ML18095A343
| ML18095A343 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/10/1990 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N90117, NUDOCS 9007170134 | |
| Download: ML18095A343 (16) | |
Text
. .
- Public Service Electric and Gas.
Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1100 Vice President and Chief Nuclear Officer
~JUL' l ~ 1.Q.
NLR-N90117 Ref: LCR 86-11 United States Nuclear Regulatory Commission Document Control Desk 0 Washington, DC 2055*5 Gentlemen:
REQUEST FOR AMENDMENT FACILITY OPERATING LICENSES DPR-70 AND DPR-75 SALEM GENERATING STATION UNIT NOS. 1 AND 2 In accordance with your letter dated March 30, 1990, we hereby revise our request for amendment to Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station, Unit Nos. 1 and 2, transmitted to you by letter dated November 3, 1987 (LCR 86-11).
This revised amendment request, which replaces those previously submitted in their entirety, would add a statement to each of the Salem licenses that the terms of the May 6, 1983 order have been satisfied by incorporating the long term corrective action requirements into the Updated Final Safety Analysis Report.
Chctnges to those corrective actions will be controlled in accordance with 10 CFR 50.59.
A copy of this._revised amendment request has been forwarded to the State of New Jersey in accordance with the requirements of 10 CFR 50.91.
If you have any questions regarding this submittal, please do not hesitate to contact us.
Sincerely, Attachments flOOI
'It*
Document Control Desk 2 NLR-N90117 JUL 1 0 '1990 c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, 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
REF: NLR-N90117 STATE OF NEW JERSEY )
) SS.
COUNTY OF SALEM
- s. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated July 10, 1990 , concerning the Salem Generating station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
this
- ."-; l.o tf Subscribed and Sworn to before me
~
o<l4r. day of ~
- m. fl/IJNJ/Ltlll
' 1990 Notary Public of New Jersey VANITA M. rJJARSHALL NOTARY PUBLIC OF t~EW JERSEY My cOmmisslon Expires May 6, 1993 My Commission expires on ~~~~~~~~~~~~~~~
PROPOSED CHANGE TO FACILITY LCR 86-11 OPERATING LICENSES DPR-70 AND DPR-75 Page 1 of 3 Proposed Change We request that Operating License DPR-70 be amended to add a new Section I to read:
"The terms of the May 6, 1983 Order have been satisfied by the incorporation of the long term corrective action requirements into the Salem Updated Final Safety Analysis Report (Appendix 7.A)."
We request that Operating License DPR-75 be *amended to add a new Section M to read:
"The terms of the May 6, 1983 Order have been satisfied by the incorporation of the long term corrective action requirements into the Salem Updated Final Safety Analysis Report (Appendix 7.A)."
Discussion On May 6, 1983, the Nuclear Regulatory Commission issued an Order modifying the operating licenses for the Salem Generating Station, Unit Nos. 1 and 2. The Order referenced a series of letters in which PSE&G had submitted its corrective action program in response to the reactor trip breaker failures. This corrective action program included short term, interim and long term actions.
Subsequently, .the Order was modified by letter dated January 31, 1984, to change the. implementation schedule for several long term actions, and again on March 18, 1986, to remove the requirement to submit Nuclear Oversight Committee Reports on a quarterly basis. The March 18, 1986 letter also stated that the terms of the Order have been satisfactorily completed.
We have since performed a detailed review of the correspondence addressing our corrective action program and identified a total of forty-three (43) long term program commitments which we have consolidated into a new UFSAR appendix (Attachment 1). The contents of this appendix will be controlled in accordance with the provisions of 10 CFR 50.59.
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PROPOSED CHANGE TO FACILITY LCR 86-11 OPERATING LICENSES DPR-70 AND DPR-75 Page 2 of 3 The treatment of this matter by license condition is different from that accorded similarly situated plants. Commitments similar to those presently required by license condition for Salem have only been the subject of letter commitments in other dockets. The requested change will thus bring the Salem licenses into conformance with other licensees.
The programmatic controls referenced by the Order are not matters which are required to be included in the technical specifications in that they are not safety limits, limiting safety system settings, surveillance requirements, limiting control settings, limiting conditions for operations, design features or administrative controls as defined in 10 CFR 50.36 and Commission practice. Such a change is also in accordance with the Commission's policy of simplifying the provisions of the operating license and technical specifications.
This initiative will serve to improve our present program by enhancing administrative control of commitment implementation and by facilitating in-house compliance verification efforts. The change will also ease the administrative burden on the licensee and the NRC staff in that minor changes to these programs would not require the issuance of license amendments.
The consolidation of the long term program commitments in the UFSAR assures that changes to these programs will be properly controlled. Any changes involving an unreviewed safety question or a change in the technical specifications would be submitted to the Commission for prior approval.
The forty-three (43) program element descriptions are grouped in Appendix 7.A of the UFSAR under the following headings:
- Training
~ Procurement & Management
- Operating Procedures
- Maintenance & Surveillance
- Control of Vendor Information In four (4) instances, our method of implementation has evolved to respond to changing station conditions or to utilize recently developed industry standards and practices. These four are discussed in detail in Attachment 2.
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1-PROPOSED CHANGE TO FACILITY LCR 86-11 OPERATING LICENSES DPR-70 AND DPR-75 Page 3 of 3 Significant Hazards Consideration Analysis We have evaluated the proposed change and the program modifications described in Attachment 2 and conclude that they do not involve a significant hazards consideration.
- 1. The proposed change does not increase the probability or the consequences of an accident previously evaluated because all breaker-related technical specification requirements remain in effect and additional controls, beyond 10 CFR 50.59 and 50.71(e), apply as follows:
- a. Training: 10 CFR 55; Regulatory Guides 1.8, 1.58 and 1.146; Generic Letters 81-01 and 84-14; INPO 85-002,86-018, 86-025,86-026, 88-006 and 88-007.
- b. Procurement & Management: 10 CFR 50.54(a) (3); Regulatory Guides 1.33 and 1.44.
- c. Operating Procedures: Regulatory Guide 1.33; Generic Letters 83-32 and 85-09; INPO 84-024.
- d. Maintenance & Surveillance: Regulatory Guide 1.33; Generic Letters 83-27, 83-28 and 89-14; INPO 85-026,85-038 and 87-028.
- e. Control of Vendor Information: Regulatory Guide 1.33; Generic Letters 82-04, 83-28 and 90-04; INPO 84-010,87-009 and 89-015.
- 2. The proposed change does not create the possibility of .a new or different kind of accident from any previously evaluated because the change does not entail any alteration to the plant design, installed equipment or the operating procedures.
- 3. The proposed change does not involve a significant reduction in a margin of safety because the change neither impacts compliance with 10CFR50.62 nor affects the safety limits, limiting safety system settings, surveillance requirements, limiting control settings, limiting conditions for operations, design features, or administrative controls as described in the Salem Technical Specifications.
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ATTACHMENT 1 SALEM GENERATING STATION UPDATED FINAL SAFETY ANALYSIS REPORT APPENDIX 7.A PROGRAM ELEMENT DESCRIPTIONS RESULTING FROM THE IMPLEMENTATION OF THE MAY 6, 1983 ORDER
- 1. TRAINING
- 2. PROCUREMENT & MANAGEMENT
- 3. OPERATING PROCEDURES
- 4. MAINTENANCE & SURVEILLANCE
- 5. CONTROL OF VENDOR INFORMATION NLR-N90117
7.A.1 TRAINING 7.A.1.1 The difference between demand and confirmatory indications for the Reactor Protection System (RPS) shall be an integral part of initial and requalification training for all licensed operators.
7.A.1.2 The procedural steps to be taken in response to an ATWS event shall be an integral part of simulator training for all licensed operators.
7.A.1.3 Identifying the location and type of RPS indicators and alarms shall be an integral part of simulator training for all licensed operators.
7.A.1.4 First-line supervisory training will be provided to all individuals, except licensed operators, within 12 months of their assumption of supervisory duties within the station. Individuals filling positions that require the acquisition of a Senior Reactor Operator (SRO) license will complete the program within 12 months of their NRC examination date. This permits them the same time allowance for program completion as the remaining supervisory classifications while allowing them time to complete license training.
7.A.1.5 Technical training will be provided to support the professional staff not in station positions.
7.A.1.6 A formal training program will be provided for senior level supervisory personnel. This program shall also offer refresher/requalif ication training for management and senior supervisory personnel.
7.A.1.7 First-line supervisory training will address the classification of procurement documents as well as the initiation., classification, processing and closeout of work orders with emphasis on QA requirements, test/retest requirements and interdepartmental coordination.
7.A.2.2 PROCUREMENT & MANAGEMENT 7.A.2.1 Detail Specification No. 83-8248 shall require:
7.A.2.1.1 That all undervoltage trip attachments (UTAs) have incorporated all design changes identified in Westinghouse Switchgear Division Procedure NDC-ELEC-18.
7.A.2.1.2 That all UTAs be lubricated per Westinghouse Technical Bulletin NSD-TB-83-02.
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7.A.2.1.3 That the manufacturer mount on a test breaker and electrically test each UTA twenty-five (25) consecutive times without failure.
7.A.2.1.4 That the manufacturer seal the two (2) cover bolts on the movable core cover and the reset lever spring adjustment screw such that future removal of cover bolts or future screw adjustment is detectable.
7.A.2.1.5 That the manufacturer submit a Certificate of Conformance documenting the above items.
7.A.2.2 The procurement program will require item classifications by Nuclear Engineering personnel with verification by Quality Assurance personnel.
7.A.2.3 Quality Assurance personnel will conduct periodic audits of the procurement program to ensure proper item classification, application of procurement procedures and practices, as well as, to verify procedural adherence by appropriate personnel.
7.A.2.4 On a sample basis, Quality Assurance shall perform a detailed review of safety/non-safety related work orders to assure compliance to program requirements such as proper classification, etc.
7.A.2.5 A member of the Independent Safety Engineering Group (Safety Review Group) will s.erve on the Station Operations Review Committee (SORC).
7.A.3 OPERATING PROCEDURES 7.A.3.1 All procedures associated with a reactor trip have been revised to require the operator to manually trip the reactor anytime he receives a demand first out annunciator and verification of this condition on the Reactor Protection Status Panel.
7.A.3.2 The Shift Routine Logs shall require that an Overhead Annunciator Control Console and Status Panel Alarm/Indication Check be performed at the beginning of each shift.
7.A.3.3 A dedicated communicator shall be assigned to each shift.
7.A.3.4 The directive utilized by the Operating Department to verify operability of safety related equipment shall require that testing in accordance with the Technical Specifications is completed prior to declaring equipment operable.
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7.A.4 MAINTENANCE & SURVEILLANCE 7.A.4.1 PSE&G has established a program to provide traceability on the reactor trip breakers. This program ensures traceability of all work to a particular breaker and its location.
7.A.4.2 Cleaning of the breakers and Westinghouse recommended lubrication is performed on the undervoltage trip attachments (UTAs) during semi-annual testing and during each refueling outage.
7.A.4.3 Cleaning of the breaker cabinets is performed during each refueling outage. The circuit breaker rooms are cleaned by a custodian on normal work days.
7.A.4.4 Procedure M3Q-2 incorporates a range of acceptable dropout voltages and instructions to replace any devices which fall outside the specified range. In addition, new UTAs installed in the plant will be tested 10 times with a 30 minute interval between each test and any devices which fail will be rejected.
7.A.4.5 The following tests will be performed before and after the semi-annual testing:
- 3 UTA trip timing tests,
- 3 shunt trip timing tests, and
- 3 closure timing test.
7.A.4.6 A bar force (static trip) measurement and an output force (added weight) measurement will be performed after semi-annual testing and after UTA replacement.
7.A.4.7 The commitment for NRC notification is addressed by notation to Table 3.3-1 of the Salem Technical Specifications.
7.A.4.8 Surveillance testing of the main reactor trip breakers utilizing the UTA has been increased to a monthly interval. This will be accomplished utilizing existing I&C Procedures PD 18.1.1008 (.009)* and new I&C Procedures IC 18.1.010 (.011)*.
7.A.4.9 Surveillance testing of the main and bypass reactor trip breakers utilizing the shunt trip will be performed on a monthly basis utilizing I&C Procedures PD 18.1.004 (.005)*, "Train A (B) Reactor Trip Breakers and P-4 Permissive Test".
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7.A.4.10 Surveillance testing utilized to prove operability of the reactor trip breakers on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to startup frequency will provide for independent testing of the shunt and undervoltage attachments and operation of the breakers utilizing the manual trip switches.
7.A.4.11 Modifications to I&C Procedures PD 18.1.008
(.009)* and IC 18.1.010 (.011)* which are to be performed on a monthly basis have been made to provide for the utilization of the Sequence of Events recorder to monitor the response time of the main trip breakers from the Solid State Protection system. This data will be recorded as part of these procedures and also in a log.
Included in these procedures will be specific acceptance criteria requiring that if exceeded, the NRC be notified prior to the performance of any corrective action.
7.A.4.12 In addition, I&C Procedures PD 18.4.002
(.005)* have been modified to include time response testing of both the main and bypass reactor trip breakers. This surveillance testing will continue to be performed on an 18 month interval prior to restart after refueling.
- Unit No. 2 7.A.5 CONTROL OF VENDOR INFORMATION PSE&G shall establish a Vendor Document control System that encompasses the following elements:
7.A.5.1 Procedures regarding control of vendor manuals.
7.A.5.2 Review of vendor manuals by Nuclear Engineering to determine applicability to installed equipment.
7.A.5.3 Identification of manuals applicable to Q-listed equipment.
7.A.5.4 Requirement that all safety related vendor manuals be incorporated under the Vendor Document Control System.
7.A.5.5 Issuance of controlled, numbered copies of vendor manuals.
7.A.5.6 Review of manual revisions and new manual issues by station user departments to ensure incorporation of applicable new information into applicable procedures.
7.A.5.7 Periodic audit of controlled copy holder files to ensure existence of latest issues.
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7.A.5.8 Establish and maintain interface with vendors of Q-equipment to assure receipt of most recent applicable information.
7.A.5.8.1 Establish and maintain information update programs with key vendors such as Westinghouse (NSSS supplier), ALCO (Diesel Mfr.), General Electric, etc.
7.A.5.8.2 Participate in the NPRDS and SEE-IN programs which comprise INPO's Vendor Equipment Technical Information Program (VETIP).
7.A.5.8.3 Establish a focal point within the Nuclear Department for receiving and processing all uncontrolled vendor technical information received on site for the Salem units.
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ATTACHMENT 2
- 1. COMMITMENT 7.A.1.4 First-line supervisory training will be provided to all individuals, except licensed operators, within 12 months of their assumption of supervisory duties within the station. Individuals filling positions that require the acquisition of a Senior Reactor Operator (SRO) license will complete the program within 12 months of their NRC examination date. This permits them the same time allowance for program completion as the remaining supervisory classifications while allowing them time to complete license training.
ORIGINAL DESCRIPTION "In an effort to develop and maintain a high caliber of supervisory personnel at our nuclear generating stations, we have initiated the development of a training program for first-level supervisors. This training will be provided for an individual prior to his assignment to supervisory responsibilities in the station, as well as to all first-level supervisors now providing supervisory functions."
COMMENTARY Based on the number of newly hired or promoted individuals, the current program scheduling guidelines for the Nuclear Department only call for presentation of the supervisory training twice each year. Also, newly hired/promoted supervisors are under the direct supervision of individuals with a greater level of experience who can provide the necessary skills in the interim through coaching.
- 2. COMMITMENT 7.A.1.7 First-line supervisory training will address the classification of procurement documents as well as the initiation, classification, processing and closeout of work orders with emphasis on QA requirements, test/retest requirements and interdepartmental coordination.
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ORIGINAL DESCRIPTION "Proficiency in determination of classification of work orders and procurement documents will be maintained by on-going periodic training and indoctrination sessions.
To maintain proficiency in the initiation, processing and closeout of work orders ongoing training will be conducted, with emphasis on Quality Assurance requirements, test/retest requirements, and interdepartmental coordination."
COMMENTARY The training elements from the original description paragraphs have been consolidated into paragraph 7.A.1.7.
our first-line supervisory training covers all station administrative procedures to include procurement, work orders and usage of the Managed Maintenance Information system (MMIS) for classification purposes.
Paragraph 7.A.2.3 reiterates our quality commitment to monitor and evaluate the procurement process. Audit findings, to include any concerning the classification of procurement documents, are formally brought to the attention of management in accordance with the provisions of our QA program. Refresher training may be indicated at that time.
Administrative control of work order classification is discussed in Item 3, below.
- 3. COMMITMENT 7.A.2.4 On a sample basis, Quality Assurance shall perform a detailed review of safety/non-safety related work orders to assure compliance to program requirements such as proper classification, etc.
ORIGINAL DESCRIPTION "An independent Quality Assurance review of the classification of each non-safety related work order is now required prior to commencing work."
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COMMENTARY By 1986, work order classification had improved significantly at Salem due to improvements to the Master Equipment List (MEL), including both its accuracy and its issuance as a controlled document. We had also increased our emphasis in training on the proper use of the MEL for personnel who classify or review work orders.
Accordingly, we went to a surveillance mode of monitoring this activity.
Since that time, we replaced the MEL with MMIS, (Managed Maintenance Information System).
- 4. COMMITMENT 7.A.5.8 Establish and maintain interface with vendors of Q-equipment to assure receipt of most recent applicable information.
7.A.5.8.1 Establish and maintain information update programs with key vendors such as Westinghouse (NSSS supplier), ALCO (Diesel Mfr.), General Electric, etc.
7.A.5.8.2 Participate in the NPRDS and SEE-IN programs which comprise INPO's Vendor Equipment Technical Information Program (VETIP).
7.A.5.8.3 Establish a focal point within the Nuclear Department for receiving and processing all uncontrolled vendor technical information received on site for the Salem units.
ORIGINAL DESCRIPTION "Identification of vendors for Q-equipment who have manual updating programs, and periodic contact with these vendors to assure receipt of most recent applicable information."
COMMENTARY In response to an acknowledged need, PSE&G established a Nuclear Department focal point for uncontrolled vendor information. Between May, 1983 and November, 1986 this group processed some 1,382 technical documents.
In line with other utilities, we are following the guidelines of INPO and participate in INPO's VETIP program. VETIP provides a forum for information exchange and evaluation among utilities and, in conjunction with the site-specific vendor update programs referenced above, provides an effective vendor interface.
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Our original practice of contacting vendors on an annual basis initially produced significant amounts of technical information that we incorporated into our vendor document system. Subsequently, that activity provided less and less new technical information. Vendors became progressively reluctant to respond to our requests and the bulk of the information we received dealt more and more with new product lines. For example, in 1985 we sent out 263 letters to vendors and received 162 responses that resulted in only four (4) usable items of information. Consequently, we have discontinued that practice.
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