ML20204C956

Forwards RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, Program at Plant,Units 1 & 2.Response Requested by 990521

ML20204C956
Person / Time
Site:	Farley
Issue date:	03/17/1999
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 9903240043
Download: ML20204C956 (6)

Text

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March 17,1999 Mr. D. N. Morcy Distribution: TScarborough

' Vice Pr:sid:nt - Fatrisy Proj:ct . CDocket File x OGC Southern Nuclear Operating Company, Inc. PUSLIC~ ACRS

- Post Office Box 1295  : PD ll-2 R/F .

PSkinner, Rll Birmingham, Alabama 35201-1295 . JZwolinski/SBlack CHawes JZimmerman HBerkow

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 PROGRAM AT JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (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 J 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 requires additional information to complete its review for Farley.

Enclosed is a request for additionalinformation regarding the GL 96-05 program at Farley. We request that you'r response be provided by May 21,1999. This date was discussed with and J agreed to by Mark Ajiuni of your staff on March 15,1999. If circumstances result in the need to j revise this date, please contact me at (301) 415-2426. J Sincerely, Original signed by:

Jacob 1. Zimmerman, Project Manager Project Directorate ll-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation i

Docket Nos. 50-348 and 50-364, -

Enclosure:

- As stated cc w/encis: See next page_ "3N'N 9903240043 990317 PDR ADOCK 0 M00348

.P FDR To receive a copy of this document, indicate in the box: "C" = Copy withoirt attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE PM:Ppit( l[$h:PDil-2 l D:Ppid/d l l l NAME- JZirffFis(man:cn- CHawesM// HBsrkd4 I/

DATE 5 //h9 3 //7/99' Sf r/99 / /99 / /99 / /97

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g NUCLEAR REGULATORY COMMISSION I 't WASHINGTON, D.C. 2055MX)01

,,g. March 17, 1999 Mr. D. N. Morey Vice President - Farley Project Southern Nuclear Operating Company, Inc. 1 Post Office Box 1295 l Birmingham, Alabama 35201-1295

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 PROGRAM AT JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (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 veriffon 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 recor.,,riendations of GL 96-05. In your letter dated June 10,1998,you indicat?d your intent to implemcit the provisions of a Joint Owners Group (JOG) Program on MOV Pariodic Verification. The NRC staff has encouraged licensees to participate in the industry-wide JOG program t ' orovide a benefit in reactor safety by sharing expertiso and l 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 requires additionalinformation to complete its review for Farley. i Enclosed is a request for additionalinformation regarding the GL 96-05 program at Farley. We request that your response be provided by May 21,1999. This date was discussed with and  !

agreed to by Mark Ajluni of your staff on March 15,1999. If circumstances result in the need to revise this date, please contact me at (301) 415-2426.

Sincerely, acob 1. Zimmerman, Project Manager Project Directorate 11-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

As stated cc w/encls: See next page

F:

Joseph M. Farley Nuclear Plant cc:

Mr. L. M. Stinson Rebecca V. Badham General Manager - SAER Supervisor Southern Nuclear Operating Company Southern Nuclear Operating Company Post Office Box 470 P. O. Box 470 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 Office Box 306 1710 Sixth Avenue North Birmingham, Alabama 35201 Mr. J. D. Woodard Executive Vice President Southern Nuclear Operating Company Post Office Box 1295 Birmingham, 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 Co!umbia, Alabama 36319

I 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 j (Farley) in response to Generic Letter (GL) 89-10, " Safety-Related Motor-Operated Valve i 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 certain aspects of the licensee's MOV program to be addressed over the long term. For example, the NRC staff noted that i the licensee agreed to (1) use the Electric Power Research Institute (EPRI) MOV l Performance Prediction Model (PPM) to establish the design-basis thrust requirements for several Unit 1 and Unit 214" Copes-Vulcan gate valves; (2) use the EPRI MOV PPM to establish the design-basis thrust requirements for Unit 2 Westinghouse gate valve 8811 A; and (3) reset the torque switches for 30 MOVs that had inadequate thrust settings. In l addition, the NRC staff noted that the licensee was expected to (1) revise its Project Desk l Instruction PDI 005.3 to alert personnel to the potential of obtaining nonconservative results when interpolating from high test pressures to lower design-basis differential pressures; (2) resolve its differences with Limitorque's guidance on overthrust events; and (3) include in the post maintenance testing requirements guidance to consider performing a dynamic test after valve repair or replacement. The licensee should describe the actions taken to address the specific long-term aspects of the MOV program at Farley noted in the NRC ,

inspection report. j

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 inspection ,

report stated that the licensee planned to evaluate the adequacy of the Pratt guidance using l the EPRI MOV PPM when availab'e. In a letter dated March 3,1995, the licensee provided j a schedule for completion of the EPRI MOV PPM butterfly valve evaluation. However, this  !

letter stated that only active, safety significant p *ity one butterfly valves would be evaluated using the EPRI MOV PPM. This scopa Jatement appears different from the  ;

information provided in the NRC inspection report. The licensee should clarify the scope of j its butterfly valve evaluations. l 1

3. In a letter dated June 10,1998, the licensee updated its commitment to implement the Joint i Owners Group (JOG) Program on MOV Periodic Verification in response to GL 96-05. In a j safety evaluation dated October 30,1997, the NRC staff accepted the JOG program as an i 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 i dynamic test program, and (3) the JOG long-term periodic test program. The licensee's letter of June 10,1998, only mentions the JOG in:erim 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 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.

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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 panet.

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 14,19987 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 significa. ice.

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 ovaluation dated October 30,1997, on the JOG program, the NRC stated that MOVs with scheduled test frequencies beyond 5 years will need to be grouped with other MOVs that will be tested on frequencies less than 5 years in order to validate assumptions for the longer test interv'als. The NRC stated that this review must include both valve thrust (or torque) requirements and actuator ouMut capability. The licensee should describe how its MOV static diagnostic testine wam 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) correlation of new MCC test data to existing direct force measurements; (2) interpretation of changes in MCC test data to chariges in MOV thrust and torque performance; (3) adequacy for use as a post maintenance diagnostic tool (e.g.,

after packing adjustments); (4) consideration of system accuracies and sensitivities to MOV degradation for both output and operating performance requirements; and (S) validation of MOV operability using MCC testing.

8. The JOG program focuses on the potential age-related increase in the thrust cr 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 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

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l ensuring adequate ac and dc MOV motor actuator outpui capability, including (1) l 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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