ML18100A658
| ML18100A658 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 10/08/1993 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9310190102 | |
| Download: ML18100A658 (6) | |
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I Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations NLR-N93156 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO GENERIC LETTER 89-10 SUPPLEMENT 5 INACCURACY OF MOTOR-OPERATED VALVE DIAGNOSTIC EQUIPMENT FACILITY OPERATING LICENSES DPR..:.70, DPR-75, AND NPF-57 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311, AND 50-354 This letter submits PSE&G's response to Generic Letter 89-10, Supplement 5, "Inaccuracy of Motor-Operated Valve Diagnostic Equipment," for the Salem and Hope Creek Generating Stations and is being filed in accordance with 10CFR50.4.
PSE&G's response to each of the NRC's reporting requirements contained in the generic letter supplement is provided in the attachment to this letter.
Should you have any questions or comments on this submittal, please do not hesitate to contact us.
Affidavit Attachment 190022 9310190102* 931ooa-. --u.r1 PDR ADDCK 05000272
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Qocument Control Desk NLR-N93156 2
c Mr. T. T. Martin, Administrator - Region I
- u. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. S. Dembek, Licensing Project Manager U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 OCT 0 8 1993
REF: NLR-N93156 STATE OF NEW JERSEY SS.
COUNTY OF SALEM J. J. Hagan, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem and Hope Creek Generating Stations, are true to the best of my knowledge, information and belief.
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Subscribed. and sworn to before me
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- - Notary_ Ih;tblic of New Jersey My Commission expires on UNDA n. VREELAND Notary Public of New Jersey My Gommission Expires Feb. 15, 1994
' 1993
RESRKSE 'IO GENERIC IEl'rER 89-10 SUPPllMENI' 5 INACXIJRACT OF HIDJR-OPERATED VALVE DIAGNQSTIC ~
- mcILITY OPERATING LICENSES DIR-70, DIR-75, AND NPF-57 SAllM AND IDPE rnEEK GENERATING smTIClNS IDCKEl' RE. 50-272, 50-311, AND 50-354 I.
INmOilJCI'ION NIR-N93156 This attachment provides PSE&G's response to Generic Letter 89-10, SUpplement 5, "Inaccuracy of Motor-operated Valve Diagnostic Equipment" for the Salem and Hope Creek Generating stations.
OUr response to each of the NRC' s reporting requirements is provided below.
NRC Reporting Requirement # 1 Within 90 days of receipt of this letter, all licensees are required to notify the NRC staff of the diagnostic equipment used to conf inn the proper size, or to establish settings, for MOVs within the scope of GL 89-10.
PSE&G Response # 1 PSE&G is employing the Liberty Technologies VOl'FS diagnostic equipment to aid in confinning proper motor operator sizes and switch settings for all MOVs within the scope of GL 89-10.
The current version of the VOIBS software being employed is 2. 31.
Previous versions of the VOIBS software have been used and the inaccuracy issues described by supplement 5 have been considered and are documented in PSE&G Engineering Evaluation A-O-ZZ-MEE-0849.
Valve settings prior to linplementation of the GL 89-10 program were all based on use of MOVATS diagnostic equipment.
Engineering Evaluation H-1-ZZ-MEE-0750 for Hope Creek and Engineering Evaluation S-C-ZZ-MEE-0751 for both units at Salem were perfonned to address concerns for those valves which had not yet been tested under the PSE&G MOV Program using Liberty Technologies VOIBS diagnostic equipment at the time of the evaluation.
NRC Reporting Requirement # 2 Within 90 days of receipt of this letter, licensees are required to report 'Whether they have taken actions or plan to take actions (including schedule and summary of actions taken or planned) to address the information on the accuracy of MOV diagnostic equipment.
PSE&G Response # 2 We have perfonned reviews of the infonnation discussed in GL 89-10 SUpplement 5. The applicability to the Salem and Hope Creek Generating stations is limited to diagnostic equipment represented by ITI-MOVATS and by Liberty Technologies.
Page 1 of 3
- Attachment Response to Generic Letter 89-10 Supplement 5 NLR-N93156
'!he ITI-MOVATS infonnation was reviewed relative to the as-left conditions for the applicable MOVs and documented in Engineering Evaluation H-1-ZZ-MEE-0750 for Hope Creek and Engineering Evaluation s-c-zz-MEE-0751 for both units at Salem.
Applicable MOVs are those which had not yet been tested under the PSE&G MDV Program using Liberty Technologies VOI'ES diagnostic equipment at the time of the evaluation.
For those valves evaluated against the ITI-MOVATS inaccuracy concerns having an estimated error band that extended beyond the GL 89-10 test window, evaluations were perfo:nned using the MOVATS ER 5. 2 methodology to address the use-as-is acceptability. If the results of these evaluations were unacceptable, either the existing settings were further evaluated and detennined not to be a concern or work orders were generated to retest the valves using the VOI'FS diagnostic equipment to establish the appropriate settings.
Disassembly and inspection of MOV components may be included for some MOVs.
All actions required to address the ITI-MOVATS inaccuracy concern are anticipated to be complete during the current Salem Unit 1 refueling outage (currently scheduled to end in December 1993) with the exception of actuator refurbishment and VOI'ES testing of the 2CV140 valve at Salem Unit 2; actions for this valve will be completed during the Unit 2 eighth refueling outage which is scheduled for the Fall of 1994.
'!he operator settings for 2CV140, including the MOVATS diagnostic error, currently exceed the nominal operator rating but are within the Limitorque Corporation guidance for acceptable loadings.
'!his is considered satisfactocy justification for deferral of the actuator refurbishment and diagnostic testing to the Unit 2 eighth refueling outage.
Interim acceptability for all other applicable valves is justified based upon the referenced engineering evaluations.
Due to the scope and complexity of major projects being implemented during the current Unit 1 outage, the current MOV test schedule may be impacted. If we cannot complete all actions required to address the ITI-MOVATS inaccuracy concern (with the exception of the 2CV140 valve) prior to the end of the current Unit 1 outage, we will update our evaluations to justify interim operation until the next Unit 1 outage.
'!he Liberty Technologies infonnation was reviewed relative to all test procedures and all applicable tests conducted to date and our review is documented in Engineering Evaluation A-O-ZZ-MEE-0849 for both stations.
'!his document is undergoing final review and approval with an expected completion date of October 29, 1993. All data for MOVs tested with VOI'ES software versions preceding 2. 3 has been evaluated for proper application of torque correction factor and effective diameter, as applicable, and for proper material constant input.
For Hope Creek, there is only minimal impact due to timely incorporation of corrections during the fourth refueling outage. '!here is some impact for Salem as a result of the higher analyzed loadings.
A variety of actions have been initiated and tracking processes have been implemented to resolve the potential discrepancies identified. 'Ihese include evaluations for overthrust of the valve andjor operator, generation of work orders for disassembly and inspection/repair, and retest. It is anticipated that all required in-plant actions will be completed during the current Salem Unit 1 outage.
Interim acceptability is justified based upon the referenced engineering evaluation.
As noted above, if we cannot complete all actions required to address the Liberty Technologies inaccuracy concern prior to the end of the current Unit 1 outage, we will update our evaluations to justify interim operation until the next Unit 1 outage.
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.. ' A:ttachment
- Response to Generic Letter 89-10 Supplement 5 NLR-N93156 Progranunatic documentation revisions affecting differential pressure test analyses, MOV capability assessments, and further refinement of weak link analyses are anticipated to be cbn"pleted prior to April 1994.
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