ML18102A515
| ML18102A515 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/01/1996 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N96332, NUDOCS 9611080150 | |
| Download: ML18102A515 (7) | |
Text
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Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations NOV 011996 LR-N96332 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NRC NOTICE OF VIOLATION INTEGRATED INSPECTION REPORTS 50-272/96-11, 50-311/96-11 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:
Inspection Report Nos. 50-272/96-11 and 50-311/96-11 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Service Electric and Gas Company (PSE&G) on October 3, 1996.
Within the scope of this report, two violations of NRC requirements were identified.
In letter dated October 3, 1996, the NRC questioned the Salem GL 89-10 Closeout Notifications in the context of 10CFR50.9(b) based on the information contained in the third party audit report.
A meeting will be held between PSE&G Management and NRC Region I to discuss this topic.
In addition to *the unresolved item discussed above, two Notices of Violation were included in the letter.
PSE&G has reviewed the violations and initiated actions to correct and prevent recurrence of the violations noted.
PSE&G will complete the necessary actions for each Salem unit prior to that unit entering Mode 6.
9611080150 96110172 PDR ADOC~ 050002 G
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Printedon
\\;I Recycled Paper
Nov 01 1996 Document Control Desk LR-N96332 2
In accordance with 10CFR2.201, PSE&G is submitting its response to these violations in Attachment 1 to this letter.
This response is applicable to Salem Units 1 and 2.
Should there be any questions regarding this submittal, please contact us.
Sincerely, C
Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. 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. Marschall (X24)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
LR-N96332 APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Units 1 and 2 Docket Nos: 50-272 50-311 License Nos:DPR-70 DPR-75 During an NRC inspection conducted from July 22-26, 1996, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
A.
10CFR 50, Appendix B, Criterion XI, "Test Control",
requires, in part, that measures shall be established to assure that all testing required to demonstrate that 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 also be evaluated to assure that test requirements have been satisfied.
Contrary to the above, as of July 21, 1996, the valve factors for the 34 motor operated valves (MOVs) in Families 3 and 9.1 were incorrectly derived from dynamic test results, in that:
- 1.
inadequate test instrumentation was used when performing the dynamic tests of charging header stop valves 1 and 2 CV68 and CV69.
- 2.
the dynamic test results for MOVs 1 and 2 CV 68 and 69 were inadequately evaluated.
Subsequent evaluation of the unusually low valve factors derived from the test data evidenced an error in the upstream pressure measurement.
- 3.
the two dynamic tests used in establishing valve factors for 20 MOVs in MOV Family 3 were not adequately justified.
PSE&G concurs with the violation.
LR-N96332 2
(1)
The reason for the violation.
The reason for this violation was attributed to personnel error.
- 1.
Personnel involved in developing and reviewing the test required a 0-5000 psig gauge, failing to identify that the expected pressure downstream of the CV68 and CV69 valves would not be charging pump discharge pressure, and would require a 0-500 psig gauge for accuracy.
- 2.
Personnel involved in developing and performing the test failed to identify that the required position of the CV71 (Flow Control Valve), located between the upstream pressure gauge and the valves being tested, could affect the apparent test differential pressure and therefore cause the results to be inaccurate.
Personnel involved in reviewing the test and incorporating the results into the MOV calculations did not identify the possible reduction in test differential pressure caused by the flow control valve.
- 3.
Rather than using only dynamic testing, PSE&G decided to use industry data to support the justification of MOV Family 3 and Family 9.1.
This industry data, though already compiled, was not prepared adequately to be used as documentation at the time of the inspection.
(2)
The corrective steps that have been taken.
- a.
Personnel involved with the occurrence were held accountable for their actions in accordance with PSE&G disciplinary policy.
- b.
Procedures Sl.OP-PT.CVC-0103 and 82.0P-PT.CVC-0103 were revised to: 1) require a 0-500 psig gauge to be installed, or that the Specialty Engineering approve use of an alternative gauge if 0-500 psig is not available, 2) fully open the CV71 flow control valve.
- c.
2CV68 and 2CV69 have been retested in accordance with the revised procedure.
The retest results indicated that the differential pressure developed by the original test was essentially unchanged (approximately 2500 psig for both tests).
LR-N96332 3
(3)
The corrective steps that will be taken to avoid further violations.
- a.
An in-depth review of other Salem Unit 2 differential pressure test procedures has been conducted to identify similar concerns.
No other problems were found.
An in-depth review of the Salem Unit 1 procedures will be conducted prior to entry into Mode 6.
- b.
1CV68 and 1CV69 will be retested prior to entry into Mode 6 for Salem Unit 1.
- c.
Additional justifications for valve Family 3 and Family 9.1 will be included in the Engineering Evaluation that will become the closeout document.
(4)
The date when full compliance will be achieved.
PSE&G will achieve full compliance for each Salem Unit prior to that unit's entry into Mode 6.
LR-N96332 4
B.
10 CFR 50, Appendix B, Criterion III, "Design Control,"
requires, in part, that measures shall be established to assure that design-basis is correctly translated into specifications, drawings, procedures, and instructions.
PSE&G Engineering Procedure NC.DE-PS.ZZ-0033(Q)-A4, "MOV Program Operating Condition Evaluation," specified a design-basis differential pressure closing requirement of 379 pounds per square inch (psid) for residual heat removal isolation MOVs 1&2 RHl and 380 psid for MOVs 1&2 RH2.
PSE&G Engineering Procedure NC.DE-PS.ZZ-0033(Q)- AB, "MOV Capability Assessment," requires the performance of mechanical design calculations using this information as design inputs to establish proper setpoints for assuring operability under design-basis conditions.
Contrary to the above, PSE&G failed to incorporate the design-basis differential pressure closing requirements into the thrust calculations for the four risk significant pressure isolation MOVs (1&2 RHl and RH2) in question.
Specifically, mechanical design calculations, S-1-RHR-MDC-0890, Sheets 1 & 2 and S-2-RHR-MDC-0906, Sheets 1 and 2, incorrectly omitted the differential pressure closing requirement from the target thrust.
The design packing load of 2500 pounds (force) was incorrectly assumed to be the only closing thrust requirement.
This combination of errors also reduced valve operating thrust margins and created the possibility that these MOVs might not close under design-basis conditions.
PSE&G concurs with the violation.
(1)
The reason for the violation.
The reason for this violation was attributed to personnel error.
The RHl and RH2 valves were unique to the Salem MOV Program, in that. these valves are position seated, parallel disk, gate valves, not torque seated as all other valves in the MOV Program.
Personnel involved with performing the calculations inserted an unusually low target thrust requirement, to be used during testing.
The low thrust value was incorrectly entered into the margin calculation resulted in an inaccurate margin determination.
LR-N96332 5
(2)
The corrective steps that have been taken.
- a.
Personnel involved with the occurrence were held accountable for their actions in accordance with PSE&G disciplinary policy.
b Calculation S-2-RHR-MDC-0890, Sheets 1 & 2 for 2RH1 and 2RH2 have been revised and verified to be correct.
- c.
2RH1 and 2RH2 have been retested.
- d.
The Salem MOVs were reviewed and these four valves were the only gate valves in either Salem Unit that are position seated and subject to this error.
(3)
The corrective steps that will be taken to avoid further violations.
- a.
Calculation S-1-RHR-MDC-0890, Sheets 1 & 2 for lRHl and 1RH2 will be revised prior to Unit 1 entry into Mode 6.
- b.
lRHl and 1RH2 will be retested prior to Unit 1 entry into Mode 6.
- c.
Calibration data in the Managed Maintenance Information System (MMIS) on the Valve Operator Data Screen ha~
been updated to prevent setting torque switches at lower than the required values.
(4)
The date when full compliance will be achieved.
PSE&G achieved full compliance for Salem Unit 2 on August 24, 1996, when the testing of 2RH1 and 2RH2 was completed.
Salem Unit 1 will achieve full compliance prior to entry into Mode 6.