ML20205G765

Forwards RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, for Plant, Units 1 & 2.Response Requested within 90 Days of Receipt of Ltr

ML20205G765
Person / Time
Site:	Limerick
Issue date:	03/22/1999
From:	Buckley B NRC (Affiliation Not Assigned)
To:	Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
GL-96-05, GL-96-5, TAC-M97062, TAC-M97063, NUDOCS 9904070375
Download: ML20205G765 (5)

Text

F:

Mr. Grrrett D. Edwards March 22, 1999 Director-Licensing, MC 62A-1 PECO Energy Company

• Nuclear Group Headquarters

. Correspondence Control Desk P.O. Box No.195 Wayne, PA 19087-0195

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 PROGRAM AT LIMERICK GENERATING STATION,

. UNITS 1 AND 2 (TAC NOS. M97062 ANDM97063)

Dear Mr. Edwards:

i On September 18,1996, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety Related Motor-Operated i 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 May 14,1998, PECO Energy Company submitted an updated response to GL 96-05 l indicating its intent to implement the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification at Limerick. The NRC staff has encouraged licensees to participate in the industry-wide JOG program to provide a benefit in reactor safety by sharing expertise l and information 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.

However, the NRC staff requires additional information to complete its GL 96-05 review for Limerick Generating Station, Units 1 and 2.

Enclosed is a request for additional information (RAl) regarding the GL 96-05 prognm. On March 17,1999, we discussed this requested information with your staff and a 90-day response from receipt of this letter was mutually acceptable.

Sincerely, original signed by:

Bartholomew C. Buckley, Senior Project Manager m Project Directorate 1-2 d 9904070375 990322 Division Licensing Project Management j '

PDR ADOCK 05000352 P PDR . Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 353

Enclosure:

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Mr. Garrett D. Edwards March 22, 1999

) Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters i

Correspondence Control Desk l P.O. Box No.195 Wayne, PA 19087-0195

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING l GENERIC LETTER 96-05 PROGRAM AT LIMERICK GENERATING STATION,  ;

UNITS 1 AND 2 (TAC NOS. M97062 ANDM97063)  !

Dear Mr. Edwards:

On September 18,1996, the 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 cr,tablish 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 May 14,1998, PECO Energy Company 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 Limerick. 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. 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.

However, the NRC staff requires additionalinformation to complete its GL 96-05 review for Limerick Generating Station, Units 1 and 2.

4 Enclosed is a request for additionalinformation (RAl) regarding the GL 96-05 program. On March 17,1999, we discussed this requested information with your staff and a 90-day response from receipt of this letter was mutually acceptable.

Sincerely, M\thC i UC Bartholomew C. Buckley, Senior Project Manager Project Directorate 1-2 l Division Licensing Project Management i

Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 353

Enclosure:

RAI cc w/ encl: See next page

i

. 1 Mr. Garrett D. Edwards Limerick Generating Station, Units 1 & 2 l PECO Energy Company l

4 cc:

J. W. Durham, Sr., Esquire Chief-Div%)n of Nuclear Safety Sr. V.P. & General Counsel PA Dept. of Environmental Resources t PECO Energy Company P.O. Box 8489 2301 Market Street Harrisburg, PA 17105-8469 {

Philadelphia, PA 19101 Manager-Limerick Licensing,62A-1 Director-Site Engineering PECO Energy Company Limerick Generating Station 965 Chesterbrock Boulevard P.O. Box A Wayne, PA 19087-5691 Sonatoga, PA 19464 Mr. James D. vcn Suskil, Vice President Limerick Generating Station Manager-Experience Assessment 1 Post Office Box A Limerick Generating Station l Sanatoga, PA 19464 P.O. Box A Sanatoga, PA 19464 Plant Manager Limerick Generating Station Library ,

P.O. Box A U.S. Nuclear Regulatory Commission  !

Sanatoga, PA 19464 Region I j 475 Allendale Road '

Regional Administrator, Region i King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission l 475 Allendale Road Senior Manager-Operations i King of Prussia, PA 19406 Limerick Generating Station 4 P.O. Box A l:

Senior Resident inspector Sanstoga, PA 19464 U.S. Nuclear Regulatory Commission Limerick Generating Station Dr. Judith Johnsrud P.O. Box 596 National Energy Committee Pottstown, PA 19464 Sierra Club 433 Orlando Avenue Director-Site Support Services State College, PA 16803 Limerick Generating Station P.O. Box A l Sanatoga, PA 19464 i

Chairman i Board of Supervisors of Limerick Township j 646 West Ridge Pike l Linfield, PA 19468 j

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• • ub REQUEST FOR ADDITIONAL INFORMATION LIMERICK GENERATING STATION. UNITS 1 AND 2 REGARDING GENERIC LETTER 96-05

1. In NRC inspection Report No. 50-352 & 353/95-19, the NRC staff closed its review of the motor-operated valve (MOV) g gram implem9nted at the Limerick Generating l Station, Units 1 and 2 (Limerick), in response to Generic Letter (GL) 8910, " Safety-Related Motor-Operated Valve Testing and Surveillance." In the inspection report, the NRC staff discussed certain aspects of the lic( ,see's MOV program to be addressed over the long term. For example, the inspectors noted that (1) the licensee had used test data from the Electric Power Research Institute (EPlil) MOV Performance Prediction Program in determining valve factors although the EPRI testing program was not intended to establish a statistical database for assigning bounding valve factors; (2) the !icensee committed to dynamically test the low pressure coolant injection valves; (3) the licensee intended to revise its MOV program to prevent applying data from a single valve to other nontestable MOVs; and (4) additional valve factorjustification was needed for Group 35 (8" Crane gate valves). The licensee should describe the actions )

taken to address the specific long-term aspects of the MOV program at Limerick that were noted in the NRC inspection report, including consideration of the NRC staff l conclusions on the EPRI program thst were subsequently provided in the NRC safety evaluation dated March 15,1996, and its supplement dated Februarv 90,1997.

2. In GL 96-05, the NRC staff discussed the scope of the prograrr,wan respect to l

safety-related MOVs that are assumed to be capable of returning to their safety position when placed in a position that prevents their safety system (or train) from performing its safety function; and the system (or train) is not declared inoperable when the MOVs are in their nonsafety position in a letter dated March 14,1997, the licensee indicated that such MOVs are not included in the GL 96-05 program at Limerick, but that operability is demonstrated through routine plant operation.' With respect to such l

1

'In a safety evaluation dated June 25,1996, to the licensee of the Duane Arnold Nuclear Center,  !

the NRC staff cc.ncluded, in response to that licensee's removal of 17 MOVs from its GL 89-10 program  !

that have safety-related functions but are normally in their safety position, that those MOVs are subject j to the requirement that they be capable of retuming to their safety position (if they are out of their safety position for surveillance or testing) or the provisions of the appropriate Technical Specifications for the i systems (or trains) out of service must be followed. The NRC staff also noted that the Duane Amold J

licensee needed to address any applicable containment isolation or pipe break isolation requirements for l these MOVs. In the f.afety evaluation, the NRC staff concluded that commitments made by the Duane  ;

Amold licensee provided adcquate confidence that those H MOVs would maintain capability to retum to '

their cafety position der accident conditions. The NRC staff also noted that the Duane Amold licensee  :

would be expected c mke appropriate action according to its Technical Specifications if plant or industry I information revealed that those MOVs were not capable of retuming to their safety position. Finally, the NRC staff stated that the Duane Amold licensee would be expected to periodical *y evaluate the capability of those MOVs to retum to their safety position as part of its long-term MOV program.

ENCLOSURE

o i

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MOVs placed in their non-safety position at Limerick, the licensee should address its plans for maintaining torque switch settings, and the feedback of industry operating experience and data. Further, the Limerick licensee should discuss the manner in

. which its approach will provide confidence that these MOVs will be capable of returning to their safety position, including (1) plans for performing required switch setting adjustments promptly, (2) any specified MOV operation under dynamic conditions, or (3) any future diagnostic testing. The Limerick licensee should describe the bases for its confidence that (1) these MOVs will continue to be capable of retuming to their safety position, (2) any degradation in MOV performance will be notified price to causing the MOVs to be incap6ble of retuming to their safety poe . 4, and (3) any i action necessary to ensure MOV capability will be taken in a timely manner, i

3. In a letter dated May 14,1998, the licensee updated its commitment to implement the  !

Joint Owners Group (JOG) Prog am on MOV Periodic \,erification in response to I GL 96-05. 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 previous letter dated March 14,1997, the licensee had genellly described the risk ranking of MOVs at Limerick for application of the interim MOV static diagnostic test program. As Limerick is a boiling water reactor (BWR) nuclear plant, is the licensee applying the Boiling Water Reactor Owners' Group (BWROG) methodology for ranking MOVs based on their safety significance as described in BWROG Topical Report NEDC 32264 and the NRC safety evaluation dated February 27.,19967 If not, the licensee should describe the methodology used l for risk ranking MOVs at Limerick in more detail. l 1

4. 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 licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. The licensee should describe the plan at Limerick 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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