ML20056F348
| ML20056F348 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, Waterford  |
| Issue date: | 08/23/1993 |
| From: | Mcgaha J ENTERGY OPERATIONS, INC. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR39243 58FR39243-00003, 58FR39243-3, CNRO-93-028, CNRO-93-28, GL-89-10, NUDOCS 9308270016 | |
| Download: ML20056F348 (4) | |
Text
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Jrshn R. McNha SfFE 3'is'2x August 23,1903
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Mr. Samuel J. Chilk, Secretary of the Commission (3
U.S. Nuclear Regulatory Commission
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Washington, D.C. 20555 i
Attention:
Docketing and Service Branch di a?
Subject:
NRC Draft Generic Letter 89-10 Supplement 6: 58 FR 39243 Od c
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Dear Mr. Chilk:
Entergy Operations, Inc. has reviewed the request for public comment published in the Federal Register on July 22,1993 (58 FR 39243) concerning NRC draft Generic Letter 89-10 Supplement 6. We wish to submit the attached comments on behalf of Arkansas Nuclear One Units 1 & 2. Grand Gulf Nuclear Station, and Waterford 3 Steam Electric Station.
Entergy Operations has also reviewed the comments prepared in regard to this matter by the Nuclear Utility Management and Resources Council (NUMARC). We ecdorse their positions, which are similar to our own.
We appreciate this opportunity to express our views on the NRC draft Generic Letter Supplement and the Commission's consideration of the our comments.
Sincerely.
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(See Page 2) i 9308270016 930823 PDR PR MISC 58FR39572 PDR
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NRC Draft Generie Letter 89-10 Supplement 6; 58 FR. 39243 August 23,1993 CNRO-93/00028 l
Page 2 of 2 j
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Mr. T. W. Alexion Mr. P. W. O'Connor Mr. R. P. Barkhurst Mr. N. S. Reynolds Mr. R.11. Bernhard Mr. R. L. Simard Mr. R. B. Bevan, Jr.
Ms. L. J. Smith Mr. J. L. Blount Mr. D. L. Wiggir/on Mr. S. D. Ebneter Mr. J. W. Yelverton Mr. E. J. Ford Central File (GGNS)
Mr. C. R. Hutchinson DCC (ANO)
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Mr. II. W. Keiser Records Center (WF3) l Mr. R. B. McGehee Corporate File [ 5 ]
Mr. J. L. Milhoan j
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NRC Draft Generic Letter 89-10 Supplement 6: 58 FR 39243 August 23,1993 Attachment to CNRO-93/00028 Page1 of2 Entergy Operations, Inc.
Comments on Draft Generic Letter 89-10 Supplement 6 Page 3, MOV Grouping, Paragraph 1 The paragraph reads in part:
"Therefore, if a licensee does not perform prototype testing for each MOV that is not practicable to test in situ, the licensee will have to group MOVs that are not practicable to test in a manner that provides adequate confidence that the MOVs are capable of performing their design-basis function."
Comment:
The basis fbr grouping is to extend the results of prototype tests to other MOVs. This statement should be reworded to clarify the relationship between prototype testing and grouping.
Consideration (4) includes:
"to the extent practicable. selection of valves for dynamic testing in the group based on a prioritization scheme that considers greatest safety-significance and least perfonnance margin" Comment:
The selection of test cancidates should have little to do with safety significance or performance margin.
A good test candidate should be considered one where n meaningfal test is possible and the results can be clearly extended to other MOVs. For example, if a 13alance of Plant valve is shown similar to other MOVs and a good flow test is possible,it should be tested to cover safety significant MOVs that are not testable.
Page 4, MOV Grouping, Consideration (6)
Comment:
It is not clear what is meant by " valve material condition" In addition, two very important considerations were omitted: seat / guide stresses and contact surface materials.
NRC Draft Generic Letter 89-10 Supplement 6; 58 FR 39243 August 23,1993 Attachment to CNRO-93/00028 Page 2 of 2 Public Questions During The February 1993 Workshop On GL 89-10 Page 4, Last Paragraph Comment:
If the expected operating history of an MOV is enveloped by that simulated at Kalsi Engineering, there does not appear to be a reason to expect licensees to ".. periodically inspect the actuators to identify any adverse effects from the increased thrust above structural ratings."
Page 10, Paragraph 4 Regarding the establishment of an industry data base by the MOV Users Group, the draft Generic Letter Supplement states:
"The [NRC] staff may audit the data base to provide an independent assessment of the quality of the data. The staff currently does not plan to mandate its use but licensees will be expected to be aware ofits contents to help ensure that a potential plant specific MOV problem is not revealed by the data base."
Comment:
The variations in test parameters, measurement techniques, hardware configuration, etc.,
l will make it impractical for utilities to be " aware of' the contents of this data base without researching the history behind each applicable test listed therein. The level of effort to accomplish this would be unreasonable, and is contradictory to the NRC position stated earlier in the draft Generic Letter Supplement that if a utility utilizes data from facilities subject to 10CFR50 Appendix B, it need not verify the data or audit the source of the data.
There does not appear to be a need for the NRC to " audit" the MOV data base. Each-i utility is responsible for the use of any test data obtained from this (or any) source. In addition, this also appears contradictory to the statement under "MOV Grouping" (page 4), that if a utility utilizes data from facilities subject to 10CFR50 Appendix B. it need not verify the data or audit the source of the data. This contradiction should be resolved by removing the statement about the NRC auditing the data base.
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