IR 05000272/1989015
| ML18094A609 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/03/1989 |
| From: | Swetland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18094A607 | List: |
| References | |
| 50-272-89-15, 50-311-89-14, NUDOCS 8908160266 | |
| Download: ML18094A609 (18) | |
Text
Report N License Licensee:
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/89-15 50-311/89-14 DPR-70 DPR-75 Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge, New Jersey 08038 Fae i l ity:
Salem Nuclear Generating Station - Units J and 2 Dates:
June 6, 1989 - July 24, 1989 Inspectors:
Kathy Halvey Gibson, Senior Resident Inspector Stephen M. Pindale, Resident Inspector Approved:
Inspection Summary:
8*3*89 Date Inspection 50-272/89-15; 311/89-14 on June 6, 1989 - July 24, 1989 Areas Inspected:
Resident safety inspection of the following areas:
operations, radiological controls, surveillance testing, maintenance, emergency preparedness, security, engi neeri ng/techni cal support, safety assessment/assurance of quality, and review of licensee event report Results:
Two violations relative to missed Technical Specification (T.S.)
surveillance tests and three examples of failure to follow procedures are
- discussed in Section These violations were licensee identified, however since corrective actions for previous similar occurrences did not prevent these instances from occurring, a violation is cite Other examples of licensee inadequate corrective actions to prevent recurrence of previously identified problems are discussed in paragraph 1 Five unresolved items were identified concerning material control (Section 2.2.lB), engineering
.
evaluations of surveillance test data (Sections 2.2.2B and 8.2B), unauthorized installation of a main steam drain valve (Section 8.2A), adequacy of correction actions to control oxygen concentration in the waste gas system (Section 9.0), and adequacy of T.S. amendment implementation (Section 9.0).
8908160266 890804 PDR ADOCK 05000272 G
PNU
Details SUMMARY OF OPERATIONS Unit 1 was in Mode 3 (Hot Standby) at the start of the inspection period with preparations for startup from the eighth refueling outage in progres On June 9, an automatic safety injection and reactor trip occurred from Mode 3 when a main steam safety valve opened prematurel The reactor was taken critical on June 1 On June 18, a unit shutdown was initiated per Technical Specifications from about 20% power due to an inoperable Safeguards Equipment Control trai Mode 3 was reached before repairs could be complete On June 19, when restart activities were in progress, an automatic reactor trip occurred from 45% power during post maintenance testing activities when a main steam isolation valve inadvertently close The following day, a safety injection check valve bonnet leak was identified inside containment, and a shutdown to Mode 5 (Cold Shutdown) was initiated for repair Valve repairs were completed on June 23, however, the licensee identified the presence of sodium in the reactor coolant system (due to improper boric acid batching).
The sodium was subsequently removed and the reactor was made critical on June 2 Full power was reached on July Power operation continued for the remainder of the inspection period.
Unit 2 operated at 100% power un~il June 10, when plant operators manually tripped the reactor after all six condenser circulators automatically tripped due to an instantaneous heavy grass buildup at the circulating water intak The unit was returned to service on June 14, and power operation continued for the remainder of the inspection perio.
OPERATIONS (71707, 71710, 93702) Inspection Activities On a daily basis throughout the report period, the inspectors verified that the facility was operated safely and in conformance with regulatory requirement Public Service Electric and Gas (PSE&G) Company management control was evaluated by direct observation of activities, tours of the facility, interviews and discussions with personnel, independent verification of safety system status and Limiting Conditions for Operation, and review of facility record These inspection activities included 169 inspection hours including weekend and backshift inspections on July 16 (9:30 a.. m. - 1:30 p.m.) and July 19 (3:00 a.m. - 5:00 a.m.).
2 Inspection Findings and Significant Plant Events 2. Unit 1 On June 9, while in Mode 3 (Hot Standby), a Unit 1 safety injection (SI) and reactor trip occurred due to a high steam line differential pressure conditio That condition was created by the No. 13MS15 main steam safety valve (MSSV) lifting twic Licensee review of this event concluded~that saturated water inside the No. 13 steam line underwent an oscillating wave phenomenon, thereby changing to steam and back to water and creating localized pressure spikes within the steam lin The pressure oscillations apparently resulted in lifting 13MS15 twice and caused the differential pressure SI signa The unit was stabilized in Mode 3 per station emergency procedure In accordance with the licensee's Emergency Plan an Unusual Event was declared due to high head SI injection into the vesse This event was reported to the NRC in accordance with 10 CFR 50.72 reporting requirement Further lice~see root cause determination identified that operating procedures did not r~quire placing the steam trap system in service in Modes 3 or 4 to drain the condensate from the main steam lines upstream of the main steam isolation valve The failure to properly use this system apparently resulted in condensate buildup inside the steam line Licensee corrective actions for this event included revising operating procedures to direct placing the steam trap system in service when the plant enters Mode 4 (Hot Shutdown) during startu In addition the licensee has requested Westinghouse to perform a review and analysis of the events to confirm the licensee's root cause determinatio Following the event, the licensee lift tested 13MS15, and found that it had lifted about 6 psig below its allowable setpoin All the MSSVs were new and just installed during the recent refueling outag All lift setpoints were factory se Based on the 13MS15 result, the licensee elected to test the other MSSV The licensee speculated that some other MSSV setpoints may also be lower than the manufacturer set value due to the installed valves being exposed to high ambient temperatures from main steam piping which increases the spring temperature and lowers the valve setpoint, The MSSVs were tested and adjusted, as necessar The licensee's engineering organization is continuing their investigation to confirm the cause of the MSSV setpoint discrepancie The inspectors review of this event is complet On June 18, 1989, the unit was shutdown to Mode 3 in accordance with T.S. due to the lA Safeguards Equipment Controller (SEC) being inoperable during maintenance in excess of T.S. action statement
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time limit The licensee replaced two failed circuit boards and reset a sequence timing switc The SEC was then tested satisfactorily and returned to servic The unit was returned to service on June 19, 198 On June 19, Unit 1 automatically tripped from 45% power due to low-low water level on the No. 13 steam generator (SG).
The plant was ascending in reactor power following completion of repairs to the lA SE The low SG level condition resulted when No. 13MS167 main steam isolation valve (MSIV) inadvertently closed during post-maintenance testing of an MSIV bypass valve on an adjacent steam lin The plant responded as per design and was stabilized in Mode 3 (Hot Standby).
The licensee notified the NRC of the event in accordance with 10 CFR 50.72 reporting requirement The test procedure, SP(0)4.0.5-V, results in the closure of the bypass valve while checking the continuity of the closure circuit for all four MSIV A similar event occurred at Unit 2 on April 11, 1989, and as a result a failed reset relay was replace The l~censee attributed the root cause of the Unit 1 event to be inadequa~e design of the test circui Further investigation revealed that due to the test circuit design, a degraded reset relay will permit inadvertent closure of the MSIV The licensee's initial efforts were to investigate a possible problem with the same relay which caused the Unit 2 reactor tri During troubleshooting the UnJt 1 circuit to determine the condition of the reset relay, the licensee recorded one inadvertent MSIV closure (under simulated conditions) out of 33 tests on the circui The relay operated satisfactorily 32 time The licensee elected to send the relay offsite for evaluation to determine whether a defect or intermittent failure exist Licensee corrective actions include implementing a Unit 1 design change to improve the circuit design by providing an additional contact to prevent the relay from resetting during the MSIV bypass valve tes The modification will not prevent the MSIVs from actuating in the event a valid fast closure signal is generate The licensee plans to similarly modify the Unit 2 circuitry during the next outage of sufficient duratio For the interim, the appropriate Unit 2 surveillance test procedure will be revised so that the circuit will not challenge the MSIV The inspector will review the Unit 2 surveillance test procedures and the modification during a future inspectio The results of the vendor evaluation of the reset relay will also be reviewed by the inspecto While in Mode 3 on June 20, the day following the reactor trip, the licensee identified that a safety injection check valve inside
2. A..
containment was leaking at its bonnet connectio Licensee management decided to cool the plant down to Mode 5 (Cold Shutdown)
to affect valve repair The repairs were completed on June 2 Subsequently, the licensee identified the presence of sodium in the reactor coolant system (RCS).
Followup investigation identified that an improper mix of boric acid compounds had been inadvertently used in the batching process and subsequently injected into the RC The sodium was subsequently removed from the RCS by use of demineralizers and the unit was returned to service on June 2 The licensee was conducting an evaluation to determine the root cause for the wrong boric acid mi Of particular concern is whether broader problems exist with respect to storage, labeling, and retrieval of material from the warehous This item is unresolved pending completion of this evaluation and review by the inspecto (UNR 272/89-15-01)
Unit 2 On June 10, plant operators manually tripped the Unit 2 reactor from about 15% reactor power following the loss of five (out of six total) circulating water (CW) pump Prior to losing the five circulators, the plant was operating at full powe Control room annunciators and indicators revealed high differential pressures across several CW screens, and operators immediately initiated a rapid manual power reductio At about 49% power, the main turbine was manually tripped and the steam dump (SD) system was being used to remove heat from the primary syste However, within several minutes of the event, SD system actuation was automatically blocked due to the loss of condenser vacuum, resulting in lifting several steam generator safety valve The control room supervisor directed plant operators to manually trip the reacto The plant was sub-sequently stabilized in Mode 3 (Hot Standby) in accordance with station procedure The plant responded to the trip as per design, however, two equipment problems occurred and are discussed belo The licensee reported this event to the NRC in accordance with 10 CFR 50.72 reporting requirement There are a total of 12 SD valves, which are divided into four groups of three such that each of the three valves dumps into one of the three condenser shell Two of the blocking signals which prohibit SD valve operation are 1.) circulator not in service (two pumps per circulator), and 2.) condenser not available (low vacuum).
During the event, five CW pumps had tripped within four minutes; resulting in the loss of circulators No. 22 and 23 which blocked the operation of eight SD valve CW pump No. 21A remained running and circulator No. 21 was still available, thereby allowing four SD valves to dump steam to the No. 21 condense About 13 minutes following the loss of the five CW pumps, the condenser not available blocking signal had actuated, and closed the four open SD valves.
During licensee troubleshooting activities, it was identified that there was a defective coil in an interfacing relay associated with the No. 21A CW pump, causing an indication that all six CW pumps (all three circulators) were unavailable and totally blocked any SD operation at the initiation of the even The other potential,equipment problem was the operation of the main steam atmospheric relief valves (21-24MS10), one on each of the four main steam line During the event, the MSlOs did not automatically open when the lift setpoints were reached, resulting in main steam safety valves (MSSVs) openin One MSSV (the lowest setpoint) per steam line opened, and then properly reseate Plant operators subsequently opened the MSlOs manually during the transien The licensee attributed the failure of all four MSlOs to a phenomenon called "reset windup", in which the valve controller 11 sits 11 at saturated conditions at about 800 psig, therefore the controller continuously attempts to seat the valv The controller apparently cannot respond to quick transients and open the valves as the setpoint is reached (1035 psig).
Operations management stated that the MSlOs do open under the majority of conditions when called upon and that operators have been trained to expect either respons The licensee is conducting an evaluation to determine the acceptability of the controller application and to develop further guidance for plant operators to provide them with an increased understanding of the design response of the MSlO The root cause of the event was attributed to an external cause and inadequate corrective action in response to a similar prior even The high screen differential pressure was the result of an apparent instantaneous accumulation of grass and debris on the scree One day prior to this event, there were extreme weather conditions, including heavy rain and high wind Those conditions resulted in significant amounts of grass to be in the river from which the CW pumps take a suctio The CW intake structure is provided with vertically mounted trash rack A mechanical rake serves to clean the trash racks, however, the licensee determined that the rake becomes ineffective when the trash racks are matted with large amounts of debri The licensee also determined that the lower one-third area of the trash racks was matted and clogged the flow of wate This condition, in turn, resulted in higher flow velocities near the water surface in order to sustain normal CW pump flowrate A similar event occurred on Unit 1 in August, 198 The corrective action associated with that event involved a one time cleaning of the racks but did not require any long term corrective actions or actions to prevent recurrenc Licensee actions for the recent occurrence included cleaning the trash racks and establishing a
2. preventive maintenance activity on an 18 month interval to periodically clean the rack In summary, plant operators responded well to the even Equipment deficiencies occurred which require licensee resolution, including correcting an inaccurate LER and investigating the MSlO valve op~ration/ application concern The *licensee identified that their actions for a previous similar *occurrence were inadequat The inspector questioned the licensee whether formalized increased monitoring of CW systems was appropriate following severe storm The licensee stated that monitoring would be considered in their evaluations. _The inspector concluded that the licensee actions in response to this event were acceptabl Both Un its ESF System Walkdown The inspector independently verified the status of engineered safety feature (ESF) systems by performing system walkdown System components and support systems were verified to be opera 1Jle, such as hangers and supports, insulation, area ventilation, valves and pumps, and component lubrication and cooling subsystem Calibration dates for installed instrumentation and proper housekeeping were also verifie The inspector performed detailed walkdowns of the high head safety injection and containment spray system The overall condition of these systems was acceptable. Individual deficiencies were brought to the licensee 1 s attention for resolutio.
RADIOLOGICAL CONTROLS (71707) Inspection Activities PSE&G 1 s compliance with the radiological protection program was verified on a periodic basi.2 Inspection Findings Tours of the radiologically controlled areas were routinely conducted by the inspector The overall condition and contamination controls in the Auxiliary Building were satisfactor Individual deficiencies were brought to the licensee's attention for resolutio.
SURVEILLANCE TESTING (61726) Inspection Activity During this inspection period the inspector performed detailed technical procedure reviews, witnessed in-progress surveillance testing, and reviewed completed surveillance package The inspector verified that J
the surveillance tests were performed in accordance with Technical Specifications, approved procedures, and NRC regulation The following surveillance tests were reviewed, with portions witnessed by the inspector:
SP(0)4.0.5-P-AF(12)
SP(0)4.0.5-P-AF(23) Inspection Findings Reactor trip and reactor trip bypass air circuit breaker semi-annual inspection, lubrication and testin Inservice Testing - Unit 1 Auxiliary Feedwater Pump No. 11 Inservice Testing - Unit 1 Auxiliary Feedwater Pump No. 12 Inservice Testing - Unit 2 Auxiliary Feedwater Pump No. 23 On June 26, 1989, the licensee informed the NRC that the Unit 2 11A
reactor trip breaker undervoltage trip att~chment (UVTA) failed the as-found (prior to the preventive maintenance activity) output force measurement tes This test measures the margin of force in addition to the weight of the trip bar that the UVTA is capable of overcomin The acceptance criteria for this test is 460 grams of weight added to the trip ba Weight is then added in 60 gram increments until the UVTA fails to trip the breaker to determine the margi The maintenance and testing of the reactor trip breaker (RTB) and UVTA is performed as part of the above six-month preventive maintenance (PM) activit As a result of the Salem ATWS event, the licensee is committed to report any deficiencies identified with the RTBs to the NR The licensee replaces the UVTAs every refueling outag The licensee has observed that while the UVTAs all meet the acceptance criteria (460 grams) when received from the manufacturer, the margin of force which the more recently purchased UVTAs are tapable of overcoming is less than the older UVTA The licensee has discussed this observation with the vendor to ascertain the cause, but to this date the vendor has not concluded a reason for the differenc However, as a result of the observed reduction in margin, the licensee has experienced intermittent failures of the UVTAs to meet the PM acceptance criteria for the output force measuremen In pursuing the cause of this particular failure, the system engineer identified two discrepancies between procedure M3Q-2 and the 11Westinghouse Maintenance Program Manual for the 08-50 Reactor Trip Circuit Breakers and Associated Switchgear 11 dated November 20,
198 The discrepancies are (1) M3Q-2 did not require a linear measurement from the trip lever pin to the trip bar as specified in the vendor manual and (2) M3Q-2 specified that the weights be added to the trip bar prior to closing the breaker, while the vendor manual indicates that the breaker should be closed first, then the weights added to the trip ba The M3Q-2 procedure was revised accordingl The licensee determined that the linear measurement discussed previously was slightly out of tolerance for the 2A RTB (18/32 11 vs 15/32 11 ).
Following adjustment, the output force measure-ment test was performed and the results were acceptable (3 trials -
580 gr., 580 gr., 700 gr.). After lubrication of the UVTA in accordance with the M3Q-2 PM requirements, the 11 as left 11 results were 760 gr., 760 gr., 760 gr. for 3 trial The 2A RTB was returned to service following completion of the M3Q-The system engineer has not concluded that the difference in test methodology is the root cause of the marginal performance of certain of the UVTAs and is continuing his investigation and discussions with the vendor and other utilitie The inspector will continue to follow licensee actions in this regar The Unit 2 surveillance test perfcrmed on the turbine driven Auxiliary Feedwater pump yielded unsatisfactorily result Two sets of data were obtained for pump differential pressure in an attempt to get acceptable dat Both sets were in the action rang The operators therefore declared the pump inoperable and entered the appropriate Technical Specification Action Statemen The Technical Department subsequently reviewed the data and determined that the pump was operabl See Section 8.2.B for details regarding the licensee's technical evaluatio The inspector questioned operations management relative to their policy regarding obtaining more than one set of data in performing a surveillance test and how the data is used if results are not the same (i.e. one set acceptable, one set not acceptable).
In the case of the AFP test, both sets of data were in the action range (unacceptable), however only one set (the less unacceptable) was used in the licensee's evaluatio The licensee stated that engineering evaluation and judgement are used in determining which data to us However, there qid not appear to be adequate documented justification for disregarding the one set of AFP differential pressure dat Further review in this area is required by the inspector to determine whether the licensee is following accepted industry testing standard This item is unresolve (UNR 272/89-15,.-02)
9 MAINTENANCE ( 62703) Inspection Activity. During this inspection period the inspector observed portions of selected maintenance activities to ascertain that these activities were conducted in accordance with approved procedures; Technical Specifications, and appropriate industrial codes and standard Portions of the following activities were observed by the inspector:
Work Order 890620098 890724091 Inspection Findings Procedure Troubleshooting Guide lIC-14.1. 001 Description Troubleshoot and repair 13MS167 fast closure circuit Investigate and repair control rod 2Dl - indication reading near maximum limit (low)
The inspector found that the maintenance activities inspected were effective with respect to meeting the safety objectives of the maintenance progra EMERGENCY PREPAREDNESS Inspection Activity PSE&G's use of and compliance with the Event Classification Guide was observed during the inspection period relative to Unusual Event declaration on June 9, 1989 and reactor trips on ~une 10 and June 1.2 Inspection Findings The licensee's activities in the above areas inspected were determined to be satisfactor.
SECURITY Inspection Activity PSE&G's compliance with the security program was verified on a periodic basis, including adequacy of staffing, entry control, alarm stations, and physical boundaries.
10 Inspection Findings Implementation of the security plan was found to be adequat.
ENGINEERING/TECHNICAL SUPPORT inspection Activity The inspectors reviewed licensee actions relative to the engineering/technical support-functional areas for the following issue.2 Inspection Findings During licensee followup concerning the Unit 1 safety injection on June 9, 1989, it was identified that during the seventh refueling outage (1987) an unauthorized globe valve was installed on the main steam system drainlin The valve provides isolation of the common main steam line steam trap discharge header to the No. 12 condense The installation was unauthorized in that a design change package was not developed and approved by SORC for th2 installation contrary to 1 icensee administrative procedure AP-8, 11 Design Change, Test and Experiment Program 11 *
The AP requires a Design Change Request for any change that involves a print revisio In addition, AP-5, 110perating Practices Program 11 requires independerit verification of component manipulations in the main steam syste Since the design change process was not implemented, the valve was not entered into the licensee 1 s computerized Tagging Request Information System (TRIS) and included as part of the main steam system valve lineu The licensee 1s investigation regarding the unauthorized valve installation is continuin Upon identification, the valve was numbered and entered into the TRIS system for configuration contro Failure to follow administrative procedures involving design changes and independent verification of valve lineups is unresolved (UNR 272/89-15-03) pending completion of licensee investigation and NRC review of corrective actions to prevent recurrenc.
A July 12, 1989 performance of SP(0)4.0.5-P-AF(23) yielded unsatisfactory results with respect to pump differential pressur The results placed the Unit 2 turbine driven auxiliary feedwater -
(AFW) pump in the required action range due to a high valu The licensee 1 s System Engineering Group analyzed the results, using previous test results, pump curves and ASME Section X By memorandum dated July 12, the licensee concluded that the results were acceptable for that performance, and the pump was declared operable and returned to service.
The basis for the licensee 1 s conclusion was that the baseline values for the pump differential pressure were at 96% of the pump curve, and the July 12 performance was 100.2% of the curv The conclusion stated that ASME Section XI allows the test results to vary by 2% of the baseline value on the high end; and the combination of a baseline which was slightly low and a test result which was slightly high, have caused the pump to fa11 into the required action rang However, the evaluation did not address the 4.2% (vice 2% allowed)
increase from the baseline value and its potential operability implication The memorandum fu~ther stated that should the pump continue to run at the slightly higher level, additional evaluation would be performed and baseline data would be changed, as necessar The licensee informed the inspector that the use of a different flow gauge on a different piping location accounted for the increase in measured differential pressure since no maintenance work was performed on the pump following its previous monthly test run which would account for the chang The inspector noted that the effect of the different test methods was not included in the licensee 1 s evaluatio Following discussion with the system engineer and re*1iew of the surveillance test and associated documentation, the inspector determined that the licensee used baseline data obtained previously using an improved gauge configuration, but performed the most recent test using a less precise measuring device and configuration since the improved gauge was offsite for calibratio The combination of the results of the two different methods yielded the unsatisfactory dat However, there was not sufficient information and analysis in the licensee 1 s evaluat5on to support this conclusio The inspector did not disagree with the licensee 1 s conclusion that the pump could fulfill its intended safety functio ASME Section XI allows for analyses to be performed to demonstrate that the required action range condition does not impair pump operability and that the pump will fulfill its function, provided a new set of reference values is then established after such an analysi At the end of the inspection period, the licensee agreed that a new baseline should be developed, and committed to perform that tas Further review of this and similar evaluations is necessary to determine whether the licensee is in compliance with ASME requirements regarding corrective actions for data beyond acceptance criteria, and development of new reference values when require This item is unresolved.(UNR 272/89-15-04) LICENSEE EVENT REPORT AND OPEN ITEM FOLLOWUP (90712, 92700) The inspector reviewed routine operating and licensee event reports submitted to the NRC Region I Office to verify that the details of the event were clearly reported, including accuracy of the description of
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cause and adequacy of corrective actio The inspector determined whether further information was required from the licensee, whether generic implicitions were indicated, and whether the event warranted onsite followu The following reports were reviewed:
Unit 1 and 2 Monthly Operating Reports - May, 1989 Uni~ 1 and 2 Monthly Operating Reports - June, 1989 Unit 1 LER 89-009; Inadequate sampling of plant vent effluent due to a procedure deficiency; Corrective actions included revising the procedure and installing a redundant sampling alignmen Failure to obtain plant vent composite samples is a licensee identified violation of Technical Specification 3.3.3.9 Table 3.3-13 Action 3 The inspector has determined that the discretion criteria of 10 CFR 2, Appendix C have been satisfied and concluded that a violation will not be cite (NCV 272/89-15-05)
LER 89-010; Due to the failur~ of a common air sample pump, both actuatiori trains of the Containment Purge/Pressure - Vacuum Relief System became inoperabl The equipment was repaired within the action requirements of Technical Specification LER 89-013; LER 89-017; Failure to perform surveillance tests within the required time in accordance with T.S. 4.0.5 (lA diesel generator service water valve and prelube oil pump) and T.S. 4.3.3.3.1 (Triaxial time - history accelographs) due to inadequate administrative control Surveillance scheduling has been a weakness in the licensee's program for which a previous violation has been issued (VIO 272/88-14-01).
Although these missed surveillances were licensee identified, the licensee's corrective actions for the previous similar violation did not prevent these recurrence Therefore, the discretion criteria of 10 CFR 2, Appendix C have not been met and a violation is propose (VIO 272/89-15-06)
This item closes violation 272/88-14-0 LER 89-014; An ESF actuation, containment ventilation isolation, occurred due to a failed channel scalar which caused a high channel spik The channel scalar was subsequently replaced, and the channel was calibrated and functionally tested satisfactoril LER 89-015; Historical failure to compare snubber drag force surveil-lance results in accordance with T.S. 4.7.9e.1 due to misinterpretation of the requiremen Field Directive No. S-C-MPOO-MFD-1, "Functional Testing of Mechanical Snubbers" had been revised to require the comparison check pending NRR approval of a license changed request (LCR) to delete this requiremen The LCR was subsequently approved by NRR on July 20, 198 The inspector has determined that this
failure to comply with T.S. constitutes a licensee identified violation which will not be cited since the discretion criteria of 10 CFR 2, Appendix C have been me (NCV 272/89-15-07)
LER 89-016; Oxygen concentration in the waste gas decay tank exceeded T.S. limits and were not reduced within the required tim The LER documents similar previous occurrences in April, 1986 and December, 1987. The root cause of the oxygen ingress has been attributed by the licensee to system design and procedure problem Corrective actions for the three occurrences involved procedure revisio This item will be unresolved pending the inspector's review of the licensee's corrective actions to prevent further recurrence of this problem. (UNR 272/89-15-08)
LER 89-018; SSPS Cabinet Connections Unsatisfactory Due to Inadequate Initial Fabrication; This event is discussed in NRC Inspection Report Nos. 50-272/89-11; 50-311/89-1 LER 89-019; Loss of Decay Heat Removal Capability Due to Personnel Error; This event is ciscussed in NRC Special Inspection Report N /89-1 LER 89-020; T.S. Surveillance 4.5.2h Non-Cqmpliance; Maximum Charging Pump Safety Injection Flow Rate Exceeded; This event is discussed in NRC Inspect~on Report Nos. 50-272/89-11; 50-311/89-1 LER 89-021; On May 23, 1989, the Radiation Protection Engineer identified that the high radiation area (HRA) (>1000 mR/hour)
including the eves holdup tank rooms was not being controlled in
- accordance with Technical Specifications in that the entrance to the HRA was not locked or guarded, for approximately a 10 minute perio A guard was posted immediately upon identification of the proble Licensee investigation identified that a contractor technician had removed the pad lock on the door and entered the area to perform a pre-job survey and failed to either lock or guard the entrance while the survey was in progres Licensee RP procedures require continuous surveillance of unlocked HRA doors to preclude unauthorized entrie Further, the results of surveys of the eves holdup tank (HUT) indicated that radiation levels near one of the three HUTs were in excess of 1000 mR/hour (maximum - 5000 mR/hour).
However no one other than the RP technician entered the area during the time the door was left unlocke On three previous occasions, one in March, 1987 and twice in October, 1987 a locked HRA door to the bioshield area was defeated due to a plastic shoe cover being put in the doors' self-locking mechanis A notice of violation was issued for the October, 1987 occurrence In addition, violations were cited in September, 1988 and January, 1989 for a number of examples of failure to follow RP procedure Due to the potential safety significance of this issue in that a person could have entered the HRA and receive an uncontrolled exposure, and since the corrective actions for the previous instances of loss of control of HRA doors and failure to follow procedures did not prevent the occurrence of the May 23, 1989 incident, a notice of violation is propose (VIO 272/89-15-09)
LER 89-022; T.S. 3.1.3.2.2a Non-Compliance Due to Personnel Error and Inadequate Administrative Controls; During control rod shutdown bank calibrations, two banks of control rods were withdrawn together, contrary to T.S. and procedural precaution The technicians involved failed to recognize the precautions and requested plant operators to move more than one bank while in Mode 3 (Hot Standby).
Technical Specification 3.1.3.2.2 was only recently revised (effective upon completion of the eighth refueling outage).
However, plant operators on shift were unaware of the amendmen The LER documented that station management has initiated a review of the process by which amendme~ts are promulgate Pending completion of this review and NRC evaluation, this item is unresolved. (UNR 272/89-15-10)
LER 89-023; TS 3.0.4 Non-Compliance Due to Personnel Error;.0.4 requires that entry into an operational condition without satisfying the Limiting Conditions of Operation is prohibite Contrary to procedural precautions, during unit startup activities on June 3, the licensee identified that only one source range channel was operable while in Mode 3 with the reactor trip breakers closed and the control rod drive system capable of rod withdrawa Two channels were required for that conditio The procedural precautions specified that two source range channels be operable prior to energizing the Rod Control System and closing the reactor trip breaker The failure to follow station procedures, as documented in LERs 89-021/022/023, constitute three examples of licensee identified violations of T.S. 6.8.1, which states that written procedures shall be established, implemented and maintaine Licensee corrective actions for multiple previous procedural compliance violations have not been effective in preventing further problems, and therefore, the discretion criteria of 10 CFR.2, Appendix C have not been satisfie These three examples of failure to follow procedures constitute an apparent violation of T.S. 6. (50-272/89-15-09)
LER 89-024; Safety Injection/Reactor Trip During Mode 3 Operation Due to Inadequate Procedures; This event is discussed in Section 2.2.1.B of this repor LER 89-027; Reactor Trip on No. 13 Steam Generator Low-Low Level Due to an Equipment Design Concern; This event is discussed in Section 2.2.1.B of this repor The LER noted that a Supplemental report was not expecte Inspector review of this identified that the same relay on Unit 2 apparently failed on April 11, 1989, resulting in a similar reactor tri The LER documented that the relay was replaced and the previously installed relay will be sent to the vendor for evaluatio The purpose of supplemental reports are to provide information not available when the LER was submitte Results of the relay evaluation may possibly support or contradict the licensee's root cause conclusio For this case in particular, when a recent similar failure occurred on the opposite Unit, a supplemental report should be submitte The licensee agreed to submit a supplemental report when the test results are received from the vendo Unit 2 LER 89-007; T.S. 3.0.3 Entry due to - two steam flow channels for one steam line inoperabl Drifting of the measured main steam line differential pressure is a continuing concern for which licensee investigation is continuin A management meeting was held recently on May 15, 1989 to discuss licensee actions to resolve this issu This issue is being followed by the inspectors as unresolve (50-272/88-17-01)
LER 89-009 and 89-010; ESF actuations containment ventilation isolation due to design and equipment problems; These ESF actuations were caused by the failure of the same plant vent noble gas monitor (2R41C).
The LER's document engineering investigations and resultant planned system modifications to upgrade the radiation monitoring system to prevent recurrence of these problem NRC inspection 50-272/89-10 reviewed the licensee's long term corrective actions in this regard and found them to be acceptable, however timeliness in completion of the actions was stressed with the license LER 89-012; Controlled Shutdown, T.S. Surveillance Non-Compliance Due to Inadequate Procedure; This event is discussed in NRC Special Inspection Reports No. 50-272/89-16; 50-311/89-1 LER 89-013; Manual Reactor Trip - Loss of Five Circulating Water System Circulating Pumps Due to External Causes; This event is discussed in Section 2.2.2.A of this repor Inspector review of the LER identified that the licensee incorrectly stated that the SD valves were lost solely due to an increase in condenser back pressur The LER did not address the immediate partial loss of the
SD system due to the loss of the associated circulator Further, the LER did not address the relay failure which permitted the event to continue due to partial SD operation, and its potential safety impac This was discussed with the licensee, who committed to resubmit the LER with the appropriate informatio The above LERs were reviewed with respect to the requirements of 10 CFR 50.73 and the guidance provided in NUREG 102 In general, the overall quality of the LERs reviewed during this inspection was adequat However, specific deficiencies were noted and communicated to the licensee including inaccurate and incomplete information as provided in Unit 2 LER 89-013 and not planning to submit a supplemental report when pertinent information is anticipated to be received from a vendor (Unit 1 LER 89-027).
Further, the inspector identified that several LERs did not include a complete the assessment of the actual and potential safety consequences and implications of the even Specifically, NUREG 1022 specifies that an assessment of an event under alternative conditioris must be included if the incident would have been more severe under reasonable and credible alternative conditions, such as power-level or operating mod These concerns were brought to the licensee's attention, who stated that a review in this area would be performe The inspector will continue to evaluate the adequacy of LERs during future routine inspection For example LER 272/89-022 includes an analysis regarding withdrRwal of the third most worthy rod, but does not analyze the impact of a luwer boron concentration which is also reasonable and credible condition that should be analyze Further, LER 272/89-021 concludes that the uncontrolled HRA door posed no risk to the health and safety of the public, however the risk to plant workers was not discussed and is obviously the reason for locking HRA'.2 Reference to Open Items The following open items from previous inspections were followed up during this inspection and are tabulated below for cross reference purpose Closed VIO 272/88-14-01 Section 1.
SAFETY ASSESSMENT/QUALITY VERIFICATION (40500, 92702)
10.l Inspection Activity The inspectors reviewed the performance,of the Station Operations Review Committee (SORC) relative to T.S. 6.5.1 requirement In addition, the inspectors reviewed the effectiveness of the licensee's corrective action program relative to 10 CFR 50, Appendix B criteri.2 Inspection Findings The inspector attended Station Operations Review Committee (SORC)
meetings on June 11 and June 1 Technical Specification member attendance requirements were verifie In general the meetings were characterized by frank discussions on the subjects reviewe No deficiencies were identifie This report documents a number of recent licensee identified problems for which previous similar problems were noted and for which corrective actions were not*adequate in preventing recurrenc For example, Section 2.0 of the report discusses unit trips attributed to grass and debris accumulation on CW trash racks and a deficient MSIV closure circuit design which recurred during this inspection period due to inadequate corrective actions for previous similar event Section 4.0 discusses the continued marginal performance of reactor trip breaker UVTAs with respect to meeting the output force measurement acceptance criteria during semiannual preventive maintenance activitie Section 9.0 includes review of LERs which document repeat problems such as failure to follow procedures, missed T.S. surveillances, oxygen ingress to the waste gas system, and RMS d~sign and equipment problems which continue to result in ESF actuation The inspector has observed increased diligence with which the licensee identifies and investigates plant problem Self assessment is considered a licensee strengt However, the licensee 1 s program for correction of self-identified problems to prevent recurrence appears to be wea This is indicated by the number of examples of repeat occurrences listed previousl These conclusions were discussed with station managemen The inspector requested that the licensee review their corrective action program in this regard to determine whether improvements are needed, and document their conclusions along with the violation responses as indicated by the inspection report cover lette The licensee agreed to perform the review and provide the requested respons.
EXIT INTERVIEW (30703)
The inspectors met with Mr. L. Miller and other PSE&G personnel periodically and at the end of the inspection report period to summarize the scope and findings of their inspection activitie Based on Region I review and discussions with PSE&G, it was determined that this report does not contain information subject to 10 CFR 2 restrictions.