ML20055E864

Comments on Util 891228 Response to Generic Ltr (GL) 89-10, Safety-Related Motor-Operated Valve (MOV) Testing & Surveillance. Requests Proposed Schedule for Completion of GL Program Along W/Justification for Alternative Schedule

ML20055E864
Person / Time
Site:	Limerick
Issue date:	07/10/1990
From:	Clark R Office of Nuclear Reactor Regulation
To:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
GL-85-03, GL-85-3, GL-89-10, TAC-75677, TAC-75678, NUDOCS 9007130030
Download: ML20055E864 (3)

Text

g y,, p uouq K k'g UNITED STATES

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5 "j NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

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July 10, 1990- 4 Docket Nos. 50-352

and 50-353 E

Mr. George A. Hunger, Jr.

Director-Licensing, MC 5-2A-5

. Philadelphia Electric Company Nuclear Group Headquarters i

L Correspondence Control Desk L P. O. Box No. 195

Wayne, Pennsylvania 19087-0195 l

SUBJECT:

GENERIC LETTER 89-10, " SAFETY-RELATED MOV TESTING AND SURVEILLANCE l-(MPA B-110), LIMERICK GENERATING STATION, UNITS 1 AND 2 ;

I (TAC NOS. 75677 AND 75678)

On June 28, 1989, theNRCissuedGenericLetter(GL)89-10requestingthe l 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, 1909, whichever is 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 workshop connents should be incorporated into your program description.

On December 28,1989, 'you submitted a response to GL 89-10. Several comments on your submittal are provided below.  !

l' 1 in the cover letter of your December 28, submittal, you refer to a letter l dated November 17, 1989, from T. E. Tipton, Nuclear Management and Resources l Council (NUMARC), to T. E. Murley, NRC, which requested clarification of '

several aspects of Generic Letter 89-10. In a letter dated January 29, 1990, from J. E. Richardson, NRC, to T. E. Tipton, the staff discussed the points raised by NUMARC and indicated that the results of the public workshops would provide additional information.

l Your response to Item c of the generic letter indicates that some testing of

MOVs under design-basis conditions has been conducted. You state, however,

. that you are.-not prepared to commit to such additional testing at this time, but. propose to make that determination within two years. In the generic letter, the' staff suggested a five-year schedule for completion of the initial test program. The staff believes that it would be very difficult for you to complete your MOV program in the five-year time frame if you do not plan to 900713003o 900710 PDR ADOCK 05000352 e eDc g'\3

Mr. George A. Hunger, Jr. Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc:

Troy B. Conner, Jr., Esquire Mr. Thomas Gerusky, Director Conner and Wetterhahn Bureau of Radiation Protection 1747 Pennsylvania Ave. , N.W. PA Dept. of Environmental Resources Washington, D. C. 20006 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Mr. Rod Krich 52A-5 Philadelphia Electric Company Single Point of Contact 955 Chesterbrook Boulevarf P. O. Box 11880 Wayne, Pennsylvania 190; (591 Harrisburg, Pennsylvania 17108-1880 Mr. Graham M. Leitch, Vice President Mr. Philip J. Duca Limerick Generating Station Support Manager Post Office Box A Limerick Generating Station Senatoga, Pennsylvania 19464 P. O. Boy A Sanatoga, Pennsylvania 19464 Mr. Marty J. McCormick, Jr.

Plant Manager Mr. Garrett Edwards l Limerick Generating Station Superintendent-Technical l P.O. Box A Limerick Generating Station l Sanatoga, Pennsylvania 19464 P. O. Box A Mr. Larry Doerflein U.S. Nuclear Regulatory Commission Mr. Gil J. Madsen l

Pegion 1 Regulatory Engineer l 475 Allendale Road Limerick Generating Station l- King of Prussia, PA 19406 P. O. Box A Sanotoga, Pennsylvania 10464 Mr. Thomas Kenny Senior Resident Inspector Library l

US Nuclear Regulatory Commission US Nuclear Regulatory Comission P. O. Box 596 Region I Pottstown, Pennsylvania 19464 475 Allendale Road l King of Prussia, PA 19406 l Mr. John Doering l Project fianager Limerick Generating Station P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Larry H6i -ins Superintendent-0perations Limerick Generating Station P. O. Box A Senatoga, Pennsylvania 19464

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M'r. George A. Hunger, Jr.

begin testing for two years. The staff recommends that you identify those MOVs for which testing in situ under design-basis conditions is practicable and develop a schedule for the testing of those MOVs within five years. For those MOVs that cannot be. tested under design-basis conditions, you should use an alternative method for demonstrating MOV operability. The staff discussed some alternatives at the workshop along with the factors that should be considered if one of those alternatives is chosen. If an alternative cannot be justified at this time, the staff recommends that the *two stage" epproach as outlined in the GL and discussed at the workshops be followed. With that approach, you would select the switch settings for those particular MOVs using the best data available and then would work to obtain applicable test data as soon as possible.

Your response to Item 1 of the generic letter indicates that a supplemental L response will be provided with the schedule for completion of the initial GL program. The staff requests that the proposed schedule along with justification .

for any alternative schedule be provided as soon as possible. The staff suggested the five-year schedule-based on the complexity of the issue and its safety importance. The staff does not believe that resolution of the issue can '

be delayed beyond the five-year schedule to any significant degree. Additionally,_

you note that any changes to your conmitments regarding the GL will be reported l to the NRC; we request that for any significant changes you do so in writieg.

In your response to the GL you propose not to provide written notification af changes to the schedule for periodic verification of MOV switch settings. The staff accepts this proposal with the condition that the justification for thi l changes be available on site.

1 l Sincerely, Original signed by l- Richard J. Clark li Richard-J. Clark, Project Manager Project Directorate 1-2 E Division of Reactor Projects - I/11 Office of Nuclear Reactor Regulation cc:-

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