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See also: [[followed by::IR 05000272/1992007]]


=Text=
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{{#Wiki_filter:Public Service Electric and Gas Company, Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200  
{{#Wiki_filter:Public Service Electric and Gas
Vice President  
: Company, Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nu_clear Operations AUG 1 O 1992 NLR-N92100 United States Nuclear Regulatory Commission Document Control Desk Was.hington, DC 20555 Gentlemen:
-Nu_clear Operations  
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/92-07, 50-311/92-07, 50-354/92-06 DOCKET NOS. 50-272 I 50-3_11 AND 50-354 Public Service Electric and. Gas (PSE&G) has received the Inspection Report dated' July 2, 1992.
* AUG 1 O 1992 NLR-N92100  
Within the scope of this inspection, one apparent violation of NRC requirements was identified (VIO 272 and 311/92-07-02)
United States Nuclear Regulatory  
The violation concerns the failure to adequately assess and provide information relative to the on-site storage of ammonium hydroxide and its potential effect on control room habitability as required by a July 10, 1981 NRC Order.
Commission  
Pursuant to.the requirements of 10 CFR 2.201, PSE&G hereby submits its response to the notice of violation.
Document Control Desk Was.hington, DC 20555 Gentlemen:  
Should you have any questions in regard to this.transmittal, qo not hesitate to call.
RESPONSE TO NOTICE OF VIOLATION  
Attachment 920010 05000272 PDR Sincerely,  
NRC INSPECTION  
 
REPORT NOS. 50-272/92-07, 50-311/92-07, 50-354/92-06  
.Document Control Desk NLR-N92100 2*
DOCKET NOS. 50-272 I 50-3_11 AND 50-354 Public Service Electric and. Gas (PSE&G) has received the Inspection  
c Mr. T. T. Martin, Administrator - Region I.
Report dated' July 2, 1992. Within the scope of this inspection, one apparent violation  
: u. S.; Nuclear Regulatory Commission.
of NRC requirements  
475 Allendale Road King of Prussia, PA 19406 Mr. J. C. Stone, Licensing Project Manager
was identified (VIO 272 and 311/92-07-02)  
: u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Ms. A. *Keller
The violation  
: u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. T. P. Johnson (509)
concerns the failure to adequately  
USNRC Senior Resident Inspector
assess and provide information  
* Mr. K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 AUG 1 O 1992  
relative to the on-site storage of ammonium hydroxide  
 
and its potential  
Document Control Desk NLR-N92100 ATTACHMENT As a result of the inspection at Salem Station during December 16-20, 1991, and in accordancewith the "General Statement of
effect on control room habitability  
.Policy and Procedure forNRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), the following violation was identified:
as required by a July 10, 1981 NRC Order. Pursuant to.the requirements  
On July 10, 1981, an Order Confirming Licensee Commitments on Post-TM! Related Issues was issued to PSE&G.
of 10 CFR 2.201, PSE&G hereby submits its response to the notice of violation.  
Section IV of the Order stated in part, "IT IS HEREBY ORDERED EFFECTIVE IMMEDIATELY THAT the licensee shall comply with the following conditions:
* Should you have any questions  
The licensee shall.satisfy the specific requirements described in.
in regard to this.transmittal, qo not hesitate to call. Attachment  
the Attachment to this Order (as appropriate to the licensee's facility) as early as practicable but no later than 60 days after the effective date of the ORDER~"
920010 05000272 PDR Sincerely,
The Attachment to the Order provided specific requirements for, among other matters, NUREG-0737 Item III.D.3.4, Control Room Habitability.
.Document  
The Attachment to the Order required that the  
Control Desk NLR-N92100  
'licensee submit, by January 1, 1981, a control room habitability evaluation meeting the requirements of NUREG-0737 Item III.D.3.4.
2* c Mr. T. T. Martin, Administrator  
Contrary to the above, PSE&G failed to satisfy the specific requirements of NUREG-0737 Item III.D.3.4 in that, as of September 13, 1991, PSE&G failed to evaluate the potential impact, relative to NUREG-0737 Item III.D.3.4, of a release* of ammonium hydroxide from transfer to and storage in a 3000 gallon storage tank located o.n the
-Region I. u. S.; Nuclear Regulatory  
* 12 O foot elevation of the Unit 1 Turbine Building, on control room habitability.
Commission.  
In addition, PSE&G's responses dated July 1, 1980 and August 13, 1980, submitted in response to NUREG-0737 Item III.D.3.4, failed to provide information relative to the presence of ammonium hydroxide.
475 Allendale  
PSE&G DOES NOT DISPUTE THE VIOLATION ROOT CAUSE The root cause was attr'ibut~d to inadequate depth of evaluation.
Road King of Prussia, PA 19406 Mr. J. C. Stone, Licensing  
A contributfng cause was inadequate documentation of analysis.
Project Manager u. s. Nuclear Regulatory  
Salem Unit 1 FSAR was approved and an operating license issued with no commitment to the then recently issued Regulatory Guide
Commission  
: 1. 78
One White Flint North 11555 Rockville  
* Document Control Desk NLR-N92100 In the process of licensing Saiem Unit 2, an-assessment was made on compliance to Regulatory Guide 1.78.
Pike Rockville, MD 20852 Ms. A. *Keller u. s. Nuclear Regulatory  
An internal memorandum,  
Commission  
-dated September 14, 1977, qualitatively evaluated several chemicals, including ammonium hydroxide, for impact on control room habitability. It was concluded at that time (September 14, 1977), that since ammonium hydroxide was not listed in Regulatory Guide 1.78 nor its reference :documents, it was not considered a hazardous chemical concern for control room habitability.
One White Flint North 11555 Rockville  
In responding to TMI Action Item III.D.3.4 the previous qualitative evaluation of September 14, 1977 and additional assessments, were used to support PSE&G's responses dated July 1, 1980 and August 13, 1980. -
Pike Rockville, MD 20852 Mr. T. P. Johnson (509) USNRC Senior Resident Inspector  
As a result of evaluations conducted in the fall of 199i, it was -
* Mr. K. Tosch, Chief NJ Department  
concluded, that even though ammonium hydroxide is a dilute liquid, ammonia gas could evolve from spilled ammonium hydroxide under postulated accident conditions.
of Environmental  
Therefore, a postulated accident of ammonium hydroxide storage was evaluated for impact on control room habitability.
Protection  
CORRECTIVE ACTIONS TAKEN Upon notification of the discrepancy, a preliminary safety assessment was conducted using the computer code "CHARM", and a site survey performed for identification of any additional*
Division of Environmental  
potentially hazardous chemicals.
Quality Bureau of Nuclear Engineering  
The preliminary "CHARM".results concluded that there was no impact on control room habitability from a postulated ammonium hydroxide accident.
CN 415 Trenton, NJ 08625 AUG 1 O 1992
In order _to provide a timely response for a final safety evaluation, a different computer code "VAPOR'' was used because "CHARM" was not validated and verified to PSE&G software requirements.
* Document Control Desk NLR-N92100  
PSE&G used the "VAPOR" code for the safety evaluation because its software had been documented and verified to comply with appropriate QA requirements for use in "important to safety" evaluations. As a result of finalizing the safety evaluation for control room habitability using the "VAPOR" computer code; additional actions were taken to address the analysis conclusion  
ATTACHMENT  
*that the toxic limit in the control *room may be exceeded.
As a result of the inspection  
The immediate compensatory measures included placing a temperature indicator and strip chart recorder in the storage tank area, limiting the amount of ammonium hydroxide volume stored, performed an engineering evaluation and subsequently reduced the concentration of ammonium hydroxide used at Salem to 15 wt%, and initiating precautionary administrative controls for tanker truck deliveries.  
at Salem Station during December 16-20, 1991, and in accordancewith  
 
the "General Statement  
Document Control Desk NLR-N92100 A preliminary analysis was conducted for the two additional chemicals, hydrazine and sodium hydroxide, -identified as a *result of the site survey.* The preliminary assessment resulted in chemical concentrations within the control room that did not
of .Policy and Procedure  
* exceed the toxic limits provided in authoritative sources.  
forNRC Enforcement  
- Therefore, it was concluded there.would be no impact on control room habitability as* a result of a postulated accident regarding either hydrazine or sodium hydroxide.
Actions," 10 CFR Part 2, Appendix C (1992), the following  
During the approval cycle for the control room habitability calculation, PSE&G questioned the "VAPOR" model assumptions and design input and determined they were very conservative.
violation  
As a result, the "CHARM" model was validated*and verified and used to complete the final evaluations. The additional evaluations used
was identified:  
.NRC regulatory criteria in the validated and verified "CHARM 1i computer code for the postulated accidents for both 27.5 and 15 wt.% ammonium hydroxide storage tank concentrations.
On July 10, 1981, an Order Confirming  
* The evaluations, utilizing the "CHARM" code model, concluded that the Regulatory Guide.1.78 toxic limit for anhydrous ammonia, based on the concentration that can be tolerated for two minutes, will not be exceeded in the control room during a postulated release at the*tank containing either 27.5 wt% or 15.wt.%
Licensee Commitments  
ammonium hydroxide.
on Post-TM! Related Issues was issued to PSE&G. Section IV of the Order stated in part, "IT IS HEREBY ORDERED EFFECTIVE  
since the concentration of ammonium hydroxide was reduced, the  
IMMEDIATELY  
.amount of deliveries on an annual basis, was anticipated to exceed the frequency threshold value for truck traffic of ten per year per Regulatory Guide 1.78.
THAT the licensee shall comply with the following  
When the frequency criteria are applicable, Regulatory Guide 1.78 requires evaluation of the shipments for impact on control room habitability.
conditions:  
Therefore, included in the additional evaluations were postulated accidents to tanker delivery trucks containing 15 wt.% ammonium hydroxide at the site main access point and.Salem unloading dock.
The licensee shall.satisfy  
A final evaluation of the two additional chemicals was conducted using the validated and verified "CHARM" computer code for hydrazine and a quaiitative analysis for sodium hydroxide.
the specific requirements  
The final evaluation confirmed the preliminary assessment that control room habitability would not be impacted.
described  
A qualitative -
in. the Attachment  
evaluation was conducted for sodium hydroxide because-of its high boiling point and very low volatility.
to this Order (as appropriate  
Under postulated accident conditions no credible. toxic airborne source can be determined.
to the licensee's  
The short term corrective actions immediately implemented, that are currently in place, are the administrative controls for tanker truck deliveries and use of 15 wt.% concentration ammonium hydroxide.
facility)  
However, the "CHARM" code model evaluations support future use of 27.5 wt.% ammonium hydroxide, and the.elimination of both tank volume restrictions and continued temperature monitoring of the storage tank area.  
as early as practicable  
 
but no later than 60 days after the effective  
Document Control Desk NLR-N92100 Administrative controls were instituted, per issuance of Chemistry procedure SC.CH-AD.z*z-0474, for the operators at Salem to isolate the control room when riotif ied that a tanker truck transporting ammonium hydroxide is*requesting site access for delivery.* The administrative controls also included notification of Hope Creek operators that an ammonium hydroxide delivery is being made for Salem.
date of the  
Evaluations, utilizing the "CHARM" code model, conclude that Regulatory Guide 1.78 toxic limits will *not be exceeded in the aope Creek control room therefore, *operator action is not required to isolate the control room~
The Attachment  
Operator training was conducted to identify.the odor of ammonia and ammonia was added to the annual olfactory recognition testing performed by the Medical Department on licensed operators~ *An Abnormal Operating Procedure, SC.OP-AB.CR-0003(Q),. "Toxic Gas Release", was issued for Salem Generating Station to isolate the control room upon notification or detection by odor of ammonia in the control room.
to the Order provided specific requirements  
Hope Creek is also required to be notified.
for, among other matters, NUREG-0737  
A similar procedure for Hope Creek already existed.
Item III.D.3.4, Control Room -Habitability.  
Changes to the Salem and Hope Creek UFSAR's have been completed that revise appropriate Sectio*ns to identify additional chemicals transported to and stored onsite, discuss the evaluations for control room habitability for these. additional cnemicals, and describe Salem's position on Regulatory Guide 1.78.
The Attachment  
The UFSAR changes will be incorporated in the next scheduled revision update.
to the Order required that the 'licensee  
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE Procedure*NC.NA-AP.ZZ-0019(Q), "Procurement of Materials and Services" is being revised to limit the procurement of quantities of new chemicais to be brought onsite to less than 100 pound containers unless analyzed for their impact on control room habitability.
submit, by January 1, 1981, a control room habitability  
In the interim, direction on chemical procurement concerning toxic hazards*was provided by PSE&G memorandum, GM Nuclear Services to GM Procurement Material Control,. dated April 8, 1992.
evaluation  
Nuclear Administrative Procedure NC.NA-AP.ZZ-0038(Q), "The Chemical Control Program", was revised to require review of chemicals for control room habitability before use.
meeting the requirements  
Procedure NC.DE-AP.ZZ-OOOl(Q), "Design Bases/Input", was revised to address the possible impact from hazardous chemicals, used in conjunction with or added by Design Changes, on control r.oom habitability.  
of NUREG-0737  
 
Item III.D.3.4.  
Document Control Desk NLR-N92100 In addition to the above specific changes, improvements to the engineering process have been implemented since the review and evaluation for* the original response to the TMI Action Item III.D.3.4.
Contrary to the above, PSE&G failed to satisfy the specific requirements  
Safety Evaluations (10CFR50.59) are more defined and comprehensive today to include nonsafety system interaction on safety systems such as the Chemical.Feed System using ammonium hydroxide.
of NUREG-0737  
Design Changes require a formalized design
Item III.D.3.4  
*bases/input process that include use of design considerations and specialty review checklists, interface record sheets, multiple.
in that, as of September  
reviews including peer review in addition to independent design verification, and cross discipline and programmatic review.
13, 1991, PSE&G failed to evaluate the potential  
PSE&G.is in full compliance}}
impact, relative to NUREG-0737  
Item III.D.3.4, of a release* of ammonium hydroxide  
from transfer to and storage in a 3000 gallon storage tank located o.n the * 12 O foot elevation  
of the Unit 1 Turbine Building, on control room habitability.  
In addition, PSE&G's responses  
dated July 1, 1980 and August 13, 1980, submitted  
in response to NUREG-0737  
Item III.D.3.4, failed to provide information  
relative to the presence of ammonium hydroxide.  
PSE&G DOES NOT DISPUTE THE VIOLATION  
ROOT CAUSE The root cause was  
to inadequate  
depth of evaluation.  
A contributfng  
cause was inadequate  
documentation  
of analysis.  
Salem Unit 1 FSAR was approved and an operating  
license issued with no commitment  
to the then recently issued Regulatory  
Guide 1. 78 * 
* Document Control Desk NLR-N92100  
In the process of licensing  
Saiem Unit 2, an-assessment  
was made on compliance  
to Regulatory  
Guide 1.78. An internal memorandum, -dated September  
14, 1977, qualitatively  
evaluated  
several chemicals, including  
ammonium hydroxide, for impact on control room habitability.  
It was concluded  
at that time (September  
14, 1977), that since ammonium hydroxide  
was not listed in Regulatory  
Guide 1.78 nor its reference  
:documents, it was not considered  
a hazardous  
chemical concern for control room habitability.  
In responding  
to TMI Action Item III.D.3.4  
the previous qualitative  
evaluation  
of September  
14, 1977 and additional  
assessments, were used to support PSE&G's responses  
dated July 1, 1980 and August 13, 1980. -As a result of evaluations  
conducted  
in the fall of 199i, it was -concluded, that even though ammonium hydroxide  
is a dilute liquid, ammonia gas could evolve from spilled ammonium hydroxide  
under postulated  
accident conditions.  
Therefore, a postulated  
accident of ammonium hydroxide  
storage was evaluated  
for impact on control room habitability.  
CORRECTIVE  
ACTIONS TAKEN Upon notification  
of the discrepancy, a preliminary  
safety assessment  
was conducted  
using the computer code "CHARM", and a site survey performed  
for identification  
of any additional*  
potentially  
hazardous  
chemicals.  
The preliminary "CHARM".results  
concluded  
that there was no impact on control room habitability  
from a postulated  
ammonium hydroxide  
accident.  
In order _to provide a timely response for a final safety evaluation, a different  
computer code "VAPOR'' was used because "CHARM" was not validated  
and verified to PSE&G software requirements.  
PSE&G used the "VAPOR" code for the safety evaluation  
because its software had been documented  
and verified to comply with appropriate  
QA requirements  
for use in "important  
to safety" evaluations.  
As a result of finalizing  
the safety evaluation  
for control room habitability  
using the "VAPOR" computer code; additional  
actions were taken to address the analysis conclusion  
*that the toxic limit in the control *room may be exceeded.  
The immediate  
compensatory  
measures included placing a temperature  
indicator  
and strip chart recorder in the storage tank area, limiting the amount of ammonium hydroxide  
volume stored, performed  
an engineering  
evaluation  
and subsequently  
reduced the concentration  
of ammonium hydroxide  
used at Salem to 15 wt%, and initiating  
precautionary  
administrative  
controls for tanker truck deliveries.  
* 
* Document Control Desk NLR-N92100  
A preliminary  
analysis was conducted  
for the two additional  
chemicals, hydrazine  
and sodium hydroxide, -identified  
as a *result of the site survey.* The preliminary  
assessment  
resulted in chemical concentrations  
within the control room that did not * exceed the toxic limits provided in authoritative  
sources. -Therefore, it was concluded  
there.would  
be no impact on control room habitability  
as* a result of a postulated  
accident regarding  
either hydrazine  
or sodium hydroxide.  
-During the approval cycle for the control room habitability  
calculation, PSE&G questioned  
the "VAPOR" model assumptions  
and design input and determined  
they were very conservative.  
As a result, the "CHARM" model was validated*and  
verified and used to complete the final evaluations.  
The additional  
evaluations  
used .NRC regulatory  
criteria in the validated  
and verified "CHARM 1 i computer code for the postulated  
accidents  
for both 27.5 and 15 wt.% ammonium hydroxide  
storage tank concentrations.  
* The evaluations, utilizing  
the "CHARM" code model, concluded  
that the Regulatory  
Guide .1.78 toxic limit for anhydrous  
ammonia, based on the concentration  
that can be tolerated  
for two minutes, will not be exceeded in the control room during a postulated  
release at the*tank containing  
either 27.5 wt% or 15 .wt.% ammonium hydroxide.  
since the concentration  
of ammonium hydroxide  
was reduced, the .amount of deliveries  
on an annual basis, was anticipated  
to exceed the frequency  
threshold  
value for truck traffic of ten per year per Regulatory  
Guide 1.78. When the frequency  
criteria are applicable, Regulatory  
Guide 1.78 requires evaluation  
of the shipments  
for impact on control room habitability.  
Therefore, included in the additional  
evaluations  
were postulated  
accidents  
to tanker delivery trucks containing  
15 wt.% ammonium hydroxide  
at the site main access point and.Salem  
unloading  
dock. A final evaluation  
of the two additional  
chemicals  
was conducted  
using the validated  
and verified "CHARM" computer code for hydrazine  
and a quaiitative  
analysis for sodium hydroxide.  
The final evaluation  
confirmed  
the preliminary  
assessment  
that control room habitability  
would not be impacted.  
A qualitative  
-evaluation  
was conducted  
for sodium hydroxide  
because-of  
its high boiling point and very low volatility.  
Under postulated  
accident conditions  
no credible.  
toxic airborne source can be determined.  
The short term corrective  
actions immediately  
implemented, that are currently  
in place, are the administrative  
controls for tanker truck deliveries  
and use of 15 wt.% concentration  
ammonium hydroxide.  
However, the "CHARM" code model evaluations  
support future use of 27.5 wt.% ammonium hydroxide, and the.elimination  
of both tank volume restrictions  
and continued  
temperature  
monitoring  
of the storage tank area.
-Document Control Desk NLR-N92100  
Administrative  
controls were instituted, per issuance of Chemistry  
procedure  
SC.CH-AD.z*z-0474, for the operators  
at Salem to isolate the control room when riotif ied that a tanker truck transporting  
ammonium hydroxide  
is*requesting  
site access for delivery.*  
The administrative  
controls also included notification  
of Hope Creek operators  
that an ammonium hydroxide  
delivery is being made for Salem. Evaluations, utilizing  
the "CHARM" code model, conclude that Regulatory  
Guide 1.78 toxic limits will *not be exceeded in the aope Creek control room therefore, *operator  
action is not required to isolate the control  
Operator training was conducted  
to identify.the  
odor of ammonia and ammonia was added to the annual olfactory  
recognition  
testing performed  
by the Medical Department  
on licensed  
*An Abnormal Operating  
Procedure, SC.OP-AB.CR-0003(Q),. "Toxic Gas Release", was issued for Salem Generating  
Station to isolate the control room upon notification  
or detection  
by odor of ammonia in the control room. Hope Creek is also required to be notified.  
A similar procedure  
for Hope Creek already existed. Changes to the Salem and Hope Creek UFSAR's have been completed  
that revise appropriate  
Sectio*ns  
to identify additional  
chemicals  
transported  
to and stored onsite, discuss the evaluations  
for control room habitability  
for these. additional  
cnemicals, and describe Salem's position on Regulatory  
Guide 1.78. The UFSAR changes will be incorporated  
in the next scheduled  
revision update. -CORRECTIVE  
ACTIONS TAKEN TO PREVENT RECURRENCE  
Procedure*NC.NA-AP.ZZ-0019(Q), "Procurement  
of Materials  
and Services" is being revised to limit the procurement  
of quantities  
of new chemicais  
to be brought onsite to less than 100 pound containers  
unless analyzed for their impact on control room habitability.  
In the interim, direction  
on chemical procurement  
concerning  
toxic hazards*was  
provided by PSE&G memorandum, GM Nuclear Services to GM Procurement  
Material Control,.  
dated April 8, 1992. Nuclear Administrative  
Procedure  
NC.NA-AP.ZZ-0038(Q), "The Chemical Control Program", was revised to require review of chemicals  
for control room habitability  
before use. Procedure  
NC.DE-AP.ZZ-OOOl(Q), "Design Bases/Input", was revised to address the possible impact from hazardous  
chemicals, used in conjunction  
with or added by Design Changes, on control r.oom habitability.
' , *. Document Control Desk NLR-N92100  
In addition to the above specific changes, improvements  
to the engineering  
process have been implemented  
since the review and evaluation  
for* the original response to the TMI Action Item III.D.3.4.  
Safety Evaluations  
(10CFR50.59)  
are more defined and comprehensive  
today to include nonsafety  
system interaction  
on safety systems such as the Chemical.Feed  
System using ammonium hydroxide.  
Design Changes require a formalized  
design *bases/input  
process that include use of design considerations  
and specialty  
review checklists, interface  
record sheets, multiple . reviews including  
peer review in addition to independent  
design verification, and cross discipline  
and programmatic  
review. PSE&G .is in full compliance
}}

Latest revision as of 02:22, 6 January 2025

Responds to Violations Noted in Insp Repts 50-272/92-07 & 50-311/92-07 on 911216-20.Corrective Actions:Temp Indicator & Strip Chart Recorder Placed in Storage Tank Area to Limit Amount of Ammonium Hydroxide Vol Stored
ML18096A879
Person / Time
Site: Salem  PSEG icon.png
Issue date: 08/10/1992
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N92100, NUDOCS 9208140125
Download: ML18096A879 (7)
v • d • e


Text

Public Service Electric and Gas

Company, Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nu_clear Operations AUG 1 O 1992 NLR-N92100 United States Nuclear Regulatory Commission Document Control Desk Was.hington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/92-07, 50-311/92-07, 50-354/92-06 DOCKET NOS. 50-272 I 50-3_11 AND 50-354 Public Service Electric and. Gas (PSE&G) has received the Inspection Report dated' July 2, 1992.

Within the scope of this inspection, one apparent violation of NRC requirements was identified (VIO 272 and 311/92-07-02)

The violation concerns the failure to adequately assess and provide information relative to the on-site storage of ammonium hydroxide and its potential effect on control room habitability as required by a July 10, 1981 NRC Order.

Pursuant to.the requirements of 10 CFR 2.201, PSE&G hereby submits its response to the notice of violation.

Should you have any questions in regard to this.transmittal, qo not hesitate to call.

Attachment 920010 05000272 PDR Sincerely,

.Document Control Desk NLR-N92100 2*

c Mr. T. T. Martin, Administrator - Region I.

u. S.; Nuclear Regulatory Commission.

475 Allendale Road King of Prussia, PA 19406 Mr. J. C. Stone, Licensing Project Manager

u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Ms. A. *Keller
u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. T. P. Johnson (509)

USNRC Senior Resident Inspector

  • Mr. K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 AUG 1 O 1992

Document Control Desk NLR-N92100 ATTACHMENT As a result of the inspection at Salem Station during December 16-20, 1991, and in accordancewith the "General Statement of

.Policy and Procedure forNRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), the following violation was identified:

On July 10, 1981, an Order Confirming Licensee Commitments on Post-TM! Related Issues was issued to PSE&G.

Section IV of the Order stated in part, "IT IS HEREBY ORDERED EFFECTIVE IMMEDIATELY THAT the licensee shall comply with the following conditions:

The licensee shall.satisfy the specific requirements described in.

the Attachment to this Order (as appropriate to the licensee's facility) as early as practicable but no later than 60 days after the effective date of the ORDER~"

The Attachment to the Order provided specific requirements for, among other matters, NUREG-0737 Item III.D.3.4, Control Room Habitability.

The Attachment to the Order required that the

'licensee submit, by January 1, 1981, a control room habitability evaluation meeting the requirements of NUREG-0737 Item III.D.3.4.

Contrary to the above, PSE&G failed to satisfy the specific requirements of NUREG-0737 Item III.D.3.4 in that, as of September 13, 1991, PSE&G failed to evaluate the potential impact, relative to NUREG-0737 Item III.D.3.4, of a release* of ammonium hydroxide from transfer to and storage in a 3000 gallon storage tank located o.n the

In addition, PSE&G's responses dated July 1, 1980 and August 13, 1980, submitted in response to NUREG-0737 Item III.D.3.4, failed to provide information relative to the presence of ammonium hydroxide.

PSE&G DOES NOT DISPUTE THE VIOLATION ROOT CAUSE The root cause was attr'ibut~d to inadequate depth of evaluation.

A contributfng cause was inadequate documentation of analysis.

Salem Unit 1 FSAR was approved and an operating license issued with no commitment to the then recently issued Regulatory Guide

1. 78
  • Document Control Desk NLR-N92100 In the process of licensing Saiem Unit 2, an-assessment was made on compliance to Regulatory Guide 1.78.

An internal memorandum,

-dated September 14, 1977, qualitatively evaluated several chemicals, including ammonium hydroxide, for impact on control room habitability. It was concluded at that time (September 14, 1977), that since ammonium hydroxide was not listed in Regulatory Guide 1.78 nor its reference :documents, it was not considered a hazardous chemical concern for control room habitability.

In responding to TMI Action Item III.D.3.4 the previous qualitative evaluation of September 14, 1977 and additional assessments, were used to support PSE&G's responses dated July 1, 1980 and August 13, 1980. -

As a result of evaluations conducted in the fall of 199i, it was -

concluded, that even though ammonium hydroxide is a dilute liquid, ammonia gas could evolve from spilled ammonium hydroxide under postulated accident conditions.

Therefore, a postulated accident of ammonium hydroxide storage was evaluated for impact on control room habitability.

CORRECTIVE ACTIONS TAKEN Upon notification of the discrepancy, a preliminary safety assessment was conducted using the computer code "CHARM", and a site survey performed for identification of any additional*

potentially hazardous chemicals.

The preliminary "CHARM".results concluded that there was no impact on control room habitability from a postulated ammonium hydroxide accident.

In order _to provide a timely response for a final safety evaluation, a different computer code "VAPOR was used because "CHARM" was not validated and verified to PSE&G software requirements.

PSE&G used the "VAPOR" code for the safety evaluation because its software had been documented and verified to comply with appropriate QA requirements for use in "important to safety" evaluations. As a result of finalizing the safety evaluation for control room habitability using the "VAPOR" computer code; additional actions were taken to address the analysis conclusion

  • that the toxic limit in the control *room may be exceeded.

The immediate compensatory measures included placing a temperature indicator and strip chart recorder in the storage tank area, limiting the amount of ammonium hydroxide volume stored, performed an engineering evaluation and subsequently reduced the concentration of ammonium hydroxide used at Salem to 15 wt%, and initiating precautionary administrative controls for tanker truck deliveries.

Document Control Desk NLR-N92100 A preliminary analysis was conducted for the two additional chemicals, hydrazine and sodium hydroxide, -identified as a *result of the site survey.* The preliminary assessment resulted in chemical concentrations within the control room that did not

  • exceed the toxic limits provided in authoritative sources.

- Therefore, it was concluded there.would be no impact on control room habitability as* a result of a postulated accident regarding either hydrazine or sodium hydroxide.

During the approval cycle for the control room habitability calculation, PSE&G questioned the "VAPOR" model assumptions and design input and determined they were very conservative.

As a result, the "CHARM" model was validated*and verified and used to complete the final evaluations. The additional evaluations used

.NRC regulatory criteria in the validated and verified "CHARM 1i computer code for the postulated accidents for both 27.5 and 15 wt.% ammonium hydroxide storage tank concentrations.

  • The evaluations, utilizing the "CHARM" code model, concluded that the Regulatory Guide.1.78 toxic limit for anhydrous ammonia, based on the concentration that can be tolerated for two minutes, will not be exceeded in the control room during a postulated release at the*tank containing either 27.5 wt% or 15.wt.%

ammonium hydroxide.

since the concentration of ammonium hydroxide was reduced, the

.amount of deliveries on an annual basis, was anticipated to exceed the frequency threshold value for truck traffic of ten per year per Regulatory Guide 1.78.

When the frequency criteria are applicable, Regulatory Guide 1.78 requires evaluation of the shipments for impact on control room habitability.

Therefore, included in the additional evaluations were postulated accidents to tanker delivery trucks containing 15 wt.% ammonium hydroxide at the site main access point and.Salem unloading dock.

A final evaluation of the two additional chemicals was conducted using the validated and verified "CHARM" computer code for hydrazine and a quaiitative analysis for sodium hydroxide.

The final evaluation confirmed the preliminary assessment that control room habitability would not be impacted.

A qualitative -

evaluation was conducted for sodium hydroxide because-of its high boiling point and very low volatility.

Under postulated accident conditions no credible. toxic airborne source can be determined.

The short term corrective actions immediately implemented, that are currently in place, are the administrative controls for tanker truck deliveries and use of 15 wt.% concentration ammonium hydroxide.

However, the "CHARM" code model evaluations support future use of 27.5 wt.% ammonium hydroxide, and the.elimination of both tank volume restrictions and continued temperature monitoring of the storage tank area.

Document Control Desk NLR-N92100 Administrative controls were instituted, per issuance of Chemistry procedure SC.CH-AD.z*z-0474, for the operators at Salem to isolate the control room when riotif ied that a tanker truck transporting ammonium hydroxide is*requesting site access for delivery.* The administrative controls also included notification of Hope Creek operators that an ammonium hydroxide delivery is being made for Salem.

Evaluations, utilizing the "CHARM" code model, conclude that Regulatory Guide 1.78 toxic limits will *not be exceeded in the aope Creek control room therefore, *operator action is not required to isolate the control room~

Operator training was conducted to identify.the odor of ammonia and ammonia was added to the annual olfactory recognition testing performed by the Medical Department on licensed operators~ *An Abnormal Operating Procedure, SC.OP-AB.CR-0003(Q),. "Toxic Gas Release", was issued for Salem Generating Station to isolate the control room upon notification or detection by odor of ammonia in the control room.

Hope Creek is also required to be notified.

A similar procedure for Hope Creek already existed.

Changes to the Salem and Hope Creek UFSAR's have been completed that revise appropriate Sectio*ns to identify additional chemicals transported to and stored onsite, discuss the evaluations for control room habitability for these. additional cnemicals, and describe Salem's position on Regulatory Guide 1.78.

The UFSAR changes will be incorporated in the next scheduled revision update.

CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE Procedure*NC.NA-AP.ZZ-0019(Q), "Procurement of Materials and Services" is being revised to limit the procurement of quantities of new chemicais to be brought onsite to less than 100 pound containers unless analyzed for their impact on control room habitability.

In the interim, direction on chemical procurement concerning toxic hazards*was provided by PSE&G memorandum, GM Nuclear Services to GM Procurement Material Control,. dated April 8, 1992.

Nuclear Administrative Procedure NC.NA-AP.ZZ-0038(Q), "The Chemical Control Program", was revised to require review of chemicals for control room habitability before use.

Procedure NC.DE-AP.ZZ-OOOl(Q), "Design Bases/Input", was revised to address the possible impact from hazardous chemicals, used in conjunction with or added by Design Changes, on control r.oom habitability.

Document Control Desk NLR-N92100 In addition to the above specific changes, improvements to the engineering process have been implemented since the review and evaluation for* the original response to the TMI Action Item III.D.3.4.

Safety Evaluations (10CFR50.59) are more defined and comprehensive today to include nonsafety system interaction on safety systems such as the Chemical.Feed System using ammonium hydroxide.

Design Changes require a formalized design

  • bases/input process that include use of design considerations and specialty review checklists, interface record sheets, multiple.

reviews including peer review in addition to independent design verification, and cross discipline and programmatic review.

PSE&G.is in full compliance

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