ML18107A361

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Forwards Responses to NRC 990301 & 990323 RAIs for Salem & Hope Creek Generating Stations Relating to GL 96-05
ML18107A361
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 05/27/1999
From: Eric Simpson
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-05, GL-96-5, LR-N990240, NUDOCS 9906090130
Download: ML18107A361 (10)
v • d • e


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  • 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 Engineeri~g MAY 2 7 1999 LR-N990240 United States Nuclear Regulatory Commission Document Control Desk
  • Washington, DC 20555 RESPONSE TO GENERIC LETTER 96-05 RAI HOPE CREEK AND SALEM GENERATING STATIONS FACILITY OPERATING LICENSES DPR-70, DPR-75, AND NPF-57 DOCKET NOS. 50-272, 50-311, AND 50-354 Gentlemen:

This letter responds to requests for additional information (RAls) related to Generic Letter 96-05 for the Hope Creek and Salem Generating Stations. The Hope Creek RAI was received in a letter dated March 1, 1999 while the Salem RAI was received in a letter dated March 23, 1999. The response to the Hope Creek and Salem RAls are included in Attachment 1 and Attachment 2, respectively.

Should you have any questions regarding this response, please contact Mr. C. Manges at 609-339-3234.

Affidavit Attachments (2)

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Document Control Desk

,LR-N990240

  • MAY 2 'l 1999 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 881 11555 Rockville Pike Rockville, MD 20852 Mr. P. Milano, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 881 Rockville, MD 20852 Mr. D. Orr (X24)

USN RC Senior Resident Inspector - HC Mr. S. Morris (X24)

USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. 0. Box415 Trenton, NJ 08625 95-4933

  • LR N990240

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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 Hope Creek Generating Station, Unit 1 and Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this d-1 day of ~ , 1999 No~j~~

ELIZABETH J. KIDD NOTARY PUBLIC OF NEW JERSEY My Commission expires on ----"M="-'-'""*om~

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  • ATTACHMENT 1 TO LR-N990240
  • RESPONSE TO THE NRC REQUEST FOR ADDITIONAL INFORMATION RELATED
  • TO GENERIC LETTER 96-05 FOR HOPE CREEK NRC RAI Question 1 "In NRC Inspection Report No. 50-354/96-04, the NRC staff closed its review of the motor-operated valve (MOV) program implemented at Hope Creek Generating Station (HCGS) by Public Service Electric and Gas Company (the licensee) in response to Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance." In the inspection report, the NRC staff discussed certain aspects of the licensee's MOV program to be addressed over the long term. For example, the inspectors noted that (1) eight gate valves were scheduled to be modified in RF07 to increase their actuator capability; and (2) the licensee planned to use the Electric Power Research Institute MOV Performance Prediction Model where butterfly valve torque requirements were not clear or verified. The licensee should describe the actions taken to address the specific long-term aspects of the MOV program at HCGS noted in the NRC inspection report."

Response to NRC RAI Question 1 (1) Inspection Report (IR) 354/96-04 stated that PSE&G identified eight gate valves that would be modified to increase their valve factor capability above 0.65. Three of the eight valves (1FDHV-F002, 1FDHV-F003, and 1ABHV-F016) were modified with new gearing and/or larger motors. One valve (1 FDHV-F001) was dynamically tested to verify valve performance and its ability to meet design basis conditions. Four valves (1 BCHV-F004A, 1BCHV-F004B, 1BEHV-F005A, and 1BEHV-F005B) were evaluated and the design conditions were determined to be overly conservative. The pressures used for the analysis of these four valves were revised downward and no modifications were required. The modifications and reanalysis have resulted in valve factor capability above 0.65 for the affected valves.

(2) A memorandum has been issued as an interim measure to require that the EPRI PPM methodology be used in the future if butterfly valve torque requirements are not clear or verified. By July 31, 1999, the Hope Creek MOV Program will be modified to include this requirement.

Page 1of3

Hope Creek RAI Response NRC RAI Question 2

  • * . LR-N990240 "In a letter dated March 13, 1997, the licensee stated its commitment to implement the Joint Owners Group (JOG) Program on MOV Periodic Verification in response to GL 96-
05. The JOG program specifies that the methodology and discrimination criteria for ranking MOVs according to their safety significance are the responsibility of each participating licensee. In its letter dated March 13, 1997, the licensee stated that the frequency of static diagnostic testing at HCGS would be based on its Probabilistic Safety Assessment and an expert review. As HCGS is a boiling water reactor (BWR) nuclear plant, is the licensee applying the Boiling Water Reactor Owners' Group (BWROG) methodology for ranking MOVs based on their safety significance as described in BWROG Topical Report NEDC-32264 and the NRC safety evaluation dated February 27, 1996? If not, the licensee should describe the methodology used for risk ranking MOVs at HCGS in more detail, including a description of (1) the process used to develop sample lists of high-risk MOVs from other BWRs; and (2) how expert panels were used to evaluate MOV risk significance."

Response to NRC RAI Question 2 A memorandum has been issued as an interim measure to require that the BWROG Topical Report NEDC-32264, Revision 2 and the associated NRC SER be applied for the risk ranking of MOVs at Hope Creek. By July 31, 1999, the Hope Creek MOV Program will be revised to incorporate this requirement and to reference these documents as the basis for MOV ranking.

NRC RAI Question 3 "The JOG program focuses on the potential age-related increase in the thrust or torque required to operate valves under their design-basis conditions. In the NRC safety evaluation dated October 30, 1997, on the JOG program, the NRC staff specified that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. The licensee should describe the plan at HCGS for ensuring adequate ac and de MOV motor actuator output capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement 1."

Response to NRC RAI Question 3 The Hope Creek plan for ensuring adequate actuator output capability is described as follows:

The Hope Creek AC valves were evaluated considering the information in Limitorque TU 98-01 and no immediate operability concerns were identified. A formal engineering evaluation to summarize and finalize the results of the evaluation will be completed by June 30, 1999. The BWROG is presently working on an evaluation methodology for DC powered Limitorque motor operated valves. The results of this methodology will be reviewed and appropriate actions will be taken at Hope Creek based on the results.

Page 2of3

Hope Creek RAI Response *

  • LR-N990240 As an ongoing effort to maintain adequate actuator capability, PSE&G is implementing a

,static test program and trending valve performance. The MOV program at Hope Creek requires trending of the following data for age or time related degradation:

  • Valve thrust
  • Motor current In some cases, data on both valve thrust and actuator torque may not be collected for a given valve; however, any data collected is trended.

By July 31, 1999, the PSE&G MOV Program will be modified to require that the following information also be evaluated:

  • Stem coefficient of friction (when adequate data is collected)
  • MOV failures or corrective maintenance Page 3 of 3
  • ATTACHMENT 2 TO LR-N990240
  • RESPONSE TO THE NRC REQUEST FOR ADDITIONAL INFORMATION RELATED

. . TO GENERIC LETTER 96-05 FOR SALEM NRC RAI Question 1 "Through NRC Inspection Report (IR) 50-272 & 311/97-03 (Unit 2), IR 50-272/98-01 (Unit 1), and IR 50-272 & 311/98-08(Unit1), the NRC staff closed its review of the motor-operated valve (MOV) program implemented at Salem in response to Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance." In the inspection reports, the NRC staff discussed certain aspects of the licensee's MOV program that were to be addressed over the long term. These issues have been separated by unit and are discussed below.

Unit 1:

In IR 50-272/98-01 and IR 50-272 & 311/98-08, the NRC noted that PSE&G agreed to (1) increase the available margins for the reactor coolant pump thermal barrier heat exchanger isolation valves, 1CC130 and 1CC190; (2) verify correct wedge shoe orientation and dynamically test Anchor/Darling double disc gate valves, 1CC117 and 1CC118; and (3) include valves 1CC118, 1CC30, 1PR? and 1SJ4 in its margin improvement plans.

Unit 2:

In IR 50-272 & 311/97-03 and in Section EB, "Miscellaneous Engineering Issues," of IR 50-272 & 311/98-08, the NRC noted that PSE&G agreed to (1) perform modifications on residual heat removal valves 2RH1 and 2RH2; (2) confirm the unsupported guide lengths df the pressurizer power operated relief block valves; (3) increase the motor actuator capability, verify the unsupported guide length, and verify the disc and guide edge treatments on the reactor coolant pump thermal barrier heat exchanger isolation valves, 2CC130 and 2CC190; (4) dynamically test and perform additional evaluations on valves 2CC136, 22CC16, 2SJ4, and 2SJ5; and (5) increase the output capability for four 24" Pratt butterfly valves included in Family 16.

Provide an update of the actions taken to address the specific long-term aspects of the MOV program at Salem noted in the NRC inspection reports."

Response to NRC RAI Question 1 Response to Unit 1 Questions (1) Motor Operated Valves 1CC131and1CC190 were modified to increase the overall gear ratio and to limit seat the valves. These modifications increased the output of the operator and increased the available margins for the valves.

Page 1of4

...

Attachment 2 Salem RAI Response (2)

  • Valves 1CC117 and 1CC118 will be dynamically tested and their wedge shoe LR-N990240 orientation will be verified during the thirteenth refueling outage for Unit 1 (1R13) that is currently scheduled to begin in September 1999.

(3) PSE&G will either initiate action to improve the margins for Valves 1CC118, 1CC30, 1PR7, and 1SJ4 or will establish performance predictability by December 31, 1999. If PSE&G decides to take action to improve the margins, the action will be completed prior to startup from the fourteenth refueling outage for Unit 1 (1 R14) that is currently scheduled to begin in April 2001.

Response to Unit 2 Questions (1) As indicated in IR 311/97-03, PSE&G intended to modify Valve 2RH1 to make it comparable to Valve 2RH2. Valve 2RH1 has been modified to the same configuration as 2RH2. As noted in IR 311/98-08, the design basis ambient temperature for these valves was determined to be overly conservative and was reduced thereby resulting in greater capability margins for the valves.

(2) The unsupported guide lengths of Valves 2PR6 and 2PR7 will be verified during the twelfth refueling outage at Unit 2 (2R12) that is currently scheduled to begin in April 2002 or during the next inspection, whichever occurs first.

(3) Valves 2CC131 and 2CC190 were modified to change the gearing and to limit seat the valve to increase motor operator output. The unsupported guide length and the disc and guide edge treatments will be verified during the eleventh refueling outage at Unit 2 (2R11) that is currently scheduled to begin in October 2000.

(4) Valves 2SJ4, 2SJ5, 2CC136 and 22CC16 have been dynamically tested. The test data will be evaluated and long-term plans developed by July 31, 1999.

(5) The spring packs for four Pratt butterfly valves in Family 16 (21 SW22, 22SW22, 21 SW23, and 22SW23) were changed to increase the operator output.

NRC RAI Question 2 "In a letter dated March 13, 1997, PSE&G stated its commitment to implement the Joint Owners Group (JOG) Program on MOV Periodic Verification in response to GL 96-05.

The JOG program specifies that the methodology and discrimination criteria for ranking MOVs according to their safety significance are the responsibility of each participating licensee. In its March 13, 1997, letter, PSE&G stated that the frequency of static diagnostic testing would be based, in part, on Salem's Probabilistic Safety Assessment and an expert review. Since Salem uses a pressurized water reactor designed by Westinghouse, discuss whether PSE&G is applying the Westinghouse Owners' Group (WOG) methodology for ranking MOVs based on their safety significance as described in WOG Engineering ReportV-EC-1658-A (Revision 2, dated August 13, 1998), "Risk Page 2 of 4

Attachment 2 Salem RAI Response *

.and the NRC's safety evaluation dated April 14, 1998. If not, describe the methodology used for risk ranking MOVs at Salem in more detail, including a description of (1) the process used to develop sample lists of high-risk MOVs from other Westinghouse plants; and (2) how expert panels were used to evaluate MOV risk significance."

Response to NRC RAI Question 2 A memorandum has been issued as an interim measure to require that the WOG Engineering Report V-EC-1658-A, Revision 2 and the associated NRC SER be applied for the risk ranking of MOVs at Salem. By July 31, 1999, the Salem MOV Program will be revised include this requirement and to reference these documents as the basis for MOV ranking.

NRC RAI Question 3 "The JOG program focuses on the potential age-related increase in the thrust or torque required to operate valves under their design basis conditions. In the NRC's safety evaluation dated October 30, 1997, on the JOG program, the NRC staff specified that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. Describe the plan at Salem for ensuring adequate a.c. and d.c. MOV motor actuator capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its supplement 1."

Response to NRC RAI Question 3 The Salem plan for ensuring adequate actuator output capability is described as follows:

The Salem MOVs have been evaluated considering the information in Limitorque TU 98-01. Although the number of low margin valves and the amount of required testing have increased, the valves were determined to be capable of performing their functions.

A formal engineering evaluation to summarize and finalize the results of the evaluation will be completed by June 30, 1999.

As an ongoing effort to maintain adequate actuator capability, PSE&G is implementing a static test program and trending valve performance. The MOV program at Salem requires trending of the following data for age or time related degradation:

  • Valve thrust
  • Motor current In some cases, data on both valve thrust and actuator torque may not be collected for a given valve; however, any data collected is trended.

Page 3of4

___ j

~ttachment 2 Salem RAI Response *

  • LR-N990240 By July 31, 1999, the PSE&G MOV Program will also be modified to require that the

,f<?llowin~ information be evaluated:

  • Stem coefficient of friction (when adequate data is collected)
  • MOV failures or corrective maintenance Page 4of4
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