ML20059A729
| ML20059A729 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/06/1990 |
| From: | Gody A Office of Nuclear Reactor Regulation |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| GL-89-10, IEB-85-003, IEB-85-3, TAC-75642, NUDOCS 9008230194 | |
| Download: ML20059A729 (3) | |
Text
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UNITED STATES 4
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q NUCLEAR REGULATORY COMMISSION l
,5 WAGNiteGTON, D, C 30546 1
August 6, 1990 Docket No. 50-483 i
Mr. Donald F. Schnell I
Senior Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166
Dear Mr. Schnell:
$UBJECT:
RESPONSE TO GENERIC LETTER 89-10. " SAFETY-RELATED MOTOR-OPERATEDVALVE(MOV)TESTINGANDSURYPLLANCE"(TACNO.75642)
On June 28, 1989, theNRCissuedGenericLetter(GL)89-10requestingthe 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 af ter December 28 1989, whichever was later.
In supplement 2 to the generic letter, the staff has delayed this schedule until January 1,1991.
Information that should be contained in your program description was discussed i
during the workshops held in September 1989. The staff positions on questions asked in the works'iops are available in Supplement 1-to the GL. The supplement should provide assistance in defining the scope of the GL and hence your program description. As your program is developed, justification for any differences between your program and the GL exemplified by the supplement should be incorporated into your progt sm description.
On December 28, 1989, you submitted a response to GL 89-10, regarding the Ca".away Plant stating that your motor-operated valve (MOV) program satisfies the recomendations of the generic letter with two exceptions.
The staff is providing the following co'ments on your submittal.
As ore exception to the recommendations of the generic letter, you state that, in lieu of performing tests of each MOV in situ under design-basis.
conditions, the HENZE-MOVATS data base methodoTogy will be used to' select MOV switch settings and to determine the need for full-flow DP testing. As discussed at the workshops, recent research and operating events have revealed that significant uncertainty surrounds the ap)11 cation of test data from one MOV to another.
Furthermore, the operating ciaracteristics of'an-MOV at static or low ludd conditions are not always indicative of MOV performance under severe conditions. This information has led the staff to conclude that the techniques used for the application of test data during the implementation of Bulletin 85-03 will not be acceptable for addressing the concerns of GL 89-10 without further justification. As a result, the staff recommends that MOVs be tested in situ under design-basis conditions where practicable.
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Mr. Donald F. Schnell
-2 August 6, 1990 i
For MOVs that cannot be tested in that manner, the staff discussed at the workshops several alternatives. One alternative was the use of a data base of test results.
As stated at the workshops, the staff has not endorsed an industry data base for the implementation of the GL.
You will be expected to justify the applicability of the data base to the particular MOV in question, including both the test results included in the data base and the conditions of those tests.
Your own experience on the use of the data base methodology as an acceptable alternative to full-flow testing for the MOVs at the Callaway Plant may be very helpful in this justification.
You state that one reason for your use of the HENZE-M0 VATS data base is your belief that the finding from the MOV tests performed by the Idaho National Engineering Laboratory were applicable only to MOV operation under two-phase flow conditions. Contrary to this view, operating events and more recent research confirm that the concerns regarding the application of test data between MOVs is relevant to a wide range of fluid conditions.
The staff suggests that you continue your participation with industry in the review of operating experience at other plants and research to ensure that your reliance on the HENZE-MOVATS data base can be justified, f
The other exce) tion to the generic letter identified involves the provisions of item 1 of tie generic letter concerning the submission of changes to the licensee's commitment. Your request to submit only changes to your commit-ments that are significant in nature is acceptable to the staff.
Your program description should be retained on-site for possible further NRC staff review. This completes the staff review and licensing action on TAC No. 75642.
Siacerely, (5(
I Anthony T. Gody, Jr., Project Manager Project Directorate 111-3 l
Division of Reactor Projects - 111, l
IV, Y and Special Projects l
Office of Nuclear Reactor Regulation l
cc: See next page l
DISTRIBUTION Docket. File-LMarsh e
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PKreutzer PD33 Gray File JHannon TScarbrough
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a Mr. D. F. Schnell Callaway Plant Union Electric Company Unit No. I cc: Dr. J. O. Cermack Mr. Bart D. Withers CFA Inc.
President and Chief 4 Professional Dr., Suite 110 Executive Officer Gaithersburg, MD 20879 Wolf Creek Nuclear Operating Corporation Gerald Charnoff, Esq.
P. O. Box 411 Thomas A. Baxter, Esq.
Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge 2300 N Street, N. W.
Mr. Dan I. Bolef, President Washington, D. C.
20037 Kay Drey, Representative Board of Directors Coalition Mr. T. P. Sharkey for the Environment Supervising Engineer, St. Louis Region Site Licensing 6267 Delmar Boulevard Union Electric Company University City, Missouri 63130 Post Office Box 620 Fulton, Missouri 65251 i
U. S. Nuclear Regulatory Conaission Resident Inspectors Office i
RRf1 Steedman, Missouri 65077 Mr. Alan C. Passwater, Manager Licensing and Fuels Union Electric Company Post Office Box 149 St. Louis, Missouri 63166 Manager - Electric Department Missouri Public Service Commission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Re U.gional Administrator S. NRC, Region 111 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P. O. Box 176 Jefferson City, Missouri 65102
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