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| issue date = 07/16/1997 | | issue date = 07/16/1997 | ||
| title = 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 | | title = 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 | ||
| author name = | | author name = Storz L | ||
| author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY | | author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY | ||
| addressee name = | | addressee name = |
Revision as of 11:49, 17 June 2019
ML18102B455 | |
Person / Time | |
---|---|
Site: | Salem ![]() |
Issue date: | 07/16/1997 |
From: | Storz L Public Service Enterprise Group |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
References | |
50-311-97-06, 50-311-97-6, LR-N970449, NUDOCS 9707220344 | |
Download: ML18102B455 (15) | |
See also: IR 05000311/1997006
Text
' ,, __ . ** Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700
Senior Vice President
-Nuclear Operations
- JUL 16 1997 LR-N970449
United States Nuclear Regulatory
Commission
Document Control Desk Washington, DC 20555 SUPPLEMENTAL
RESPONSE TO A NOTICE OF VIOLATION
INSPECTION
REPORT 50-311/97-06
SALEM GENERATING
STATION UNIT NO. 2 DOCKET NO. 50-311 Gentlemen:
Inspection
Report No. 50-311/97-06
for Salem Nuclear Generating
Station Unit No. 2 was transmitted
to Public
Electric & Gas Company (PSE&G) on May 30, 1997. Within the scope of this report, one violation
of NRC requirements
was c.i ted. The violation
involved the failure to follow established
procedures
for the documentation
of test results. By letter dated June 30, 1997 (Our Ref: LR-N970371), PSE&G submitted
its response to the cited violation.
As stated in the original PSE&G response, the root cause of the violation (all f; cited examples)
was attributed
to poor human performance
of l)J personnel
performing
the activities
and poor human performance
by management
in the oversight
of these activities.
The corrective
actions stated in the June 30 response were designed to address ';* the root cause in its broadest form. To provide a complete understanding
of PSE&G's actions taken, PSE&G is supplementing
the June 30, 1997 original response to address the specific actions taken relative to each of the cited examples.
Mssrs. D. Powell and M. Rencheck of PSE&G discussed
the submittal
of this supplemental
response with Mr. W. Ruland (NRC Region I) via telephone
on July 9, 1997. 9707220344
970716 PDR ADOCK 05000311 G PDR *..* *,_, _ .. \J Printedon
\:I Recycled Paper 1111111111111111111111111111111111111111
- 0&4011.
- * Document Control Desk LR-N970449
2 JUL 16 1997 Additionally, by letter dated April 11, 1997 (Our Ref-: N97194), PSE&G responded
to a similar violation
transmitted
in Inspection
Report 50-311/96-21.
This violation
involved deficient
conditions
for the testing of the Control Room Area Air Conditioning
System. As a result of subsequent
PSE&G investigation, as well as NRC inspections, other deficient
conditions
were identified
relative to the same design modification
test procedures.
In light of the applicability
of these findings to Control Room Area Air Conditioning, and in response to Inspection
Report 50-311/97-06
request, PSE&G considers
the information
provided in the June 30, 1997 letter to be relevant to the April 11, 1997 response.
In the June 30, 1997 response, PSE&G stated that (Corrective
action E) ten non-HVAC system Special Test Procedures (STPs) in five systems were reviewed.
PSE&G would like to expand on this corrective
action by identifying
the procedures
reviewed.
The STPs reviewed are: Fire Protection
2EC-3298 Package 1 -STPs 1-3 lEC-3701 Package 1 -STP 1 Electrical
2EC-3332 Package 2 -STPs 1 & 2 Diesel lEC-3529 Package 2 -STP 1 Service Water 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 11 -STP 1 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 17 -STPs 1-7 2EC-3590 Package 18 -STPs 1-5 Safety Injection
2EC-3461 Package 1 -STPs 1 & 2 95-4933
- Document Control Desk LR-N970449
3 JUL 16 1997 Attachment
I to this letter contains the original violation
as cited in Inspection
Report 50-311/97-06.
Attachment
II contains PSE&G's supplemental
information
relative to these *events. Should there be any questions
regarding
this submittal, please contact us. Sincerely,
- * Document Control Desk LR-N970449
Attachment
4 C Mr. Hubert J. Miller, Administrator
-Region I U. s. Nuclear Regulatory
Commission
.475 Allendale
Road King of Prussia, PA 19406 JUL 16 1997 Mr. L. N. Olshan, Licensing
Project Manager -Salem U. S. Nuclear Regulatory
Commission
One White Flint North 11555 Rockville
Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall
-Salem (X24) USNRC Senior Resident Inspector
Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering
33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
ATTACHMENT
I LR-N970449
NOTICE OF VIOLATION
Public Service Electric & Gas Company Docket No:
Salem Nuclear Generating
Station License No: DPR-75 Unit 2 During an NRC inspection
conducted
on March 1 to April 12, 1997, violations
of NRC requirements
were identified.
In accordance
with the "General Statement
of Policy and Procedure
for NRC Enforcement
Actions." NUREG-1600, the violations
are listed below: Appendix B, Criterion
V of 10 CFR 50 requires that activities
affecting
quality be prescribed
by procedures
and shall be accomplished
in accordance
with those procedures.
Procedure
NC.DE-AP.ZZ-0012(Q), "Test Program", Revision 6, Section 5.2.c requires testing to be conducted
with approved step-by-step
Special Test Procedures, existing procedures, or standards.
Section 5.2.e requires recording
test data on data sheets . * Section 5.2.f requires evaluating
test results to ensure they are acceptable
prior to restoring
plant equipment.
- Contrary to the above, post-modification
test procedures
for Salem cdntrol room area air conditioning
system (CAACS) were not followed, required.data
was not recorded, and plant equipment
was restored with test results outside established
acceptance
criteria, as evidenced
by the following
examples:
1. Procedure
lEC-3505 package No. 1 STP-2, Revision 2, *control Area Air Conditioning
System (CAACS) and Emergency
Air Conditioning
System (EACS) Coil Test Procedure (to verify heat transfer capability
of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation
of an Action Request (AR) to clean the coils if the coil appearance
was not "bare metal or shiny appearance".
The condition
of the coil for 1HVE200, recorded on Attachment
7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated . 1
ATTACHMENT
I LR-N970449
2. Procedure
lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential
for leakage into the control room pressure boundary], attachment
7.3 establishes
EACS charcoal filter housing and duct maximum allowable
leakage test acceptance
criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established
acceptance
criteria, but the test results were approved and the EACS system was restored to service. 3. Procedure
lEC-3505 Package No. 1 STP-4, Revision 3, attachment
7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric
pressure recorded in inches of mercury (inHg) and initial boundary pressures
in pounds per square foot (psf) absolute (abs.), the test pressures
were less than the required 4 inwc. 4. Procedure
lEC-3505 Package No. 1
Revision 3, Appendix A, steps 2.e and 2.h require recording
the initial and final times of the test. The times were not recorded.
5. Procedure
lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring
review of test data by the test engineer was incorrectly
deleted by Modification
Concern and Resolution
297. This is* a Severity Level IV problem (Supplement
1). 2
ATTACHMENT
II SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
"1. Procedure
lEC-3505 package No. 1 STP-2,
2, Control Area Air Conditioning
System (CAACS) and Emergency
Air Conditioning
System (EACS) Coil Test Procedure (to verify heat transfer capability
of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation
of an Action Request (AR) to clean the coils if the coil appearance
was not "bare metal or shiny appearance".
The condition
of the coil for 1HVE200, recorded on Attachment
7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated." (1) The reason for the violation.
The root cause for the violation
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation
was poor human performance
by the *CAV project team and testing personnel
and management
oversight.
Personnel
involved failed to meet PSE&G's standard of procedural
compliance.
Personnel
did not properly revise CAV Special Test Procedures (STPs) in accordance
with PSE&G procedures
to reflect changes in testing methodology
and acceptance
criteria.
In addition inadvertent
removal of the test engineer acceptance
signoff by the project team is an example of inattention
to detail. PSE&G management
also did not provide an adequate level of management
oversight
of personnel
preparing.and
implementing
the CAV_Special
Test Procedures." * (2) The corrective
steps that have been taken. 1. AR 970320247
was issued to evaluate the white chalky film observed on the coil. The white chalky film (lead oxide) observed on the coil was the result of chemical cleaning of the EACS coil by the vendor. This white chalky substance
was evaluated
and determined
to have no effect on the heat transfer characteristic
of the coil . 1
- * ATTACHMENT
II SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
2. The design change test procedure
acceptance
criterion
was revised as per the above evaluation
and vendor recommendation.
3. LR-N970371, dated June 30, 1997, -contains
additional
information.
(3) The corrective
steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information.
(4) The date when full compliance
will be achieved.
PSE&G achieved compliance
when the AR 970320247
was issued. LR-N970371, dated June 30, 1997, contains additional
information . 2
- ATTACHMENT I I SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
"2. Procedure
lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential
for leakage into the control room pressure * boundary], attachment
7.3 establishes
EACS charcoal filter housing and duct maximum allowable
leakage test acceptance
criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established
acceptance
criteria, but the test results were approved and the EACS system was restored to service." (1) The reason for the violation.
The root cause for the violation
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation
was poor human performance
by the CAV project team and testing personnel
and management
oversight.
Personnel
involved failed to meet PSE&G's standard of procedural
compliance.
Personnel
did not properly revise CAV Special Test Procedures (STPs) in accordance
with PSE&G procedures
to reflect changes in testing methodology
and acceptance
criteria.
In addition inadvertent
removal of the test engineer acceptance
signoff by the project team is an example of inattention
to detail. PSE&G management
also did not provide an adequate level of management
oversight
of personnel
preparing
and implementing
the CAV Special Test Procedures." (2) The corrective
steps that have been taken. 1. Engineering
Evaluation
S-C-SC-MEE-1212, Control Area Ventilation:
Review of CREACS Filter Housing Test Requirements
and Acceptance
Criteria, issued on May 30, 1997, evaluated
the recorded leakage rate acceptable.
2. Modification
Concern and Resolution (MCR) 193 to the design change test procedure
revised the leakage rate 3
- ATTACHMENT
II SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
acceptance
criterion
based on Control Room Dose Calculation
and was evaluated
in Engineering
Evaluation
S-C-SC-MEE-1212.
3. LR-N970371, dated June 30, 1997, contains additional
information.
(3) The corrective
steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information.
(4) The date when full compliance
will be achieved.
PSE&G achieved compliance
when the Engineering
Evaluation
was issued demonstrating
that the recorded leakage rate was acceptable, and MCR 193 to lEC-3505 revised the leakage rate acceptance
criterion.
LR-N970371, dated June 30, 1997, contains additional
information . 4
- ATTACHMENT
II SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
"3. Procedure
lEC-3505 Package No. 1 STP-4, Revision 3, attachment
7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric
pressure recorded in inches of mercury (inHg) and initial boundary pressures
in pounds per square foot (psf) absolute (abs.), the test pressures
were less than the required 4 inwc." (1) The reason for the violation.
The root cause for the violation
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation
was poor human performance
by the CAV project team and testing personnel
and management
oversight.
Personnel
involved failed to meet PSE&G's standard of procedural
compliance.
Personnel
did not properly revise CAV Special Test Procedures (STPs) in accordance
with PSE&G procedures
to reflect changes in testing methodology
and acceptance
criteria.
In addition inadvertent
removal of the test engineer acceptance
signoff by the project team is an example of inattention
to detail. PSE&G management
also did not provide an adequate level of management
oversight
of personnel
preparing
and implementing
the CAV Special Test Procedures." (2) The corrective
steps that have been taken. 1. Engineering
Evaluation
S-C-SC-MEE-1212, Control Area *ventilation:
Review of CREACS Filter Housing Test Requirements
and Acceptance
Criteria, issued on May 30, 1997, evaluated
the higher initial test pressures
and accepted the test data. 2. The HEPA and Charcoal Filter Housing decay calculations
were revised with acceptable
results. 3. The test procedure
acceptance
criteria was revised. 4. LR-N970371, dated June 30, 1997, contains additional
information . 5
ATTACHMENT
II SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
(3) The corrective
steps that will be takeri to avoid further violations.
dated June 30, 1997, contains the required information.
(4) The date when full compliance
will be achieved.
PSE&G achieved compliance
when the Engineering
Evaluation
was issued determining
that the higher recorded test pressures
were acceptable, the test procedure
acceptance
criteria was revised, and the HEPA and Charcoal Filter Housing decay calculations
were revised. LR-N970371, dated June 30, 1997, contains additional
information . * 6
I ---.. ATTACHMENT I I SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
"4. Procedure
lEC-3505 Package No. 1 STP-4,
3, Appendix A, steps 2.e and 2.h require recording
the initial and final times of the test. The times were not recorded." (1) The reason for the violation.
The root cause for the violation
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation
was poor human performance
by the CAV project team and testing personnel
and management
oversight.
Personnel
involved failed to meet PSE&G's standard of procedural
compliance.
Personnel
did not properly revise CAV Special Test Procedures (STPs) in accordance
with PSE&G procedures
to reflect changes in testing methodology
and acceptance
criteria.
In addition inadvertent
removal of *the test engineer acceptance
signoff by the project team is an example of inattention
to *detail. PSE&G management
also did not provide an adequate level of management
oversight
of personnel
preparing
and implementing
the CAV Special Test Procedures." (2) The corrective
steps that have been taken. 1. The test engineers
responsible
have been counseled
and advised of the importance
of strict procedure
compliance.
Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was *recorded, which was the only value necessary
for the required calculation.
2. LR-N970371, dated June 30, 1997, contains additional
information.
(3) The corrective
steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information . * 7
... ATTACHMENT
II SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
(4) The date when full compliance
will be achieved.
PSE&G achieved compliance
when the test was completed
satisfactorily.
Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was recorded, which was the only value necessary
for the required calculation.
LR-N970371, dated June 30, 1997, contains the required information.
"5. Procedure
lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring
review of test data by the test engineer was incorrectly
deleted by Modification
Concern and Resolution
297." (1) The reason for the violation.
The root cause for the violation
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation
was poor human performance
by the CAV project team and testing personnel
and management
oversight.
Personnel
involved failed to meet PSE&G's standard of procedural
compliance.
Personnel
did not properly revise CAV Special Test Procedures (STPs) in accordance
with PSE&G procedures
to reflect changes in testing methodology
and acceptance
criteria.
In addition inadvertent
removal of the test engineer acceptance
signoff by the project team is an example of inattention
to detail. PSE&G management
also did not provide an adequate level of management
oversight
of personnel
preparing
and implementing
the CAV Special Test Procedures." (2) 1. 2. 3. * The corrective
steps that have been taken. The test engineer responsible
for removing the procedure
step was counseled.
A review signature
was added for a level III sign off of test results. The test results were reviewed by a level III test engineer . 8
_, *-I l ... * * ATTACHMENT I I SUPPLEMENTAL
RESPONSE TO NOTICE OF VIOLATION
SALEM GENERATING
STATION UNIT 2 LR-N970449
4. LR-N970371, dated June 30, 1997, contains additional
information.
(3) The corrective
steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information.
(4) The date when full compliance
will be achieved.
PSE&G achieved compliance
when a review signature
was added for a level III sign off of test results and the test results were reviewed by a level III test engineer.
LR-N970371, dated June 30, 1997, contains additional
information . 9