ML18106A372

Provides 1997 Summary of Changes to NRC Commitments That Have Been Made But Not Reported by Other Means.Changed Commitments Listed W/Source Document

ML18106A372
Person / Time
Site:	Salem
Issue date:	03/10/1998
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N980006, NUDOCS 9803190202
Download: ML18106A372 (10)

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Public Service Electric and Gas Company E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1700 Senior Vice President - Nuclear Engineering MMl o 1998 LR-N980006 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 1997

SUMMARY

OF REVISED REGULATORY COMMITMENTS SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

This correspondence is being transmitted in accordance with the Nuclear Energy Institute (NEI) process for managing NRC commitments and associated NRC notification. It provides a summary o(change.s to NRC commitments that have been made but not reported by other means. The following information is provided regarding each of the changed commitments and their source documents.

LER 272/91-034-00, "Two ESF Signal Actuations, 1R11A Channel Spikes Due to Equipment Failures" This LER notified the NRC of two ESF actuations of the Containment Purge/Pressure-Vacuum Relief system due to degraded cable

. connections. A commitment was made to contact the cable manufacturer to discuss the feasibility of replacing the existing connectors with a more reliable connector.

Additionally, the LER corrective action committed to change the work standard associated with installing these connectors. The vendor was contacted and the existing cable connectors were determined to be the most reliable type available.

Additional connector installation information was provided by the vendor at that time.

This information was incorporated into the controlled vendor manual vice into a work standard. The vendor manual is the controlled document that is referenced whenever work is performed on these cable connectors. This is considered to be a commitment change since the applicable vendor manual was revised in lieu of changing a work standard.

LER 272/94-017-00 and -01, "Inadequate Margin for Pressurizer Overpressure Protection During Low Temperature Conditions" This LER notified the NRC of inadequate design margin for the Pressurizer Overpressure Protection System (POPS) during low temperature operation. One corrective action of the LER to ?ddress this issue was to remove power from the Safety Injection (SI) pumps upon entry into Mode 4 (350° F >Tave> 200 ° F). Because of changes to the POPS TS Bases subsequent to * *.

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• MAR 1 o 1998 LR-N980006 this LER, this administrative control commitment is overly conservative and unnecessary. Adherence to the requirements of Technical Specification (TS) 3.5.3 (ECCS Subsystems - Tave < 350 ° F) now provides adequate design margin relative to the POPS analysis and fulfills the purpose of the original LER corrective action commitment.

LER 272/95-026-01, "Main Steam Safety Valves Failed Lift Set Test" This LER notified the NRC of Main Steam Safety Valves (MSSV) that exceeded their allowable lift set pressure tolerance during surveillance testing. One corrective action from this LER was to revise the procedure for Main Steam Safety In-place Testing. This revision was to be accomplished by December 31, 1996. Due to changes in the recovery dates for the Salem Units and reprioritization of work (including procedure revisions), this commitment was not met until March 31, 1997.

LER 272/96-005-04, "Technical Specification Surveillance Requirement Implementation Deficiencies" This LER documented a failure to properly implement a TS surveillance related to testing of charcoal canisters in the Auxiliary Building, Control Area, and Fuel Handling Ventilation systems. Corrective Action #12 of this LER committed to revise the ventilation procedures for the Control Area and the Fuel Handling Ventilation systems before entry into Mode 6; and to revise the ventilation procedures for the Auxiliary Building Ventilation system before entry into Mode 4. This corrective action commitment was changed to require that the ventilation procedures be revised before entry into Mode 6 for the Fuel Handling Ventilation system and before entry into Mode 4 for Control Area and Auxiliary Building Ventilation Systems. The commitment change was made to reflect a one time TS change that was approved to allow Control Room Emergency Air Conditioning system (CREACS) to be inoperable in Modes 5 and 6 during the implementation of a Control Room and CREACS upgrade. It will make the times that the procedure revisions are due consistent with the times that the various ventilation systems will be operable.

LER 272/95-016-01, "Difference Between Containment Design Parameters And Accident Analysis" This LER reported a discrepancy between the containment structure design basis as described in the TS, the UFSAR Chapter 15 accident analysis, and the design calculations for the containment. One of the root causes of this discrepancy was the failure to identify all affected sections of the TS and the UFSAR in the 10CFR50.59 Safety Evaluations for proposed changes to the containment temperature profile. Corrective action #2 of this LER committed to revise Nuclear Administrative Procedure (NAP)-59, "1 OCFR50.59 Reviews and Safety Evaluations" to address text search recommendations by July 31, 1996. This commitment was changed to also include incorporation of guidance on the use of text search in the 10CFR50.59 program administrative standard. The commitment date was

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• MAR 1o1998 LR~N980006 changed to September 1, 1996 so that the changes could be issued in conjunction with the next NAP-59 revision.

LER 272/91-002-00, 311/91-003-00, "ASME Code Class 3 Piping Leakage Caused By Equipment Failure" The corrective action for both LER's included implementation of a detailed weekly walkdown by System Engineering of Room Cooler Service Water piping to provide early identification of Service Water leakage. This leakage was caused by the failure of the installed Service Water piping due to galvanic corrosion.

To provide a long term corrective action to deal with the piping failures, the cement lined piping that was installed was replaced with 6% moly piping. These walkdowns have been discontinued because this modification eliminated the source of the piping failures.

LER 311/96-015-00, "Breach Of Containment Closure During Core Reload" This LER documented a breach of containment closure that occurred during a refueling outage at Salem Unit 2. The event was caused by inadequate implementation of scheduling and outage risk management requirements and because of an inadequate review of work in progress as required by the containment closure procedure. A corrective action from this LER added the Shutdown Safety Plan System Scorecard to key plant schedules to heighten the plant staff's awareness of the equipment that is required for plant safety (protected equipment). The Shutdown Safety Plan System Scorecard has been replaced for this purpose by the Shutdown Status Sheet. This action was taken because the Shutdown Status Sheet provides information on protected plant equipment that is more accurate and up to date than the information provided by the Shutdown Safety Plan Scorecard.

LER 272/95-008-00, "Controlled Shutdown Following Technical Specification 3.0.3 Entry Due To lnoperability Of Switchgear And Penetration Area Ventilation" This LER documented a controlled shutdown of Salem Unit 1 as required by TS when two of the three Switchgear And Penetration Area Ventilation System (SPAVS) supply fans were found to be inoperable due to equipment failure. During the investigation of this occurrence, it was determined that a contributing factor to the failures was a lack of a preventive maintenance program for the fan motors. The fan motors installed at that time utilized double shielded bearings. In order to preclude future failures of the SPAV fan motors, this LER committed to implement recurring preventive maintenance tasks to replace the SPAV fan motor bearings on a regular schedule. This preventive maintenance task is appropriate for fan motors fitted with the double shielded bearings.

Subsequent to this commitment the SPAV fan motors were replaced with new motors fitted with open/single shielded bearings. The preventive maintenance requirements were evaluated for this bearing design and were determined to be periodic lubrication and vibration monitoring. These requirements have been implemented for the SPAV

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• 4 PAAR 1o1998 LR-N980006 fans and will replace the bearing replacement preventive maintenance task committed to in the LER.

~ LER 311/94-005-00, "Late Surveillance Testing Of Reactor Trip System Power Range Instrument Channel 2N41 Due To Inadequate Communication" This LER documented the late performance of a surveillance test of a Reactor Trip System Power Range Instrument channel because of inadequate communication between the Senior Maintenance Controls Supervisor (SMCS) and the Station Controls Scheduler (SCS).

As a corrective action to prevent recurrence of this event, the SMCS was directed to establish and maintain a sign-off log to ensure that a daily review of reports listing upcoming overdue Technical Specification surveillances is conducted. Since the establishment of this commitment, the position of SMCS has been eliminated. The responsibility to review the Technical Specification Overdue Report is now fulfilled by the Technical Specification Surveillance Coordinators in accordance with Nuclear Administrative Procedure (NAP)-12.

LER 272/95-013-00, "Surveillance Testing Of Seismic Monitoring Instrumentation Performed Approximately Six And One Half Hours Late" This LER documented a missed TS surveillance on Salem Unit 1 Seismic Monitoring equipment. As a part of the LER corrective action, the position of Unit Surveillance Coordinator was established in the Station Planning and Scheduling Group with one coordinator for each unit. This position was intended to serve as an additional barrier to ensure continuity of surveillance scheduling and completion. This position is not recognized by procedure NAP-12, Technical Specifications Surveillance Program. NAP-12 establishes the responsibilities of the Planning and Scheduling Department. Under NAP-12 the responsibility to plan and schedule surveillances rests with the Planning and Scheduling Surveillance Coordinator. The responsibility to ensure that surveillance tasks are completed rests with the Technical Specification Administrator and the Department Technical Specification Surveillance Coordinators. These positions provide the barriers needed to ensure that surveillances are completed. Based upon this, the position of Unit 1(2) Surveillance Coordinator has been eliminated.

LER 311/95-006-00, "Missed Surveillance - Charcoal Adsorber Testing Exceeded Technical Specification Surveillance Requirement Time Limit" This LER documented a missed surveillance caused in part by the utilization of an informal process for monitoring charcoal adsorber run time hours. To prevent a recurrence of this event the Operations Department committed to review Technical Specification surveillance requirements to ensure that there are no other surveillances that depend on an informal or non-proceduralized scheduling process. This review was to be completed by October 30, 1995. Procedure revisions, if required, were to be completed by December 31, 1995. This event occurred during an extended shutdown of both Salem Units. In order to better prioritize the station's efforts to restart the units

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• 5 MAR 1O1998 LR_:N980006 following this extended shutdown, the reviews and procedure revisions, if required will be completed prior to the applicable mode change in lieu of the previously committed completion dates.

LER 272/84-012-00, "Charging/Safety Injection Valves - Disks Becoming Separated/Detached From Stems" This LER documented an issue related to failures of high head safety injection throttle valves in which the valve disk was found to have become unthreaded from the valve disk nut. In one LER corrective action, the station committed to radiograph the Safety Injection throttle valves each time they were manipulated or had flow pass through them. The radiography was to be performed to ascertain if the disks were starting to loosen. Subsequent to this commitment, several system changes were made which make a repeat failure of a Safety Injection throttle valve unlikely. Because of these changes, the costs and exposure risks associated with radiography are no longer warranted to assure valve integrity. Therefore, the commitment to radiograph the valves is not necessary and will no longer be performed.

LER 272/96-005-08, "Inadequate Technical Specification Testing Of The Pressure Isolation Valves" This LER documented a discrepancy that was discovered related to the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) testing methodology which could result in the Technical Specification limit for PIV leakage and the total identified leakage being exceeded. In the corrective action to this LER the station committed to revise the test procedures for performing the RCS PIV leak testing for each Salem Unit before that unit entered Mode 4. The test procedures for performing the RCS PIV leak testing have been determined to be required to be performed prior to entry into Mode 3, not prior to entry into Mode 4. This commitment has been changed to reflect that requirement.

LER 311/95-025-00, "Single Failure Conditions That Could Have Potentially Compromised The Ability Of The Service Water System To Carry Out Its Intended Safety Function During The Recirculation Phase Of An Accident" This LER reported a condition identified during restart readiness reviews involving the plant Service Water pumps. During a reportability review of Problem Reports (PR) associated with Service Water alignment problems, a condition was identified which could have potentially affected the ability of the system to perform its design function.

As a part of the corrective action for this LER, the station committed to develop a procedure to address the specific concerns of the Problem Reports. These revisions were to have been implemented by April 1996. To allow for time for the completion of the revision review process, the procedure revision implementation was completed on June 30, 1996.

Notice of Violation, NRC Inspection 50-272/85-01 and 50/311/85-04, Violation of Technical Specification 6.8 This violation addressed the failure to establish and

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maintain written procedures. Specifically, Surveillance Procedure (SP) 4.4.6.2d, RCS Water Inventory Balance was inadequately established. Four issues were identified in the violation. One of these issues addressed a procedural deficiency that no correction was being made to account for temperature changes during the surveillance. In response to this violation, a commitment was made to ensure that RCS temperature (Tave) would be the same at the beginning and end of the test. In lieu of that solution, the station has decided to incorporate a change to the procedure to compensate for temperature changes. This was done to relieve the burden on operators of ensuring that RCS temperature is the same at the beginning and end of the test.

PSE&G Letter NLR-N91051, Status of Radiation Monitoring System Upgrade Project, Dated April 8, 1991 PSE&G letter NLR-N91051 provided the status of an upgrade to the Salem Radiation Monitoring System (RMS) to provide a more reliable system. This was necessary to reduce the number of inadvertent safety system actuations. The letter stated that "The RMS Upgrade Project will provide both Salem Units with a new computerized radiation monitoring system." This statement implies a total system replacement. Subsequent to that commitment, the station took a more cost effective approach to the project. In lieu of a total system replacement, the project will now be accomplished through corrective maintenance, equipment upgrades, or channel replacement as it applies to individual RMS instruments.

PSE&G Letter, Post Accident Sampling System TMI Action Item 11.8.3 Implementation Report No. 1 and 2 Units Salem Generating Station, Dated August 31, 1983 This commitment involves PSE&G's response to NUREG 0737, Item 11.B.3, NRC Evaluation Criteria Guidelines For Post Accident Sampling Systems (PASS). This response addressed each of the criterion of Item 11.B.3. Item 11.B.3, Criterion 11 B stated that the ventilation exhaust from the PASS sampling station should be filtered with charcoal absorbers and high-efficiency particulate air (HEPA) filters. Item 11.B.3, Criterion 11, Clarification, stated that a dedicated sample station filtration system is not required, provided a positive exhaust exists which is subsequently routed through charcoal absorbers and HEPA filters. In its response, PSG&G stated that the Salem PASS exhaust configuration would be connected to the Auxiliary Building Ventilation (ABV) system and would utilize the ABV HEPA and charcoal filtration capabilities. This configuration has been determined to be inappropriate because it does not meet the intent of Criterion 11. The PASS vent is tied into the Normal ABV flowpath. However, this flowpath is not lined up to the charcoal filter either in normal ABV operation or ABV operation during a LOCA. In post LOCA conditions, the Auxiliary Building charcoal filters and HEPA filters are aligned to the ECCS Emergency Areas and are not available for PASS cabinet filtration. To resolve this issue, PSE&G will amend Section 12.3.3 of the Implementation Report to reflect the results of an Engineering Evaluation that assessed the radiological consequences of an unfiltered release of post-accident airborne activity resulting from postulated PASS leakage. This evaluation indicated

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LR..:N980006 that alignment of the PASS ventilation with the charcoal adsorbers is not needed to maintain post-accident offsite and control room dose consequences within exposure guideline values of 10CFR Part 100, paragraph 11, and 10CFR Part 50, Appendix A, Criterion 19 respectively.

NRC Technical Restart Issue #29 - Notice of Violation LR-N95196, 11/15/95, Failure of the 2RC40 Reactor Head Vent Valve to Stroke This commitment originated as a result of an event that occurred on July 6, 1994 in which the safety-related Reactor Head Vent valve 2RC40 failed to operate (stroke open) during testing. As a corrective action to prevent recurrence, the operating procedures for Salem Unit 1 and 2 were changed to require that the Reactor Head Vent valves be flushed with demineralized water each time the valves were used. This was done to remove boron accumulation internal to the valve. To accomplish this procedure operations personnel are required to set up temporary check valves and hoses to a demineralized water source. This corrective action was implemented before a detailed root cause determination was performed to identify why the valve failed to open. The root cause of this event was ultimately determined to be degradation of the valve internals, and not boron accumulation. Although flushing can be an appropriate corrective action for the failure of the valve to operate if the internals are degraded, flushing should not be required if the valves are in good material condition. In lieu of the commitment to flush the valves with demineralized water each time they are operated, corrective actions have been implemented to prevent recurrence. The Reactor Head Vent valves have been replaced with new valves. Preventive maintenance activities have been developed to perform internal inspections of these valves on a 54 month frequency. Should a flush of the valves be required, procedural changes have been made to conduct the flush with Reactor Coolant system water vice demineralized water.

PSE&G Letter To The NRC Dated 26 July 1978, Fire Protection Program, Salem Generating Station During the station's licensing phase, PSE&G committed to the installation of concrete curbs at the entrance to each Emergency Diesel Generator (EOG) bay. This commitment was made in the above referenced correspondence in response to an NRC position to questions related to the Fire Protection program. The curbs are intended to contain a potential diesel oil or fuel leak to prevent its spread from one EOG bay to another. It was subsequently determined that the curbs were not installed during construction. To fulfill this commitment, curbs were installed. However, instead of concrete curbs (as originally committed) steel angle curbs sealed with caulk were installed as an acceptable substitute. This alternative was considered to be acceptable because steel is more impermeable than concrete and steel is not as susceptible to cracking or shrinkage as concrete. Additionally, the caulking that was used is normally used in penetration seal applications. Periodic inspections will be

' . MAR 1 o 1998 Document Control Desk 8 LR.:N980006 performed on the curbs as a part of the fire door inspections to verify their integrity and their ability to perform their intended function.

Regulatory Guide 1.97, Instrumentation Of Light-Water Cooled Nuclear Power Plants To Assess Plant Conditions During And Following An Accident, Commitment For Channels R4, RS, R9, and R34 On Salem Units 1 and 2 To Be Part Of Variable 19 This commitment change removes variable 19A from Regulatory Guide 1.97. According to Revision 2 of Regulatory Guide 1.97, Variable 19A is intended to: (1) detect a Type C containment breach, (2) determine the magnitude of effluent material release rates, and (3) provide continuous assessment of effluent releases of radioactive materials in the Fuel Handling Area and the Penetration Area.

This variable (Category 2) required an instrument detection range of 1.0E-1 to 1.0E+4 R/hr. Revision 3 of Regulatory Guide 1.97 eliminated the need for radiation monitor channels R4, R5, R9, and R34 to be included in the Regulatory Guide 1.97 Variable 19A as a Type C variable because there is no longer a requirement to monitor a breach of containment. The Type E requirements for these monitors no longer apply because:

(1) effluent from the Mechanical Penetration Area, the Fuel Handling Building, and the Charging Pump Cubicle (via Auxiliary Building Ventilation system) is routed through the plant vent which meets Regulatory Guide 1.97 requirements, (2) access to the Fuel Handling Building, Mechanical Penetration Area, and Charging Pump Cubicle is not permitted following an accident, and (3) Emergency Operating Procedures no longer require access to these areas.

PSE&G Commitment Regarding Vendor Document Recontact Program, PSE&G Response To NRC Order Following Salem Reactor Trip Breaker Event (May 6, 1983), PSE&G Response To Generic Letter 83-28, And PSE&G Response To Generic Letter 90-03. The PSE&G Vendor Document Recontact Program originated in the response to the NRC Order following the Salem Reactor Trip Breaker Event. It was affirmed in the PSE&G response to Generic Letter 83-28 and was modified in the PSE&G response to Generic Letter 90-03. The commitment requires that selected vendors be recontacted on an annual basis to verify that the currently approved vendor d.ocuments are the most current. PSE&G has determined that the current recontact effort is not meeting expectations. While it meets the requirements of the NRC commitments, it is not providing adequate assurance that all applicable information is being maintained current. To improve the quality and usefulness of the recontact process, PSE&G is changing the recontact process from an annual recontact to a more rigorous recontact on a three year cycle. Rather than a single recontact attempt, the program will be continuously performed during the three year period, one third completed each year. This method has been successfully used at many other utilities.

LER 311/97-008-00, "Failure To Enter Action Statement For Having Both Radiation Monitors In The Same Control Room Air Intake Duct Inoperable" This

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• IAR1O1998 LR.:N980006 LER reported the failure of Operations personnel to recognize the necessity for entry into a Technical Specifications action statement because of inoperable radiation monitors. In order to avoid similar human errors in the future, a corrective action commitment to this LER was made to revise the nomenclature of the Control Room Air Intake Duct Radiation Monitor Channels to improve the human factors of the system.

This commitment was to be met by 12/01/97. Due to work prioritization by the Design Engineering group, this commitment has been rescheduled for completion by 3/31/98.

Notice of Violation, NRC Inspection Report 50-272/97-07 and 50-311/97-07, Violation of Technical Specification. In Attachment 3 to this violation response and as requested in your inspection report, PSE&G provided its perspective of the failure of Phase 1 of the Technical Specification Surveillance Improvement Project (TSSIP) to identify the inadequate surveillance. In PSE&G's response, we stated that a Technical Specification license change request (LCR) to make the Unit 1 and Unit 2 Technical Specifications identical was scheduled to be issued by December 31, 1997. The proposed LCR was not part of the long term corrective actions associated with the actual Notice of Violation, and is thought to be an enhancement to the Technical Specifications. Therefore, as a result of other priority work needed to support the Salem Unit 1 restart this LCR will be processed consistent with the priorities of other LCRs needed to support plant operations.

Notice of Violation, NRC Inspection Report 50-354/97-01, Violation of 10CFR50, Appendix 8, Criterion V, Instructions Procedures, and Drawings. This violation originated as a result of scaffolds that were installed in safety-related areas that lacked appropriate construction documentation, had insufficient periodic inspections, and were not removed within a timely manner following completion of the work activities for which the scaffolds were erected. As a part of its response to this notice of violation, PSE&G stated that "Initial training will be expanded and will be conducted for selected individuals in the Nuclear Business Unit's Group by August 15, 1997 to qualify scaffold builders to install and dismantle scaffolding, and to qualify supervisor/designees to review scaffolding. Ongoing continuous training will occur as necessary." In order to provide more flexibility in the utilization of its work force, PSE&G has eliminated the requirement for individuals to complete the one week scaffold training course as a prerequisite to assist in the removal of scaffolds. This training course focuses on the program requirements and on the proper erection of scaffolds. Training course content related to the physical removal of scaffolds is restricted to industrial safety requirements, such as fall protection. Training in fall protection and other industrial safety requirements are addressed as a part of General Employee Training. This change will not revise inspection criteria, qualification for scaffold builders, or the tracking of erected scaffolds.

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• IAR 1o1998 LR:N980006 Should there be any questions, please contact us.

C Mr. Hubert J. Miller, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Ms. M. Evans - Salem (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625