ML17191B223

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Forwards Request for Addl Info Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves
ML17191B223
Person / Time
Site: Dresden, Byron, Braidwood, Quad Cities, LaSalle  Constellation icon.png
Issue date: 02/04/1999
From: Rossbach L
NRC (Affiliation Not Assigned)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
GL-96-05, GL-96-5, TAC-M97018, TAC-M97019, TAC-M97025, TAC-M97026, TAC-M97042, TAC-M97043, TAC-M97060, TAC-M97061, TAC-M97091, TAC-M97092, NUDOCS 9902080158
Download: ML17191B223 (9)


Text

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NUCLEAR REGULATORY COMMISSION '5t>* 37~h7~('1-.ftf/4p5/4:4 WASHINGTON, D.C. 2056S-0001 J/5 'f Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West Iii

  • 1400 Opus Place, Suite 500 Downers Grove, IL 60515 February 4, 1999

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO GENERIC LETTER 96 BRAIDWOOD, BYRON, DRESDEN, 1l/'SAbbE AND QUAD CITIES (TAC NOS. M97018, M97019, M97025, M97026, M91042:M97043, M97060, M97061,

. M97091 AND M97092)

Dear Mr. Kingsley:

. On September 18, 1996, the NRC issued Generic Letter (GL) 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to request that nuclear power plant licensees establish a program or ensure the effectiveness of the current program,

  • to verify on a *periodic basis that safety-related motor-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On August 24, 1998, Commonwealth Edison Company (ComEd, the licensee) submitted an updated response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification at its five nuclear stations. The NRC staff has encouraged licensees to participate in the industry-wide JOG program to provide a benefit in reactor safety by sharing expertise and information on MOV performance and to increase the efficiency of GL 96-05 activities at nuclear plants. Licensee participation in the JOG program also minimizes the amount of information necessary for the NRC staff to review each licensee's response to GL 96-05. As a result, the NRC staff requires only limited information to complete its GL 96-05 review for Braidwood, Units 1 and 2; Byron, Units 1 and 2; Dresden, Units 2 and 3; LaSalle, Units 1 and 2; and Quad Cities, Units 1 and 2.

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0. Kingsley February 4, 1999
  • The questions-contained in the enclosed request for additional information (RAI) were discussed with members of your staff on January 7 and 22, 1999. It was agreed that the responses would be provided withir:i 60 days of receipt of this letter.

Sincerely, ORIG. SIGNED BY Lawrence W. Rossbach, Project Manager

  • Project Directorate 111-2 Division of Reactor Projects - 111/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456, STN 50-457, 50-237, 50-249,

. 50-373, 50-374, 50-2.54; 50-265

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0. Kingsley The questions contained in the enclosed request for additional information (RAI) were discussed with members of your staff on January 7 and 22, 1999. It was agreed that the responses would be provided within 60 days of receipt of this letter.

Docket Nos. STN 50-454, STN 50-455, STN 50-456, STN 50-457, 50-237, 50-249, 50-373, 50-37 4, 50"'.254, 50-265

Enclosure:

RAI cc w/encl: See next page Sincerely, Lawrence W. Rossbach, Project Manager Project Directorate 111-2 Division of Reactor Projects - 111/IV Office of Nuclear Reactor Regulation

0. Kingsley
    • cc:

Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield *. Illinois 62704 Document Control Desk-Licensing Commonwealth Edison Company 1400 Opus Place, Suite400 Downers Grove, Illinois 60515 Ms. C. Sue Hauser, Project Manager Westinghouse Electric Corporation

  • Energy Systems Business Unit Post Office Box 355 Pittsburgh, Pennsylvania 15230 Joseph Gallo Gallo & Ross 1025 Connecticut Ave., N.W., Suite 1014
  • Washington, DC 20036 Howard A. Leamer Environmental law and Policy Center of the Midwest 35 East Wacker Drive Suite 1300 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek RR 1, Box 182 Manteno, Illinois 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061
  • Commonwealth Edison Company Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 George L. Edgar Morgan, Lewis and Bochius 1800 M Street, N.W.

Washington, DC 20036 Attorney General 500 S. Second Street Springfield, Illinois 62701 Commonwealth Edison Company

  • Byron Station Manager 4450 N. German Church Road Byron, Illinois 61010-9794 Commonwealth Edison Company Site Vice President - Byron 4450 N. German Church Road Byron, Illinois 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office RR 1, Box 79 Braceville, Illinois 60407 Mr. Ron Stephens Illinois Emergency Services and Disaster Agency 110 E. Adams Street Springfield, Illinois 62706 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434 Commonwealth Edison Company Braidwood Station Manager RR 1, Box 84 Braceville, Illinois 60407-9619
0. Kingsley Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, Illinois 60935.

Commonwealth Edison Company Site Vice President - Braidwood RR 1, Box 84 Bracemille, Illinois 60407..:9619 Commonwealth Edison Company Site Vice President - Dresden 6500 N. Dresden Road Moms, Illinois 60450-9765

  • Commonwealth Edison Company Dresden Station Manager 2605 N. 21st Road Marseilles, Illinois 61341-9756 U.S. Nuclear Regulatory Commission Dresden Resident Inspectors Office 6500 N. Dresden Road Morris, Illinois 60450-9766 William D. Leach Manager - Nuclear MidAmerican Energy Company 907 Walnut Street P.O. Box657 Des Moines, Iowa 50303 Vice President - Law and Regulatory Affairs MidAmerican Energy Company One River Center Place 106 E. Second Street P.O. Box 4350 Davenport, Iowa 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, Illinois 61201 Commonwealth Edison Company

  • Chairman Grundy County Board Administration Building 1320 Union Street Morris, Illinois 60450 Commonwealth Edison Company Quad Cities Station Manager 22710 206th Avenue N.

Cordova, Illinois 61242-9740 Commonwealth Edison Company Site Vice President - Quad Cities.

22710 206th Avenue North Cordova, Illinois 61242-97 40 U.S. Nuclear Regulatory Commission Quad Cities Resident Inspectors Office 22712 206th Avenue N.

Cordova, Illinois 61242 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 W. Randolph Street, Suite 12 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission LaSalle Resident Inspectors Office 2605 N. 21st Road Marseilles, Illinois 61341-9756 Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Chairman Illinois Commerce Commission Leland Building 527 E. Capitol Avenue Springfield, Illinois 62706

0. Kingsley Commonwealth Edison Company LaSalle Station Manager 2601 N. 21st Road Marseilles, Illinois 61341-9757 Commonwealth Edison Company Site Vice President - LaSalle 2601 N. 21st Road Marseilles, Illinois 61341-9757 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, Illinois 60601 Dr. Cecil Lue-Hing Director of Research arid Development Metropolitan Sanitary District of Greater Chicago 100 E. Erie Street Chicago, Illinois 60611 Mr. David Helwig Senior Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, Illinois 60515 Mr. Gene H. Stanley
  • PWR Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, Illinois 60515 Mr. Christopher Crane BWR Vice President Commonwealth Edison Company Executive Towe rs West Ill 1400 Opus Place, Suite 900 Downers Grove, Illinois 60515 Commonwealth Edison Company Mr. R. M. Krich Vice President - Regulatory Services Commonwealth Edison Company Executive Towe rs West Ill 1400 Opus Place, Suite 500.

Downers Grove, Illinois 60515 Commonwealth Edison Company Reg. Assurance Supervisor - Byron 4450 N. German Church Road Byron, Illinois 61010-9794 Commonwealth Edison Company

  • Reg. Assurance Supervisor - Braidwood RR 1, Box 84 Braceville, Illinois 60407-9619 Commonwealth Edison Company Reg. Assurance Manager - Dresden 2605 N. 21st Road Marseilles, Illinois 61341-9765 Commonwealth Edison Company Reg. Affairs Manager - Quad Cities 22710 206th Avenue North Cordova, Illinois 61242-9740 Commonwealth Edison Company Reg. Assurance Supervisor -LaSalle 2601 N. 21st Road Marseilles, Illinois 61341-9757 Ms. Pamela B. Stroebel Senior Vice President and General Counsel Commonwealth Edison Company P.O. Box767 Chicago, Illinois 60690-0767

REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE TO GENERIC LETTER 96-05

1.

In.separate NRC inspection reports, the NRC staff closed its review of the motor-operated valve (MOV) program implemented at each operational station in response to Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance." In these inspection reports, the NRC staff discussed certain aspects of the licensee's MOV program to be addressed over the long-term. Commonwealth Edison Company (Com Ed) should describe the actions taken to address the specific long-term aspects of the MOV program as noted in the NRC inspection reports for each of the five ComEd stations.

Examples from the NRC MOV program inspection reports for each of the operational ComEd stations are given beginning on the following page.

2.

The Joint Owners Group (JOG) program focuses on the potential age-related increase in the thrust or torque required to operate valves under their design-basis conditions. In the NRC safety evaluation on the JOG program dated October 30, 1997, the NRC staff specified that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. ComEd should describe the plan at each of it's five operational nuclear stations for E!nsuring adequate ac and de MOV motor actuator output capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement 1.

3.

In a letter dated August 24, 1998, ComEd updated its commitment to implement the JOG Program on MOV Periodic Verification at its five operational nuclear stations in response to GL 96-05. The JOG program specifies that the methodology and discrimination criteria for ranking MOVs according to their safety significance are the responsibility of each participating licensee. In a previous letter dated March 15, 1997, the licensee stated that the ranking of MOVs at its nuclear stations (including Byron and Braidwood) matched the

-Boilin.g Water Reactor Owners' Group (BWROG) methodology as described in BWROG Topical Report NEOC-32264, "Application of Probabilistic Safety Assessment to Generic Letter 89-10." As Byron and Braidwood are pressurized water reactor (PWR) nuclear plants designed by Westinghouse, the licensee should describe the application of the BWROG methodology to Byron and Braidwood, including (1) the preparation of a sample list of high-risk MOVs from other Westinghouse nuclear plants, and (2) consideration of the GOnditions and limitations discussed in the NRC safety evaluation dated February 27, 1996, on the BWROG methodology. In respqnding to this request, the licensee might apply insights from the guidance provided in the Westinghouse Owners' Group (WOG)

Engineering Report V".'EC-1658-A (Revision 2, dated August 13, 1998), "Risk Ranking Approach for Motor-Operated Valves in Response to Generic Letter 96-05," and the NRC safety evaluation dated April 14, 1998, on the WOG methodology for risk ranking MOVs at Westinghouse-designed pressurized water reactor (PWR) nuclear plants.

ENCLOSURE

o~ Kingsley EXAMPLES FROM THE INSPECTION REPORT FOR EACH STATION NRC Inspection Report No. 50-454 & 455/96003 for Byron:

(1) additional evaluation was needed to determine the acceptability of removing four service water strainer backwash MOVs from the GL 89-10 program scope; (2) the licensee was evaluating 11 low margin MOVs for future margin improvements; (3) the setup calculations for several MOVs did not account for high ambient temperature effects on the output of ac motors identified in a 10 CFR Part 21 notice prepared by Limitorque Corporation; (4) valve-specific information was needed to justify valve factors for any non-dynamically

  • tested MOVs that do not use the bounding values provided in the licensee's applicable white paper on the rising stem data sheets; (5) the licensee was to monitor industry information that may be applicable to its Borg Warner valves; and (6) diagnostic testing of 44 butterfly valves was scheduled for the next three refueling outages.

NRC Inspection Report No. 50-456 & 457/96009 for Braidwood:

(1) the licensee was relying on a valve degradation margin to offset a weakness in the valve factors used by rising stem data sheets for some non-dynamically tested MOVs; (2) the licensee planned to revise the minimum required thrust determination contained in procedure BWHS 4002-061, "Rising Stem Motor Operated Valve Diagnostic Test (Gate and Globe Valves)" to properly account for variations in torque switch repeatability; (3) the licensee had developed a plan to resolve torque switch repeatability issues for residual heat removal (RHR) pump miniflow control valves 1 RH611 and 2RH61 O; and (4) diagnostic testing of 15 butterfly valves was planned for the next two refueling outages.

NRC Inspection Report No. 50-237 & 249/96015 for Dresden:

(1) the licensee established a margin improvement plan for severaf MOVs, including Crane MOVs that used flow isolation valve factors; (2) additional industry information was needed to justify valve factors for Anchor/Darling double disc gate valves under high temperature applications; (3). a long-term valve factor basis was needed for 28" Crane flex-wedge gate valves 2-202-05A/B and 3-202-05A/B; and (4) the Dresden MOV program would be revised to account for concerns regarding load sensitive behavior in the valve opening direction.

NRC Inspection Report No. 50-254 & 265/95018 for Quad Cities:

(1) the licensee established a margin improvement plan for several MOVs, including Crane MOVs that used flow isolation valve factors; (2) additional industry information was needed to justify valve factors for Anchor/Darling double disc gate valves under high temperature applications; (3) a long-term valve factor basis was needed for 28" Crane flex-wedge gate valves 2-202-05A/B; (4) the rising-stem data sheets would be revised to account for concerns regarding load sensitive behavior in the valve opening direction; and

0. Kingsley (5) the licensee would revise its white papers to ensure that current MOV switch settings are reviewed. when the thrust windows on rising-stem data sheets are modified.

NRC Inspection Report No. 50-373 & 374/95009 for LaSalle:

(1) the licensee stated that marginal MOVs (including 1E12-F017B)would be modified during the next outage to improve thrust margins:

(2) several globe valve calculations required revisions to incorporate guide-based area terms; and (3) the licensee planned to review the NRC safety evaluation (dated March 15, 1996) on the methodology developed by the Electric Power Research Institute (EPRI) to predict the torque required to operate butterfly valves..