IR 05000272/1982012

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IE Insp Repts 50-272/82-12 & 50-311/82-13 on 820512-0608. Noncompliance Noted:Failure to Review & Approve Procedures & Failure to Perform Surveillance Tests Re Containment Penetration Isolation Points
ML20054J671
Person / Time
Site: Salem  PSEG icon.png
Issue date: 06/14/1982
From: Blumberg N, Chung J, Hill W, Lazarus W, Norrholm L, Petrone C, Shaub E, Roxanne Summers, Lester Tripp
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20054J667 List:
References
50-272-82-12, 50-311-82-13, NUDOCS 8206290411
Download: ML20054J671 (21)


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(DCSNumbGrs-see attach d shest)

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION I

l 50-272/82-12 Report Nos.

50-311/82-13

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50-272 Docket Nos.

50-311

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DPR-70 License Nos.

DPR-75 Licensee:

Public Service Electric and Gas Company

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80 Park Plaza Newark, New Jersey 07101 Facility Name:

Salem Nuclear Generating Station - Units 1 and 2 Inspection At:

Hancocks Bridge, New Jersey Inspection Conducted-May 12 - June 8, 1982 h

6!/#Mb Inspectors:

L.tJ. Norrholm, Senior Resident Inspector date

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C. lo. Sa R. Summers, Resident Reactor Inspector date

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n Ft W. 'a rus) Reactor Inspector date

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W. !(l Hill,s., Senior Resident Inspector (Region IV)

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w N. J. Blumperg, Reactor Ins /ector date

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6//UEL J. W. Chung, Reactor Inspector date fT d /O 6 2-E. T. Shaub', Reactor Inspector date

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. D. P trone, Reactor Inspector date Approved By:

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[.. E."Tr;bp, Chief, Reactor Projects Section No. 2A, date

Projects Branch No. 2, DPRP 8206290411 820614 PDR ADOCK 05000272

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Report Nos. 50-272/82-12 and 50-311/82-13 DCS Nos:

I 050272-820329 050311-820328 050272-820405 050311-820417 050272-820406 050311-820418

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050272-820409 050311-820423 050272-820410 050311-820504 050272-820422 050311-820519 050272-820501 050311-820521 050272-820419 050311-820526 050272-820425

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Inspection Sumary:

Inspections on May 12 - June 8, 1982 (Combined Report Numbers 50-272/82-12 and 50-311/82-13)

Unit 1 Areas Inspected:

Routine inspections of plant operations including tours of the facility; confonnance with Technical Specifications and opera-ting parameters; log and record reviews; reviews of licensee events; house-keeping; implementation of strike plans; and followup on previous inspection items.

The inspection involved 250 inspector hours by the resident and regional NRC inspectors. This included continuous inspection coverage (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day) during the continuing strike.

Results: One violation was identified (Failure to review and approve pro-cedures - Paragraph 10).

Unit 2 Areas Inspected: Routine inspections of plant operations including tours of the facility; conformance with Technical Specifications and opera-ting parameters; log and record reviews, reviews of licensee events; house-keeping; implementation of strike plans; and followup on previous inspection items. The inspection involved 260 inspector hours by the resident and regional NRC inspectors. This included continuous inspection coverage (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day) during the continuing strike.

Results: Two violations were identified (Failure to review and approve pro-cedures - Paragraph 10, failure to perfonn surveillance tests - Paragraph 3b).

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DETAILS 1.

Persons Contacted J. Driscoll, Assistant General Manager - Salem Operations L. Fry, Operations Manager J. Gallagher, Maintenance Manager H. Midura, General Manager - Salem Operations L. Miller, Technical Manager J. O'Connor, Radiation Protection Engineer F. Schnarr, Reactor Engineer R. Silverio, Assistant to the General Manager J. Stillman, Station QA Engineer The inspector also interviewed other licensee personnel during the course of the inspections including management, clerical, maintenance, operations, perfomance and quality assurance personnel.

2.

Status of Previous Inspection Items (Closed) Violation (272/81-29-01and311/81-29-02) Failures to provide or follow adequate procedures. Licensee corrective and preventive measures included the modification or preparation of the following procedures: SP(0) 4.6.2.2.(b) Containment Systems - Spray Addi-tive Unit 2 with "on-the-spot" change dated December 4,1981; PD-3.6.001, Primary System Lithium Addition, Revision 3, dated February 19,1982; PD-3.6.002, Hydrazine Addition to the RCS, Revision 3, dated February 19, 1982; PD-3.6.014 Ion Exchanger Resin Refilling, Revision 1, dated January 7, 1982; and Emergency Instruction-I-4.24, Pressurizer Pressure Control Malfunctions, Revision 0, dated April 7, 1982. All changes made are responsive to the items identified. The spray additive surveillance proce-dure has an upper limit established. The chemistry addition procedures require verification by a second qualified individual and the emergency instruction provides guidance for operator action in the event of postulated loss of pressure control. The inspector had no further questions.

(Closed) Violation (272/81-23-06 and 311/81-21-04) Mode changes with equipment inoperable due to closed valves or failure to perfom surveillance tests. The inspector confirmed licensee corrective and preventive measures stated in the reply letter dated November 9, 1981.

The Tagging Request and Inquiry System (TRIS) computer is functional in both units and provides current valve position and tagging status. The containment airlock test for Unit 2 is scheduled and perfomed as required and a review of current sur-veillances confimed that the post accident monitoring instru-mentation surveillance is being conducted at the specified frequency.

The inspector had no further questions.

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(Closed) Violation (311/81-21-06) Failure to wrap diesel power cables for fire protection as required by license. As documented in NRC Inspection Reports 50-311/81-26 and 50-311/81-29, completion of all required fire wrapping has been confimed.

In addition, the licensee rssponse to this item stated that further steps would be taken to improve controls over the design change implementation program. Based on observations during the recent refueling outage, increased emphasis on documentation completion and verification by system walkdowns was evident. The inspector also reviewed the results of Corporate Quality Assurance Department Audit S-81-35 which addresses Design Change Request (DCR) implementation. The inspector had no further questions.

(Closed) Unresolved Item (311/81-21-02) Program to clean electrical relays. When witnessing relay maintenance, as documented in NRC Inspection Report 50-311/82-05, the inspector confirmed that the licensee's Relay Department conducts a periodic program of relay maintenance and cleaning. The inspector had no further questions on this item.

(Closed) Violation (272/81-09-01) Failures to make timely' reports to NRC. The inspector confimed that the licensee has undertaken several measures to ensure timely reporting, including; direct reporting from the site, assignment of individuals with the sole responsibility for timely reporting, improved tracking mechanisms for responses, and changes to the Emergency Plan.

Proper use of the above systems and the Emergency Plan Classi-fication Guide should be effective in preventing recurrence of this item.

(Closed) Unresolved Item (272/81-23-07) Periodic incorporation of "on-the-spot" changes into procedures.

Revision 11 to Adninistra-tive Procedure 3. Document Control Program, dated November 12, 1981, requires that permanent on-the-spot changes be incorporated during. the two-year procedure review or when the number of changes causes ~ the procedure to be difficult to use. A sampling inspection of procedures confirmed that the above adninistrative requirement is being complied with. The inspector had no further questions.

(Closed) Follow Item (272/79-31-01) Adequacy of AP-17 for radioactive

. waste audits. Since identification of this item, organizational changes have occurred such that all station audits are now the responsibility of the Corporate QA Department. Accordingly, the governing document is QA Instruction 18-1, Audits by the Quality Assurance Department, Revision 8, dated September 4,1981.

This QAI specifically requires an annual audit of the packaging and transport of radioactive material, and acknowledges this area as a safety related activity. The inspector had no further questions on this ite (Closed) Violation (272/78-30-02) Failure to follow procedure during waste compacting. Licensee responsibility for this operation has shifted to the radiation protection group and is governed by a new procedure, RP 13.004, Operation of the Stock Equip-ment Trash Compactor, Revision 0, dated April 7,1981. The procedure is silent with respect to area monitoring but is explicit in requiring air sampling, which is the more pertinent issue. Adequate airflow is also required as a prerequisite.

The applicable Extended Radiation Exposure Permit (EREP # 9902)

furthor specifies the wearing of respiratory protection. The

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j inspector had no further questions on this item.

(Closed) Follow Item (272/82-10-03) Review of Cycle 4 startup test data.

Post refueling tests were conducted during the period April 7 to May 12, 1982. The inspector reviewed test results for the following core parameters; isothemal temperature coefficient, critical boron concentration, power coefficient, integral rod worth, and hot channel factors at 95% rated thermal power. All values were acceptable.

(Closed) Violation (272/81-23-01, 311/81-21-01) Failures to perfom four-hour surveillance of rod position when required. The inspector

confimed licensee corrective and preventive measures which consist of requiring the recording of rod position every four hours regardless of the deviation alam condition. This action is dictated in licensee direction to shift operators and has consistently been perfomed for the past several months. The inspector had no further questions.

(Closed) Follow Item (272/81-20-02) Procedure revisions to address anoma-lous gas releases. The inspector reviewed chemistry procedures PD-3.8.023, PD-3.3.020, and PD-3.8.016, all of which had been revised on July 31, 1981. Each procedure had been revised to include recording and evaluation of Plant Vent Monitor, R16, readings on a daily basis, providing a mechanism for review and control of anomalous gas releases. With respect to the failure to make these changes as originally stated, the inspector also confirmed that a single system of tracking and controlling comitments has been established and a response coordinator has been designated with the responsibility of ensuring such comit-ments are met in a timely manner. The inspector had no further questions.

(Closed) Violation (311/81-27-01) Failure to submit special Auxiliary Feedwater Pump Test report within the time specified by the license. The inspector verified licensee corrective and pre-ventive measures designed to track these types of reports and ensure timely submission. The inspector had no further questions on this item.

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3.

Review of Plant Operations A.

Daily Inspection The inspector toured the control room area to verify proper manning, access control, adherence to approved procedures, and compliance with LCOs.

Instrumentation and recorder traces were observed. Status of control room annunciators was reviewed. Nuclear instrument panels and other reactor protective systems were examined. Control rod in-sertion limits were verified. Containment temperature and pressure indications were checked against Technical Specifications.

Effluent monitors were reviewed for indications of releases. Panel indica-tions for onsite/offsite emergency power sources were examined for automatic operability. During entry to and egress from the protected area, the inspector observed access control, security boundary in-tegrity, search activities, escorting, badging, and availability of radiation monitoring equipment.

The inspector reviewed shift supervisor, control room, and field operator logs covering the entire inspection period. Sampling reviews were made of tagging requests, night orders, the jumper / bypass log, incident reports, and QA nonconformance reports. The inspector also observed several shift turnovers during the period.

The above daily inspections, which included back shifts, were made on May 12 - June 8, inclusive.

Due ^4 the on-going strike, continuous (24-hour) inspection coverage was maintained through the inspection period.

No unacceptable conditions were identified.

B.

Plant Tours The inspector toured accessible areas of the plant at least once per week.

The tours included the control rooms, relay rooms, switchgear rooms, penetration areas, auxiliary building (elevations 122', 100',

84',64',55'), fuel handling building, turbine building, service watar intake structure, plant perimeter and containment. During these tours, observations were made relative to equipment condition, fire hazards, fire protection, adherence to procedures, radiological con-trols and conditions, housekeeping, security, tagging of equipment, ongoing maintenance and surveillance, and availability of redundant equipment.

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Operability of the following Unit 1 and 2 ESF subsystems was verified by confinning flowpath valve positions, breaker alignment, instrumen-

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tation and equipment condition:

Containment Spray (both trains -

Auxiliary Building), Auxiliary Feedwater (3 trains - Auxiliary Building and Penetrations), Safety) Injection (both trains - Yard, Auxiliary Building)and Penetrations, Service Water (both trains - Yard, Auxiliary

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Building. Current tagouts were selected for review and were verified in effect as specified. Records of current surveillance for tank boron concentrations, vital heat trace and pump testing were reviewed. The

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inspector conducted a complete walkdown of the Unit 2 Auxiliary Feed-water System, to examine confonnance with as-built drawings, lineups, supports, instrumentation, electrical and controls cabinets and to confirm availability of the system.

The following Limiting Conditions for Operation, not directly verifi-able in the control room, were confirmed by field inspection or record Fire barriers (3.7.11), Diesel Fuel inventory (y Feedwater (3.7.1.3),

review:

service water availability to Auxiliar 3.8.1.1), and CARD 0X system availability (3.7.10.3).

During these plant tours, minor problems associated with unsecured compressed gas bottles, apparent fire hazards, and poor housekeeping were identified and were discussed with facility management.

During a plant tour on May 22, 1982, the inspector noted that valves

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2SJ332 and 2SJ333, which are series drain isolation valves located

between containment isolation valve 2SJ53 and the containment wall in

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the penetration area, were not locked or tagged. These valves fall into the group defined in Technical Specification 4.6.1.1.a which re-

quires that, at least once per 31 days, all penetrations not capable of being closed by operable containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions.

The valves were, however, not included in the list of valves verified by surveillance procedures to comply with the above specification.

In addition, a drawing review revealed that companion drain valves 2SJ368 and 2SJ369, inside containment,were not on the 92-day surveillance list as required by the same specification. Simultaneous opening of all four valves would have provided an effective 3/4" opening in containment.

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When positions were verified, all valves were found closed as they had been during the most recent system valve lineup on October 4,1981.

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Further review of system drawings by the inspector found that vent and

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drain valves 2SJ338, 2SJ339, 2SJ340, and 2SJ341, which are located be-tween outside containment isolation valve 21SJ40 and the containment

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wall, were also not included in the 31 day valve verification.

It was further noted that none of these valves exist on Unit 1.

Failure to include the above valves in the 31 day surveillance listing constitutes a violation of Technical Specification 4.6.1.1.a (311/82-13-02).

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Prior to the end of this report period, the licensee had identified a total of 14 such valves outside containment and 2 inside. All were added to the surveillance listing and confimed shut.

While inspecting Unit 2 Containment on May 20, 1982, the inspector noted that the tags attached to fire hose stations 2FP-89 and 2FP-96 indicated that the most recent hose inspection was conducted on January 3,1982. Technical Specification 4.7.10.4.a requires visual inspection of these hose stations once per 31 days if accessible during plant operations. Review of the completed surveillance pro-cedure. in which hose station inspections are documented, revealed

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that these had been annotated as " inaccessible." The inspector agreed with the licensee that a containment entry at power for the sole pur-pose of inspecting fire hoses was probably unnecessary. However, experience showed that entries for a variety of reasons are made an average of once per week. The licensee stated that an alternate procedural mechanism would be established to take advantage of un-planned containment entries and accomplish the fire hose inspection during those times. This item is unresolved pending further review by the inspector (311/82-13-03).

The inspector had no further questions relative to observations during plant tours.

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Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9.1 and 6.9.2 were reviewed by the inspector. The reports were reviewed to determine that the report included the required infomation; that test results and/or supporting information were consistent with design predictions and perfomance specifications; that planned corrective action was adequate for resolution of identified problems; and, whether any information in the report should be classified an an abnomal occurence.

The following periodic and special reports were reviewed:

Unit 1 Monthly Operating Report - April 1982

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Unit 2 Monthly Operating Report - April 1982

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No unacceptable conditions were identifie.

Surveillance Testing a.

The inspector observed the perfomance of surveillance tests to confim the following: testing was perfomed in accordance with adequate pro-cedures; test instrumentation was calibrated; limiting conditions for operations were met; removal and restoration of the affected components l

were properly accomplished; test results confomed with Technical Speci-fication and procedural requirements and were reviewed by personnel other than the individual performing the test; deficiencies noted were reviewed and appropriately resolved; personnel perfoming the surveil-lance activities were knowledgeable of the systems and the test pro-cedures and were qualified to perfom the tests.

These observations included:

Inservice (ASME XI) Inspection of Auxiliary Feedwater Pumps

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Inservice (ASMEXI)TestingofContainmentValves

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Testing of turbine governor and stop valves

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Inservice (ASME XI) Inspection of Boric Acid Transfer Pump

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Operability Test of Emergency Diesel Generator 2C

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Inservice (ASME XI) Inspection of Containment Spray Pumps

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11 and 12 Channel Check of Power Range Nuclear Instrument 2N44

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Retest of Containment Fan Coil Unit 24 following breaker

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maintenance Inservice (ASME XI) Inspection of Safety Injection Valves

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Functional check of Area and Process Radiation Monitors

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j One hour load test of Emergency Diesel Generator 28

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Primary and Secondary Chemistry Sampling and Analysis

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In addition, the inspector selected over 40 surveillance requirements and verified that documentation confimed testing was current as

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required by Technical Specifications.

No unacceptable conditions were identified.

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Maintenance Activities The inspector observed portions of maintenance activities to detennine that the work was conducted in accordance with approved procedures, regulatory guides, Technical Specifications, and industry codes or standards. The following items were considered during this review:

limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing was performed prior to declaring that particular component as operable; and activities were accomplished by qualified personnel.

Portions of the following maintenance activities were observed:

Repacking of Heater Drain Punp 12

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Repair of pressure control valve 22 SW 57

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Temporary repair of vent valve 1 CV 372

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Repair of high speed breaker for 24 Containment Fan Coil Unit (CFCU)

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Repair of service water leak on 22 CFCU

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Repair of area radiation monitors 2R41 A, B, C

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Repair of Fire Pump 2 Starter

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No unacceptable conditions were identified.

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Operating Events a.

UNIT 1 The plant operated at full power for the entire report period with some power reductions for secondary plant maintenance to heater drain pumps, condensers, and circulating water traveling screens.

b.

UNIT 2 At 7:20 a.m. on May 19, during containment inspection to detennine

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the cause of increased leakage to the sump, operators discovered a 1.5 gpm service water leak in a coil of Containment Fan Coil Unit 22. The leak was isolated and repaired.

In accordance with IE Bulletin 80-24, the leak was reported to NRC via ENS.

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-- While repairing the service water inlet pressure control valve (22SW57) for Containment Fan Coil Unit 22 on May 21, the licensee The organisms were identified as mostly oysters (g the valve.

found an accumulation of shellfish remains foulin crassostrea virginica) indigenous to Delaware Bay but not usually found this far up-river due to low salinity. No other flow restrictions were found through monitoring of process parameters. However, evidence of the same organisms was found in valve 21SW57, a Turbine Auxiliaries heat exchanger and in a Unit I condenser water box. The licensee is continuing to inspect components-served by the Service Water system and is seeking authority to increase the chlorination rate to the system, currently limited by the NPDES pemit. This is the first occurrence of fouling by these organisms. The licensee postulates that, during the low runoff conditions of the sunner 1981 drought, river water was sufficiently saline to allow viable spat to travel through the service water strainers and lodge in low flow areas of the system. An LER will be submitted.

While investigating the cause of continuous running of the Con-

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tainment sump ptsnp on May 26, licensee operators discovered a service water leak in the motor cooler for Containment Fan Coil Unit (CFCU)21. The leak was. estimated in excess of 100 gpm and was isolated immediately at 2:50 p.m.

In accordance with IE Bulletin 80-24, the leak was reported via ENS to the NRC Duty Officer as required. Subsequent review confirmed that the

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containment sump had not overflowed; however, based on hold-up tank level changes and observation of the leak, approximately 8000 gallons of service water'had spilled. A brazed end-cap on the motor cooler manifold broke, spraying service water onto the fan coil unit motor and into the containment. An attempt to dry the motor was made during replacement of the motor cooler; however, subsequent testing of the motor indicated a motor ground fault.

The motor was then replaced with a spare motor onsite. However, this motor would not run in the high (nomal mode) speed but would run in the low (accident mode) speed. The CFCU was therefore considered operable and additionally the licensee prepared a safety evaluation detailing the acceptability of operating normally with one CFCU not being able to function in the high speed. All Technical Specification surve'illance requirements are met without the high speed feature opereble. An LER will be submitted.

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Operating license DPR-75 is conditioned with a requirement that

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NUREG-0737 item II.F.1 (High range conitoring of noble gas, particulates, and radiciodine) be completed by June 1,1982.

Since the work necessary to provide continuous sampling of these effluents requires an outage and would clearly not be completed on time, the licensee applied for relief from NRR on May 28, 1982.

Indications are that an extension may be granted.

Interim sampling and analysis methods continue to be available. This item is unresolved pending a decision on the license amendment request (311/82-13-04).

c.

SITE At midnight on April 30 all bargaining unit employees represented

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by International Brotherhood of Electrical Workers (IBEW) Local 1576 initiated a strike. The IBEW represents all personnel on site with the exception of security and office workers. Operators up to the level of reactor operator were included. At the con-clusion of the inspection period, the IBEW was still on strike and both units were operating at full power.

The inspector had no further questions with respect to operating events.

8.

Licensee Events a.

In Office Review of Licensee Event Reports The inspector reviewed LERs submitted to the NRC:RI office to verify that details of the event were clearly reported, including the accur-acy of the description of cause and adequacy of corrective action.

The inspector detemined whether further infomation was reqdired from the licensee, whether generic implications were involved, and whether the event warranted onsite followup. The following LERs were reviewed:

UNIT 1

82-19/03L No. 2 Fire Pump - Inoperable 82-20/03L Auxiliary Feedwater Storage Tank - Low Level 82-21/03L No.12 Steam Generator Steam Flow Channel 2 - Inoperable

82-22/03L No.14 Containment Fan Coil Unit - Inoperable 82-23/03L Containment - Plant Vent Radioactivity Monitors -

Inoperable

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82-24/03L No. 12 Containment Fan Coil Unit - Inoperable

82-25/03L No. 13 Steam Generator Wide Range Level - Inoperable

82-26/03L Boric Acid Storage Tanks and Boron Injection Tank

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Concentration Out of Specification 82-27/99X0 No. 2 Fire Pump - Inoperable

82-28/03L Refueling Water Storage Tank Low Level 82-29/03L No.12 Containment Fan Coil Unit - Inoperable

82-30/03L Containment Type B and C Leak Rate Test - One Valve Out of Specification UNIT 2

82-23/03L 100' Elevation Containment Air Lock - Inoperable

82-24/03L Boric Acid Storage Tanks and Boron Injection Tank -

Concentration Out of Specification 82-26/03L No.1C4 Rod Position Indicator - Inoperable 82-27/03L Missed Surveillance - Reactor Coolant System Water

Inventory 82-28/01T Containment Service Water Leak - No. 23 Containment

Fan Coil 82-29/03L Containment Sump Monitoring System - Inoperable

82-30/03L No. 24 Containment Fan Coil Unit - Inoperable

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Onsite Licensee Event Followup For those LERs selected for onsite followup (denoted by asterisks in detail paragraph 8a), the inspector verified the reporting require-ments of Technical Specifications and Regulatory Guide 1.16 had been met, that appropriate corrective action had been taken, that the event was reviewed by the licensee as required by AP-4 and 6, and that con-tinued operation of the facility was conducted in accordance with Technical Specification limits. The following findings relate to the LERs reviewed on site:

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UNIT 1 82-19/03L The first of these reports details the failure of No.

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and 2 Fire Pump due to starter and voltage regulator 82-27/99X problems which put it out of service for four days.

The redundant pump remained available. The second report discusses a subsequent period of r.ine days during which the pump was inoperable due to a failure to start in the automatic mode. Again, the redundant pump was available, as well as the backup supply of water from the Hope Creek site.

In the first case, the starter had exhibited a symptom of repeatedly attempting to engage once the pump was running. Al-though the pump was satisfactorily tested following replacement of the starter, the repeated pumping of the starter had sufficiently damaged the flywheel ring gear to cause failt e to start in the later event. The ring gear was replaced and the ptnp satis-factorily tested.

82-22/03L This report details failure to achieve 700 gpm flow

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through Containment Fan Coil Unit 14 during surveillance testing due to a low output from the high speed air supply regulator for flow control valve 14SW57. The monthly surveillance test requires that 700 gpm be achieved but does not specify the speed.

In low speed, these units achieve in excess of 2500 gpm. Since this failure affected the high speed regulator, the unit would probably have been operable in the accident (low speed) mode.

82-24/03L These reports detail failures to achieve required service

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and water flow through Containment Fan Coil Unit 12 during 82-29/03L surveillance testing on April 10 and May 1,1982 due to sticking of control valve 12SW223.

In each case the valve was exercised and a successful test conducted. A subsequent failure on May 26 resulted in disassembly of

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the valve for inspection.

It was then noted that the flow silencer, a bundle of small diameter tubes, was severely eroded and apparently contacting the vee-ball disc in t:u valve. The flow silencer was removed, a spacer inserted, and the valve reassembled and returned to service. The inspector confimed that a Deficiency Report was written to track restoration of the valve to design configuration. Another Licensee Event Report will be submitted detailing the most recent failure.

The inspector further noted that Containment Fan Coil I

Units are run routinely such that flow control failures l

will be detected at intervals considerably shorter than the required 31 day surveillance interva I a

82-25/03L This event is detailed in NRC Inspection Report 50-272/

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82-10, paragraph 5.a.

82-26/03L This event is detailed in NRC Inspection Report 50-272/

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82-10, paragraph 5.a.

82-28/03L This report discusses a situation in which the Refueling

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Water Storage Tank (RWST) level went below the minimum prescribed by Technical Specifications while filling the Spent Fuel Pit with borated water. Level was re-stored within the seven hours required to place the unit in Hot Standby. The inspector reviewed Operating In-struction II-8.3.1, Filling the Spent Fuel Pit, Revision 4, dated June 5, 1981. The procedure makes adequate reference to monitoring RWST level during this operation to prevent decreases below the required volume. Despite these cautions, this event occurred. The licensee corrective action included only counseling of the

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operator. Since the margin between a full tank and the Technical Specification minimum is small (less than 5%

of tank level), the licensee concurred with the inspector's position that additional actions, possibly in the fom of some operator aid, were appropriate and should be explored. Adequacy of licensee preventive measures to prevent such events remains unresolved (272/82-12-02).

The LER, as submitted on May 21, 1982, also contains an error in the event date. A corrected copy was submitted.

UNIT 2 82-23/03L Inoperability of air lock doors has been a recurring

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problem. Licensee corrective steps have included a change in the vendor for door seals.

Recently, the licensee received a new preventive maintenance program from the air lock vendor, and expects to implement the recommendations in the near future. This program will be reviewed in followup of previous unresolved item 272/81-12-03.

82-24/03L On March 28, 1982 boric acid batching to Unit 2 Boric

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Acid Storage Tanks and subsequent transfer to Unit 1 to increase levels in preparation for startup was in pro-gress.

In the course of these operations, a sample on Unit 2 showed low concentration, below Technical Speci-fication limits. The concentration was restored within the time limits established for placing the unit in hot standby. No plausible explanation for dilution was proposed. The licensee agreed that further investigation was necessary to identify probable causes and develop preventive measures to preclude recurrence. This item is unresolved p(ending completion of the licensee's investigation 311/82-13-05).

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-- 82-27/03L During power escalation,the licensee failed to perfom a water inventory balance within the time interval (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) specified by Technical Specifications to determine reactor coolant system leak rate. Due to the nature of Xenon effects in the reactor, simply terminating the power escalation would not provide the steady state conditions necessary to accurately make the leak rate determination. The licensee further notes in the report that Unit 1 Technical Specifications acknowledge that the test be perfomed under steady state conditions.

During the period that a current leak rate value was unavailable, remaining indicators, such as activity levels and sump pump operations, were monitored to con-firm no changes in conditions. The licensee states, in the report, that a change to Unit 2 Technical Specifica-tions will be proposed to account for non-steady state conditions and that a supplement will be submitted for the LER. This item will be confirmed during a subsequent inspection (311/82-13-06).

82-28/01T This event is discussed in NRC Inspection Report 50-311/

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82-09, paragraph 5.b.

82-29/03L This report details an event in which the containment

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sung pump ran continuously for a period of almost three hours before it was detemined that the discharge valve had failed shut while cycling breakers in search of a ground. The inspector noted that the length of time that the pump ran before investigation was significant since this is the primary detection method for leaks in containment, especially service water leaks. Normally the pump runs for only two minutes to pump sump water from the high to low level sensors. The licensee stated that additional action to provide a more visible indicator of sump pump operation besides the auxiliary alarm annun-ciator/ typewriter system currently in use will be eval-uated. Adequacy of licensee corrective action in this event remains unresolved (311/82-13-07).

82-30/03L Twice, on April 17, 1982, Containment Fan Coil Unit 24

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tripped on overcurrent when started. The unit was lubricated and a guillotine damper repositioned and the unit successfully started and declared operable. A subsequent failure on May 18 may also have some bearing on these failures.

In the later failure, the overcurrent settings were found lower than those on the remaining uni ts. When the overcurrent trips were reset, the unit functioned nomally on starting. A separate LER will be submitted for the later event.

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9.

Cleanliness and Housekeeping The inspector reviewed licensee administrative controls over general house-keeping and cleanliness practices to confirm that adequate procedural guid-ance is provided in these areas. The following facility procedures were reviewed:

Administrative Procedure (AP) - 9. Control of Station Maintenance,

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Revision 7, dated April 13, 1982.

Administrative Procedure (AP) -' 21, Mechanical System Cleanliness

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Program, Revision 2, dated March 18, 1982.

Administrative Procedure (AP) - 31, Housekeeping Program, Revision

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0, dated March 19. 1982.

Operations Directive (OD) - 13, Containment Cavity Area Tool Account-

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ability, Revision 1, dated April 6, 1982.

Fire Fighting and Organization Manual,. Revision 5, dated September

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15, 1980.

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Maintenance Procedure M11F, Tool and Miscellaneous Items, Cleanliness

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and Closure Control, Revision 3, dated August 31, 1981.

In aggregate, the above procedures establish housekeeping zones, control housekeeping during work activities, require the removal of excess equipment,-

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require the removal of combustibles, and establish responsibilities for these activities. With respect to equipment, the procedures establish system clean-liness levels, specify cleaning methods, require material accountability for

"open" systems, establish practices for maintaining cleanliness of systems, and establish responsibilities for these activities.

The inspector had no questions with respect to the established programs for housekeeping and cleanliness.

10. Procedures a.

The inspector observed that a new Operations Directives Manual (ODM)

had recently been issued to replace a previous ODM. The ODM contains both Administrative Directives (AD's) and Operations Directives (0D's).

AD-13. Independent Review of Operations Department Documents, Revision 0, dated April 2,1982, lists those 0D's which must be reviewed by the 50RC and approved by the Station Manager. The following OD's were not included in AD-13 and did not hase SORC review or Station Manager approval. These OD's covered procedural areas within the scope of Regulatory Guide 1.33, as indicated, or otherwise contained safety related subject matter:

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00-3, "Large Motor Starting Criteria" (R.G. 1.33 - 1978, paragraph

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3);

0D-9, " Dropped Control Rods and Power Mismatch Circuit" (R.G.1.33 -

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1978, paragraphs 3.b and 6.1);

0D-12. " Technical Specification Interpertations" (Safety Related);

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00-15, "Use of Operations Department Procedures" (R.G. 1.33 - 1978,

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paragraph 1.d and ANSI 18.7 - 1976, paragraph 5.2.2);

00-16, " Tagging Request and Inquiry System (TRIS)"(R.G. 1.33 - 1978,

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paragraph 1.c and ANSI N18.7 - 1976, paragraph 5.2.6);

00-18, " Senior Shift Supervisor and Shift Supervisors Logs" (R.G.

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1.33 - 1978, paragraphs 1.g and 1.h);

OD-20};" Shift Turnover Responsibilities" (R.G.1.33 - 1978, paragraph

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1.g OD-37, "Use of Safety Tags to Comply with Section 4.5.2 of the

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Technical Specifications"(R.G. 1.33 - 1978, paragraph 1.c);

00-38, " Diesel Generator Valid Start Criteria" (R.G. 133 - 1978,

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paragraph 3;s); and, OD-51, " Leakage from Plant Systems" (Safety Related).

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Additionally AD-13 states that 0D-33, " Operations Log 13, Control In-strumentation/ Alarm Inoperable /0ut of Calibration" shall be reviewed by the SORC and approved by the Station Manager. However, this OD was issued without such review and approval.

ANSI N18.7 - 1976, paragraphs 5.2.19, 5.3.2(8), and 5.3.10 require that acceptance criteria be included in test procedures. The inspector observed that surveillance test procedures for safety related pumps per the criteria of ASME Code,Section XI, did not contain specific accep-tance criteria. Data was recorded and submitted to Maintenance Depart-ment engineers for review.

Operators were unable to make a detennination of pump acceptability at the completion of tests. Acceptance criteria

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were established based on tables included in procedure M-17F. However, the actual acceptance criteria for each pump were not included in pro-cedure M-17F but were established separately for each pump. While the specific acceptance criteria were not reviewed by the SORC nor approved by the Station Manager, the explicit method used in procedure M-17F to determine those criteria was properly reviewed and approved and is, therefore, acceptable.

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Failure to obtain SORC review and Station Manager approval of safety related procedures is contrary to Technical Specifications 6.8.1 and 6.8.2 and Regulatory Guide 1.33 and constitutes a violation (272/82-12-01and311/82-13-01).

b.

In each unit, the licensee has acknowledged the need for local copies of operating instructions at the hot shutdown panel, the waste system control panel (104) and in the diesel generator control room. During plant tours, the inspector noted that a number of the local copies of these procedures were not up to date when compared with the master copies in the control room. Further review found that the licensee had issued Administrative Directive-3, Document Control, on March 30, 1982.

This procedure details control mechanisms for local procedures, and lists, specifically, those procedures to be placed locally. Prior to the end of this inspection period, the inspector confirmed that new binders with complete, up to date, procedures had been placed at the above locations.

Extraneous procedures were being removed. The in-spector noted, however, that no clear mechanism for making on-the-spot changes to local procedures had been defined. This item remains un-resolved (272/82-12-03).

11. Emplove.2 Strike At midnight April 30, 1982, all bargaining unit employees represented by International Brotherhood of Electrical Workers Local 1576 went on strike.

These employees included all operators to the level of Nuclear Control Operator (licensed Reactor Operators), and all maintenance and technician personnel at non-supervisory levels. Prior to the strike, the inspectors confirmed that the licensee had adequately prepared a contingency plan for continued operation. As the strike continued, the inspectors verified that regulatory and safety criteria were adequately addressed by assigned per-sonnel.

Licensed duties in the control room were assigned to currently experienced Senior Reactor Operators who normally perfom the shift supervisory functions.

Similarly, maintenance and technical functions were assigned to supervisory personnel with current or recent experience in the respective jobs to be perfomed. Twelve hour shift rotations were established with all licensed positions being adequately covered by recently experienced operators. Non-licensed positions were filled by a core of licensed operators augmented by engineers and staff personnel receiving on-the-job training.

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The strike continued through the end of this report period. The inspectors evaluated continuity of manning as required by the license, qualifica-tions of personnel in assigned tasks, and the impact on plant staff of protracted working hours and confinement. The inspection also addressed continuity of surveillance and maintenance activities as required to comply with Technical Specifications.

One week into the strike, the licensee instituted a rotation plan whereby approximately 25% of the staff would leave for two days after working six days. Adequate two-shift staffing was maintained on site to meet all requirements. After the third week, only a few off-shift personnel were retained on site.

No unacceptable conditions were identified.

12. Unresolved Items Areas for which more information is required to determine acceptability are considered unresolved. Unresolved items are contained in Paragraphs 3, 7, 8 and 10.

13.

Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings.