ML20207K825
| ML20207K825 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/15/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Heishman R, Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NLR-N86182, NUDOCS 8701090532 | |
| Download: ML20207K825 (6) | |
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Pubbc Service Electric and Gas W AA U
Company Corbin A. McNelli, Jr.
Pubhc Service Electric and Gas Company P O Box 236, Hancocks Bridge. NJ 0803H 6Y9 b'be
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December 15, 1986 f
NLR-N86182 5
Mr. James M. Taylor Office of Inspection & Enforcement United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. Robert F.
Heishman, Chief Vendor Programs Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement Gentlemen:
NRC INSPECTION 50-272/86-23 AND 50-311/86-23 SALEM GENERATING STATION UNIT NOS. 50-272 AND 50-311 Public Service Electric and Gas Company has received the subject inspection report dated November 13, 1986 which identified seven (7) Potential Enforcement / Unresolved Items with regard to the Salem Environmental Qualification Program and other areas reviewed during the inspection.
As suggested in the cover letter of the inspection report, PSE&G has taken actions to correct the deficiencies identified during the inspection.
The cover letter also indicated your receipt of our letter of November 7, 1986 which presented our position on four of the five Potential Enforcement / Unresolved Items identified during the exit meeting of August 15, 1986.
The attached information is intended to reiterate the positions set forth in the [[letter::05000272/LER-1986-019-01, :on 861001,two 2-inch Conduit Penetrations in Svc Water Intake Structure Fire Barrier Wall Discovered Improperly Sealed Per Tech Spec 3.7.11.Cause Undetermined. Penetration Sealed.Investigation Continuing|November 7, 1986 letter]] as well as state the PSE&G position on the remaining items.
I We ask that you continue your review of the previous submittal and include in that review our attached responses to the other two identified Potential Enforcement / Unresolved Items.
We desire to meet with appropriate members of the NRC staff in the near future to discuss both the results of your review and your considerations in determination of the final disposition of the identified deficiencies.
We will contact you to schedule a date for this meeting.
Your cooperation in this matter is appreciated.
7 Sincerely, t
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G701090532 861215 gDR ADOCK 05000272 i,
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r, Mr. James M. Taylor 2
12/15/86 s
C Mr.
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C. Fischer Licensing Project Manager-Mr. T. J.
Kenny Senior Resident Inspector Mr.
S.
D.
Ebneter, Director Division of Reactor Safety USNRC Region I 1
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e ATTACHMENT POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-27/86-23-01; 50-311/86-23-01 Contrary to Criterion II of Appendix B to 10CFR50, at the time of the inspection, PSE&G failed to have documentation of EQ training for Systems Analysis Group (SAG) personnel.
RESPONSE
PSE&G does not agree with this finding The inspector refers to the Salem Updated FSAR commitment to NRC Regulatory Guide 1.33, Revision 2 and its subsequent endorsement of ANSI 18.7-1976.
Section 3.3 of ANSI 18.7-1976 requires that provisions be made for indoctrination and training of personnel performing activities affecting quality to assure that suitable proficiency is achieved and maintained.
Section 3.4.2 of ANSI 18.7-1976 further requires that personnel shall have appropriate experience, training and retraining to assure that necessary competence is maintained in accordance with ANSI 18.1-1971.
This response will reference ANSI /ANS-3.1-1981, the most recent update of ANSI 18.1.
In addition to training, Section 3.3 of ANSI /ANS-3.1-1981 indicates that education, experience, health and skills commensurate with their functional level of responsibility contribute to the ability of nuclear power plant personnel to assure safe and efficient operation of the plant through their decisions and actions.
Although training in the procedure which governs the EQ program (GM8-022) and the procedure which controls the design change process (GM8-009) is provided periodically (the most recent training in GM8-022 was given on August 26, 1986), PSE&G contends that this training cannot and should not be the only factor upon which adequate training in the EQ program is judged.
Section 5.3.2 of ANSI /ANS-31-1981 states that training shall be provided to compensate for deficiencies identified by comparing the individuals experience and knowledge to the task analysis.
A review of the resumes of SAG personnel who performed the EQ evaluations indicates prior experience in the EQ field and in the various types of engineering analyses which are used to establish the qualification of equipment.
These personnel are required, in their work indoctrination, to review and be familiar with GM8-022, GM8-009 and their associated reference material, l
which includes IE Bulletin 79-OlB, NUREG-0588, IEEE 323-1974 and 10CFR50.49.
The members of SAG involved in the Salem program had also viewed training tapes and a slide presentation prepared by Arkansas Power and Light Company and EPRI on EQ programs.
The intradepartmental EQ training received by SAG was observed as part of an independent audit of the Salem EQ program performed by DiBenedetto Associates, Inc. in December 1985.
The executive summary of the DiBenedetto audit states that "...In the audit teams opinion, the training provided by PSE&G is the most comprehensive in industry."
SAG personnel have been supervised over the last two years of the Salem EQ program by an experienced supervisor (7 yrs. EQ experience) who has taken part in numerous NRC working meetings, EPRI conferences and IEEE seminars related to EQ.
This individual has provided an important check and review function for the EQ documentation which has been generated and reviewed by SAG.
This review function has also provided valuable feedback to the other members of SAG.
PSE&G feels that the combination of educational background, training and experience which has existed and continues to exist in SAG has provided for effective development, implementation and continuing review of the EQ program at Salem.
POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-272/86-23-03; 50-311/86-23-03 Contrary to 10CFR50.49(f) and (k) and Section 5.1 of NUREG-0588, PSE&G did not adequately demonstrate qualification of Rockbestos coaxial and EPR cables.
RESPONSE
PSE&G does not agree with the finding Please review Attachment B-1 of the November 7, 1986 submittal for a detailed analysis.
POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-272/86-23-04; 50-311/86-23-04 Contrary to 10CFR50.49(f) and (k) and NUREG-088, PSE&G had not established qualification of the inside containment Limitorque operators because use of the operators without gear case grease relief valves was not demonstrated to be acceptable.
RESPONSE
l PSE&G does not agree with this finding Please review Attachment B-2 of the November 7, 1986 submittal for detailed analysis.
l POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-272/86-23-05; 50-311/86-23-05 Contrary to 10CFR50.49(f) and (k) and Sections 4(9) and 4(10) of NUREG-0588 at the time of the inspection, the qualification files did not provide adequate basis for the qualified life of the pressure transmitters and RTD's used in the Exo Sensors hydrogen analyzers.
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RESPONSE
PSE&G does not agree with this finding Please review Attachment B-3 of the November 7, 1986 submittal for a detailed analysis.
POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-272/86-23-06; 50-272/86-23-06 Contrary to 10CFR50.59(f) and (k) and Section 2.1 of
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NUREG-0588, at the time of inspection, the qualification files for ASCO solenoid valves failed to demonstrate that the valves could meet specified post-accident operability requirements.
RESPONSE
l PSE&G does not agree with this finding The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> post-accident operating time noted in the inspection report was enveloped by the 30 day test.
The greater than 119 days post-accident operating time for sampling system solenoid valves was enveloped by 8348.15 days of equivalent operating time as determined by Arrhenius analyses.
Arrhenius methodology is an acceptable means for determining equivalent operating time and PSE&G feels that the required 120 day post-accident operating time was adequately enveloped by the analysis performed.
the 10*C rule was not utilized.
POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-272/86-23-09; 50-311/86-23-09 Contrary to 10CFR50.49(d), (f) and (k) and NUREG-0588, at the time of the inspection, PSE&G had not established qualification of Scotch 70/ construction electric wiring splices used in outside containment Limitorque motor valve operators.
Additionally, PSE&G had not included these splices on the EO equipment list.
RESPONSE
PSE&G does not dispute this Potential Enforcement / Unresolved Item An EQ report has been assembled and a safety evaluation performed.
The safety evaluation indicated that the Scotch 70 electrical splice has the ability to meet its functional requirements and operating specifications for its installed life.
POTENTIAL ENFORCEMENT / UNRESOLVED ITEM 50-272/86-23-10; 50-311/86-23-10 Contrary to Criterion III of Appendix B to 10CFR50, at the time of the inspection, Rosemount Flow transmitter 2FT-128 was not seismically qualified because the installation differed from the tested configuration and engineering justification for the differences was not documented.
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RESPONSE
PSE&G does not dispute the Potential Enforcement / Unresolved Item as stated.
The results of analysis performed to verify that the transmitter is properly mounted indicated that the existing mounting is capable of withstanding the Design Basis Earthquake (DBE) seismic loading with an ample safety factor.
The subject flow transmitter is required to be mounted in accordance with seismic criterion as it is a Reg. Guide 1.97 Category 2 equipment.
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