ML18094A597

Responds to NRC 890703 Ltr Re Violations Noted in Insp Rept 50-272/89-17.Corrective Actions:Inservice Testing Program Will Be Evaluated to Determine Appropriate Method for Testing Accumulator Check Valves & Training Plan Developed

ML18094A597
Person / Time
Site:	Salem
Issue date:	08/02/1989
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89149, NUDOCS 8908080330
Download: ML18094A597 (7)

See also: IR 05000272/1989017

Text

' ' * Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609-339-4800

Vice President

-Nuclear Operations

• AUG 0 2 1989 NLR-N89149

United States Nuclear Regulatory

Commission

Document Control Desk Washington

DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION

NO. 50-272/89-17

SALEM GENERATING

STATION UNIT NO. 1 DOCKET NOS. 50-272 Public Service Electric and Gas Company (PSE&G) has received the subject inspection

report dated July 3, 1989, which included a Notice of Violation

concerning

failure to notify the NRC within four hours and failure to have SORC review a procedure

that contained

an SSI. Pursuant to the requirements

of 10 CFR 2.201, 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

Sincerely, s. LaBruna Vice President

-Nuclear Operations

.. * * * Document Control Desk NLR-N89149

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 0 2 1989

J .. * * * ATTACHMENT

1

1 VIOLATION

A Technical

Specification

6.8.2 requires that surveillance

and test activity procedures

shall be independently

reviewed to make a determination

as to whether the procedure

contains a significant

safety issue (SSI). Additionally, Technical

Specification

6.5.1.6 requires that the Station Operations

Review Committee (SORC) shall review procedures

that involve an SSI. Contrary to the above, on May 20, 1989, Surveillance

Procedure

No. SP(0)4.0.5-V-SJ-6, "Inservice

Testing -Valves -Safety Injection," which involved an SSI, injection

of nitrogen into the reactor coolant system, was not reviewed by SORC. RESPONSE The test methodolbgy

for the Accumulator

discharge

check valves was developed

in 1982 to provide full stroke testing. This test method was developed

to comply with an IST program submittal

for NRC approval.

Inspection

Report 50-272/82-23, issued on October 5, 1982, documents

the inspectors

review of the status of the Salem IST program in regards to the submittal.

A major portion of the review was to finalize an NRC Staff evaluation

of the submittal.

The inspector

reviewed the procedures

and indicated

that the minimum design flow rates were not identified

in the test procedures

and were needed to demonstrate

the minimum safety analysis design flowrate criteria through the valves. Surveillance

procedure

SP(O) 4.0.5-V-REFUEL

was developed

for Units 1 and 2 to meet this requirement.

The Safety Evaluation

Report for the IST Program submittal

was issued on April 12, 1983. In the evaluation

section of the SER the NRC indicated

that Salem should investigate

a means to satisfy the NRC full-stroke

exercise criteria (demonstrate

safety analysis design flowrate through the check valves). SP(O) 4.0.5-V-REFUEL

procedure

provided the means to full flow test the check valves.for

the IST Program. This procedure

was reviewed by SORC in 1982 and again in 1984. When the SP(O) 4.0.5-V-REFUEL

procedure

was broken down into separate procedures

as a procedural

enhancement, during the two year review process, SP(O) 4.0.5-V-SJ-6

was developed.

This procedure

specifies

the same testing methodology

as the previous procedure

and was reviewed by a Station Qualified

Reviewer.

The SQR determined

that the procedure

did not contain a SSI. The SQR was performing

a two year review; therefore, he was reviewing

the changes and comments with respect to the technical

review. However, since he was aware that* the procedure

was performed

satisfactorily

using the steps specified

by the procedure

and that the procedure

had been

• * SORC approved, he did not perform a full technical

basis review of the old procedural

steps. It did, however, receive the required two year review specified

by procedure.

When it was decided that the procedure

should be separated

to reduce the confusion

involved with multiple tests covered by one procedure, it was felt that the steps were the same and thus the review performed

was adequate.

The procedures

do not provide specific guidance on the exact review steps to perform if the two year review results in new procedures

being developed

to seperate an old procedure.

In reviewing

the guidance of AP-32, Implementing

Procedures

Program, the guidance provided would indicate that an SSI was not involved as the examples provided discuss revising the procedure

for specific purposes.

In this case of the SP(O) 4.0.5-V-SJ6

procedure

the revision was made to make the procedure

more usable not to change order of steps or step method. Therefore, by the SS! criteria an SS! was not involved.

However, review of the incident did reveal that the original procedure (SP(0)4.0.5-REFUEL)

should have required a 50.59 safety evaluation

in that it did involve a change to the a test described

in the FSAR. Corrective

Actions Taken Use of the accumulator

discharge

procedure

SP(0)4.0.5-V-SJ-6

was immediately

discontinued.

The weaknesses

with the SP(0)4.0.5-V-SJ-6

and AOP-RHR-1

procedures

were reviewed with the Operations

Procedure

Writers. Corrective

Actions to Prevent Recurrence

PSE&G will evaluate the !ST Program to determine

the appropriate

method for testing the accumulator

check valves. This will be determined

by October 24, 1989. PSE&G will revise appropriate

procedures

for accumulator

check valve test after method is determined, and ensure SORC review. To be completed

by December 31, 1989. A training plan will be developed

and procedures

revised to incorporate

the information

and improvements

provided by the Engineering

and OSR evaluations

of the event. This will be completed

by September

29, 1989. PSE&G is currently

developing

an extensive

procedure

upgrade program that will ensure that high risk procedures

are identified

and that adequate precaution

and human factor considerations

are included .

,\ To assist the procedure

upgrade effort, PSE&G will establish

an independent

review group to perform SQR review to ensure that all commitments

and 10CFR50.59

requirements

are being met and maintained.

The procedure

upgrade effort is scheduled

for completion

by December, 1991. PSE&G will also provide additional

training to the present SQR reviewers, by October, 1989, to ensure that they remain fully astute of the SSI requirement

and the appropriate

procedural

requirements

resulting

from current revisions

to the Administrative

Procedures.

PSE&G will revise the existing guidance on two year reviews to ensure that specific guidance is provided for instances

where the revision process leads to the development

of new procedures.

This will be completed

by December, 1989. PSE&G IS IN FULL COMPLIANCE.

VIOLATION

B 10CFRS0.72(b)

(2) "Four-hour

reports," requires that the licensee shall notify the NRC within four hours of the occurrence

of any event or condition

that alone could have prevented

the fulfillment

of the safety function of structures

or systems that are needed to remove residual heat. Contrary to the above, on May 20, 1989, when the residual heat removal capability

was lost for about fifty minutes, the licensee did not notify the NRC within four hours. RESPONSE PSE&G DOES NOT CONTEST THE VIOLATION

Corrective

Actions Although the four hour report was not made in accordance

with the Event Classification

Guide (ECG) PSE&G recognized

that the seriousness

of the incident warranted

NRC attention, and contacted

the NRC on Saturday, May 20, 1989, to provide the NRC with the significant

information

associated

with the event. When PSE&G management

recognized

that a four hour report should have been made. PSE&G promptly made the report on Monday, May 22, 1989. --

I Prior to the loss of RHR event, an effort to review and upgrade the ECG was undertaken

by the Emergency

Preparedness

Group. The ECG was reviewed against 10CFR50.72

and 50.73, NUREG-1022

and NUREG-0654

to insure consistency

with the regulations.

Cross references

to the applicable

reporting

requirements

were added to the ECG subsections.

Additionally, the sections were revised to facilitate

usage. The revised ECG has several advantages

over the version in use at the time of the event. The revised sections are tied directly to plant conditions (i.e. , "Loss of Decay Heat Removal" is more explicit than coupling the "Safeguards" and "Technical

Specifications" sections for a single event). All of the applicable

emergency

and non-emergency

events are addressed

in the "Loss of Decay Heat Removal" section. Cross references

to the applicable

regulatory

requirements

help assure that the ECG addresses

the reporting

criteria, and also facilitates

update of the ECG in light of changes in regulations.

This revision will correct the ECG deficiency

relative to the loss of RHR and assure that events are properly reported in accordance

with regulations.

The revised ECG was issued on May 26, 1989. CORRECTIVE

ACTIONS TO PREVENT RECURRENCE

The new ECG was reviewed against the regulations

by the Licensing

Department

to insure compliance

with the regulations.

During the next requal cycle (scheduled

to begin in September, 1989) the licensed operators

will be provided with additional

ECG and 10CFR50 training to strengthen

their understanding

and usage of the ECG with regard to the appropriate

regulatory

requirements.

PSE&G IS IN FULL COMPLIANCE