ML18096A879

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
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)

See also: IR 05000272/1992007

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

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 * 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