ML20006A259

Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Util Will Develop Program to Enhance Maint,Analysis & Testing Already Conducted on motor-operated Valves

ML20006A259
Person / Time
Site:	Pilgrim
Issue date:	01/15/1990
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BECO-90-013, BECO-90-13, GL-89-10, NUDOCS 9001260049
Download: ML20006A259 (2)

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'l Pilgnm Nuclear Power station Rocky Hill Road l Plymouth, Massachusetts 02360 i r

I Ralph G. sird BECo 90- 013

- senior vice President - Nuclear January 15, 3990 U.S. Nuclear Regulatory Commission  !

Document Control Desk e Washington, DC 20555 License DPR-35 i Docket 50-293 RESPONSE TO GENERIC LETTER 89-10 SAFETY RELATED MOTOR-OPERATED VALVE TE3 TING AND SURVEILLANCE Boston Edison is submitting the following response to Generic Letter 89-10.

The Generic Letter requested that we advise you of our plan to implement the schedule and recommendations of the Generic Letter. This submittal is being l made in accordance with the provisions of 10CFR50.54(f).

f Boston Edison will develop a program in response to Generic Letter 89-10 which will enhance the maintenance, analysis and testing already being conducted on .

Motor Operated Valves (MOV's) at Pilgrim Nuclear Power Station (PNPS). Our ,

plan is to begin a design basis review of M0V's in the first quarter of 1991 and to begin testing in RF0 #9, It is anticipated that the testing will require three refueling outages. He are currently evaluating MOV diagnostic testing systems, including partially or wholly installed systems, for use in support of this testing. The Generic Letter 89-10 work scope has been

• incorporated into our Long Term Program (LTP itam #487) and the schedule for GL 89-10 will be included in the next submittal cf the LTP.

The Boiling Hater Reactor Owner's Group (BHROG) is presently working on defining the scope of a MOV program compliant with the generic letter. The BHROG report is scheduled for November 1990. He will monitor the BHROG effort and factor the results into the Pilgrim test program as appropriate. "

-He implemented a MOV Upgrade Program at Pilgrim during RF0 #7. That program consisted of both hardware and software upgrades. All Limitorque MOV's were inspected and refurbished where necessary. Additionally, station procedures were upgraded, controlled drawings were developed and MOV training programs .

were enhanced. Consistent with the guidance orovided in Generic Letter 89-10, commitments made in response to IEB 85-03 will be incorporated into a test program developed to meet the recommended actions of Generic Letter 89-10.

(See BECo Letter 87-183 dated November 13, 1987).

Pilgrim Station will perform Generic Letter 89-10 recommended testing to the fullest extent that is reasonably practical and which will neither place the plant in an unsafe' condition or damage equipment. As recognized in the generic letter, in-situ design basis testing.cannot be performed in many instances, for these cases, testing will be performed at reduced pressures 'And flows and the results will be evaluated for design basis conditions. / hj f O 9001260049 900115 Q gDR ADOCK0500g3

I BOSTON EDISON COMPANY January 15, 1990 U. S. Nuclear Regulatory Commission Page Two

' The development of the program described in the generic letter will require the dedication of significant resources. There are many factors which may be beyond our direct control, including: the timely availability of valve  ;

documentation from vendors, plant conditions which prohibit full flow and full differential pressure testing, questions raised by an NRC sponsored testing l program, such as, the validity of valve factors currently used in actuator sizing equations, and questions as to what constitutes an acceptable test.

These factors will be considered in the scheduling of our program.

Also, ongoing discussions among NUMARC and the NRC concerning portions of Generic Letter 89-10 which may require a "backfit analysis" are pending resolution. Boston Edison will monitor these activities and incorporate the .

results into our final program scope and schedule as appropriate.

Should you or your staff have any questions regarding this response, please contact our Licensing staff.

r Commonwealth of Massachusetts I

County of Plymouth l Then personally appeared before me, Ralph G. Bird, who being duly sworn, did

, - state that he is Senior Vice President - Nuclear of Boston Edison Company and L that he H duly authorized to execute and file the' submittal contained herein l in the name and on behalf of Boston Edison Company and that the statements in l said submittal are true to the best of his knowledge and belief. .

My commission expires: Med DATE M 6./fff .

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] NOTARYPUKIC RAH /amm/3953 cc:. Mr. D. Mcdonald, Project Manager Division of Reactor Projects - I/II i Office of Nuclear Reactor Regulation Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pikt.

Rockville, MD 02852 U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station e -- e- --y++w -+ A ---*+e m- w -.-*_e )_-* -*-*a