ML20137A747
| ML20137A747 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/17/1997 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-96-05, GL-96-5, NLS970049, NUDOCS 9703210070 | |
| Download: ML20137A747 (6) | |
Text
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- h P.O. BOX ILL NEB 4 A 68321 Nebraska Public Power District "M*ETi NLS970049 March 17,1997
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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Response to NRC Generic Letter 96-05 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. NRC Generic Letter 96-05 dated September 18,1996," Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves"
- 2. Letter to USNRC from G. R. Horn dated November 18,1996," Response to NRC Generic Letter 96-05" i
This submittal provides the Nebraska Public Power District's (District's) 180 day response to NRC Generic Letter (GL) 96-05 (Reference 1). As committed to in the 60 day response l
(Reference 2), the District has established a program to verify on a periodic basis that safety-related MOVs continue to be capable of performing their safety functions within the current licensing bases for Cooper Nuclear Station (CNS). Additional details on this program are provided in Attachment 1.
Should you have any questions concerning this matter, please contact me.
1 Sine rely,
/n orn Sen r Vice President Of Energy Supply
/crm Attachment ec: Regional Administrator USNRC - Region IV
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NLS970049 March 17,1997 Page 2 of 3 Senior Project Manager 4
USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution
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NLS970049 March 17,1997 Page 3 of 3 STATE OF NEBRASKA
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NEMAHA COUNTY
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G. R. Horn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this correspondence on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.
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. Horn Subsciibed in my presence and sworn to before me this / '7" day of / )lthod_,1997.
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A'ttachment I to NLS970049 Page1of2 1
PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-OPERATED VALVES (NRC GENERIC LETTER 96-05)
Background
Based on concerns regarding the limited guidance provided in Generic Letter (GL) 89-10 and its supplements for the preservation of motor operated valve design-basis capability, the NRC issued GL 96-05. The GL requested licensees establish a program, or to ensure the effectiveness ofits current program, to verify on a periodic basis that safety-related MOVs continue to be capable of performing their safety functions within the current licensing basis of the facility. An overview of the program implemented to address the periodic verification of the design-basis capability of safety-related motor-operated valves at Cooper Nuclear Station (CNS) is provided below.
Discussion In response to GL 96-05, the industry established the Joint Owners' Group (JOG) Periodic Verification (PV) Program. The purpose of this program is to collect data on a broad range of valve applications in order to develop a sound engineering basis for addressing potential changes in required thrust or torque and valve factors over time. Accordingly, the District hasjoined the i
JOG PV Program and has committed to dynamically testing selected valves in accordance with test specifications established in NEDC-32719,"BWR Owners' Group Program on Motor-Operated Valve (MOV) Periodic Verification."' As the data gathered under the JOG PV Program is compiled and evaluated, the CNS MOV Program will be modified, as required, to l
encompass conclusions drawn from the industry testing.
4 Except as noted below, static testing per NEDC-32719 will begin during Refueling Outage 17, scheduled to begin on March 28,1997. Under the JOG PV Program, the frequency for ongoing testing is established by a matrix that associates risk and margin criteria. To ensure that the test frequency for program MOVs does not exceed the specified interval, the initial testing interval for each valve is derived using the most recent test date.
l in response to NRC Inspection Report 96-10, the District com.mitted to maintaining the existmg available valve factors for Program Groups 2,3, and 8 valves until a related Inspector Follow-up j
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Transmitted to the NRC under BWROG-97061 letter to USNRC from K. P.
Donovan (BWROG) dated March 7,1997,"BWR Owners' Group Program on Motor-Operated Valve (MOV) Periodic Verification (NEDC-32719, dated March 1997)"
O A'ttachm'eni 1 to NLS970049 Page 2 of 2 Item (IFI)is resolved 2 Accordingly, valves in these groups will be static tested at the frequency established by the current CNS MOV PV Program until either:
The related IFI is closed; or Margins are established through testing, modifications, configuration changes, etc.; or Documented valve factors are validated.
Once one of the above actions is accomplished, the testing frequency for these valves will be established by NEDC-32719 matrix.
While the scope of static testing has been frozen for Refueling Outage 17, changes to the frequency of static testing will be evaluated in response to industry issues, changes in margin, etc.
Due to required modifications to support JOG PV Program testing, dynamic testing of the CNS assigned valves will begin in Refueling Outage 18 (scheduled during the Fall of 1998) and will continue for three outages.
The above described testing supersedes commitments for periodic verification as delineated in GL 89-10 closure documentation. Currently, the margin for program MOVs is established based on the valve design setup criteria (i.e., group valve factors, bounding coefficient-of-friction, assumed packing load, calculated differential pressure loads, bounding rate-of-loading, standard equipment / component errors, and degradation margin). This methodology will continue to be used and any additional margin above this will be evaluated against the JOG PV Program matrix to determine the static testing interval. While MOVs that are positioned out of their normal system lineup due to surveillance testing are not formally included in the MOV program as documented in the closure documentation for GL 95-073A, these valves will continue to be maintained with sufficient analytical capability to return to their standby system lineup position.
2 Letter to T. P. Gwynn (USNRC) from P. D. Graham (NPPD) dated August 6, 1996," Confirmation of Commitment" 3
Letter to USNRC from G. R. Horn (NPPD) dated October 13,1995, "60 - Day Response to Generic Letter 95-07, Cooper Nuclear Station, NRC Docket 50-298,DPR-46" d
Letter to USNRC from G. R.. Horn (NPPD) dated February 13,1996, "I 80 - Day Response to Generic Letter 95-07, Cooper Nuclear Station, NRC Docket 50-298,DPR-46"
- l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS970049 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Except as noted below, static testing per NEDC-32719 will RE17 begin during Refueling Outage 17.
Valves in Groups 2, 3,
and 8 will be static tested at the frequency established by the current CNS MOV PV Program until either: the related IFI is closed; or margins are established through testing, modifications, configuration None changes, etc.; or documented valve factors are validated.
Once one of the these actions is accomplished, the testing frequency for these valves will be established by NEDC-32719 matrix.
Dynamic testing of the CNS assigned valves will begin in RE18 Refueling Outage 18 (scheduled during the Fall of 1998) and will continue for three outages.
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PROCEDURE NUMBER 0.42 l
REVISION NUMBER 3 C1 l
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