IR 05000272/1985015

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Insp Repts 50-272/85-15 & 50-311/85-17 on 850701-31. Violation Noted:Chemistry Instruction CH-3.5.012, Gas Decay Tanks - Sampling, Inadequately Maintained on 850412 When on-the-spot Change 1 Made to Instruction
ML18092A736
Person / Time
Site: Salem  PSEG icon.png
Issue date: 08/20/1985
From: Limroth D, Norrholm L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18092A734 List:
References
RTR-NUREG-0737, TASK-1.C.1, TASK-1.D.2, TASK-2.B.1, TASK-2.F.2, TASK-2.K.3.01, TASK-2.K.3.05, TASK-3.D.3.4, TASK-TM 50-272-85-15, 50-311-85-17, GL-83-37, NUDOCS 8508270208
Download: ML18092A736 (14)


Text


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Report No Docket No U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50-272/85-15 50-311/85-17 50-272 50-311 DPR-70 050272-810521 050272-830506 050272-840107 050272-840309 050272-840606 050272-850701 050311-850407 License No DPR-75 Licensee:

Public Service Electric and Gas Company 80 Park Plaza Newark, New Jers~y 07101 Facility Name:

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

Hancocks Bridge, New Jersey Inspection Conducted:

July 1, 1985 - July 31, 1985 Inspectors:

Reviewed by:

Approved by:

Inspection Summary:

6'*15*8S date e/10/as date Inspections on July 1, 1985 -,July 31, 1985 (Combined Report Numbers 50-272/85-15 and 50-311/85-17)

Areas Inspected:

Routine inspections of plant operations including: followup on outstanding inspection items, operational safety verification, waste gas decay tank sampling, maintenance observations, surveillance observations, ESF system walkdown, review of special reports, licensee event followup, TMI Items, and security allegatio The inspection involved 182 inspector hours by the resident NRC inspector Results:

This inspection identified two violations, one of which is of parti-cular concern because of the repetitive nature of the root cause (paragraph 4).

The failure to adequately sample the waste gas decay tanks contrary to the ( 8508270208 850822

~,

PDR ADOCK 05000272 I G PDR

requirements of Technical Specifications was a direct result of the implemen-tation of an improper on-the-spot change to the sampling procedur This on-the-spot change did not receive an adequate review and therefore when implemen-ted, changed the decay tank sample point to a control air line rendering the sample results meaningles A failure to follow procedures (paragraph 3.3.2.b.)

was also cited as a violatio Management took corrective action as described in paragraphs 3.3.2.b. and c.

  • DETAILS Persons Contacted Within this report period, interviews and discussions were conducted with members of licensee management and staff as necessary to support inspection activit.

Followup on Outstanding Inspection Items (Closed)

Inspector Follow Item (272/82-35-01).

This item addresses shielding design calculations and the fact that the licensee did not have adequate procedures to perform shielding design calculation The inspector reviewed recent design calculations for shielding and noted they had been performed utilizing an approved procedur This item is considered close (Closed)

Inspector Follow Item (272/83-13-02).

This ite~ resulted from a review of LER 83-20 which left open a licensee action ite The inspector has reviewed Procedure RP 1.024 which now incorporates the control of temporary shielding and insures removal of restraining pins from hanger This item is considered close (Closed)

Unresolved Item (311/83-24-08).

This item was opened during the review of LER 83-35 and identified the possibility of exceeding rod insertion limits during certain condition Administrative limits for operations were established and an evaluation was performe This item was further addressed in inspection 85-13 when the licensee proposed a new core configuration,and left open based on NRR acceptance of that new desig NRR issued the necessary Technical Specification change and the resident inspector has reviewed the Cycle 3 Reload Safety Evaluation Report which addresses the rod insertion limit concer The cycle 3 core has been loaded and physics tests have been performe No findings have been identified with regard to rod insertion limits or hot channel factor The inspector considers this item close (Closed)

Inspector Follow Item (272/84-08-02).

This item resulted from a review of LER 84-02 which left open a licensee action ite The inspector has reviewed de-sign changes lEC-1867 and 2EC-1868 which will replace main steam isolation valve steam assist valve These valves are on the master schedule to be installed during the next refueling outage The licensee has upgraded the existing valves by replacing the gasket and packing materia This item is considered closed.

(Closed)

Inspector Follow Item (272/84-13-04).

This item was written after a review of LER 84-0 The licensee was to follow up with a supplemental report after an engineering evaluation had been mad The inspector reviewed both the supplemental report and engineering evaluatio The inspector also reviewed Design Change IEC-1874 which added piping with a polyethylene copolymer coating to the service water syste The inspector considers this item close (Closed)

Unresolved Item (272/84-19~01; 311/84-19-01).

Venting of steam supply lines impact on safety related cable During the observation of maintenance activities an inspector observed that steam was directed onto a safety related cable tra He requested the licensee to conduct an evaluation of this steam environment on the cable The inspector reviewed safety evaluation S-C-G210-MSE-268 dated August 8, 1984, which concluded that ambient conditions did not exceed the environmental qualifications of the electrical cable The licensee also conducted a visual inspection of the cable tray contents and found no physical damag The inspector has no further question (Closed)

Inspector Follow Item (272/84-19-02).

This item was written relative to the timeliness of SORC reviews and the involvement of the SRG (Safety Review Group) resentative at the SORC meetin The inspector has observed one meeting and has conducted a review of the latest SORC involvement in post trip reviews and considers this item close (Closed)

Inspector Follow Item (272/84-28-02).

This item was written to close out licensee actions with respect to LER 84-1 The inspector has reviewed OD-12 Interpretation Guide 16, Procedural Changes l-OP-5, l-OP-6, l-OP-8, and OPIV-8.3.1.. The inspector also noted that the licensee submitted a license**

change request to NRR in November 198 This request is still under review by NR The inspector considers this item close (Closed)

Unresolved Item (311/84-35-01).

Following a reactor coolant depressurization the inspector contended that a LOCA had occurred in accordance with WCAP 980 The licensee requested Westinghouse to perform an evaluation to see if a LOCA had occurred and if a steam generator tube inspection was require The inspector reviewed the results of the evaluation which states that a LOCA did not occur and that there was not a pressure reversal of the steam generators and therefore a tube inspection was not require This item is considered closed.

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Operational Safety Verification 3.1 Documents Reviewed Selected Operators* Logs Senior Shift Supervisor 1 s (SSS) Log Jumper Log Radioactive Waste Release Permits (liquid & gaseous)

Selected Radiation Exposure Permits (REP)

Selected Chemistry Logs Selected Tagouts Health Physics Watch Log 3.2 The inspectors conducted routine entries into the protected areas of the plants, including the control rooms, Auxiliary Building, fuel buildings, and containments (when access is possible).

During the inspection activities, discussions were held with operators, techni-cians (HP & I&C), mechanics, supervisors, and plant managemen The purpose of the inspection was to affirm the licensee 1 s commitments and compliance with 10 CFR, Technical Specifications, and Adminis-trative Procedure (1)

On a daily basis, particular attention was directed to the following areas:

Instrumentation and recorder traces for abnormalities; Adherence to LC0 1 s directly observable from the control room; Proper control room shift manning and access control; Verification of the status of control room annunciators that are in alarm; Proper use of procedures; Review of logs to obtain plant conditions; and, Verification of surveillance testing for timely completio (2)

On a weekly basis, the inspectors confirmed the operability of selected ESF trains by:

Verifying that accessible valves in the flow path were in the correct positions; Verifying that power supplies and breakers were in the correct positions; Verifying that de-energized portions of these systems were de-energized as identified by Technical Specifications;

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Visually inspecting major components for leakage, lubrica-tion, vibration, cooling water supply, and general opera-ting conditions; and, Visually inspecting instrumentation, where possible, for proper operabilit (3)

On a biweekly basis, the inspectors:

Verified the correct application of a tagout to a safety-related system; Observed a shift turnover; Reviewed the sampling program including the liquid and gaseous effluents; Verified that radiation protection and controls were properly established; Verified that the physical security plan was being implemented; Reviewed licensee-identified problem areas; and, Verified selected portions of containment isolation lineu Inspector Comments/Findings:

The inspectors selected phases of the units' operation to determine compliance with the NRC's regulation The inspectors determined that the areas inspected and the licensee's actions did not constitute a health and safety hazard to the public or plant personne The following are noteworthy areas the inspector researched in depth:.

Unit 1 Unit 1 operated at 100% power throughout this report period with the exception of minor power reductions to perform surveillance testin Unit 2 Unit 2 began this report period in Mode 5 (cold shutdown)

with repairs in progress on pressure safety valve PR-Additional plant maintenance was performed and the unit was taken critical at 9:00 a.m. on July 7, 198 b.

On July 7, 1985 at 7:26 p.m., the reactor tripped from 33%

due to a main turbine trip caused by a high high water

The loss of water level control was caused when the operator made an error in the transfer of level control from manual to automati The operator failed to identify and utilize the proper procedure for this evolution and reversed the order of the manual-auto transfe This failure to follow procedure constitutes a violation (50-311/85-17-01).

The operator was disciplined and retrained on the need to utilize proce-dure On July 8, 1985 at 3:21 a.m., the unit was taken critical and another startup commence At 4:20 a.m., the reactor tripped due to a low low water level in No. 23 S This trip was also attributed to operator error; however, proce-dures were not violate The reason for the trip has been attributed, by the licensee, to lack of management coordina-tion during a complex evolutio The licensee management took corrective action by removing the supervisor in charge from shift work and placing him in a training status to study plant coordination during complex evolution The management also held shift meetings with each shift to emphasize the importance of coordination and cooperation of all involved in a plant startup and complex evolutio The unit was taken critical at 11:59 a.m. and placed on the line at 9:01 The Vice President Nuclear was present in the control room for the feedwater transition phase from manual to automatic and the placing of the unit on the gri On July 20, 1985 at 3:45 a.m., the licensee entered a Tech-nical Specification Action Statement when the leak rate calculation measured greater than 1 gp At 4:10 a.m. the licensee declared an unusual event and began a unit shut-dow The unit reached hot standby (Mode 3) at 12:03 The licensee cooled down and depressurized, within Tech-nical Specification limits until they could repair a packing leak on No. 3 level column isolation valve on July 21, 198 At 7:19 p.m. on July 21, 1985, the licensee commenced a unit startu During rod withdrawal a shutdown bank rod, 284, dropped into the cor The trip breakers were opened and an investigation identified an open stationary gripper coi The licensee subsequently found that a pin on the connector, located on the reactor head, was not made u The connector was re-connected and rod testing commence During the rod testing, rod 1C4 would not mov The licensee feels this connection was disturbed when technicians were working on 28 On July 23, 1985, the licensee completed repairs and testing of the control rod The unit was returned to J

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service at 4:54 Then at 5:58 a.m. the boron injection tank and boric acid storage tanks were found out of speci-fications during the 3-day routine samplin Technical Specifications limits are 20,000 to 22,500 ppm for the tanks and the sampling results were 18,500 pp The licensee brought the unit off the line and shut down per Technical Specifications and began boric acid batch addi-tions to the affected tank On July 24, 1985, the boron injection and boric acid storage tanks were returned to specifications and at 3:30 a.m. the unit was returned to servic The unit was brought to full power and the licensee is operating with increased surveillance on the monitoring of Boric Acid System This report period ends with the unit at 100% powe Waste Gas Decay Tank Sampling On July 1, 1985, the licensee determined that the Waste Gas Decay Tank grab samples required by Environmental Technical Specification Table 2.3-3 had not been obtained during 'the period of April 12 - July 1, 198 During this time period 12 releases from Unit 1 and 22 releases from Unit 2 were made without first obtaining a representative sample of the tank 1 s content Although the licensee obtained grab samples which were intended to be representative of the tank 1s contents, an on-the-spot change had been made to the chemistry sampling instruction (CH-3.5.012) which changed the sample point to the control air side of a pressure transmitte This resulted in the release of the waste gas tanks without prior samplin Section 11.3 of the FSAR states that 11before a tank is discharged to the environment, it is sampled and analyzed to determine and record the activity to be released, and then discharged to the plant vent at a controlled rate, and monitored for gross activit Samples are taken manually by opening the isolation valve to the plant vent discharge line and permitting gas to flow to the gas analyzer where it can be collected in a gas sample vesse After sampling, the isolation valve is closed until the tank contents are released.

Environmental Technical Specification Table 2.3-3 requires the licensee to obtain a grab sample prior to each waste gas storage releas The sample results are then used to determine the dose rate from iodine-131, tritium and certain particulate radionuclide Chemistry Instruction CH-3.5.012, 11Gas Decay Tanks - Sampling 11 describes the actions necessary for sampling the gas decay tank On April 12, 1985 on-the-spot change number 1 was written and approved to provide the cap-ability to sample the gas decay tanks from the pressure gauges on the 104 panel in the auxiliary buildin This new sampling procedure was developed in order to provide an improved sampling method; however, during the on-the-spot change review neither the supervisor in charge nor the senior shift supervisor identified the fact that this new method was a change of

intent from the original procedur It appears that a lack of understan-ding of P&ID symbols contributed to the inadequate review in that the chemistry supervisor misinterpreted the symbol 11 PP on print 205240 to mean 11 pressure tap 11 instead of 11 pressure transmitter 11 *

Instead of sampling the gas decay tanks this new method actually sampled the control air side of a pressure transmitte Therefore the pre-release dose rate calculations were meaningless and the licensee failed to obtain the samples required by Environmental Technical Specification Table 2.3-A region based health physics inspector conducted a review of the licensee's plant release calculations and determined that the releases made from the plant vent during the period of April 12 - July 1, 1985 presented no hazard to the publi The calculations were based upon the plant vent monitor which was in service during each of the thirty-four release There were no unmonitored waste gas releases during the period in questio The region based inspector's findings are documented in combined Inspection Report 50-272/85-17; 50-311/85-1 The inspector noted that there have been several recent examples of violations involving on-the-spot changes to procedures as documented in Inspection Reports 311/85-07, 272/85-03, 311/84-22 and 272/84-08 -

311/84-0 In addition, the post-change review/approval process performed by the department head, Quality Assurance, SORC (Meeting number 85-075), and the General Manager also failed to identify the inadequacy of the procedure chang The licensee's failure to perform an adequate review of on-the-spot change number 1 to chemistry instruction CH-3.5.012 is a violation (50-272/85-15-01; 50-311/85-17-02). Maintenance Observations The inspectors observed portions of various safety-related maintenance activities to verify that redundant components were operable, these activities did not violate the limiting conditions for operation, required administrative approvals and tagouts were obtained prior to initiating the work, approved procedures were used or the activity was within the 11 skills of the trade, 11 appropriate radiological controls were properly implemented, ignition/fire prevention control~ were properly implemented, and equipment was properly tested prior to returning it to servic During this inspection period the following activities were observed:

Spent Fuel Heat Exchanger outlet flange repair per work order 85-06-19-006-1 Repair of various service water valves No violations were identifie *

10 Surveillance Observations During this inspection period, the inspector reviewed in-progress surveillance testing as well as completed surveillance package The inspector verified that the surveillances were performed in accordance with licensee approved procedures and NRC regulation The inspector also*

verified that the instruments used were within calibration tolerances and that qualified technicians performed the surveillance The following surveillances were reviewed in depth with portions of the procedures witnessed by the inspecto SP(0)4.l.2.7a Unit 1 SP(0)4.l.2.5a Unit 2 SP(0)4.5. Unit 2 SP(0)4.7.l.2C Unit 2 Reactivity Control System - Borated Water Sources Surveillance Procedure Reactivity Control System - Borated Water Sources Surveillance Procedure Emergency Core Cooling - ECCS Subsystems AFWST Flow Path to Each Steam Generator No violations were identifie.

Engineered Safety. Feature (ESF) System Walkdown The inspectors verified the operability of the selected ESF system by performing a walkdown of accessible portions of the system to confirm that system lineup procedures match plant drawings and the as-built configuration, to identify equipment conditions that might degrade performance, to determine that instrumentation is calibrated and functioning, and to verify that valves are properly positioned and locked as appropriat The Unit 1 auxiliary feedwater and Unit 2 containment spray systems were inspecte No violations were identifie.

Review of Periodic and Special Reports Upon receipt, the inspectors reviewed periodic and special report The review included the following:

inclusion of information required by the NRC; test results and/or supporting information consistent with design predictions and performance specifications; planned corrective action for resolution of problems, and reportability and validity of report informa-tio The following periodic reports were reviewed:

Unit 1 Monthly Operating Report - June 1985 Unit 2 Monthly Operating Report - June 1985

11 Licensee Event Report Followup The inspector reviewed the following LERs to determine that reportability requirements were fulfilled, immediate corrective action was taken, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification Unit 1 LER 85-005 Waste Gas Decay Tanks Not Sampled Prior to Releasing Contents A discussion of this event can be found i*n paragraph 4 of this inspection repor Unit 2 LER 85-007 Premature Lifting of Steam Generator Safety Valve This LER addressed the premature lifting of steam generator safety valve 22MS14 which was subsequently found, by the licensee, to be approximately 300 psi out of calibratio Further investigation, by the licensee, indicated that several other safety valves on steam generator No. 22 were also hundreds of psi out of specificatio No viable reason could be found for the valves' being so far out of specification and the licensee took the following actions to prevent recurrence and also to insure that no tampering occurred with the valve Lock wires were installed on the valve cap Temperature measurements are now recorded when the safety valves are se Physical measurements are recorded of the settings between the top of the shaft and the adjustment nu A four hour temperature soak is now necessary prior to setting the adjustment nu Since the lock wires have been installed several wires were found broken, but measurements and testing proved that no tampering had occurre The licensee intends to replace the wire seals with heavier and stronger wir.

Update on NUREG 0737 (TMI Action Plan)

10.1 The following TMI Action Items are still considered open and this section of the report updates their statu l. Short Term Accident and Procedures Review l.C.1.2.B Inadequate core cooling revise Procedures l.C.1.3.B Transients and Accidents revise Procedures The latest letter to NRR from PSE&G dated May 15, 1985, updates NRR on the implementation of the above procedure The procedures have been approved and issued, but not yet inspected by the resident inspecto l. Plant Safety Parameter Display Console l.D. l.D. Installed Fully Implemented PSE&G has submitted to NRR the safety analysis and implementation plan and is scheduled to install the system during the 1986 refueling outage PSE&G's latest correspondence with NRR dated June 27, 1985 provides additional information requested by NRR with regard to the safety analysi II.B.1 Reactor Coolant System Vents II.B.1.2 Installed II.B.1.3 Procedures The latest letter from NRR considers this item close The resident inspector plans to inspect the implementation of the system during the next report perio II. Instrument for Detection of Inadequate Core Cooling II.F.2.3.B Implement The current letter from NRR to PSE&G outlines the following:

(1)

the currently installed RVLIS system for Units 1 and 2 is acceptable with the condition that the Kit No. 2 installation for Unit 2 should be completed during the 3rd refueling outage (February 1985);

(2)

the commitments to upgrade the core exit thermocouples (CETs)

and to update emergency operating procedures based on Westing-house Owners Group ERG Revision 2 are acceptable; (3)

the proposed schedule to complete upgrading of the existing CET system prior to startup after 1986 refueling outages for both units, and to train operators and implement the revised procedures between November 1984 and March 1985 is acceptable;

(4)

the final, proposed Technical Specification changes to the Accident Monitoring Instrumentation in Tables 3.3-lla, 3.3-llb and 4.3-11 should follow the guidance described in Generic Letter No. 83-37, 11 NUREG-0737 Technical Specifications 11 (in addition to the subcooling margin monitor (SMM), these tables should include the CET and RVLIS with correct definition of the number of RBLIS channels, i.e., One Full Range and One Dynamic Head indication comprising a complete channel and should also provide for redundant SMMs upon completion of the SMM upgrading; and (5)

the current SMM is required to be upgraded, and an additional backu~ SMM display is also required to meet the requirements specified in NUREG-0737 Appendix The inspector researched the above open items and has verified that; (1)

The Kit No. 2 has been installed in both units, but not inspecte (2)

The emergency procedures are in place, but not inspecte (3)

This area will be inspected when complete (4)

The Technical Specifications have been submitted to NRR via letter of December 13, 198 (5)

The Subcooling Margin Monitor will be upgraded during the 1986 outages on both unit II. Final Recommendations B&O Task Force

- II.K.3. Auto Trip of RCPs The latest letter from NRR dated June 28, 1985, gives the licensee options as to how to operate the RCP's during certain condition The licensee will respond within the time frame of the letter, 45 day The licensee is currently reviewing the option.2 The following TMI Action Items are considered close II. Final Recommendations B&O Task Force

- II.K.3. Auto PORV Isolation Test and Installation Final letter from NRR dated October 6, 1983, agrees with the licensee's safety analysis and states that automatic isolation of PORVs is not require II.K.3.25. Power on Pump Seals

The latest letter from NRR dated July 6, 1982, agrees with the licensee's safety analysis and states that the current installed system is adequat III.D.3 Control Room Habitability

- III.D.3.4:2 Modification The latest letter from NRR dated July 1, 1980, agrees with the licensee's safety analysis and states that no changes are necessar No violations were identifie.

Security Allegation An anonymous phone call received by Region I caused the resident inspectors to conduct a review into two areas of securit The alleger stated 11 there were not enough guards to cover a contingency (loss of the computer system for example) and that guards were not properly dressing out (wearing the proper anti-contamination clothing) in radiation protection area The resident inspectors conducted an investigation into these allegations with the following result there are adequate compensatory postings to address contingencies at the station with the present shift mannin guards do not as a rule enter contaminated areas and therefore do not don protective clothin However, they may b~ present at the entrance to contaminated area The inspector considers these items close.

Exit Interview At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection scope and finding An exit interview was held with licensee management at the end of the reporting perio The licensee did not identify 2.790 material.