ML20005E522

Responds to Generic Ltr 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance.

ML20005E522
Person / Time
Site:	Callaway
Issue date:	12/28/1989
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-10, IEB-85-003, IEB-85-3, ULNRC-2128, NUDOCS 9001080065
Download: ML20005E522 (4)

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1901 Gratnot Srrett Post Offee Bs 149 St lov:s. M sswiL3166

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t Decembcr 28, 1989 Donaldr.schneII O^r Euic mc t;;;;~~

L- 3' U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, D.C. 20555 j Gentlemen ULNRC-2128 DOCKET No. 50-483 CALLAWAY PLANT SAFETY-RELATED MOTOR-OPERATED VALy_E TESTING AND SURVEII4ANCE

Reference:

NRC Generic Letter No. 89-10, dated June 28, 1989 The attachment to this letter provides Union Electric's response to Generic Letter 89-10. This generic letter required licensees to advise the NRC in writing, that the schedule and recommendations as detailed in the generic letter would be met.

This letter satisfies the six-month response date as required by Action Item L. If you have any questions concerning this letter, please contact me.

Very truly yours, g

Donald F. Schnell WEK/dvd Attachment 10 %0 O I \

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- i ATTACHMENT TO ULNRC-2128  !

UNION ELECTRIC RESPONSE TO l

_NRC_ GENERIC LETTER _FO. 89-10 l

Generic Letter 89-10 requires utilities to develop a program similar to that already established at Callaway Plant to verify operability of all safety-related MOVs.In response to NRC IE Bulletin No. 85-03, Union Electric initiated a program to verify Feedwater in the Auxiliary operabilityand of selected Safety motor-operator valves (MOVs)This program consisted of 34 rafety-related Injection systems.After the implementation of the requirements of IEB 85-03, MOVs.

Union Electric expanded the MOV program to include all safety-related MOVs (with untested safety-related MOVs being diagnostically tected as design reviews are completed). When fully implemented, Union Electric will have 153 safety-related MOVs in the testing program. '

Callaway Plant's MOV program satisfies the recommendations of the Generic Letter with the following exceptions:

1)

Generic Letter 89-10 Item C states that all safety-related MOVs '

are to be demonstrated operable by testing them at design basis differential pressure (DP) and/or flow. In lieu of performing full flow DP testing on each MOV, Union Electric intends to utilize the HENZE-MOVATS DP data base methodology If (which sufficient contains results of DP tests performed on MOVs).

data base, points for a particular type of MOV existThe in the datathe amount of thrust to operate against DP conditions.

methodology requires either 4 or more data points from valves  ;

of the same type, manufacturer, orifice diameter, and stem diameter; or 20 or more points from valves of theMOV If an same type to cannot negate the need for "in situ" DP testing.or if an MOV cannot provide the satisfy the 4 or 20 criteria, needed ing thrust thrust as determined limitations from/ the of the valve data base actuator without assembly, exceed-it will be evaluated for the need to DP test.

There are several reasons that we feel the data base methodol-ogy is an acceptable alternative to DP testing each valve.

Union Electric's experience finds the MOV thrust requirements from the data base to be conservative when Thecompared blowdown with actual testing DP tests performed at Callaway Plant. as performed by Idaho National Engineering Laboratories tions, which is not indicative of the system conditions for the safety-related MOVs at Callaway Plant. The HENZE-MOVATS DP data base methodology utilizes data from DP tests in single Also, the phase conditions similar to Callaway's application. pla would result in increasing the probability of abnormal opera-tional occurrences. Union Electric intends to use the HENZE-MOVATS DP data base methodology until it is proven by further research to be nonconservative in single phase conditions.

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2) The last paragraph in Generic Letter 89-10, Action Item L recommends that the licensee submit in writing to the NRC any It is j future changes to commitments to this Generic Letter.

Union Electric's intention to submit only those changes which such as changes to the scope,  :

are significant in nature (i.e., l basis, or methodology of our MOV program). l There are concerns at Union Electric and within the nuclear industry regarding certain aspects of the Generic Letter. NUMARC has madeIt contact with the NRC and is working to reselve these concerns.

is Union Electric's desire to have the differences resolved between the NRC and the industry, through NUMARC. regarding the requirements of the Generic Letter. We will continue to follow the resolution of these differences and modify our program as necessary, i

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o i cci Gerald Charnoff, Esq.

L Shaw, Pittman, Potts & Trowbridge ,

2300 N. Street, N.W. l l- Washington, D.C. 20037  ;

t- i Dr. J. O. Cermak I CFA. Inc.

4 Professional Drive (Suite 110)  :

Gaithersburg, MD 20879 l i R. C. Knop Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission  ;

Region III 799 Roosevelt Road l- Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission .

RR#1 Steedmam, Missouri 65077 Tom Alexion (2)

Office of Nuclear Reactor Regulation U.S.. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 .

11555 Rockville Pike Rockville, MD 20852-Manager, Electric Department '

Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 >

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