ML20207L011

Forwards RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, for Nine Mile Point Nuclear Station,Units 1 & 2

ML20207L011
Person / Time
Site:	Nine Mile Point
Issue date:	03/11/1999
From:	Hood D NRC (Affiliation Not Assigned)
To:	Mueller J NIAGARA MOHAWK POWER CORP.
References
GL-96-05, GL-96-5, TAC-M97071, TAC-M97072, NUDOCS 9903170333
Download: ML20207L011 (8)

Text

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

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Mr. John H. Mueller Chief Nuclear Officer Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Operations Building, Second Floor P.O. Box 63 Lycoming, NY 13093

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05, " PERIODIC VERIFICATION OF DESIGN-BASIS CAPABILITY OF SAFETY-RELATED MOTOR-OPERATED VALVES," NINE MILE POINT NUCLEAR STATION, UNIT NOS.1 AND 2 (TAC NOS. M97071 AND M97072)

Dear Mr. Mueller:

The U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 96-05 on September 18,1996, to request that nuclear power plant licensees establish a program, or ensure the effectiveness of the current program, to periodically verify that safety-related motor-operated valves (MOVs) are capable of performing their safety functions within the current licensing bases of the facility. Niagara Mohawk Power Corporation (NMPC) responded by letters dated November 18,1996; March 17 (two letters), June 9, September 30,1997; February 27, November 19,1998; and February 12,1999. Our review of your responses recognizes, as discussed in your November 19,1998, letter, that NMPC intends to implement g the provisions of the Joint Owners Group (JOG) Program on MOV Periodic Verification. While NMPC's participation in the JOG program minimizes the additional information needed for the g/

NRC staff to complete its review for the Nine Mile Point units, some additional information is, nevertheless, needed and is identified in the enclosure.

- The schedule for responding to this letter was discussed with Messrs S. Leonard and T. Page in your organization. Based upon that discussion, a mutually agreeable response date is May 11,1999.

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if you have questions regarding this letter or are unable to meet this response schedule, please contact me by phone on (301) 415-3049 or by electronic mail at dsh@nrc. gov.

Sincerely, add /

Darl S. Hood, Senior Project Manager Project Directorate I-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosure:

Request for Additional Information cc w/ encl: See next page I

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J. Mueller If you have questions regarding this letter or are unable to meet this response schedule, please contact me by phone on (301) 415-3049 or by electronic mail at dsh@nrc. gov.

Sincerely, 1

1 Original signed by: I Darl S. Hood, Senior Project Manager Project Directorate 1-1 i Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

Docket File PUBLIC  ;

PDI-1 R/F JZwolinski/SBlack SBajwa Slittle DHood OGC ACRS S. Barber, RI A. Blough, RI TScarbrough DTerao DOCUMENT NAME: G:\NMP1-2\RAl97071.WPD To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy n OFFICE PM:PDI-1 _

, lE LA PDI-11 Q, I D:PDI-1 , , A/} l l I NAME DHood/rst . O O - Slittle W $8ajwa ff 9 ' A /

DATE 03/ n /99 03/ ll /99 03/tl/99 Official Record Copy

l . a March 11, 1999 J. Mueller If you have questions regarding this letter or are unable to meet this response schedule, please contact me by phone on (301) 415-3049 or by electronic mail at dsh@nrc. gov.

Sincerely, Original signed by:

Darl S. Hood, Senior Project Manager Project Directorate 11 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosure:

Request for Additional Information ,

cc w/ encl: See next page D STRIBUTION:

E%3 PUBLIC PDl-1 R/F JZwolinski/SBlack SBajwa SLittle i DHood I OGC l ACRS S. Barber, RI l A. Blough, RI '

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DOCUMENT NAME: G:\NMP1-2\RAl97071.WPD To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with

, attachment / enclosure "N" = Nc copy n OFFICE PM:PDI-1 , [E LA:PDI 1 R l D:PDI 1 , , A/) l l l NAME DHood/rst , M R ELittt F SBajwa /FU'#l /

DATE D3/ti /99 03/ H /99 03/ [1 /99 I

Official Record Copy

John H. Mueller Nine Mile Point Nuclear Station Niagara Mohawk Power Corporation Unit Nos.1 and 2 cc:

Regional Administrator, Region 1 Charies Donaldson, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General 475 Allendale Road New York Department of Law King of Prussia, PA 19406 120 Broadway New York, NY 10271 Resident inspector U.S. Nuclear Regulatory Commission Mr. Paul D. Eddy i'.O. Box 126 State of New York Department of Lycoming. NY 13093 Public Service Power Division, System Operations Mr. Jim Rettberg 3 Empire State Plaza New York State Electric & Gas Albany, NY 12223 Corporation Corporate Drive Mr. Timothy S. Carey Kirkwood Industrial Park Chair and Executive Director P.O. Box 5224 State Consumer Protection Board Binghamton, NY 13902-5224 5 Empire State Plaza Suite 2101 Albany, NY 12223 Supervisor Town of Scriba Mark J. Wetterhahn, Esquire Route 8, Box 382 Winston & Strawn Oswego, NY 13126 1400 L Street, NW

'Nashington, DC 20005-3502 Mr. Richard Goldsmith Syracuse University Gary D. Wilson, Esquire College of Law Niagara Mohawk Power Corporaticil E.1. White Hall Campus 300 Erie Boulevard West Syracuse, NY 12223 Syracuse, NY 13202 Mr. John V. Vinquist, MATS Inc. Mr. F. Waiiam Valentino, President P.O. Box 63 New York State Energy, Research, Lycoming, NY 13093 and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 l

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REQUEST FOR ADDITIONALINFORMATION REGARDING RESPONSE TO GENERIC LETTER 96-05 NIAGARA MOHAWK POWER CORPORATION (NMPC)

NINE MILE POINT NUCLEAR STATION. UNIT NOS.1 AND 2 (NMP1&ll DOCKET NOS. 50-220 AND 50-410 I

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1. In NRC .nspection Report (IR) No. 50-220 & 410/97-09, the NRC staff closed its review of the motor-operated valve (MOV) program implemented at NMP1&2 in response to Generic Letter (GL) 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance," based upon the results of the inspection and the NMPC's actions to resolve outstanding MOV issues as described in a letter dated September 30,1997. With respect l to the future actions identified in your September 30,1997, letter;  ;

(1) Discuss the status of your plan to implement motor actuator modifications to increase the available margins for NMP2 Main Steam drain valves 2 MSS *MOV111 and 2 MSS *MOV112.

(2) In a letter dated February 27,1998, NMPC summarized its consideration of the available margin for the NMP2 Reactor Water Cleanup valve 33-01. Please j discuss the following aspects of NMPC's consideration of the capability of MOV 33-01: i

a. The orientation of this Anchor / Darling double-disc gate valve and the thrust requirements associated with different orientations;

b. The design requirement for the valve to isolate the Reactor Coolant System in the event of a pipe break and the conditions in the NRC safety evaluation dated March 15,1996 and its supplement dated February 20, 1997, on the flow mitigation performance of Anchor / Darling double-disc gate valves;

c. The use of the guidelines provided by the Electric Power Research Institute (EPR!) in applying the valve friction coefficient in modeling valve performance with the EPRI MOV Performance Prediction Model(PPM);

d. The condition in tne NRC's safety evaluation on the EPRI MOV PPM regarding potential damage of Anchor / Darling double-disc gate valves under blowdown conditions; and

e. The assumptions for stem friction coefficient and rate-of-loadir,g in evaluating the capability of MOV 33-01 and the monitoring of those parameters.

2. In its letter dated September 30,1997, NMPC identified specific actions it would take to resolve concems identified by NRC IR 50-220 & 410/97-09. These actions included modifications to increase the actustor capabilities of the NMP1 Fe7dwate' valves 31-07 cad 31-08 during the spring 1999 refueling outage. In a letter dated February 12,1999, Enclosure

NMPC informed the NRC staff that it was revising its previous commitment to increase the l actuator capabilities of the Feedwater valves. This change was based upon NMPC's i determination that the design-basis function for these valves occurs for a containment isolation function, which results in a lower differential pressure than originally used by the design calculations. NMPC also stated that the thrust requirements for Feedwater valves 31-07 and 31-08 are now based upon a derivation of the Electric Power Research Institute (EPRI) MOV Performance Prediction Model (PPM), which it acknowledges is not directly applicable to the internal design of these valves.

Please discuss: I (1) The basis for the original differential pressure value selected for Feedwater valves 31-07 and 31-08; (2) The basis for revising the original analysis to only consider the valves' containment isolation function; and l (3) NMPC's plan for validating the application of EPRI MOV PPM methods to the Edwards Equiwedge design for these valves. j i

3. In its letter dated November 19,1998, NMPC updated its commitment to implement the l Joint 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 MOVs according to their safety significance are the responsibility of each participating licensee. In previous letters dated March 17,1997 (NMP2) and June 7, 1997, (NMP1), NMPC stated that risk insights would be used to determine the MOV periodic test frequencies.

Is NMPC applying the Boiling Water Reactor Owners' Group (BWROG) methodology for ranking MOVs based on their safety significance as described in BWROG Topical Report NEDC-2?264 and the NRC safety evaluation dated February 27,19967 If not, please describe the methodology used for risk ranking MOVs at NMP1&2 in more detail, including a description of (1) the process used to develop sample lists of high-risk MOVs from other BWR plants, and (2) how expert panels were used to evaluate MCV risk significance.

4. NMPC indicates that its MOV static diagnostic periodic verification program may include motor power diagnostic test methods. Please briefly describe your plans for the use of test data from the motor cont ol 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 l

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l (4) Validation of MOV operability using MCC testing.

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 its safety evaluation dated October 30,1997, on the JOG program, the NRC staff stated that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation.

Please describe the plan at NMP1&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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