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See also: [[followed by::IR 05000311/1997006]]


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{{#Wiki_filter:' ,, __ . ** 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  
{{#Wiki_filter:' ,, __ . ** 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  
Senior Vice President  
-Nuclear Operations
-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:
* JUL 16 1997 LR-N970449  
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.
United States Nuclear Regulatory  
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.
Commission  
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.
Document Control Desk Washington, DC 20555 SUPPLEMENTAL  
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  
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  
\:I Recycled Paper 1111111111111111111111111111111111111111  
*0&4011.   
*0&4011.   
** * Document Control Desk LR-N970449  
**
2 JUL 16 1997 Additionally, by letter dated April 11, 1997 (Our Ref-: N97194), PSE&G responded  
* 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.
to a similar violation  
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.
transmitted  
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 Inspection  
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.
Report 50-311/96-21.  
PSE&G would like to expand on this corrective action by identifying the procedures reviewed.
This violation  
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   
involved deficient  
** 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.
conditions  
Attachment II contains PSE&G's supplemental information relative to these *events. Should there be any questions regarding this submittal, please contact us. Sincerely,   
for the testing of the Control Room Area Air Conditioning  
**
System. As a result of subsequent  
* Document Control Desk LR-N970449 Attachment 4 C Mr. Hubert J. Miller, Administrator  
PSE&G investigation, as well as NRC inspections, other deficient  
-Region I U. s. Nuclear Regulatory Commission  
conditions  
.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  
were identified  
-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:
relative to the same design modification  
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.
test procedures.  
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.
In light of the applicability  
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.
of these findings to Control Room Area Air Conditioning, and in response to Inspection  
Section 5.2.e requires recording test data on data sheets .
Report 50-311/97-06  
* Section 5.2.f requires evaluating test results to ensure they are acceptable prior to restoring plant equipment.
request, PSE&G considers  
* 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:
the information  
: 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".
provided in the June 30, 1997 letter to be relevant to the April 11, 1997 response.  
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
In the June 30, 1997 response, PSE&G stated that (Corrective  
: 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.
action E) ten non-HVAC system Special Test Procedures (STPs) in five systems were reviewed.  
: 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".
PSE&G would like to expand on this corrective  
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.
action by identifying  
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.
the procedures  
Personnel involved failed to meet PSE&G's standard of procedural compliance.
reviewed.  
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.
The STPs reviewed are: Fire Protection  
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   
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  
* ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449
2EC-3461 Package 1 -STPs 1 & 2 95-4933   
: 2. The design change test procedure acceptance criterion was revised as per the above evaluation and vendor recommendation.
** Document Control Desk LR-N970449  
: 3. LR-N970371, dated June 30, 1997, -contains additional information.
3 JUL 16 1997 Attachment  
(3) The corrective steps that will be taken to avoid further violations.
I to this letter contains the original violation  
LR-N970371, dated June 30, 1997, contains the required information.
as cited in Inspection  
(4) The date when full compliance will be achieved.
Report 50-311/97-06.  
PSE&G achieved compliance when the AR 970320247 was issued. LR-N970371, dated June 30, 1997, contains additional information . 2
Attachment  
* 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
II contains PSE&G's supplemental  
* 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.
information  
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.
relative to these *events. Should there be any questions  
Personnel involved failed to meet PSE&G's standard of procedural compliance.
regarding  
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.
this submittal, please contact us. Sincerely,   
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:
** * Document Control Desk LR-N970449  
Review of CREACS Filter Housing Test Requirements and Acceptance Criteria, issued on May 30, 1997, evaluated the recorded leakage rate acceptable.
Attachment  
: 2. Modification Concern and Resolution (MCR) 193 to the design change test procedure revised the leakage rate 3
4 C Mr. Hubert J. Miller, Administrator  
* 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.
-Region I U. s. Nuclear Regulatory  
: 3. LR-N970371, dated June 30, 1997, contains additional information.
Commission  
(3) The corrective steps that will be taken to avoid further violations.
.475 Allendale  
LR-N970371, dated June 30, 1997, contains the required information.
Road King of Prussia, PA 19406 JUL 16 1997 Mr. L. N. Olshan, Licensing  
(4) The date when full compliance will be achieved.
Project Manager -Salem U. S. Nuclear Regulatory  
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.
Commission  
LR-N970371, dated June 30, 1997, contains additional information . 4
One White Flint North 11555 Rockville  
* 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.
Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall  
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.
-Salem (X24) USNRC Senior Resident Inspector  
Personnel involved failed to meet PSE&G's standard of procedural compliance.
Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering  
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.
33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
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:
ATTACHMENT  
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.
I LR-N970449  
dated June 30, 1997, contains the required information.
NOTICE OF VIOLATION  
(4) The date when full compliance will be achieved.
Public Service Electric & Gas Company Docket No:  
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 .
Salem Nuclear Generating  
* 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.
Station License No: DPR-75 Unit 2 During an NRC inspection  
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.
conducted  
Personnel involved failed to meet PSE&G's standard of procedural compliance.
on March 1 to April 12, 1997, violations  
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.
of NRC requirements  
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.
were identified.  
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.
In accordance  
: 2. LR-N970371, dated June 30, 1997, contains additional information.
with the "General Statement  
(3) The corrective steps that will be taken to avoid further violations.
of Policy and Procedure  
LR-N970371, dated June 30, 1997, contains the required information .
for NRC Enforcement  
* 7 
Actions." NUREG-1600, the violations  
... ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 (4) The date when full compliance will be achieved.
are listed below: Appendix B, Criterion  
PSE&G achieved compliance when the test was completed satisfactorily.
V of 10 CFR 50 requires that activities  
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.
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.  
LR-N970371, dated June 30, 1997, contains the required information.  
(4) The date when full compliance
"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.
will be achieved.
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.
PSE&G achieved compliance
Personnel involved failed to meet PSE&G's standard of procedural compliance.
when the AR 970320247
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.
was issued. LR-N970371, dated June 30, 1997, contains additional
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.
information . 2 
* The corrective steps that have been taken. The test engineer responsible for removing the procedure step was counseled.
* ATTACHMENT I I SUPPLEMENTAL
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
RESPONSE TO NOTICE OF VIOLATION
_, *-I l ... *
SALEM GENERATING
* ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449
STATION UNIT 2 LR-N970449
: 4. LR-N970371, dated June 30, 1997, contains additional information.
"2. Procedure
(3) The corrective steps that will be taken to avoid further violations.
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
LR-N970371, dated June 30, 1997, contains the required information.
for leakage into the control room pressure * boundary], attachment
(4) The date when full compliance will be achieved.
7.3 establishes
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.
EACS charcoal filter housing and duct maximum allowable
LR-N970371, dated June 30, 1997, contains additional information . 9}}
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
}}

Revision as of 20:00, 31 July 2019

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 PSEG icon.png
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)
v • d • e


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

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