ML20096G897
| ML20096G897 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/22/1992 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-92-0077, ET-92-77, GL-89-10, NUDOCS 9205270033 | |
| Download: ML20096G897 (3) | |
Text
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/
W9LP CREEK
' NUCLEAR OPERATING CORPORATION May 22, 1992 rorresi t anodes Vice Presider,t Eng:neering & Technical Serwc*$
ET 92-0077
'Yt U. S. Nuclear Regul.icory Commission ATTN:
Document Control Desk Mail Station Pl-137 gb M *#
'f}h Washington.'D. C. 20555 w
Subject:
Docket No.
50-482:
Schedule Extension to Complete initial Test Program Pursuant to Generic Letter 89-10
" Safety-Related Motor-Operated Valve Testing and Surveillance" Gentlemen:
The purpose of this letter is to propose a limited extension to the final completion date for the initial test program required by Generic Letter 89-10 for Wolf Creek Generating Station.
The completion date, pursuant to Generic Letter 89-10, is June 29, 1994.
Molf Creek Nuclear Ci9 rating Corporation believes a six month extension, to December 31,
- 1994, is necessary in order to encompass an additional refueling outage.
The attachment provides an explanation and justification for the proposed extension.
If you have any questions concerning this matter, please contact me or Mr. S. G. Wideman of my staff.
Very truly yoars,
/'
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.:W Forrest T. Rhodes Vice President Engineering & Technical Services FTR/aem Attachment cci A. T. Howell (NRC), w/a R. D. Martin (NRC), v/a G. A.
Pich (NRC), v/a W. D. Reckley (NRC), w/a
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) B x 411 Burhngt n. KS 66839 Phone (316) 364 8831 482 PDR An Eaus Optundy Empoyt M F HC VET Il0 p
Attachment to ET 92-0077 Page 1 of 2 Justification for Proposed Extension
)
In letter NO 89-0228, dated December 26, 1989 to NRC from J.
A.
- Bailey, WCNOC, Wolf Creek Nuclear Operating Corporation (WCNOC) committed to meet the schedule requirements of Generic Letter 89-10
" Safety-Related Motor-Operated Valve Testing and Surveillance."
This Generic Letter required all design basis reviews,
- analysis, verifications, tests and g*I 4
inspections be completed within 5 years or three refueling outages of the date of the r,eneric letter, whichever is later.
For WCNOC, June 28, 1994 is the later.
However, with the increased attention and realization of the
(.
requirements associated with complying to Generic Letter 89-10, especially g
in regard to design basis testing, a schedule extension to December 31, 1994 is needed.
This extension, in respect to the recent Motor-Operated Valve (MOV) activities and improved program, was discussed between WCNOC and NRC personnel during the MOV inspection that was conducted in November 1991.
A schedule extension to the end of 1994 will encompass WCNOC's seventh refueling outage and thereby provide an additional refueling outage in which to perform all design basic testing and other activities related to the MOV Program.
The need for the additional refucling outage is twofold.
The first consideration includes scheduling and operability.
By maintaining the current refueling schedules, peak load requirements are met and there is no impact on fuel design or spent fuel storage.
Including an additional scheduled outage increases the time frame in which to test MOVs that cannot be tested during power operation.
It will allow additional outage time to test MOVs that, if tested at power, may pose a risk to continued plant operation.
The concern associated with at-power testing is greater for some MOVs due to the potential for entering Limiting Conditions for Operability (LCO's) required by the Technical Specifications.
The need for entering voluntary LCO's, if warranted, would be decreased, if not eliminated, and r
thereby lessening the possible effects of at-powe. te s ti ng.
7 The second factor has resulted from MOV activities associated with the fifth refueling outage.
Management and plant personnel now have an increased awareness and more aggressive attitude toward implementation of the MOV Program and WCNOC's commitment to ensuring compliance with Generic Letter 89-10.
This has been demonstrated by the significant efforts made by WCNOC in reviewing, evaluating and correcting hardware related MOV deficiencies prior to the restart from the tifth refueling outage.
This effort initiated anu implemented formal procedures that documented design basis reviews as well as calculations necessary for MOV sizing, thrust / torque requirements and switch settings.
The work activities involved a review of current industry issues and utilized conservative assumptions, for coefficient of friction, degraded voltage, rate of loading, and torque switch repeatability.
Deficiencies and generic problems were investigated in order to determine the scope and consequences for other applicable MOV's.
In addition, past operability reviews were performed on MOVs within the scope of the restart effort.
Attachment to ET 92-0077 Page 2 of 2 A dedicated full-time MOV team has been established to continue the evaluation of WCNOC's safety-related MOV's within the Generic Letter 89-10 MOV Program.
This team has been chartered with creating a long term MOV Program to fully implement the requirements of the generic letter.
The MOV selection for each outage has been based upon a priority of importance in order that MOVs requiring increased attention are reviewed and evaluated first. MOV priority was based on a rating system using four factors.
These factors are safety significance, high dP on valve opening, high dP on valve closing and known MOV maintenance work based upon testing and trending to date.
Based on this prioritizatioa, a plan has been developed to fully implement the requirements of Generic Letter 89-10 for approximately two thirds of the safety-related MOVs by the original June 1994 date.
Testing of the remaining MOVs will be completed by December 31, 1994.
WCNOC's approach to the initial test program requirements of Generic Letter 89-10 is now more focused on compliance and the overall long term MOV Program establishment.
The realiza+1on of the safety significance and technical issues involved has created the proper attention necessary to pursue and implement all aspects relevant to the MOV Program at WCNOC.
However, this enhanced approach to MOV testing requires tLe extension of the completion date for Generic Letter 89-10 compliance to December 31, 1994.
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