ML19332D126
| ML19332D126 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/10/1989 |
| From: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, NUDOCS 8911300043 | |
| Download: ML19332D126 (2) | |
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Yg OPU Nuclear Corporation -
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N' U.SC Nut,learLRegulatory Commission
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'4 Dear Sirs j
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By ' letter. dated October 3,g 1989, GP'1 Nuclear responded as required.to. Generic'
'L6t.ter.89-04~" Guidance on Developing Acceptable Inservice Testing Programs". At the' request <ofJtheiUSNRC, a conserence--call was held on October 12,'1989 to-
, (clarify and expand upon-the~ GPUN :;esponse. This'lettar is being written te f
,' document;the results of the October 12,,1989 conversation.
'The NRC; questioned why the October 3, 1989-response primarily described the status-of on-going; work'in the{ Inservice Testing'(IST) review, and was not more finalized
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,1 11n3 content.: GPUN-answered that.the present review was performed by comparingLthe p.\\
- f requiremer.ts.of,GL 89-04'with the existing IST program (ASME'XI, 1974 edition with M aummer?1975'addendc), Land.with the requirements of the code which is' presently 1 anticipated to;be effective.for the 10 year. update (OM6 and-OM10). ' Application of l
these new requirements:may change the: scope of the IST program both in number of j
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, ; components 1ano testing requirements. As the review of. systems, components and 1
requirements continues,. differences are being identified between the program i
s written to the original code and the new version of the; code. Additioral 3
Leomponents have been identified =which were not within the scope'of thelexisting
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program,1but-needed to be included for Generic Letter 89-04 considerations. -This Enecessitated the d3velopment of new procedures and" caused scheduling. c.fianges.
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.other components'which'are presently in the IST program would be deleted or
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subject,to different test criteria per the new Code edition.- Therefore, hardware imodificationsLperformed, solely for the purpose of complying with the intent of GL 89-041are unwarranted inLthat some of these-modifications would be unnecessary to-
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comply with the 10 year update.
h As' described in'the GPUN submittal of October 3, 1939 and restated during tne y
ucctober-13, 1989. conference call, GPUN has integrated the Generic Letter response Linto'the 10: year' update, thereby providing a continually improving program.
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intent of the October 3, 1989 letter was not to finalig.e the results of the Lreviews but rather to-provide.the NRC with: 1) the status of work accomplished; and 2)' the scheduid for work remaining.
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/On December'2,.19 %, the NRC issued its safety evaluation of the1IST Program, Rev. 4.' 'GPUNl addressed the.NRC :roncerns'in the safety evaluation at.d submitted.
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.Rev. 5 as: requested.by the.NRC.
As a' result of thel changes to the program-4
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. required by the Generic Letter and preparation.for the 10 year update, the existing testing'may not be performed in. full conformance with the preeint IST program. JTherefore, CPUN. committed during the' conference call to submitting i
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Revision 6 toithe IST-program by August 3, 1990. Revision 6:will include those-procedural and scope changes required-to comply with'GL 89-04, except for those changes which may-require hardware modifications.
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. determined to be required for either:the Generic Letter'89-04 requirements or inext 10 year update will be' addressed in the 10 year update submittal.
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- Finally, the'NRC noted that ag procedures 1are rewritten to mee,t new
' requirements, they'may temporarily conflict with exieting'requit'ements..GPUN' y
- concurred,.but stated ths,t the; evolutionary nature of major-programmatic-
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[ upgrades always results in an interim period when previous requirements and
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. future requirements conflict. GPUN will-continue to revise'its procedures to l%
comply with the GL 89-04. requirements and the ASME Code requirements of our next-10 year update. Although this may result in a procedure which does not fully comply with the existing IST program.at any given point in time, the coverall'effect of the upgrade =to newer Code requirements will result in a-K
-continua 1lyl improving program.
1If.any:further information is required, please contact Mr. John Rogers at
'609-971-4893.-
t Very truly yours,
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Fitzpatrick Vice Presiderit & Director 1-Oyster Creek j g:
EEF/JR/je-1 (11-12):
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.cci Mr. William T. Russell, Administrator j
'd.S. Nuclear Regulatory Comn.ission Region.I
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475 Allendale Road King of' Prussia, PA 19406 Mr.. Alexander W. Dromerick-f' ti.S. Nuclear Regulatory Commission Washington,'DC 20555 NRC Resident Inspector Oyster Creek Nuclear Generating Station
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