ML20211H043

Submits Comments on San Onofre Response to NRC Request for Addl Info on risk-informed IST Program

ML20211H043
Person / Time
Site:	San Onofre
Issue date:	08/09/1999
From:	Raghavan L NRC (Affiliation Not Assigned)
To:	NRC
References
TAC-M97097, TAC-MA45969, NUDOCS 9909020001
Download: ML20211H043 (2)

Text

, a y & UNITED STATES j ,j

't NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205N1

• • • ,./ August 9,1999 MEMORANDUM FOR: Docket File FROM: L. Raghavan, Senior Project Manager d f/b -

Project Directorate IV, Section 2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -- FACSIMILE TRANSMISSION, ISSUES TO BE DISCUSSED IN AN UPCOMING PHONE CONVERSATION ON (TAC NOS: M97097 AND MA45969)

The attached questions were transmitted by f ax today to Mr. Jack Rainsberry of Southern Califomal Corporation (SCE) to prepare him and others for an upcoming telephone call. This memorandum and the attachment do not convey a formal request for information or represent an NRC staff position.

Docket Numbers 50-361 50-362 Distribution PUBLIC S. Dembeck S " S "'

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h 9909020001 990009 PDR ADOCK 05000361 P PDR

COMMENTS ON SAN ONOFRE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON RISK-INFORMED IST PROGRAM AND GL 96-05 PROGRAM

1. The staff will review the licensee's responses to Questions 6 through 11 regarding the GL 96-05 motor-operated valve (MOV) program at San Onof re separately f rom the Risk-inf ormed IST program. Follow-up questions on the responses to Questions 6 through 11 may be provided at a later date.

2. In Question 12, the staff requested the licensee to address the conditions on the use of Code Case OMN-1 listed in GL 96-05. The licensee's consideration of those conditions is not apparent in the RAI response.

3. In Question 12, the staff requested the licensee to address the use of riskinsights to evaluate ,

I potential extensions of the quarterly exercise intervals of high-risk MOVs. The licensee's evaluation of the risk significance of such extensions is not apparent in the RAI response.

4. In Question 13, the staff requested the licensee to describe the process that the licensee will follow for determining test intervals until sufficient plant-specific data are acc imulated. On pages 7 and 8 n Enclosure 3 to the RAI response, the licensee indicates that MCVs classified as LH and LSSC will be assigned initial test intervals of 6 years. The licensee does not describe ;is process for selecting this test interval including its assumed degradation rate.

5. On pages 7 and 8 of Enclosure 3 to the RAI response, the licensee states that the testing of LH and LSSC MOVs (active) will be conducted according to OMN-1 at an initialinterval not to exceed 6 years and that passive MOVs will be tested according to the Code of record on a frequency not to exceed 6 years. The licensee should describe its consideration of the provision in OMN-1 that MOVs must be exercised at least every refueling outage to ensure proper intemal lubrication for LH and LSSC active and passive MOVs.

6. On page 11 of Enclosure 3 to the RAI response, the licensee lists the elements to be considered in grouping components. The RAI response does not indicate that service conditions (such as fluid temperatures and pressures) or intemal design (such as Stellite sliding surfaces) will be considered in grouping MOVs and other valves.

7. The licensee should discuss its basis for extending the seat leakage testing for LH and LSSC  !

MOVs to 6 years.

8.. Has the licensee developed procedures for implementing OMN-1 at San Onofre?

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