ML18102B605

Provides Current Status of Actions Implemented in Response to NRC Readiness Assessment Team Insp Rept,Conducted 970609- 23 & 0709-11.Commitment Matrix Re Closure of Insp,Encl

ML18102B605
Person / Time
Site:	Salem
Issue date:	10/03/1997
From:	Eliason L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-311-97-80, LR-N970645, NUDOCS 9710100157
Download: ML18102B605 (9)

Text

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Public Service Electric and Gas Company Leon R. Eliason Public Service Electric and(JC'fOIT1S8rlJ991'* Box 236, Hancocks Bridge, NJ 08038 609-339-1100 Chief Nuciear Officer & President Nuclear Business Unit LR-N970645 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

SUBJECT:

Response to NRC Readiness Assessment Team Inspection (RATI)

Report No. 50-311/97-80 Gentlemen:

The purpose of this correspondence is to provide Public Service Electric & Gas Company's (PSE&G) current status of actions implemented in response to the Nuclear Regulatory Commission (NRC) Readiness Assessment Team Inspection report. The Inspection, conducted from June 9-23, and July 9-11, 1997, concluded that significant progress had been made in enhancing overall station performance and that no issues were identified by the team that required resolution before restart. There were, however, several issues identified that warranted continued attention to assure they are properly controlled.

PSE&G Senior Managem~nt has initiated appropriate corrective actions to address concerns with vendor manual program weaknesses; out-of-date administrative procedures; and changes in the area of maintenance scheduling that pose a challenge to reduce the corrective action backlog. A matrix of actions and their current status is included in Attachment 1. Additionally, Attachment 2 describes our proposed solution to the Auxiliary Building and Control Room Ventilation issues.

Should you have any questions related to any corrective actions or their status we would be pleased to discuss them with you.

Sincerely,

( 9710100157 971003 PDR ADOCK 05000311 G PDR 1111111111111111111111111111111111111111

• & & 6 F 9 0

• Document Control Desk LR-N970645

• OCT 3 1997 Attachments C Mr. Hubert J. Miller - Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Ms. M. Evans - Salem (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933

ATTACHMENT 1 COMMITMENT MATRIX CLOSURE OF SALEM UNIT 2 READINESS ASSESSMENT TEAM INSPECTION COMMITMENTS NRC RATI REPORT PSE&G COMMITMENT STATUS 1.a Review open Business Process items to Reviewed Business Process Action Requests and Complete determine their appropriate significance as appropriate, reclassified them as Condition level and classification. Resolutions.

Significance level X PIRS items reviewed.

Identified some which should have been CRs, but were closed. No action required.

2.a Clarify reporting options for individuals Strengthen the communications of the alternate Complete uncomfortable using the Employee reporting path of the Employee Concerns Program.

Concerns Program.

Publish Nuclear Today Article on the alternate method of reporting employee concerns.

2.b Review with the Employee Concerns staff, the Complete Employee Concerns Procedure to confirm the understanding of the alternate path.

2.c Incorporate alternate path information into the Complete Managing for Nuclear Safety training.

NRC RATI REPORT PSE&G COMMITMENT STATUS*

2.d Incorporate alternate path information into Complete Management Actions Response Checklists .

(MARC) refresher training.

2.e Conduct face to face meetings with Quality Complete Assurance/Nuclear Safety Review personnel.

2.f Update the Employee Concerns Program brochure. Expect completion Draft complete; expect brochure distribution by by 10/31/97.

10/31/97.

3.a Review surveillance procedures to Sample 5% of surveillances and evaluate against Complete.

determine if systems or components are Info Notice 97-16 concerns.

being preconditioned. Approx. 80 items sampled per MIL-Spec 105E reviewed, no pre-conditioning identified.

4.a Resolve concerns with implementation Procedure sponsors reviewed their procedures to Complete and maintenance of administrative identify procedures which can be retired and procedures ... developed a review schedule for those procedures necessary for departmental use. Approximately 10 procedures were retired.

4.b Engineering Department Managers and Complete Supervisors will roll out an expectation that procedure revision currency be verified prior to procedure usage.

NRC RATI REPORT PSE&G COMMITMENT STATUS*

4.c The engineering Assurance Procedure/Programs Complete personnel have been directed to expedite procedure revisions by: processing as necessary to support on-going work , dividing the revision requirements among all available group personnel to facilitate parallel processing, and application of additional personnel to reduce the procedure revision delivery time.

4.d Engineering Department Managers and Complete Supervisors re-communicated Nuclear Business Unit (NBU) management's expectations regarding procedure usage and adherence via rolldowns within the departments.

Managers and Supervisors were tasked with providing additional attention to procedure usage practices during the performance of work tasks.

4.e ... and concerns regarding contractor Engineering Department Managers and Complete training records. Supervisors were tasked with verifying/developing documentation for their assigned contractor personnel in compliance with procedure (current NAP-68) requirements.

NRC RATI REPORT PSE&G COMMITMENT STATUS*

4.f An evaluation of the procedure (NAP-68) by Expected NAP-68 I Engineering was conducted to determine whether revision - I:

I alternative methods of establishing and implementation by maintaining contractor qualifications, e.g., 11/30/97 I Engineering Support Personnel Job Qualification Guides and continuing training, can be recognized as an allowable substitute. Other department comments are being solicited with NAP-68 implementation expected by 11/30/97.

4.g Training was provided to Engineering Department Complete Managers and Supervisors reviewing NBU requirements for the use of contractors for both supervised and independent qualifications.

5.a Describe efforts to address weaknesses Accelerate the vendor contact program to include Completion is a in the vendor manual control program those vendors applicable to S2/SC safety related function of vendor including: maintenance rule - risk significant systems. responsiveness The vendor contact cycle for 1997 has been and is targeted for vendor re-contact; ... accelerated and expanded, 144 vendors were end of 1997.

originally planned to be contacted in 1997. An additional 140 vendors were added to the 1997 schedule based on the above criteria and have been notified. Note: The contact covers all manuals supplied by the vendor including those applicable to Salem 1 and Hope Creek.

NRC RATI REPORT PSE&G COMMITMENT STATUS.

5.b vendor manual document backlog Document the long term vendor document Complete management; performance indicators program. Process issues: fragmentation of .

and goals; long term plans for the processes; consistency in how document revisions program; ... are made, establish Performance Indicators (clear cut backlog reduction goal).

The Vendor Document Program Plan was revised on August 28, 1997 to add elements regarding Management Oversight, Performance Indication, Self Assessment, Long-Term Strategic Direction.

Sections that required general update included Organization and staffing, Backlog, Departmental Interfaces, and Training.

5.c shelf life issues for short shelf life safety Conducted a sampling of short shelf-life items for Complete related equipment; ... evaluation of conformance with PSE&G guidelines.

One item, a hydrogen sensor, shelf life was revised to address a concern. A summary report of the review will be maintained in the EQ files.

5.d and engineering evaluation of pre 1987 Reviewed 68 old (pre-87) General Electric Service Complete vendor notices. Advice Letters (SALs) to determine applicability to Salem, 27 closed. Of 41 assigned for further evaluation, 9 have been closed, 32 are being tracked in Corrective Action Program with various due dates through 11 /98.

6.a Single failure vulnerability of the Auxiliary Complete the Auxiliary Building Ventilation design See Attachment 2 Building Ventilation (ABV) during modification to eliminate operator compensatory accident conditions. action (work around).

See Attachment 2.

NRC RATI REPORT PSE&G COMMITMENT STATUS*

7.a Observations of the operator work Revise the work around procedure by August 1997. Complete around program identified deficiencies SC.OP-AP.ZZ-0030 Rev.1 implemented 8/29/97.

with definitions and same priority assigned to all workarounds.

A 0 ATTACHMENT 2 AUXILIARY BUILDING AND CONTROL ROOM VENTILATION Public Service Electric & Gas (PSE&G) has completed extensive post modification testing on the Control Area Air Conditioning System (CAACS) and its subsystem, the Control Room Emergency Air Conditioning System (CREACS). The CREACS subsystem provides filtration, and cooling to the Control Room Envelope (CRE) during radiological emergencies to assure that radiological exposures to the control room operators are maintained As Low As Reasonably Achievable (ALARA). The CREACS is designed to actuate either automatically or manually, and to pressurize the CRE to +0.125 in. w.c. with respect to all adjacent areas.

The CREACS is a standby system consisting of two redundant trains of filtration equipment, with one train powered from Salem Unit 1, and the other from Salem Unit 2 vital power distribution system. Each train is capable of meeting the pressurization and filtration requirements established for the CRE. Testing has demonstrated however, that in order to meet the pressurization requirement in the maintenance mode of operation (i.e., one filtration train isolated), operator actions beyond normal system realignment are required. These actions include opening of doors in the relay room and electrical penetration areas, posting of fire watches and establishing compensatory security measures. These actions are required due to pressurization that occurs in the affected areas when their respective ventilation systems align to the accident mode of operation.

PSE&G recently developed a conceptual design directed at eliminating these additional operator actions. The conceptual design involved extensive modifications to the safety related Battery Room and Switchgear and Penetration Area Ventilation systems. It should be noted that, entry into the maintenance mode of operation is a planned and proceduralized evolution conducted during plant operation only as necessary. Entry into the maintenance mode during an accident is not anticipated. The period of time that the plant is allowed to remain in the maintenance mode is also limited by Technical Specifications. Based on these considerations, PSE&G has concluded that the potential safety benefits (i.e., reduced operator actions to achieve the maintenance mode alignment) derived from these modifications do not justify the associated cost.

In lieu of further modifications to the plant ventilation systems, PSE&G is preparing a License Amendment Request for submittal to the NRC. This request is intended to eliminate the dependence on the previously described administrative actions by restating the acceptance criteria for the CREACS positive pressure test. Until such time as this request is reviewed an approved

• by the NRC, PSE&G will retain the current set of administrative controls governing entry to the maintenance mode of operation.