ML20059A716

Provides Comments on 900105 Response to Generic Ltr 89-10 Re safety-related motor-operated Valve Testing & Surveillance. Util Should Provide Description of Methodology for Periodic Verification of motor-operated Valve Switch Settings

ML20059A716
Person / Time
Site:	Davis Besse
Issue date:	08/08/1990
From:	Lynch M Office of Nuclear Reactor Regulation
To:	Shelton D TOLEDO EDISON CO.
References
GL-89-10, IEB-85-003, IEB-85-3, TAC-M75654, NUDOCS 9008230190
Download: ML20059A716 (3)

Text

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• . UNITED STATES

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k NUCLEAR REGULATORY COMM15SION T II wAswiwarow, p. c.sosas -

. August Bf 1990

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Docket No. 50-346 1

Mr. Donald C. Shelton Vice President - Nuclear

-Toledo Edisc1 Company j Edison Plaza - Stop 712 300 Madison Avenue i Toledo, Ohio 43652 ,

Dear Mr.-Sheltoni

SUBJECT:

RESPONSE TO GENERIC LETTER 89-10. " SAFETY-RELATED MOTOR-0PERATED VALVE (MOV)TESTINGANDSURVEILLANCE"(TAC.N0;M75654)

On June 28, 1989, theNRCissuedGenericLetter(GL)-89-10requestingthe establishment of a program to ensure the operability _ of all safety-related MOVs under design basis conditions. -The p ogram in GL 89-10 significantly expands the scope of the. program outlined NRC Bulletin 85-03 and its  !

supplement, i

The schedule provided in the generic le'tter requested that a description of  !

your MOV program be available for' review by June 28, 1990, or the first.

refueling outage after December 28.-1989, whichever was'later. :Due to delays in issuing Supplement 1 of the generic letter,-the staff has decided to delay inspections until at least January 1,1991. Therefore, your prograr-description need not be available on-site until January 1 1991, or the first :i refueling after December 28, 1989, whichever is later.- Information that- 1 should be- contained in your program description was discussed during the "

workshops held in September 1989-and is provided in Supplement,1'to the'

-generic letter. As your MOV program is developed '- justificatun for any differences between your program and the generic letter exemplified by

• Supplement 1 should be , incorporated into your program description.

• On January 5,1990, you submitted a response to GL 89-10, regarding the< ,

Davis-Besse Nuclear Power. Station. Several comments on your submittal are '

provided below. 1 In the cover letter to your January 5 submittal, you requested the.NRC' staff to respond to a letter dated November 17, 1989,- from T.E. Tipton; Nuclear-ManagementandResourcesCouncil;(NUMARC),tto-T.E.Murley,NRC,. requesting clarification of several aspects of the generic letter. On January 29, 1990, J.E. Richardson, NRC, responded in a letter to T.E. Tipton, NUMARC. In_that letter the staff discussed the points raised by NUMARC and indicated that-the results of the public workshops would provide additional information.

In your, response to Item c of the generic letter, you indicate that you had performed some tests of MOVs under design-basis conditions. The' selection!of valves for testing under design-basis conditions was said to have been based

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EMN Donald C. Shelton -

2- August 8, 1990 '!

, on the appearance of lowest valve capability and highest thrust requirement.

You then state that you are " currently evaluating any further flow testing that may be possible." We interpret this to mean that you will apparently rely on static or partial flow tests with diagnostics for those MOVs that will not be tested under design-basis conditions. As you are aware, recent research results reveal that it is difficult to anticipate which valves will- .

have the least capability and highest thrust requirement. Furthermore, '

research results and operating experience have found that tests at static  !

conditions do not always demonstrate that a MOV will operate under design-  :

basis conditions. For these reasons, the staff recommends that you test I MOVs in situ under full flow and differential pressure desit nasis con.

ditioiis, where practicable. For MOVs that cannot be tested L M s minner, you should attempt to demonstrate the capability of those MOVs u....,, o., -

l r.ative methods. Where alterne b methods cannot be adequately justified at this time, the staff recommcnds you use the "two stage" approach discussed  !

at the workshops. .

In your response regarding the generic letter schedule, you indicate that you have implemented and completed the provisions of the generic letter with_

the apparent exception that testing of MOVs under design-basis testing is not always performed where practicable. You also state that you do not belin e the 5-year or three-refueling outage schedule for completion of the j initial program to be realistic if design-basis testing is to be performed.  ;

The staff recommended that MOVs be tested in situ under design-basis

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conditions, where practicable, because of tiie concerns regarding the ex- l trapolation of test data from static conditions and the applicability of  ;

test data from one MOV to another. The staff considers the need to complete the initial program within 5 years to be important. Also important, however, is the need to conduct the program in a manner that provides adequate confidence that the MOVs will perform their safety functions.

Therefore, the staff requests that you provide an estimated schedule for completion of the initial program as described in the generic letter and discussed at the workshops, in reference to your response to item d of the generic letter, the staff recommends that you provide a description of your methodology for the periodic verification of MOV switch settings in your program description.

Your program description should be retained on-site for possible further NRC staff review. ,

Sincerely, Original si M. D. Lynch,gned by John Sr. Project N. Hannon for/

Manager Project Directorate III-3 Division of Reactor Projects - III, IV, V ud Special Projects Office of Reactor Regulaiton cc: See next page ,

DISTRIBUTION

Docket File * JHannon ACRS(10)

NRC & Local PDRs MDLynch Pegion III, DRS PDIll-3 Reading OGC PD33 Gray File DCrutchfield TMarsh JZwclinski PKreutzer EJordan *See Prev 17usly Concurrence a

DOCUMENT NAME: M75654 GL 89-10 RESPONS 0*fice: LAJ/$11-3 PM/PDill! PD/PD -3 *EMEB Suename: PKreutzer MJLy ch/lb LBMarsh Datt: 9 / 9 /90 f/ /90 [JHannon/ p/9008/02/90

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o Mr. Donald C. Sheltcri. . Davis-Besse Nuclear Power Station - ..,

-Toledo Edison Company Unit ~No. 1- 1 j

CC

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David E. Burke, Esq.  ;

. The Cleveland Electric Radiological Health Program l Illuminating Company' 1

0hio Department of Health (

P. O. Box 5000 1224 Kinnear Road - :I Cleveland, Ohio, 44 L Columbus, Ohio 43212

i. Mr. Robert W. Schrauder ' Attorney General

Manager, Nuclear Licinsingl Department of Attorney- N Toledo Edison Compan/. General 3H Edison Plaza 30 East Broad Street-

i. 300 Madison Avenue Columbus..0hio 43215 t l Toledo, Ohio 43652 .

-Mr. James W. Harris, Director Gerald Charnoff, Esq.- .AddresseeOnly)-

( i, Shaw, Pittman, Potts ' Division of Power Generation ,

and Trowbridge Ohio Department of Industrial' Relations-2300 N Street N.W. 2323 West 5th Avenue l Washington, D.C. 20037 .P. 0. Box 825 i Columbus, Ohio 43216 .

1 Regional Administrator, Region III (

U.S. Nuclear Regulatory Comission Ohio Environmental Protection Agency 799 Roosevelt. Road DERR--Compliance Unit d Glen Ellyn, Illinois 60137 PO Box 1049 1800 Watermark Drive ,

Mr. Robert B. Borsum ATTN: Zack A. Clayton 4 t Babcock & Wilcox ColumbusfOhio 43266-0149  :

i=

Nuclear Power Generation Division  :

Suite C25, 1700 Rockville Pike President, Board of- .

County Comissioners of ..

Resident Inspector Ottawa County  ;

U. S. Nuclear Regulatory Comission Port Clinton, Ohio 43452 5503 N. State Route 2 Oak Harbor, Ohio 43449 State of Ohio , .

a Public Utilities Comission 180 East Broad Street Columbus, Ohio 43266-0573 4

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