ML20073D371

Response to NRC GL 89-10,suppl 6, Info on Schedule & Grouping & Staff Responses to Addl Public Questions

ML20073D371
Person / Time
Site:	Davis Besse
Issue date:	09/16/1994
From:	Stetz J CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-10, TAC-M75654, NUDOCS 9409270173
Download: ML20073D371 (6)

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CENTE N

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300 Madison Avenue John P. Stetr foledo, OH 43652-0001 Vice President - Nuclear 419-249-2300 Davis-Besse Docket Number 50-346 License Number NPF-3 Serial Number 2247 September 16, 1994 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555

Subject:

Response to NRC Generic Letter 89-10, Supplement 6, "Information on Schedule and Grouping, and Staff Responses to Additional Public Questions" (TAC No. M75654)

Gentlemen-The purpose of this letter is to provide updated information with  ;

regard to Toledo Edison's (TE's) commitments pursuant to NRC Generic Letter (GL) 89-10. This information involves clarification of the schedule for completion of the Motor Operated Valve (MOV) initial testing program for the Davis-Besse Nuclear Power Station (DBNPS) and clarification of changes to the planned scope of individual MOV {

testing. .

Supplement 6 to GL 89-10, dated March 8, 1994 (Log Number 4170), ,

requires' licensees that intend to modify'their current commitments'to ,

GL 89-10 and extend their schedule for completion _of the GL 89-10 test program to provide the NRC staff with certain information.

Specifically, the completion status of the GL 89-10 program as of the current commitment date and information on those MOVs whose capability vill not be verified by dynamic testing by the current commitment date is required to be submitted.

i By letters dated November 8, 1990 (Serial Number 1870) and i September 21, 1992 (Serial Number 1-995), TE committed to completing ,

the Davis-Besse Nuclear Power Station (DBNPS) MOV initial testing l E

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Docket Number 50-346

- License Number NPF-3 Seri'al Number 2247 Page 2 program by startup from the ninth refueling outage (9RFO), which is scheduled to begin on October 1, 1994. Prior to 9RF0, approximately 50 percent of the dynamic tests and 60 percent of the static tests scheduled for the initial test program vill be completed. Dynamic testing which is practicable and meaningful to conduct is expected to be completed within the previously committed time frame. In addition, valves within the scope of the GL 89-10 program vill, as a minimum, be setup and tested under static conditions. Initial evaluations for continued operability for the tested MOVs vill also be completed by the committed date. Upon completion of these activities, the functionality of these valves vill be established using the t at available information. However, additional time vill be required to complete more detailed evaluations and preparation of closure justification packages.

Information on the planned extent of testing and information to be contained in the evaluations mentioned above is provided in the attachment to this letter. Additionally, data obtained from the testing vill be used as input into valve performance prediction models to predict valve performance under design basis conditions. Since these models are not yet available for use, the extension of the evaluation schedule is justified. Completion of these activities is expected by April 1, 1995. Deficiencies identified during the detailed evaluations will be evaluated and corrected within the scope of the DBNPS corrective action program, which will include an evaluation of MOV operability. Corrective actions or additional testing deemed necessary as a result of the detailed evaluations vill be completed no later than the end of the tenth refueling outage.

Should you have any questions or require additional information, please contact Mr. William T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.

Very truly yours, KP/ eld Attachments cc: L. L. Gundrum, NRC Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346

+ License Number NPF-3 Serial Number 2247

. Attachment Page'1 of 3 TOLEDO EDISON TESTING AND EVALUATION PHILOSOPHY The following information provides clarification as to the general philosophy with regard to the extent of testing and content of evaluations necessary to complete the initial M0V testing program pursuant to NRC Generic Letter (GL) 89-10. Note that the dynamic testing philosophy is more comprehensive than was specified in TE's letter dated November 8, 1990 (Serial Number 1870).

Dyn,amic Testing Philosophy It is the philosophy of Davis-Besse Nuclear Power Station (DBNPS) to dynamically test motor operated valves in the GL 89-10 program which are practicable and meaningful to test.

The dynamic test conditions are established as close as possible to design basis conditions. A test is considered not practicable if:

1) The test would place the plant in conditions outside Technical Specification limits;

2) Test line-up or conduct may endanger personnel or result in unacceptable equipment reliability;

3) A plant modification is required to perform the test; or

4) Interlocks must be defeated to perform the test.

A test is not considered meaningful if the results vould provide little or no information in addition to that obtained in a static test.

Examples of tests which are not meaningful include:

1) Test conditions would be at insufficient differential pressure or flow to provide reliable data extrapolation to design basis conditions;

2) Dynamic test data is expected to differ little from static test data; or

3) Diagnostic test equipment cannot be used (i.e., stem or ambient.

temperatures are beyond the capability of the equipment).  ;

l The Davis-Besse MOV Valve Basis Document vill provide documentation of which valves vill be tested dynamically. It vill also provide  ;

justification for those valves which vill not be dynamically tested. l I

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Docket Number 50-346

. License Number NPF-3 Serial Number 2247

.' Attachment Page' 2 of 3 MOV Performance Evaluation Philosophy It is the philosophy of the DBNPS that the valves included in the GL 89-10 program vill be evaluated to verify their design basis capability in accordance with the general guidelines described below.

1) All valves subject to the GL 89-10 program vill be tested under static conditions. As part of the static test, the valve's thrust values will be verified (and adjusted if necessary) to be within the limits established by the valve-specific calculations for static conditions. These calculations use conservative assumptions for valve parameters (e.g., valve factor, stem factor, etc.; based upon the best available industry information) and predict valve performance under design basis conditions. Static tests vill be completed for each valve prior to startup from ninth refueling outage (9RFO).

2) Valves meeting the criteria described earlier for further testing vill be dynamically tested. Data obtained from dynamic testing vill be used in an initial evaluation of the valve's performance. The initial evaluation vi]1 be completed prior to returning a valve to service. The initial evaluations are intended to validate valve performance predictions obtained from the valve-specific thrust calculations. The initial evaluations provide reasonable assurance, in a timely manner, that a valve vill be capable of performing its designated function under design basis conditions. Since all practicable j and meaningful dynamic testing vill be completed by startup from 9RF0, these initial evaluations vill also be completed.

3) After completion of testing, a final evaluation vill be performed for each valve. The final evaluations will involve the following activities, as required:

a) Revision of valve thrust calculations; b) Comparison of test results with results of similar valve testing, both for industry and DBNPS testing; or c) Comparison of test resu)tf eith the Kalsi Engineering computer model. This. computer model was developed as part of the Electric Power Research Ins:1(ute /alve test program ,

and vill be used to predict DBNPS specific valve '

performance under design basis conditions using best available data.

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Docket Number 50-346

. License Number NPF-3 Serial Number 7247 i Attachment Page 3 of 3 .

These final evaluations vill serve as a basis for closure of the testing activities for each valve. Based upon experience gained during valve testing at DBNPS, the final evaluations are not expected to negate the results of the initial evaluations.

However, deficiencies identified during these evaluations vill be evaluated and corrected in accordance with the DBNPS.

corrective action program, which vill include an evaluation of MOV operability.- Should additional testing or corrective actions be varranted as a result of the final evaluations, they i vill be completed no later than the end of the tenth refueling outage (10RFO).

Vith the planned scope of testing during 9RF0, sufficient in-house resources are not available to perform the detailed final evaluations during 9RFO. In addition, the Kalsi Engineering computer model is presently undergoing verification and validation, and is therefore not yet available for use. As such, the final evaluations for all valves in the GL 89-10 program vill not be completed until April 1, 1995.  ;

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. Docket Number 50-346

• License Number NPF-3

. Serial Number 2247 l Enclosure f

' Page 1 of 1 l 1

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i RESPONSE TO GENERIC LETTER 89-10, SUPPLEMENT 6 j ;

FOR l 1

DAVIS-BESSE NUCLEAR POVER STATION j UNIT NUMBER 1 l, i*

This letter is submitted pursuant to 10 CFR 50.54(f). Enclosed is Toledo Edison's response to Generic Letter 89-10, Supplement 6 l (Serial Number 2247), "Information on Schedule and Grouping, and Staff ,

Responses to Additional Public Questions"  ;

By: -

John PC5tetz / l Vice President - Nuclear i Swcirn and subscribed before me on this 16th day of September,1994.

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