ML18093B234

Responds to NRC 880912 Ltr Re Violations Noted in Insp Repts 50-272/88-16 & 50-311/88-16.Corrective Actions:Documented Review Will Be Performed Re Prioritization & Completion of Work Orders for PASS by 881201 to Prevent Recurrence

ML18093B234
Person / Time
Site:	Salem
Issue date:	10/19/1988
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88174, NUDOCS 8810250380
Download: ML18093B234 (6)

Text

Public Service

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Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nuclear Operations OCT 19 1988 NLR-N88174 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO VIOLATION 272/88-16-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received yoQr Notice of Violation tran~mitted with your letter of September 12, 1988, "Combined Inspection 50-272/88-16 and 50-311/88-16 11

• Per telecon with Mr. P. Swetland; PSE&G was granted an extension to the response due date, *until October 19, 1988. In addition to addressing the violation yoQr letter requested PSE&G respond to additional concerns discussed in Section 9 of the Inspection Report. PSE&G's responses are provided in the Attachment.

If you have any questions concerning this response please contact us.

Sincerely, Attachment c Mr. J. c. Stone Licensing Project Manager Mr. R. w. Borchardt Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 8810250380 881019 PDR ADOCK 05000272 G PNU

ATTACHMENT In your Notice of Violation you requested PSE&G to address the violation concerning the Post Accident Sampling System (PASS) and the additional concerns presented in Section 9 of the Inspection Report. Section 9 also adds further discussion on the details of the violation. PSE&G has reviewed the subject report and reviewed past documentation to attempt to fully and adequately address all of the concerns. Each concern and it's corresponding response is presented below.

NOTICE OF VIOLATION Technical Specification (T.S.) 6.8.4(e) requires in part that the Post Accident Sampling System (PASS) program include procedures for sampling and analysis, and provisions for maintenance of PASS sampling and analysis equipment. T.S. 6.8.l requires that procedures be established, implemented and maintained.

Contrary to the above, on July 20, 1988 it was determined that PASS sampling and analysis equipment was not properly maintained and procedures for sampling and analysis were not properly implemented in that (1) PASS Reactor Coolant System (RCS) sample flow and pressure gauges have been broken since January 1988, (2)

RCS sample flow and pressure were not being set and verified in accordance with established PASS sampling and analysis procedures during sampling evolutions, and (3) the PASS Abnormal Condition/Troubleshooting Guide was not issued in a timely manner.

RESPONSE

1. CORRECTIVE STEPS TAKEN a" The flowrator (RC-FI-2) and pressure gauge (RC-G-3) were repaired on August 30, 1988.

b. The PASS Abnormal Condition/Troubleshooting *Guideline was issued on July 27, 1988

2. CORRECTIVE STEPS TO BE* TAKEN.TO PREVENT FURTHER VIOLATIONS

a. A documented review will be performed, regarding prioritization and completion of work orders for the PASS, by December 1, 1988 to prevent the recurrence of unacceptable delays in the implementation of repairs on future equipment problems *

b. Chemistry technicians and supervisors will be re-instructed on the importance of following procedures; emphasizing the proper actions to take where equipment is specified in the procedure and that equipment is inoperable. This training will be completed by December 1, 1988.

3. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

a. Full compliance was achieved on August 30, 1988.

UNR 272/88-16-02 In review of NUREG-0737 Item II.B.3, Criterion 8 requirements, the inspector determined that action by the licensee is needed to ensure the capability of obtaining backup samples. This item is unresolved pending licensee review of PASS in-line monitored parameters and making provisions for backup analysis capability including procedures and training (T.S. 6.8.4.e requirement) and integrated dose estimates (NUREG-0737, Item II.B.3, criterion 6).

RESPONSE

The position of PSE&G has been (Reference letters dated August 31, 1983 and March 6, 1985) and still is that it did not anticipate taking undiluted backup grab samples but would instead flush, repair the instrument and perform in-line analyses in a timely manner. PSE&G has been informed that the NRC now believes that this is unacceptable. Consequently, PSE&G is essentially just starting to re-address the methods of obtaining, handling, analyzing, storing and disposing of undiluted backup grab samples. In the interim, PSE&G will maintain our previously committed on~line backup capabilities until a full backup grab

. sample program is implemented.

At present the extent of work and engineering changes necessary to fully implement an undiluted grab sampling and analyses program is not clearly defined.

The engineering department of PSE&G. will develop a project scope proposal by February 15, 1989. This project scope shall include the required undiluted backup sampling, analyses, equipment, procedures, integrated dose estimates and training. We estimate the *undiluted backup grab sample capability to be fully implemented by December 19_89.

UNR 272/88-16-03 The inspector had several concerns relative to the control and testing of ARM 2R52. The range of the monitor is o - 10,000 R.

The inspector questioned whether (1) electrical calibration, source checks and functional alarm testing are performed to . .

verify operation of the monitor especially to verify accuracy at the low end of the scale (.lR - lR); (2) whether controls are implemented to ensure compliance with T.S. 6.12 requirements for high radiation areas; and whether ARM 2R52 is included in the Radiation Monitoring System (RMS) program manual. Control and testing of ARM 2R52 is unresolved pending licensee resolution qf these issues.

RESPONSE

1. Electrical calibration, source checks and functional alarm testing is performed IAW procedure 2IC-4-1.084. The initial functional testing and calibration were performed on January 1, 1987. The testing is required to be performed on a once per 18 month frequency and is due October 30, 1988. The calibration procedure covers all ranges of the monitor including the O.lR to lR. Radiation Protection Services is currently evaluating ARM 2R52 for the possible addition of an audible alarm.

2. a. Controls are implemented, to ensure compliance with Technical Specification 6.12, by the station Administrative Procedures and Emergency Operating

'Procedures. This is accomplished by the use of alarming dosimeters, radiation work permits and precautions in PASS procedures. Radiation workers are issued dose limits and dose rate instruments as required to control access and dose in high radiation areas.

b. We reviewed and found that ARM 2R52 is not in the Radiation Monitor System manual. The monitor will be added to the manual by Radiation Protection Services by December 31, 1988.

UNR 272/88-16-04 The inspector requested that the licensee verify that work orders for all designated valves have been completed.

RESPONSE

PSE&G has verified that that all work orders for the appropriate

• PASS valves have been completed since December 19,1986.

UNR 272/88-16-05 It was noted that hydrogen comparison results between RCS and PASS samples are not consistent. The licensee committed to investigate the reason for the inconsistency and resolve the problem. The inspector will review the licensee's corrective actions.

RESPONSE

The calibration procedure for the PASS gas chromatograph will be revised to include multipoint curves. The procedure revision and the revised calibration curves shall be completed by December 1, 1988. A preliminary multipoint curve has been developed and.the most recent data demonstrates that the comparison results are acceptable.

UNR 272/88-16-06 The inspector noted that only one train of component cooling (CC) water is available for sample coolers for the PASS. During lengthy outages of the cc train the licensee rigs demineralized water to the sample coolers, but backup cooling provisions are apparently not made for short duration CC unavailability.

Provisions for implementation of a backup method for non-redundant isolated PASS support systems is unresolved pending licensee review and action .

.RESPONSE NUREG-0737 does not require redundant support systems for the PASS. The component cooling system also does not fit the description of an isolated system in that it is normally available and lined up to support the PASS. The isolated auxiliary system mentioned in Criterion 3 of the NUREG refers to systems that would be normally isolated and would therefore require action to be taken to place the system in service. By example, it also seems to imply that it applies only to the direct sample path (RCS, Containment Atmosphere).*

Taking the component cooling supply out of service prevents the PASS system from being able to collect a proper sample. For normal Technical Specification items there is a designated time limit and appropriate action guidance provided. The PASS does not have this type of guidance as the NRC decided it was not a "shutdown" item. Although no specific guidance is provided for.

the time the system is down, PSE&G believes that the system should be repaired promptly and makes a good faith effort to meet this .

In cases where the component cooling water will be impaired for longer periods of time, PSE&G establishes a back-up means of cooling to ensure PASS operability. Please note that a back-up might not be needed if the maintenance being performed is minor and the system could be promptly restored. It should also be noted that the PASS sample coolers can be supplied by either of the two Unit 2 component cooling water trains.