IR 05000272/1990008
| ML18095A240 | |
| Person / Time | |
|---|---|
| Site: | Salem |
| Issue date: | 05/15/1990 |
| From: | Anderson C, Della Greca A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A239 | List: |
| References | |
| 50-272-90-08, 50-272-90-8, 50-311-90-08, 50-311-90-8, NUDOCS 9006050080 | |
| Download: ML18095A240 (6) | |
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Report No Docket No License No Licensee:
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/90-08 50-311/90-08 50-272 50-311 DPR-70 DPR-75 Public Service Electric and Gas Company 80 Park Plaza - 17C Newark, New Jersey Facility Name:
Salem Generating Station, Units 1 and 2 Inspection at:
Hancocks Bridge, New Jersey Inspection Dates:
February 26 - March 2, 1990 Inspector:
Approved by:
fi. rt. j 'o.e~,J~
A. L. Della Greff. Sr. Reactor Engineer, Plant Systems Section, EB, DRS c£~
C. J. Anderson, Chief, Plant Systems Section, Engineering Branch, DRS s-A~ 1~-0 Date Inspection Summary:
Inspection on February 26 - March 2, 1990 (Inspection Report Nos. 50-272/90-08 and 50-311/90-08)
Areas Inspected:
Announced inspection by regional personnel to review the status of previously identified open items and to determine the adequacy of the licensee's actions to resolve the Results:
The inspector determined that the licensee adequately addressed eight of the 16 open items reviewe Resolution of the remaining issues is either incomplete or inadequate for closur A non-cited violation was identified.
9006050080 900524 PDR ADOCK 05000272 Q
- DETAILS 1.0 Persons Contacted 1.1 Public Service Electric & Gas Company R. Bashall, Systems Analysis Supervisor
- A. Blum, Program Analysis Supervisor
- M. L. Bursztein, Nuclear Electrical Engineering Manager D. Dodson, Principal Engineer ~ Licensing P. O'Donnell, I&C Supervisor
- F. F. Pla, Lead Designer - Engineering
- D. A. Smith, Station Licensing Engineer
- R. J. Smith, Equipment Qualification Engineer 1.2 Proto - Power E. R. DeWeese, Staff Engineer J. G. Fougere, Engineer
- Denotes personnel present at the exit meeting of March 2, 1990 2.0 Status of Previously 1dentified Items The purpose of the inspection was to review the status of previously identified concerns and to determine the adequacy of the licensee's corrective actions in resolving each issu.1 (Closed) Unresolved Items (50-272/89-06-01 and 50-311/89-05-01) pertaining to the installed configuration of the Victoreen Radiation Monito During a 1986 inspection, the NRC reviewed the qualification documents for the BIW, XLPE, insulated coaxial cable used with the Victoreen high range radiation m.onito Since the package did not contain insulation resistance data, the package was reviewed again in April 198 The insulation resistance and installation method of this cable is very critical when the cable is used with the radiation monitor because of the extremely low signal level The 1989 inspection could not ascertain the installation configuration of the monitor lnd cable because of a lack of documentatio~ in the qualification package and because of the instrument's inaccessibilit During the current inspection, the documents and photographs furnished by the licensee confirmed that the installation method used at the Salem station conformed with one of the methods used by Victoreen to qualify the radiation monito Accordingly, the original questions raised by the inspector regarding the installation are resolved and the items are close However, during this inspection it was noted that the junction box and flexible conduit used at the interface with the radiation monitor are not moisture proo Therefore, the adequacy of the cable was questioned again. This issue is addre5sed further in section 3.0 of this repor.
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2.2 (Closed) Deviation Items No. 50-272/89-13-01 & 50-311/89-12-01 regarding redundancy requirements for Hot Leg Water Temperatur The licensee considers the hot leg water temperature to be a type A variable under Regulatory Guide (RG) 1.9 However, the May 1989 review of this variable revealed that the design did not include redundant instruments as recommended by RG 1.9 In response to the Notice of Deviation issued, the licensee explained that the monitoring method used at the Salem plants conforms with Alternative No. 3 addressed by the NRC in its letter, dated November 18, 1982, to the *
Westinghouse Owners Grou This alternative, which proposes measuring hot leg water temperature on a system basis, was considered to achieve reliable temperature indication by the. NRC, as determined by additional documentation provided by the licensee, and to meet the redundancy criteria of RG 1.9 In view of the above, the deviation is withdrawn and the issue is close.3 (Open) Deviation Items No. 50-272/89-13-02 & 50-311/89-12-02 relative to the lack of redundant instrumentation for Effluent Radioactivity - Noble Gas Exhaus The licensee classifies the effluent radioactivity monitoring for noble gas exhaust as a type A variabl However, the licensee did not provide redundant Class lE instrumentation in accordance with the recommendations of RG 1.97 for type A variable Following the issuance of the NRC's Notice of Deviation, the licensee reviewed the basis for its classification of this variable and determined that the instruments had been added to the type A list for the sole purpose of providing redundant indication for Steam Generator Tube Ruptur Therefore, the licensee concluded that the variable need not be classified as type Regulatory Guide 1.97 classifies the monitoring of gas effluents as type C or E and Category 2 or 3 variable for which no redundancy is require The licensee plans to revise its FSAR accordingl The licensee's resolution of this issue is acceptabl However, the item remains open pending the NRC's review of the revised FSA.4 (Closed) Deviation,Items No. 50-272/89-13-03 & 50-311/89-12-03 pertaining to redundancy requirements for Auxiliary Feedwater Flo The licensee considers the auxiliary feedwater flow to be a type A variabl However, contrary to the RG 1.97 recommendations, the design did not include redundant instrument loop In response to the Notice of Deviation issued by the NRC, the licensee reviewed its design and determined that wide range level instrumentation provides indirect indication for this variabl The licensee also provided documentation (pages II.E-3 and 4 of SER Supplement No. 4, dated April 1980) that the NRC, in conjunction with its review of NUREG-0578, paragraph 2.1.7.b, requirements had accepted steam generator level as back up instrumentation for auxiliary feedwater flo.. *
Upon review of the documentation package provided by the licensee, the inspector concurs that the level instrumentation provides adequate back up indication of auxiliary feedwater flow and that it meets the intent of RG 1.9 Therefore, the issue regarding redundancy of the subject variable is close.5 (Open) Deviation Items No. 50-272/89-13-04 & 50-311/89-12-04 regarding the lack of redundancy for Steam Generator Radiation monitoring equipmen The licensee classifies steam generator radiation to be a type A variabl Therefore, in accordance with the position taken in the SER, the licensee provided Class lE steam line radiation monitor To comply with the redundancy recommenda-tions of RG 1.97, the licensee provided a recorder which uses a redundant power supply, but the same signals used for primary indication of the variabl During the May 1989 inspection, the NRC identified several single failures which would impair both redundant channels and, thus, prevent the post-accident availability of this variable to the operato In their response to the Notice of Deviation, the licensee concurred with the, inspector's evaluation and recognized that some modifications to the monitoring were require During the current inspection, the licensee indicated that the purpose of the main steam line radiation monitors was that of detecting and identifying steam generator tube rupture Therefore, it proposed to use the non safety-related condenser air ejector exhaust radiation monitor and the safety-related steam generator's narrow and wide range level instruments to provide redundant indication for the subject variabl The licensee based its argument on the fact that functional redundancy was previously accepted by the NRC, as in the case of the auxiliary feedwater flow and steam generator level discussed in Par. 2.4, abov The inspector agreed that the steam generator level would respond to a tube ruptur However, he observed that the detection of the level change would largely depend upon the size of the leak and the speed of response of the feedwater contro In addition, no direct relationship exists between radiation activity levels in the main steam line and water level in the steam generato With respect to the radiation monitor in the condenser air ejector exhaust, it does not, by itself, identify the source of radiation (location of tube rupture).
In addition, the instrument is not safety related. Therefore, it cannot be depended upon to satisfy detection requirements,* following an acciden Therefore, since steam generator radiation is classified as a type A variable, the licensee's proposed resolution to the redundancy question is not acceptable. This issue remains open pending further review by the license.6 (Open) Unresolved Items No. 50-272/89-13-05 & 50-311/89-12-05 relative to the use of resistors as circuit isolator During the May 1988 inspection, a review of wiring diagrams revealed that the licensee used resistor networks to isolate Class 1 instrument signals from the class 2 plant compute Since resistors generally are not considered to be effective isolators against unwanted signals external to the safety related circuit, the inspector asked the licensee to evaluate its design and ensure that the single failure criterion had not been inadvertently violate *
During the current inspection the licensee provided documentation relating to the design of the plant computer and its interfaces with incoming signal Evaluation of the documentation provided indicates that the computer design precludes normal feedback of signals to the safety-related instrument circuit Confirming its letter of September 5, 1989 to the NRC, the licensee indicated that it was currently evaluating the seismic capability of the computer interface racks and integral component This analysis would ensure that the requirements of paragraph 4.7.2 of IEEE 279-1971 with respect to short circuits, open circuits, and application of the maximum AC or DC potehtial would be satisfie To properly address the inspector's concern regarding inadvertent or accidental feedback of signals from the computer to the safety related circuits, the analysis should evaluate not only the potential of feedback as a result of credible faults occurring in the termination areas, but also the capability of applicable interfacing components (e.g. computer cards) of isolating faults affecting other areas of the plant computer (e.g. power supplies).
This item remains open pending the licensee's completion of the above evaluation and the NRC 1 s review of its result.7 (Open) Unresolved Items No. 50-272/89-13-07 & 50-311/89-12-07 regarding separation criteria used in process racks and multiplex system During the May 1989 inspection, the NRC inspector observed a Deficiency Evaluation Report relating to potential separation and isolation problems existing in the process racks and in the SPDS computer's multiplexer During the subject inspec+ion, this issue was again discussed with the license The inspector, thus, determined that the separation concerns were being evaluated by an engineering contracto In support of their statement, the licensee provided a preliminary report, prepared by their contractor, which adqresses isolation and separation requirements and provides recommendations to the licensee as to the resolution of the discrepancies observed. *The report is under review by the license In view of the preliminary nature of the report and proposed corrective actions, this issue remains open pendin9 further review by the NR.8 (Closed) Unresolved Items No. 50-272/89-13-08 & 50-311/89-12-08 relative to the updating of the FSA During the May 1989 inspection, the NRC identified various discrepancies between the FSAR and the licensee's description of its compliance with the RG 1.97 recommendation The licensee agreed that an updating of the FSAR was needed and committed to the required revision As a follow up action, the NRC inspector asked the licensee for an update on the status of the FSAR revision and determined that such revision is currently scheduled for November 199 In view of the above, this item is close ' *
3.0 Qualification of BIW Cable As discussed in paragraph 2.1 above, the installation of the Victoreen high range radiation monitor was evaluated to close a previously identified NRC concer During the course of this review, the inspector noted that the flexible conduit and junction box at the cable/monitor interface are not moisture proo The capability of the cable to remain impermeable to the LOCA environment is important for the qualification of the Victoreen instrumen This was proved by the failures experienced by the manufacturer during the qualification test Potential cracking of the.cable jacket led the manufacturer to seal the cable from the environment of the test chambe This test method, identified as alternative No. 3 in the qualification report of the Victoreen radiation monitor, leaves the burden on the user to ensure that the cable is qualified for the specific applicatio Since the installation method used by the licensee_did not seal the cable from the containment environment, the qualification report was reviewed to determine the capability of the cable jacket to prevent moisture from entering the connector are Evaluation of the qualification package for the BIW cable used at the Salem station (XLPE insulated, CSPE jacketed coaxial cable) shows adequate qualification of the insulation syste The report, however, does not specifically address qualification levels of the jacket materia In response to the NRC concerns, the licensee conducted a study on the qualifica-tion levels of the cabl~ jacketing material and, following the inspection, on March 13, 1990, they submitted an analysis which reduces the qualified life of the cable from 40 years to 18.8 year For conservatism, the analysis recommends a further reduction of the qualified life to 15 year *
The inadequacy of the docum~ntation addressing qualification of the BIW cable for the specific application constitutes a violation of lOCFR 50.49, paragraphs (f) and (j) which require that (1) each item of electrical equipment be qualified by testing and/or analysis of identical or similar equipment; and (2) a record of the qualification shall be maintained in an auditable form to permit verifi-cation that each item important to safety is qualified and that the equipment meets the specified performance requirements under the postulated environmental condition In accordance with the NRC Enforcement Policy, lOCFR Part 2, Appendix C the violation is of severity level V (Supplement I).
However, because the safety significance of the violation is minor, corrective actions were initiated prior to the end of the inspection period, and the fact that the criteria specified in Section V.A of lOCFR Part 2, Appendix C, were satisfied, the violation is not being cited. (50-272/90-08-01; 50-311/90-08-01)
4.0 Exit Meeting The inspector met with the licensee 1 s personnel described in Section 1.0 of this report at the conclusion of the inspection on March 2, 199 At that time, the scope of the inspection and the inspection results were summarize At no time, during the inspection, was written material given to the licensee.