IR 05000272/1993008
| ML18100A701 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 11/09/1993 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hagan J Public Service Enterprise Group |
| References | |
| NUDOCS 9311160023 | |
| Download: ML18100A701 (11) | |
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NOV 9 1993 Docket No.
Mr. Vice President - Nuclear Operations Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038
Dear Mr. Hagan:
SUBJECT: NRC INSPECTION NOS. 50-272/93-08; 50-311/93-08; 50-354/93-06 This refers to your letter dated September 13, 1993 in response to our letter dated August 30, 1993.
- Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely, ORUllUAL SiGNED BY EDWARD C. WENZINGER Edward C. Wenzinger, Chief Projects Branch No. 2 Division of Reactor Projects
....
NOV 9 \\993
cc:
C. Vondra, General Manager - Salem Operations R. Hovey, General Manager - Hope Creek Operations F. Thomson, Manager, Licensing and Regulation R. Swanson, General Manager - QA and Nuclear Safety Review J. Robb, Director, Joint Owner Affairs A. Tapert, Program Administrator cc w/cy of Licensee's Letter:
C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
R. Fryling, Jr., Esquire M. Wetterhahn, Esquire P.J. Curham, Manager, Joint Generation Department, Atlantic Electric Company Consumer Advocate, Office of Consumer Advocate W. Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Document Room (PDR)
Local Public Document Room (LPDR)
NRC Resident Inspector State of New Jersey bee w/cy of Licensee's Response Letter:
Region I Docket Room (with concurrences)
E. Wenzinger, DRP J. White, DRP S. Dembek, Projects Manager, PDI-2, NRR J. Stone, Project Manager PDI-2, NRR L. Nicholson, Acting PDI-2, NRR R1 RP~
EWenzinger 11~93 OFFICIAL RECORD COPY
.Jooeph J. Hegao Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 OCT 13 1993 Vice President * Nuclear Operations
NIR-N93160 United states Nuclear Regulato:cy Commission J:bcl.Iroont Control Desk W~,
D.C.
20555 Gentlemen:
REVISED REPLY 'ID A NOI'ICE OF VIOIATION NRC INSPECI'ION RER:>Rl' NCS. 50-272 & 311/93-08 AND 50-354/93-06 SAIEM AND HOPE CREEK GENERATING STATIONS IX>CKEI' NCS. 50-272, 50-311 AND 50-354 Public SeJ:vice Electric am. Gas Ccxnpany (PSE&G) has received your letter dated AugUst 30, 1993 requesting that PSE&G provide a revised response to the Notice of Violation transmitted in the subject Inspection Report.
ruring a telephone conversation with Mr. J. White (NRC), a response due date of October 13, 1993 was agreed upon.
Pursuant to the provisions of le>crn2.201, PSE&G here.by sul:mits its revised response to the Notice of Violation. 'llris revised response supersedes our previous response letter dated June 7, 1993 in its entirety.
Should you have any questians on this transmittal, please contact us.
Attaclnrent
D:x:ument Control Desk NIR-N93160
C Mr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulato:cy Commission 475 AllerDale Road Kin:J of Prussia, PA 19406 Mr. J. c. stone, Licensing Project Manager - Salem U. s. Nuclear Regulato:cy Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. s. Dembek, Licensin] Project Manager - Hope Creek U. S. Nuclear Regulato:cy Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. Marschall ($09)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Departnent of Erwirormw=ntal Protection Division of Erwiromnental Quality B.lreau of Nuclear Engineering CN 415 Trenton, NJ 08625 OCT 1 3 1993
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A'ITACliMENI'
Introduction
'lhe subject Notice of Violation (NOV) was identified in canbined NRC Inspection Report 272/93-08, 311/93-08 & 354/93-06 dated May 5, 1993.
'Ihe NOV cited three examples where the requirements of 10CFR50.59 were not fully met.
In a letter dated June 7, 1993, PSE&G resporxied to the NOV.
By letter dated August 30, 1993 the NRC notified PSE&G that the response to example #2 was acceptable, however, a revised response was required for examples
- 1 arxi #3.
'!his letter provides a revised response to examples
- 1 arxi #3.
PSE&Gs response to example #2 remains the same arxi has been reiterated here. 'Ihis letter constitutes our revised response to the Notice of Violation arxi supersedes our initial response letter dated June 7, 1993 in its entirety.
Notice of Violation 10CFR50.59 (B) (1) states, in part, that records of charges to the facility as described in the Updated Final Safety Analysis Report (UFSAR) " *** must include a written safety evaluation which provides the basis for the detennination that the charge, test, or experiment does not involve an unreviewed safety question.*i
Contrary to the above, the licensee made the followirg dlan:;Jes to the facility as described in the UFSAR arxi did not provide written safety evaluations providi.m the basis for a detennination that an unreviewed safety question was not involved.
1.
Ho:pe Creek Deficiency Report HI'E 92-230 documented a use-as-is disposition for unqualified gauges in the glarxi seal portion of the High Pressure Coolant Injection (HPCI)
system, including chargi.rg the oormal position of the isolation valves for these gauges fran open to closed, which changed the facility as described in UFSAR Figure 6.3-2 because it shows the gauges within the safety-related l:x::JuOOary arxi the isolation valves as being nonnally open.
2.
Salem Unit 1 Temporary Modificatiai '!MR 92-031 provided telrporary pc7ft1er fran the l~ vital bus (oonnal power is fran the lB vital bus) to the Salem l No. 12 Auxiliary BuildinJ Fan, which charged the facility as described in Tables
'8.3-2, 8.3-3, am Figure 8.3-4A in the UFSAR.
3.
Salem Unit 2 'I'errp:>rary Modificatiai '!MR 92-043 installed a terrporary "blank flan;Je in the Service water system upstream of marrua1 isolation valve 22SW414, \\tli.dl charged the facility as shown on Figure 9.2-lB in the UFSAR.
'1HE VIOIATION *
Reason for the Violation 1.
Deficiency Report HI'E 92-230
'!he originally installed pressure gauges needed replacement.
PSE&G's Managed.Maintenance Infonnation System (MMIS) listed the subject pressure gauges as safety related, although the part number in:licated non-safety related. '!he verxior (GE)
was contacted in an attenpt to procure safety related gauges.
'Ibey stated that they do not make safety related gauges for that application. '!he non-safety related pressure gauges were installed during the 4th refueling outage to support system testing' am were left in-place.
Hope Creek Deficiency Report (DR)92-230 was written to address this issue. '!he DR was dispositioned "use-as-is" with the root valves maintained in the closed position.
'!he accanpanying lOCFRS0.59 applicability review detenni.ned that the gauges did not change the facility as described in the SAR.
'!his was based on the review of a number of Hope Creek UFSAR sections, including Section 6. 3 * 2 * 2.1. 'Ibis section states that failure of the glan:l seal portion of the High Pressure Coolant Injection (filcr) system (of whidl these gauges are a part) will not prevent the mcr system from fulfilling its core cooling objective.
However, the review corxiucted did not identify am document two other UFSAR sections that further describe the subject gauges.
UFSAR Table 3.2-1, Part V.c.10, Note 10, identifies these root valves am instnnnent lines (am therefore the gauges) as Quality Group D (non-safety-related). 'Ibis is consistent with section 6. 3. 2. 2.1.
However, UFSAR Figure 6.3-2 depicts these gauges as being within the "Q" (safety-related) bouroary am in:iicates the root valves are nonnally open.
'!his is inconsistent with section 6.3.2.2.1 am Table 3.2-1 am represents a discrepancy within* the UFSAR.
'!he use-as-is disposition of the m represented a change to the facility as it is described in Figure 6.3-2 (non-safety related gal¥Jes instead of safety-related gauges am root valves charged fran open to closed). 'Iherefore, in accordanJe with our procedures, the awlicability review should have resulted in a safety evaluation.
2.
Temporai:y Modification 'IMR 92-031 salem Unit 1 'l'emp:>rai:y Modification ('I'-*:xi) 'IMR 92-031 provided terrporai:y power from the lC Vital Bus to 12 Auxiliary Building Stwly Fan (nonnal power is from 1B Vital Bus). 'Ibis T-Mcd was similar to a previrus ~'
'IMR
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92-005, which provided temporai:y J?C:Mer from the lC Vital Bus to 12 F\\lel Hamling Buildirq Exhaust Fan, No.1 Battery Room Exhaust Fan, an:l No.1 Radiation Monitor sample Pump (nonral p:JWer is from 1B Vital Bus) *
'!he same ~i.neer processed both T-Mods.
'!MR 92-005 was *
evaluated as a ~e to the facility as described in the SAR; it received SORC review an:i approval.
'!he author believed that '!MR 92-031 involved the same issues an:i referenced the previous T-Mod ('!MR 92-005) for a discussion of cable separation concerns.
A copy of '!MR 92-005 was attached to '!MR 92-031.
Since '!MR 92-005 was SORC approved with no unreviewed safety question (USQ) identified, the author sunnised that he could ref erenc:::e the previous T-Mcd an:i disposition*'IMR 92-031 as no change to the facility as described in the SAR.
'Ibis conclusion is clearly incorrect.
Each 50.59 review I1UlSt be irrleperrlently carpleted.
3.
Temporacy Modification CT-Modl '!MR 92-043 T-Mod '!MR 92-043 docurrented the installation of a temporai:y blank flange within a Service Water (SW) header tagged out for maintenance.
'lhe backgrourxi on this T-Mcd is as follows:
On June 11, 1993 a portion of pipe in the Salem 22 service water (SW) chiller retmn header was leakin;J am in need of replacement.
(See attached figure). '!his pipe was upstream of isolation valve 22SW414.
'IWo chiller comensers to.iere required to maintain operability of the Emergercy Control Room Air OJOOitioner (ECAC) *
'!his meant that, in addition to Chiller OJrxienser 23, either Chiller Corxienser 21 or 22 was required to be in operation.
In order to maintain Chiller OJrxienser 21 or 22 in operation, (with Chiller Corxienser 23 operatirg) a blank flange was installed upstream of isolation valve 22SW414 between existirg break flanges.
OUr previous response stated that the blank flange merely supplemented the closed isolation valve (22SW244) for SW header separation. However, that infonnation was miscammunicatei.
'lhe blank flange an:i valve 22SW414 served as isolation points for the leaking section of pipe.
'!he cognizant ~ineer prepared T-Mcd '!MR 92-043 to doo.nnent installation of the tenporai:y blank flange in the SW system.
A documented lOCFR 50.59 applicability review was perfonm for T-M>D 'lMR 92-043 as required by PSE&G procedures.
'!he applicability review concluded that installation of a blank flange in the SW system was not a dlar¥Je to the facility as described in the UFSAR.
'!his was based on considerirg the blank flange instcillation to be in support of maintenance.
PSE&G Administrative Procedure NC.NA-AP.ZZ-0059(Q) (NAP-59)
establishes the process whereby FSE&G meets the requirements of lOCFRS0.59.
NAP-59, Section 6.2.4 states that
'
maintenance activities "nonnally do not require a safety evaluation." '!he installation of the blank flange was considered to be a maintenance activity based on the followirq:
'!he blank flange was in.stalled to support maintenance (PiPe replacement).
'!he blank flange was installed per ASME Code requirements an:1. perfo:nned the same function as closed valve 22SW414.
('!here were no components, other than a closed drain valve, between the blank flange an::l valve 22SW414).
When the pipin:;J replacement was completed, the blank Was renoved.
In interpreti.n; the blank flange installation to be a maintenance activity, the applicability review concluded that a safety evaluation was not necessacy.
However, NAP-59, Section 6.2.1 in1icates that temporary design changes involvi.n; disconnected pipin:J or renoval. of components should be considered a "chan;Je." since 8ale.m UFSAR Figure 9.2-lB, Sheet 5 depicts this section of the Service Water system, the applicability review should have resulted in a safety evaluation.
It should be noted that the inf onna.tion included in the doannented applicability review would have been used as supportin:J information in a safety evaluation if one had been written.
Corrective Action Taken 1.
'!he 50.59 applicability review for DR HIE 92-230 has been revised to reference the two additional UFSAR sections (Table 3.2-1 am Figure 6.3-2). Since the use-as-is disposition of the DR represents a chan;Je to the facility as it is described in Figure 6.3-2, (non-safety related gauges instead of safety-rel_ated gauges am root valves cban;Jed from open to closed) a lOCFRS0.59 safety evaluation has been perf onned am concluded that the configuration chan;Je does not represent an unreviewed safety question. Also an engineering change has been implemented to make UFSAR Figure 6. 3-2 consistent with the rema.irrler of the UFSAR.
ressons leai:ned fran this example have been rolled down to department system engineers to ensure they are aware of the requirements am management expectations.
2.
With regard to T-MJD 'R-031, the awropriate department manager coun.seled the author on the 50. 59 process am stressed why his action was unacceptable.
We con:hlcted a review of previously oampleted 50.59s to identify any similar instances.
'!he review concluded that this example was not safety significant an::l was an isolated incident involvin:J one plant engineer.
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'!his incident has been discussed with all department engineers, to ensure they are aware of the requirements and management expectations *
3.
With regard to T-M:>D 'IMR 92-043, the blank flange was removed upon replacement of the leaking pipe and the co:rrlition no longer exists.
'Ihe lessons learned from this will be djscussed with department system engineers to ensure they are aware of the requirements arrl management expectations.
Corrective Actions to Prevent Recurrence PSE&G considers these three exanples as unique instances of 10CFR50. 59 ilrplementation shortcomings.
'Ihese three exanples will be forwarded to the Nuclear Training Department to use as exanples in the lOCFRS0.59 training nOOul.e.
'Ihe training nOOul.e will also address circlnnstances where conflictin;J statements or figures exist within the UFSAR.
Status of Compliance PSE&G is in full ccmpliance.
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FIGURE DEPICI'ING IllSTALIATION OF BIANK FIANGE (Example #3)
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