ML18094A597

Responds to NRC 890703 Ltr Re Violations Noted in Insp Rept 50-272/89-17.Corrective Actions:Inservice Testing Program Will Be Evaluated to Determine Appropriate Method for Testing Accumulator Check Valves & Training Plan Developed

ML18094A597
Person / Time
Site:	Salem
Issue date:	08/02/1989
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89149, NUDOCS 8908080330
Download: ML18094A597 (7)

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Stanley LaBruna Vice President - Nuclear Operations Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609-339-4800 AUG 0 2 1989 NLR-N89149 United States Nuclear Regulatory Commission Document Control Desk Washington DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION RE~ORT NO. 50-272/89-17 SALEM GENERATING STATION UNIT NO. 1 DOCKET NOS. 50-272 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated July 3, 1989, which included a Notice of Violation concerning failure to notify the NRC within four hours and failure to have SORC review a procedure that contained an SSI. Pursuant to the requirements of 10 CFR 2.201, our response to this Notice of Violation is provided in the attachment to this letter.

Should you have any questions in regards to this transmittal, do not hesitate to call.

Sincerely,

s. LaBruna Vice President -

Nuclear Operations Attachment

• Document Control Desk NLR-N89149 C Mr. J. c. Stone 2 AUG 0 2 1989 Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

..J ATTACHMENT 1

ATTACH~ENT 1 VIOLATION A Technical Specification 6.8.2 requires that surveillance and test activity procedures shall be independently reviewed to make a determination as to whether the procedure contains a significant safety issue (SSI). Additionally, Technical Specification 6.5.1.6 requires that the Station Operations Review Committee (SORC) shall review procedures that involve an SSI.

Contrary to the above, on May 20, 1989, Surveillance Procedure No. SP(0)4.0.5-V-SJ-6, "Inservice Testing - Valves - Safety Injection," which involved an SSI, injection of nitrogen into the reactor coolant system, was not reviewed by SORC.

RESPONSE

The test methodolbgy for the Accumulator discharge check valves was developed in 1982 to provide full stroke testing.

This test method was developed to comply with an IST program submittal for NRC approval. Inspection Report 50-272/82-23, issued on October 5, 1982, documents the inspectors review of the status of the Salem IST program in regards to the submittal. A major portion of the review was to finalize an NRC Staff evaluation of the submittal. The inspector reviewed the procedures and indicated that the minimum design flow rates were not identified in the test procedures and were needed to demonstrate the minimum safety analysis design flowrate criteria through the valves. Surveillance procedure SP(O) 4.0.5-V-REFUEL was developed for Units 1 and 2 to meet this requirement.

The Safety Evaluation Report for the IST Program submittal was issued on April 12, 1983. In the evaluation section of the SER the NRC indicated that Salem should investigate a means to satisfy the NRC full-stroke exercise criteria (demonstrate safety analysis design flowrate through the check valves). SP(O) 4.0.5-V-REFUEL procedure provided the means to full flow test the check valves.for the IST Program.

This procedure was reviewed by SORC in 1982 and again in 1984.

When the SP(O) 4.0.5-V-REFUEL procedure was broken down into separate procedures as a procedural enhancement, during the two year review process, SP(O) 4.0.5-V-SJ-6 was developed. This procedure specifies the same testing methodology as the previous procedure and was reviewed by a Station Qualified Reviewer. The SQR determined that the procedure did not contain a SSI.

The SQR was performing a two year review; therefore, he was reviewing the changes and comments with respect to the technical review. However, since he was aware that* the procedure was performed satisfactorily using the steps specified by the procedure and that the procedure had been

• SORC approved, he did not perform a full technical basis review of the old procedural steps. It did, however, receive the required two year review specified by procedure.

When it was decided that the procedure should be separated to reduce the confusion involved with multiple tests covered by one procedure, it was felt that the steps were the same and thus the review performed was adequate. The procedures do not provide specific guidance on the exact review steps to perform if the two year review results in new procedures being developed to seperate an old procedure.

In reviewing the guidance of AP-32, Implementing Procedures Program, the guidance provided would indicate that an SSI was not involved as the examples provided discuss revising the procedure for specific purposes. In this case of the SP(O) 4.0.5-V-SJ6 procedure the revision was made to make the procedure more usable not to change order of steps or step method. Therefore, by the SS! criteria an SS! was not involved. However, review of the incident did reveal that the original procedure (SP(0)4.0.5-REFUEL) should have required a 50.59 safety evaluation in that it did involve a change to the a test described in the FSAR.

Corrective Actions Taken Use of the accumulator discharge procedure SP(0)4.0.5-V-SJ-6 was immediately discontinued.

The weaknesses with the SP(0)4.0.5-V-SJ-6 and AOP-RHR-1 procedures were reviewed with the Operations Procedure Writers.

Corrective Actions to Prevent Recurrence PSE&G will evaluate the !ST Program to determine the appropriate method for testing the accumulator check valves.

This will be determined by October 24, 1989.

PSE&G will revise appropriate procedures for accumulator check valve test after method is determined, and ensure SORC review. To be completed by December 31, 1989.

A training plan will be developed and procedures revised to incorporate the information and improvements provided by the Engineering and OSR evaluations of the event. This will be completed by September 29, 1989.

PSE&G is currently developing an extensive procedure upgrade program that will ensure that high risk procedures are identified and that adequate precaution and human factor considerations are included .

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To assist the procedure upgrade effort, PSE&G will establish an independent review group to perform SQR review to ensure that all commitments and 10CFR50.59 requirements are being met and maintained. The procedure upgrade effort is scheduled for completion by December, 1991.

PSE&G will also provide additional training to the present SQR reviewers, by October, 1989, to ensure that they remain fully astute of the SSI requirement and the appropriate procedural requirements resulting from current revisions to the Administrative Procedures.

PSE&G will revise the existing guidance on two year reviews to ensure that specific guidance is provided for instances where the revision process leads to the development of new procedures. This will be completed by December, 1989.

PSE&G IS IN FULL COMPLIANCE.

VIOLATION B 10CFRS0.72(b) (2) "Four-hour reports," requires that the licensee shall notify the NRC within four hours of the occurrence of any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to remove residual heat.

Contrary to the above, on May 20, 1989, when the residual heat removal capability was lost for about fifty minutes, the licensee did not notify the NRC within four hours.

RESPONSE

PSE&G DOES NOT CONTEST THE VIOLATION Corrective Actions Although the four hour report was not made in accordance with the Event Classification Guide (ECG) PSE&G recognized that the seriousness of the incident warranted NRC attention, and contacted the NRC on Saturday, May 20, 1989, to provide the NRC with the significant information associated with the event.

When PSE&G management recognized that a four hour report should have been made. PSE&G promptly made the report on Monday, May 22, 1989.

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I Prior to the loss of RHR event, an effort to review and upgrade the ECG was undertaken by the Emergency Preparedness Group. The ECG was reviewed against 10CFR50.72 and 50.73, NUREG-1022 and NUREG-0654 to insure consistency with the regulations. Cross references to the applicable reporting requirements were added to the ECG subsections.

Additionally, the sections were revised to facilitate usage.

The revised ECG has several advantages over the version in use at the time of the event. The revised sections are tied directly to plant conditions (i.e. , "Loss of Decay Heat Removal" is more explicit than coupling the "Safeguards" and "Technical Specifications" sections for a single event).

All of the applicable emergency and non-emergency events are addressed in the "Loss of Decay Heat Removal" section.

Cross references to the applicable regulatory requirements help assure that the ECG addresses the reporting criteria, and also facilitates update of the ECG in light of changes in regulations. This revision will correct the ECG deficiency relative to the loss of RHR and assure that events are properly reported in accordance with regulations.

The revised ECG was issued on May 26, 1989.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE The new ECG was reviewed against the regulations by the Licensing Department to insure compliance with the regulations.

During the next requal cycle (scheduled to begin in September, 1989) the licensed operators will be provided with additional ECG and 10CFR50 training to strengthen their understanding and usage of the ECG with regard to the appropriate regulatory requirements.

PSE&G IS IN FULL COMPLIANCE