ML18100A663
| ML18100A663 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 10/13/1993 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N93160, NUDOCS 9310210223 | |
| Download: ML18100A663 (9) | |
Text
Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations OCT 13 1993 NIR-N93160 United States Nuclear Regulatory Conunission Document Control Desk Washington, D.C.
20555 Gentlemen:
REVISED REPLY 'IO A NOrICE OF VIOIATION NRC INSPECI'ION REIDRI' NOS. 50-272 & 311/93-08 AND 50-354/93-06 SALEM AND HOPE CREEK GENERATING STATIONS IXlCKEI' NOS. 50-272, 50-311 AND 50-354 Public Service Electric and Gas Conpmy (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.
D.lring a telephone conversation with Mr. J. White (NRC), a response due date of October 13, 1993 was agreed tJIX>n.
Pursuant to the provisions of 10CFR2.201, PSE&G hereby submits its revised response to the Notice of Violation. '!his revised response supersedes our previous response letter dated June 7, 1993 in its entirety.
Should you have any questions on ;this transmittal, please contact us.
Attachment
?1nn,~-::
9310210223 931013 PDR ADOCK 05000272 G
PDR Vice dent...;
Nuclear Operations
Document Control Desk NIR-N93160 2
c Mr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulatory Cormnission 475 Allendale Road King of Pn.Jssia, PA 19406 Mr. J. c. Stone, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission one White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. s. Dembek, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission one White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. C. Marschall (S09)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 OCT 1 3 1993
A'ITACHMENT Introduction
'Ihe subject Notice of Violation (NOV) was identified in c::nnbined NRC Inspection Report 272/93-08, 311/93-08 & 354/93-06 dated May 5, 1993.
'lhe NOV cited three exanples where the requirements of 10CFRS0.59 were not fully met.
In a letter dated June 7, 1993, PSE&G responded to the NOV.
By letter dated August 30, 1993 the NRC notified PSE&G that the response to exanple #2 was acceptable, however, a revised response was required for examples
- 1 and #3.
'Ibis letter provides a revised response to exanples
- 1 and #3.
PSE&Gs response to exanple #2 remains the same and has been. reiterated here. '!his letter constitutes our revised response to the Notice of Violation and supersedes our initial response letter dated June 7, 1993 in its entirety.
Notice of Violation 10CFRS0.59 (B) (1) states, in part, that records of changes 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 change, test, or experiment does not involve an unreviewed safety question. 11 Contrary to the above, the licensee made the following changes to the facility as described in the UFSAR and did not provide written safety evaluations providing the basis for a detennination that an unreviewed safety question was not involved.
- 1.
Hope creek Deficiency Report HI'E 92-230 documented a use-as-is disposition for unqualified gauges in the gland seal portion of the High Pressure Coolant Injection (HPCI) system, including changing the nonnal position of the isolation valves for these gauges from open to closed, which changed the facility as described in UFSAR Figure 6. 3-2 because it shows the gaug~ within the safety-related boundary and the isolation valves as being nonnally open.
- 2.
Salem Unit 1 Temporary Modification '!MR 92-031 provided tenporary power from the lC vital bus (nonnal power is from the 1B vital bus) to the Salem 1 No. 12 Auxiliai:y Building Fan, which changed the facility as described in Tables 8.3-2, 8.3-3, and Figure 8.3-4A in the UFSAR.
- 3.
Salem Unit 2 Tenporary Modification '!MR 92-043 installed a tenporary blank flange in the Service Water system upstream of manual isolation valve 22SW414, which changed the facility as shown on Figure 9.2-lB in the UFSAR.
/
RJBLIC SERVICE EIECI'RIC AND GAS COMPANY (PSE&G) OOES Nor DISRJTE
'!HE VIOIATION.
Reason for the Violation
- 1.
Deficiency Report HTE 92-230
- 2.
'!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 mnnber indicated non-safety related. 'lhe vendor (GE) was contacted in an attempt to procure safety related gauges.
'Ibey stated that they do not make safety related gauges for that application. 'lhe non-safety related pressure gauges were installed during the 4th refueling outage to support system testing, and were left in-place.
Hope ~
Deficiency Report (DR)92-230 was written to address this issue. 'lhe DR was dispositioned "use-as-is" with the root valves maintained in the closed position.
'lhe accompanying 10CFR50.59 applicability review detennined that the gauges did not change the facility as described in the SAR.
'Ibis was based on the review of a number of Hope Creek UFSAR sections, including Section 6. 3. 2. 2.1. '!his section states that failure of the gland seal portion of the High Pressure Coolant Injection (HPCI) system (of which these gauges are a part) will not prevent the HPCI system from fulfilling its core cooling objective.
However, the review conducted did not identify and docmnent two other UFSAR sections that further describe the subject gauges.
UFSAR Table 3.2-1, Pcirt V.c.10, Note 10, identifies these root valves and instnnnent lines (and therefore the gauges) as Quality Group D (non-safety-related). '!his 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) boundal:y and indicates the root valves are nonnally open.
'Ibis is inconsistent with section 6.3.2.2.1 and Table 3.2-1 and represenq; a discrepancy within the UFSAR.
'lhe use-as-is disposition of the DR represented a change to the facility as it is described in Figure 6.3-2 (non-safety related gauges instead of safety-related gauges and root valves changed. from open to closed). 'lherefore, in accordance with our procedures, the applicability review should have resulted in a safety evaluation.
Temporary Modification '!MR 92-031 Salem Unit 1 Temporary Modification (T-Mod) '!MR 92-031 provided temporary power from the lC Vital Bus to 12 Auxiliary Building SUpply Fan (nonnal power is from 1B Vital Bus). 'Ibis T-Mod was similar to a previous T-Mod., '!MR 92-005, 'Which provided temporacy power from the lC Vital Bus to 12 Fuel Handling Building Exhaust Fan, No.1 Ba:ttecy Room Exhaust Fan, and No.1 Radiation Monitor Sample PlUnp (nonnal power is from 1B Vital Bus).
'!he same engineer processed both T-Mods.
'IMR 92-005 was evaluated as a change to the facility as described in the SAR; it received SORC review and approval.
'lhe author believed that '!MR 92-031 involved the same issues and referenced the previous T-Mod ('IMR 92-005) for a discussion of cable separation concerns.
A copy of 'IMR 92-005 was attached to '!MR 92-031.
Since 'IMR 92-005 was SORC approved with no unreviewed safety question (USQ) identified, the author surmised that he could reference the previous T-Mod and disposition 'IMR 92-031 as no change to the facility as described in the SAR.
'lhis conclusion is clearly incorrect.
F.ach 50.59 review must be independently completed.
- 3.
Temporary Modification CT-Mod) 'IMR 92-043 T-Mod '!MR 92-043 documented the installation of a temporary blank flange within a Service Water (SW) header tagged out for maintenance.
'!he background on this T-Mod is as follOVJS:
on June 11, 1993 a portion of pipe in the Salem 22 seJ:Vice water (SW) chiller return header was leaking and in need of replacement.
(See attached figure).
'lhis pipe was upstream of isolation valve 22SW414.
Two chiller condensers were required to maintain operability of the Emergency Control Room Air Conditioner (ECAC).
'!his meant that, in addition to Chiller Condenser 23, either ari.ller Condenser 21 or 22 was required to be in operation. In order to maintain ari.ller Condenser 21 or 22 in operation, (with Chiller Condenser 23 operating) a blank flange was installed upstream of isolation valve 22SW414 between existing 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 miscommunicated.
'!he blank flange and valve 22SW414 seJ:Ved as isolation points for the leaking section of pipe.
'!he cognizant engineer prepared T-Mod 'IMR 92-043 to doa.nnent installation of the temporary blank flange in the SW system.
A doa.nnented 10CFR 50.59 applicability review was perfonned for T-MOD '!MR 92-043 as required by PSE&G procedures.
'lhe applicability review concluded that installation of a blank flange in the SW system was not a change to the facility as described in the UFSAR.
This was based on considering the blank flange installation to be in support of maintenance.
PSE&G Administrative Procedure NC.NA-AP.ZZ-0059(Q) (NAP-59) establishes the process whereby PSE&G meets the requirements of 10CFR50.59.
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 following:
The blank flange was installed to support maintenance (pipe replacement).
The blank flange was installed per ASME Code requirements and perfonned the same function as closed valve 22SW414.
(There were no corrponents, other than a closed drain valve, between the blank flange an:i valve 22SW414)
- When the piping replacement was completed, the blank was removed.
In interpreting the blank flange installation to be a maintenance activity, the applicability review concluded that a safety evaluation was not necessary.
However, NAP-59, Section 6.2.1 indicates that terrporary design changes involving disconnected piping or removal of components should be considered a "change. 11 Since Salem 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 info:anation included in the documented applicability review would have been used as supporting inf onnation in a safety evaluation if one had been written.
Corrective Action Taken
- 1.
The 50.59 applicability review for DR HIE 92-230 has been revised to reference the two additional UFSAR sections (Table 3.2-1 and Figure 6.3-2). Since the use-as-is disposition of the DR represents a change to the facility as it is described in Figure 6.3-2, (non-safety related gauges instead of safety-related gauges and root valves changed from open to closed) a 10CFR50.59 safety evaluation has been perf onned and concluded that the configuration change does not represent an unreviewed safety question. Also an engineering change has been ilrplemented to make UFSAR Figure 6.3-2 consistent with the remainder of the UFSAR.
Iessons learned from this example have been rolled down to department system engineers to ensure they are aware of the requirements and management expectations.
- 2.
With regard to T-MOD 'IMR-031, the appropriate department manager counseled the author on the 50. 59 process and stressed why his action was unacceptable.
We conducted a review of previously completed 50.59s to identify any similar instances.
'!he review concluded that this example was not safety significant and was an isolated incident involving one plant engineer *
'!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-IDD 'IMR 92-043, the blank flange was removed upon replacement of the leaking pipe and the condition no longer exists.
The lessons learned from thi~, will be discussed with deparbnent system engineers to ensure they are aware of the requirements and management expectations.
Corrective Actions to Prevent Recurrence PSE&G considers these three examples as unique instances of 10CFR50. 59 inplementation shortcomings.
These three exanples will be fo:rwarded to the. Nuclear Training Deparbnent to use as exanples in the 10CFR50.59 training module.
The training module will also address circmnstances where conflicting statements or figures exist within the UFSAR.
Status of Compliance PSE&G is in full corrpliance
- FIGURE DEPICTING lliSTALIATION OF BIANK FI.ANGE (Example #3)
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