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See also: [[followed by::IR 05000272/1989011]]


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{{#Wiki_filter:Public Service Electric and Gas Company Stanley LaBruna Public Service Electric sind Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-4800  
{{#Wiki_filter:Public Service Electric and Gas Company Stanley LaBruna Public Service Electric sind Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-4800 Vice Pres'1dent  
Vice Pres'1dent  
-f-Juclear Operauons AUG 0 7 1989 NLR-N89153 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
-f-Juclear  
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-272/89-11 AND 50-311/89-10 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated July 6, 1989, which included a Notice of Violation concerning failure to document the safety basis for the reactivity computer.
Operauons  
Pursuant to the requirements of 10CFR2.201, our response to this Notice of Violation is provided in the attachment to this letter. Should you have any questions in regards to this transmittal, do not hesitate to call. Attachment 8908170088 890807 PDR ADOCK 05000272 Q PNU Sincerely,   
AUG 0 7 1989 NLR-N89153  
**
United States Nuclear Regulatory  
* Document Control Desk NLR-N89153 C Mr. J. C. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector 2 Mr. W. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 AUG o 'i l:it.u
Commission  
* ATTACHMENT TO NLR-N89153 . PUBLIC SERVICE ELECTRIC AND GAS SALEM GENERATING STATION UNIT NOS. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION Your letter dated July 6, 1989 transmitted combined NRC Inspection Report 50-272/89-11 and 50-311/89-10 for Salem Units 1 and 2 which included a Notice of Violation pertaining to Salem Units 1 and 2. The specific item identified in the notice and our response is discussed in the following paragraphs.
Document Control Desk Washington, DC 20555 Gentlemen:  
Violation 272/89-11-03 lOCFR Part 50.59 permits the licensee to make changes in the facility without prior NRC approval provided that the change does not involve an unreviewed safety question (USQ). A written safety evaluation which provides the bases for the determination that a USQ is not involved must be completed and maintained.
RESPONSE TO NOTICE OF VIOLATION  
Contrary to the above, as of May 10, 1989, a reactivity computer had been added to both units' control rooms in close proximity to seismically qualified safety related equipment, and no safety evaluation existed documenting why no USQ was involved.
NRC INSPECTION  
RESPONSE PSE&G believes that the portable reactivity computers have been in place for both units since initial plant operation (Unit 1 -1977, Unit 2 -1981). Therefore, the requirements of 10CFR50.59 do not apply, since 10CFR50.59 applies only to modifications to the original plant configuration.
REPORT NO. 50-272/89-11  
Since the Inspection Report also addresses a seismic concern, an explanation of events pertinent to the reactivity computer follows. In 1984 Salem performed a complete walkdown of both units to ensure that all jumpers/lifted leads were documented in the design configuration of the plant. One of the jumpers identified in this effort was the reactivity computer.
AND 50-311/89-10  
An evaluation of the reactivity computer was performed in 1984, to correctly document the as found condition of the plant. This evaluation focused on the wiring which provides input to the reactivity computer from the plant instrumentation.
SALEM GENERATING  
This evaluation concluded that no unreviewed safety question was involved.
STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection  
In order to ensure proper documentation and control an evaluation was performed in April, 1988 to incorporate the jumper/lifted lead into the current TMOD (temporary modification) program. TMODs 88-088 (Unit 1) and 88-089 (Unit 2) concluded that a 50.59 was not involved based on the design basis of the Salem Units. However, the associated safety evaluation did note that the installation was seismically deficient in the Seismic II/I area. SORC I _J reviewed the TMOD and safety evaluation and determined that since the Salem licensing design basis did not commit to the Seismic II/I criteria, it was acceptable to leave the reactivity computer in plaqe until the computer could be installed seismically on the control room panel. Two design change packages were initiated (lSM-0687 and 2SM-0688), to permanently install this equipment in the control room. These packages were to be installed in the next refueling outage for each unit. In response to the inspector's concerns, a review of the Salem licensing, seismic design basis was performed.
report dated July 6, 1989, which included a Notice of Violation  
SNGS was not designed to a Seismic II/I criteria, and as the equipment is not safety related, it was not seismically mounted. This is consistent with the 1988 evaluation determination.
concerning  
The reactivity computer was identified as a seismic concern and.it was recognized that resolution would be addressed under the GL 87-02 implementation program. Based on the possibility of potential interaction with control room instrumentation and the NRC's expressed concerns, management decided to remove the equipment from the control rooms (except during startup activities), instead of awaiting resolution through the DCP process and or the implementation of the GL 87-02 program. CORRECTIVE ACTIONS IMPLEMENTED The reactivity computer racks have been removed from the Salem 1 and 2 control Rooms and will remain out pending permanent installation during the next refueling outage. The racks may be temporarily reinstalled to assist in plant startups.
failure to document the safety basis for the reactivity  
These reinstallations will be of relatively short duration and will be controlled under the appropriate station procedures.
computer.  
CORRECTIVE ACTIONS TO PREVENT RECURRENCE The reactivity computer is being permanently installed on the RP-3 panel as part of the Control Room Design Review process. The installation is currently scheduled for the next refueling outage for each unit (April, 1990 for Unit 2 and September, 1990 for Unit 1). The concerns over Seismic II/I are a recognized NRC and industry concern. PSE&G is actively involved in the Seismic Qualification Utility Group (SQUG) working to achieve resolution of this issue relative to unresolved Safety Issue A46. Salem is also subject to resolution under Generic Letter 87-02, which will require walkdowns and evaluations of equipment required for safe shutdown in the event of an Seismic Interaction (Seismic II/I) is one of the issues that has been included in the Generic Implementing Procedure (GIP) developed by the SQUG to address A46 and GL 87-02. As a result of the SQUG effort on A46 and GL 87-02, criteria have been developed for this program but remain open with the NRC pending resolution of some issues. Upon NRC final approval, as stated in our response to GL 87-02, PSE&G will begin the walkdowns and these will be completed within 2 outages. The criteria will also be incorporated into plant programmatic standards and Design Change Package (DCP) review forms to assure proper Seismic II/I review of future modifications.
Pursuant to the requirements  
Completion of these items is dependent on the final NRC review and approval of the GIP. -PSE&G IS IN FULL COMPLIANCE PSE&G's resolution of concerns associated with Seismic II/I issues is being addressed under GL 87-02 and Unresolved Safety Issue A46. The date of completion is contingent upon final NRC review and approval of the GIP prepared for guidance in addressing GL 87-02. PSE&G has committed to finalize plant walkdowns within 2 outages of the approval.
of 10CFR2.201, our response to this Notice of Violation  
Dependent on the results of the walkdowns, future modifications may be needed. The schedule for modifications cannot be determined until the scope of work is identified.
is provided in the attachment  
As such,. PSE&G intends to follow this issue through the resolution to Generic Letter 87-02. For further details, see the PSE&G response to the Generic Letter (PSE&G letter NLR-N88163 dated October 7, 1988).}}
to this letter. Should you have any questions  
in regards to this transmittal, do not hesitate to call. Attachment  
8908170088  
890807 PDR ADOCK 05000272 Q PNU Sincerely,   
** * Document Control Desk NLR-N89153  
C Mr. J. C. Stone Licensing  
Project Manager Ms. K. Halvey Gibson Senior Resident Inspector  
2 Mr. W. T. Russell, Administrator  
Region I Mr. Kent Tosch, Chief New Jersey Department  
of Environmental  
Protection  
Division of Environmental  
Quality Bureau of Nuclear Engineering  
CN 415 Trenton, NJ 08625 AUG o 'i l:it.u
* ATTACHMENT  
TO NLR-N89153 . PUBLIC SERVICE ELECTRIC AND GAS SALEM GENERATING  
STATION UNIT NOS. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION  
Your letter dated July 6, 1989 transmitted  
combined NRC Inspection  
Report 50-272/89-11  
and 50-311/89-10  
for Salem Units 1 and 2 which included a Notice of Violation  
pertaining  
to Salem Units 1 and 2. The specific item identified  
in the notice and our response is discussed  
in the following  
paragraphs.  
Violation  
272/89-11-03  
lOCFR Part 50.59 permits the licensee to make changes in the facility without prior NRC approval provided that the change does not involve an unreviewed  
safety question (USQ). A written safety evaluation  
which provides the bases for the determination  
that a USQ is not involved must be completed  
and maintained.  
Contrary to the above, as of May 10, 1989, a reactivity  
computer had been added to both units' control rooms in close proximity  
to seismically  
qualified  
safety related equipment, and no safety evaluation  
existed documenting  
why no USQ was involved.  
RESPONSE PSE&G believes that the portable reactivity  
computers  
have been in place for both units since initial plant operation (Unit 1 -1977, Unit 2 -1981). Therefore, the requirements  
of 10CFR50.59  
do not apply, since 10CFR50.59  
applies only to modifications  
to the original plant configuration.  
Since the Inspection  
Report also addresses  
a seismic concern, an explanation  
of events pertinent  
to the reactivity  
computer follows. In 1984 Salem performed  
a complete walkdown of both units to ensure that all jumpers/lifted  
leads were documented  
in the design configuration  
of the plant. One of the jumpers identified  
in this effort was the reactivity  
computer.  
An evaluation  
of the reactivity  
computer was performed  
in 1984, to correctly  
document the as found condition  
of the plant. This evaluation  
focused on the wiring which provides input to the reactivity  
computer from the plant instrumentation.  
This evaluation  
concluded  
that no unreviewed  
safety question was involved.  
In order to ensure proper documentation  
and control an evaluation  
was performed  
in April, 1988 to incorporate  
the jumper/lifted  
lead into the current TMOD (temporary  
modification)  
program. TMODs 88-088 (Unit 1) and 88-089 (Unit 2) concluded  
that a 50.59 was not involved based on the design basis of the Salem Units. However, the associated  
safety evaluation  
did note that the installation  
was seismically  
deficient  
in the Seismic II/I area. SORC I _J
reviewed the TMOD and safety evaluation  
and determined  
that since the Salem licensing  
design basis did not commit to the Seismic II/I criteria, it was acceptable  
to leave the reactivity  
computer in plaqe until the computer could be installed  
seismically  
on the control room panel. Two design change packages were initiated (lSM-0687  
and 2SM-0688), to permanently  
install this equipment  
in the control room. These packages were to be installed  
in the next refueling  
outage for each unit. In response to the inspector's  
concerns, a review of the Salem licensing, seismic design basis was performed.  
SNGS was not designed to a Seismic II/I criteria, and as the equipment  
is not safety related, it was not seismically  
mounted. This is consistent  
with the 1988 evaluation  
determination.  
The reactivity  
computer was identified  
as a seismic concern and.it was recognized  
that resolution  
would be addressed  
under the GL 87-02 implementation  
program. Based on the possibility  
of potential  
interaction  
with control room instrumentation  
and the NRC's expressed  
concerns, management  
decided to remove the equipment  
from the control rooms (except during startup activities), instead of awaiting resolution  
through the DCP process and or the implementation  
of the GL 87-02 program. CORRECTIVE  
ACTIONS IMPLEMENTED  
The reactivity  
computer racks have been removed from the Salem 1 and 2 control Rooms and will remain out pending permanent  
installation  
during the next refueling  
outage. The racks may be temporarily  
reinstalled  
to assist in plant startups.  
These reinstallations  
will be of relatively  
short duration and will be controlled  
under the appropriate  
station procedures.  
CORRECTIVE  
ACTIONS TO PREVENT RECURRENCE  
The reactivity  
computer is being permanently  
installed  
on the RP-3 panel as part of the Control Room Design Review process. The installation  
is currently  
scheduled  
for the next refueling  
outage for each unit (April, 1990 for Unit 2 and September, 1990 for Unit 1). The concerns over Seismic II/I are a recognized  
NRC and industry concern. PSE&G is actively involved in the Seismic Qualification  
Utility Group (SQUG) working to achieve resolution  
of this issue relative to unresolved  
Safety Issue A46. Salem is also subject to resolution  
under Generic Letter  
87-02, which will require walkdowns  
and evaluations  
of equipment  
required for safe shutdown in the event of an  
Seismic Interaction (Seismic II/I) is one of the issues that has been included in the Generic Implementing  
Procedure (GIP) developed  
by the SQUG to address A46 and GL 87-02. As a result of the SQUG effort on A46 and GL 87-02, criteria have been developed  
for this program but remain open with the NRC pending resolution  
of some issues. Upon NRC final approval, as stated in our response to GL 87-02, PSE&G will
begin the walkdowns  
and these will be completed  
within 2 outages. The criteria will also be incorporated  
into plant programmatic  
standards  
and Design Change Package (DCP) review forms to assure proper Seismic II/I review of future modifications.  
Completion  
of these items is dependent  
on the final NRC review and approval of the GIP. -PSE&G IS IN FULL COMPLIANCE  
PSE&G's resolution  
of concerns associated  
with Seismic II/I issues is being addressed  
under GL 87-02 and Unresolved  
Safety Issue A46. The date of completion  
is contingent  
upon final NRC review and approval of the GIP prepared for guidance in addressing  
GL 87-02. PSE&G has committed  
to finalize plant walkdowns  
within 2 outages of the approval.  
Dependent  
on the results of the walkdowns, future modifications  
may be needed. The schedule for  
modifications  
cannot be determined  
until the scope of work is identified.  
As such,. PSE&G intends to follow this issue through the resolution  
to Generic Letter 87-02. For further details, see the PSE&G response to the Generic Letter (PSE&G letter NLR-N88163  
dated October 7, 1988).
}}

Revision as of 19:56, 31 July 2019

Responds to Violations Noted in Insp Repts 50-272/89-11 & 50-311/89-10.Corrective Actions:Reactivity Computer Racks Removed from Control Rooms of Facilities & Will Remain Out Pending Permanent Installation During Next Refueling
ML18094A611
Person / Time
Site: Salem  PSEG icon.png
Issue date: 08/07/1989
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89153, NUDOCS 8908170088
Download: ML18094A611 (5)
v • d • e


Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric sind Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-4800 Vice Pres'1dent

-f-Juclear Operauons AUG 0 7 1989 NLR-N89153 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-272/89-11 AND 50-311/89-10 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated July 6, 1989, which included a Notice of Violation concerning failure to document the safety basis for the reactivity computer.

Pursuant to the requirements of 10CFR2.201, our response to this Notice of Violation is provided in the attachment to this letter. Should you have any questions in regards to this transmittal, do not hesitate to call. Attachment 8908170088 890807 PDR ADOCK 05000272 Q PNU Sincerely,

  • Document Control Desk NLR-N89153 C Mr. J. C. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector 2 Mr. W. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 AUG o 'i l:it.u
  • ATTACHMENT TO NLR-N89153 . PUBLIC SERVICE ELECTRIC AND GAS SALEM GENERATING STATION UNIT NOS. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION Your letter dated July 6, 1989 transmitted combined NRC Inspection Report 50-272/89-11 and 50-311/89-10 for Salem Units 1 and 2 which included a Notice of Violation pertaining to Salem Units 1 and 2. The specific item identified in the notice and our response is discussed in the following paragraphs.

Violation 272/89-11-03 lOCFR Part 50.59 permits the licensee to make changes in the facility without prior NRC approval provided that the change does not involve an unreviewed safety question (USQ). A written safety evaluation which provides the bases for the determination that a USQ is not involved must be completed and maintained.

Contrary to the above, as of May 10, 1989, a reactivity computer had been added to both units' control rooms in close proximity to seismically qualified safety related equipment, and no safety evaluation existed documenting why no USQ was involved.

RESPONSE PSE&G believes that the portable reactivity computers have been in place for both units since initial plant operation (Unit 1 -1977, Unit 2 -1981). Therefore, the requirements of 10CFR50.59 do not apply, since 10CFR50.59 applies only to modifications to the original plant configuration.

Since the Inspection Report also addresses a seismic concern, an explanation of events pertinent to the reactivity computer follows. In 1984 Salem performed a complete walkdown of both units to ensure that all jumpers/lifted leads were documented in the design configuration of the plant. One of the jumpers identified in this effort was the reactivity computer.

An evaluation of the reactivity computer was performed in 1984, to correctly document the as found condition of the plant. This evaluation focused on the wiring which provides input to the reactivity computer from the plant instrumentation.

This evaluation concluded that no unreviewed safety question was involved.

In order to ensure proper documentation and control an evaluation was performed in April, 1988 to incorporate the jumper/lifted lead into the current TMOD (temporary modification) program. TMODs88-088 (Unit 1) and 88-089 (Unit 2) concluded that a 50.59 was not involved based on the design basis of the Salem Units. However, the associated safety evaluation did note that the installation was seismically deficient in the Seismic II/I area. SORC I _J reviewed the TMOD and safety evaluation and determined that since the Salem licensing design basis did not commit to the Seismic II/I criteria, it was acceptable to leave the reactivity computer in plaqe until the computer could be installed seismically on the control room panel. Two design change packages were initiated (lSM-0687 and 2SM-0688), to permanently install this equipment in the control room. These packages were to be installed in the next refueling outage for each unit. In response to the inspector's concerns, a review of the Salem licensing, seismic design basis was performed.

SNGS was not designed to a Seismic II/I criteria, and as the equipment is not safety related, it was not seismically mounted. This is consistent with the 1988 evaluation determination.

The reactivity computer was identified as a seismic concern and.it was recognized that resolution would be addressed under the GL 87-02 implementation program. Based on the possibility of potential interaction with control room instrumentation and the NRC's expressed concerns, management decided to remove the equipment from the control rooms (except during startup activities), instead of awaiting resolution through the DCP process and or the implementation of the GL 87-02 program. CORRECTIVE ACTIONS IMPLEMENTED The reactivity computer racks have been removed from the Salem 1 and 2 control Rooms and will remain out pending permanent installation during the next refueling outage. The racks may be temporarily reinstalled to assist in plant startups.

These reinstallations will be of relatively short duration and will be controlled under the appropriate station procedures.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE The reactivity computer is being permanently installed on the RP-3 panel as part of the Control Room Design Review process. The installation is currently scheduled for the next refueling outage for each unit (April, 1990 for Unit 2 and September, 1990 for Unit 1). The concerns over Seismic II/I are a recognized NRC and industry concern. PSE&G is actively involved in the Seismic Qualification Utility Group (SQUG) working to achieve resolution of this issue relative to unresolved Safety Issue A46. Salem is also subject to resolution under Generic Letter 87-02, which will require walkdowns and evaluations of equipment required for safe shutdown in the event of an Seismic Interaction (Seismic II/I) is one of the issues that has been included in the Generic Implementing Procedure (GIP) developed by the SQUG to address A46 and GL 87-02. As a result of the SQUG effort on A46 and GL 87-02, criteria have been developed for this program but remain open with the NRC pending resolution of some issues. Upon NRC final approval, as stated in our response to GL 87-02, PSE&G will begin the walkdowns and these will be completed within 2 outages. The criteria will also be incorporated into plant programmatic standards and Design Change Package (DCP) review forms to assure proper Seismic II/I review of future modifications.

Completion of these items is dependent on the final NRC review and approval of the GIP. -PSE&G IS IN FULL COMPLIANCE PSE&G's resolution of concerns associated with Seismic II/I issues is being addressed under GL 87-02 and Unresolved Safety Issue A46. The date of completion is contingent upon final NRC review and approval of the GIP prepared for guidance in addressing GL 87-02. PSE&G has committed to finalize plant walkdowns within 2 outages of the approval.

Dependent on the results of the walkdowns, future modifications may be needed. The schedule for modifications cannot be determined until the scope of work is identified.

As such,. PSE&G intends to follow this issue through the resolution to Generic Letter 87-02. For further details, see the PSE&G response to the Generic Letter (PSE&G letter NLR-N88163 dated October 7, 1988).

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