ML20056B436

Comments on Util 891229 Response to Generic Ltr 89-10, Safety-Related Motor-Operated Valve (MOV) Testing & Surveillance. Addl Discussion of Plans for Periodic Verifications of Proper MOV Program Description Requested

ML20056B436
Person / Time
Site:	Clinton
Issue date:	08/08/1990
From:	John Hickman Office of Nuclear Reactor Regulation
To:	Spangenberg F ILLINOIS POWER CO.
References
GL-89-10, IEB-85-003, IEB-85-3, TAC-75647, NUDOCS 9008280276
Download: ML20056B436 (3)

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Docket No. L0-461 Mr. Frank A. Spangenberg Licensing and Safety _

Clinton Power Station P. O. Box 678

,-n Mail Code V920 Clinton, Illinois 61727

SUBJECT:

RESPONSE-TO GENERIC LETTER 89-10, " SAFETY-RELATED MOTOR-OPERATEDVALVE(MOV)TESTINGAND-SURVEILLANCE"(TACNO.75647)

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 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.

On December 29, 1989, you submitted a response to GL 89-10. regarding the Clinton Power Station.' The-staff is providing the following comments on your

' submittal.

The GL requested that licensees have available a description of the GL program for review by NRC personnel by June 28, 1990, or the first refueling outage after December 28,1989,,whichever was later.

In your December 29 submittal, you state that the design-basis reviews and required thrust determinations will be completed by January 1, 1991.

Additionally you state that the scope and schedule for flow testing will be available by February 28, 1991. The staff considers the Lproposed-completion dates for these activities to be acceptable, provided you prepare the description of the overall program by February 28, 1991.

At-the

'public workshops held in September 1989 the staff indicated the information

-that should be contained in the program description. The results of the workshops are provided in supplement 1 to the generic letter. The minutes are of;particular assistance in clarifying the scope of_the generic '.atter and.the staff's position with respect to the inadvertent operation of motor-operated valves [MOVs). You should compare your program with the a

staff _ positions on the GL in supplement 1 and should justify in your program description any differences with those positions.

Additionally you state that torque switches on your rising stem MOVs have been tested to ensure that the delivered thrust meets or exceeds the valve manufac-turer's recommendations. As discussed at the workshops and demonstrated by plant experience, the recommendations of the valve manufacture have been shown

'in many instances to be inadequate to ensure the capability of the MOV under design-basis conditions. You should not accept the thrust calculations of the valve manufacturer without evaluating their accuracy.

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'Mr.' Frank A. Spangenberg Also, in your regonse-to Item a.', you state that the required thrust.will be determined using analytical. techniques standard to:the industry." ' As indicated above,-the standard. techniques for calculating required thrust have been found-to be-inadequate.in many instances'. You will be expected to' justify the-analytical. method used to detern:ine the required thrust of all MOVs within

'the GL program.- Your_ response to Item a of the generic letter also indicates

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that,the design-basis review for each MOV in the program wi11' include a deter-mination of the maximum differential pressure under which the valve is expected to operate. You should also determine the maximum flow, where applicable, during the design-basis reviews.

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'In your response-to Item c. of the GL, you indicate that tests had been performed s

on your safety-related MOVs under static conditions to verify that they meet the manufacturer's recommendations.

In addition to casting-doubt on the' accuracy.

o of-the standard thrust equation, the recent research results and operating = _

experience have revealed that the performance characteristics of an MOV at static _ :

conditions is not necessarily indicative of the MOV performance at design-basis conditions.

With respect to Item d. of the GL, your should provide additional' discussion of your plans for periodic verifications of proper MOV-switch settings in your program description. You should review GL Supplement I and provide l justification where your plans differ from the staff's recommendations.

In your response to Item e. of the C you state that all design basis. conditions will be considered in the desina-N review. The staff assumes that you will determine the actual vc

,-...i e. at the MOV, which is referred to as

" degraded voltage." Supplement I to the GL provides a discussion of the voltage to be considered during the design-basis reviews.

Further NRC staff review of your program on-site is anticipated.

Sincerely, l-John B. Hickman, Project Manager Project Directorate III-3 Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation m

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.c Mr. Frank A. Spangenberg Clinton Power Station Illinois Power: Company-Unit-1 4

t ec: Mr. J. S. Perry Illinois Department Vice President' of Nuclear Safety Clinton Power Station Office of Nuclear Facility Safety P. O. Box 678 1035 Outer Park Drive Clinton,-Illinois 61727 Springfield, Illinois 62704

't Mr.-J. A. Miller Managar-Nuclear Station Mr. Donald Schopfer Engineering Department Project Manager Clinton Power Station Sargent & Lundy Engineers P. O. Box 678 55 East Monroe Street' Clinton, Illinois 61727 Chicago, Illinois 60603 Sheldon Zabel, Esquire Schiff, Hardin & Waite J,

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233 Wacker Drive Chicago, 111'nois 60606 Resident Inspector

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~U. S. Nuclear Regulatory Commission RRf3, Box 229 A Clinton, Illinois.61727 Mr.-L. Larson Project Manager General Electric Company 175 Curtner Avenue N SanJose, California /C395 95125 t

Regional _ Administrator, Region III

799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 i;

Chairman.of DeWitt County c/o County Clerk's Office DeWitt County Courthouse Clinton, Illinois 61727 Robert Neumann Office of Public Counsel-State of Illinois Center-100 W. Randolph Suite 11-300 Chicago, Illinois 60601 i

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