ML17284A897
| ML17284A897 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/18/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17284A896 | List: |
| References | |
| GL-96-05, NUDOCS 9910260055 | |
| Download: ML17284A897 (16) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATIONBY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE RESPONSE TO GENERIC LETTER 96-05 "PERIODIC VERIFICATIONOF DESIGN-BASIS CAPABILITYOF SAFETY-RELATED MOTOR-OPERATED VALVES" ENERGY NORTHWEST--
WNP-2 DOCKET NO. 50-397
1.0 INTRODUCTION
Many fluid systems at nuclear power plants depend on the successful operation of motor-operated valves (MOVs) in performing their safety functions. Several years ago, MOV operating experience and testing, and research programs sponsored by the nuclear industry and the U. S. Nuclear Regulatory Commission (NRC), revealed weaknesses in a wide range of activities (including design, qualification, testing, and maintenance) associated with the performance of MOVs in nuclear power plants.
For example, some engineering analyses used in sizing and setting MOVs did not adequately predict the thrust and torque required to operate valves under their design-basis conditions.
In addition, inservice tests of valve stroke time under zero differential-pressure and flow conditions did not ensure that MOVs could perform their safety functions under design-basis conditions.
Upon identification of the weaknesses in MOV performance, significant industry and regulatory activities were initiated to verify the design-basis capability of safety-related MOVs in nuclear power plants. After completion of these activities, nuclear power plant licensees began establishing long-term programs to maintain the design-basis capability of their safety-related MOVs. This safety evaluation (SE) addresses the program developed by Energy Northwest (licensee) to verify periodically the design-basis capability of safety-related MOVs at WNP-2.
2.0 REGULATORY RE UIREMENTS The NRC regulations require that MOVs important to safety be treated in a manner that provides assurance of their intended performance.
Criterion 1 to Appendix A, "General Design Criteria for Nuclear Power Plants," to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) states, in part, that structures, systems, and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed.
The quality assurance program to be applied to safety-related components is described in Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 99'L0260055 99iQi8 PDR ADOCK 05000397 P
1 j
In Section 50.55a of 10 CFR Part 50, the NRC requires licensees to establish inservice testing (IST) programs in accordance with Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.
In response to concerns regarding MOV performance, on June 28, 1989, the NRC staff issued Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance,"
which requested that nuclear power plant licensees and construction permit holders ensure the capability of MOVs in safety-related systems to perform their intended functions by reviewing MOVdesign bases, verifying MOVswitch settings initiallyand periodically, testing MOVs under design-basis conditions where practicable, improving evaluations of MOV'failures and necessary corrective action, and trending MOV problems.
The staff requested that licensees complete the GL 89-10 program within approximately three refueling outages or five years from the issuance of the generic letter. Permit holders were requested to complete the GL 89-10 program before plant startup or in accordance with the above schedule, whichever was later.
The NRC staff issued seven supplements to GL 89-10 that provided additional guidance and information on MOVprogram scope, design-basis reviews, switch settings, testing, periodic verification, trending, and schedule extensions.
GL 89-10 and its supplements provided only limited guidance regarding MOV periodic verification and the measures appropriate to assure preservation of design-basis capability. Consequently, the staff determined that additional guidance on the periodic verification of MOVdesign-basis capability should be prepared.
On September 18; 1996, the NRC staff issued GL 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," requesting each licensee to establish a program, or ensure the effectiveness of its current program, to verify on a periodic basis that safety-related MOVs continue to be capable of performing their safety functions within the current licensing bases of the facility. In GL 96-05, the NRC staff summarized several industry.
and regulatory activities and programs related to maintaining long-term capability of safety-related MOVs. For example, GL 96-05 discussed.non-mandatory ASME Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor Operated Valve Assemblies in LWR Power Plants, OM Code 1995 Edition; Subsection ISTC," which allows the replacement of ASME Code requirements for MOVquarterly stroke-time testing with exercising of safety-related MOVs at least once per operating cycle and periodic MOVdiagnostic testing on a frequency to be determined on the basis of margin and degradation rate.
In GL 96-05, the NRC staff stated that the method in OMN-1 meets the intent of the generic letter with certain limitations. The NRC staff also noted in GL 96-05 that licensees remain bound by the requirements in their code of record regarding MOVstroke-time testing, as supplemented by relief requests approved by the NRC staff.
In GL 96-05, licensees were requested to submit the following information to the NRC:
a.
within 60 days from the date of GL 96-05, a written response indicating whether or not the licensee would implement the requested actions; and b.
within 180 days from the date of GL 96-05, or upon notification to the NRC of completion of GL 89-10 (whichever is later), a written summary description of the licensee's MOV periodic verification program.
The NRC staff is preparing an SE on the response of each licensee to GL 96-05. The NRC staff intends to rely to a significant extent on an industry initiative to identify valve age-related degradation which could adversely affect the design-basis capability of safety-related MOVs (described in Section 3.0) where a licensee commits to implement that industry program.
The NRC staff will conduct inspections to verify the implementation of GL 96-05 programs at nuclear power plants as necessary.
3.0 JOINT OWNERS GROUP PROGRAM ON MOV PERIODIC VERIFICATION In response to GL 96-05, the Boiling Water Reactor Owners Group (BWROG), Westinghouse Owners Group (WOG), and Combustion Engineering Owners Group (GEOG) jointlydeveloped an MOVperiodic verification program to obtain benefits from the sharing of information between licensees.
The Joint Owners Group (JOG) Program on MOV Periodic Verification is described by the BWROG in its Licensing Topical Report NEDC-32719, "BWR Owners'roup Program on Motor-Operated Valve (MOV) Periodic Verification," and described by the WOG and the GEOG in their separately submitted Topical Report MPR-1807, "Joint BWR, Westinghouse and Combustion Engineering Owners'roup Program on Motor-Operated Valve (MOV) Periodic Verification." The stated objectives of the JOG program on MOV Periodic Verification are (1) to provide an approach for licensees to use immediately in their GL 96-05 programs; (2) to develop a basis for addressing the potential age-related increase in required thrust or torque under dynamic conditions; and (3) to use the developed basis to confirm, or ifnecessary to modify, the applied approach.
The specific elements of the JOG program are (1) providing an "interim" MOVperiodic verification program for applicable licensees to use in response to GL 96-05; (2) conducting a dynamic testing program over the next 5 years to identify potential age-related increases in required thrust or torque to operate gate, globe, and butterfly valves under dynamic conditions; and (3) evaluating the information from the dynamic testing program to confirm or modify the interim program assumptions.
The JOG interim MOV periodic verification program includes (1) continuation of MOV stroke-time testing required by the ASME Code IST program; and (2) performance of MOV static diagnostic testing on a frequency based on functional capability (age-related degradation margin over and above margin for GL 89-10 evaluated parameters) and safety significance.
In implementing the interim MOV static diagnostic test program, licensees willrank MOVs within the scope of the JOG program accor'ding to their safety significance.
The JOG program specifies that licensees need to justify their approach for risk ranking MOVs. In Topical Report NEDC 32264, "Application of Probabilistic Safety Assessment to Generic Letter 89-10 Implementation," the BWROG described a methodology to rank MOVs in GL 89-10 programs with respect to their relative importance to core-damage frequency and other considerations to be added by an expert panel.
In an SE dated May 20, 1996, the NRC staff accepted the BWROG methodology for risk ranking MOVs in boiling water reactor nuclear plants with certain conditions and limitations.
In the NRC SE (dated October 30, 1997) on the JOG Program on MOV Periodic Verification, the NRC staff indicated its view that the BWROG methodology for MOV risk ranking is appropriate for use in response to GL 96-05. With respect to Westinghouse-designed pressurized water reactor nuclear plants, the WOG prepared Engineering Report V-EC-1658, "Risk Ranking Approach for Motor-Operated Valves in
Response
to Generic Letter 96-05." On April 14, 1998, the NRC staff issued an SE accepting with certain conditions and limitations the WOG approach for ranking MOVs based on their risk
4, significance.
Licensees not applicable to the BWROG or WOG methodologies need to justify their MOV risk-ranking approach individually.
The objectives of the JOG dynamic test program are to determine degradation trends in dynamic thrust and torque, and to use dynamic test results to adjust the test frequency and method specified in the interim program ifwarranted.
The JOG dynamic testing program includes (1) identification of conditions and features which could potentially lead to MOV degradation; (2) definition and assignment of valves for dynamic testing; (3) testing valves three times over a 5-year interval with at least a 1-year interval between valve-specific tests according to a standard test specification; (4) evaluation of results of each test; and (5) evaluation of collective test results.
In the last phase of its program, the JOG willevaluate the test results to validate the assumptions in the interim program to establish a long-term MOV periodic verification program to be implemented by licensees.
A feedback mechanism willbe established to ensure timely sharing of MOVtest results among licensees and to prompt individual licensees to adjust their own MOV periodic verification program, as appropriate.
Following consideration of NRC staff comments, the BWROG submitted Licensing Topical Report NEDC-32719 (Revision 2) describing the JOG program on July 30, 1997.
Similarly, the CEOG and the WOG submitted Topical Report MPR-1807 (Revision 2) describing the JOG program on August 6 and 12, 1997, respectively.
On October 30, 1997, the NRC staff issued an SE accepting the JOG program with certain conditions and limitations as an acceptable industry-wide response to GL 96-05 for valve age-related degradation.
4.0 WNP-2 GL 96-05 PROGRAM On November 7, 1996, Energy Northwest submitted a 60-day response to GL 96-05 notifying the NRC that it would implement the requested MOV periodic verification program at WNP-2.
On March 13, 1997, the licensee submitted a 180-day response to GL 96-05 providing a summary description of the MOV periodic verification program planned to be implemented at WNP-2.
In a letter dated May 20, 1998, the licensee updated its commitment to GL 96-05.
On June 4, 1999, the licensee provided a response to a request for additional information regarding GL 96-05 forwarded by the NRC staff on March 26, 1999.
In its letter dated March 13, 1997, the licensee described its MOV periodic verification program, including scope, risk-ranking, test frequency, as-found testing, and implementation of the JOG program at WNP-2. For example, the licensee indicated that the interim MOV static diagnostic test program at WNP-2 applied the same test frequencies as identified in the JOG topical report. The licensee also stated that dynamic testing of selected MOVs would be performed under its MOV periodic verification program.
The licensee stated that adjustments would be made to its GL 96-05 program based on the results of the JOG testing program.
The licensee stated that its MOV periodic verification program would be revised by September 18, 1997, to incorporate the JOG program at WNP-2.
In its letter dated May 20, 1998, the licensee updated its commitment to continue its ongoing participation in the JOG MOV periodic verification program as a member of the BWROG and to implement the program elements described in Topical Report NEDC-32719 (Revision 2) describing the JOG program.
5.0 NRC STAFF EVALUATION The NRC staff has reviewed the information provided in the licensee's submittals describing the program to verify periodically the design-basis capability of safety-related MOVs at WNP-2 in response to GL 96-05.
NRC Inspection Reports 50-397/95-24 (IR 95-24) and 50-397/96-04 (IR 96-04) provided the results of inspections to evaluate the licensee's program to verify the design-basis capability of safety-related MOVs in response to GL 89-10. The staff closed the review of the GL 89-10 program at WNP-2 in IR 96-04 based on verification of the design-basis capability of safety-related MOVs. The staff's evaluation of the licensee's response to GL 96-05 is described below.
5.1 MOV Program Scope In GL 96-05, the NRC staff indicated that all safety-related MOVs covered by the GL 89-10 program should be considered in the development of the MOV periodic verification program.
In GL 96-05, the staff noted that the program should consider safety-related MOVs that are assumed to be capable of returning to their safety position when placed in a position that prevents their safety system (or train) from performing its safety function; and the system (or train) is not declared inoperable when the MOVs are in their nonsafety position.
In its letter dated November 7, 1996, the licensee committed to implement the requested MOV periodic verification program at WNP-2 in response to GL'96-05 and did not take exception to the scope of the generic letter.
In IR 96-04, the NRC staff reviewed the scope of the licensee's MOV program in response to GL 89-10 at WNP-2 and found that the licensee omitted several MOVs from its GL 89-10 program that are stroked to their non-safety position for surveillance or test activities although the licensee considered the system or train to continue to be operable.
In its letter dated March 3, 1997, the licensee indicated that the scope of its MOV program would be revised to be consistent with GL 96-05... In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee described the revised scope of the MOV program at WNP-2. For example, the licensee reported that three safety-related test return MOVs were added to the GL 96-05 MOV periodic verification program scope.
These test return valves are assumed to be capable of returning to their safety position when placed in a position that prevents their associated safety system from performing its required safety function. The licensee noted that these three valves willbe tested as part of its GL 96-05 MOV periodic verification program and will be qualified in accordance with its GL 89-10 program by the end of refueling outage 15 (scheduled for fall 1999).
Each of these three valves is operated on a quarterly basis under full flow conditions during the system's inservice testing surveillance test. The licensee stated that all other test return valves not included in the GL 89-10 program are addressed by declaring the associated safety system inoperable when valves are not in their normal safety position.
The staff considers the licensee to have made adequate commitments regarding the scope of its MOV program.
5.2 MOVAssumptions and Methodologies Licensees maintain their assumptions and methodologies used in the development of its MOV programs consistent with the plant configuration throughout the life of the plant (a concept commonly described as a "living program").
For example, the design basis of safety-related
t I
i' MOVs is maintained up-to-date, including consideration of any plant modifications or power uprate conditions.
In IR 96-04, the NRC staff reviewed the licensee's justification for the assumptions and methodologies used in the MOV program in response to GL 89-10 at WNP-2. The staff determined that the licensee had adequately justified the assumptions and methodologies used in its MOV program with certain long-term aspects discussed in the following section.
The licensee's [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], indicated ongoing activities, such as review of motor actuator output, to update its MOV program assumptions and methodologies.
The staff considers the licensee to have adequate processes in place to maintain the assumptions and methodologies used in its MOV program, including the design basis of its safety-related MOVs.
5.3 GL 89-10 Long-Term Items When evaluating the GL 89-10 program at WNP-2, the NRC staff discussed in IR 96-04 several items of the licensee's MOV program to be addressed over the long term.
In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee reported on the status of those long-term GL 89-10 aspects.
The licensee stated that it (1) completed a formal review of the NRC's SE on the Electric Power Research Institute (EPRI) MOVperformance prediction methodology (PPM) and confirmed that the EPRI MOV PPM calculations were performed in accordance with the conditions and limitations in the SE; (2) revised its MOV operability determination procedures to use GL 89-10 performance parameters; (3) increased the available margin for valve HPCS-MO-15 by adjusting its torque switch setting. The NRC staff also discussed the licensee's revision of its MOVoperability procedures in NRC Inspection Report 50-397/97-13.
In GL 89-10, the NRC staff identified pressure locking and thermal binding as potential performance concerns for safety-related MOVs. The NRC staff completed the review of the licensee's actions in response
. to GL 95-07, "Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," in an SE dated July 15, 1999.
In IR 96-04, the NRC staff discussed qualitative and quantitative aspects of the licensee's program for trending MOVperformance at WNP-2. For example, the licensee reviews MOV diagnostic test data, stroke time, thrust or torque output, coefficient of friction, and valve factor, and uses this information to trend various MOV performance parameters.
The licensee also compares MOVfailures at WNP-2 to industry-wide MOVfailures. The licensee periodically evaluates this information to identify and correct adverse conditions.
In IR 96-04, the NRC staff noted that it willcontinue to monitor the licensee's MOVtrending program.
With the licensee's ongoing MOV activities and trending program, no outstanding issues regarding the licensee's GL 89-10 program remain at WNP-2.
5.4 JOG Program on MOV Periodic Verification In its letter dated May 20, 1998, the licensee updated its commitment to implement the JOG program on MOV periodic verification as described in Topical Report NEDC-32719 (Revision 2).
In an SE dated October 30, 1997, the NRC staff accepted the JOG program as an industry-wide response to GL 96-05 with certain conditions and limitations. The conditions and limitations discussed in the NRC SE dated October 30, 1997, apply to the JOG program at WNP-2. The JOG program consists of the following three phases:
(1) the JOG interim static diagnostic test program; (2) the JOG 5-year dynamic test program;.and (3) the JOG long-term periodic test program.
In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee agreed that a commitment to the JOG program includes all three phases of the program, unless otherwise specified.
The staff considers the commitments by the licensee to implement all three phases of the JOG program at WNP-2 to be an acceptable response to GL 96-05 for valve age-related degradation.
In its letter dated March 13, 1997, the licensee noted that the interim MOVstatic diagnostic testing under the JOG program would be performed on a test frequency based on deterministic and probabilistic methods.
The licensee stated that the static test frequency for all valves in the GL 96-05 program will be the same as specified by th'e JOG program.
In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee stated that grouping willbe used to justify static test intervals beyond 5 years to ensure that valve thrust requirements and actuator output capability are maintained.
In its letter dated March 13, 1997, the licensee indicated that MOV ranking at WNP-2 was assigned based on the MOVrisk-ranking approach and results presented in the BWROG Topical Report NEDC 32264-A. The licensee's expert panel reviewed the risk ranking of each valve to determine ifrisk-ranking adjustments were necessary.
The licensee also conducted deterministic-based reviews of maintenance and test histories.
The BWROG provided an example list of risk-significant MOVs for consideration by each licensee in applying the owners group methodology.
The conditions and limitations discussed in the NRC SE dated February 27, 1996, on the BWROG methodology apply to the JOG program at WNP-2. Based on the licensee's description, the staff considers the licensee's approach in risk ranking MOVs at WNP-2 to be acceptable.
In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee stated that, in the long-term, it willevaluate the use of diagnostic methods that acquire data from the motor control center (MCC) when stroking an MOV under static conditions. The issues to be evaluated for use of MCC test data include:
(1) the correlation between new MCC test data and existing. direct. MOV.data measurements; (2) the relationship between changes in MCC test data and MOVthrust and torque performance; (3) system accuracies and sensitivities to MOVdegradation for both outputs and operating performance requirements; and (4) validation of MOVoperability using MCC testing.
The licensee is tracking industry efforts to validate the effectiveness of MCC testing in meeting the JOG program static testing requirements.
Ifthe results are successful, the licensee might use MCC-based data in performing MOV diagnostic testing at WNP-2.
The JOG program is intended to address most gate, globe and butterfly valves used in safety-related applications in the nuclear power plants of participating licensees.
The JOG indicates that each licensee is responsible for addressing any MOVs outside the scope of applicability of the JOG program.
The NRC staff recognizes that the JOG has selected a broad range of MOVs and conditions for the dynamic testing program, and that significant information willbe obtained on the performance and potential degradation of safety-related MOVs during the interim static diagnostic test program and the JOG dynamic test program. As the test results are evaluated, the JOG might include or exclude additional MOVs with respect to the scope of its program. Although the test information from the MOVs in the JOG dynamic test program might not be adequate to establish a long-term periodic verification program for each MOV outside the scope of the JOG program, sufficient information should be obtained from the JOG dynamic test program to identify any immediate safety concern for potential valve age-related degradation during the interim period of the JOG program.
Therefore, the NRC
staff considers it acceptable for the licensee to apply its interim static diagnostic test program to GL 96-05 MOVs that currently might be outside the scope of the JOG program with the feedback of information from the JOG dynamic test program to those MOVs. In the NRC SE dated October 30, 1997, the NRC staff specifies that licensees implementing the JOG program must determine any MOVs outside the scope of the JOG program (including service conditions) and justify a separate program for periodic verification of the design-basis capability (including static and dynamic operating requirements) of those MOVs.
5.5 Motor Actuator Output The 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 SE dated October 30, 1997, on the JOG program, the NRC staff specifies that licensees are responsible for addressing the thrust or torque delivered by the MOVmotor actuator and its potential degradation.
Although the JOG does not plan to evaluate degradation of motor actuator output, significant information on the output of motor actuators will be obtained through the interim MOV static diagnostic test program and the JOG dynamic test program.
Several parameters obtained during MOV static and dynamic diagnostic testing help identify motor actuator output degradation when opening and closing the valve including, as applicable, capability margin, thrust and torque at control switch trip, stem friction coefficient, load sensitive behavior, and motor current.
In its letter dated March 13, 1997, the licensee indicated that as-found testing will be used to assure adequate actuator output capability for safety-related MOVs at WNP-2 to perform their design-basis functions.
In IR 96-04, the staff noted that the licensee monitors actuator thrust or torque output and stem coefficient of friction, and evaluates any changes in these parameters.
In Technical Update 98-01 and its Supplement 1, Limitorque Corporation provided updated guidance for predicting the torque output of its ac-powered motor actuators.
In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee reported that it had reviewed this information for incorporation into the MOV setpoint calculations at WNP-2. The licensee stated that revisions to its ac-powered motor actuator setpoint calculations will be complete by February 28, 2000. Any MOV operability concerns that might be identified in the future will be processed in accordance with established regulatory requirements and plant-specific commitments.
In its [[letter::05000397/LER-1998-011, :on 980617,ECCS Pump Room Flooding Was Noted Due to FP Sys Pipe Break.Caused by Inadequate Design of FP Sys.Detailed Review of FP Sys Design Was Conducted|letter dated July 17, 1998]], forwarding Technical Update 98-01, Limitorque indicates that a future technical update willbe issued to address the application of dc-powered MOVs. In its [[letter::GO2-99-103, Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs|letter dated June 4, 1999]], the licensee stated that it has evaluated dc-powered motor actuator setpoint calculations, and willcomplete the revisions of those calculations by February 28, 2000.
Until Limitorque provides specific guidance for evaluating dc-powered motor actuators, the licensee is revising the setpoint calculations to incorporate a 0.9 application factor.
The NRC staff considers the licensee to be establishing sufficient means, with ongoing evaluation of new industry information, to monitor MOV motor actuator output and its potential degradation.
i
6.0 CONCLUSION
The NRC staff finds that the licensee has established an acceptable program to verify periodically the design-basis capability of the safety-related MOVs at WNP-2 through its commitment to all three phases of the JOG program on MOV periodic verification and the additional actions described in its submittals.
Therefore, the staff concludes that the licensee is adequately addressing the actions requested in GL 96-05. The staff may conduct inspections at WNP-2 to verify the implementation of the MOV periodic verification program is in accordance with the licensee's commitments; this SE; the SE dated October 30, 1997, on the JOG program on MOV periodic verification; and the SE-dated May 20, 1996, on the BWROG methodology for ranking MOVs by their safety significance.
Principal Contributors:
T. Scarbrough, NRR S. Tingen, NRR I
Date:
0ctober 18, 1999
1 I~
Mr. J..V. Parrish October 18, 1999 This closes the staff's efforts in regards to TAC No. M97119. The staff appreciates your efforts in regard to this matter.
Sincerely, Docket No. 50-397
Enclosure:
Safety Evaluation cc w/encl: See next page ORIG.
SIGNED BY Jack Gushing, Project Manager, Section 2 Project Directorate IV 8 Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation DISTRIBUTION:
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