ML20249C430

Forwards Revised Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs

ML20249C430
Person / Time
Site:	Comanche Peak
Issue date:	06/24/1998
From:	Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-05, GL-96-5, TXX-98154, NUDOCS 9806290321
Download: ML20249C430 (6)

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'""'" 9 LOG # TXX-98154 i "":. =

File # 10035

. C Ref. # 10CFR50.54(f) nlELECTRIC GL 96-05 g%% - June 24,1998

' Se. dor Mee President

& Princ(pelNuclear ORicer -

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U. S. Nuclear _ Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 REVISED RESPONSE TO GENERIC LETTER 96-05," PERIODIC

--VERIFICATION OF DESIGN-BASIS CAPABILITY OF

. SAFETY-RELATED MOTOR-OPERATED VALVES" REF: 1) . NRC Safety Evaluation, dated October 30,1997, on " Joint BWR, Westinghouse and Combustion Engineering Owners' Group Program on Periodic Verification on Motor-Operated Valves (MOV)

. Periodic Verification, Topical Report MPR-1807, Revision 2,

. July 1997"

2) Generic Letter 96-05,-" Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves",

dated September 18,1996

3) TU Electric letter logged TXX-98136 from Mr. C. L. Terry to NRC dated May 21,1998

4) Limitorque Technical Update 98-01, " Actuator Output Torque '

Calculation"(Preliminary For Reference Only), dated May _15,1998 On October 30,1997, the Nuclear Regulatory Commission issued a Safety Evaluation (SE) (Reference 1) which, within the conditions and limitations described in the SE, stated that the NRC Staff considers the Joint Owners' Group (JOG) Program on MOV Periodic Verification an acceptable industry-wide response to Generic Letter (GL) 96-

05.

-The JOG agreed that after issuance of the SE, requests would be made for participating utilities to notify the NRC of their plans to implement the JOG program described in Reference'1 and that any deviations from that program would be justified.

.TU Electric previously provided a response to Generic Letter 96-05 (Reference 2) via Reference 3. As a result of phone conversations with the NRC Staff on June 3,1998, L

TU Electric agreed to revise _its response to items 1 and 2 of Generic Letter 96-05.

{i I The response is provided in Attachment 2 of this letter.

In addition, this letter provides TU Electric's response on the subject NRC Safety l Evaluation (Reference 1). TU Electric will continue to participate in the JOG MOV

. Periodic Verification Program as a member of the Westinghouse Owner's Group

-(WOG) and will incorporate the results of that program into the CPSES overall GL 96- o$

- 05 MOV Periodic Verification program as described in Attachment 2.

COMANCHE PEAV STEAM ELECTRIC STATION

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002 Glen Rose. Texas 76W 1002 4

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l TXX-98154 Page 2 of 2' Referonce 4 has been reviewed for potential impact on the CPSES MOV program.

Due to the extensive component level (i.e. motor dyno and torque test stand) test program at CPSES, the guidance provided in Limitorque Technical Update 98-01 for calculating actuator output torque does not affect the CPSES MOV program.

This communication contains a licensing basis commitment regarding CPSES Units 1 and 2 which is described in Attachment 3 to this letter.

If you have any questions, please contact Carl Corbin at (254) 897-0121.

Sincerely, C. L. Terry Bv: M ^

' Rog'er B. Walker Regulatory Affairs Manager CBC/cbc Attachments cc: Mr. E. W. Merschoff, Region IV Mr. J. l. Tapia, Region IV '

Mr. T. J. Polich, NRR j Resident inspectors, CPSES l

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Attachment 1 to TXX-98154  ;

Page 1 of 1. ' j

' UNITED STATES Oi AMERICA ~ I NUCLEAR REGULATORY COMMISSION in the Matter of )

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Texas Utilities Electric Company ). Docket Nos. 445

) and 50-44fs )

~ (Comanche Peak Steam Electric ) j Station, Units 1 & 2) ) {

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AFFIDAVIT Roger D. Walker being duly sworn, hereby deposes and says that he is the Regulatory {

Affairs Manager for Comanche Peak Steam Electric Station of TU Electric, the licensee 1 herein; that he is duly authorized to sign and file with the Nuclear Regulatory - 1 Commission this Response to Generic Letter 96-05, " Periodic Verification of

' Design-basis Capability of Safety-Related Motor-Operated Valves".; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, hformation and belief. ,

-1 RogdVD. Walker 'j Regulatory Affairs Manager j STATE OF TEXAS ) )

COUNTY OF '. totorn>

Subscribed and sworn to before me, on this S day of ha4d> 1998.

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// 'N CAR 01.YN L COSENTINO Notary Public l h,g] W180!NW2

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I Attachment'2 to TXX-98154 .!

Page i of 2 ?

.NRC GL- 96-05. Reauired Resoonse. Item 1 Within 60 days from the date of this generic letter, a written response indicating

, whether or not the addressee will implement the action (s) requested herein. If the

-addressee intends to implement the requested action (s), the addressee shall submit a -

schedule for completing implementation; if an addressee chooses not to implement the -

requested action (s), the addressee shall submit a description of any proposed-alternative course of action, the schedule for completing the alternative course of action (if applicable), and the safety basis for determining the acceptability of the planned alternative course of action.

. TU Electric Resoonse to item 1' TU Electric is revising the time frame stated in TXX-97055 (dated March 14,1997) for :l Implementation of the GL 96-05 recommendations from: the seventh refueling outage i for CPSES Unit 1 and the fourth refueling outage for CPSES Unit 2, to: the eighth l refueling outage for CPSES Unit 1 and the fifth refueling outage for CPSES Unit 2. This extension is required to enable the coordinated implementation of the Generic Letter-96-05 actions with the risk informed inservice Testing Program currently being reviewed

. by the NRC Staff. This schedule change is acceptable due to the extensive actions

. taken in response to NRC GL 89.10.

NRC GL-96-05. Reauired Response. Item 2 4

Within 180 days from the'date of this generic tetter, or upon notification to NRC of icompletion of GL 89-10 (whichever is later), the addressee shall submit a written -

summary description of its MOV periodic verification program established in accordance with the Requested Actions paragraph or the alternative course of action established by

~t he addressee in response to item 1 above.

TU Electric Resoonse to lteqL2 TU Electric intends to satisfy the Motor Operated Valve Periodic Verification issues byl complying with the' requirements of ASME O&M Code Case OMN-1," Alternate Rules for Preservice and inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants, OM Code-1995 Edition, Subsection ISTC," with the following limitations:

1) The potential benefits (such as identification of decreased thrust output and increase thrust requirements) and potential adverse effects (such as-accelerated aging or valve damage) will be considered when determining

the appropriate testing for each MOV.

'2) Where the selected inservice test frequency extends beyond 6 years or 4 refueling cycles (whichever !s longer), performance and test experience obtained from valve testing conducted during the first 6_ year or 4 refueling -

B outage time period shall be evaluated to justify the longer periodic verification frequency.-

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Attachment 2 to TXX-98154 Page 2 of 2 '

3) The risk insights determined during TU Electric's participation in the Electric Power Research Institute (EPRI) Risk-Informed inservice Testing s Pilot Project (ref. EPRI TR-105869) and on-going development of an 3

updated risk-informed categorization process based upon ASME Research guidance and Codes as applicable will be used in accordance with the requirements of the ASME OM Code Case OMN-1.

TU Electric intends to implement the requirements of ASME Code Case OMN-1 as described in Relief Request V-8 (TXX-98153, from Mr. C. L. Terry to the NRC, dated June 24,1998).

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Attachment 3 to TXX-98154 Page 1 of 1

• This communication contains the following commitment which is ongoing in nature and will be incorporated into the CPSES licensing basis by the eighth refueling outage for Unit 1 and the fifth refueling outage for Unit 2:

CDF Number Commitment 27136 TU Electric intends to ::atisfy the Motor Operated Valve Periodic Verification issues by complying with the requirements of ASME O&M Code Case OMN-1," Alternate Rules for Preservice and inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants, OM Code-1995 Edition, Subsection ISTC," subject to the limitations and exceptions described in TXX-98154.

The CDF (Commitment Data Form) number is used by TU Electric for internal tracking of CPSES commitments.

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