ML18096A879
| 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
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 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
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
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