/

William A. Macon, Jr., Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374 Distribution:

PUBLIC OGC

Enclosure:

As stated PD3/2 r/f ACRS AMendiola DHills, RIII cc w/encl: See next page CRosenberg WMacon ADAMS Accession Number: ML022170131 OFFICE PM:LPD3-2 LA:LPD3-2 SC:LPD3-2 NAME WMacon CRosenberg AMendiola DATE 08/13/02 08/13/02 08/14/02 OFFICIAL RECORD COPY

LaSalle County Station Units 1 and 2 cc:

Site Vice President - LaSalle Regional Administrator Exelon Generation Company, LLC U.S. NRC, Region III 2601 North 21st Road 801 Warrenville Road Marseilles, IL 61341-9757 Lisle, IL 60532-4351 LaSalle County Station Plant Manager Illinois Department of Nuclear Safety Exelon Generation Company, LLC Office of Nuclear Facility Safety 2601 North 21st Road 1035 Outer Park Drive Marseilles, IL 61341-9757 Springfield, IL 62704 Regulatory Assurance Manager - LaSalle Document Control Desk-Licensing Exelon Generation Company, LLC Exelon Generation Company, LLC 2601 North 21st Road 4300 Winfield Road Marseilles, IL 61341-9757 Warrenville, IL 60555 U.S. Nuclear Regulatory Commission Senior Vice President - Nuclear Services LaSalle Resident Inspectors Office Exelon Generation Company, LLC 2605 North 21st Road 4300 Winfield Road Marseilles, IL 61341-9756 Warrenville, IL 60555 Phillip P. Steptoe, Esquire Vice President Sidley and Austin Mid-West Operations Support One First National Plaza Exelon Generation Company, LLC Chicago, IL 60603 4300 Winfield Road Warrenville, IL 60555 Assistant Attorney General 100 W. Randolph St. Suite 12 Senior Vice President Chicago, IL 60601 Mid-West Regional Operating Group Exelon Generation Company, LLC Chairman 4300 Winfield Road LaSalle County Board Warrenville, IL 60555 707 Etna Road Ottawa, IL 61350 Vice President - Licensing and Regulatory Affairs Attorney General Exelon Generation Company, LLC 500 S. Second Street 4300 Winfield Road Springfield, IL 62701 Warrenville, IL 60555 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney Generals Office 100 W. Randolph Street Chicago, IL 60601

LaSalle County Station Units 1 and 2 Director - Licensing Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Counsel, Nuclear Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager - Licensing -Clinton and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

REQUEST FOR ADDITIONAL INFORMATION LASALLE COUNTY STATION, UNITS 1 AND 2

1. Under Proposed Alternative Provisions in Relief Request RV-14, the licensee proposes to use the motor-operated valve (MOV) testing provisions in ASME OMa-1996, Subsection ISTC, at LaSalle County Station, Units 1 and 2, in lieu of its present inservice testing (IST) requirements in its Code of record, OMa-1988, Part 10. Discuss planned changes to inservice testing intended at LaSalle through this relief request, other than the application of the provisions of ASME Code Case OMN-1, Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light Water Reactor Power Plants.

2. In paragraph B under Proposed Alternative Provisions in Relief Request RV-14, the licensee requests relief from Sections 3.3(b), 3.4, and 6.3 of ASME Code Case OMN-1.

In paragraph B, the licensee describes its commitment to conduct sample as-found testing to validate its assumptions for MOV degradation (rather than performing as-found testing in all situations). Discuss the planned activities as alternatives to Sections 3.4 and 6.3 of the code case.

3. In paragraph C.3 under Proposed Alternative Provisions in Relief Request RV-14, the licensee states that LaSalle does not consider stem lubrication to invalidate the as-found condition of an MOV. In Section 3.3(b), ASME Code Case OMN-1 notes that MOV stem lubrication might invalidate the as-found condition for inservice testing. In paragraph B under Proposed Alternative Provisions, the licensee commits to perform sample MOV as-found testing to validate its degradation assumptions. Discuss plans to continue the commitment to conduct sample MOV as-found testing to support the ongoing assumption that stem lubrication does not adversely impact the as-found condition of the MOV.

4. In paragraph E under Proposed Alternative Provisions in Relief Request RV-14, the licensee states that it will continue to perform exercise tests and position indication tests in accordance with ISTC requirements for those MOVs identified as having IST requirements, but are not subject to diagnostic testing. The diagnostic test provisions of ASME Code Case OMN-1 are applicable to all MOVs within the scope of the code case.

Supplement 1 to Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance, indicated that successful industry experience with some valve types (such ball and plug valves) could be used to justify the omission of MOV dynamic tests in validating their design-basis calculations. Discuss plans to satisfy the provisions for diagnostic testing of MOVs within the scope of ASME Code Case OMN-1.