ML20199E668

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Forwards RAI Re Licensee Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, for Plant,Units 1 & 2
ML20199E668
Person / Time
Site: Beaver Valley  FirstEnergy icon.png
Issue date: 01/14/1999
From: Dan Collins
NRC (Affiliation Not Assigned)
To: Cross J
DUQUESNE LIGHT CO.
References
GL-96-05, GL-96-5, TAC-M97015, TAC-M97016, NUDOCS 9901210047
Download: ML20199E668 (6)


Text

. . Mr. J. E. Cross January 14, 1999 Pr:sid:nt-Grntr; tion Group Duquasn3 Light Comp:ny Post Office Box 4 i Shippingport, PA .15077 i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING RESPONSE TO GENERIC LETTER (GL) 96-05 FOR BEAVER VALLEY POWER STATION, '

UNIT NOS.1 AND 2 (TAC NOS M97015 AND M97016)

Dear Mr. Cross:

On September 18,1996, the NRC issued Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to request that nuclear power plant licensees establish a program, or ensure the effectiveness of the current program, to verify on a periodic basis that safety-related motor-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On April 13,1998, Duquesne Light Company (DLC) submitted an updated response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on l MOV Periodic Verification at Beaver Valley Power Station, Units 1 and 2 (BVPS-1 and BVPS- l

! 2). The NRC staff has encouraged licensees to participate in the industry-wide JOG program '

to provide a benefit in reactor safety by sharing expertise and information on MOV performance and to increase the efficiency of GL 96-05 activities at nuclear plants.

The NRC staff has been reviewing your submittals, however, we have determined that additionalinformation is required to complete our review of DLC's JOG Program implementation at BVPS-1 and BVPS-2. The NRC requests that you provide a response to the enclosed RAI within 60 days of receipt of this letter. This was discussed with Lyle Berry of i your staff on January 6,1999 and was established as a mutually agreeable timetable for your l response. If circumstances result in the need to revise the target date, please call me at the earliest possible opportunity.

If you have any questions regarding this request, please contact me at (301) 415-1427.

Sincerely. O r i gi n a l signed by

Daniel S. Collins, Project Manager l l Project Directorate I-1 l

9901210047 990114 Division of Reactor Projects - l/11 l DR ADOCK 050003 4 Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

Request for Additional r

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t Docket File MO'Brien DCollins TSarbrough DTerao PUBLIC JZwolinski MO'Brien ACRS PDI-1 Reading SBajwa OGC Peselgroth, Region 1 OFFICE pol-1/PM PbfN/td > PDI-1/D NAME D 1 :lec FIdB[i n SBajwa h DATE I /O/99 )/N99 / /N/99 l OFFICIAL RECORD COPY DOCUMENT NAME: G:\ BEAVER \RAl97015.WPD

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. Mr. J. E. Cross January 14, 1999 i .

Prasidsnt-Gantration Group Duqussna Light Company q Post Office Box 4 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING RESPONSE TO GENERIC LETTER (GL) 96-05 FOR BEAVER VALLEY POWER STATION, UNIT NOS.1 AND 2 (TAC NOS. M97015 AND M97016)

Dear Mr. Cross:

On September 18,1996, the NRC issued Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to request that nuclear power plant licensees establish a program, or ensure the effectiveness of the current program, to verify on a periodic basis that safety-related motor-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On April 13,1998, Duquesne Light Company (DLC) submitted an updated response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification at Beaver Valley Power Station, Units 1 and 2 (BVPS-1 and BVPS-2). The NRC staff has encouraged licensees to participate in the industry-wide JOG program to provide a benefit in reactor safety by sharing expertise and information on MOV performance and to increase the efficiency of GL 36-05 activities at nuclear plants.

The NRC staff has been reviewing your submittals, however, we have determined that additionalinformation is required to complete our review of DLC's JOG Program implementation at BVPS-1 and BVPS-2. The NRC requests that you provide a response to the enclosed RAI within 60 days of receipt of this letter. This was discussed with Lyle Berry of your staff on January 6,1999 and was established as a mutually agreeable timetable for your response, if circumstances result in the need to revise the target date, please call me at the earliest possible opportunity.

l If you have any questions regarding this request, please contact me at (301) 415-1427.

I Sincerely. Ori gi n al signed by:

Daniel S. Col; ins, Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

Request for Additional information ,

l cc w/ encl: See next page DISTRIBUTION:

Docket File MO'Brien DCollins TSarbrough DTerao PUBLIC JZwolinski MO'Brien ACRS PDI-1 Reading SBajwa OGC Peselgroth, Region i OFFICE PQl-1/PM PDfht 3 PDI-1/D NAME D$1  : Ice thdNn SBajwa DATE I / B/99 //b99 [ //k/99 OFFICIAL RECORD COPY DOCUMENT NAME: G:\ BEAVER \RAl97015.WPD

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[ ,j l UNITED STATES NUCLEAR REGULATORY COMMISSION

, g l p 't WASHINGTON, D.C. 20556 4001 l b y,g # January 14, 1999 Mr. J. E. Cross President-Generation Group Duquesne Light Company Post Office Box 4 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING RESPONSE TO GENERIC LETTER (GL) 96-05 FOR BEAVER VALLEY POWER STATION, UNIT NOS.1 AND 2 (TAC NOS. M97015 AND M97016)

Dear Mr. Cross:

On September 18,1996, the NRC issued Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to request that nuclear power plant licensees establish a program, or ensure the effectiveness of the current program, to verify on a periodic basis that safety-related motor-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On April 13,1998, Duquesne Light Company (DLC) submitted an updated response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification at Beaver Valley Power Station, Units 1 and 2 (BVPS-1 and BVPS-2). The NRC staff has encouraged licensees to participate in the industry-wide JOG program to provide a benefit in reactor safety by sharing expertise and information on MOV performance and to increase the efficiency of GL 96-05 activities at nuclear plants.

The NRC staff has been reviewing your submittals, however, we have determined that additionalinformation is required to complete our review of DLC's JOG Program implementation at BVPS-1 and BVPS-2. The NRC requests that you provide a response to the enclosed RAI within 60 days of receipt of this letter. This was discussed with Lyle Berry of your staff on January 6,1999 and was established as a mutually agreeable timetable for your response, if circumstances result in the need to revise the target date, please call me at the earliest possible opportunity, if you have any questions regarding this request, please contact me at (301) 415-1427.

Sincerely,

/ 2( 5 bw" 6 l Daniel S. Collins, Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

Request for Additional information cc w/ encl: See next page l

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I 3

J. E. Cross Beaver Valley Power Station, Units 1 & 2 Duquesne Light Company

- cc:

Jay E. Silberg, Esquire Bureau of Radiation Protection Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of 2300 N Street, NW. Environmental Resources Washington, DC 20037 ATTN: Michael P. Murphy Post Office Box 2063 i Director-Safety and Licensing Harrisburg, PA 17120 '

Department (BV-A) l Duquesne Light Company Mayor of the Borough of

! Beaver Valley Power Station Shippingport  !

PO Box 4 Post Office Box 3 Shippingport, PA 15077 Shippingport, PA 15077 Commissioner Roy M. Smith Regional Administrator, Region i West Virginia Department of Labor U.S. Nuclear Regulatory Commission

- Building 3 Room 319 )

475 Allendale Road i Capitol Complex King of Prussia, PA 19406 Charleston, WV 25305 Resident inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public Utilities Commission Post Office Box 298 180 East Broad Street Shippingport, PA 15077 Columbus, OH 43266-0573 Director, Pennsylvania Emergency Duquesne Light Company

~ Management Agency Beaver Valley Power Station Post Office Box 3321 PO Box 4 Harrisburg, PA 17105-3321 Shippingport, PA 15077 I ATTN: S. C. Jain, Senior Vice President Ohio EPA-DERR Nuclear Services (BV-A)

ATTN: Zack A. Clayton Post Office Box 1049 Mr. J. A. Huitz, Manager i l- Columbus, OH 43266-0149 Projects & Support Services First Energy l- Dr. Judith Johnsrud 76 South Main Street ,

j National Energy Committee Akron, OH 44308  ;

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? Sierra Club '

l - 433 Orlando Avenue State College, PA 16803

Duquesne Light Company
Beaver Valley Power Station
PO Box 4 Shippingport, PA 15077 l ATTN: Kevin L. Ostrowski, Division Vice l

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l REQUEST FOR ADDITIONAL INFORMATION REGARDING RESPONSE TO GENERIC LETTER 96-05 FOR BEAVER VALLEY POWER STATION. UNIT NOS.1 AND 2.

DOCKET NOS. 50-334 AND 50-412 l

1. In NRC Inspection Report No. 50 344 & 412/95-12, the NRC staff closed its review of 1 the motor-operated valve (MOV) program implemented at the Beaver Valley Power j Station, Unit Nos.1 and 2 (BVPS-1 and BVPS-2), in response to Generic Letter (GL) l l 89-10, " Safety Related Motor-Operated Valve Testing and Surveillance." In the inspection report, the NRC staff discussed certain aspects of Duquesne Ught Company's (DLC's) MOV program to be addressed over the long term. For example, l the inspectors noted that (1) DLC's periodic verification program will gather additional data to support the use of a 10% load sensitive behavior margin; (2) DLC planned to increase the thrust margin for the Unit 1 quench spray pump discharge valves prior to {

the end of the next refueling outage; (3) DLC relied on available valve factors in some  !

cases where the assumed valve factors did not have strong support; and (4) DLC's periodic verification program will gather additional data to determine if stem lubricant degradation is occurring. Please describe the actions taken to strengthen group valve factor assumptions and address the specific long-term aspects of the MOV program at BVPS-1 and BVPS-2 noted in the subject NRC inspection report. l l

2. In a letter dated November 18,1996, DLC stated its commitment to implement the Joint l Owners Group (JOG) Program on MOV Periodic Verification in response to GL 96-05.

The JOG program specifies that the methodology and discrimination criteria for ranking i MOVs according to their safety significance are the responsibility of each participating i licensee, in a subsequent letter dated April 13,1998, DLC stated that risk ranking of MOVs at BVPS-1 and BVPS-2 for application of the JOG interim MOV static diagnostic i testing program will be based on guidance provided in Westinghouse Owners Group 4 (WOG) Engineering Report V-EC-1658-A (Revision 1), " Risk Ranking Approach for Motor Operated Valves in Response to Generic Letter 96-05," with some stated j exceptions. For example, DLC stated that (1) MOVs were only ranked based on Core i Damage Frequency (CDF) importance measures, (2) only MOVs not modeled in the probabilistic risk assessment (PRA) were reviewed by the expert panel, (3) the PRA analyst used his judgment to review the quantitative ranking based on PRA CDF importance measures, and (4) MOVs that were only modeled as passive failures were ranked based on CDF, and then qualitatively reassessed by the PRA analyst. These exceptions do not appear to reflect the importance of the expert panel as described by WOG Engineering Report V-EC-1658-A and the NRC safety evaluation dated April 14, '

1998. DLC should describe the composition and duties of the expert panelin risk ranking MOVs at BVPS-1 and BVPS-2. With respect to each of its specific exceptions,

DLC should justify that its MOV risk-ranking approach is consistent with the guidance  ;

i contained in WOG Engineering Report V-EC-1658-A and the NRC safety evaluation.

In light of its exceptions to the WOG MOV risk-ranking approach, please discuss consideration of the example list of risk significant MOVs provided by the WOG in the j engineering report.

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3. The JOG program focuses on the potential age-related increase in the thrust or torque required to operate valves under their design-basis conditions. In the NRC safety evaluation dated October 30,1997, on the JOG program, the NRC staff specified that licensses are responsible for addressing the thrust er torque delivered by the MOV motor actuator and its potential degradation. Please describe the plan at BVPS-1 and BVPS-2 for ensuring adequate ac and de MOV motor actuator output capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement 1.

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