ML17180A780
| ML17180A780 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 05/31/1994 |
| From: | Dick G Office of Nuclear Reactor Regulation |
| To: | Farrar D COMMONWEALTH EDISON CO. |
| References | |
| GL-89-10, TAC-M88631, TAC-M88632, TAC-M88633, TAC-M88634, TAC-M88635, TAC-M88636, TAC-M88637, TAC-M88638, TAC-M88639, TAC-M88640, TAC-M88641, TAC-M88642, NUDOCS 9406080336 | |
| Download: ML17180A780 (6) | |
Text
',; '.,. Oocket Nos. STN 50-45~ I 50-457.~
STN 50-454, ST~ 50-455, I 237, 50-2491 50-373, I 374, 50-254,,50-265, May 31, 1994 295' 50-304 Mr. D. L. Farrar, Manager Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West Ill, Suite 500 1400 OPUS Place Downers Grove, Illinois 60515
Dear Mr. Farrar:
SUBJECT:
SCHEDULE JUSTIFICATION /OR GL 89-10 ACTIVITIES (TAC NOS. M88631(
M88632~ M88633{M88634, M88635,I M88636, M88637, M88638, M88639, M88640, M88641 AND M88642)
The staff has reviewed your letter dated November 1, 1993, concerning certain commitments and plans associated with the Motor-Operated Valve (MOV) programs established at Commonwealth Edison Company (CECo) Nuclear Stations and has several comments and questions (enclosed).
The enclosure requests information related to your reprioritization and margin review efforts, and butterfly valve testing plans. If you have any questions, please contact Ge6rge Dick at (301) 504-3019.
Sincerely, Original signed by:
i 9406080336 940531.
PDR ADOCK
- 05000237
- George F. Dick, Jr., Senior Project Manager Project Directorate 111-2
.,_. _ P
.PDR.,_:_. _JO.,___,
Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation
Enclosure:
NRR Review of Updated Schedule for Commonwealth Edison Activities in Response to Generic Letter 89-10 cc w/enclosure:
See next page Distribution:
Docket File POI I 1-2 R/F A. T. Gody, Jr.
G. Dick NRC & Local PDRs C. Hawes ACRS (10)
J. Zwolinski
____ '3. ___ Dyer
_L_ Scarbrou h OFC B.
Cl~yton, RIIIl J. Jacobson, RIIJ D:PDIII-2 e
- -Jov[R~-- -----~i' --- - --
94 YES NO ifo\\ I
Mr. 0. L. Farrar cc:
Mr. William P. Poirier Westinghouse Electric Corporation Energy Systems Business Unit Post Offi~e Box 355, Bay 236 West Pittsburgh, Pennsylvania 15230 Joseph Gallo Gallo & Ross 1250 Eye St., N.W.,.Suite 302 Washington, D.C.
20005 Regional.Administrator U. S. NRC, Region III 801 Warrenville Road Lisle, Illinois 60532-4351 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935 Chairman Rock Island County Board
- of Supervisors 1504 3rd Avenue North Rock Island County Office Bldg.
Rock Island, Illinois 61201 U. S. Nuclear Regulatory Commission Resident Inspectors Office
- Rural Route #1, Box 79 Braceville, Illinois 60401 Mr. Ron Stephens, Director Illinois Emergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois 62706 Howard A. Learner Environmental Law and Policy Center of the Midwest 203 North LaSalle Street Suite 1390 Chicago, Illinois 60601 EIS Review Coordinator U.S. Environmental Protection Agency 77 W. Jackson Blvd.
Chicago, Illinois 60604-3590 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434 Commoilalth Edison Company U. S. Nuclear Regulatory Commis.sion Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 Attorney General 500 South 2nd Street Springfield, Illinois 62701 U. S. Nuclear Regulatory Commission Resident Inspectors Office 105 Shiloh Blvd.
Zion, Illinois 60099
- George L. Edgar Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, D.C.
20036.
Commonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010
- Illinois Dept. of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Mayor of Zion Zion, Illinois 60099 Dr. J:ec il Lue-Hing Director of Research and Development Metrop~litan*sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611
Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. G. Spedl Plant Manager Dresden Nuclear Power Station 6500 North Dresden Road Morris, Jllinois 60450-9765 U. S. Nuclear Regulatory Commission Resident Inspectors Office.
Dresden Station 6500 *North Dresden Road Morris, Illinois 60450-9766 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450
- Phill1p P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 West Randolph Street
- Suite 12 Chicago, Illinois 60601 Resident Inspector /LaSalle, NPS U. S. Nuclear Regulatory Commission Rural Route No. 1 P. 0. Box 224
. Marseilles, Illinois 61341 Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350
.,..;...
- Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street Chicago, Illinois 60601 LaSalle Station Manager LaSalle County Station Rural Route 1 P. 0. Box 220 Marseilles, Illinois 61341 Chairman
.Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Stephen E. Shelton Vice President 1ow~-Illinois Gas and Electric Company P. 0. Box 4350 Davenport, Iowa 52808.
Mr. Richard Bax Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission 22712 206th Avenue North Cordova, Illinois 61242
(.
ENCLOSURE NRR REVIEW OF UPDATED SCHEDULE FOR COMMONWEALTH EDISON ACTIVITIES IN RESPONSE TO GENERIC LETTER 89-10
Background
On June 28, 1989, the NRC issued Generic Letter {GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," requesting that licensees establish a program to verify the design-basis capability of safety-related motor-op~rated valves {MOVs) and certain other MOVs in safety-related systems in nuclear power plants.
In GL 89-10, the NRC requested that licensees complete the verification of design-basis capability of MOVs within the scope of the generic letter by June 28, 1994, or the third refueling outage after Oecember 28, 1989 {whichever was later).
In a letter dated September 28,
. 1990, Commonwealth Edison Company {CECo) committed to complete design-basis reviews, static and practicable dynamic testing for its 1090 Priority 1 MOVs by the end of the third refueling outage per unit beginning with the Spring 1991 outages and for the remaining 450 Priority 2 MOVs by the end of the fifth refueling outage per unit beginning with-the 1991 outages.
The staff in a.
letter dated January 23, 1991, accepted the CECo schedule but requested that every effort be made to complete the first stage of the two-stage approach (that is, setting MOVs using the best available information) for all GL 89-10 MOVs within the schedule recommended in the generic letter. Since then, the NRC staff has conducted several inspections at CECo facilities and has raised concerns regarding the safety focus of the programs, the management control over the programs, and several important technical issues related to ensuring the design-basis ~apability of CECo's safety-related MOVs.
On August 26, 1993, the NRC staff held a meeting with CECo management to discuss staff concerns that CECo was not making sufficient progress to satisfy its commitments to the NRC regarding GL 89-10 and to discuss perceived program changes which may have invalidated assumptions made by the staff in accepting_
CECo's extended schedule for responding to GL 89-10.
Following this meeting.,.
the NRC staff requested in a letter to CECo dated September 9, 1993, to resubmit justification for the schedule for its response to GL 89-10 and to provide a status of its static testing to set MOVs within the scope of GL 89-10 using the best available information.
On November 1, 1993, CECo submitted its schedule justification for GL 89-10 activities at its six nuclear stations and a status of its static testing of GL 89-10 MOVs.
CECo also submitted an updated schedule commitment for responding to GL 89-10.
GL 89-10, Supplement ft, "Information on Schedule and Grouping, and Staff Responses to Additional Public Questions," was issued on March 8, 1994.
CECo GL 89-10 Schedule Justification and Uodate As stated in its November 1, 1993, submittal, CECo believes that static testing with diagnostics for all GL 89-10 MOVs {except butterfly valves) will be completed within three refueling outages at each unit from the Spring 1991 outages.
CECo states that progress to date of MDV dynamic testing at Byron, Braidwood, and Zion indicates that its schedule commitment will be met at
,. those stations. In its letter, CECo indicates that MOV dynamic testing at LaSalle, Dresden, and Quad Cities had not had an appropriate focus, but asserts that corrective action has been implemented to resolve this issue.
Among the activities specified by CECo are: (1) an internal assessment of the MOV program, (2) a pilot reprioritization of the GL 89-10 MOV population at LaSalle using the station probabilistic risk assessment and an expert evaluation team, (3) a margin review for as-left settings for high and medium safety significant MOVs at LaSalle, (4) planned reprioritization and margin reviews at the other CECo stations, and (5) planned dynamic testing of more than 30% of MOVs within CECo's GL 89-10 program with evaluation of the safety impact of removal of certain globe valves and low differential pressure gate valves from dynamic testing in order to focus on more safety significant MOVs.
CECo acknowledges that the MOV reprioritization and exclusion of certain globe and low differential pressure gate valves represent a change from its previous commitment to dynamically test all GL 89-10 MOVs if practicable and meaningful where greater than 80% design-basis conditions can be achieved.
CECo also has not determined an appropriate diagnostic system for testing butterfly valves.
, In response to an NRC staff concern regarding the use of 0.3 valve factors, CECo states that it has used valve factors greater than 0.3-for some gate valves in its MOV program.
Based on its current and planned MOV activities, CECo believes that its previous conclusion that its extended schedule for responding to GL.89-10 represents only a marginal reduction in the net benefit resulting from the generic letter action items re~ains applicable.
As an update of its response to GL 89-10, CECo committed to the following actions in its November 1, 1993, letter:
- 1.
CECo will complete reprioritization and margin reviews for all GL 89-10 MOVs by June 28, 1994, with appropriate corrective actions initiated as
. necessary.
CE Co states that the evaluations wil 1 be performed with best available information, including valve factors equal to or greater than 9.5 as appropriate.
- 2.
CECo will perform MOV dynamic testing on a schedule guided by the results of the reprioritizations and margin reviews.
- 3.
CECo will complete static testing for all GL 89-10 MOVs (except butterfly valves} by the end of the third ~efueling outage at each unit.
after the Spring 19~1 outages.
- 4.
CECo will submit its plan for butterfly valves when available (expected mid-1994).
NRR Review of CECo GL 89-10 Schedule Justification and Update The NRC staff recognizes the effort being made by CECo to correct the weaknesses in its MOV program identified by NRC inspections and its internal
. assessments.* The staff considers CECo's commitment to reprioritize th~ MOVs within the scope of GL 89-10 and to perform a margin review for ~ach of these MOVs by June 28, 1994, using best available information to be a significant
~
~
'i step toward resolving the staff's concerns about MOV capability at CECo'*s facilities..
The NRC staff ~as the following comments and requests for information regarding CECo's plan to complete its response to GL 89-10:
- 1. The staff is particularly interested in CECo's method to assess margin when some static tests will not be completed until the third refueling o~tage on each unit after the Spring 1991 outages.
In past inspections, inspectors have noted weaknesses in justification for some valve factors, particularly for valves which are not subject to design differential pressure test conditions. The staff requests.that CECo submit the method used for, and the re~ults of, its reprioritization and margin reviews for all GL 89-10 MOVs {including those for which static.
tests will not be completed until the third refueling outage) following completion on.June 28, 1994, with a summary of actions planned {and schedule) in response to those activities.
- 2.. The. staff requests that CECo submit the status of-its plan for butterfly
- valves.and, when available, submit the plan to the staff.
- 3. During f~ture inspections, the NRC staff will sample.safety significint MOVs that have been dynamically tested, as well as MOVs that have not
. been dynamically tested, to review their design-basis capability.
Fro~
. these MOV reviews, *the staff wi 11 determine whether operability concerns exist regarding safety-related MOVs as CECp ~ompletes its response to GL 89-10.
The NRC staff considers CECo's successful completion of ~ts margin review for GL 89-10 MOVs by June 28, 1994, and action in response to the margin review,*
to'be essential for acceptance of CECo's justification for its extended schedule response to GL 89~10. Therefore, the staff will. continue to assess
- the _progress being made by CECo in responding to GL 89-10 through review of tECo submittals arid eval~ation of the design-basis capability of selected MOVs during future inspections.