ML17328A766
| ML17328A766 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/01/1990 |
| From: | Colburn T Office of Nuclear Reactor Regulation |
| To: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| GL-89-10, IEB-85-003, IEB-85-3, TAC-75650, TAC-75651, NUDOCS 9011130310 | |
| Download: ML17328A766 (8) | |
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%~*y4 UNITEDSTATES
,NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 November 1,
1990 Docket tIos. 50-315 and 50-316 Mr. llilton P. Alexich, Vice President Indiana Yichigar Power Company c/o Amer icar, Electri c Power Service Corporatiori 1 Riverside Plaza
- Colunbus, Ohio 43216
Dear Yir. Alexich:
SUBJECT:
RESPONSE
TO GENERIC LETTER 89-10, "SAFETY-RELATED MOTOR-OPERATED VALVE (YOV) TESTING AND SURVEILLANCE" (TAC NOS. 75650 AND 75651) h On June 28, 1989, the NRC issued Generic Letter (GL) 89-10 requesting licerisees to establish a program to ensure the capability of all safety-related YOVs urider desior: basis coriditions.
The program iri GL 89-10 sigriificaritly expands the scope of the progran outliried in NRC Bulletin 85-03 arid its supplement.
The schedule provided iri the generic letter requested that a descriptiori of your MiOV prooran:
be available for review by June 28, 1990, or the first refuelirig outage after Decenber 2S, 1989, whichever was 1ater.
Due to delays in issuing supp1enierit 1 of the generic letter, the staff stated in Supplenierit 2 that i>>spectioris of Generic Letter S9-10 programs will be delayed until at least January 1, 1991.
Inforn.ation that should be coritained in your progran.
descriptior v.'as discussed duririg the workshops held in September 1989.
Staff positions ori questions presented during the workshops are currently available as supplement 1 to the gerieric letter.
As your YiOV prograni is developed, justification for arp differences between your program arid the GL as clarified by supplement 1 should be incorporated into your program descriptior>.
Ori Decerrber 29, 1989, you subniitted a response to GL 89-10, regardino the D, C.
Cook Nuclear Plant.
The staff has provided several conn'erits on your subrrittal below.
You indicateo that, for YiOVs that caririot be tested in situ under design-basis corditioris, those YOVs v'ill be grouped in ari effort to apply test data fron: orie YOV to.another MiGV iri the group.
The staff reconimends that, if you cannot justify the application of test data to an MOV, you follow the two-stage
- approach, by selectirig switch settings for that particular YiOV based on the best data available and then working to obtairi applicable test data as soon as possible.
Your statemert that, where applicable test data is not available, "the extrapolated stroke tests will constitute the verification of operability" may need further evaluation as to whether that approach actually addresses the GL concerns.
The two-stage approach is intended to allow licensees to set the ttOV switches in the best possible n.armer until applicable test data beconies available.
The capability of the YOV will not be considered verified until the test data that is justifiably applicable to that MOV is obtairied.
Iri your resporise to Item i of the generic letter, you commit to neeting the gerieric letter schedule for many YCVs in the progran;,
however, you iridicate that the progran; n'ight riot be conipleted until 1996 for certain YiOVS.
The staff 9011130310 901101 PDR ADOCK 05000315 P
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Yr. Viilton P. Alexich believes that the verification of RGV capability must rot be delayed beyond the GL schedule to ary sigr:ificarit exterit.
For those VGVs whose capability a;ight not be den<<nstvated urider design-basis coriditions uritil 1996, tte staff recoreerids thai, you use the two-stage approach to set the switches of those YOVs usirig the best data available within the GL schedule.
You should theri complete the capability verificatiori of these YiOVs by the end of 1996.
Ori page 8 of your response, you iridicate that. testing on NGVs in situ under desigri-basis coriditiors rright not be practicable in nany instarices.
The staff rioted this possibility ir the generic letter arid discussed several alternatives at the workshops, iricluding the factors that riced to be considered if one of those alternatives is selected.
Your response states that, if design-basis testirig is riot practicable and applicable test data is not available, "analytical oiethods and extrapolations to desigr basis coriditions will be used to verify operability."
The staff, however, will accept arialytical methods arid extrapolatioris of data only if appropriately justified, If testirig of an VGl iri situ urider desigr:-basis conditiors is riot practicable and the use of ar:
alterrative ne4tiod caririot be justified, vie reconnend that you use the two-stage apIroach to select VOV switch settirigs based on the best data available, theri working to obtain applicable test data as soon as possible.
On page 9 of your resporise, you indicate that, for iristances where testiric cf an h'Cl ir. situ urider'esigr-basis corditions is rot practicable, the HOVs will be grouped to deterriirie if desigri-basis test data nay be applied fron: ariother.
YCV in the group.
Additiorally, ycu state that only ore VOV iri a group would be tested t<oke testitic v,ith diagricstic equipnent, extrapolatiori of data, ano coopar'isor'ith test results fron. similar valves.
The staff does not believe that the operatirig characteristics of YOVs urder vari>us conditions are uride>stood sufficiertly to riake such a broad statement.
Your prograni descriptior. should be retainec cn-site for possible further NRC staff review. If you have any questions, please contact me at (301) 492-1341.
Sincerely, cc:
See riext page Timothy G. Colburn, Sr. Project Hanager Project Directorate III-I Divisior of Reactor Projects - III, IV, V 5 Special Projects Offi ce of Nu c 1 ea r Rea ctor Regu1 at ion
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Yr. Yiilton Alexich Indiana Yichigan Power Company Donald C.
Cook. huclear Plant cc:
Reg iona l Ada inistra tor, Reg ion II I U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attorney General Department of Attorney General 525 l.'est Ottawa Street Lanising, Yichigan 48913 Township Supervisor Lake Township Hall Post Office Box 818 Bridgman, Vichigan 49106 Al Blinc, P'ant Vianager Donald C.
Cool f'uclear Flart Post Office Box 458 Bridgman, t'ichigan 49106 U.S. Nuclear Reculatory Commissicn Resident Irspecturs Office 77CO Ped Arrow Highway Steversville, Yichigan 49127 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 t~ Street, P.l~.
Nashingion, DC 20037 Yayor, City of Br idgman Post Office Box 366 Bridgrran, Yiichigan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Nichigan 48909 huclear Facilities arid Environmental Yonitoring Section Office Division of Radiological Health Department of Public Health 3500 N. Logan Street Post Office Box 30035 Lansing, Yiichigan 48909 Yir. S. Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Yir. Y.ilton P. Alexich believes that the verification of HGV capability niust nct be delayed beyond the GL schedule to any significant extent.
For those YiGVs whose capability night not be den'onstrated urider design-basis conditions until 1996, the staff recore ends that ycu use the two-stage approach to set the switches of those YGVs using f,he best data available withir. the GL schedule.
You should then complete the capability verification of these YiOVs by the end of 1996.
Gr page 8 of your response, you indicate that testing on YOVs in situ under desig(i-basis conditior s n:ight not be practicable in n any instances.
The staff noted this possibility in the generic letter arid discussed several alternatives at the workshops, including the factors that need to be considered if one cf those alterratives is selected.
Your response states that, if design-basis testing is not practicable and applicable test data is not available, "analytical niethods ard extrapolations to design basis conditions will be used to verify operability."
The staff, however, will accept analytical methods and extrapolations of data orly if appropriately justified. If testing of an YGV in situ under desior.-basis condft,ious is not practicable and the use of an alterr.ative niethod cannot be 'ustified, we reconnend that you use the tvo-staoe approach to select YiGV switch settings based or the best data available, then working to obtain applicable test data as soori as possible.'n page 9 of your response, ycu irdicate that, for instances vihere testing cf an YCV ir situ under desigr,-basis conditions is not practicable, the YOVs will be grouped
$ c detern:inc if design-basis test data niay be appliecl fron: another YCV in the group.
Additionally, ycu state that only one YCV in a group would be test<<~i to establish the operating characteristics for all YiGVs in that group.
Recent r<<search results arid operatirg experience,
- hcvever, have; dencnstrated that sinilar YGVs may nct perform in the sanie niar:rer urider design-basis conditions.
Ycu v,ill be expected tc iustify ary applicaficri of fest data from or)e fiGV to another iri ycur program descriptior.
The staff also disagrees v'ith ycur assertion that generic and valve specific prob'.ems can be identified through stroke testing v,ith diagnostic equipnent, extrapclation of data, ard conparison with test results from similar valves.
The staff does riot believe that the operating characterisiics cf YOVs urder various ccriditions are undersfood sufficieritly to nake such a broad statement, Your progran descriptior should be retained cn-site for pcssibl>> further fiRC staff review. If ycu have any ouesticns, please contact me at (301) 492-1341.
Sincerely,
/s/
cc:
See next paoe Tin'othy G. Colburn, Sr. Project Yianager Project Directorate III-1 Divisicn cf Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation See previcus ccr currence*
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Vir. Milton P. Alexich 2>>
believes that the verification of HOV capability must not be delayed beyond the GL schedule to any significant extent.
For those NOVs whose capability might not be demonstrated under design-basis conditions until 1996, the staff recommends that you use the two-stage approach to set the switches of those ViOVs usino the best data available within the GL schedule.
You should then complete the capability verification of these tlOVs by the end of 1996.
On page 8 of your response, you indicate that tesCing on NOVs in situ under design-basis conditions might not be practicable in many instances.
The staff noted this possibility in the generic letter and discussed several alternatives at the workshops, including the factors that need to be considered if one of those alternatives is selected.
Your response states that, if design-basis testing is not practicable and applicable test data is not available, "analytical meChods and extrapolations to design basis conditions will be used to verify operabi lity."
The staff, however, will accept analytical methods and extrapolations of data only if appropriately justified. If testing of an NOV in situ under design-basis conditions is noC practicable and the use of an alternative method cannot be justified, we reconmend that you use the two-stage approach to select NOV switch settings based on the best data available, then 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 KOV in situ under design-basis conditions is not practicable, the NOVs will be grouped to determine if design-basis test data may be applied from another YOV in the group.
Additionally, you state that only one YiOV in a group would be tested to establish the operating characteristics for all ttOVs in that group.
Recent research results and operating experience,
- however, have demonstrated that similar NOVs may not perform in the same manner under design-basis conditions.
You will be expected to jusCify any application of test data from one NOV to another in your program description.
The staff also disagrees with your assertion that generic and valve specific problems can be identified through stroke testing with diagnostic equipment, extrapolation of data, and comparison wiCh test results from similar valves.
The staff does not believe thaC Che operating characteristics of ViOVs under various conditions are understood sufficiently to make such a broad statement.
Your program description should be retained on-site for possible further NRC staff review. If you have any questions, please contact me at (301) 492-1341.
Sincerely,
/s/
Timothy G. Colburn, Sr. Project Nanager Project Directorate III-1 Division of Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation cc:
See next page See previous concurrence~
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