ML20114B799
| ML20114B799 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/28/1992 |
| From: | Marsh W SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9208310242 | |
| Download: ML20114B799 (4) | |
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Southern California Edloon Company 2 3 F AH. f H ST Pt [1
- F v iN1-C At J ^;4Nt A 97 716 August 28, 1992 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Schedule for Generic Letter 89-10 "Hotor Operated Valve Testing and Surveillance" San Onofre Nuclear Generating Station Units 2 and 3
References:
1)
Generic Letter 89-10, " Safety Related Motor-Operatrid Valve Testing and Surveillance," issued on June 28, 1989 2)
Supplement 1 to Generic Letter 89-10, "Results of the Public Workshops," issued on June 13, 1990 The purpose of this letter is to request, for San onofre Unit 3, relief from the Generic Letter (GL) 89-10 requirement to complete the Mctor-Operated Valve (MOV) testing within five years or three refueling outages from June 28, 1989.
GL 89-10 allowed refueling outages that started within six months of June 28, 1989, not to be counted as one of the tnree refueling outages.
The Cycle 5 refueling outage was the first Unit 3 refueling outage following the issuance of GL 89-10.
The Cycle 5 refueling outage started on April 14, 1990, approximately 3.S months part the six month grace period.
Because of the magnitude of the MOV testing program, and because the Cycle 5 refueling outage occurred a relatively short period of time after the GL 89-10 issuance, we believe the Cycle 5 refueling outage should not be counted as one of the three refueling outages.
Also, this letter requests additional time following the end of the third refueling outage to Unit 2 and Unit 3 to finalize the program and prepare the report.
9208310242 920928 PDR ADOCK 05000361 P
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l Document Control Desk '
Suppler.ont 1 to Generic Letter 89-10, "Results of the Public Workshops," states the following in the response to Question 41:
)
"... The staff is not planning to extend the generic letter schedule in a formal manner.
hovertheless, d.e staff recognizes thc complexity of the MOV issue and will be flexible in considering requests by individual licensees for schedule extensions.
For example, the staff will consider favorably a request for a schedule extension if the particular licensee has an aggresnive program for performing design-basis testing, where practicable, and for obtaining design-basis test data when such testing in situ is not practicable."
"In paragraph k of the generic letter, the staff indicates that refueling outages that start within six months of the date of the generic letter need not be counted as one of the three cutages specified in the schedule for licensees.
Licensees with refueling outages scheduled shortly after this six-month period might consider themselves unfairly penalized.
The sta'f did not intend to penalize those licenGeeF. but had to er*'blish the cutoff at some point.
The. staff will take th.
fact into consideration when evaluating requests for schedule extensions.
Identifying, planning, and scheduling work to support the mid-April 1990 start of the Unit 3 Cycle 5 refueling outage <as well under way when GL 89-10 was issued.
Bechuse of the complexities of GL 89-10, SCE was unable to test any MOVs during the Cycle 5 refueling outage.
Consequently, the 93 Unit 3 valves currently identified in the MOV program would need to-be tested in two Unit 3 refueling outages to meet the original GL 89-10 schedule.
We tested 43 valves during the recent Cycle 6 refueling outage leaving 50 valves to be tested during the Cycle 7 refueling outage.
The testing of the 50 remaining valves plus the potential rotesting of some valves due to increased industry t
information is a major undertaking and will significantly impact the-Unit 3 Cycle 7 refueling outage critical path.
To avoid lengthening the Unit-3 Cycle 7 refueling outage, Southern California Edison (SCE) proposes a testing schedule based on the fact that both Units 2 and 3 contain valves of similar type, size.-and service.
SCE intends to test-
- approximately 25 valves during the Unit 2 Cycle 7 refueling outage which are of similar type, size, and service to Unit 3 j.
valves necding to be tested.
The majority of the remaining valve types will be tested during the Unit 3 Cycle 7 refueling outage.
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Document Control Desk,
The_ entire in-situ testing program for Units 2 and 3 will be completed in their respective Cycle 8 refueling outages.
Final analysis and additional calculations, following the testing performed during the Cycle.8 refueling, will be completed along with any required out-of-plant testing within 9 months following the end of the' Cycle 8 refueling outage.
SCE needs the additional time following the end of the Cycle 8 refueling to analyze the results of tests performed during the Cycle 8 refueling outage.
These results may require additional calculations and 3 cad to valve testing to be performed under laboratory conditions.
Because Unita 2 and 3 are like kind plants in design and
- construction, a problem idantified in one unit would be applicable to the other unit.
Any concerns about valve operability found by the set point calculations or by testing are applied-to all applicable valves in both units, and, if necessary, immediate action is taken.
For example, based on the results of two Emergency Core Cooling System Miniflow Valve Test-Failures at Unit 3 in the first quarter of 1992, we shut dcwn Unit 2 to test valves of similar type, size, and service.
The results of these tests showed strong performance correlations between valves at Units 2 and 3.
That is, valves in the two Units were experiencing similar deficiencies.
Therefore, SCE requests that Unit 3 be allowed until the end of the Cycle 8 refueling outage, approximately August of 1995, to complete the GL ' 89-10 MOV in-situ testing requirements, based on the following reasons:
the Unit 3 Cycle 5 refueling outage occurring only about 3.5 months past the six month GL 89-10 grace
- period, lengthening the Unit 3 Cycle 7 refueling outage to test
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all 50 remaining valven, L
the najority of MOV types, sizes and oervices in use at L
San Onofre Unit 3.boing tested within the GL 89-10 original' schedule,_i.e. approximately 68 valves at Unit 3 and the remaining valves (approximately 25) at Unit 2,-and.
the potential need to retest-certain valves due to L
increased-industry information concerning MOV l
. performance.
SCE also requests an_ additional 9 months following the Cycle _8 refueling outage for Unit 2 and Unit 3 to complete the final i;
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Document Cont 7lol Desk
~4-analyses, - c.ilculations, out-of-plant testirv;, and the final report.
If have any questions, please call me.
Very truly youru, df4ll%0l1lda Walter C. Marsh Assistant Manager, Nuclear Regulatory Affairs cc:
J.
B. Martin, Regional Administrator, NRC Region V
- l C.
W.
Caldwell, NRC Senior Resident Inspector, San Onofre
-Unitr
- 1., 2&3 M.
D.
Fields, NRC Project Manager, San Onofre Units 2 and 3
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