ML17158A476
| ML17158A476 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/21/1994 |
| From: | Poslusny C Office of Nuclear Reactor Regulation |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| GL-89-10, TAC-M89590, TAC-M89591, NUDOCS 9409260178 | |
| Download: ML17158A476 (4) | |
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0O gO 0p*~4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHlNGTON, D.C. 20555-0001 September 21, 1994 Hr. Robert G.
Byram Senior Vice President-Nuclear Pennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101
SUBJECT:
EXTENSION OF GENERIC LETTER 89-10 PROGRAM SCHEDULE AT SUSQUEHANNA (TAC Nos.
H89590 AND 89591)
Dear Hr. Byram:
On July 14 and September 7,
- 1994, conference calls were conducted between PP&L representatives and members of the Region I and NRR staff, to discuss questions that had arisen during the staff's review of the April 29 letter.
Based on our review of your submittal and discussions during the conference
- calls, we have the following concerns regarding the licensee's justification for the Susquehanna GL 89-10 schedule extension.
Concern 1
On April 29,
- 1994, Pennsylvania Power
& Light Company (PP&L) submitted a
, letter notifying the NRC staff of a change in the scheduled commitments for the motor-operated valve (HOV) program developed at Susquehanna Steam Electric Station in response to Generic Letter (GL) 89-10, "Safety-Related Hotor-Operated Valve Testing and Surveillance."
You had originally committed to complete the GL 89-10 program at Susquehanna within the five-year schedule recommended in GL 89-10.
In your April 29 letter, you indicated that HOV testing is now scheduled to be completed during the next Unit 1 and 2
refueling outages beginning in March and September 1995, respectively.
Completion of functionality assessments for untested HOVs based on the Electric Power Research Institute's methodology is said to be scheduled for completion by December 31, 1995.
PP8L plans to remove from its GL 89-10 program, 34 HOVs in the main steam line isolation valve-leakage control system (MSIV-LCS) in anticipation of a plant modification to remove the HSIV-LCS from the plant.
Previous discussions with the NRC staff regarding removal of these HOVs from the GL 89-10 program assumed that the modification to remove this system from the plant would be completed by the original GL 89-10 completion date.
- However, you have not submitted a request for the removal of the HSIV-LCS from the plant and continue to rely on these HOVs to perform a safety function.
Consequently, the schedule to delete this system from both units has been delayed.
We believe that the HSIV-LCS MOVs should be retained in the GL 89-10 program until (1) you no longer rely on the MSIV-LCS to perform a safety function and (2) the staff has accepted this change in system availability.
9409260178 94092l PDR ADOCK',05000387
- P
'PDR
Mr. Robert G.
Byram o
Concern 2
PP&L plans to remove four service water supply and return HOVs for the uEn diesel generator from the GL 89-10 program.
- However, you identified these HOVs to have a safety function to close under differential pressure if a loss of coolant accident (LOCA) initiated while the uEu diesel generator is in the test mode.
Because of this active safety function, we believe that these HOVs should be retained in the GL 89-10 program.
With respect to PP&L's plan to remove several plug and modulating valves from its GL 89-10 program, you will need to be able to justify the capability of these HOVs to perform their safety functions even if not addressed in the GL 89-10 program.
Concern 3
PP&L informed the NRC staff that some HOV tests might not be completed as planned during the latest Unit 2 outage.
If so, those HOVs will need to be included in the staff's review of the Susquehanna GL 89-10 schedule extension.
Although we can agree to an interim extension until PP&L's justification is reviewed in more detail, we do not consider at this point in time that you have adequately justified the proposed GL 89-10 program schedule extension for Unit 1 to March 1995 and for Unit 2 to September 1995.
In. addition, you stated that a further schedule extension may also be necessary in order to be able to address the HSIV-LCS valves.
Region I is planning an HOV inspection at Susquehanna during the fall of this year.
During the inspection, and based on its findings, Region I and NRR staff will further evaluate our concerns and complete our determination of whether PP&L's justification for the proposed GL 89-10 schedule extension is adequate and acceptable to the staff.
If you have any questions concerning this review and our concerns, please contact me at 301-504-1402, or Tom Scarbrough at 301-504-2794.
Sincerely,
/s/
Docket Nos. 50-387/50-388 Chester
- Poslusny, Senior Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation cc:
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SU89590.GEN
Hr. Robert G.
Byram Concern 2
PP&L plans to remove four service water supply and return MOVs for the "E" diesel generator from the GL 89-10 program.
However, you identified these HOVs to have a safety function to close under differential pressure if a loss of coolant accident (LOCA) initiated while the "E" diesel generator is in the test mode.
Because of this active safety function, we believe that these MOVs should be retained in the GL 89-10 program.
With respect to PP&L's plan to remove several plug and modulating valves from its GL 89-10 program, you will need to be able to justify the capability of these HOVs to perform their safety functions even if not addressed in the GL 89-10 program.
.Concern 3
PP&L informed the NRC staff that some MOV tests might not be completed as planned during the latest Unit 2 outage.
If so, those HOVs will need to be included in the staff's review of the Susquehanna GL 89-10 schedule extension.
Although we can agree to an interim extension until PP&L's justification is reviewed in more detail, we do not consider at this point in time that you have adequately justified the, proposed GL 89-10 p'rogram schedule extension for Unit 1 to March 1995 and for Unit 2 to September 1995.
In addition, you stated that a further schedule extension may also be necessary in order to be able to address the MSIV-LCS valves.
Region I is planning an MOV inspection at Susquehanna during the fall of this year.
During the inspection, and based on its findings, Region I and NRR staff will further evaluate our concerns and complete our determination of whether PP&L's justification for the proposed GL 89-10 schedule extension is adequate and acceptable to the staff.
If you have any questions concerning this review and our concerns, please contact me at 301-504-1402, or Tom Scarbrough at 301-504-2794.
Sincerely, Docket Nos. 50-387/50-388 cc:
See next page Q.~ 4 Chester
- Poslusny, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Robert G.
Byram Pennsylvania Power
& Light Company Susquehanna Steam Electric Station, Units 1
& 2 CC:
Jay Silberg, Esq.
- Shaw, Pittman, Potts
& Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. J.
M. Kenny
'icensing Group Supervisor Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Scott Barber Senior Resident Inspector U.
S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania 18603-0035 Mr. William P, Dornsife, Director Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. 0.
Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Harold G. Stanley Vice President-Nuclear Operations Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1,
Box 1797 Berwick, Pennsylvania 18603 George T. Jones Vice President-Nuclear Engineering Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101