ML20207E249

Discusses Licensee 980617 Updated Response to GL 96-05 Indicating Intent to Implement Provisions of JOG Program for MOV Periodic Verification for Fermi-2.Forwards RAI Re Fermi-2 Response to GL 96-05

ML20207E249
Person / Time
Site:	Fermi
Issue date:	02/22/1999
From:	Kugler A NRC (Affiliation Not Assigned)
To:	Gipson D DETROIT EDISON CO.
References
GL-96-05, GL-96-5, TAC-M97047, NUDOCS 9903100203
Download: ML20207E249 (4)

Text

Mr. Douglas R. Gipson Senior Vice President Nuclear Generation Detroit Edison Company 6400 North Dixie Highway Newport, Michigan 48166

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE FERMI 2 RESPONSE TO GENERIC ~ TTER 96-05, " PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILO i OF SAFETY-RELATr0 MOTOR-OPERATED VALVES," (TAC NO. M97047)

Dear Mr. Gipson:

The NRC issued Generic L Stter (GL) 96-05 on September 1G,1996, 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 June 17,1998, the Detroit Edison Company submitted an updated response to GL 96-05 indicating its intent to implement the provisions of a Joint Owners Group (JOG) program for MOV periodic verification. 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.

Additional information, as discussed in the enclosure, is requested in order for the staff to complete its review. The enclosed request was discussed with Mr. R. Johnson of your staff on February 18,1999. A mutually agreeable completion schedule of 60 days was established. If circumstances result in the need to revise the schedule, please call me at the earliest opportunity.

If you have any questions concerning this request, please contact me at (301) 415-2828.

Sincerely, ORIGINAL SIGNED BY Andrew J. Kugler, Project Manager Project Directorate 111-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

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Mr. Douglas R. Gipson Fermi 2 Detroit Edison Company

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John Flynn, Esquire Senior Attorney Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological Protection Division Michi2an Department of

, Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mallroom Lansing, Michigan 48909-8130 U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Monroe County Emergency Management Division 963 South Raisinville N.anroe, Michigan 48161 l Regional Administrator, Region ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532 4351

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Norman K. Peterson Director, Nuclear Licensing Detroit Edison Company Fermi 2 280 TAC 6400 North Dixis Highway

, Newport, Michigan 48166 4

i December 1990 a

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. REQUEST FOR ADDITIONAL INFORMATION RELATED TO f THE FERMI-2 RESPONSE TO GENERIC LETTER 96-05, '

" PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-OPERATED VALVES," (TAC NO. M97047) {

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1. In NRC Inspection Report No. 50-341/95010, the NRC staff closed its review of the motor-operated valve (MOV) program implemented at Fermi 2 in response to Generic j 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 l program to be addressed over the long term. For example, the inspectors noted that j (1) the licensee intended to use the Electric Power Research Institute (EPRI)

Performance Prediction Model (PPM) to establish thrust requirements for non-testable valve Group E (Powell) and Group H (Velan and Lunkenheimer) gate valves; (2) the licensee's methods for addressing paracitic loads should conform to guidance provided by the NRC safety evaluation on the EPRI MOV PPM when issued; and (3) long-term actions were needed to resolve the torque switch settings for seven do powered MOVs that were set above their degraded voltage output capabilities. The licensee should describe the actions taken to address the specific long-term aspects of the MOV program at Fermi 2 noted in the NRC inspection report.

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2. In a letter dated June 17,1998, the licensee updated its commitment to implement the l Joint Owners Group (JOG) program and stated that the interim static test program differs i

in some respects from the program described in the Boiling Water Reactor Owners' Group (BWROG) Topical Report NEDC-32719, "BWR Owners' Group Program on  !

l Motor-Operated Valve (MOV) Periodic Verification," (Revision 2, dated July 30,1997).

For example, the licensee's interim static test program allows valves with highest priority to be tested only once every three refueling outages as compared to the frequency of l every outage recommended by the JOG static test program for high-risk valves with low I l margins. In the NRC safety evaluation dated October 30,1997, on BWROG Topical )

Report NEDC-32719, the NRC staff stated that MOVs with scheduled test frequencies j beyond 5 years will need to be grouped with other MOVs that will be tested on {

frequencies less than 5 years in order to validate assumptions for the longer test intervals. The NRC staff stated that this review must include both valve thrust (or torque) ,

l requirements and actuator output capability. The licensee should describe how its MOV static diagnostic testing program will satisfy this condition of the NRC safety evaluation on the BWROG topical report.

3. The licensee should briefly describe its plans for the use of test data from the motor control center (MCC) including (1) correlation of new MCC test data to existing direct force measurements; (2) interpretation of changes in MCC test data to changes in MOV thrust and torque performance; (3) consideration of system accuracies and sensitivities to MOV degradation for both output and operating performance requirements; and (4) validation of MOV operability using MCC testing. f l

t l l ENCLOSURE i

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, 4. In its letter dated March 18,1997, the licensee states that it will implement the " objective" of the final JOG periodic verification program. The NRC staff considers that, when a licensee commits to the JOG Topical Report on the MOV Periodic Verification Program, the licensee is committing to implement each of the three phases of the described JOG program, including (1) JOG interim static diagnostic test program, (2) JOG 5-year dynamic test program, and (3) JOG long-term periodic test program. Where a licensee proposes to implement an approach different from any of these three phases of the JOG program, the licensee will be expected to notify the NRC and to provide justification for the proposed attemative approach. For example, if a licensee proposes not to implement the third phase of the JOG program (JOG long-term periodic test program) l after the specific long term test criteria have been established following the JOG 5-year dynamic test program, the licensee will be expected to notify the NRC and to justify its proposed alternative long-term test criteria. The Fermi-2 licensee should discuss its commitment to the JOG long term periodic test program and whether it is consistent with the NRC staff's interpretation of a commitment to all three phases of 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 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 Fermi 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 (not available to the public).

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