IR 05000272/1991002
| ML18095A817 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/06/1991 |
| From: | Eselgroth P, David Silk NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A816 | List: |
| References | |
| 50-272-91-02, 50-272-91-2, 50-311-91-02, 50-311-91-2, NUDOCS 9103270087 | |
| Download: ML18095A817 (7) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION I INSPECTION REPORT FACILITY DOCKET NOS.:
50-272 and 50-311 INSPECTION REPORT NOS.:
50-272 and 50-311/91-02 FACILITY LICENSE NOS.:
DPR-70 and 75 LICENSEE:
Public Service Gas and Electric Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 FACILITY:
Salem Units 1 and 2 INSPECTION DATES:
January 14 - 17, 1991 SUBMITTED BY:
APPROVED BY:
David Silk Senior Operations Engineer, PWR Section eter selgroth, Chief PWR Section, Ope~ations Branch Division of Reactor Safety INSPECTION SUMMARY:
Date AREAS INSPECTED:
Routine, announced inspection of the corrective actions taken to address deficiencies identified during the EOP Team Inspection (Report 50-272 and 50-311/90-80) conducted January 16 - 25, 199 RESULTS:
Of the eight items reviewed by the inspector, three items were close Two additional items can be closed upon the licensee's issuance of an approved administrative procedure governing the writing of the abnormal operating procedures (AOPs).
The remaining three items are open until further corrective action is complete Determination of the progress of correcting AOP deficiencies was not feasible because the new AOPs are in rudimentary stages of developmen During this inspection, an Unresolved Item (91-02-01) was identified pertaining to the EOP maintenance progra The licensee corrected specific NRC identified weaknesses but the corrective actions did not address other EOPs which contained the same weaknesses.
9103270087 910315'
PDR ADOCK 05000272 G
PDR PERSONS CONTACTED
- M. Aldaugh Ed Carter Bob Cornman
- Tom Floyd
- Wayne Grau John Kerin Bill Lowry Mike Morroni
- Joe Varga
- E. Villar
- Fred Wilt see DETAILS
- Denotes those present.at the Exit Meeting held on January 17, 1991 2. 0 REVIEW OF EDP *:-EAM INSPECTION 50-272/90-80 & 50-311/90-80 OPEN ITEMS*
SCOPE The inspection was conducted to determine the adequacy of the licensee's c6rrective actions taken to address the findings of the EDP Team Inspet-
. tion conducted January 16 - 25, 199 To evaluate the licensee's actions, the inspector reviewed EOPs, AOPs, and other supportive dbcumentatio In addition, a plant tour was conducted to check if the identified labeling deficiencies were correcte FINDINGS OPEN (90-80-01):
Resolve fire door automatic closure problem and esta-blish interim compensatory measure The inspector checked with th~ site protection group to verify that the licensee was performing the compensatory measures to which it committe The inspector reviewed documentation of daily inspections and hourly firewatches performed by the nuclear fire.departmen The documentation substantiated the performance of the licensee's compensatory measure The daily inspection is similar to the Technical Specification 18 month surveillance that is performed to check the operability of fire barrier The hourly firewatches are performed due to the Appendix R and Penetration Seal Projects requirement Individuals performing both of these tours are instructed to observe fire doors and ensure they are in the closed position or if they are in need of maintenanc The fire department has a blanket work order to expedite repairs needed by the fire door Also, as part of the compensatory measures, the fire department has disseminated information (via postings and brief articles in a licensee site news-letter) to site personnel to heighten awareness of the importance of the fire door Based on the above information, the licensee is addressing
any immediate safety concern related to open fire door When the Pene-tration Seal Projects are completed in various areas of the plant (some areas will be completed about mid-1991), the hourly firewatches are no longer require According to the licensee, the firewatches will be removed based upon the ventilation condition, door maintenance history for the area and other pertinent fire safety related issue The root cause of the fire door problem is the ventilation syste The unbalanced flow of air through the plant had caused some physical damage to the doors (due to slamming), as well as keeping doors from automati-cally closing and making other doors difficult to open or close (in addition to causing personn~l safety hazards due to some swinging doors).
The ventilation system problem has not been correcte The licensee had tried to correct the ventilation system by balancing the dampers to control air flo However, the air flow through the entire ventilation system is not constan The air intake from the outside is dependent upon temperatur Thus balancing the dampers alone did not produce a permanent effect and did not resolve the root issu The licensee is now in the process of evaluating other factors that would affect air flow prior to balancing the dampers agai Because the root cause of the fire doors has not been resolved this 1tem remains ope CLOSED (90-80-02):
Correct deviation document errors and more fully document deviation justification Review EOPs and correct logic state-ments that have action and decision steps in the wrong sequenc The deviations between the EOPs and the Emergency Response Guidelines (ERGs) that were identified in the report 90-80 were resolved by the license This was confirmed by the inspector investigating the EOP steps in question, the associated ERGs, and the deviation dricumen Step 69 of LOPA-1 now includes the phrase 11 Reset containment spray signal. 11 The inspector noticed, however, that the phrase was not properly located within the ste The EOP coordinator was informed of this error and agreed to correct i LOPA-3 step 16 now contains the corresponding caution from ERG ECA-Step 41 of TRIP-1 (Rev 1), which checks for the existence of a steam generator tube rupture (SGTR), is now at step 32 (Rev 2) to expedite the identification and mitigation of a SGT LOPA-2 step 25.1 now includes checking RCS subcooling when verifying natural circu-latio The inspector checked other EOPs containing steps regarding verifying natural circulatio The majority of these steps also should hav~ directed the operators to check RCS subcooling as per the ERG There was no documentation accounting for these deviations from the ERG The listing below are procedural steps where RCS subcooling should be checked as per the ERG TRIP-2 step 24 TRIP-3 step 2 LOSC-1 step 41 LOSC-2 step 3 SGTR-1 step 4 SGTR-3 step 3 LOCA-2 step 2 * *
Also associated with this open item were EDP formatting deficiencie Action statements located before decision steps were corrected. (i.e.,
"Dump steam using steam dumps 11 preceded "Are steam dumps available?").
The inspector checked the LOCA (1 through 6) and SGTR (1 through 5) EDP series for the incorporation of the steam dump steps, as well as other decision step The decision points and action steps were in proper orde Report 90-80 identified a repeated instance in the SGTR series in which cautions contained actions steps (i.e., the operator is instructed to shift auxiliary feedwater pump suction to its alternate source if a low level alarm on the auxiliary feedwater storage tank is received) which was not in compliance with the Writer 1s Guid Cautions were checked in Revision 2 of the SGTR (1 through 5) and the LOSC (1 and 2) EDP series and none were found to contain action step The issues identified by the inspection team for 90-80 were incorporated into Revision 2 of the Salem EOP Other similar items not identified by the NRC during the EDP inspection were not corrected by the license This demonstrates a weakness in the EDP maintenance program to check and correct deficiencies that are common to other EOP If changes are made to an EDP, the other EOPs are checked by reviewing each step of every procedure by hand to incorporate common change A goal of the program is to acquire the means to make changes automatically that are pertinent to other EOP The EDP coordinator agreed to correct the deficiencies noted by the NRC on this inspectio Based on the licensee 1 s response to previously identified weaknesses this item is considered close OPEN (90-80-03):
Identify and correct labeling deficiencie The inspector, with the assistance of the EDP coordinator, verified that previously identified labeling deficiencies associated with the EOPs, listed in Attachment 2 of Report 90-80, were correcte Several ADP related labeling deficiencies were checked and labels were found to be in place except for valve CV71 located within Panel 311 and the Fire Hazards Book Box in Unit Many of the ADP related labeling problems where the procedure did not match the ADP were not investigated by the inspector because the AOPs are currently being upgrade The AOPs are to be walked down during their final review, and this process should identify and resolve any labeling discrepancie Several control room labeling problems were noted in 90-8 These items are currently being prepared to be prioritized for wor These items were to be included in the Control Room Design Review (CRDR) Projec But, due to limitations of this project, these items will *now be addressed by the Nuclear Department Resource Allocation Project (NDRAP).
Presently, these items are not approved design change Based upon this condition and the status of the AOPs in regards to checking plant labeling, this item will remain ope OPEN (90-80-04):
Perform Verification and Validation walkdowns of AOPs and correct identified deficiencies.
Only several noted deficiencies were corrected by the license The reason that those corrections were made was based upon the operational significance of the deficiency as deemed by the license While reviewing those corrections, the inspector found that one dealt with the resolving of an inescapable loop in a procedure (AOP-ELEC-460/230V-A) and the others corrections switched the order of actions "Trip the RCP 11 and 11Trip the reactor 11 in procedures related to the RCPs (AOP-RCP-2 through 7) to "Trip the reactor 11 firs The remaining deficienc.ies are to be corrected as the AOPs are revise The revised AOPs are presently in the developmental stage The inspector was informed that as the AOPs are being drafted, walkdowns are being performed to validate the procedures and thus identify and correct any noted deficiencie Also, in accordance with a draft writer 1s guide for the AOPs, a final verification and validation (V & V) is *to be performed at the end of the procedure development stages as a final review of the procedure As indicated in a letter dated June 8, 1990, PSE&G has set a
- date of December 1991 to perform a human factors upgrade, including a V and V walkdown of the AOP Given the present state of the AOPs, the inspector did not walkdown any AOPs for V & V purposes to evaluate the effectiveness of the licensee to identify and correct ADP deficiencie This item will.remain ope CLOSED (90-80-05):
Organize EDP table actions to m1n1m1ze required operator movement in the control roo Provide P/A phone capability for the Desk Operator in the simulato The inspector checked the tables of Revision 2 of TRIP-The valves listed were now grouped by system The tables had been re-organized to minimize operator movement in the control room as verified by the inspec""
to The inspector visited the simulator and verified that the licensee has installed a P/A phone similar.to that of the control roo Therefore, based upon these corrections by the licensee this item is close OPEN (90-80-06):
Correct differences between EOP-TRIP-4, 5, and 6 and AD-4 Revise ADP writer's guide to require local versus control room action distinction in AOP In accordance with the licensee's procedure AD-44 section 3.4.4.c, proce-dures are to provide guidance to the operators when exiting a procedur The inspector checked EOP-TRIP-4, 5, and 6 and confirmed that the revised EOPs directed the operator where to go at the end of a procedur The inspector checked the end points of all the EOPs to ensure that the licensee was consistent in all procedure Only EDP LOSC-2 states 11 End of Procedure 11 without providing further direction for the. operato This again demonstrates a weakness in the EDP program to correct common deficiencies among the EOP In regards to the AOPs not distinguishing between remote and local opera-tions, the draft of the AOPs 1 writers guide does contain directions to
specify local actions and locations of equipmen But, due to the fact
- that an approved AOPs 1 writers guide has not been issued, the inspector can not close this ite CLOSED (90-80-07):
Develop a formal and objective means to d~termine training required on EDP revision Revise AD-44 to require immediate EDP changes to be made within two week The revised AD-44 section 3.4 states the type of training required for various types of EDP change There are three basic levels of training corresponding to EOPs change Information directives, shift briefings, or simulator sessions can be used to train operators dependent upon the significance of the EDP chang Also; AD-44 section 3.1.7 states that the EDP coordinator shall revise the EOPs within two weeks if an immediate change is require One EDP change was implemented since the revision of AD-4 The change was initiated on 11/26/90 and was implemented on 12/12/9 This exceeded the two weeks by two days, but demonstrates the intent of the licensee to change EOPs in a timely manne Based on the changes to AD-44 to address NRC EDP inspection concerns; this item is close OPEN (90-80-08):
Revise AD-44 and AD-2 to require in-plant walkdowns of both EOPs and AOP The revised AD-44 section 2.4 addresses the V and V process for the EOPs which includes in-plant walkdowns of the EOP The draft writer's guide for the AOPs, which parallels the writer's guide for the EOPs, does include the walkdown of the AOP But due to the draft status of the AOPs writer's guide, thls item will remain open until an approved procedure is issue.0 CONCLUSIONS Items 2, 5, and 7 are considered ~losed. Items 6 and 8 can be closed upon the issuance of a facility approved procedure (ADP writer's guide).
Items 1, 3, and 4 will remain open until further licensee corrective action is complete There is a problem in the EDP maintenance program regarding the identifi-cation and correction of common deficiencies in the EOPs as noted in paragraphs under items 90-80-02 and 06 abov The absence of checking RCS subcooling during natural circulation verification and not providing specific guidance at the end of LOSC~2 are examples of such weaknesse AD-44 section 3.1.3.a addresses EDP changes that affect more than one EDP but is not being fully implemented by the license Based upon the licensee not performing comprehensive corrective actions regarding samples of NRC identified weaknesses, this problem is considered Unresolved (272 and 377/91-02-01).
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7 EXIT MEETING At the conclusion of the site inspection, on January 17, 1990, an exit meeting was held with the licensee's representatives (noted in Paragraph l~O) to discuss the scope and findings as detailed in the repor Written material was not provided to the licensee at any time during this inspection by the inspecto Based on the NRC Region I review of this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.