BSEP-97-0072, Forwards Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves
| ML20137C040 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/17/1997 |
| From: | Campbell W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-97-0072, BSEP-97-72, GL-89-10, GL-96-05, GL-96-5, NUDOCS 9703240139 | |
| Download: ML20137C040 (6) | |
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CP&L 1
e Carolina Power & Light Company William R. Campbell PO Box 10429 Vice Presicient Southport NC 28461 Brunswick Nuclear Plant SERIAL: BSEP 97-0072 MAR 171997 i
United States Nuclear Regulatory Commission ATTENTION: Document Control Desk l
j Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS 1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 RESPONSE TO NRC GENERIC LETTER 96-05, " PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-OPERATED VALVES "
Gentlemen:
On September 18,1996, the NRC staff issued Generic Letter 96-05, " Periodic Verification 4
of Design-Basis Capability of Safety-Related Motor-Operated Valves (MOVs)." This response provides Carolina Power & Light (CP&L) Company's 180-day response as requested by the Generic Letter for the Brunswick Steam Electric Plant, Unit Nos.1 and 2. provides a summary of the implementation plan for the MOV periodic verification program, with Enclosure 2 providing a list of commitments.
i Please refer any questions regarding this letter to Mr. Keith Jury, Manager - Regulatory Affairs, at (910) 457-2783.
Sincerely, b
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William R. Campbell GMT/
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Enclosures:
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- 1. Response
- 2. List of Regulatory Commitments w:
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t William Levis, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power &
Light Company.
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My commission expires:
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cc:
Mr. L. A. Reyes, NRC Regional Administrator, Region 11 i
Mr. D. C. Trimble, Jr., NRR Project Manager - Brunswick Steam Electric Plant Mr. C. A. Patterson, NRC Senior Resident inspector - Brunswick Steam Electric Plant The Honorable J. A. Sanford, Chairman - North Carolina Utilities Commission i
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u ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 RESPONSE TO NRC GENERIC LETTER 96-05
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" PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-i OPERATED VALVES"
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CP&L's Brunswick Steam Electric Plant, Unit Nos.1 and 2 intends to implement the following requested actions of Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves (MOVs)" as outlined below:
j NRC Reauested Action Each addressee of this generic letter is requested to 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 j
within the current licensing bases of the facility. The program should ensure that changes in required performance resulting from degradation (such as those caused by age) can be properly identified and accounted for. Addressees that have developedperiodic verification programs in response to GL 89-10 should review those programs to determine whether any changes are appropriate in light of the information in this generic letter.
NRC Reauired Response Within 180 days from the date of this generic letter, or upon notification to the NRC of completion of GL 89-10 (whicheveris later), the addressee shallsubmit a written summary description ofits MOVperiodic verification program establishedin accordance with the Requested Actions paragraph or the alternative course of action established by the addressee in response to item 1 above.
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k CP&L Response CP&L's Brunswick Steam Electric Plant, Unit Nos.1 and 2 intends to implement a MOV periodic verification program that will comply with the intent of Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves (MOVs)," as outlined below. At the present time, Brunswick Steam Electric Plants have a periodic verification program such that over five years or three refueling outages, static testing of MOVs within the scope of GL 89-10 is performed. CP&L recognizes that a static testing program does not detect age related degradation, and is therefore participating in the Joint Owners' Group (JOG) test program, established by the Boiling Water Reactor (BWR) Owners' Group and j
the Westinghouse Owners' Group, to incorporate dynamic testing results into j
CP&L's program. CP&L willimplement a MOV periodic verification program which conforms to the JOG program. The scope of the valves in the CP&L MOV periodic j
verification program will be identical to the scope of the GL 89-10 program. The CP&L program will consist of three elements:
i 1.
The first element is a static test program to periodically confirm that each affected MOV is set up to assure that it is capable of performing its required safety function. The existing static periodic verification program will be appropriately adjusted to satisfy the requirements of the JOG test program.
CP&L will determine new test frequencies based on safety significance and margin, as appropriate. Safety significance has been determined based on i
guidance provided in NEDC 32264, " Application of Probabilistic Safety i
Assessment to Generic Letter 89-10 Implementation." Margin will be determined based on guidance provided in NEDC 32719, "BWR Owners' Group Program on Motor-Operated Valve (MOV) Periodic Verification." The margin criteria used at CP&L to establish test frequencies is to be at least as conservative as those specified by the JOG program description.
2.
The second element is a dynamic test program. CP&L, in cooperation with the other JOG test program plants, will be performing differential pressure tests on a representative population of MOVs over a period of five years.
The population of valves in the JOG test program was selected such that it would cover the range of the key factors which may influence potential degradation. The results of these tests will be used to verify, or if necessary, to modify the criteria in the interim test program. The dynamic tests will be performed and evaluated in accordance with the uniform specifications of the JOG test program, thereby ensuring that consistent results are obtained from the various participants.
The JOG program provides for periodic assessment and evaluation of test results to ensure that findings are disseminated to member plants in a timely manner. The assessment frequency specified in the JOG program document is at least once annually. CP&L will participate in the assessment and El-2
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i evaluation process and will adjust its periodic verification program as appropriate. CP&L will address any applicable safety assessment issues identified by the NRC during its review of the JOG testing program and the i
resulting MOV test data.
3.
At the completion of the dynamic test element, the results of the JOG j
program will be appropriately incorporated into CP&L's MOV periodic j
verification program for the Brunswick Steam Electric Plant.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 RESPONSE TO NRC GENERIC LETTER 96-05
" PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-OPERATED VALVES" LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Carolina Power & Light Company in this document. Any other actions discussed in the submittal represent intended or planned actions by Carolina Power & Light Company. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager-Regulatory Affairs at the Brunswick Nuclear Plant of any questions regarding this document or any associated regulatory commitments.
Commitment Committed j
date or j
outage j
1.
CP&L will implement a Motor Operated Valve periodic verification j
program as a participant in the Joint Owners' Group test program N/A that is in accordance with the actions delineated in Generic Letter 96-05.
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