ML18102B455

Forwards Supplemental Response to Violations Noted in Insp Rept 50-311/97-06.Corrective Actions:Ar 970320247 Issued to Evaluate White Chalky Film Observed on Coil

ML18102B455
Person / Time
Site:	Salem
Issue date:	07/16/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-311-97-06, 50-311-97-6, LR-N970449, NUDOCS 9707220344
Download: ML18102B455 (15)

See also: IR 05000311/1997006

Text

' ,, __ . ** Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700

Senior Vice President

-Nuclear Operations

• JUL 16 1997 LR-N970449

United States Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 SUPPLEMENTAL

RESPONSE TO A NOTICE OF VIOLATION

INSPECTION

REPORT 50-311/97-06

SALEM GENERATING

STATION UNIT NO. 2 DOCKET NO. 50-311 Gentlemen:

Inspection

Report No. 50-311/97-06

for Salem Nuclear Generating

Station Unit No. 2 was transmitted

to Public

Electric & Gas Company (PSE&G) on May 30, 1997. Within the scope of this report, one violation

of NRC requirements

was c.i ted. The violation

involved the failure to follow established

procedures

for the documentation

of test results. By letter dated June 30, 1997 (Our Ref: LR-N970371), PSE&G submitted

its response to the cited violation.

As stated in the original PSE&G response, the root cause of the violation (all f; cited examples)

was attributed

to poor human performance

of l)J personnel

performing

the activities

and poor human performance

by management

in the oversight

of these activities.

The corrective

actions stated in the June 30 response were designed to address ';* the root cause in its broadest form. To provide a complete understanding

of PSE&G's actions taken, PSE&G is supplementing

the June 30, 1997 original response to address the specific actions taken relative to each of the cited examples.

Mssrs. D. Powell and M. Rencheck of PSE&G discussed

the submittal

of this supplemental

response with Mr. W. Ruland (NRC Region I) via telephone

on July 9, 1997. 9707220344

970716 PDR ADOCK 05000311 G PDR *..* *,_, _ .. \J Printedon

\:I Recycled Paper 1111111111111111111111111111111111111111

• 0&4011.

• • * Document Control Desk LR-N970449

2 JUL 16 1997 Additionally, by letter dated April 11, 1997 (Our Ref-: N97194), PSE&G responded

to a similar violation

transmitted

in Inspection

Report 50-311/96-21.

This violation

involved deficient

conditions

for the testing of the Control Room Area Air Conditioning

System. As a result of subsequent

PSE&G investigation, as well as NRC inspections, other deficient

conditions

were identified

relative to the same design modification

test procedures.

In light of the applicability

of these findings to Control Room Area Air Conditioning, and in response to Inspection

Report 50-311/97-06

request, PSE&G considers

the information

provided in the June 30, 1997 letter to be relevant to the April 11, 1997 response.

In the June 30, 1997 response, PSE&G stated that (Corrective

action E) ten non-HVAC system Special Test Procedures (STPs) in five systems were reviewed.

PSE&G would like to expand on this corrective

action by identifying

the procedures

reviewed.

The STPs reviewed are: Fire Protection

2EC-3298 Package 1 -STPs 1-3 lEC-3701 Package 1 -STP 1 Electrical

2EC-3332 Package 2 -STPs 1 & 2 Diesel lEC-3529 Package 2 -STP 1 Service Water 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 11 -STP 1 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 17 -STPs 1-7 2EC-3590 Package 18 -STPs 1-5 Safety Injection

2EC-3461 Package 1 -STPs 1 & 2 95-4933

• • Document Control Desk LR-N970449

3 JUL 16 1997 Attachment

I to this letter contains the original violation

as cited in Inspection

Report 50-311/97-06.

Attachment

II contains PSE&G's supplemental

information

relative to these *events. Should there be any questions

regarding

this submittal, please contact us. Sincerely,

• • * Document Control Desk LR-N970449

Attachment

4 C Mr. Hubert J. Miller, Administrator

-Region I U. s. Nuclear Regulatory

Commission

.475 Allendale

Road King of Prussia, PA 19406 JUL 16 1997 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 Mr. C. Marschall

-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

I LR-N970449

NOTICE OF VIOLATION

Public Service Electric & Gas Company Docket No:

Salem Nuclear Generating

Station License No: DPR-75 Unit 2 During an NRC inspection

conducted

on March 1 to April 12, 1997, violations

of NRC requirements

were identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRC Enforcement

Actions." NUREG-1600, the violations

are listed below: Appendix B, Criterion

V of 10 CFR 50 requires that activities

affecting

quality be prescribed

by procedures

and shall be accomplished

in accordance

with those procedures.

Procedure

NC.DE-AP.ZZ-0012(Q), "Test Program", Revision 6, Section 5.2.c requires testing to be conducted

with approved step-by-step

Special Test Procedures, existing procedures, or standards.

Section 5.2.e requires recording

test data on data sheets . * Section 5.2.f requires evaluating

test results to ensure they are acceptable

prior to restoring

plant equipment.

• Contrary to the above, post-modification

test procedures

for Salem cdntrol room area air conditioning

system (CAACS) were not followed, required.data

was not recorded, and plant equipment

was restored with test results outside established

acceptance

criteria, as evidenced

by the following

examples:

1. Procedure

lEC-3505 package No. 1 STP-2, Revision 2, *control Area Air Conditioning

System (CAACS) and Emergency

Air Conditioning

System (EACS) Coil Test Procedure (to verify heat transfer capability

of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation

of an Action Request (AR) to clean the coils if the coil appearance

was not "bare metal or shiny appearance".

The condition

of the coil for 1HVE200, recorded on Attachment

7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated . 1

ATTACHMENT

I LR-N970449

2. Procedure

lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential

for leakage into the control room pressure boundary], attachment

7.3 establishes

EACS charcoal filter housing and duct maximum allowable

leakage test acceptance

criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established

acceptance

criteria, but the test results were approved and the EACS system was restored to service. 3. Procedure

lEC-3505 Package No. 1 STP-4, Revision 3, attachment

7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric

pressure recorded in inches of mercury (inHg) and initial boundary pressures

in pounds per square foot (psf) absolute (abs.), the test pressures

were less than the required 4 inwc. 4. Procedure

lEC-3505 Package No. 1

Revision 3, Appendix A, steps 2.e and 2.h require recording

the initial and final times of the test. The times were not recorded.

5. Procedure

lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring

review of test data by the test engineer was incorrectly

deleted by Modification

Concern and Resolution

297. This is* a Severity Level IV problem (Supplement

1). 2

ATTACHMENT

II SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

"1. Procedure

lEC-3505 package No. 1 STP-2,

2, Control Area Air Conditioning

System (CAACS) and Emergency

Air Conditioning

System (EACS) Coil Test Procedure (to verify heat transfer capability

of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation

of an Action Request (AR) to clean the coils if the coil appearance

was not "bare metal or shiny appearance".

The condition

of the coil for 1HVE200, recorded on Attachment

7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated." (1) The reason for the violation.

The root cause for the violation

was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation

was poor human performance

by the *CAV project team and testing personnel

and management

oversight.

Personnel

involved failed to meet PSE&G's standard of procedural

compliance.

Personnel

did not properly revise CAV Special Test Procedures (STPs) in accordance

with PSE&G procedures

to reflect changes in testing methodology

and acceptance

criteria.

In addition inadvertent

removal of the test engineer acceptance

signoff by the project team is an example of inattention

to detail. PSE&G management

also did not provide an adequate level of management

oversight

of personnel

preparing.and

implementing

the CAV_Special

Test Procedures." * (2) The corrective

steps that have been taken. 1. AR 970320247

was issued to evaluate the white chalky film observed on the coil. The white chalky film (lead oxide) observed on the coil was the result of chemical cleaning of the EACS coil by the vendor. This white chalky substance

was evaluated

and determined

to have no effect on the heat transfer characteristic

of the coil . 1

• * ATTACHMENT

II SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

2. The design change test procedure

acceptance

criterion

was revised as per the above evaluation

and vendor recommendation.

3. LR-N970371, dated June 30, 1997, -contains

additional

information.

(3) The corrective

steps that will be taken to avoid further violations.

LR-N970371, dated June 30, 1997, contains the required information.

(4) The date when full compliance

will be achieved.

PSE&G achieved compliance

when the AR 970320247

was issued. LR-N970371, dated June 30, 1997, contains additional

information . 2

• ATTACHMENT I I SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

"2. Procedure

lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential

for leakage into the control room pressure * boundary], attachment

7.3 establishes

EACS charcoal filter housing and duct maximum allowable

leakage test acceptance

criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established

acceptance

criteria, but the test results were approved and the EACS system was restored to service." (1) The reason for the violation.

The root cause for the violation

was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation

was poor human performance

by the CAV project team and testing personnel

and management

oversight.

Personnel

involved failed to meet PSE&G's standard of procedural

compliance.

Personnel

did not properly revise CAV Special Test Procedures (STPs) in accordance

with PSE&G procedures

to reflect changes in testing methodology

and acceptance

criteria.

In addition inadvertent

removal of the test engineer acceptance

signoff by the project team is an example of inattention

to detail. PSE&G management

also did not provide an adequate level of management

oversight

of personnel

preparing

and implementing

the CAV Special Test Procedures." (2) The corrective

steps that have been taken. 1. Engineering

Evaluation

S-C-SC-MEE-1212, Control Area Ventilation:

Review of CREACS Filter Housing Test Requirements

and Acceptance

Criteria, issued on May 30, 1997, evaluated

the recorded leakage rate acceptable.

2. Modification

Concern and Resolution (MCR) 193 to the design change test procedure

revised the leakage rate 3

• ATTACHMENT

II SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

acceptance

criterion

based on Control Room Dose Calculation

and was evaluated

in Engineering

Evaluation

S-C-SC-MEE-1212.

3. LR-N970371, dated June 30, 1997, contains additional

information.

(3) The corrective

steps that will be taken to avoid further violations.

LR-N970371, dated June 30, 1997, contains the required information.

(4) The date when full compliance

will be achieved.

PSE&G achieved compliance

when the Engineering

Evaluation

was issued demonstrating

that the recorded leakage rate was acceptable, and MCR 193 to lEC-3505 revised the leakage rate acceptance

criterion.

LR-N970371, dated June 30, 1997, contains additional

information . 4

• ATTACHMENT

II SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

"3. Procedure

lEC-3505 Package No. 1 STP-4, Revision 3, attachment

7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric

pressure recorded in inches of mercury (inHg) and initial boundary pressures

in pounds per square foot (psf) absolute (abs.), the test pressures

were less than the required 4 inwc." (1) The reason for the violation.

The root cause for the violation

was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation

was poor human performance

by the CAV project team and testing personnel

and management

oversight.

Personnel

involved failed to meet PSE&G's standard of procedural

compliance.

Personnel

did not properly revise CAV Special Test Procedures (STPs) in accordance

with PSE&G procedures

to reflect changes in testing methodology

and acceptance

criteria.

In addition inadvertent

removal of the test engineer acceptance

signoff by the project team is an example of inattention

to detail. PSE&G management

also did not provide an adequate level of management

oversight

of personnel

preparing

and implementing

the CAV Special Test Procedures." (2) The corrective

steps that have been taken. 1. Engineering

Evaluation

S-C-SC-MEE-1212, Control Area *ventilation:

Review of CREACS Filter Housing Test Requirements

and Acceptance

Criteria, issued on May 30, 1997, evaluated

the higher initial test pressures

and accepted the test data. 2. The HEPA and Charcoal Filter Housing decay calculations

were revised with acceptable

results. 3. The test procedure

acceptance

criteria was revised. 4. LR-N970371, dated June 30, 1997, contains additional

information . 5

ATTACHMENT

II SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

(3) The corrective

steps that will be takeri to avoid further violations.

dated June 30, 1997, contains the required information.

(4) The date when full compliance

will be achieved.

PSE&G achieved compliance

when the Engineering

Evaluation

was issued determining

that the higher recorded test pressures

were acceptable, the test procedure

acceptance

criteria was revised, and the HEPA and Charcoal Filter Housing decay calculations

were revised. LR-N970371, dated June 30, 1997, contains additional

information . * 6

I ---.. ATTACHMENT I I SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

"4. Procedure

lEC-3505 Package No. 1 STP-4,

3, Appendix A, steps 2.e and 2.h require recording

the initial and final times of the test. The times were not recorded." (1) The reason for the violation.

The root cause for the violation

was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation

was poor human performance

by the CAV project team and testing personnel

and management

oversight.

Personnel

involved failed to meet PSE&G's standard of procedural

compliance.

Personnel

did not properly revise CAV Special Test Procedures (STPs) in accordance

with PSE&G procedures

to reflect changes in testing methodology

and acceptance

criteria.

In addition inadvertent

removal of *the test engineer acceptance

signoff by the project team is an example of inattention

to *detail. PSE&G management

also did not provide an adequate level of management

oversight

of personnel

preparing

and implementing

the CAV Special Test Procedures." (2) The corrective

steps that have been taken. 1. The test engineers

responsible

have been counseled

and advised of the importance

of strict procedure

compliance.

Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was *recorded, which was the only value necessary

for the required calculation.

2. LR-N970371, dated June 30, 1997, contains additional

information.

(3) The corrective

steps that will be taken to avoid further violations.

LR-N970371, dated June 30, 1997, contains the required information . * 7

... ATTACHMENT

II SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

(4) The date when full compliance

will be achieved.

PSE&G achieved compliance

when the test was completed

satisfactorily.

Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was recorded, which was the only value necessary

for the required calculation.

LR-N970371, dated June 30, 1997, contains the required information.

"5. Procedure

lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring

review of test data by the test engineer was incorrectly

deleted by Modification

Concern and Resolution

297." (1) The reason for the violation.

The root cause for the violation

was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation

was poor human performance

by the CAV project team and testing personnel

and management

oversight.

Personnel

involved failed to meet PSE&G's standard of procedural

compliance.

Personnel

did not properly revise CAV Special Test Procedures (STPs) in accordance

with PSE&G procedures

to reflect changes in testing methodology

and acceptance

criteria.

In addition inadvertent

removal of the test engineer acceptance

signoff by the project team is an example of inattention

to detail. PSE&G management

also did not provide an adequate level of management

oversight

of personnel

preparing

and implementing

the CAV Special Test Procedures." (2) 1. 2. 3. * The corrective

steps that have been taken. The test engineer responsible

for removing the procedure

step was counseled.

A review signature

was added for a level III sign off of test results. The test results were reviewed by a level III test engineer . 8

_, *-I l ... * * ATTACHMENT I I SUPPLEMENTAL

RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT 2 LR-N970449

4. LR-N970371, dated June 30, 1997, contains additional

information.

(3) The corrective

steps that will be taken to avoid further violations.

LR-N970371, dated June 30, 1997, contains the required information.

(4) The date when full compliance

will be achieved.

PSE&G achieved compliance

when a review signature

was added for a level III sign off of test results and the test results were reviewed by a level III test engineer.

LR-N970371, dated June 30, 1997, contains additional

information . 9