ML20059E951

Requests Addl Info Re Graded Approach for GL 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance

ML20059E951
Person / Time
Site:	Monticello, Kewaunee, Point Beach, Prairie Island, Ginna
Issue date:	01/07/1994
From:	Gamberoni M Office of Nuclear Reactor Regulation
To:	Richard Anderson NORTHERN STATES POWER CO.
References
GL-89-10, NUDOCS 9401130083
Download: ML20059E951 (7)

Text

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a Docket Nos. 50-282, 50-306, 50-263, 50-266, 50-301, 50-305, and 50-244 ,

January 7,1994 Mr. Roger 0. Anderson, Director Licensing and. Management Issues Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GRADED APPROACH FOR  !

GENERIC LETTER 89-10, SAFETY-RELATED MOTOR-0PERATED VALVE TESTING AND SURVEILLANCE Meetings were held at NRC headquarters on June 7, 1993, and October 18, 1993, '

to discuss the cooperative efforts group process to develop a graded motor-operated valve testing program. Meeting summaries were published on June 15, 1993, and November 16, 1993.

Following these presentations, the staff has discussed your approach and has developed a number of questions. These questions are provided in Enclosure 1. >

Before the staff can continue evaluation of your process, a response to the enclosed questions is required. If you have any questions regarding this request, please contact Marsha Gamberoni on 504-3024 or Tom Scarbrough on ,

504-2784.  ;

The reporting and/or recordkeeping requirements contained in this letter ,

affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Original sigred by Marsha Gamberoni, Project Manager Project Directorate III-l a

Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Comments on Cooperative Efforts .

cc w/ enclosure:

See next pages .

DISTRIBUTION Docket File R. Blough J. Roe OGC NRC & Local PDRs C. Jamerson J. Zwolinski ACRS (10)

PD 31 Reading M. Gamberoni B. Jorgensen, Region III

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e Enclosure 1 COMMENTS ON COOPERATIVE Eff0RTS GROUP PRESENTATION ON A GRADED APPROACH TO GENERIC LETTER 89-10 (October 18,1993)

1. As stated in paragraph 1 of Generic letter 89-10, each licensee is required by 10 CFR 50.54(f) to notify the staff in writing of any changes to its commitments to GL 89-10 with justification retained on site. The Cooperative Efforts Group proposal fcr a " graded ap; roach" to GL 89-10 constitutes a significant change to a licensee's commitment to test motor-operated valves (MOVs) where practicable and would require a written submittal notifying the staff of the change.

2. In addition to changing its commitment to a graded approach, Monticello plans to extend its schedule for meeting its commitment to GL 89-10 beyond its original November 1994 completion date to Spring 1996. As indicated in paragraph 1 of GL 89-10, Monticello is required to notify the staff in writing of the schedule change. Supplement 6 to GL 89-10 (to be issued in the near future) will provide specific information that is needed by the staff to evaluate a licensee's justification for a change to its GL 89-10 schedule. Monticello should contact its NRR Project Manager to discuss the most efficient means of providing that information.

3. Monticello categorized its safety-related MOVs as either "important" or

" unimportant" based on PRA and deterministic considerations. No concerns were identified with the licensee's prioritization of its MOVs in its GL 89-10 program. However, some of the reasons listed by the licensee of why an MOV could be considered " unimportant" are of concern (for example, redundancy). The staff would need to review each MOV placed into the

" unimportant" category by a licensee.

4. Monticello stated that the "important" safety-related MOVs would have their performance justified "per differential pressure test or through industry efforts or grouping." Monticello stated that the " unimportant" safety-related MOVs would have their performance justified by " test or  ;

engineering analysis." Upon request by an NRC inspector, each licensee is responsible for demonstrating that any safety-related MOV can perform its safety function. It is not clear how the licensee will implement these two methods of justifying the performance of "important" and " unimportant" safety-related MOVs. If a licensee chooses not to test an MOV even though such testing is practicable, Supplement 6 to GL 89-10 should be referred to for information on the important considerations in grouping MOVs for ,

the application of test data from one M0V to another. l

5. Monticello indicated that static tests would be used in an effort to verify periodically the design-basis capability of safety-related MOVs.

However, the licensee had not developed justification for the use of static test data to demonstrate design-basis capability. The licensee stated during the meeting that the "important" safety-related MOVs constitute 99.9% of the risk. If so, the licensee should consider using its graded-approach philosophy to enhance the basis of the method and increase the frequency for periodically verifying the design-basis capability of those "important" safety-related MOVs. The licensee proposes a 5 to 10 refueling cycle schedule for periodic verification of the design-basis capability of " unimportant" safety-related MOVs, but did not provide justification for this schedule beyond the recommended schedule in GL 89-10 for periodic verification.

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6. Monticello indicated that static thrust tests would be used to demonstrate l performance for post-maintenance testing. However, some maintenance might i affect the performance of the valve that could only be revealed through 4 dynamic testing. .Also, some maintenance might affect the torque l performance of the MOV.

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i Northern States Power Company Monticello Nuclear Generating Plant and Prairie Island Nuclear ,

Generating Plant cc:

Mr. Roger 0. Anderson, Director Kris Sanda, Commissioner Licensing and Management Issues Department of Public Service Northern States Power Company 121 Seventh Place East 414 Nicollet Hall Suite 200 Minneapolis, Minnesota 55401 St. Paul, Minnesota 55101-2145 J. E. Silberg, Esquire Lisa R. Tiegel -

Shaw, Pittman, Potts and Trowbridge Assistant Attorney General i 2300 N Street, N. W. Environmental Protection Division Washington DC 20037 Suite 200 520 Lafayette Road U.S. Nuclear Regulatory Commission St. Paul, Minnesota 55155 '

Resident inspector Office  ;

2807 W. County Road 75 Mr. E. L. Watzi, Site General Monticello, Minnesota 55362 Manager Prairie Island Nuclear Generating Site General Manager Plant Monticello Nuclear Generating Plant Northern States Power Company  ;

Northern States Power Company 1717 Wakonade Drive East '

Monticello, Minnesota 55362 Welch, Minnesota 55089 Robert Nelson, President U.S. Nuclear Regulatory Commission Minnesota Environmental Control Resident Inspector Office i Citizens Association (MECCA) 1719 Wakonade Drive East 1051 South McKnight Road Welch, Minnesota 55089-9642 l St. Paul, Minnesota 55119-i Mr. Jeff Cole, Auditor / Treasurer l Commissioner Goodhue County Courthouse {

Minnesota Pollution Control Agency Box 408 520 Lafayette Road Red Wing, Minnesota 55066-0408 St. Paul, Minnesota 55119 i Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Commissioner of Health Minnesota Department of Health 717 Delaware Street, S. E.

Minneapolis, Minnesota 55440 Darla Groshens, Auditor / Treasurer Wright County Government Center 10 NW Second Street

. Buffalo, Minnesota 55313 l

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Dr. Robert C. Mecredy R.E. Ginna Nuclear Power Plant cc:

Thomas A. Moslak, Senior Resident Inspector R.E. Ginna Plant '

U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, New York 14519 -l Regional Administrator, Region I  !

U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms. Donna Ross i Division of Policy Analysis & Planning New York State Energy Office Agency Building 2 '

Empire State Plaza Albany, New York 12223 Charlie Donaldson, Esq.

Assistant Attorney General  !

New York Department of Law 120 Broadway New York, New York- 10271 Nicholas S. Reynolds Winston & Strawn ,3 1400 L St. N.W. C' Washington, DC 20005-3502 Ms. Thelma Wideman Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7370 Route 31 Lyons, New York 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 111 West f all Road, Room 11 Rochester, New York 14620 1

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, Mr. C. A. Schrock Wisconsin Public Service Corporation Kewaunee Nuclear Power Plant CC:

Mr. C. A. Schrock Manager - Nuclear Engineering Wisconsin Public Service Corporation Post Office Box 19002 Green Bay, Wisconsin 54037-9002 Foley & Lardner Attention: Mr. Bradley D. Jackson One South Pinckney Street P. O. Box 1497 Madison, Wisconsin 53701-1497 Chairman Town of Carlton Route .1 Kewaunee, Wisconsin 54216 Mr. Harold Reckelberg, Chairman Kewaunee County Board Kewaunee County Courthouse Kewaunee, Wisconsin 54216 '

Chairman 3 Public Service Commission of Wisconsin Hill farms State Office Building Madison, Wisconsin 53702 Attorney General 114 East, State Capitol Madison, Wisconsin 53702 .

i U. S. Nuclear Regulatory Commission i Resident Inspectors Office Route #1, Box 999 Kewaunee, Wisconsin 54216 .

Regional Administrator - Region III U. S. Nuclear Regulatory Connission 801 Warrenville Road Lisle, Illinois 60532-4531 Mr. Robert S. Cullen Chief Engineer Wisconsin Public Service Commission P. O. Box 7854 Madison, Wisconsin 53707

t Mr. Robert'E. Link Point Beach Nuclear Plant Wisconsin Electric Power Company Unit Nos. I and 2 ,

cc:

Ernest L. Blake, Jr. -

Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.

Washington, DC 20037 Mr. Gregory J. Maxfield, Manager Point Beach Nuclear Plant .

Wisconsin Electric Power Company 6610 Nuclear Road Two Rivers, Wisconsin 54241 Town Chairman Town of Two Creeks Route 3 Two Rivers, Wisconsin 54241 Chairman Public Service Commission of Wisconsin Hills Farms State Office Building Madison, Wisconsin 53702 Regional Administrator, Region III U.S. Nuclear Regulatory Commission ,

799 Roosevelt Road

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Glen Ellyn, Illinois 60137 Resident inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, Wisconsin 54241 l

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