ML18100A662
| ML18100A662 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/12/1993 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, NLR-N93166, NUDOCS 9310210213 | |
| Download: ML18100A662 (17) | |
Text
- >*a.,
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 OCT 1 2 1993 NLR-N93166 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
INSERVICE TESTING PROGRAM SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated October 9, 1992, the NRC provided the Safety Evaluation of the Inservice Testing Program Relief Requests for Pumps and Valves, Salem Nuclear Generating Station, Units 1 and 2.
Public Service Electric & Gas Company (PSE&G) hereby submits the supplemental information requested in response to the anomalies identified in the Technical Evaluation Report which was an Enclosure to the Safety Evaluation.
By letter dated March 30, 1987, (ref: NLR-N87052) PSE&G submitted the Inservice Testing Program for the second ten year intervals for Salem Unit Nos. 1 and 2.
At this time, PSE&G requested that Salem Unit Nos. 1 and 2 be placed on the same inspection interval schedule.
Unit 2 had not reached the end of its first ten year interval and was being updated early.
PSE&G did not realize that it was necessary to resubmit this request as part of its Generic Letter 89-04 submittal, dated October 3, 1989 (Ref: NLR-N89196). of this letter contains a brief description of each anomaly and PSE&G's response to the anomaly.
contains the selection criteria for components in the IST Program.
Should there be any questions with regard to this submittal, please do not hesitate to contact us *
. 9310210213 931012-~-
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Document Control Desk NLR-N93166 c
Mr. J. c. Stone Licensing Project Manager Mr. c. Marschall Senior Resident Inspector 2
Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Manager IV OCT 1 2 1993 New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
NLR-N93166 ATTACHMENT 1 PSE&G'S RESPONSE TO ANOMALIES IDENTIFIED IN TECHNICAL EVALUATION REPORT The following items contain a brief description of the anomalies identified in the Technical Evaluation Report and PSE&G's response to each anomaly.
Anomaly 1 Relief requests for Auxiliary Feedwater Pumps and Boric Acid Transfer Pumps may be withdrawn if new instrumentation has been installed.
Response
New flow instrumentation has been installed, no relief is necessary.
This relief request is withdrawn.
Anomaly 2 Chilled Water Pumps -
Develop and provide information to show the requested relief adequately addresses pump operational readiness or provide a reasonable alternative to the Code.
Response
The installed flow measurement instrumentation is calibrated to an inaccuracy of 3% which is the design limit of these Fischer-Porter Rotometers.
The ASME Code requirement is 2%
inaccuracy and a range of no greater than three times expected flow.
PSE&G's* instrumentation inaccuracy exceeds the Code by 50%.
However, the range of these instruments is 0-400 GPM, while the code allowed range would be 0-1110 GPM.
Since our expected full scale range used for testing is approximately 36% of that allowed by the Code, the combination of the full scale range and accuracy of the installed instrumentation is equal to or more conservative than the Code requires.
In addition, the test flow rate specified in the test procedure is the :rumm. design flow.
This flow is 18% greater than the system design flow requirements.
Assuming the inaccuracy from the flow meter would result in the excess flow margin being approximately 17%.
The reduction in flow margin will not impact the ability of the pumps to perform the required safety function.
The station calibration program is utilized to maintain instrument accuracy in accordance with the requirements of paragraph IWP-4140.
NLR-N93166 Anomaly 3 2
Service Water Pumps (Unit 2 only} -
Pursue the installation of adequate flow instrumentation or other means of testing or provide additional information to support current relief request.
Response
A new test loop has been installed.
The instrumentation associated with this loop exceeds the accuracy requirements of the Code.
This relief request is withdrawn.
Anomaly 4 Test supervisors must meet the qualification requirements of ASME PTC 25.3 Section 4.09.
Response
The Salem Maintenance Department has incorporated the requirements of Section 3.02 of PTC 25.3 -
1976 September 1977 Addendum into the qualification requirements for test supervisors of relief valve testing.
Anomaly 5 SJ44 Containment Sump Suction Valves - Relief should be granted to observe remote position indication on an every other refueling basis provided this test is performed whenever manways for Containment Sump are removed.
Response
The remote position verification has been added as a requirement whenever the manways are opened.
There is no feasible alternate indirect method of verifying valve position.
These are Containment Sump RHR Suction valves and any alternative test to verify remote position indication would require flooding the Containment Sump.
NLR-N93166 Anomaly 6 3
SJ55 Accumulator Discharge Check Valves - Investigate burping accumulators to part-stroke exercise these valves in cold shutdown.
Response
The SJ55 valves, Accumulator discharge check valves cannot be part-stroke exercised during cold shutdown.
To provide flow through the check valve, the upstream Accumulator Outlet valve SJ54 must be opened.
The SJ54s are motor operated valves that are required to complete full stroke before they can change direction.
Full stroke of the SJ54 could cause a complete discharge of the water volume in the accumulator and possibly injection of nitrogen into the reactor coolant system.
This could lead to gas binding the RHR Pumps and a subsequent loss of shutdown cooling.
Salem experienced a similar event as documented in Salem Unit 1 LER 89-019.
Anomaly 7 PR25 ECCS Discharge Relief Check Valves - Relief approved provided post-maintenance testing performed on check valves.
Response
A part-stroke test has been specified as a required post-maintenance retest after the periodic disassembly and inspection.
Anomaly 8 Reactor Head Vents -
Provide an alternate method to perform Remote Position Verification and perform exercising during cold shutdowns.
Response
Reactor Head Vents are tested on a cold shutdown frequency.
Acoustic monitoring is used to satisfy the requirement for stroke time and remote position indication of the valves.
This method is currently being used at Hope Creek Nuclear Generating Station.
NLR-N93166 Anomaly 9 4
SJ3 Charging Pump Suction Valves from RWST -
Develop and implement test to be performed during cold shutdown or provide additional justification to test on refueling cycle basis.
Response
These valves will be tested as requested on a cold shutdown frequency.
This relief request is withdrawn.
Anomaly 10 Service Water Supply to Turbine Generator Check Valves -
Relief approved provided disassembly and inspection in accordance with GL 89-04 including post-maintenance testing is performed on check valves.
Response
Disassemby and inspection will be performed in accordance with GL 89-04.
Post-maintenance testing requirements have been identified in the appropriate Maintenance Department procedure.
Anomaly 11 Service Water Supply to the Nuclear Header Check Valves -
Relief approved provided disassembly and inspection in accordance with GL 89-04 including post-maintenance testing is performed on check valves.
Response
Disassemby and inspection will be performed in accordance with GL 89-04.
Post-maintenance testing requirements have been identified in the appropriate Maintenance Department procedure.
Anomaly 12 In future IST submittals, provide a unique identifier for relief requests.
Response
Future IST submittals will contain unique identifiers for relief requests.
Current relief requests are identified by component numbers.
It would not be practical to provide an alternate unique identifier until the next ten-year update.
NLR-N93166 5
Anomaly 13 ECCS Injection Check Valves -
Function paragraph of relief request only addresses open function.
Valves must be tested in both directions.
Response
The closed direction test is performed every cold shutdown and leakrate tested every two years for all valves identified except 1(2)SJ70.
Relief is being requested for the full stroke open and closed test of 1(2)SJ70.
The SJ70 valves will be tested on a refueling cycle frequency.
The basis for relief from cold shutdown testing is as follows:
Anomaly 14 Valve can only be full stroke exercised during cavity fill in support of refueling activities.
Except when injecting RHR into the reactor, RHR pumps are tested on recirculation flow of 500 GPM from discharge to suction of the pump.
Flow through SJ70 would be minimal.
It would not be possible to exercise test the valve under these conditions.
During cold shutdown, RHR Pump suction is normally from the RCS Hot Leg and the isolation valve from the Refueling Water Storage Tank is closed.
There would not be sufficient pressure differential across the check valve to ensure full closure.
Change title of relief requests that identify cold shutdown as an alternative to quarterly testing.
Cold shutdown testing is approved by the Code and relief is not necessary.
Response
PSE&G will not seek relief in future submittals for cold shutdown testing.
The justifications for cold shutdown testing will be included in the IST Program.
Anomaly 15 For valves that cannot be tested at power, evaluate all requests to ensure adequate bases has been provided to justify testing of valves at a frequency other than cold shutdown or test valves on a cold shutdown frequency.
NLR-N93166
Response
6 All valves that cannot be tested at power are either being tested on a Cold Shutdown frequency or justification has been provided to test at an alternate frequency.
Anomaly 16 Diesel Generator.Fuel Oil Engine Driven Booster Pumps -
The Unit 2 relief request appeared to be missing information.
It was assumed to be the same as Unit l's request.
Revise the Unit 2 relief request at a future program update.
Response
The Unit 2 relief request was missing information as assumed and was int~nded to be the same as Unit 1.
The text will be corrected in the next submittal.
Anomaly 17 The program should include a discussion of the development process such as a listing of documents used, method of component selection, basis for testing required, basis for categorizing valves, and method used to maintain the program current.
Response
The selection criteria process is contained as Attachment 2 to this letter.
This criteria is contained in the IST Manual, but was not included in previous submittals to the NRC.
The Inservice Testing Program is controlled by Administrative Procedure NC.NA-AP.ZZ-0070(Q).
One of the responsibilities of the IST Engineer in this procedure is to review design changes for effect on the IST Program.
The IST Engineer is listed as speciality review in the Design Change Process Administrative Procedure NC.NA-AP.ZZ-OOOS(Q).
Anomaly 18 VC2 and VC3 Containment Purge Isolation Valves -
The proposed frequency for testing valves is unclear and inconsistent between the units.
Response
Valves will be tested in Cold Shutdown; relief request is withdrawn.
NLR-N93166 Anomaly 19 7
VCl and VC4 Containment Purge Isolation Valves -
The proposed frequency for testing valves is unclear.
If valves are to be tested at an interval of greater than every cold shutdown or at cold shutdown when certain conditions are met, provide a relief request with a basis for the extended interval and the alternate testing frequency.
Response
Valves will be tested in Cold Shutdown; relief request is withdrawn.
ATTACHMENT.2 SELECTION/DESIGN CONSIDERATION CRITERIA
0 "ASH Yiaa.t.Iao ROI.t.YaaaISROO RDisaa I ROI.t.oa~as it.SI u. 'IYA an cIHOa A ROI.t.oas
V. PUMP AND VALVE IST SELECTION/DESIGN CONSIDERATION CRITERIA A.
PUMPS
- 1.
PUMP IST SELECTION CRITERIA These instruction are intended to be used when evaluating pumps for inclusion in (or exemption from) the IST Program and for design considerations when adding new pumps to the plant.
Pumps which should be evaluated by the use of these instructions include all ASME Code Class 1, 2 and 3 pumps, as well as any other pumps which are in systems or portions of systems which ma¥ be relied upon to perform a safety function, as defined below.
- a.
SAFETY FUNCTION For the purposes of the IST Program, a pump is considered to have a safety function if it must perform a specific function in shutting down the reactor, in maintaining the reactor in the safe shutdown condition, or in mitigating the consequences of an accident.
When determin*ing if a pump has a safety related function, all possible functions of the pump and the f lowpath in which it is located must be considered.
- 2.
DESIGN CONSIDERATIONS FOR PUMP TESTING If a new pump has been added to the plant, and has been determined to be safety related per the pump selection criteria section above, certain testin9 considerations must be incorporated into the design to allow proper testin9 of these pumps.
The new pumps shall be tested in accordance with the ASME Section XI, IWP, as described in this Manual (IV. B.1)
- B.
VALVES
- 1.
VALVE IST SELECTIOH CRITERIA These instructions are intended to be used when evaluating valves for inclusion in (or exemption from) the IST Program and_ for design considerations when addin9 new valves to the plant.
Specifically the following information is intended to clarify points of concern when using either the IST Program Applicability Questionnaire (PAGE V-6) and the Flowchart for Determination of IST (valve) Program Requirements (PAGE V-7) to perform the subject evaluatiqn.
Valves which should be evaluated by the use of these instructions include all ASME Code Class 1, 2 and 3 valves, as well as any other valves which are in systems or portions of systems which may be relied upon to perform a safety function, as defined on the following page.
v-2 Rev. o
V.B. VALVES (cont'd)
- a.
SAFETY FUNCTION For the purposes of the IST Program, a valve is considered to have a safety function if it must perform a s~ecif ic function in shuttin9 down the reactor or in maintaining the reactor in the safe shutdown condition, or in mitigating the consequences of an accident.
When determining if a valve has a *safety function, all ~ossible functions of the valve must be considered.
A valve may have any number of functions, of which anr number may be safety functions.
Any valve which is determined by evaluation not to have a safety function is not within the scope of Subsection IWV of ASME Section XI, and is not subject to IST requirements.
NOTE:
Section 11 of Generic Letter 89-04 should also be reviewed when determining which valves and/or systems should be reviewed for inclusion in the IST Program.
(1)
SEAT LEAKAGE If seat leakage is limited to a specified maximum amount when the valve is in the closed position to fulfill its safety function, it is classified in ASME Section XI as a Category A valve.
All category A valves require leakrate testing.
Valves in category A generally fall into one or more of the following groups:
(a) containment Isolation Valves (CIVs)
These valves must be tested in accordance with the Type C ~est requirements of 10CFR50, Appendix J.
The results of these tests are used to satisfy the requirements of ASME Section XI.
(b)
RCS Pressure Isolation Valves These valves are norma11r tested in accordance with the requirements of ASME Section XI, Subsection IWV.
(c)
Safety or Relief Valves Category A valves in this group which are not CIV's are only required to be setpoint tested per the requirements of ASME Section XI.
NOTE:
For additional information, see paragraph IV.B.2.c. in this Manual.
V-3 Rev. o
V.B.A SAJ'ETY FUNCTION (cont'd)
(2)
CHANGE OF POSITION Valves which are required to change position in order to accomplish their safety function are defined in Subsection IWV as ACTIVE valves, and must be exercise tested in accordance with the requirements of ASME Section XI.
The type of exercise testing which must be conducted is dependent on the type of valve.
Check valves must be FORWARD and/or REVERSE FLOW TESTED, depending on the direction of their safety function(s).
Relief valves must be SETPOINT TESTED according to ASME PTC 25.3-1976.
All others must be EXERCISE TESTED through at least one complete cycle of full travel.
Valves which are used for system control, however, are only included if they have a required fail-safe position.
Valves which do not have to change position in order to accomplish a safety function are defined in Subsection IWV as PASSIVE valves, and do not have any IST requirements other than leakrate testing, if applicable (see page V-1).
NOTE:
For additional information, see paragraph IV.B.2. in this Manual.
(3)
ASME Section XI requires that the limiting full-stroke operating time for all power-operated valves which come under the scope of Subsection IWV be specified by the Owner.
All such valves must then be STROKE-TIME TESTED per the requirements of ASME Section XI. Power-operated valves which are designed to fail in the conservative position are required to be FAIL-SAFE TESTED.
Typically, valves with air or hydraulically-operated actuators or solenoid actuators are provided with the failsafe feature, whereas motor-operated valves are not.
NOTE:
For additional information, see paragraph IV.B.2. in this Manual.
REMOTE POSITION INDICATORS All valves which are included in the scope of Subsection IWV that are equipped with remote position indicators must have a REMOTE POSITION INDICATOR VERIFICATION V-4 Rev. o
V.B.
VALVES (cont'd)
(5) performed to ensure that the indicator accurately reflects the valve's position.
NOTE:
For additional information, see paragraph IV.B.2.h. in this Manual.
CATEGORY D VALVES Cate9ory D valves are defined in ASME Section XI as valves which are actuated by an energy source capable of only one operation, such as rupture disks or explosively-actuated valves.
Due to the very low number of this category of valve in use at any plant, they are not covered by the attached questionnaire or flow chart.
However, since Category D valves are, by nature, active, they must be evaluated for inclusion in the IST Program.
Requirements for testing of Category D valves are con-tained in Subsection IWV of ASME Section XI.
NOTE:
For additional information, see paragraph"IV.B.2. in this Manual.
- 2.
DESIGN CONSIDERATIONS FOR VALVB TESTING If a new valve has been added to the plant, and has been determined to be safety related per the valve selection criteria section above, certain testin9 considerations must be incorporated into the design to allow proper testing of these valves.
For example, appropriate vents, drains, test connections and flow measuring devices, etc., must be built into the design to accommodate these testing requirements.
The following are typical improvements in design that could be considered.
- a.
Testable Check Valves
- b.
Soft seated valves for leak rate tested valves.
- c.
Conveniently located test connections, vent and drains.
For specific valve testing requirements see section IV.l. of this Manual or ASME Section XI, Subsection IWV of the 1983 through the Summer of 1983 Addenda.
V-5 Rev. 1
V.B.
VALVES (cont'd)
INSERVICE TEST (IST) PROGRAM APPLICABILITY QUESTIONNAIRE VALVE NUMBER(S):~~~~~~~~~- REF. DRAWING:
DWG COORO:
~~~~~
- 1. Does this valve have a safety function, as defined in B.1.a of this Section?
[ ]
YES
[ ]
NO - review is complete; this valve is exempt from the IST Program
- 2. Is this valve limited to a specified maximum amount of seat leakage in order* to accomplish its safety function?
[ ] YES - requires LEAKRATE TESTING (refer to B.l.a.(1) of this section.)
[ ] NO
- 3. Is this valve permitted *to be in such a position during normal plant operation that it could be required to change position in order to accomplish its safety function?
[ ] YES
[ ] NO NOTE:
If the answers to both question 2 and 3 are NO, this evaluation is complete.
No IST requirements apply.
- 4. If the answer to Question No. 3 is YES, is this a control or modulating valve which is used for system control and does not have a required fail safe position?
[ ] YES - this valve is exempt from IST requirements
[ ] NO - requires EXERCISE TESTING or SETPOINT TESTING (refer to B.1.(2) of this section.)
- 5. Is the valve actuator power-operated?
[ '] YES - requires STROKE-TIME TESTING
[ ] NO
- 6. If the answer to Question No. 5 is YES, is the power-operated actuator provided with a fail-safe feature?
[ ] YES - requires FAIL-SAFE TESTIHG
[ ] NO
[ ] NOT APPLICABLE
- 7. Is remote position indication provided for this valve?
[ ] YES - requires REMOTE POSITION INDICATION VERIFICATION [ ] NO V-6 Rev. o
~---------.,
V.B.
VALVES (cont'd)
V-7 Rev. o