ML20005E622
| ML20005E622 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/22/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, IEB-85-003, IEB-85-3, NUDOCS 9001100009 | |
| Download: ML20005E622 (4) | |
Text
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b South C?ntin: DIctric & Gas Comp;ny' Vice Presidsnt ollie S. Eredhim r
- c P.O. Box 88.
p F
. Jinkinsvdle, SC 20065 Nuclear Operations (803) 345 4040
=a -
December 22, 1989 p W s
t Document Control Desk U.S. Nuclear Regulatory Comission Washington, D. C.
20555
Subject:
Virgil C. Summer Nuclear Station Cperating License No. NPF-12 Docket No. 50/395 1
L y,
Response to Generic Letter No. 89-10 Gentlemen:
South Carolina Electric & Gas' Company (SCE&G) received Generic Letter No. 89-10, " Safety-Related Motor Operated Valve (MOV) Testing and Surveillance." on July'18, 1989. This Generic Lette* extended the scope of Bulletin 85-03 to include all safety-related MOVs as well as all position-changeable MOVs to provide assurance that they would function.when subjected to design basis conditions.
~This letter provides confirmation that SCE&G will comply with the schedule and requirements of the Generic Letter. Virgil C. Summer Nuclear Station (VCSNS)
M s initiated the process of ensuring that the testing, inspection,- and
- maintenance of safety-related and position-changeable MOVs in safety-related i-systeras is adequately addressed and will meet the requirements of the Generic E
Letter..Non-nuclear safety-related MOVs will be evaluated for inclusion based on their importance to safety.
Thefollowingitems(a-m)outlinetheVCSNSresponsetospecificrequirements addressed in the Generic Letter:
o.
a.
Review and document the design basis for the operation of each M0V.
VCSNS is in the process of performing design-basis reviews for all MOVs in the Generic Letter 89-10 population. As mentioned above, the MOV
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l population will include all safety-related M0Vs and position-changeable l
MOVs in safety-related systems. All of the recommendations of item a. of the Generic Letter and item e. (as applicable) will be addressed in the reviews.
b.
Using the results of the design basis, establish the correct switch settings.
i The VCSNS evaluation will include analytical techniques which will utilize the existing methodology of valve and operator vendors to establish l
correct switch settings.
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Dccument' Control-Desk Letter c
December 22, 1989 Page 2 of 4 c.
Individual MOV switch settings should be changed as appropriate to those established in response to item b.
Whether the switch settings are changed or not, the MOV should be demonstrated to be operable by testing
-it at the design-basis differential pressure and/or flow determined in response to item a.
Static diagnostic testing of MOVs will be performed and switch settings will be changed as required. The Generic Letter 89-10 MOV population will be reviewed to determine if the valve can be tested at the differential pressure identified in item a. above. The review will include a determination of the plant condition required to support the differential pressure test.
In cases where design-basis differential testing cannot be performed, a justification will be provided and an alternative method will be specified to substantiate the switch settings established in item b. above. VCSNS will utilize methods such as the
-grouping of MOVs to optimize the differential pressure tests being performed.
d.
Prepare or revise procedures to ensure that correct switch settings are determined and maintained throughout the life of the plant.
VCSNS procedures will ensure correct switch settings are established and maintained thrmghout the life of the plant. The correct switch settings will be established as described in items b. and c. above. The procedures will include instructions for testing and preventive maintenance on MOVs.
e._
The design-basis review should not be restricted to a determination of-estimated maximum design-basis differential pressure, but should include an examination of the pertinent design and installation criteria that were used in choosing the particular M0V.
The design-basis review addressed in item a., of each MOV will be a thorough review that will include, but not be limited to, the following:
Design-Basis Degraded Voltage (where applicable)
Power Supply and Cable Sizing f.
Documentation of explanations and the description of actual test methods used for accomplishing item c. should be retained as part of the required records for the M0V.
Documentation of explanations and the description of actual test methods used for testing will be retained as part of the required M0V records.
The switch settings of all MOVs will be reviewed regardless of any previous evaluation under Bulletin 85-03.
If design-basis differential pressure testing cannot be performed (due to plant conditions, system configuration, etc.) alternatives to testing will be provided.
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-Document'C3ntrol Desk Letter L
,s December 22, 1989-r '
.Page 3 of 4 g.
Licensee review of deficiencies, misadjustments, and degraded conditions found during compliance with Bulletin 85-03.
VCSNS will review the problems listed in Attachment A of Generic Letter 89-10 for applicability to our facility.
h.
Each MOV failure and corrective action taken, including repair, alteration, analysis, test, and surveillance, should be analyzed or justified and documented.
Any MOV failures or other occurrences with MOVs, such as changes in switch settings, will be documented as required. Data collected on each MOV will be trended and, where appropriate, shared with the industry through mechanisms such as the NPRDS.
1.
Schedule.
p VCSNS will meet the following schedule for compliance with the Generic Letter:
All design-basis reviews, analyses, verifications, tests, and inspections for compliance with items a. through h. will be completed within five years or three refueling outages, whichever is later, of the Generic Letter date.
The design-basis differential pressure testing will be scheduled to begin in the upcoming outage currently scheduled for March of 1990.
The description and schedule for the design-basis reviews currently taking place and the implementation description and schedule including items b. through h. will be available for review by June 28, 1990.
j.
Surveillance for MOV degradations or misadjustments.
l Surveillance intervals established for each MOV will not exceed a periodicity of five years or three refueling outages unless a longer interval can be justified. These intervals will be set following a review of the safety importance of the MOV and its maintenance and l
performance history. The surveillance will also be performed following maintenance or adjustment that could affect the surveillance results.
k.
This item does not apply to VCSNS.
1.
I 1-m.-Reporting Requirements.
1 This letter satisfies the initial reporting requirement specified by Generic Letter 89-10. VCSNS intends to comply with the requirements of the letter and will notify the NRC within 30 days of the completion of actions addressed in the first paragraph of item 1.
05cument: Control Desk Letter i Beo3mber 22, 1989.
.. Page 4 of 4 N'
- Should you. have any questions, please call at your convenience.
t Very truly yours, O. S. Bradham CJM/OSB: led
~ Attachment-c:
D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols,.Jr.
E. C. Roberts W. A. Williams, Jr.
S. D. Ebneter J. J. Hayes, Jr.
General Managers C. A. Price R. B. Clary K. E. Nodland-
.J. C. Snelson R. L. Prevatte J. B. Knotts, Jr.
-NSRC NPCF RTS (LTR890010)
File (815.14) o
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