ML18092B519

Responds to NRC 870312 Ltr Re Violations Noted in Insp Repts 50-272/87-03 & 50-311/87-04.Corrective Actions:Detailed Review of Containment Integrity Surveillances Immediately Performed & Discrepancies Corrected

ML18092B519
Person / Time
Site:	Salem
Issue date:	04/14/1987
From:	Corbin McNeil Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N87063, NUDOCS 8704210273
Download: ML18092B519 (4)

Text

• Public Service Electric and Gas Company Corbin A. McNeill, Jr. Vice President

-Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Nuclear April 14, 1987 NLR-N87063 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 NRC INSPECTION REPORT 50-272/87-03 AND 50-311/87-04 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company {PSE&G) is in receipt of your letter dated March 12, 1987, which transmitted a Notice of Violation regarding failure to verify closure of five primary containment-boundary valves as required by Technical cation Surveillance Requirement 4.6.1.la.

Pursuant to the provisions of 10 CFR 2.201, the PSE&G response to the subject Notice of Violation is provided in Attachment

1. Attachments C Mr. D. C. Fischer Licensing Project Manager Mr. T. J. Kenny Senior Resident Inspector Sincerely, Director, Bureau of Radiation Protection Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 8704210273 870414 PDR ADOCK 05000272 G PDR *\'

-[' _____ _ ATTACHMENT 1 10 CFR 2. 201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION RESPONSE TO NOTICE OF VIOLATION The NRC letter dated March 12, 1987 identified a violation of Salem Generating Station CSGS> Technical Specification Surveillance Requirement

4. 6. 1. 1a which is required to ensure primary containment integrity is maintained.

During NRC Inspection 50-272/87-03 and 50-311/87-04, the NRC Inspector reviewed SGS Containment Integrity Surveillance Procedures CSPC0>4.6.1.1A1-I and -II> against Unit "as-built" drawings for selected systems penetrating containment and identified five CS> valves which should have been included in the surveillance but were omitted. These five valves are all located in the piping associated with the discharge from various relief valves in the Auxiliary Building which subsequently form a common header that penetrates containment and discharges to the Pressurizer Relief Tank C PRT>. The piping associated with these valves is only required to have a single check valve inside containment for isolation.

This single check valve is PR-25, which was itself not included in the SGS Inservice Testing CIST> Program until a recent program review in July of 1986 Cthe revised IST Program was submitted to Steven A. Varga, NRC from C.A. McNeill, Jr. on September 24, 1986). During the July 1986 review, the personnel involved failed to recognize that the relief valve discharge lines could have vents associated with them. This oversight is attributable to the normal design of relief valve discharge lines which are usually solid sections of piping directly piped to a common header or tank. Because the group reviewing the IST Program failed to recognize the potential of vents being installed on the relief valve discharge piping, only the common 4 inch header was reviewed for containment integrity surveillance requirements.

1. PSE&G DOES NOT DISPUTE THE VIOLATION.

2. THIS VIOLATION IS ATTRIBUTABLE TO A FAILURE BY PSE&G TO ADEQUATELY REVIEW IST PROGRAM CHANGES AGAINST CONTAINMENT INTEGRITY SURVEILLANCE REQUIREMENTS.

3. IMMEDIATE CORRECTIVE ACTIONS: a> Upon no ti fi ca ti on of possible discrepancies, the Shi rt Supervisor immediately performed a detailed review of both Unit *1 and Unit Containment Integrity Surveillances.

Because of the known discrepancy involving particular

.. : ... *-.... ' -,-.

• attention was paid to relief valve discharge lines and the Shift Supervisor identified 4 other vents off relief lines C 2SJ293, 2SJ299, 2CV309 and 2CV365> not included in the containment integrity surveillance.

All five of these *valves are identified in the Notice of Violation.

Additionally, the Shift Supervisor reviewed Unit tt1 and Unit tt2 containment surveillances against each other and found nine <9> other discrepancies.

Certain valves were contained on the Unit tt1 surveillance and not on Unit tt2 surveillance, and vice-versa.

After the review or the Containment Integrity Surveillances, the Shift Supervisor had the surveillances performed and also had the discrepancies corrected.

The tagging request inquiry system <TRIS> was updated and the surveillance lineups were changed to reflect the corrections.

All valves which were noted as discrepancies on the integrity lineups were round in their closed positions, as required by their normal surveillance.

After the performance or the surveillance, all the above noted valves were locked closed. b> In response to the Shift Supervisor's and NRC Inspector's findings, the Technical Department Procedure Group completed a review or the Containment Integrity Surveillances against the SGS Containment Isolation System UFSAR Table 6. 2-10. This review verified the Shift Supervisor's findings and also discovered ten C10) more discrepancies.

1) Six C6> vent and drain valves associated with the excess letdown heat exchanger component cooling supply line had not been included in the surveillance.

-Two < 2> or these valves C CC180 and CC278> were already locked closed in accordance with the normal component cooling water lineup, therefore they were just added to the integrity surveillance lineup -Four <4> of the valves were normally closed in accordance with the normal component cooling water lineup, therefore the normal position or these valves was changed to locked closed. However, three of these valves CCC205, CC110 and CC275> are located in the excess letdown heat exchanger room Ca locked, high radiation area inside the bioshield and essentially inaccessible>.

Because or the inaccessibility or these valves, PSE&G will check these valves only on the initial lineup and rely on the fact that they are located in a locked room. The fourth valve CCC274) was added to the containment integrity surveillance . .. ., .. -

• • • -< -... -r-* 2> Four C4> drain valves associated with the steam generator blowdown header located inside containment C11-14GB19) had not been included in the containment integrity surveillance and therefore were added to the "inside" containment surveillance and their normal position was changed from closed to locked closed. 4. LONG-TERM CORRECT! VE ACTIONS: PSE&G's long-term solution for providing adequate review of design changes and IST Program changes is close coordination between the System Engineers and the Technical Department Procedures Group. Due to greater system specific training and design criteria expertise possessed by the System Engineers, a better level of review than that which previously existed is expected.

5. COMPLIANCE PSE&G is now in full compliance the Technical Specification Surveillance Requirement

4. 6. 1. 1a . . . ::*