"Consideration of Valve Mispoitioning in Boiling Water Reactors" (Generic Letter 89-10, Supplement 4)

February 12, 1992



TO:       ALL LICENSEES OF OPERATING NUCLEAR POWER PLANTS AND 
          HOLDERS OF CONSTRUCTION PERMITS FOR NUCLEAR POWER 
          PLANTS

SUBJECT:  GENERIC LETTER 89-10, SUPPLEMENT 4,
          "CONSIDERATION OF VALVE MISPOSITIONING IN BOILING
          WATER REACTORS"

In Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve (MOV) 
Testing and Surveillance," the staff recommended, among other things, that 
any MOV in a safety-related system that is not blocked from inadvertent 
operation from either the control room, the motor control center, or the 
valve itself be considered capable of being mispositioned (referred to as 
position-changeable MOVs) and be included in licensees' MOV programs.  When 
determining the maximum differential pressure or flow for position- 
changeable MOVs, the licensee should consider the fact that the MOV must be 
able to recover from mispositioning.  Supplement 1 to GL 89-10 limited the 
prevention of inadvertent MOV operation within the context of the generic 
letter to the potential for MOV mispositioning from the control room.

The Boiling Water Reactors Owners' Group (BWROG) submitted a backfit appeal 
on the recommendations for position-changeable valves.  The staff, with the 
assistance of Brookhaven National Laboratory (BNL), has reviewed and 
evaluated the issues concerning mispositioning of valves from the control 
room and has determined that the recommendations in GL 89-10 should be 
changed for boiling water reactors (BWRs).  The BNL study, which used 
probabilistic risk assessment techniques, and the staff's evaluation were 
included in a letter from NRC to the BWROG dated this same date.  

The staff no longer considers the recommendations for inadvertent operation 
of MOVs from the control room to be within the scope of GL 89-10 for BWRs.  
However, the staff believes that consideration of valve mispositioning 
benefits safety.

Modifying the provisions in GL 89-10 for valve mispositioning does not 
affect the GL 89-10 provisions for licensees to review safety analyses, 
emergency procedures, and other plant documentation to



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determine the design basis(1) fluid conditions under which all MOVs in 
safety-related piping systems may intentionally be called upon to function.  
This position also does not supersede the NRC's generic recommendations or 
regulations on valve mispositioning that pertain to other issues such as 
intersystem loss-of-coolant accidents (ISLOCA) or fire protection (10 CFR 
50, Appendix R).

This modification to the recommendations addresses only BWR plants.  The NRC 
will perform a similar review for pressurized water reactors (PWR).  The NRC 
staff will review results of the PWR study and may revise GL 89-10, if 
warranted, appropriately to clarify the NRC's position regarding 
consideration of valve mispositioning within the scope of GL 89-10 for PWRs.  
The BWROG may complete the design basis reviews consistent with the position 
herein.

This generic letter contains no information collection requirements and 
therefore is not subject to the requirements of the Paperwork Reduction Act 
of 1980 (44 U.S.C. 3501 et seq.).


                         James G. Partlow
                         Associate Director for Projects
                         Office of Nuclear Reactor Regulation


     1 Design basis conditions are those conditions during both normal 
operation and abnormal events that are within the design basis of the plant.