ML20092M073
| ML20092M073 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/20/1995 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9509280330 | |
| Download: ML20092M073 (3) | |
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Southem Califomia Edison Company l-P. O. box 128 SAN CLEMENTE, CALWORNIA 92674 0128 MICHARD M ROSEN8 LUM tt Lt pwoest
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September 20, 1995 U.S.. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C.
20555 Gentlemen:
Subject:
Docket No. 50-361 and 50-362 NRC Inspection Report 50-361/95-13 and 50-362/95-13 San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 The purpose of this letter is to provide additional information regarding two NRC comments documented in the subject inspection report, as follows:
MOV LUBRIC 710N PROGRAM The second page of the subject inspection report summary, under the heading of' Engineering, reads in part, While long in coming, the recently developed program for assessing replacement frequency of motor-operated valve grease appeared thorough....
Edison disagrees with the phrase "while long in coming...".
The associated inspection report section 5.3 discussing this issue provides no basis in fact for this opinion.
Edison believes a review of the facts and circumstances, provided below, indicates
'a prudent and timely evolution of the grease program.
At initial licensing in 1983, the grease inspection program was based on Limitorque's " Lubrication, Inspection Procedure and Data" vendor manual which recommends grease inspection "...every_
18 months or until operating experience indicates otherwise."
In
.1988,~ Edison had developed sufficient operating experience to justify a change to every three fuel cycles.
The following year, Generic Letter (GL) 89-10'was.. issued, causing l
Edison, over;a five year period,:to modify our programs;to test' and maintain motor-operated valves (MOVs).
Our GL 89-10 effort g92so33o950920 g~.ADOCK 05000361
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,)*"[5 DOCUMENT lCONTR'OLLDESK-will be complete byfthe end of the current refueling outage on
. SONGS Unit'3.
As part of the GL 89-10 program to. enhance MOV preventive-
. maintenance, Edison modified the "everyLthree cycles" grease inspection frequency to incorporate a new methodology which accommodates-the different MOV environments (e.g.,
temperature, gear speed, etc.), and the relative safety significance of the MOV application.
It is expected all GL 89-10 MOVs will be incorporated into the enhanced preventive _ maintenance program by
.the end of 1995, which is compatible with the final NRC approved implementation date for GL 89-10.
E In-summary, Edison believes the NRC has mis-characterized the timelinesslof the MOV lubrication-inspection program by describing it as "long in coming." We believe the. program was developed in.a timely manner, concurrently with the NRC approved schedule for GL 89-10 implementation.
. WORK.AROUNDS Inspection Report 95-13,.Section 2.3,
" Unit 2' Power Ascension on June-14F 1995," characterizes the following as a work around:
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.The high pressure turbine' governor valves provided secondary steam pressure oscillations which led to reactor coolant temperature. swings at low power...
The licensee had modified these. valves during the-Cycle 8 outage, in order to decrease. steam
-differential pressure, and the valves now provided the oscillations when not fully open.
The inspector considered this was due to a design problem which the licensee was already aware of and was reviewing at the end of the inspection period.
The noted pressure / temperature oscillations were not expected as
(. P) governor a' result of the modifications to the High Pressure H
valves.-
Considerable design efforts, including prototype valve
-testing, had been done to ensure the new design would not have abnormal flow induced pressure disturbances.
Edison does not believe the modifications to the HP governor valves.were'the cause of.the secondary.s'eam pressure c
. oscillations.- The oscillations occurred independent of the 1
. governor valve modification'and in spite of diligent design.
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- DOCUMENT ~ CONTROL DESK bs fengineering efforts _and prototype testing to ensure the, design is-
. s t abl e '. - The magnitude of the oscillations was such that the-appropriate management action was to continue the unit-return to service:while additional information was obtained to determine-
'the' root cause.
'In. contrast,' Edison' defines-an operator "workJaround" to be an
~ action performed'by. operators so that a responsible resolution of a plant problem can be avoided.
There is no such element of avoidance of responsible conduct in this instance.
If you have any further-questions or comments please call me.
Sincerely,
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cc:
L. J. Callan, Regional-Administrator, NRC-Region IV J. E. Dyer, Director of Reactor Projects, NRC Region.IV 2
K. E.JPerkins, Jr.,. Director, Walnut Creek Field Office J. A. Sloan,.NRC Senior Resident-Inspector, San Onofre Units
- 2. & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 & 3 1
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