ML20205P595

Forwards RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, Issued on 960918.Response Requested within 90 Days of Date of Ltr

ML20205P595
Person / Time
Site:	South Texas
Issue date:	04/15/1999
From:	Alexion T NRC (Affiliation Not Assigned)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
GL-96-05, GL-96-5, TAC-M97102, TAC-M97103, NUDOCS 9904200238
Download: ML20205P595 (6)

Text

p p ter% t g UNITED STATES s* j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enmas m k

g**,.. April 15,1999 .

Mr. William T. Cottle l

President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 l

Wadsworth,TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 96-05, SOUTH TEXAS PROJECT, UNITS 1 AND 2 (TAC NOS. M97102 AND M97103)

Dear Mr. Cottle:

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.

On November 18,1998, you submitted an updated response to GL 96-05 indicating your intent to impisment the provisions of a Joint Owners Group (JOG) Program on MOV Periodic Verification. The NRC staff has encouraged licensees to participate ire 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 only limited information to complete its GL 96-05 review for the South Texas Project.

Enclosed is a request for additional information (RAI) regarding the GL 96-05 program at the South Texas Project. Thic request was discussed with Mr. Wayne Harrison of your staff on 1 y

9904200238 990415 PDR ADOCK 05000498 P PDR

r-W. T. Cottle 2 l 1

April 6,1999, and a mutually agreeable response to the RAI of within 90 days from the date of !

this letter was established. The staff appreciates the efforts expended with respect to this matter.

I Sincerely, I

W> Jh w.

Thomas W. Alexion, Project Manager, Section 1 Project Directorate IV & Decommissioning i

Division of Licensing Project Management 1 Office of Nuclear Reactor Regulation  !

Docket Nos. 50-498 and 50-499 l

Enclosure:

As stated

! cc w/ encl: See next page l

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l W. T. Cottle 2 April 6,1999, and a mutually agreeable response to the RAI of within 90 days from the date of this letter was established. The staff appreciates the efforts expended with respect to this matter.

I Sincerely, j l i ORIGINAL SIGNED BY: l Thomas W. Alexion, Project Manager, Section 1 l Project Directorate IV & Decommissioning l Division of Licensing Project Management Office of Nuclear Reactor Regulation l Docket Nos. 50-498 and 50-499 i

Enclosure:

As stated cc w/ encl: See next page l

l l

OlSTRIBUTION:

Docket File!

PUBLIC PDIV-1 r/f JZwolinski/SBlack i TScarbrough l OGC l 'ACRS KBrockman, RIV I

DOCUMENT NAME: 1:\STPFINAL\RAl97102.WPD To ow. . coo , e ei. aocum.nt mec m m. non c.c wo .a.cnm nv.ncio.u,. e-cm .an .n.csm. nit.ncio.u,. u . uo copy OFFICE PM/PDWO E LA/PDIV-1 F SC/PDIV-1 6 NAME TAlex16h CJamerson:S [ RGramm N DATE h/ f h/99 M/ ([ /99 j Y ([ /99 l

/ OFFIC 'AL RECORD COPY 1.

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Mr. William T. Cottle l STP Nuclear Operating Company South Texas, Units 1 & 2 l

cc:

Mr. Comelius F. O'Keefe Jack R. Newman, Esq.

Senior Resident inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

P. O. Box 910 Washington, DC 20036-5869 l Bay City, TX 77414 Mr. T. H. Cloninger Vice President A. Ramirez/C. M. Canady Engineering & Technical Services City of Austin STP Nuclear Operating Company i Electric Utility Department P. O. Box 289 l 721 Barton Springs Road Wadsworth,TX 77483 Austin,TX 78704 Office of the Govemor Mr. M. T. Hardt ATTN: John Howard, Director Mr. W. C. Gunst Environmental and Natural City Public Service Board Resources Policy P. O. Box 1771 P. O. Box 12428 l San Antonio,TX 78296 Austin, TX 78711 l

Mr. G. E. Vaughn/C. A. Johnson Jon C. Wood Central Power and Light Company Matthews & Branscomb l

P. O. Box 289 One Alamo Center Mail Code: N5012 106 S. St. Mary's Street, Suite 700 j Wadsworth, TX 74483 San Antonio, TX 78205-3692 l lNPO Arthur C. Tate, Director l Records Center Division of Compliance & Inspection 700 Galleria Parkway Bureau of Radiation Control Atlanta, GA 30339-3064 Texas Department of Health l 1100 West 49th Street Regional Administrator, Region IV Austin,TX 78756 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Jim Calloway Arlington,TX 76011 Public Utility Commission of Texas Electric Industry Analysis D. G. Tees /R. L Balcom P. O. Box 13326 Houston Lighting & Power Co. Austin, TX 78711-3326 P. O. Box 1700 Houston,TX 77251 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414

~

l Reauest for AdditionalInformation_ l

)

Response to Generic Letter 96-05 South Texas Prolect. Units 1 and 2

1. In NRC letter dated Merch 2,1995 (ACN 9503080315), the NRC ctaff closed its review of the motor-operated valve (MOV) program implemented at the South Texas Project t (South Texas) in response to Generic Letter (GL) 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance," based on the results of NRC 1' Inspection Report No. 50-498 & 499/94-32 (dated November 10,1994) and information contained in a letter from STP Nuclear Operating Company (the licensee) dated January 9,1995. In the inspection report, the NRC staff discussed certain aspects of the licensee's MOV program to be addressed over the long term. For example, the l

inspectors noted that the licensee committed to apply results from the Electric Power

. Research Institute (EPRI) MOV Performance Prediction Model (PPM) for those MOVs that had no test data available to validate the assumed valve factor. In addition, in the March 2,1995, letter, the staff noted that the licensee (1) committed to dynamically test a minimum of eight MOVs (six gate valves, one globe valve, and one butterfly valve) l with diagnostics each refueling outage; (2) agreed to revise the post maintenance test l guidelines to review the need for dynamic testing regardless of valve type or achievable l test differential pressure; and (3) committed to complete an MOV over-current protection review and to take appropriate actions, where necessary. The licensee should describe the actions taken to address the specific long-term aspects of the MOV program at South Texas noted in the NRC inspection report and the NRC staff's letter dated March 2,1995.

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2. In a letter dated November 18,1998, the licensee updated its commitment to implement l the JOG program. However, the licensee stated that it will" consider" the JOG program l testing results. The NRC staff has determined that, when a licensee commits to the l JOG Topical Report on the MOV Periodic Verification Program, the licensee is committing to implement each of the three phases of the described JOG program, ,

, including (1) JOG interim static diagnostic test program, (2) JOG 5 year dynamic test i

! program, and (3) JOG long-term periodic test program. Where a licensee proposes to implement an approach different from any of these three phases of the JOG program, ,

! the licensee will be expected to notify the NRC and to provide justification for the proposed attemative approach. For example, if a licensee proposes not to implement  ;

the third phase of the JOG program (JOG long-term periodic test program) after the specific long-term test criteria have been established following the JOG 5-year dynamic j test program, the licensee will be expected to notify the NRC and to justify its proposed

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alternative long-term test criteria. The South Texas licensee should discuss its commitment to the JOG long-term periodic test program and whether it is consistent with the NRC staff's interpretation of a commitment to all three phases of the JOG program.

ENCLOSURE t .

2

3. The licensee's updated commitment stated that the South Texas MOV risk-ranking approach differs in some respects from the program described in the Westinghouse Owners Group (WOG) Engineering Report V-EC-1658-A (Revision 2, dated August 13, 1998)," Risk Ranking Approach for Motor-Operated Valves in Response to Generic Letter 96-05," and the NRC safety evaluation dated April 14,1998, on Revision 1 of WOG Engineering Report V-EC-1658. The licensee intends to substitute its own risk-informed performance-based approach to address the safety significance of MOVs at South Texas. The licensee should describe the methodology used for risk ranking MOVs at South Texas in more detail, including (1) a description of how the South Texas methodology differs from the method described in WOG Engineering Report V-EC-1658-A and the NRC safety evaluation; (2) a discussion of the applicability of the conditions and limitations conteJaed in the NRC safety evaluation of WOG Engineering Report V-EC-1658-A; (3) the process used to develop a sample list of high-risk MOVs from other Westinghouse plants; (4) how expert panels were used to evaluate MOV risk significance; and (5) a discussion of the static test frequency that will result from application of the South Texas MOV risk-ranking methodology.

4. 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 licensees are rerponsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. The licensee should describe the plan at South Texas for ensuring adequate ac and de MOV motor actuator output capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement 1 dated July 17,1998.

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