ML17328A323
| ML17328A323 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/11/1990 |
| From: | Colburn T Office of Nuclear Reactor Regulation |
| To: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| GL-89-10, TAC-75650, TAC-75651, NUDOCS 9007180082 | |
| Download: ML17328A323 (9) | |
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION WASHINGTON, D. C. 20555 Oul y 11, 1990 Docket Nos. 50-315 and 50-316 Mr. Milton P. Alexich Indiana Michigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Dear Mr. Alexich:
SUBJECT:
RESPONSE
TO GENERIC LETTER 89-10, "SAFETY-RELATED MOTOR-OPERATED VALVE (MOV) TESTING AND SURVEILLANCE" (TAC NOS. 75650 AND 75651)
On June 28, 1989, the NRC issued Generic Letter (GL) 89-10 requesting the establishment of a program to ensure the operability of all safety-related MOVs under design basis conditions.
The program in GL 89-10 significantly expands the scope of the program outlined in NRC Bulletin 85-03 and its supplement.
The schedule provided in the GL requested that a description of your MOV program be available for review by June 28, 1990, or the first refueling outage after December 28, 1989, whichever was later.
Information that should be contained in your program description was discussed during the workshops held in September 1989.
The staff positions on questions presented during the workshops have been issued in the form of a supplement to the GL.
As your program is developed, justification for any differences between your program and the GL exemplified by the meeting minutes should be incorporated into your program description.
On December 29, 1989, you submitted a response to GL 89-10, regarding the D. C.
Cook Nuclear Plant.
The staff has provided several comments on your submittal below.
In your response to item a of the GL, you state that, because the emergency core cooling system includes consideration of single active component failures inadvertent MOV mispositioning is already addressed in the existing design basis for that system at D.C. Cook.
The staff position on inadvertent MOV operation is documented in the GL supplement.
In your response to item c of the GL, you indicated that MOVs which cannot be tested in situ under design-basis conditions will be grouped in an effort to apply test data from one MOV to another YIOV within the group. If you cannot justify the application of test data to an YiOV, the staff recommends that you use the two stage approach by selecting switch settings for that particular MOV based on the best data available and then working to obtain applicable test 9007180082 5'00711 PDR 4DOCK 05000315 P
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e data as soon as possible.
Your statement that, where applicable test data are not available, "the extrapolated stroke tests will constitute the verification of operability" may need further evaluation to determine whether this approach actually addresses the GL concerns.
The two stage approach is intended to allow licensees to set the NOV switches in the best possible manner until applicable test data become available.
The operability of each MOV will not be considered verified until test data that are justifiably applicable to that NOV are obtained.
In your response to Item i of the GL, you commit to meeting the schedule for many HOVs in the program; however, you indicate that the program might not be complete until 1996 for certain NOVs.
The staff believes that the verification of NOV operability must not be. delayed beyond the GL schedule to any significant extent.
For those MOVs that might not be demonstrated to be operable under design-basis conditions until 1996, the staff recommends that you use the two stage approach to set the switches of those MOVs using the best data available within the GL schedule.
You should then complete the operability verification of those MOVs by the end of 1996.
On page 8 of your response, you indicate that testing of NOVs in situ under design-basis conditions might not be practicable in many instances.
The staff noted this possibility in the GL and discussed several alternatives at the workshops, including the factors that need to be considered if one of those alternatives is selected.
You state that, if design-basis testing is not practicable and applicable tests are not available, analytical methods and extrapolations to design basis conditions will be used to verify operability.
The staff, however, will accept analytical methods and extrapolations of data only if appropriately justified. If testing of an MOV in situ under design-basis conditions is not practicable and the use of an alternative method cannot be justified, we recommend that you use the two stage
- approach, working to obtain applicable test data as soon as possible.
On page 9 of your response, you indicate that for instances where testing of an MOV in situ under design-basis conditions is not practicable the HOVs will be grouped to determine if design-basis test data may be applied from another MOV within the group.
Additionally, you state that only one NOV in the group would be tested to establish the operating characteristics for all MOVs in that group.
Recent research results and operating experience,
- however, have demonstrated that similar HOVs might not perform in the same manner under design-basis conditions.
You will be expected to justify any application of test data from one MOV to another in your program description.
The staff also disagrees with the your assertion that generic and valve specific problems can be identified through stroke testing with diagnostic equipment, extrapolation of data, and comparison with test results from similar valves.
The staff does not believe that the operating characteristics of HOVs under various conditions are understood sufficiently to make such a broad statement.
Your program description should be retained on-site for possible further XRC staff review.
Sincer ely, cc:
See next page Timothy Colburn, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation
Mr. Ni 1 ton A 1 ex i ch Indiana Michigan Power Company Donald C.
Cook Nuclear Plant CC:
Regional Administrator,. Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Michigan 48913 Township Super visor Lake Township Hall Post Office Box 818 Bridgman, Michigan 49106 Al Blind, Plant Manager Donald C. Cook Nuclear Plant Post Office Box 458 Bridgman, Michigan 49106 U.S. Nuclear Regulatory Commission Resident Inspectors Office 7700 Red Arrow Highway Stevensvi lie, Michigan 49127 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 I> Street, H.H.
Washington, DC 20037 Mayor, City of Bridgman Post Office Box 366 Bridgman, Michigan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3500 N. Logan Street Post Office Box 30035 Lansing, Michigan 48909 Nr. S.
Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Your program description should be retained on-site for possible further NRC staff review.
Sincerely, cc:
See next page Timothy Colburn, Project Hanager Project Directorate III-1 Division of Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation DISTRIBUTION ICRETFKE~
JzIIDLIIIMI NRC 5 LOCAL PDR PSHUTTLENORTH EJORDAN ACRS(10)
PD31 R/F AGODY, JR OGC LMARSH See previous conccurrence*
LA/PD31:DRSP*
PN/PD31:DRSP PSHUTTLEMORTH TCOLBURN 6/18/90 7/
/90 (A)D/PD31:DRSP*
ENEB*
RPIERSON LBHARSH 6/18/90 6/18/90 COOK GL 89-10 REPONSE DUP
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Your program description should be retained on-site for possible further NRC staff review.
Sincerely, cc:
See next page Timothy Colburn, Project Hanager Project Directorate III-1 Division of Reactor Projects - III, IY, V 8 Special Projects Office of Nuclear Reactor Regulation DISTRIBUTION.
OCRET7EE JzNDLINKKI NRC 5 LOCAL< PDR PSHUTTLEMORTH EJORDAN ACRS(10)
PD31 R/F OGC AGODY', JR LHARSH See previous conccurrence*
LA/PD31:DRSP*
PN/PD31 DRSP PSHUTTLEMORTH TCOLBURN 6/18/90 7/
/90 (A)D/PD31:DRSP*
ENEB*
RPIERSON LBMARSH 6/18/90 6/18/90 COOK GL 89-10 REPONSE DUP