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)

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).