ML20216C982

Provides Addl Info Requested by NRC During 970603 Telcon Re Operation & Maintenance Relief Requests 2VR-7 & 2VR-8

ML20216C982
Person / Time
Site:	Wolf Creek
Issue date:	09/02/1997
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-97-0102, ET-97-102, NUDOCS 9709090184
Download: ML20216C982 (10)

Text

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W$LF CREEK NUCLEAR OPERATING CORPORATION Richard A. Muench Vce PreOdent Engineer!ng September 2, 1997 ET 97-0102 U. S. Nuclear Regulatory Commission ATTN Document Control Desk Mail Station P1-137 Washington, D. C.

20555

Reference:

Letter ET 97-0002, dated January 28, 1997, from R. A. Muench, WCNOC to USNRC Subject Docket No. 50-482:

Rosponse to Request for Additional Information Concerning Operation and Maintenance Relief Requests 2VR-7 and 2VR-8 Gentlemen:

The Reference transmitted Wolf Creek Nuclear Operating Corporation (WCNOC)

Relief Requests 2VR-7 and 2VR 8.

This letter provides additional information requested by the NRC during a June 3, 1997, telephone conversation between the NRC Staff and WCNOC personnel.

Attachment I provides additional information concerning Relief Request 2VR-7 Attachment II provides revised Relief Request 2VR-8.

This revision to Relief Request 2VR-8 supersedes Relief Request 2VR-8 that was transmitted by the Reference.

WCNOC considers the referenced ASME Code and Code Case to be an acceptable alternative to the requirements of ASME/ ANSI OM-1987 and the ASME/ ANSI OMa-1988 Addenda.

If you have any questions regarding this submittal, please contact me at (316) 364-8831, extension 4034, or Mr. Richard D. Flannigan at extension 4500.

Very tu.Ay yours, 9709090184 970902 PDR ADOCK 0500 2

Richard A. Muench

,0 RAM /jad 1

Attachment I - Additional Information for Rel4ef Request 2VR-7 Attachttent II - Revised Relief Request 2VR-8

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cc W.

D. Johnson (NRC), w/a 1

E. W. Merschoff (URC), w/a J.

F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a ylillll]l,lH!lllll;lllll (i'- 0 ' 'T 0 3O

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An Equal opportunity Emp6 eyer M F HCNET

5 Attachment I to ET 97-0102 Page 1 of 6 Relief Request No. 2VR-7 Supplement 1 During a telephone conversation with the NRC Staff on June 3, 1997, The NRC l

ctaff requested that Wolf Creek Nuclear Operating Corporation (WCHOC) provide uti t iona l clarifying information concerning Relief Request 2VR-7 Based on t.. i s telephone conversation, WCNOC is providing the requested supplementary inrormation.

The NRC StaJf requested the implementation details explaining how WCh0C will transition from our current program to using ASME Code Case OMN-1.

In addition, WCNOC is providing a comparison of Code Case OMN-1 to the axisting Motor Operated Valve (MOV) Program.

Transition Plan Wu,0C requusted the use of ASME Code Case OMN-1 using Relief Request 2VR-7 as an alternative to existing ASME Code requirements.

As an alternative, the Code Case may be applied to certain components encompassed by the Code Case scope statement rather than all at once, which would be a coct prohibitive endeavor.

Engineering will evaluate each MOV group on the basis of safety importance and cost to determine the priority and scope for inclusion into the Inservice Testing (IST) OMN-1 testing program.

WCNOC supports the Generic Lecter 96-05 industry approach described by the, " Joint BWR and Westinghouse Owners' Group Program on Motor Operated Valve (MOV) Periodic Verification,"

(MPR-1807 r0) also known as the JOG approach.

The review of the JOG ".pproach and ASME Code Case ONN-1 requirements, by WCNOC, did not yield any in xmpatibilities between reipirements.

WCNOC will ensure that all ASME Code Case OMN-1 requirements are met for valves selected to be within the scope of the IST OMN-1 testing program, except where specific relief is provided by the NRC.

Code Case OMN-1 requireran'.s that are currently not implemented ir. the MOV Program will be implementeo sing a controlled process in compliance with Code Case OMN-1 requirements and evaluated under 10 CFR 50.59.

Two Code Case OMN-1 requirements were identified that are not performed by existing WCNOC proceduits.

Procedural implementation of these requirements will be developed when Lne transition from existing Code requirements to Code Case OMN-1 is approved.

Other additional procedure enhancements, to clarify specific ASME Code Caae OMN-1 requirements ir. existi rig procedures, will also be implemented after approval to begin the transition to the proposed alternative approach is granted.

Attachment I to ET 97-0102 Page 2 of 6 Relief Acquest No. 2VR-7 Supplement 1 Code Case Comparison to Existing WCNOC MOV Program The following is comparison of Code Case OMN-1 to existing MOV Program a

]

elements, which will demonstrate compliance with specific Code Case elements, f

1 Code Case OMN-1 section 3.1 - the design basis verification testing required j

by this section was performed for Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance," and is documented in the plant records, as discussed by NRC inspection report 50-482/95-04.

Code Case OMN-1 section 3.2

- the preservice testing described by this paragraph apply to, "the period of time following completion of construction 9

activities related to the valve and before first electrical generation by nuclear heat, in which compenent and system testing takes place," or before j

implementing inservice testing.

This paragraph applies to start-up testing u

and does not apply to WCNOC at this time.

Code Case OMN-1 section 3.3 - the inservice OMN-1 testing interval shall begin for each group from the date when the first valve is documented as being acceptably tested under the WCNOC surveillance program.

Section 3.3a - MOVs

}

are grouped at WCNOC using a process described by section 3.5.

Section 3.3b -

MOV testing procedures and plant scheduling requirements ensure that testing of MOVs is performed in the as-found condition except when the need for corrective maintenance is necessary and testing is impractical or detrimental.

Section 3.3c - WCNOC utilizes an appropriate mix of static and dynamic testing committed to by WCNOC letter WM 95 0087 dated May 19, 1995, " Reply to Request for Additional Information Associated with the Completion of Commitments to Ceneric Letter 89-10,

' Safety-Related Motor-Operated Valve Testing and Surveillance'."

Cge Case OMN-1 section 3.3.la - the inservice te sting frequency shall be dcrermined using section 6.4.4 and additional insichts as appropriate.

The basis for the inservice test frequeacy shall be documented in plant records.

Section 3.3.lb - sufficient data exists from MOV testing to determine the testing frequency in accordance with section 6.4.4.

Code Case OMN-1 section 3.4 - the requirements to test an MOV that has had maintenance that could affect its performance is controlled in a manner described in section 3.4 by :CNOC procedure AP 16E-002, " Post Maintenance Testing."

WCNOC procedure

-ENG-001,

" Motor Operated Valve Performance Monitoring," controls the evaluation of MOV performance, calculations, and reference values.

Code Case OMN-1 section 3.5 - grouping of MG* i is justified by an engineering evaluation documented in WCNOC plant records.

Section 3.5a&b requirements are satisfied as part of the engineering evaluation procass.

Section 3.5c&d discuss testing of the representative MOV(s) from each group over the specified test interval.

The determination of the representative MOV(s) to be tested over each test interval will be controlled and documented by the LCNOC IST surveillance process.

Section 3.5e - the test results will be analyzed and evaluated using WCNOC procedure I-ENG-001,

" Motor Operated Valve Performance Monitoring."

The data and results will be documented using existing IST program process means described by WCNOC procedure AP 29B-002, "ASME " ode Testing of Pumps and Valves."

Attachment I to ET 97-0102 Page 3 of 6 Relief Request No. 2VR-7 Supplement 1 Code Case Comparison to Existing WCNOC MOV Program (continued)

Code Case OMN-1 section 3.6.1 - A sample review of the potential MOVs that will be selected for the IST OMN-1 testing program indicates that many are cycled due to Technical Specification Surveillance programs other than the IST program at least once per fuel cycle, and in some cases quarterly.

Before a group of MOVs are placed in the IST OMN-1 +esting program, procedures that strole the MOV will be identified to ensure compliance.

Code Case OMN-1 section 3.6.2 - the exercising frequency for MOVs shall be considered using existing performance monitoring programs.

The main programs that implement-the performance monitoring at WCNOC are the MOV Periodic Verification and Monitoring Program, the Maintenance Rule Program, the Reliability Centered Maintenance Program, and the Performance Improvement Program. Additional risk insights that will be utilized are provided from the EPRI Risk-Based Inservice Testiag Pilot Project results for WCNOC.

Code Case OMN-1 section 3.6.3 - existing surveillance procedures that stroke the MOV, and as discussed for compliance with section 3.6.1 above, are compliant with the requirements of this section.

Code Case OMN-1 sect'.on 3.7.1&2 - The EPRI Risk-Besed Inservice Te. ting Pilot Project results for WCNOC meet the requirements detailed in this section and may be utilized to adjust test frequency, methodology, grouping, or stroke frequency.

Additional risk screening, evaluation, and documentation will re performed fer the JOG MOV periodic verification project.

WCNOC wil1 enst re compliance with applicable industry Codes and regulatory guides for future risk categorization processes when they are approved and the process is implemented.

When risk based criteria are applied, it shall 'ae dor in conjunction with the criteria described by section 3.7.2.

Code Case OMN-1 section 5.1 - these requirements are met by sarious WCNOC programmatic controls that are audited by the WCNOC quality assurance program and the NRC.

Code Case ONN-1 section 5.2 - WCNOC testing procedures ensure that the test conditions are sufficient to determine the MOV functional margin.

Procedural controls ensure that the documertation requirements are met for section 9 as described (see discussion for section 9).

Code Case OMN-1 section 5.3a - ':hese requirements are met by various WCNOC programmatic controls such as WCNOC procedures AP 12-001,

" Housekeeping Control," and AP 12-003, " Foreign Material Exclusion."

Code Case OMN-1 section 5.3b - The MOV limits discussed have been incorporated into WCNOC document E-025-00007, "MOV Design Configuration."

Test equipment precautions and limits are incorporated into WCNOC procedure MGE LT-099, "MOV Diagnostic Testing."

Code Case OMN-1 secticn 5.3c - a fluid transfer evaluation is performed prior to the implementation of testing using WCNOC procedure AP 21D-002, " Evaluation

_for Potential Fluid / Energy Transfer Paths."

Code Case OMN-1 section 5.4 - the procedure requirements discussed by this section are contained in WCNOC procedure AP 23D-001, " Motor Operated Valve Program," and those procedures referenced therein.

1

Attachment I te ET 97-0102 Page 4 of 6 Relief Request No. 2VR-7 Supplement 1 Code Case Comparison to Existing WCNOC HOV Program (continued):

Code Case OMN-1 section. 5.5 - the procedure requirements discussed by this section are contained in WCNOC procedure AP 23D-001, " Motor Operated Valve Program," and those procedures referenced therein.

Code Car,e OMN-1 section 6.1 - WCNOC procedures WCNOC-85, " Motor Operated Valve Calculotion Guidelines," and AP 23D-001, " Motor Operated Valve Program," as well as individual design evaluations, provide compliance with this section.

Code Case OMN-1 section 6.1.1 the ability to express MOV performance in other terms than those units provided by the Code Case are understood.

Code Case OMN-1 section 6.2 the analysis described is performed by r

procedures MGE LT-099, "MOV Diagnostic Testing," and I-ENG-001,

" Motor l

Operated Valve Performance Monitoring."

Coda Case OMN-1 section 6.3 - the analysis described is performed by WCNOC procedures MGE LT-099, "MOV Diagnostic Testing" and I-ENG-001, " Motor Operated Valve Performance Monitoring."

Code Case OMN-1 section 6.4 - the determination described is performed by WCNOC procedure I-ENG-001, " Motor Operated Valve Performance Monitoring."

Code Case OMN-1 section.6.4.1 - compliance with these sections are provided by individual evaluations performed for the Generic Letter 89-10 program.

The result.s of these evaluations are contained in WCNOC document E-025-00007, "MOV Design Configuration."

Code Case OMN-1 section 6.4.2.1 - the identified parameter is determined using WCNOC procedures MGE LT-099, "MOV Diagnostic Testing," and WCNOC-85, " Motor Operated Valve Calculation Guidelines."

Code Case OMN-1 section 6.4.2.2 - the identified parameter is determined using WCNOC proceduras MGE LT-099, "MOV Diagnostic Testing" and WCNOC-85, " Motor Gpert.ted Valve Calculation Guidelines."

Code Case OMN-1 section 6.4.3 - the functional margin will be determined using a controlled process, in compliance with Code Case OMN-1 requirements and evaluated under 10 CFR 50.59, that will be developed when the transition from existing Code requirements to Code Case OMN-1 is approved.

Code Case OMN-1 section 6.4.4 - the test interval will be determined using a controlled process, in compliance with Code Case OMN-1 requirements and evaluated under 10 CFR 50.59, that will be developed when the transition from existing Coce requirements to Code Case OMN-1 is approved.

Code Case OMN-1 sect'on 6.5 - when C/ performance is unacceptable, corrective action shall be taken in accordar e w.ith the WCNOC corrective action program.

Code Case OMN-1 section 9.1& - This documentation requirement is met by WCNOC procedure MGE LT-099, "MOV Diagnostic Testing."

Code Case OMN-1 section 9.lb - This documentation requirement is met by WCNOC procecures MGE LT-099, "MOV Diagnostic Testing," AP 16C-002, " Work Controls,"

and AP 24E-001,

" Identification and Control of Materials, Parts and Components."

Attachment I to ET 97-0102 Page 5 of 6 t

Relief Requent No. 2VR-7 Supplement 1 Code Case Comparison to Existing WCNOC HOV Program (continued):

Code Case OMN-1,section 9.lc - This documentation requirement is met by WCNOC procedure MGE LT-099, "MOV Diagnostic Testing."

Code Case OMN-1 section 9.1d - WCNOC procedures AP 21D-002, " Evaluation for Potential Fluid / Energy Transfer Paths," MGE LT-099, "MOV Diagnostic Testing,"

volve specific test procedures screened and evaluated under 10 CFR 50.59, and l

the associated references in the aforementioned procedures meet. this documentation requirement.

Code Case OMN-1 section 9.le - this documentation requirement is met using WCNOC procedure MGE LT-099, "MOV Diagnostic Testing," and the procedures or documents referenced therein.

l Code Case OMN-1 section 9.lf - this documentation requirement is met using WCNOC procedure MGE LT-099, "MOV Diagnostic Testing," and the procedu-es or l

documents referenced therein, t

Code Case OMN-1 section 9.10 - WCNOC procedures AP 21D-002, " Evaluation for Potential Fluid / Energy Transfer Paths," MGE LT-099, "MOV Diagnostic Testing,"

valve specific test procedures screened and evaluated under 10 CFR 50.59, and the associated references in the aforementioned procedures meet this documentation requirement.

Code Case OMN-1 section 9.1h - this documentation requirement will be met using WCNOC procedure AP 29B-003, " Surveillance Testing."

Code Case OMN-1 section 9.11 - WCNOC procedures AP 21D-002, " Evaluation fe r Potential Fluid / Energy Transfer Paths," MGE LT-099, "MOV Diagnostic Testing,"

valve specific test procedures screened and evaluated under 10 CFR 50.59, and the associated references in the aforementioned procedures meet this cocumentation requirement.

Code Case OMN-1 section 9.11 WCNOC p';ocedures AP 29B-003, "Surveillanc.

Testing," AP 21D-002, " Evaluation for Potential Fluid / Energy Transfer Paths,"

MGE LT-099, "MOV Diagnostic Testing," valve specific test procedures screened and evaluated under 10 CFR 50.59, and the associated references in the aforementioned procedures meet this documentation requirement.

. Code Case OMN-1 section 9.2

- WCNOC procedures AP 29B-003, " Surveillance

_ Testing," AP 21D-002, " Evaluation for Potential Fluid / Energy Transfer Paths,"

MGE LT-099, "MOV Diagnostic Testing," valve specific test procedures screened and evaluated under 10 CFR 50.59, and the associated references in the aforementioned procedures meet this documentation requirement.

The long term performance monitoring of the test results is further provided for in WCMOC procedure I-ENG-001, " Motor Operated Valve Performance Monitoring."

Attachment I to ET 97-0102 Page 6 of 6 Relief Request No. 2VR-7 Supplement 1 Conclusiont With the exceptions of ASME Code Case OMN-1 section 6.4.3,

" Calculation of MOV Functional Margin," and section 6.4.4, " Determination of MOV Test Interval "

compliance with all sections of ASME Code Case OMN-1 has been demonstrated.

Procedure enha.. cements, to clarify specifically the ASME Code Case OMN-1 requirements in existing procedures, will be implemented after approval to begin the transition to the proposed alternative approach is granted. ASME Code Case OMN-1 sections 6.4.3 and 6.4.4 are considered specific to the requirements of the Code Case.

Resources will be devoted to the development and approval of procedures to implement these requirements when approval to implement ASME Code Case OMN-1 is granted by the NRC.

Attachment-II to ET 97-0102 Page 1 of 3 Relief Request No. 2VR-8 Revision 1 l

V&lve (s) :

All Check Valves Category:

C Function

• System Dependent.

Test Requirement:

ASME OMa 1988 Part 10 section 4.3.2,

" Exercising Tests for Check Valves" Basis for Relief:

ASME OMa 1988 Part 10 section 4.3.2,

" Exercising Tests for Check Valves" discusses test requirements for check valves that are within the Scope statement of paragraph 1.1.

The NRC and ASME have long recognized that the existing ASME Code check valve i

testing requirements will not typically detect degradation of performance or necessarily a check valve's ability to perform its intended function.

Certain check valves need more attention in order to determine l

their failure or maintenance patterns. Once these mechanisms have been analyzed, confirmed, and the valve or group of similar valves have had their performance improved, then the same level of attention is no longer needed.

Certain check valves need less attention as they have continuously exhibited acceptable operation every time they have been disassembled and examined or every time they have been non-intrusively tested. Once the reasons for their behavior have been

analyzed, and confirmed, then the

test, examination, and preventive maintenance activities necessary to maintain the continued acceptable performance can

.be optimized.

Once optimized, the same level of attention is no longer needed.

The above examples demonstrate how the same types of tests and their associated intervals may need to be periodically adjusted based on the valve's performance.

The ASME has developed a process that allows the uwner certain flexibility in establishing the types of

test, examination, and preventive maintenance activities and their associated intervals.

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Attachment II to ET 97-0102 Page 2 of 3 Relief Request No. 2VR-8 Revision 1 Basis for Relief (cont.)

ASME OMa-1996 Subsection ISTC 4.5 including the Mandatory Appendix II,

" Check Valve Condition Monitoring Program," provides the equivalent or improved guidance with respect to the current check valve testing requirements set forth in ASME OMa 1988 Part 10 section 4.3.2, " Exercising Checks for Check Valves." Requirements are given for the implementation of a

sample disassembly examination program.

ASME OMa 1996 ISTC Mandatory Appendix II provides a methodology to optimize testing, examination, and preventive maintenance activities.

Wolf Creek Generating Station (WCGS) has an established Check Valve Reliability Improvement Program that has previously been inspected by the NRC (ref. NRC Inspection Report 50-482/94-14) and evaluated by an industry peer assessment team.

The audits demonstrate the acceptability of the WCGS Check Valve Reliability Improvement Program.

ASME OMa 1996 Subsection ISTC 4.5 with Mandatory Appendix II is an alternative l

to the current test requirements that provides an acceptable level l

of quality and safety.

A maximum test interval based upon current NRC and ASME guidance is specified.

The maximum test interval allowed by ASME Code for relief valves is 10 years.

The current maximum test interval spacified for check valve disassembly is 8 years.

The maximum test interval for ASME OMN-1,

" Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants OM Code-1995, Subsection ISTC," referenced in Generic Letter 96-05,

" Partial Bypass of Shutdown Cooling Flow From the Reactor Vessel," is 10 years.

The guidance of Generic Letter 96-05 for maximum test intervals will be used as specified below.

AlternatiNe Testing:

Check valve testing will comply with tha requirements of ASME OMa 1996 Subsection ISTC 4.5, including the dandatory Appendix II with the following limitations:

1) Where the most frequently performed appropriate measure (test, examination, or preventive maintenance) interval extends beyond 60 months, performance, examination, maintenance history, and test experience from previous tests shall be evaluated to justify the periodic verification interval.

2) In no case shall a test or examination interval exceed 120 months.

3) The risk insights determined during Wolf Creek Nuclear Operating Cor., oration participation in the EPRI Risk-Based Inservice Testing Pilot Project (ref. EPRI TR-105869) and on-going development of an updated risk-based categorization process based upon ASME Research guidance and Codes as applicable may be used to ensure that the testing, examination,l or preventive measures taken are commensurate with each valve's safety significance.

4) Check valve obturator movement will be tested or examined in both the open and closed direction to ensure unambiguous detection of functionally degraded check valves.

ASME OMa Code-1996 ISTC 4.5.4 will be used to determine valve obturator movement requirements.

Attachment II to ET 97-0102 Page 3 of 3 Relief Request No. 2VR-8 Revision 1 Alternative Testing (cont.):

i L: Extensions of IST intervals will consider plant safety impact and be supported and justified by applicable methods of trending related to industry generic and plant specific experience to provide assurance that the valve is capable of performing its intended function over the entire interval.

6) Initial IST interval extensions of any valve must be limited to 2 fuel cycles or 3 years.

Subsequent extended intervals must be limited to 1 fuel cycle per extension, up to 10 years.

7) If it is decided to discontinue the Condition Monitoring Program on a valve or group of valves, the testing and examination will revert back to the original ASME Code requirements.

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