ML20205D613

Discusses GL 96-05 Issued by NRC on 960918 & NNECO 970317 Response to GL 96-05,indicating Intent to Implement Provisions of JOG Program on MOV Periodic Verfication at Millstone 2.Forwards RAI Re GL 96-05

ML20205D613
Person / Time
Site:	Millstone
Issue date:	03/23/1999
From:	Stephen Dembek NRC (Affiliation Not Assigned)
To:	Necci R NORTHEAST NUCLEAR ENERGY CO.
References
GL-96-05, GL-96-5, TAC-M97068, NUDOCS 9904020254
Download: ML20205D613 (6)

Text

r 1 Mr. Rtymond P. N:cci March 23, 1999 Vics Prrsid:nt - Nucir r Ov:rsight end Ragul:ttory Affairs Northeast Nuclear Energy Company ,

c/o Mr. David A. Smith Manager - Regulatory Affairs P.O. Box 128 Waterford, CT 06385 1

I

SUBJECT:

REQUEST F OR ADDITIONAL INFORMATION REGARDING GENERIC LETTER j 96-05 PROGRAM AT M:LLSTONE NUCLEAR POWER STATION, UNIT 2 (TAC )

. NO. M97068) -

Dear Mr. Necci:

On September 18,1996, the U.S. Nuclear Regulatory Commission (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 that safety-related motor-operated valves (MOVs) j continue to be capable of performing their safety functions within the current licensing basis of the i facility. '

On March 17,1997, Northeast Nuclear Energy Company submitted a response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification at Millstone, Unit 2. The NRC staff has encouraged licensees to participate la ,

the industry-wide JOG program to provide a benefit in reactor safety by sharing expertise and i information on MOV performance and to increase the efficiency of GL 96-05 activities at nuclear plants. Licensee participation in the JOG program also minim!1es the amount of information necessary for the NRC staff to review each licensee's response to GL 96-05. As a result, the NRC staff requires only limited information to complete its GL 96-05 review for Millstone, Unit 2.

Enclosed is a request for additional information. Please respond to this request within 60 days of receipt of the forwarding letter. This schedule was agreed to in a March 22,1999, phone call with Mr. Ravi Josni of your staff. ,

Sincerel .

l ephen k, Project Manager 9940g2 gg i-Droject Directorate 1-2

)ivision of Licensing Project Management P PDR ,

Office of Nuclear Reactor Hegulation Doci:et No. 50-336

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Enclosure:

Request for Additional Information

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(, s* NUCLEAR REGULATORY COMMISSION 2 WASHINGTON D.C. WS 0001 g */ Maren 23, 1999 Mr. Raymond P. Necci Vice President - Nuclear Oversight and Regulatory Affairs Northeast Nuclear Energy Company c/o Mr. David A. Smith Manager- Regulatory Affairs P.O. Box 128

. Waterford, CT 06385 )

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 PROGRAM AT MILLSTONE NUCLEAR POWER STATION, UNIT 2 (TAC NO. M97068)

Dear Mr. Necci:

On September 18,1996, the U.S. Nuclear Regulatory Commission (NRC) lasued Ger.eric 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 that safety related mo'or-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On March 17,1997, Northeast Nuclear Energy Company submitted a response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification at Millstone, Unit 2. The NRC staff has encouraged licensees to participate in

'he industry-wide JOG program to provide a benefit in reactor safety by sharing expertise and iformation on MOV performance and to increase the efficiency of GL 96-05 activities at nuclear plants. Licensee participation in the JOG program also minimizes the amount of information necessary for the NRC staff to review each licensee's response to GL 96-05. As a result, the NRC staff requires only limited information to complete its GL 96-05 review for Millstone, Unit 2.

Enclosed is a request for additional inbrmation. Please respond to this request within 60 days of receipt of the forwarding letter. This schedule was agreed to in a March 22,1999, phone call with Mr. Ravi Joshi of your staff.

Sincerely, I

Stephen Dembek, P oject Manager Project Directorate '-2 Division of Licen*.g Project Management Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

Request for Additiona Information cc w/ encl: See next page

R

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i Millstons Nucl2ar PowIr Station

( Unit 2 l

cc:

Ms. L. M. Cuoco Ernest C. Hadley, Esquire ,

Senior Nuclear Counsel 1040 B Main Street  :

Northeast Utilities Service Company P.O. Box 549  ;

l P. O. Box 270 _ West Wareham, MA 02576 Hartford, CT 06141-0270 l Mr. R. P. Necci i Edward L Wilds, Jr., Ph.D.

. Vice President - Nuclear Oversight Director, Division of Radiation and Regulatory Affairs Department of Environmental Protection Northeast Nuclear Energy Company 79 Elm Street P. O. Box 128 L Hartford, CT 06106-5127 Waterford, CT 06385  !

Regional Administrator, Region i Mr. J. T. Carlin U.S. Nuclear Regulatory Commission Vice President - Human Services 475 Allendale Road Northeast Utilities Service Company King of Prussia, PA 19406 P. O. Box 128 Waterford, CT 06385 j First Selectmen i Town of Waterford Mr. Allan Johanson, Assistant Director i 15 Rope Ferry Road Office of Policy and Management  !

Waterford, CT 06385 Policy Development and Planning l Division i Mr. Wayne D. Lanning, Director 450 Capitol Avenue - MS# 52ERN Millstone inspections P. O. Box 341441 Office of the Regional Administrator Hartford, CT 06134-1441  !

- 475 Allendale Road l King of Prussia, PA 19406-1415 Mr. M. H. Brothers  !

Vice President - Millstone Operations {

Charles Brinkman, Manager Northeast Nuclear Energy Company j Washington Nuclear Operations P.O. Box 128 1 ABB Combustion Engineerir;g Waterford, CT 06385 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Mr. J. A. Price .

Director - Unit 2 Operations Senior Resident inspector j

Northeast Nuclear Energy Company Millstone Nuclear Power Station P.O. Box 128 c/o U.S. Nuclear Regulatory Commission Waterford, CT 06385 P.O. Box 513 i Niantic, CT 06357 Mr. L. Olivier Senior Vice Presidc nt and Chief -

Mr. F. C. Rothen Nuclear Officer - Millstone Vice President - Nuclear Work Services . Northeast Nuclear Energy Company Northeast Utilities Service Company P.O. Box 128 P. O. Box 128 Waterford, CT 06385 Waterford, CT 06385

p Millstone Nuclear Power Station k Unit 2 .

i I

cc:

l Citizens Regulatory Commission Ms. Nancy Burton '

ATTN: Ms. Susan Perry Luxton 147 Cross Highway 180 Great Neck Road Redding Ridge, CT 00870 Waterford, CT 06385 Deborah ICatz, President Citizens Awareness Network l P. O. Box 83 I Shelburne Falls, MA 03170 I Ms. Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4100 Legislative Office Building  ;

Capitol Avenue Hartford, CT 06106 j Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P. O. Box 0630 Niantic, CT 06357-0630 1

Attomey Nicholas J. Scobbo, Jr. l Ferriter, Scobbo, Caruso, Rodophele, PC 1 Beacon Street,11th Floor Boston, MA 02108 l I

Mr. D. B. Amerine Vice President - Engineering Services Northeast Nuclear Energy Company i P. O. Box 128  !

Waterford, CT 06385 l Mr. D. A. Smith Manager - Regulatory Affairs Northeast Nuclear Energy Company 1 P. O. Box 128 l Waterford, CT 06385 l l

1 i

REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE OF MILLSTONE NUCLEAR POWER STATION, UNIT 2 TO GENERIC LETTER 96-05

1. In the U.S. Nuclear Regulatory Commission's (NRC's) Inspection Report No.

50-336/98-04, the NRC staff closed its review of the motor-operated valve (MOV) progrcq implemented at Millstone, Unit 2, in response to Generic Letter (GL) 89-10,

" Safety-Related Motor-Operated Valve Testing and Surveillance." In the inspection report, the NRC staff discussed certain aspects of the licensee's MOV program to be addressed over the long term. For example, the inspectors noted that the licensee agreed to (1) dynamically test a duplicate valve to main steam isolation bypass valves 2-MS-65A/B under steam blowdown conditions; (2) dynamically test auxiliary feedwater pump turbine trip throttle valve 2-MS-464 during plant startup; (3) statically test three ,

feedwater block valves to confirm stem friction coefficient assumptions prior to or during j plant startup; (4) dynamically test valves 2-FW-44,2-MS-210, and 2MS-202 to confirm  !

stem friction coefficient and load sensitive behavior design assumptions; (5) monitor I industry testing of " inverted guide" design valves to verify valve performance; (6) evaluate available industry data ard test results to compare the performance of Stellite .l 21 on Stellite 6 to the performance of Stellite 6 on Stellite 6; and (7) update load sensitive behavior and stem friction coefficient analyses as future in-plant dynamic tests '

are performed. The licensee should update the actions taken to address the specific long-term aspects of the MOV program at Millstone, Unit 2, noted in the NRC inspection j report.

The NRC staff will review this information to verify that the licensee is implementing the remaining long-term MOV aspects so that the licensee is able to establish its long-term MOV program in response to GL 96-05 and verify on a periodic basis that the safety-related MOVs at Millstone, Unit 2, are capable of performing their design-basis safety functions in accordance with the requirements of 10 CFR Part 50, Aopendices A and B.

2. In a letter dated March 17,1997, the licensee stated that it is participating in the Joint Owners Group (JOG) Program on MOV Periodic Verification in response to GL 96-05.

On August 6,1997, the Combustion Engineering (CE) Owners Group submitted Revision 2 of Topical Report MPR-1807 on the JOG Program on MOV Periodic Verification. On October 30,1997, the NRC staff completed a safety evaluation (SE) concluding that the JOG program is an acceptable industry wide roponse to GL 96-05, with certain conditions and limitations. The licensee should update its commitment to the JOG program to address Revision 2 of the JOG topical report and the NRC SE.

This information is needed to verify that the licensee is implementing the version of the topical report that has been reviewed and accepted by the NRC in the SE dated October 30,1997.

3. The JOG program specifies that the methodology and discrimination criteria for ranking MOVs according to their safety significance are the responsibility of each participating licensee, in a letter dated March 17,1997, the licensee stated that MOVs will be evaluated based on risk insights, available margin, operating frequency, and MOV environment. As Millstone, Unit 2, is a pressurized water reactor (PWR) designed by CE, the licensee should describe the methodologies used for risk-ranking MOVs at Millstone, Unit 2, in detail, including the preparation of sample lists of high-risk MOVs

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from other CE nuclear plants. In responding to this request, the licensee might apply insights from the guidance provided in the Westinghouse Owners Group (WOG)

Engineering Report V-EC-1658-A (Revision 2, dated August 13,1998), " Risk Ranking Approach for Motor-Operated Valves in Response to Generic Letter 96-05," and the NRC SE dated April 14,1998, on the WOG methodology for risk-ranking MOVs at Westinghouse-designed PWR nuclear plants. The licensee could also obtain insights from an MOV risk-ranking methodology developed by the Boiling Water Reactor Owners Group.

This information is needed to verify that the licensee has established an acceptable methodology for ranking safety-related MOVs in accordance with their safety .

significance at Millstone, Unit 2, as required by the licensee's commitment to the JOG program on MOV periodic verification.

4. The JOG topical report specifies the static diagnostic test frequencies to be used by each participant's interim periodic test program to provide confirmation that each MOV is set up in a manner that ensures positive margin for ooerability. Test frequencies are selected (not to exceed 10 years) based on valve risk and available margin. In its letter dated March 17,1997, the licensee stated that prior to exceeding a three refueling ,

outage or 5-year test interval, test information obtained from the first 5-year or three - l refueling-outage time period would be evaluated to justify a longer test interval. l However, the licensee's letter also includes an exception to the JOG static diagnostic test program by stating that MOVs with a very high margin and low safety significance l will be stroked (exercised), but will not have parameters diagnostically monitored and l trended. The licensee should justify this deviation from the JOG program, including the methods used to ensure that each MOV will have adequate margin (after accounting for age-related degradation) to remain operable until the next scheduled test.

. The NRC SE dated October 30,1997, accepted the JOG program on MOV periodic verification as an industry-wide response to GL 96-05, and required that participating licensees justify any deviations from the JOG program.

5. 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 MC SE dated October 30,1997, on the JOG program, the NRC staff specified that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. The licensee should descdbe the plan at Millstone, Unit 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.

This information is needed to verify that the licenses is meeting its commitment to implement the recommendations of GL 96-05 to verify on a periodic basis the design-basis capability of safety-related MOVs by ensuring that the licensee is monitoring MOV motor actuator output performance and ootential degradation for its GL 96-05 MOVs.