ML18094A749

Forwards Response to Generic Ltr 89-04 & Rev 2 to Inservice Testing Program for Pumps & Valves for 2nd 10-yr Insp Interval.

ML18094A749
Person / Time
Site:	Salem
Issue date:	10/03/1989
From:	Crimmins T Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18094A750	List: ML18094A749 ML18094A753
References
GL-89-04, GL-89-4, NLR-N89196, NUDOCS 8910130089
Download: ML18094A749 (5)

Text

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,. J ' l Public Service Electric and Gas Company Thomas 1)11. Crimmins, Jr. Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4700 Vice President - Nuclear Engineering OCT O 3 1989 NLR-N89196 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

CONFIRMATORY LETTER NRC GENERIC LETTER NO. 89-04 SALEM GENERATING STATION - UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) hereby details Salem Generating Station's level of conformance with Generic Letter 89-04, "Guidance On Developing Acceptable Inservice Testing Programs". Attachment 1 provides our item-by-item response to each position in the Generic Letter.

Additionally, our revised Inservice Testing (!ST) Program, incorporating guidance provided in the Generic Letter, and a summary of program changes, are provided in Attachment 2.

Should you have any questions with regard to this submittal, we will be pleased to discuss them with you.

Enclosure C Mr. J. C. Stone USNRC Licensing Project Manager Mrs. K. Halvey Gibson USNRC Senior Resident Inspector Mr. W. T. Russell, Administrator USNRC Region I Mr. K. Tosch, Chief (w/o attachment 2)

New Jersey Department of Environmental Protection

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REF: NLR-N89196 STATE OF NEW JERSEY SS.

COUNTY OF SALEM Thomas M. Crimmins, being duly sworn according to law deposes and says:

I am Vice President - Nuclear Engineering of Public Servi~e Electric and Gas Company, and as such, I find the matters set forth in our letter dated October 3, 1989, concerning the Salem Generating Station, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this~ day of {Pe,~~ I 1989

, Lfl4LiLttD'tk ~VI Notary Public of New Jersey VANITA M. MARSHALL NOTARY PUBLIC OF NEW JERSEY My Commissiirn Explrns May 6, 1993 My Commission expires on

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RESPONSE TO GENERIC LETTER 89-04 ATTACHMENT 1 A detailed review of all applicable systems in the Inservice Testing (IST)

Program, for Salem Generating Station Unit Nos. 1 and 2, was conducted to verify compliance with the guidance contained in NRC Generic Letter 89-04. The areas which were examined are as follows:

1) Identification of all components which fall under the scope of the Generic Letter, as well as ASME Section XI, Subsections IWP and IWV,

2) Verification of proper testing requirements for all components, including approved alt~rnate testing methods where applicable,

3) Review of testing procedures to ensure measurement of required parameters as well as employment of consistent testing method, and

4) Preparation of relief requests for those components that cannot be tested to the requirements of the Generic Letter or ASME Section XI.

Below is a synopsis of how each stated position in the Generic Letter is addressed by our program. It should be noted that Position 7 was not addressed due to its applicability to BWR's only.

Position 1 and 2 - CHECK VALVE FLOW TESTING These two positions are treated together since they deal with the same subject.

When compliance with Position 1 is not achievable, Position 2 provides an alternate testing method. Full flow exercise testing on check valves is performed every three (3) months when system operating conditions permit; however, most of the check valves are full flow tested only during Cold Shutdown conditions with partial flow testing conducted on the three month frequency.

There are some check valves (e.g. ECCS Accumulator discharge, Service Water return to the Delaware River, etc.) which cannot be full flow tested under any plant condition. For these valves, a periodic disassembly program has been established which conforms to the guidance provided by Item 2.

Position 3 - CHECK VALVE BACKFLOW TESTING Backflow testing for all applicable check valves is performed within the guidelines specified in the Generic Letter. Backflow verification is performed using several different methods including pressure indications, leak testing, and visual observation (e.g. position indicators, inspection ports, radiography, etc.).

r Position 4 - PRESSURE ISOLATION VALVE TESTING 2 The pressure isolation valves (PIV's) at Salem Generating Station units are identified in each plant's Technical Specifications (TS) along with their maximum allowable leakage. The IST Program was reviewed to ensure that all of these valves, and their associated allowable leakage values, are included in its scope. Additionally, the test procedures for these valves were reviewed to assure that the valves were being individually tested as required.

Position 5 - LIMITING VALUES OF FULL-STROKE TIMES FOR POWER OPERATED VALVES The Code intent, with respect to measuring the full-stroke times of power operated valves is to detect valve degradation. PSE&G's Salem Generating Station presently complies fully with ASME Section XI, subsection IWV, regarding limiting stroke time values for power operated valves and required corrective actions. Presently, if the stroke time increases by the code specified amount from the previous stroke time, the test frequency is increased to once per month (if the testing in that operating mode is possible) until corrective action can be taken. At Salem Station, the 4.0.5(V) - Maintenance Procedure controls the monthly testing requirements and issuance of work requests for corrective actions.

Because, as the Generic Letter states, The code does not provide any requirements or guidelines for establishing these limits nor does it identify the relationship that should exist between these limits and any limits identified for the relevant valves in the plant TS or safety analysis", we have reviewed the licensing and/or design bases for each power operated valve in our program and taken the following position:

1) All valves have been reviewed and provided with a "design basis or licensing value" for declaring valve operability (sources are Technical Specifications, UFSAR, Manufacturer, NSSS Vendor, etc.).

2) The standard code requirements of IWV-3413(a) and IWV-3417(b) will continue to be followed by comparing previous valve stroke times with present stroke time and taking the appropriate actions.

3) PSE&G continues to follow industry efforts and is presently reviewing our 4.0.5 (V) Programs for changes that will enhance our trending capabilities for power operated valves.

In summary, for each power operated valve in our program, a "design value" for determining operability has been established and if that value is exceeded that valve or its associated system will be declared inoperable in accordance with the Technical Specifications. Any procedural revisions brought about by design value changes or by the addition/deletion of any valves will be incorporated by December 31, 1989 (which corresponds to the current test frequency).

Based upon their review of our current 4.0.5 (V) Program techniques, an IST task team (comprised of a Central Preventative Maintenance Group and Technical Department personnel from each station) will detail improvements in IST testing, trending and tracking by March 31, 1990. These improvements will be implemented in accordance with existing Reliability Centered Maintenance methodology.

Position 6 - LIMITING STROKE TIMES FOR RAPID-ACTING VALVES 3 Valves with Technical Specification stroke times less than or equal to 10 seconds will conform to our program for the valves encompassed by Position 5 above. The design value for each valve is listed in the !ST Program.

For valves with a stroke time of 2 seconds or less, the alternate method of specifying 2 seconds as the limiting value (and not applying the Code's 50%

increase in stroke time criteria) as provided by the Generic Letter, will be applied. This deviation will be listed in our !ST Program for each applicable valve.

Position 8 - TECHNICAL SPECIFICATIONS ACTION STATEMENT START TIMES Salem Station is presently in compliance with the Generic Letter Position 8 requirements regarding 4.0.5 (P) performance and operability. The Operations Department is provided with baseline and code pump performance values for determining pump operability. If pump test results are in the "required action range", the shift operators immediately declare the pump inoperable and enter the appropriate ACTION statement.

With regard to valve operability, the operators also have "design values" for determining valve operability and entering ACTION statements.

Position 9 - PUMP TESTING USING MINI-FLOW RETURN LINES All pump testing at Salem Station utilizing mini-flow return lines is conducted through instrumented flow lines. All of the affected pumps also receive a full flow test when plant conditions permit. This is an acceptable deviation, per the Generic Letter, and will be listed as such in the IST Manual. There are some Emergency Diesel Generator engine-shaft-mounted positive displacement pumps for which testing per Section XI, IWP is not feasible. For these pumps, relief requests have been prepared that detail how they will be tested.

Position 10 - CONTAINMENT ISOLATION VALVE TESTING All of the containment isolation valves from the Appendix J Program are listed in the IST Program as Category A or A/C valves. The IST Program specifies them as valves that are leak tested per Appendix J, which satisfies the requirements of IWV-3421 through IWV 3425. As indicated in the Generic Letter, this is an acceptable test method. For containment isolation valves six inches or larger, the acceptable deviation from IWV-3427(b), as delineated in the Generic Letter, has been listed in our IST Program.

Position 11 - IST PROGRAM SCOPE Our complete review of the existing IST Program, which addressed specific items contained in this section of the Generic Letter, resulted in the addition of some new valves to our program which had been previously overlooked.

A listing of all changes incorporated as a result of our review is contained in ... along with a resubmittal of the entire IST Program with those changes in place.