ML20055E961

Requests Addl Info Re Util 891228 Response to Generic Ltr 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance

ML20055E961
Person / Time
Site:	Peach Bottom
Issue date:	07/05/1990
From:	Suh G Office of Nuclear Reactor Regulation
To:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
GL-89-10, IEB-85-003, IEB-85-3, TAC-75698, TAC-75699, NUDOCS 9007130124
Download: ML20055E961 (3)

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UNITED STATES L ,

Vf-NUCLEAR REGULATORY COMMISSION.. l M f.E  :, WASHINCTON, D. C. 20$$5 l 1i e d '

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' July 5,.1990 Docket Nos. 50-277-

,' and 50-278 . ,

' Mr. George A. Hunger, Jr. ,

. Director-Licensing, MC 5-2A-5 '

1 Philadelphia Electric Company

-Nuclear Group Headquarters '

Correspondence Control Desk-P.O. Box No'. 195 i Wayne , Pennsylvania 19087-0195 i

Dear Mr. Hunger:

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SUBJECT:

RESPONSE TO GENERIC LETTER 89-10. " SAFETY-RELATED MOTOR'-OPERATED YALVE (MOV) 1ESTING AND SURVEILLANCE," PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3 (TAC N05. 75698/7579)

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 i

. .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 is later. Information that should be

.w contained in your. program description was discussed during the workshops held' in Seatember 1989. The staff positions on questions presented during the works 10ps have been issued in the form of.a supplement to the GL. As your program is developtid, justification for any differences between your program 4 m and the GL exemplified by the workshop comments should be incorporated into your program description.

On' December 28, 1989, you submitted a response to Generic Letter 89-10, 4

, -" Safety-Related Motor-0perated Valve Testing and Surveillance." Several: j l comments on your submittal are provided below. t In the cover letter of your December 28 submittal, you refer to a letter dated' .

November 17, 1989, from T. E. Tipton, NVclear' Management and Resources 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

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by HUMARC and indicated that the results of the public workshops would provide edditional information.

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

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Mr. George A. Hunger, Jr. July 5, 1990 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 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 dicussed some alternatives at the workshops 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 reconsnends that the "two stage" approach 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 availeble 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 response will be provided with the schedule for completion of the ir,;cie' 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 complaxity of the issue end 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 commitments regarding the Cl will be reported to the NRC; we request that for any significant changes, you do so in writing. In your response to the GL you propose not to provide written notification of changes to the schedule for periodic verification of MOV switch settings. The staff accepts this proposal with the condition that the justification for the changes be available on site.

Sincerely, Original signed by Gene Y. Suh, Project Manager Project Directorate I-2 Division of Reactor Projects - I/11 Office of Muclear Reactor Regulatio i cc:

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.Mn. George A. Hunger, Jr. Peach Bottom Atomic Power Station.

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• Philadelphia Electric Company Units 2 and 3

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Troy B. Conner, Jr. , Esq. Single Point of Contact 1747 Pennsylvania Avenue, N.W. P. O. Box 11880 Washington, D.C. 20006 Harrisburg, Pennsylvania 17108-1880 Philadelphia Electric Company Mr. Thomas M. Gerus % tirector ATTH: Mr. D. B. Miller, Vice President Bureau of Radiation Protection 7 Peach Bottom Atomic Power Station Pennsylvania Department of b Route 1 Box 208 Environmental Resources Delta,. Pennsylvania 17314 P. O. Box 2063 Harrisburg. Pennsylvania 17120 Philadelphia Electric Company .i

. ATTN: Regulatory Engineer, Al-25 Peach Bottom Atomic Power Station Board of Supervisors 4

-Route 1. Box 208 Peach Bottom Township Delta, Pennsylvania 17314 R. D.-#1 Delta, Pennsylvania 17314 Resident Inspector

'U.S. Nuclear Regulatory Comission Public Service Comission of Maryland Prfach Bottom Atomic.' Power Station -Engineering Division P.O. Box 399 ATTH: Chief Engineer y In1ta, Pennsylvania 17314 231 E. Baltimore Street T- <

Baltimore, MD 21202-3486 7

Regional Administrator, Region I U.S. Nuclear Regulatory Comission Mr. Tom Magette 475 Allendale Road .

Power Plant Research Progran King of Prussia, Pennsylvania 19406 Department of Natural Resources B-3 Nr. Roland Fletcher Tawes State Office Building Cepartment of Environn'ent Annapolis, Maryland 21401 201 West Preston Street q Baltimore, Maryland 21201 h

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