ML18094A611

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
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)

See also: IR 05000272/1989011

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).