ML18101B227

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Discusses 951211 Meeting W/Util Re Items 2 & 3 of CAL-1-95-09 Concerning Commitment to Perform Special Review of long-standing Salem Issues.Meeting Attendee List & Slides Encl
ML18101B227
Person / Time
Site: Salem  
Issue date: 02/13/1996
From: Cooper R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Eliason L
Public Service Enterprise Group
References
CAL-1-95-09, CAL-1-95-9, NUDOCS 9602220023
Download: ML18101B227 (39)
v • d • e


Text

.,

February 13, 1996 Mr. Leon R. Eliason Chief Nuclear Officer & President Nuclear Business Unit Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

CLOSURE OF ITEMS 2 AND 3 OF SALEM CONFIRMATORY ACTION LETTER 1-95-009

Dear Mr. Eliason:

This letter refers to items 2 and 3 of Confirmatory Action Letter (CAL) 1 009, dated June 9, 1995, in which you committed to perform a special review of the long-standing Salem issues and meet with NRC representatives to communicate and gain NRC agreement on the scope and comprehensiveness of your plan to support Salem restart.. In your letter, dated November 24, 1995, you submitted to the NRC the results of your review of long-standing equipment reliability and operability issues, including corrective maintenance and operator work-arounds, and the effectiveness and quality of your past management oversight and review.

A meeting between the NRC and Public Service Electric and Gas (PSE&G) was held on December 11, 1995 in which you presented the results of your review and the corrective actions you plan to implement to ensure that Salem will be operated in a safe and reliable manner.

The enclosures to this letter are a list of the principle attendees and a copy of the slides presented during that meeting.

The NRC sought and acquired information from the states of New Jersey and Delaware relative to their concerns about the performance of the Salem units, as well as, concerns about your restart plan.

Addition~lly, on December 18, 1995, the NRC conducted a meeting with interested members of the public to receive their comments and concerns. Collectively, these interactions provided the NRC valuable insight into your restart plan and the concerns of these external parties.

In two recent internal meetings on January 3 & 31, 1996, the NRC Salem Assessment Panel critically reviewed your restart plan to determine whether your recent activities satisfied items 2 and 3 of the Salem CAL (1-95-009).

During our review, we considered: 1) the scope and depth of your overall restart plan; 2) assessment panel member reviews of your individual restart plans; 3) independent NRC inspections of your system readiness review process;

4) previous assessment panel deliberations and interactions with your staff, the state and the public; 5) the information you provided in the December 11 meeting; 6) improvements in recent safety review activities (Station Operations Review Committee and Corrective Action Review Board); and 7) the new management team you put in place with a demonstrated strong commitment to safety. Although we were generally satisfied that your plan satisfied CAL items 2 & 3, we noted that your plan did not specifically address recent weaknesses in Emergency Preparedness.

We also noted that your performance 210090 9602220023 960213 PDR ADOCK 05000272 p

PDR

Mr. Leon R. Eliason 2

indicators are still under development, including those you will use to evaluate your overall readiness for plant restart after the completion of this extended outage.

We were informed on January 4, 1996 by Clay Warren, General Manager-Salem Operations, that you intend to address these items and that you will be updating your overall plan from time to time.

Based on the above, we have concluded that* your overall restart plan, if implemented effectively, should adequately address the numerous Salem issues to support a safe plant restart. Thus, items 2 & 3 of the CAL have been satisfied.

We will continue to pursue the aforementioned items and other issues through our planned inspection activities. The assessment panel derived an initial list of items to be inspected from NRC Manual Chapter 0350.

These items will be communicated to you in the near future.

At the conclusion of this extended outage, in accordance with the Confirmatory Action Letter, we will conduct a public meeting with you to discuss your operational readiness assessment for each unit. Additionally, we intend to conduct a Readiness Assessment Team Inspection (RATI), just prior to restart, to independently confirm that your actions have resulted in the necessary performance improvementi to support safe plant restart.

When you are satisfied in all respects that the facility is ready to restart, we request that you certify that in writing to the NRC Regional Administrator.

In summary, the NRC has found that commitments 2 and 3 of the subject CAL have been satisfied. In accordance with 10 CFR 2.790, a copy of this letter will be placed in the NRC Public Document Room.

Closure of other CAL items will be addressed by separate correspondence.

Thank you for your cooperation.

Docket Nos. 50-272; 50-311

Enclosures:

1.

Meeting Attendee List

2.

Meeting Slides ORIGINAL SIGNED BY:

Richard W. Cooper, II, Director Division of Reactor Projects

Mr. Leon R. Eliason 3

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.

C. Warren, General Manager - Salem Operations M. Reddemann, General Manager - Hope Creek 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. Macfarland 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

Mr. Leon R. Eliason 4

- Distribution w/encl:

Region I Docket Room (with concurrences)

Kay Gallagher, DRP Nuclear Safety Information Center (NSIC)

D. Screnci, PAO NRC Resident Inspector PUBLIC Distribution w/encl: (Via E-Mail)

L. 01 sh an, NRR W. Dean, OEDO J. Stolz, PDI-2, NRR M. Callahan, OCA Inspection Program Branch, NRR (!PAS)

DOCUMENT NAME:

cal item.2&3 (Salem)

To receive a copy of this document, indicate in the box: "C' = Copy without attachment/enclosure "E' = Copy with attachment/enclosure "N" = No copy OFFICE RI:DRP NAME

  • SBar DATE I/BJ 2/ f /96 2/ I /96 OFFICIAL RECORD COPY

NRC/PSE&G MEETING DECEMBER 11, 1995 - 10:00 AM LIST OF PRINCIPLE ATTENDEES ENCLOSURE 1 PSE&G SENIOR MANAGEMENT AND PRESENTERS Jim Ferland Leon Eliason Louis Storz Elbert Simpson Clay Warren Eric Salowitz Jeffrey Benjamin Jay Doering Michael Rencheck Mark Reddemann Jerry McMahon Dave Garchow Chuck Johnson Chris Bakken Jay Laughlin David Powe 11 Tim Martin Wi 11 i am Dean Eugene Kelly John Stolz Leonard Olshan Larry Nicholson Scott Barber Charles Marschall Roy Zimmerman Victor Mccree Richard Cooper James Wiggins Joseph Schoppy Todd Fish Chairman of the Board & CEO President - Nuclear Business Unit & Chief Nuclear Officer Senior vice President - Nuclear Operations Senior Vice President - Nuclear Engineering General Manager - Salem Operations Director - Nuclear Support Director - QA & Nuclear Safety Review NRB Member Technical Manager - Salem General Manager - Hope Creek Operations Director - Nuclear Training Center Director - System Engineering Director - Nuclear HR & Administrative Services Manager - Salem Operations Manager - Salem Maintenance Manager - Nuclear Licensing & Regulation Regional Administrator - Region I Regional Coordinator, DEDO, HQ Chief, Plant Systems Section, DRS, Region I (SAP Member)

Director, Projects Directorate I-2, NRR (HQ SAP Vice Chair)

Licensing Project Manager, Salem, HQ (SAP Member)

Chief, Projects Branch 3, DRP, Region I (SAP Chair)

Project Engineer, Projects Branch 3, Region I (SAP Member)

Senior Resident Inspector, Salem, Region I (SAP Member)

Associate Director for Projects, HQ Regional Operations Staff Chief, DEDO, NRR Director, Division of Reactor Projects, Region I Director, Division of Reactor Safety, Region I Resident Inspector, Salem, Region I Resident Inspector, Salem, Region I

ENCLOSURE 2 Public Service Electric and Gas Company NUCLEAR BUSINESS UNIT SALEM RESTART MEETING December 11, 1995 SALEM GENERATING STATION D

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NUCLEAR BUSINESS UNIT (NBU)

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CHIEF NUCLEAR OFFICER and PRESIDENT L. R. ELIASON I

w SRVPNUC OPS DIR - NUC BUS UNIT DIR -QA/ NSR SUPPT L F.STORZ J. A. BENJAMIN E. M. SALOWITZ I>.

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\\. OPNSSERV SALEM TRAINING Pl..NTENGR&

SYSTEM PROJECTS ENGR I

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0 Denotes new employee - external hires Q Denotes new responsibilities - internal hires D Denotes no change LICENSING &

ACTION &

SAFETY REVIEW REGULATION QUALITY SE RVS RAD PRO OUTAGE DIR - NUC HR & ADM.

SR VP - NUC ENGR SERV E. C. SIMPSON C. P. JOHNSON I

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NUC ENGR NUCLEAR

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SALEM DESIGN FUELS

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SALEM RESTART PLAN

  • PROCESS OVERVIEW CLAY WARREN
  • CULTURAL CHANGES - HUMAN PERFORMANCE, CLAY WARREN SELF-ASSESSMENT & CORRECTIVE ACTION
  • OPERATIONS CHRIS BAKKEN
  • SYSTEM & EQUIPMENT RELIABILITY MIKE HENCHECK
  • MAINTENANCE I WORK CONTROL JAY LAUGHLIN
  • ENGINEERING DAVE GARCHOW *
  • TRAINING JERRY McMAHON
  • READINESS FOR RESTART CLAY WARREN
  • KEYS FOR SUCCESS LOU STORZ

Salem Restart Plan PROCESS OVERVIEW iiiE"*ru**TiF*v*****A*i\\iii***"*li(iu"*l\\iii*******p**E*.R.*F*.*ci*R"IVii"l\\fcE"*.*--\\

WEAKNESSES I

PLANT-PROCESS-PEOPLE l

FEEDBACK SALEM RESTART PLAN ACTION PLANS RESULTS RESTART READINESS ASSESSMENTS RESTART AGREEMENT START UP & POWER ASCENSION PROGRAM

).

Salem Restart Plan DEVELOPMENT OF COMMON CAUSE NRC INSPECTION REPORTS INPO REPORTS PLANT PROCESS PEOPLE ISSUES DUALITY ASSURANCE ASSESSMENTS FOCUSED SELF ASSESSMENT COMPREHENSIVE PERFORMANCE ASSESSMENT LICENSEE EVENT REPORTS TEAM INCIDENT REPORTS*

COMMON CAUSE ANALYSIS CULTURE SURVEY

Salem Restart Plan COMMON CAUSAL FACTOR AREAS

  • Operations Focus of Organization
  • Equipment Performance Standards
  • Work Control Process
  • Conservative Decision Making and Safety Perspective
  • Root Cause Analysis and Corrective Action Effectiveness
  • Self Assessment Process
  • Roles, Responsibilities and Accountability
  • Work Standards
  • Monitoring and Enforcement of Performance Expectations
  • Communications and Coordination (Vertical and Horizontal)
  • Training and Qualifications
  • Staffing and Work Loads

Salem Restart Plan Overview of Implementation Process

(

Where We Were

) (

Course of Action

) (

Where We Will Be

)

  • PLANT RESTART ACTION PLANS
  • PLANT
  • Systems Operating in

-Unreliable accordance with Design

- Poorly Maintained

  • HUMAN PERFORMANCE
  • PROCESSES
  • SELF ASSESSMENT
  • PROCESSES

-Ineffective Procedures

  • CORRECTIVE ACTION
  • Effective Procedures &

Processes to Continuously

& Processes

  • OPERATIONS Improve Performance &
  • PEOPLE
  • SYSTEM & EQUIPMENT Materiel Condition
  • Ineffective Leadership RELIABILITY
  • PEOPLE

- Poor Accountability

  • Well Trained &
  • Sub-Standard
  • MAINTENANCE Qualified Work-Force Performance
  • WORK CONTROL who will Safely Operate the Plant
  • ENGINEERING
  • People will want to
  • TRAINING come to Work, to Work Measurements of Effectiveness PERFORMANCE INDICATORS

CULTURAL CHANGES - YOU ARE THE DIFFERENCE HUMAN PERFORMANCE SELF ASSESSMENT PROBLEM RESOLUTION NBU CULTURE SELF IDENTIFIED PROBLEMS CORRECTIVE ACTION e1

Salem Restart Plan Human Performance

~(==W=he::r::e:::::W::e:::::::W::e::r::e==::::) ;.(==C=o=u=r=se=of=A=c=t=io=n=*==-) (;:==W=h=er=e=W=e :::::W::::i::ll:::::B::e::::::=..)

  • Ineffective Leadership
  • Low Standards
  • Poor Accountability
  • Inadequate Feedback
  • Lack of Teamwork
  • Events
  • New Nuclear Business Unit Salem Management Team
  • Communication of New Mission, Goals, Practices &

Conduct

  • Raise Performance Standards

& Establish Accountability Training & Development Focusing on New Skills &

Behaviors

  • Perform Culture Index
  • Work Teams
  • Effective Leadership
  • High Standards & Expectations
  • Personnel Accountability
  • Teamwork Resolving Poor Performance Measurements of Effectiveness
  • Number of Human Error Caused Events
  • Culture Index Results
  • People on Improvement Plans
  • Absenteeism I Overtime Use

Salem Restart Plan Self Assessment

(~===""=h=e=r=e=\\¥=e=\\V==er=e====::::.)(

==C=o=u=r=se=o=f=A=c=t*=*o=n====~)(~===""=h=e=r=e=\\V=e=\\V==il=IB=e==~)
  • Self Assessment Not Inherent to Organization
  • Outside Groups Identified Weaknesses
  • Established Self Assessment as Organization Expectation
  • Established Self Assessment Program:

v Peer Observation v Management Observation v Planned Departmental Assessments

  • Established Dedicated Self Assessment Coordinator
  • Self-Identification of Problems
  • Questioning Attitude
  • Timely, Effective Problem Resolution Measurements of Effectiveness
  • Issues Self-Identified by Line Organizations
  • Identification of Precursors
  • Duality & Thoroughness of Assessments

Salem Restart Plan Corrective Action

(:;:=::W=h::e:::r:::e =W=e=W=e=re==::::;..)(;: =:::C::o::u::rs::e:::o::f::::A:::.c::ti:::on==:::-) (;:==W=h=er=e=W=e=W=i=ll=B=e=~)

  • Threshold for Problem Identification too High
  • Weak Root Cause Analysis
  • Ineffective Corrective Actions
  • Lack of Line Ownership
  • Inadequate Trending and Feedback I Followup
  • Numerous Corrective Action Processes
  • Low Value Perceived
  • Established Line Ownership
  • Consolidated Process
  • Establish and Communicate Higher Standards and Expectations
  • Corrective Action Review Board
  • Reallocate Resources I Qualified Staff Upgrade Root Cause Skills
  • Line Ownership of Process
  • Timely Reversal of Negative Trends
  • Timeliness & Duality of Root Cause Analysis and Corrective Actions Measurements of Effectiveness
  • Timely Completion of Evaluations I Corrective Actions
  • Total Open Condition Reports
  • Review Board Rejection Rate
  • Duality of Evaluations
  • Repeat Issues

(

Where We Were

  • Low Standards for Personnel and Equipment Performance
  • Weak Supervision and Leadership
  • Not an Operations Led Organization (Lack of Ownership) o Deficient Policies &

Procedures

  • Ineffective Corrective Actions and Self Assessment
  • Disconnected Processes Salem Restart Plan Operations

) (

Course of Actign

) (

Where We Will Be

)

  • Establish High Standards of
  • High Safety Oriented Standards Performance Focused on of Performance Safety
  • Number One Priority
  • Reactor
  • Improve Leadership and Safety Qualifications through
  • Operations Led Organization Training and Staffing Changes
  • Adherence to Effective Policies
  • Review and Revise Appropriate

& Procedures Policies & Procedures

  • Training and Knowledge Levels Improve Corrective Action and Established Self-Assessment
  • Self Assessment and
  • Establish Operations, Corrective Action part of the Maintenance & Engineering Culture Teams Measurements of Effectiveness
  • Self-Identified Plant Problems
  • Control Room Deficiencies I Operator Work Arounds
  • Schedule Adherence
  • Adherence to Standards
  • Safety System Availability I Reliability

Salem Restart Plan System & Equipment Reliability

(~==="'=h=e=r=e=\\V=e=\\V::::::::er=e====~) ~(===C=o=u=rs=e=o=f=A=ct=io=n=====)(;==="'=h=e=r=e=\\V=e=\\V==il=IB==e==~)

  • Ineffective System Engineering Processes
  • Fundamentals
  • Implement System
  • Systems Configured and Operated in accordance
  • Lack of System Dwnersh ip
  • Recurring Equipment Problems Readiness Review Program
  • Implement System Teams
  • Improve Equipment Root Cause Analysis Implement Performance Monitoring Process with Design
  • System Readiness Affirmed
  • Effective System Performance Monitoring
  • Ability to Identify Root Causes to Recurring Equipment Problems Measurements of Effectiveness
  • System Team Walkdown Effectiveness
  • System Readiness Review Results
  • Resolution of Long Standing Equipment Problems
  • System Availability I Reliability

Salem Restart Plan Maintenance I Work Control

(_~_\\V_h_e_r_e_\\V_e_\\V~e_re~~-) ;(===C=o=u=r=se=o=f=A=c=t=io=n=====)(_~_\\V_h_e_r_e_\\V_e_\\V~i_ll_B_e~~)

  • Ineffective Problem Identification and Resolution
  • Ineffective Prioritization or Implementation of Work Activities
  • Insufficient Control of Non-Station Personnel
  • Unclear Responsibilities for Materiel Condition
  • Incomplete and Ineffective Preventive Maintenance Program
  • Self Assessment not Normal Part of Culture
  • Communicate High Standards and Expectations
  • Develop Corrective Action Team
  • New Work Management Program
  • Ensure Control and Oversight of All Personnel
  • Improve Leadership &

Qualification through Training

  • Establish Effective Self Assessment Program
  • Timely Identification and Resolution of Problems
  • Materiel Condition that Meets '

Operations, Maintenance and Engineering Needs and Expectations

  • On Line Maintenance Program

{risk managed & system availability I reliability improved)

  • Living Preventive Maintenance Program
  • Benchmarking with the Industry
  • Questioning Attitude and Self Assessment of Activities Measurements of Effectiveness
  • Materiel Condition Trending
  • Maintenance Rework
  • Schedule Adherence
  • Self -Identified Problems

Salem Restart Plan Engineering

( ___

W_h.....

er_e_W_e _W_e_r_e ___

) (

Course of Action

) (,_ __

W_h_e_r_e_W_e_W_il_l _B_e __ )

  • Expectations, Roles &

Responsibilities Not Clearly Defined

  • Issues Not Proactively Identified, Prioritized &

Resolved

  • Programs I Procedures Weaknesses
  • Issues Backlogged
  • Inadequate Safety Culture &

Continuous Improvement

  • Mixed Engineering Duality
  • Weak Self Assessments &

Training

  • Communicate Expectations, Roles & Responsibilities
  • Implement System Readiness &

Configuration Reviews

  • Prioritize Design Changes &

Improve Quality

  • Implement Improved Programs I Procedures Characterize & Reduce Backlog
  • Strengthen Self Assessment Process
  • Measure I Enhance Staff Technical Abilities
  • Roles & Responsibilities Understood by Staff
  • Systems Operated as Designed
  • Design Changes Support Operations
  • Engineering Processes Contribute to System Availability I Reliability
  • Backlogs Effectively Managed Strong Safety & Continuous Improvement Culture
  • High Duality Engineering Deliverables
  • Effective Self Assessments
  • Intrusive Engineering Measurements of Effectiveness
  • Backlog of Engineering Work Items
  • Self Assessments & Benchmarking of Programs I Repeat Findings
  • Availability I Reliability of Risk Significant Systems

Salem Restart -Plan Training

(-~-"'----h~er~e_\\¥.._._e~\\V~e_r_e~~-) (_~_C_o~u_r~se~o~f_A_c~t~io_n __ ~_,)(_~_\\V_h_e_r_e_\\V_e_\\V~il_l_B_e~-J)

  • Insufficient Line Management Involvement
  • Industry Disconnect
  • Lack of Systematic Approach to Training Improvement
  • Operator Programs on Probation
  • Programs Declining
  • Reorganize Training with Industry Experience
  • Simplify Procedures
  • Industry Experience Review Team
  • Strengthen On-the-Job Training in the Plant ework Self Assessment Process
  • New Training Materials and Techniques
  • Evaluate NBU Incumbents
  • Implementation of Systematic Approach to.

Training

  • Accredited Programs
  • Strong Industry and Line Management Involvement
  • Operate the way we Train &

Train the way we Operate Measurements of Effectiveness

  • Accreditation
  • Reduction in Rework and Person!flel Errors
  • Operators, Craft, Technical & Engineering Incumbent Evaluations
  • Line Ownership of Training

Readiness For Restart PROGRESS TO DATE Nine Salem Restart*Action Plans Actions Performed 363 Actions Scheduled 151 Total Action Items 742 Actions in Progress 216 Actions Late 12 Work Control Process 1

System Engineering 1

Training 1

Operations 1

Maintenance 7

Engineering 1

Readiness For Restart FOCUS ON RESULTS

  • RESTART READINESS REVIEW
  • ROUTINE SELF-ASSESSMENTS
  • SYSTEM READINESS ASSESSSMENTS
  • DEPARTMENT READINESS ASSESSMENTS
  • OPERATIONAL READINESS ASSESSMENT
  • INTEGRATED READINESS ASSESSMENT
  • MANAGEMENT REVIEW COMMITTEE ASSESSMENT
  • DUALITY ASSURANCE RESTART VERIFICATION

Readiness For Restart EXAMPLES OF RESTART CRITERIA

  • MATERIEL CONDITION, RELIABILITY & SYSTEM READINESS e
  • OPERATIONS LED ORGANIZATION
  • TIMELY AND EFFECTIVE CORRECTIVE ACTION PROCESS
  • SYSTEM TEAM OWNERSHIP
  • STAFFING AND QUALIFICATIONS
  • DECREASING NUMBER OF PERSONNEL ERRORS
  • OPERATOR WORKAROUNDS (NONE SIGNIFICANT)
  • DECREASING REPEAT EVENTS AND MAINTENANCE REWORK
  • INCREASING PROPORTION OF SELF-IDENTIFIED ISSUES

Keys for Success EFFECTIVE LEADERSHIP PRODUCTIVE TEAMWORK CORRECTIVE ACTION EFFECTIVE TRAINING ACCOUNTABILITY FOR RESULTS You Are The Difference e1

Salem Restart Meeting December 11, *1995 CLOSING REMARKS

\\

.I

Public Service Electric and Gas Company E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1700 Senior Vice President - Nuclear Engineering FEB 1 3 1996 LR-N96035 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC GENERIC LETTER 95-07 PRESSURE LOCKING AND THERMAL BINDING OF SAFETY-RELATED POWER-OPERATED GATE VALVES SALEM GENERATING STATION UNIT NOS. 1 & 2 FACILITY OPERATING LICENSE NOS. DPR-70 & DPR-75 DOCKET NOS. 50-272 & 50-311 The Nuclear Regulatory Commission issued Generic Letter (GL) 95-07, Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves, on August 17, 1995.

In response to GL 95-07, Public Service Electric and Gas Company (PSE&G) has completed the Requested Actions for Salem Generating Station Units 1 & 2 in accordance with the 180 day schedule contained in the generic letter to ensure that safety-related power-operated gate valves susceptible to pressure locking or thermal binding will be capable of performing their intended safety functions under all modes of plant operation.

The Enclosure provides a summary description and results of the susceptibility evaluations. contains the screening criteria used in determining which power operated safety related gate valves are or are not susceptible to pressure locking or thermal binding. contains the listing of those valves that were determined to be susceptible to pressure locking and/or thermal binding, and a summary of the disposition of each of the valves based on the screening criteria contained in.

Corrective actions completed or planned along with the schedule for completion are discussed in the Enclosure for those valves listed in Attachment 2 that remained susceptible to pressure locking or thermal binding.

9602210380 960213 PDR ADOCK 05000272 P

PDR

@. Printed on

~

Recycled Paper

Document Control Desk LR-N96035 2

FEB 1 3 1996 Should you have any questions on this submittal, please contact us.

Enclosure w/ Attachments (2)

Affidavit C

Mr. T. T. Martin, Administrator - Region 1

u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager -

Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. c. s. Marschall (X24)

USNRC Senior Resident Inspector Mr. Kent Tosch, Manager, iv Bureau of Nuclear Engineering 33 Arctic Parkway CN 415

,Trenton, NJ 08625

REF: LR-N96035 STATE OF NEW JERSEY SS.

COUNTY OF SALEM E. C. Simpson, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station Unit Nos. 1 and 2, are true to the best of my knowledge, information and belie~~

Subscribed this

\\'.?>

and Sworn J!h before me day of

-~

1996 My Commission expires on --~~~~~A=N~M~!_.,~~~~~~n~P~~~-

NOTARY PUHL1L: OF rfrW JERSEY My Corniliission ti*.ptres !Jct 13, 1997

LR-N96035 ENCLOSURE

SUMMARY

DESCRIPTION RESPONSE TO NRC GENERIC LETTER 95-07 1 PRESSURE LOCKING AND THERMAL BINDING OF SAFETY RELATED POWER OPERATED GATE VALVES SALEM GENERATING STATION UNITS 1 & 2 DOCKET NOS. 50-272 & 50-311 This report provides information to satisfy the 180 day reporting requirements of Generic Letter 95-07 (Ref. 1).

The scope of the review for Salem Generating Station Units 1 and 2 includes all power operated gate valves (air, hydraulic and motor operated) for their susceptibility to pressure locking or thermal binding (PL/TB) as follows:

Within the requested 90 days of the issuance of the generic letter, perform a screening evaluation of all safety related power operated gate valves to identify valves potentially susceptible to pressure locking or thermal binding.

Provide a basis for operability for those valves identified as susceptible as required or take appropriate actions in accordance with Technical Specifications.

Within the requested 180 days of the issuance of the generic letter, evaluate operational configurations of those valves identified as susceptible and perform further analyses as appropriate.

Take needed corrective actions (or justify longer schedules) to ensure valves are capable of performing their intended safety function.

The Salem response is based on a review process following the screening criteria contained in Attachment 1 to identify those safety related power operated gate valves that may be susceptible to pressure locking or thermal binding.

This resulted in a list of valves that may be susceptible to pressure locking or thermal binding.

A total of 60 valves were identified as potentially susceptible.

No hydraulically or air operated valves were determined to have a safety related open function.

The identified valves were further screened for susceptibility using the criteria in Attachment 1 based upon the design and operating conditions to which the valve may be exposed, including process and ambient conditions.

Valve surveillance requirements were also considered. contains the results of this screening which concluded that 14 valves are susceptible to pressure locking and 8 valves are susceptible to thermal binding.

Evaluation of power operated gate valves that could be Page 1 of 3

LR-N96035 ENCLOSURE

SUMMARY

DESCRIPTION susceptible to pressure locking had previously been completed for Salem Units 1 and 2 during the plant design and construction phase.

This evaluation resulted in design modifications to 24 valves that included 1) drilling a hole in one of the disk faces to vent the bonnet to the adjacent piping and 2) installation of a bypass line to vent the bonnet to the adjacent piping or another pressure sink as identified in Attachment 2.

Additional evaluations were performed including detailed operability analyses, as required, of the valves listed in.

Operability for the valves listed below (identified with an *) could not be demonstrated using conservative design basis analysis methods.

These deficiencies were reported to the NRC under 10CFR50.73(a) (2) (ii) (LER 272/96-002).

Valves Analyzed for Operability 11 & 12 CS2

  • 21 & 22 CS2 1 & 2 PR6 1 & 2 PR7 1 & 2 SJl 1 & 2 SJ2 2SJ12 2SJ13 11 & 12 SJ113 21 & 22 SJ113 11 & 12CC16 21 & 22CC16 Containment Spray Header Isolation Valves*

PORV Block Valves*

RWST Supply Isolation to Charging/Safety Injection*

BIT Outlet Isolation RHR Discharge to SI Pump Suction Valves (SI Pump Cross-over Valves)*

RHR Heat Exchanger Component Cooling System Outlet Isolation On the basis of these reviews, appropriate procedure changes and modifications have been initiated for completion prior to restart of Salem Units 1 and 2 from the current outage.

The SJl, SJ2, 2SJ12, 2SJ13 and SJ113 valves will be modified to preclude pressure locking by providing an appropriate bonnet cavity pressure relief path.

Pressure locking of the CS2 valves will be addressed by a surveillance test procedure change to cycle the valves after the system has been depressurized.

For thermal binding concerns, the PR6 and PR7 valves will be modified to Page 2 of 3

LR-N96035 ENCLOSURE

SUMMARY

DESCRIPTION provide primary control of the motor operator based on disc position instead of torque control, and a maximum thrust limit will be identified as a test procedure control to assure a positive margin of capability.

The thermal binding concern for the CC16 valves does not require a change to the method of motor control.

Similar to the PR6 & PR7 valves, a maximum thrust will be identified.

References:

1.

NRC Generic Letter 95-07, dated August 17, 1995

2.

PSE&G initial response to Generic Letter 95-07, LR-N95164, dated October 16, 1995

3.

MPR Associates, Inc. Report No. MPR-1693, Evaluation of Salem Valves for Pressure Locking and Thermal Binding, Rev. o dated November 1995, and Rev. 1 dated January 1996

4.

Design Change Packages lEC-3540 & 2EC-3467 Page 3 of 3

LR-N96035 ATTACHMENT 1 SUSCEPTIBILITY SCREENING METHODOLOGY INITIAL SCREENING BASED ON VALVE TYPE/FUNCTION An initial screen was performed for both pressure locking and thermal binding based on the valve type and function.

All safety related air-, hydraulic-and motor-operated valves were identified.

The bill of materials (BOM) for each valve was reviewed to determine the valve type (e.g., gate, globe, butterfly, etc.).

All non-gate valves were eliminated, resulting in a list of all safety-related, power-operated gate valves.

The design basis requirements of each valve were then reviewed to determine if the valve has a safety function to open.

Valves which are not required to open are not susceptible to PL/TB and were eliminated from further evaluation.

SCREENING BASED ON VALVE MODIFICATIONS Some valves at Salem have been modified to address potential pressure locking concerns.

Modifications include 1) drilling a hole in one of the disk faces to vent the bonnet to the adjacent piping and 2) installation of a bypass line to vent the bonnet to the adjacent piping or another pressure sink.

These modifications prevent pressure locking of a valve since the bonnet is vented.

The maintenance history in MMIS was used to identify valves which have been modified; these valves are not susceptible to pressure locking.

Valve modifications were not used as thermal binding screening criteria.

SCREENING BASED ON DISK TYPE Solid wedge gate valves are less susceptible to pressure locking than flexible wedge or double disk gate valves because the solid disk design does not allow bonnet pressure to apply a direct load on each disk half in the pipe-axis direction.

Solid wedge gate valves are typically being removed from consideration in pressure locking evaluations.

Further, pressure locking experience documented in NUREG-1275, Vol. 9 indicates that instances of problems have occurred strictly with double disk.and flexible wedge gate valves, and not with solid wedge gate valves.

One solid wedge gate valve application was identified to have a scenario where the bonnet pressure may exceed that in the adjacent piping.

This application is the component cooling water outlet isolation valves from the RHR heat exchangers (Valves 11CC16, 12CC16, 21CC16 and 22CC16).

Analyses confirmed that Page 1 of 5

LR-N96035 ATTACHMENT 1 SUSCEPTIBILITY SCREENING METHODOLOGY bonnet pressure does not result in a required thrust which exceeds actuator capacity for these solid wedge gate valves.

This conclusion is consistent with the approach used for solid wedge gate valves at other plants, and is consistent with experience which indicates that pressure locking problems do not occur with solid wedge gate valves.

Accordingly, these solid wedge gate valves at Salem were determined to be acceptable as is, and the remaining efforts were focused on the other gate valve types (flexible wedge, double disk).

Copes-Vulcan parallel disk gate valves are not susceptible to thermal binding since these valves do not "wedge" at closure.

These valves have a spring between the parallel disk halves which maintains contact between the disks and seats.

Differential thermal expansion between internal components will be accommodated by.compression or relaxation of the spring.

Anchor/Darling double disk gate valves are not susceptible to thermal binding as documented in NUREG-1275, Vol. 9.

The valve assembly drawings and References 3 and 4 were reviewed to determine the disk type for each valve.

SCREENING BASED ON GENERAL CONDITIONS For each valve that was not screened out based on type/function, modifications or disk type, the general conditions under which the valve operates were reviewed to determine if it is susceptible to PL/TB.

This screening is described below.

Pressure Locking Pressure a higher opening.

pressure locking occurs when the fluid in the valve bonnet is at pressure than the adjacent piping at the time of valve The following two scenarios for elevated bonnet were considered.

"Bonnet Heatup" -- entrapment of incompressible fluid in the bonnet during valve closure, followed by bonnet heat-up prior to valve opening.

The bonnet heatup scenarios considered were:

heatup due to an increase in the temperature of the environment during an accident. (Normal ambient temperature variation is not considered because it occurs over a long time period and pressure changes*

tend to be alleviated through extremely small amounts of leakage.

Experience indicates that normal Page 2 of 5

LR-N96035

  • ATTACHMENT 1 SUSCEPTIBILITY SCREENING METHODOLOGY temperature variations are not a source of pressure locking events),

heatup due to an increase in the temperature of the process fluid on either side of the valve.

"Pressure-Trapping" -- pressurization of the valve bonnet during normal system operation or system surveillance test conditions, followed by de-pressurization of the adjacent piping prior to valve opening.

The following scenarios were considered:

back-leakage past check valves, and system operating pressures (including surveillance test conditions) which are higher than the system pressure when the valve is required to open.

The normal and accident temperature envelopes from environmental design criteria for various plant locations were used to identify potential heatup of the environment.

The applicable P&IDS, isometric drawings and Configuration Baseline Documents (CBD) were reviewed to determine process fluid temperatures and nearby heat sources.

The CBDs were also used to determine the conditions when the valve is required to open to perform its design basis function and the conditions under which the valve is closed.

Valves for which there were no plausible bonnet heatup or pressure-trapping scenarios are not susceptible to pressure locking.

The following assumptions were made in performing.this screening evaluation.

1.

For valves in water systems, the bonnet is completely filled with water upon valve closure.

2.

There is no leakage from the bonnet either through the packing or. through the bonnet-to-body seal.

3.

The disk-to-seat seal allows leakage from the adjacent piping to the bonnet but not from the bonnet to the adjacent piping.

4.

Check valves allow sufficient leakage such that the pressures are the same on both side of the check valve.

Page 3 of 5

LR-N96035 ATTACHMENT 1 SUSCEPTIBILITY SCREENING METHODOLOGY Thermal Binding Thermal binding occurs due to temperature changes of valve internal components.

The following scenarios for thermal binding were considered.

The process fluid temperature is greater than the ambient temperature when the valve is closed, which can result in heat up and expansion of the stem after insertion (closure).

The valve temperature increases or decreases between the time the valve is closed and then opened under design basis conditions, which can result in:

Differential expansion of the disk and body, and Differential expansion of the body and stem The environment and process fluid temperatures during valve closure and subsequent opening under design basis conditions were determined as described above for pressure locking.

Valves for*

which there were no plausible scenarios, as described above, were not susceptible to thermal binding.

SCREENING BASED ON SPECIFIC CONDITIONS No pressure locking screening criteria based on specific conditions were used.

Thermal binding analysis criteria address uniform temperature conditions, i.e., they do not cover transient or steady-state temperature gradients in the valve body or disk.

Based on the discussion of thermal binding events in NUREG-1275, Vol. 9, thermal binding tends to occur after temperature changes over long time periods, where the valve would be in thermal equilibrium.

The thermal.binding analysis methods developed are intended to be conservative.

For example, bounding values of valve stiffness were used based on data obtained in the EPRI MOV program.

To ensure that the methods are bounding, they are validated against data.

Specifically, six strokes (on five gate valves) were identified in the EPRI MOV Program data, where the valve temperature decreased significantly between closure and opening.

The screening criteria were based on the following inputs:

Page 4 of 5

LR-N96035 ATTACHMENT 1 SUSCEPTIBILITY SCREENING METHODOLOGY Valve body material, Valve disk material, Valve seat ring material, Valve stem material, Process fluid temperature, ambient temperature, and valve steady state temperature when the valve is closed, and valve steady state temperature when the valve is opened under design basis conditions.

Page 5 of 5

LR-N96035 ATTACHMENT 2 RESULTS FROM SCREENING OF POTENTIALLY SUSCEPTIBLE SALEM VALVES Pressure Locking1 1 l Thermal Binding"'

Valve ID(s)

Description Susceptible?

Basis For No Susceptible?

Basis For No l 1CC16, 12CC16, RHR heat exchanger component cooling These solid wedge valves Yes 21CCI6, 22CC16 system outlet isolation valves have a scenario with elevated bonnet pressure, but analyses indicate positive margin for operation under this condition 11 CS2, l 2CS2, Containment spray header isolation Yes No General Conditions screen 21CS2, 22CS2 valves (no heatup/cooldown) 1CS14, 2CS14 Spray additive tank isolation valves No General Conditions screen No General Conditions screen (no heatup/pressure-trapping)

(no heatup/cooldown) 1CS16, 2CS16, Spray additive tank isolation valves No General Conditions screen No General Conditions screen ICS17, 2CS17 (no heatup/pressure-traooing)

(no heatup/cooldown)

I 1CS36, 12CS36 RHR to containment spray system No Modifications screen No Disk Type screen isolation valves (bypass line installed)

(double disk) 2 I CS36, 22CS36 RHR to containment spray system No Modifications screen No Specific Conditions screen isolation valves (bypass line installed)

AT:O IPR6, 2PR6, PORV block valves No General Conditions screen Yes IPR7, 2PR7 (no heatup/pressure-traooing) lRHI, IRH2, RCS hot leg suction isolation valves No Modifications screen No Disk Type screen 2RHI, 2RH2 (bypass line installed)

(parallel disk) l 1RH19, 12RH19 RHR heat exchanger discharge cross-No Modifications screen No Disk Type screen connect (bypass line installed)

(double disk) lSJl, 1SJ2, RWST supply valves to the Yes No General Conditions screen 2SJI, 2SJ2 charging/safety injection pumps (no heatup/cooldown) 1SJ12, 1SJ13 Boron injection tank outlet isolation No Modifications screen No Disk Type screen valves (hole drilled in disk)

(double disk) 2SJ12, 2SJI3 Boron injection tank outlet isolation Yes No General Conditions screen valves (no heatup/cooldown) l1SJ40, 12SJ40, SI pump discharge valves to RCS hot legs No Modifications screen No Disk Type screen 21SJ40, 22SJ40 (hole drilled in disk)

(double disk) l 1SJ44, 12SJ44, Containment sump supply valves No Modifications screen No Disk Type screen 21 SJ44, 22SJ44.

(bypass line installed)

(double disk)

Page 1 of 2

LR-N96035 ATTACHMENT 2 RESULTS FROM SCREENING OF POTENTIALLY SUSCEPTIBLE SALEM VALVES Pressure Locking<ll Thermal Binding 111 Valve ID(s)

Description Susceptible?

Basis For No Susceptible?

Basis For No l ISJ45, 12SJ45 RHR heat exchanger supply valves to the No Modifications screen No Disk Type screen SI and charging pump suction (bypass line installed)

(double disk) 2ISJ45 RHR heat exchanger supply valves to the No Modifications screen No General Conditions screen SI and charging pump suction (bypass line installed)

(no heatup/cooldown)

  • 22SJ45 RHR heat exchanger supply valves to the No Modifications screen No Specific Conditions screen SI and charging oump suction (bypass line installed)

.AT::O l ISJ54, l2SJ54, Accumulator isolation valves to the RCS No General Conditions screen No General Conditions screen l3SJ54, 14SJ54, cold leg (no heatup/pressure-trapping)

(no heatup/cooldown) 2ISJ54, 22SJ54, 23SJ54, 24SJ54 l ISJI 13, 12SJI 13, RHR discharge to SI pump suction to Yes No Specific Conditions screen 21 SJI 13, 22SJI 13 charging/safety injection pump suction

/iT=O valves (SI pump cross-over valves)

Note 1: For valves identified as Susceptible, See enclosed Summary Description Page 2 of 2

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