ML20247L984
| ML20247L984 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 05/14/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-96-05, GL-96-5, NUDOCS 9805260132 | |
| Download: ML20247L984 (4) | |
Text
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A GL 96-05 i
v PECO NUCLEAR ncme c-965 Chesterbrook Boulevard A Unit of PECO Energy Wayne, PA 19087-5691 May 14,1998 Docket Nos. 50-277 50-278 50-352 50-353 License Nos. DPR-44 DPR 56 NPF-39 NPF-85 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Response to Generic Letter 96-05, " Periodic Verification of Design-Bases Capability of Safety-Related Motor-Operated Valves *
References:
1)
Letter from G. A. Hun 0er Jr. (PECO Energy Company) to U. S. Nuclear Regulatory Commission (USNRC) dated March 14,1997 2)
Safety Evaluation on Joint Owners' Group Program on Periodic Verification of Motor Operated Valves described in Topical Report NEDC-32719 (Revision 2), dated October 30,1997 l
3)
Generic Letter 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, " dated September 18,1996
Dear Sir / Madam:
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In the Reference 1 letter PECO Energy Company (PECO Energy) provided a description of its l
MOV periodic verification program established in response to Generic Letter (GL) 96-05 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Limerick Generating Station (LGS), Units 1 and 2. The purpose of this letter is to notify the USNRC of our intent to revise the PECO Energy " Current (interim)* Program as committed in Reference 1.
On October 30,1997, The USNRC issued a Safety Evaluation (SE) (Reference 2), which within the conditions and limitations described, stated that the staff considers the Joint Owners' Group (JOG) Program on MOV Periodic Verification to be an acceptable industry-wide response to GL 96-05. The JOG had agreed that after issuancn of the SE, requests would be made to participating utilities to notify the USNRC of their plans to implement the JOG pro 0 ram described in Revision 2 of the topical report which was the subject of the SE (i.e., NEDC-32719), and that any deviations from the JOG program would be justified. In response to this request, PECO Energy will adopt the JOG
- interim" MOV Periodic Verification Program which will supersede the
" Current (Interim)" Program described in Reference 1. This new JOG interim program wiil be in j
1l place for at least five (5) years after which a Final (Long Term) MOV Periodic Verification j
/
9905260132 980514
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PDR ADOCM 050002 U 9
- pan,
May 14,1998 Page 2 Program 1eveloped by the JOG will be available to replace it, and to incorporate the lessons
'leamed and MOV performance trends observed during the course of the " Interim" Program.
PECO Energy is taking no technical exceptions to the JOG Program, but requires the following schedule relief during the transition from the current PECO Energy program to the USNRC approved JOG Program:
- 1) PECO Energy will require six months from the date of this letter to revise program documents and engineering tools which support the implementation of the revised MOV Periodic Verification Program.
- 2) PECO Energy will require the following program transition schedule extensions to obtain sufficient trendable test data, and perform engineering analysis necessasy to validate the extens!on of high margin, low safety significance MOVs beyond the five (5) year maximum periodic verification test (PVT) interval discussed in Reference 2 without detailed justification:
MOVs' Testable Durina Schedule Extension2 Non-Outage 1 cycle (24 months)
Outage Only 2 cycles (48 months)
Immediately upon adopting the JOG Program, a significant number of high margin, low safety significant MOVs will exceed the five (5) year maximum PVT interval since their baseline diagnostic test performed during the GL 89-10 Program. Therefore, an extension is required. The affected low safety significant MOVs have large measured margins in excess of expected MOV degradation levels such that no MOV operability concems are expected to result from extending their PVT intenal beyond five (5) years. Based on repeat valve diagnostic testing experience, this conclusion will be supported by detailed technical analysis of MOV performance data at the end of the program transition schedule extension. PECO Energy is confident that once the test data is grouped, trended and statistically analyzed, a strong technical position can be developed that supports the maximum ten (10) year PVT intewal allowed by the JOG Program for high margin, low safety significant valves.
PECO Energy has been, and will continue, to perform scheduled MOV periodic verification testing e!.tablished under the current (Reference 1) program throughout the six month program transition period. All MOVs within the scope of GL 96-05 have been diagnostically tested at least once with the majority l aving multiple diagnostic tests. This scheduled testing would also De required under the JOG Program since both programs base the determination of PVT intervals on both safety importance and margin. To date, PECO Energy has met all of the JOG Dynamic Test Program differential prassure testing cornmitments and reaffirms its commitment to support the JOG Dynamic Test Program. The JOG Dynamic Test Program is an important element in ascertaining degradation trends and forming the basis of the Final (Long Term) MOV Periodic Verification Program.
Full compliance with the JOG Program also entails development and implementation of a revised Long Term MOV Periodic Verification Program following completion of the five (5) year JOG Dynamic Test Program. PECO Energy intends to continue participating in the JOG MOV Periodic Verification Program as a member of the Boiling Water Reactor Owners' Group.
Consequently, all previous discussion provided by PECO Energy in Reference 1 regarding the final (revised) program is superseded by this revised commitment to adopt the JOG Program.
' MOVs include only low safety and high margin. All others will be tested within the five (5) year interval.
2 Extension is from date of this letter.
May 14,1998 Page 3 If you have any questions, please contact us.
Very t
- yours,
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Ga ett D. Edwards J
Director-Licensing Attachments
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cc:
H. J. Miller, Administrator, Region I, USNRC E
A. C. McMurtray, USNRC Senior Resident inspector, PBAPS A. L. Burritt, USNRC Senict Resident inspector, LGS
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COMMONWEALTH OF PENNSYLVANIA:
ss.
COUNTY OF CHESTER J. B. Cotton, being first duly swom, deposes and says:
That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached response to Generic Letter 96-05, for Peach Bottom Facility Operating Licenses DPR-44 and DPR-56, and Limerick Facility Operating Licenses NPF-39 and NPF-85, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
tb h &
Vice President l
l Subscribed and swom to before methis /f/
ay d
of 1998.
a.qJW l
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1 Notary Public NOTARIAL SEAL CAFOL A. WAL10N. Notary Put#O City of Philadelphia. Poda County M Empires May 28,2001 1
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