ML20206G241

Forwards Revised RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, Program at Farley.Requests to Be Notified of Rev to Original Target Date of 990521

ML20206G241
Person / Time
Site:	Farley
Issue date:	04/30/1999
From:	Jacob Zimmerman NRC (Affiliation Not Assigned)
To:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
References
GL-96-05, GL-96-5, TAC-M97045, TAC-M97046, NUDOCS 9905070138
Download: ML20206G241 (6)

Text

i Marsrbuh Mr. D. N. Moray Distribution:

Vice PrIsident - Farl

y Proj:ct Dock t Fila -

OGC Sguthern Nucirer Op; rating Comp:ny, Inc. PUBLIC ACRS Post ti)ffice Box 1295 PD 112 R/F PSkinner, Ril Birmingham, Alabama 35201-1295 JZwolinski/SBlack

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - RE: REVISED REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 (TAC NOS. M97045 AND M97046)

Dear Mr. Morey:

On September 18,1996, the NRC issued Generic Letter (GL) 96-05, ' Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," 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.

In letters dated November 7,1996, March 14,1997, and June 10,1998, you provided a response tc the recommendations of GL 96-05, in your letter dated June 10,1998, you indicated your intent to implement the provisions of a Joint Owners Group (JOG) Program on 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. Licensee participation in the JOG program also minimizes the amount of information necessary for the NRC staff to review each licensee's response to GL 96-05. As a result, the NRC staff required additional information to comp lete its review for Farley and issued a request for additional information (RAI) on March 17,1999. However, based on subsequent conversations with members of your staff, questions 1 and 2 have been revised.

1 Enciosed is a revised request for additional information regarding the GL 96-05 program at Farley. If circumstances result in the need to revise the original target response date of May 21,1999, please contact me at (301) 415-2426.

Sincerely, btbir n$rr akl)roject Manager, Section 1 Project Directorate ll Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

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April 30,1999 Mr. D. N. Morey Vice President - Farley Project Southern Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201-1295

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - RE: REVISED REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 (TAC NOS. M97045 AND M97046)

Dear Mr. Morey:

On September 18,1996, the NRC issued Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," 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.

In letters dated November 7,1996, March 14,1997, and June 10,1998, you provided a response to the recommendations of GL 96-05. In your letter dated June 10,1998, you indicated your intent to implement the provisions of a Joint Owners Group (JOG) Program on 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. Licensee participation in the JOG program also minimizes the amount of information necessary for the NRC staff to review each licensee's response to GL 96-05. As a result, the NRC staff required additional information to complete its review for Farley and issued i

a request for additional information (RAI) on March 17,1999. However, based on subsequent 1

conversations with members of your staff, questions 1 and 2 have been revised.

Enclosed is a revised request for additional information regarding the GL 96-05 program at Farley. If circumstances result in the need to revise the original target response date of May 21,1999, please contact me at (301) 415-2426.

1 Sincerely, 1

Jacob 1. Zimmerman, Project Manager, Section 1 Project Directorate ll Division of Licensing Project Management c

Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

As stated cc w/encls: See next page

j

' Joseph M. Farley Nuclear Plant cc:

Mr. L. M. Stinson Rebecca V. Badham i

General Manager-SAER Supervisor Southem Nuclear Operating Company Southem Nuclear Operating Company Post Office Box 470 P. O. Box 470 i

Ashford, Alabama 36312 Ashford, Alabama 36312 Mr. Mark Ajiuni, Licensing Manager Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm Post OfTUe Box 306 1710 Sixth Avenue Noeth Birmingham, Alabama 35201 Mr. J. D. Woodard Executive Vice President Southern Nuclear Operating Company Post Office Box 1295 Bi mingham, Alabama 35201 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, Alabama 36302 Resident inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, Alabama 36319

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y REVISED REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE OF GENERIC LETTER 96-05

~ JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 1.

In NRC letter dated November 9,1995, the NRC staff closed its review of the motor-operated valve (MOV) program implemented at the Joseph M. Farley Nuclear Plant (Farley) in response to Generic Letter (GL) 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance," based on the results of NRC Inspection Report (IR) 50-348 & 364/94 28 (dated January 6,1995) and information contained in a letter from the licensee dated March 3,1995. In IR 94-28, the NRC staff discussed aspects of the licenaee's MOV program to be addressed over the long term. The NRC staff reviewed those long-term aspects of the MOV program during subsequent inspections at Farley as documented in IR 95-21 (dated March 4,1996) and IR 96-13 (dated December 23,1996). The licensee should discuss its consideration cf the following long-term aspects of its MOV program: (1) the weaknesses identified in IR 96-13 by the NRC inspectors regarding the licensee's support for the capabilities of several Unit 1 and Unit 214" Copes-Vulcan gate valves, including the application of the Electric Power Research Institute (EPRI) MOV Performance Prediction Methodology (PPM) and the limited capability margin of MOV 1-8811 A; (2) the potential weakness in the licensee's approach for setting the torque switches for 30 MOVs as described in IR 95-21; (3) the revision of the licensee's Project Desk Instruction PDI 005.3 noted in IR 94-28 to alert personnel to the potential for obtaining nonconservative results when interpolating from high test pressures to lower design-basis differential pressures; and (4) post maintenance testing guidance discussed in IR 94-28 to consider performing a dynamic test after valve repair or replacement.

2.

In IR 94-28, the NRC staff noted that the Farley GL 89-10 MOV program included 94 butterfly valves manufactured by Pratt. The adequacy of the manufacturer-provided torque requirements for these MOVs had not been verified by the licensee. The NRC staff indicated that the licensee planned to evaluate the adequacy of the Pratt guidance using the EPRI MOV PPM when available. In a letter dated March 3,1995, the licensee provided a schedule for completion of the EPRI MOV PPM butterfly valve evaluation. In IR 96-13, the NRC staff found the licensee's evaluation of 16 Pratt butterfly valves using the EPRI MOV PPM to be acceptable. The licensee should describe the basis for its evaluation of the remaining 78 safety-related Pratt butterfly valves at Farley.

1 3.

In a letter dated June 10,1998, the licensee updated its commitment to implement the Joint Owners Group (JOG) Program on MOV Periodic Verification in response to GL 96-05. In a safety evaluation dated October 30,1997, the NRC staff accepted the JOG program as an industry-wide response to GL 96-05 with certain conditions and limitations. The JOG program includes (1) the JOG interim static diagnostic test program, (2) the JOG 5-year dynamic test program, and (3) the JOG long-term periodic test program. The licensee's letter of June 10,1998, only mentions the JOG interim static diagnostic test program and the JOG dynamic test program. Where a licensee proposes to implement an approach different from the JOG program, the licensee will 1

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9 be expected to notify the NRC and to provide justification for the proposed alternative approach. The Farley licensee should clarify its commitment with respect to all three phases of the JOG program.

4.

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 a letter dated March 14,1997, the licensee stated that MOV safety significance would be based on an existing probabilistic assessment and inputs from an expert panel. As Farley is a pressurized water reactor (PWR) nuclear plant designed by Westinghouse, is the licensee applying the Westinghouse Owners' Group (WOG) methodology for ranking MOVs based on their safety significance as described in WOG Engineering Report V-EC-1658 A, " Risk Ranking Approach for Motor-Operated Valves in Response to Generic Letter 96-05," and the NRC safety evaluation dated April 14, 1998? If not, the licensee should describe the methodology used for risk ranking MOVs at Farley in more detail, including a description of (1) the process used to compare Farley high-risk MOVs to a sample list of high-risk MOVs from other Westinghouse plants; and (2) how expert panels were used to evaluate MOV risk significance.

5.

From the licensee's letter dated March 14,1997, it is not clear whether the Farley interim MOV static diagnostic test program is consistent with the JOG program. For example, the licensee noted the use of " criteria-based" and " time-based" methods in establishing the Farley MOV static diagnostic test frequencies. The licensee should discuss its MOV static test matrix and justify any differences between its interim MOV static diagnostic test program and the JOG program.

6.

In its letter dated March 14,1997, the licensee states that various MOV diagnostic measurement techniques will be used as part of two different sets of static diagnostic test frequencies. Depending on MOV safety significance, at-the-valve static diagnostic tests will range from 72 months to 126 months and motor control center (MCC) tests will range from 18 months to 72 months. This combination of test frequencies results in all MOVs being re tested at least every 72 months. In the NRC safety evaluation dated October 30,1997, on the JOG program, the NRC stated that MOVs with scheduled test frequencies beyond five years will need to be grouped with other MOVs that will be tested on frequencies less than five years in order to validate assumptions for the longer test intervals. The NRC stated that this review must include both valve thrust (or torque) 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.

.7.

The licensee should briefly describe its plans for the use of test data from the motor control center (MCC) including (1) corrolation 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) adequacy for use as a post maintenance diagnostic tool (e.g., after packing adjustments); (4) corsideration of system accuracies and sensitivities to MOV degradation for both output and operating performance requirements; and (5) validation of MOV operability using MCC testing.

8.

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 l _.

i 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 Farley for ensuring adequate ac and de MOV motor actuator output capability, including (1) consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement 1; and (2) Justification of any potential use of Farley's reduced voltage output test methodology discussed in IR 94-28.

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