IR 05000272/1996011
| ML18102A463 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/03/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18102A460 | List: |
| References | |
| 50-272-96-11, 50-311-96-11, GL-89-10, NUDOCS 9610160173 | |
| Download: ML18102A463 (19) | |
Text
September 6, 1996
SUBJECT:
SALEM MOV INSPECTIQ.tf NQ~.:.i§Q,-"27,2/96*11; 50-311/96-11 AND NOTICE OF VIOLATION*.
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Dear Mr. Eliason:
1-10.624
[;J02 This letter transmits the report of an inspection of the Salem motor-operated valve (MOV)
program conducted by Mr. L. Prividy at the Salem Nuclear Generating Station from July 22-26, 1996, and September 6, 1996. The inspectors focused on areas important to public health and safety, performing an independent evaluation of MOV program procedures, calculations, and test results associated*wi~h.:~NRe ($'.~~~lie Letter (GL) 89-1 O, "Safety-related Motor-Operated Valve Testing and Su~illatite.t;~~Tlie.preliminary findings were initially discussed on July 26, 1996 and later discussed with Mr. G. Overbeck and other members of your staff by telephone on September 6, 1996.
-M-The NRC ~ncluded that its review of the Salem GL 89-10 MOV program coul not be closed because tr1a des;gn-basis capabiiity of all safety-related MOVs has not been erified as requested in GL 89-10. Past test results had not been thoroughly evaluate to assure the verification of MOV program assumption.s*such as, a* 0 *. 1"5 stem friction co rcient and a 30% ~
thrust margin to account for various unc~rtainties:: No ~pacific margin wa established for load sensitive behavior. In addition to th~se obs~_iyatio'hs, several MOV rogram test
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procedure deficiencies were identified which invalidated the
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iof"-.6°mor11tratin9 tl=\\e de~igo...&asis eapmbi* ;t ll:<Me'tis. Also, the torque switch sett gs CJ for two risk significant MOVs were not correctly set to assure that they would close un er
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design-basis conditions. These issues constitute violations of NRC requirements, as ited in
\\:J the enclosed Notice of Violation (Notice) and are of concern because they call into estion fundamental elements of the MOV programs at both Salem Units which your letter of March 20, 1995, and June 25, 1996, stated were complete. Further, an independent re 1e a year ago reached similar conclusions, but these we7 re not acted upon, calling into q stio program oversight and ownership.
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""" 509 339 5250 H0.624 GJ03 Mr. Leon Your efforts taken to dynamically test"50% of th OVs was a noted strengt~and we no-fe.
J;mee::ctal&d that you are performing
<:!ynamic tests to confirm earlier results and to '><.
improve thrust margins in support of ~program closure. In this regard, we also understand that you have initiated comprehensive corrective actionffto enable com letion of a revised MOV program closure report for both Salem Units restart of Unit. f our uriaerstanding in these matters is incorrect, please advise us accordingly in t e
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response letter requested below. J _. IJ dt~.f ~
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You are required to respond toVthis letter.and sh'ould follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements. ~),,.~.~/ic~ ~ -~
You are also requested to ')'iiiond to ~[lin po days to explain when the Salem MOV program will be full~~l!emented**and Complete [~including additional MOV testing,
/JJJ revised calculations, and ~attlatiellt9-Ml!SBiaily for the non-tested valve populatio~ a.Ad-t:.4:/~a-.:L..
when the Salem MOV program will be ready for an NRC closure inspection.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. The responses directed by. this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
Your cooperation with us is appreciated.
Docket Nos.
50-272, 50-311 Enclosures:
Sincerely,
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- .:--" EugencfM. Kelly, Chief Systems Engineering Branch Division of Reactor Safety 2. NRC Inspection Report Nos. 50-272/96-11; 50-311/96-11
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.... 609 339 5250 Mr. Leon cc w/encl:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
D. Garchow, General Manager - Salem Operations J. Benjamin, Director - Quality Assurance & Nuclear Safety Review D. Powell, Manager, Licensing and Regulation R. Kankus, Joint Owner Affairs A. Tapert, Program Administrator R. Fryling, Jr., Esquire M. Wetterhahn, Esquire P. MacFar1and Goelz, Manager, Joint Generation..
Atlantic Electric Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland State of New Jersey State of Delaware
~ID. 624
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- 09/06/96 12:53 DRS DI lJ.... 61219 339 525121 M0.624 NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Docket Nos: 50-272 50-311 License Nos: DPR-70 DPR-75 Units 1 and 2 During an NRC inspection conducted on from July 22-26, 1996, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
A.
1 O CFR 50, Appendix B, Criterion XI, requires, in part, that measures shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily In service is identified in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test procedures shall include provisions for assuring that adequate test Instrumentation is used. Test results shall be evaluated to assure that test requirements have been satisfied.
Contrary to the above, as of July 21, 1996, the Salem MOV test program did not assure that:
1.
the dynamic test results of the MOVs in Families 3 and 9.1 were correctly evaluated to assure that the requirements pertaining to the valve factors assumed in the Salem MOV program for the non-dynamically tested valves in these families were valid. As a result, the assumed valve factors for the non-dynamically tested MOVs in Families 3 and 9.1 had to be reevaluated.
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the dynamic test results of the charging header stop valves (1 and 2 CV 68 and 69) were adequately evaluated to assure that the requirements pertaining to the valve factors assumed In the Salem MOV program for these valves were valid. Further evaluation of the very low valve factors calculated from the test data evidenced an error in the upstream pressure measurement and, as a result, the dynamic test procedures had to be corrected and new dynamic tests had to be performed for these MOVs.
3.
adequate-test instrumentation was used when performing the dynamic testing of 1 and 2 CV 68 and 69 to assure that the test requirements pertaining to differential pressure measurement as specified in the Salem MOV program had been satisfied. As a result, this improper te.st instrumentation contributed to incorrect valve factor determinations for these valves.
This is a Severity Level IV violation (Supplement I).
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""" 609 339 5250
~lO. 624 Notice of Violation
B.
10 CFR 50, Appendix B, Criterion Ill, requires, in part, that measures shall be established to assure that the design-basis as defined in 10 CFR 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, as of July 21, 1996, design control measures were not properly established to assure that the RCS hot*leg to RHR suction header MOVs (1 and 2 RH1} would close under their design.basis conditions as specified in PSE&G procedure NC.DE-PS.ZZ-0033(Q)-A4, "MOV Program Operating Condition Evaluation." Specifically, PSE&G made Incorrect assumptions in the mechanical design calculations that resulted In low torque switch settings for these MOVs, creating the possibility that they might not close under design-basis conditions.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to-the NRC Resident Inspector at the facility that is the subject of this Notice, within 30. days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearty marked as a "Reply to a Notice of Violation" and should include for each viofatlon: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be QiV'.en to extending the response time.
- Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the POR without redaction. However, if you find it necessary to include such infonnation, you should clearly indicate the specific information that you desire not to be placed in the PCR, and provide the legal basis to support your request for withholding the information from the public.
Dated at King of Prussia, Pennsylvania this 6th day of September 1996.
Gl06
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12:54 DRS DIU.
~ 509 339 5250 t-10.524 EXECUTIVE SUMMARY Salem Generating Station Units *1 and 2 MOV Inspection Nos. 96-11 Despite dynamic testing of more than 50% of the motor operated valves at Salem, (MOVs),
Public Service Electric and Gas (PSE&G) was unable to adequately demonstrate that it had verified design-basis capability of all the safety-related valves in the Salem GL 89-10 MOV program. The MOV program at Salem Units 1 and 2, being implemented in accordance with Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance,"
included 190 MOVs which were grouped into 16 families. Several MOV program testing deficiencies were identified as a test control violation (VIO 2721311/96-11--01).
The valve factor results from four dynamic tests of the charging header stop valves, which were to be applied to 12 MOVs in Family 9.1, were shown to be invalid due to test procedure and test method problems. Family 3, which contained 22 MOVs, included only two dynamic tests. Past test results had not been thoroughly evaluated to assure the verification of MOV program assumptions such as, a 30% margin to account for various uncertainties and a 0.15 stem coefficient of friction. No specific margin was established for load sensitive behavior.
Many of these findings were similar to the conclusions from an independent assessment of Salem's MOV program conducted in August 1995. However, PSE&G had not established firm management controls for providing action plans to address the independent team's findings.
Beyond the above noted inadequacies which prevent Salem MOV program closure, the failure to take appropriate design control measures to assure that the reactor coolant system hot leg to residual heat removal suction header MOVs would close under design-basis conditions was identified as a design control violation (VIO 272/311/98-11-05). PSE&G made incorrect assumptions in the mechanical design calculations that resulted in low torque switch settings for these risk significant, pressure isolation valves, creating the possibility that they might not close under postulated accident conditions. Another recently identified problem, preventing Salem MOV program closure,.Involved past plant changes that had been implemented without appropriate consideration given to their impact on the MOV design-basis setpoint documents. Resolution of this isisue will be needed to assure there are proper switch settings for MOV program completion.
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