IR 05000272/1995019
| ML18101B134 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/13/1995 |
| From: | Larry Nicholson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18101B133 | List: |
| References | |
| 50-272-95-19, 50-311-95-19, NUDOCS 9512180324 | |
| Download: ML18101B134 (23) | |
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Report No License No Licensee:
Facility:
Dates:
Inspectors:
Approved:
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/95-19 50-311/95-19 DPR-7 DPR-75 Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Salem Nuclear Generating Station October 15, 1995 - November 18, 1995 C. S. Marschall, Senior Resident Inspector J. G. Schoppy, Resident Inspector T. H. Fish, Resident Inspector J. D. Noggle, Senior Radiation Specialist ( j/Pt_
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Nie o son, C ie Branch 3 Inspection Summary:
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This inspection report documents inspect i o.ns to assure public hea-1 th-and * "
safety du*ring day and back shjft hours of station actjv.it,ies; Jncludfog: -* --- '.:.. * --**
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operations, radiological controls, maintenance, surveillances, security, engineering, technical support, safety assessment and quality verificatio The Executive Summary delineates the inspection findings and conclusions.
9512180324 951213 PDR ADOCK 05000272 G
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EXECUTIVE SUMMARY Salem Inspection Reports 50-272/95-19; 50-311/95-19 October 15, 1995 - November 18, 1995 OPERATIONS (Module 71707) The inspectors concluded that control operators appropriately confirmed the validity of the Salem Unit 2 Fuel Handling Ventilation (FHV) low differential pressure alarm. Although senior operators initially did not adequately challenge the engineers to resolve the
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implications of the FHV low differential pressure alarm, in response to the inspectors questions, operations managers challenged engineering and initiated measures to insure FHV remained operable during fuel handling activitie * ~~
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The inspectors determined poor planning led to untimely implementatton of the~ ~
winterization plan, to a potential adverse impact on Unit 1 spent fuel pool cooling, and to unnecessarily extending the outage of an off-site power sourc Planning personnel aggressively-attacked these issues and improved planning performanc Improvements included an increased focus on pre-job planning, schedule adherence, contingency planning and shutdown risk assessmen Improved planning and schedule adherence resulted in a net safety gain due to reduced equipment outage time and risk-managed outage window At times, control room operators and shift supervisors remained informed and protective of key plant equipment required to perform.safety function Operations demonstrated good risk perspective in challenging the planning
.process to minimize conditions that resulted in the station having an
- emergency.diesel unavailable concurrent with a single source of off-site powe Operations management ini t i.ated and successfully conducted contingency plan drills for Unit 2 loss of shutdown cooling and Unit 1 loss of normal diesel fuel oil transfer capabilit *
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Poor communication.and control resulted in an undesired serv}ce* water -pressur switch isolation, and operation of a positive displacement charging pump at low speed ~ith the reactor coolant system depressurized. Although the miscommunications resulted in no safety consequence, operators failed to effectively control and maintain plant equipmen "1:*
At other times, operators did not effectively ccmtrol plant activities... The inspectors noted several examples of poor work control that resulted in maintenance supervisors receiving authorization to begin work before operators established adequate taggin The inspectors also noted that because the maintenance supervisors appropriately verified their tagouts, they detected the deficient tagging conditions, and thus prevented possible injury to
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MAINTENANCE/SURVEILLANCE (Modules 61726, 62703) The NRC identified that technicians did not effectively use a spent fuel pit pump coupling alignment procedur On another occasion, maintenance technicians strictly controlled and precisely documented emergency di'esel ~generator service water check valve maintenanc Over the period, maintenance showed continuing improvement in attention to detail, interface with operations, supervisor oversight, and procedure usag Mechanical maintenance personnel did not practice adequate foreign material exclusion when working on main steam isolation valve (MSIV) hydraulic actuators, as demonstrated by the debris maintenance personnel discovered in the no. 13 MSIV actuator hydraulic oil reservoir. Maintenance staff had a reasonable explanation for how the debris intrusion occurred. They -.
appropriately inspected all MSIV actuatorjreservoirs and, based on the inspection results, scheduled the reservo,rs to be drained and flushe Salem staff attempts to correct tagging problems have not been effective as demonstrated by operators tagging the wrong component during a switchyard evolutio The inspectors concluded that operators did not follow procedure requirements;- ttowever, this is not a cited violation due.to previous enforcement action taken for the same problem, and PSE&G commitment to maintain both units shutdown to address such long-standing issues prior to restar ENGINEERING (Module 37551) System engineers appropriately translated a concern with bolt wastage in the no. 11 Component Cooling Heat Exchanger (CCHX) to an operability question for the no. 21 CCHX and no.. 22 CCH Based on inspection res._u,lts of nos. 21 and 22 CCHXs, engineers appropriately determined Unit 2 tCHXs operabl '
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PLANT SUPPORT (Module 71707)
The NRC observed-several.poor radiolOgical*
worker practice In addition, the licensee attri.buted.a number-:of :recent radiologically"occurrence reports (RORs) to personnel errors' and ~poor practices.. These practices resulted in no significant radiation exposure or personal contamination to involved individuals. Radiation Protection (RP)
supervisors and technicians responded promptly and appropriately to add~ess- **
these issues. Managers discussed this recent trend in poor radiological worker practices in a daily management meeting and indicated that a more programmatic concern existed. Radiation Protection management provided timely, well-documented ROR root cause trending and trackin An announced inspection of the solid radwaste/transportation program was conducted by Mr. J. Noggle at the Salem Nuclear Generating Station on October 23 - 27, 1995. Areas reviewed included management oversight, training, radwaste processing, radwaste sampling, radioactive material shipping, and onsite radwaste storag The solid radwaste/transportation program was determined to be strong. A reduction in the independent surveillance of radioactive shipm~~ts was note The licensee reinstated the review of all reportable""QUantify shipment No violations of regulatory requirements were identified.
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Security force members (SFMs) did not pursue repair of degraded assessment aids in a timely manner. Security force acceptance of this condition represented a security force "work-around."
SFMs adequately compensated for the degraded equipmen The inspectors determined the degraded assessment aids presented a potential challenge to SFM performanc Security management initiated work orders to correct the deficiencie SAFETY ASSESSMENT AND QUALITY VERIFICATION The Station Operations Review Committee (SORC) demonstrated a good questioning attitude and safety perspective involving several plant procedures and equipment modification In response to a missing service w~ter pressure switch and three mispositioned
- service wa~er and fuel handling ventilation instrument valves, Salem managers appropriately determined that*:tj)e-tprocS:ss for insuring proper alignment of instrument valves did not effecT1velY control or document valve positio Salem managers took appropriate action to verify instrument valve position for the missing pressure switc In addition, they initiated action to improve labeling and procedures to control instrument valve alignments. System engineering managers found that system engineers identified the missing pressure switch in August 1995 and did not appropriately document it or otherwise communicate it to the operators. The system_engin~ering managers reasonably attributed the omission to personnel error,* and.t'responded.
appropriatel As a result of th~ lack of discussion or preparation for a coastal storm on November 14, inspectors concluded that Salem management did not have an effective means to in$ure per~onnel initiated site-wide preparations for severe weathe :... *
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TABLE OF CONTENTS EXECUTIVE SUMMARY.
TABLE OF CONTENTS.
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~. Summary of Operations........... Fuel Handling Ventilation {FHV) Operability. Planning Performance............... Communication and Control............ Work Control
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.. Safety Focus
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MAINTENANCE AND SURVEILLANCE Maintenance......
.... Control of Maintenance.... Foreign Material Exclusion {FME) Tagging............. Surveillance*..........
ENGINEERING....... ~....... Component Cooling Heat Exchangers.
PLANT SUPPORT.............. Radiological Work Practices....
. Security.... _.*,.......
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5.0. SAFETY ASSESSMENT AND QUALITY VERIFICATION...*
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9 Management Oversight.....
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5. 2 Service Water Pressure Switches....
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9 P~eparation for Severe Weather
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lb REVIEW OF REPORTS 7. 0.. EXJJ:.INTERVIEWS/MEETINGS
..... Resident Exit Meeting.
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ATTACHMENT I - RADWASTE/TRANSPORTATION INSPECTION v
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DETAILS OPERATIONS The inspectors verified that Public Service Electric and Gas (PSE&G) operated the facilities safely and in conformance with regulatory requirement The inspectors evaluated PSE&G's management control by dir~ct *observation of activities, tours of the facilities, interviews and discussions with personnel, independent verification *of safety system status and Technical Specification compliance, and review of facility record The inspectors performed normal and back-shift *inspections, including 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> of deep back-shift inspection.1 Summary of Operations Unit 1 remained defueled for the duration of the inspection perio Unit 2 operators maintained Unit 2 in mode 5 (Cold Shutdown) for the duration of the perio.2 Fuel Handling Ventilation (FHV) Operability On October 31, Salem staff discovered that the low differential pressure (dp)
alarm switch for Unit 2 FHV did not function properly. The basis for Technical Specification 3.9.12 states that operation of FHV ensures mitigation of fuel handling accidents, as discussed in the UFSAR accident analysi The action statement for TS 3.9.12 states that with-FHV inoperable, stop all activjties in the fuel handling building involving fuel movement or movement of loads over the spent fuel poo The surveillance requirements of TS 4.9.12 require operators to dem6nstrate the FHV capa6ilitY to develop an air pressure*
drop of 0.125 inches water gauge below atmospheric*:pressure~~> _
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After implementation of a design change package,- operators re~~i~ed ~u~erous FHV low differential pressure alarm Plant staff determined that personnel simultaneously opening the inner and outer doors between the fuel handling building and the auxiliary building, and gusts of wind from the northwest appeared to cause the low dp alarm Engineering staff verified that FHV continued to function properly. Other members of the plant staff prepared to resume spent fuel pool re-racking activitie The inspectors noted that the nuclear control operato*rs had confirmed that the FHV low differential pressure alarm functioned properl An* engineering memo that evaluated the FHV ability to meet it' s design function stated that the FHV system remained operable under short duration, spurious alarm condition The memo further stated that they had not determined the cause of the spurious alarm Based on available information, the inspectors could not determine if the alarms reflected an inoperable FHV syste The inspectors also noted that the senior operators had not challenged the unsupported engineering conclusion that FHV remained operable. Operations managers reviewed the engineering memo~ met with engineering to discuss the cause of the alarms, and concluded that the facts did not support FHV operability for alarm conditions.
In response, engineers provided instrumentation to measure the actual differential pressure between the surface of the spent fuel pool (as opposed to the instrument rack) and atmospheric pressure. Engineers initiated efforts to relocate the external sensor point for atmospheric pressure to reduce its susceptibility to wind gusting. The operations manager requested that engineering initiate a procedure to provide control of the doors between the fuel handling building a_nd the auxiliary building to insure that pl~nt personnel opened no more than one door at a time during re-racking activitie The inspectors concluded that nuclear control operators appropriately confirmed the validity of the Salem Unit 2 Fuel*Han~Ji~g Ventilation low differential pressure al arm. Although senior operators*_,tncittally did not adequately challenge the engineers to resolve the implications of the FHV low differential pressure alarm, in response to the inspectors questions, operations managers challenged engineering and initiated measures to insure FHV remained operable during fuel handling *activitie.3 Planning Performance The inspector noted several plann.ing shortcomings, however, the Planning Department and Salem statiDn irf'general, continued to aggressively attack*
these issues and improve planning performanc Planning shortcomings included failure to timely implement the winterization plan, potential adverse impact on spent fuel pool cooling, and extended offsite power source outage duratio The inspector observed an increased focus.on pre-job planning, schedule adherence, contingency planning, and shutdown risk assessmen The inspector noted, however, that improved planning and schedule adherence during_ the Jnspection period resulted in a net safety gain due to reduced equipment outage time and risk-managed outage window I
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Salem organization failed to properly pla*n.cald::*wealherYP-~otectfvi~~~-a~ure Approxim~tely.80 man-months of -winterization work -disappeared fr~oin :the
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planning schedule from May 1995 to October 1995. Consequently, maintenance and Engineering hastily implemented procedures and initiated design changes in a last-minute attempt to fulfill this nee On *November 5, 1995, Planning scheduled component cooling water (CCW) valve maintenance that required isolation of the one available source of component cooling to the spent fuel pool (SFP) heat exchange Fortunately, the nuclear shift supervisor recognized the impact on SFP cooling and did not authorize the scheduled maintenanc On November 7, 1995, operations tagged no. 14 station power transformer (SPT) and placed Unit 1 in a single source of offsite power conditio Lack of a focused maintenance plan resulted in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay prior to no. 14 SPT work commencemen *
Management placed increased emphasis on proper planning, schedule adherence, and shutdown risk minimizatio The inspector noted improved communication and coordination between operations, maintenance, engineering and plannin Mechanical maintenance, in particular, regularly achieved 100% schedule adherence.
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3 Co11DDunication and Control The inspector observed several exa!J1ples of poor operations communication and control. Although the miscommunications resulted in no safety consequence, operators failed to effectively control and maintain plant equipmen Operations wrote condition reports to evaluate the occurrences relative to equipment and personnel,performanc On October 23, 1995, operations found no. 12 service water pump low flow differential pressure (d/p) switch isolated. This d/p switch affected the n service water pump auto-start feature on low service water header pressur The Senior Nuclear Shift Supervisor decided* to maintain the switch* isolate On October 25, operations attempted to unisolate the pressure switc On Novefuber3, operations found the pressure switch isolated again. Operations discovered that on October 24, another operating shift u~isolated the pressure switc On October 25, the equipment operator actually isolated the switch again vice unisolating it as operations desire.
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On November 4, 1995, operations secured the no. 23 charging pump following the report of "banging noises" when operations placed the pump in servic The~
Maintenance Supervisor advised the operating shift that the pump should not be operated at low speed with the reactor coolant system depressurize Operations maintained the pump "available"-; bu'f not "operable." Contrary to the above direction, on November 6, the operating shift.proceeded to perform a
"break-in" run on the pump and placed the pump in service at low speed. A work control center (WCC) Nuclear Shift Supervisor (NSS), upon hearing of the
"break-in" run, proceeded to the pum The WCC NSS heard a loud banging noise at the pump and.requested the shift remove the pump from service. Maintenance found no obvious pump damag Operations requested that **engineering fully eva 1 uate potent i a 1 pump damage and provide J imit i ng ot>:e~C1:~tng p~~~meters * Work Control
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The inspectors noted sever a 1 examp 1 es of poor work contra 1. that res.ulted in maintenance supervisors receiving authorization to begin work before operators established adequate taggin On October 24, a work control supervisor issued a work order for electrical maintenance personnel to repair a vent~lation dampe Subsequently, when the electrical maintenance job supervisor attempted to verify tagging boundaries for the repair he discovered that operators had not yet hung any tags for the jo He reported the discrepancy t~ the work control supervisor, who subsequently rescheduled the repai Similarly, on November 1, a mechanical maintenance supervisor received a work order to inspect the fan belts of a ventilation exhaust fa When he went to the work control center to verify tagging boundaries he learned that the fan was still in servic The job supervisor informed the work control center supervisor that the tagout was inadequate, and postponed the inspection.
- The inspectors concluded these examples highlighted weaknesses in the work control proces In the example of the damper repair, the work control supervisor performed an inadequate review of the scheduling and tagging information available on the work order. Regarding the fan belt inspection, operators had installed an alternate power supply jumper _for the fan without performing an adequate review of related tagging requests and work order The inspectors also noted that because maintenance supervisors appropriately verified their tagouts, they detected the deficient tagging conditions, and thus prevented possible injury to maintenance personne.6 Safety Focus Control room operators and shift supervisors remained informed and protective of plant equipment required to perform key safety functions. Operations management demonstrated good risk perspective in **ciiallenging *the planning process to minimize emergency diesel unavailability and single source of off-site power conditions. Operations management initiated and successfully conducted contingency plan drills for Unit 2 loss of shutdown cooling and Unit I loss of normal diesel fuel oil transfer capabilit.0 MAINTENANCE AND SURVEILLANCE Maintenance
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The inspectors observed portions of the following safety-related maintenance to learn if the licens~e conducted the activities in accordance with approved procedures, Technical Specifications, and appropriate industrial codes~and __.
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The inspector observed portions of the following activities:. __ -.
Unit Salem I
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Salem I Salem I Salem I Salem I Salem 2 Work Order(WO) or Design Change Package (DCPl WO 940811077 WO 95I027199 DCP IEC332I WO 950305I24 WO 951105007 DCP 2EC-3224 Description Piping replacement for service water intake bay no. 3.
Component cooling spent fuel pit heat exchanger inlet gate valve packing adjustmen IA EDG intake and exhaust modifications IA EDG lube oil pump repair IA vi ta 1 bus breaker....cubicle
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maintenance Unit 2 spent fuel pool re-rac.......,..._
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The inspectors observed that the plant staff performed the maintenance effectively within the requirements of the station maintenance progra.2 Control of Maintenance The inspector observed mixed performance in the control of maintenanc The inspector determined that technicians did not effectively use a spe~t fuel pit (SFP) pump coupling alignment procedur On another occasion, maintenance technicians strictly controlled and precisely documented emergency diesel generator service water check valve maintenanc Over the period, the inspector noted an overall improvement in attention to detail, interf~ce with operations, supervisor oversight, and procedure usag *- *~
On October 18, 1995, the inspector obseJW;Qd-_.technicians preparing to perform a coupling alignment on no. 21 SFP pum Technicians did not use SC.MD-EU.ZZ-0002, Coupling Alignment, to control the activity though preparatory steps taken are detailed in the alignment procedur The workers did not use the procedure to control the activity. Failure to implement the procedure is not a cited violation due to previous enforcement action taken for this same problem, and PSE&G commitment to maintain units shutdown to address such long-standing issues prior to restart. Following inspector questioning, maintenance supervisors conducted_an objective self-assessment of this activity and determined that the technicians should have entered the coupling alignment procedure prior to commencing wor Maintenance management provided the technician the opportunity to relay lessons learned to the maintenance departmen On October 30, 1995, the inspector observed contractors engaged in emergency "'-._
diesel generator service water check_ valve maintenance. _ The task involved three check valves and three separate work packages with each *valve-in a different state of repair. The inspector_ noted that-the.. contractor pre-bri efed the work, completed required per_gui sites;~ performed. work :*act i vfti es as detailed in the work package and maintairied the procedures up to dat Additionally, the contractor exhibited good knowledge* of plant conditions, including potential impact of his work on plant safety status, and fully informed operations of his activities. The supervisor made frequent visits to the job site and provided close oversight of the maintenanc.3 Foreign Material Exclusion (FME)
Mechanical maintenance personnel did not practice adequate FME when working on main steam isolation valve (MSIV) hydraulic actuators, as demonstrated by the debris maintenance personnel discovered in the no. 13 MSIV actuator hydraulic oil reservoi On October 26, during vendor disassembly of the hydraulic actuator for the n MSIV, a mechanical maintenance supervisor noted a small piece of rolled up cardboard in the hydraulic actuator oi 1 reservoir*:***"" The purpose of the actuator is to stroke the valve open and closed for' test purposes; it does not close the MSIV in accident conditions. The supervisor immediately notified the mechanical maintenance supervisor of the debri *
The mechanical maintenance manager formed a team to determine how the foreign material intrusion occurre The team reviewed all work since 1990 that involved the actuator and did not find.anything significant that could explain the cardboard intrusion. The team believed a mechanic could have rolled the cardboard into a makeshift dipstick, and then stuck it into the reservoir fill hole to determine whether level was at or near full capacity. The mechanic then could have accidently dropped the tube into the oil reservoirj,and not reported i Because of the debris in. the no. 13 actuator, the manager initiated inspections of all other*MSIV actuator reservoirs. These inspections yielded harmless results: maintenance personnel discovered a small piece of tape, a wood sliver, and minor amounts of sedimen Work requests - required to be completed before plant start up - were initiated to drain and flush the hydraulic system for all actuators. The manager also reviewed the matter with all maintenance personnel and reemphasized the importance of good FME practice *
The inspectors concluded that the maintenance staff had a reasonable explanation for how the debris intrusion occurre The inspectors determined that maintenance personnel appropriately inspected all actuator reservoirs, and scheduled the reservoirs to.be drained and flushe.4 Tagging Salem staff attempts to correct tagging problems have not been effective as demonstrated by operators tagging the wrong component during a switchyard evolutio On November 3, operators on night shift closed and tagged the wrong 13 KV grounding switc The correct switch was the ground for.no. 14 station power transformer (SPT).
Instead, an operator closed and tagged the grounding switch for bus section C-The alpha-numeric identifier of the ground switches differed by one character: 3JlYDBSC80 for no. 14 SPT ground switch vs. 3JlYDBSCD80 for the C-D bus ground switch. Since the C-D bus section -was inside the tagging boundary (i.e., deenergized), no electrical transient occurred when the operator closed the wrong switc The senior reactor operator supervising the evolution did not recognize the tagging erro The operator who performed the second verification also failed to recognize the erro On day shift, a mechanical maintenance supervisor walked down the tagout before his crew performed maintenanc He, too, failed to detect the error. Later, an electrical maintenance supervisor walked down the tagout in preparation for his wor He detected the error, and reported it to the
senior nuclear shift supervisor (SNSS).
The SNSS stopped work associated with the tagout, directed operators to re-verify the tagout, and reported the matter to the operations manage The operations manager subsequently stopped all tagging activities, removed the operators involved from shift duties, and directed Maintenance *and.Operations staff to reemphasize the importance of self-checking, independent verification, and tagging safety. Operators resumed tagging on November 6.
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- Operations management reviewed the tagging event to determine what caused the error and concluded the operators did not follow procedure Management based their conclusion on evidence that the operators and supervisors failed to adequately self-check their work and failed to correctly perform independent verificatio The inspectors independently reviewed the event and also concluded that the operators failed to follow procedure The inspectors noted that both the tagging sequence and switchyard interlocks protected the operators from any e 1 ectri ca 1.~azard; however they a 1 so determined the error was very seri ou*s because of the number of safety barriers that broke dow In the past, Salem management did not adequately address such breakdown In contrast, this time plant management clearly told the individuals involved that their performance did not meet expectations and that management would not tolerate additional
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lapse The inspector noted operations management also formed a team to develop solutions for the tagging problem The inspectors concluded operations management responded appropriately~
The inspectors have previously identified problems with Salem personnel not fo 11 owing procedures, and the NRC h*as taken es ca 1 ated enforcement action against these problem Also, Nuclear Business Unit management has kept both units shut down to address long-standing issues, including tagging, and will resolve the issues prior to re-start. Therefore, the NRC will not cite this as a violation. Surve;11ance The inspectors performed detailed technical procedure reviews, observed survei 11 ances, and reviewed completed *surveil 1 ance packages. The __ inspectors verified that plant staff did the surveillance tests in accordance with approved procedures, Technical Specifications and:NRC regulations*.
The inspector reviewed the following surveillances:
Unit Salem I Salem 2 Procedure N Sl.OP-ST.DG-0017 S2.0P-PT.CUC-0002 Test IB Diesel Generator Overspeed Trip Test Charging Pump Flow Test The inspectors observed that plant staff did the surveillances safely, effectively proving operability of the associated system. *' *. -'
ENGINEERING.1 Component Cooling Heat Exchangers System engineers appropriately translated a concern with bolt wastage in n Component Cooling Heat Exchanger (CCHX) to an operability question for the no. 21 CCHX and no. 22 CCH Based on inspection resul~s of nos. 2l and 22 CCHXs, engineers appropriately determined Unit 2 CCHXs operabl On October 10, a condition report documented that the bolts for no. 11 CCHX had experienced wastage as a result of corrosio The corrosion ap~arently resulted from water leaking around the gasket of the heat exchanger end bel System engineers concluded that the wastage suffered by six bolts, in a population of approximately 70 bolts, did not affect heat exchanger*
operabilit The system manager appropriately initiated a work request to inspect the bolts on the no. 21 CCHX and no. 22 CCH Engineers did not find evidence of bolt wastag As engineers evaluated the significance and extent of CCHX bolt wastage, the inspectors noted that management reviewed plant status and outage schedule ~t planning meetings; however, the plant staff did not discuss the status of work or degraded.conditions affecting equipment important to decay heat removal, such as CCHX bolt wastage, for either of the*Salem units. PLANT SUPPORT Radiological Work Practices The inspector obser~ed several poor radiological worker-practice In addition, the.licensee attributed a number of recent radiologically occurrence reports (RORs) to personnel errors and poor practices. These practices resulted in no significant radiation exposure or personal contamination to involved individuals. R'diation Protectfon (RP) supervisors and technicians responded promptly and appropriately to address these issues. Managers discussed this recent tr.end in poor radiological worker practices in a daily management meeting and indicated that a more programmatic concern existe The inspector noted that Radiation Protection management provided timely,.
well-documented ROR root cause trending and trackin On October 31, 1995, the inspector identified two* separate instances of candy wrappers in contaminated trash bags in the RCA. - Radiation Protection management provided additional guidance to plant personnel concerning the dangers of eating within the RC On October 31, 1995, the inspector observed a contractor improperly removin*g anti-contamination clothing upon exiting a contaminated are The contractor potentially contaJTiinated the "sj;ep-off-pad." A Radiation Protection technician ensured that the te'CfiniCian and step-off-pad were clea The RP technician provided additional training to the contractor concerning prop~r dress and undress procedure. *
Radiation _Protection noted recent problems in proper ant i-contami nation and undreS-S\\~-:Racfiation Work Permit (RWP) sign-on, and general attention to detail.
. Radiation Protection management placed increased emphasis on radiation worker knowledge, performance, and accountability. The inspector observed that RP action_ to address issues on an individual, case by case, basis only resulted in limited improvements to dat.2 Security The inspector noted that security did not pursue repair of degraded assessment "
aids in a timely manne One perimeter camera was completely "blacked out,"
one camera operated intermittently, another had a significantly degraded picture, and a fourth had a rolling pictur In addition, a number of cameras were extremely blurry at night. The inspector observed that security force members (SFM) properly compensated for the degraaefhequipmen The degraded assessment aids present an i ncrea.sed cha 11 enge to security force members and a potential performance detractor. Security force acceptance of this condition represents a security force "work-around." Security management initiated work orders to correct deficiencie.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION Management Oversight The Station Operations Review Committee (SORC) demonstrated a goo~ questioning attitude and safety perspective involving several plant procedures and equipment modification Engineering presented a request to allow a fuel handling building temperature
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range of 40 degrees F to 105 degrees SORC memb~rs ~uestioned the
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engineering basis for the change and identified-manY unan~wered questions concerning exhaust fan performance, boron precipitation and overhead crane nil-ductility temperatur SORC questioning demonstrated a good understanding
.and appreciation of technical specification and Final Safety Analysis Report (FSAR) requirements. Although it required three separate SORC meetings, SORC approved the request after engineering provided sufficient technical basi ~-
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. Service Water Pressure Switches On October 20, operators learned of a missing pressure switch associated with the no. 26 service water (SW) pum Salem designed the pressure switch to automatically start the no. 26 SW pump from a standby condition in response-to low SW header pressure. Operators learned that technicians had identified the -
lack of the pressure switch in 199 Technicians also discovered an isolated Unit 2 fuel handling building (FHB)
flow differential pressure (dp) switch. At the di~gction of the shift supervisors, equipment operators verified installation of the remaining eleven pressure switches. During the verification, an operator found the pressure switch for the automatic low pressure start of no. 12 SW pump isolate *
In response to the mis-positioned valves, operations and maintenance managers directed a verification of instrumentation associated with several systems for both Salem units.- The systems included service water, component cooling water, emergency diesel generators, residual heat removal (Unit 2 only), and fuel handling building ventilatio In addition to the discrepancies descriL~d above, technicians found a pressure switch associated with the n SW pump traveling screens isolate Due to the lack of an effec~ive process to control and document alignments performed by Instrumentation and Controls technicians, and due to the poor labeling of the instrument valves, the Salem managers found that they could not determine when or how the valves had been mis-positione.d*'F<""Jhey concluded, however, that Salem staff had ineffective controf of instrument v~lve..aHgnment The managers initiated action to improve labeling and proae<iur~~ontrol of valve alignment The system engineers had identified the missing switch and verified existence of the remaining eleven pressure switches in August 1995. A system engineering man~ger determined that the engineers had not documented the missing pressure switch due to personnel error. The system engineering manager re-emphasized the expectation that system engineers document conditions adverse to quality in a Condition Report and inform control room operators in a ti~ely manne The inspectors concluded that the Salem managers appropriately identified that the process for i~suring proper alignment of instrument valves did not effectively control or document valve position. Salem managers took appropriate action to verify instrument valve position for the* missing pressure.. $Witc In addition,' they initiated action to imp rove label i ng and procedur~~ to control inst~ument valve alignments. System engineering managers found that system;engineers identified the missing pressure switch in August atid did not appropriately document or otherwi:se.. communicate the * -*.
discrepancy to operators. The system enginee.ring managers* rea*scinably '. ::.:.
attributed the omission to personnel error, and 'responded appropri.atel Although the system engineers did not sure ineffective action, as required by procedure, the NRC will not take additional enforcement action in this instance, since ineffective corrective action has been identified in recent escalated enforcement action, the licensee ~oluntarily held the Salem uriits down for an extended period to correct equipment and process problems, and they plan to establish an effective corrective action process prtor to restarting the Salem unit.3 Preparation for Severe Weather On November 14, a coastal storm with winds predicted to reach 30 to 50 knots approached*Sale Weather forecasters also predicted coastal flooding and flooding in low-lying areas. The inspectors noted that the Salem staff did not plan to initiate procedures for preparing the site for the stor Further, managers and supervisors did not discuss the approaching storm or the need'to implement the site procedure for storm preparation at the morning
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meeting In response to inspector questions, site managers initiated storm preparations. The inspectors noted that the site staff had not initiated
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storm preparations on previous occasions until questioned by the inspector * -;.:,.;.~The' insp-ectors concluded that Salem did not have an effective means to insure initiation of site-wide preparations for severe weathe *
- REVIEW OF REFilRTS The inspectors reviewed the following Licensee Event Re~orts (LERs):to determine whether the licensee took the corrective actions stated in the report, detect if the licensee responded to the events adequately, and
.ascertain if regulatory requirements *and commitments were appropriately addressed:
Unit 1 Number LER 95-021 Event Date April 3, 1993 Description Inoperability of both reactor vessel level indication system trains due to a single even The inspectors determined that the LER listed above does not warrant further inspection or enforcement.action and considered the LER closed.
Unit 1 LER 95-15 July 11, 1995 LER 95-16 July 20, 1995 LER 95-18 July 20 1995 LER 95-~3 January 6, 1994 Incomplete documentation of emergency diesel generator.technical spec_i fi cation.
surveil 1 ance *(see ::
inspection report 95-13).
Difference between containment design parameters and acci.dent analysis (see inspection report 95-13).
Improper range gauges used for inservice testing (see inspection report 95-13).
Failure to plug steam generator tubes due to missed eddy current indications (see inspection report 95-17).
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The inspectors addressed NRC concerns and_ regul.a:tory requirements in inspection reports as noted abov.0 EXIT INTERVIEWS/MEETINGS 7.1 Resident Exit Meet_ing The inspectors met with Mr. C. Warren 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 NRC Region I review :.and*tltscussiorrs with PSE&G, it was determined that this report does not contain information subject to 10 CFR 2 restriction *"::-;'.-.
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DOCKET/REPORT NO LICENSEE:
FACILITY:
- 'INSPECTION AT:
INSPECTION DATES:
INSPECTOR:
- APPROVED BY:
.ATTACHMENT ~
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/95--19 50-311/95-19 Public Service Electric and Gas Company Salem Nuclear Generating Station, Units I and 2 Hancocks Bridge, New Jersey October 23-27, 1995 Jo
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R iation Safety Branch ivision of Reactor Safety
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DETAILS INDIVIDUALS CONTACTED Principal Licensee Employees T. Cellmer, Radiation Protection Manager, Hope Creek T. DiGuiseppi, Radiation Safety Manager 1 Services R. Gary, Senior Radiation Protection Supervisor, Hope Creek J. Gomeringer, Radiation Safety Specialist, Services J. Kepley, Nuclear Quality Assurance Engineer E. Lawrence, Quality Assurance Engineer, Salem K. Maza, Chemistry/Health Physics/Radwaste~Manager, Hope Creek C. Munzenmaier, General Manager, Nuclear Operations Services D. Parks, Radiation Protection/Chemistry Training Manager *
R. Ritzman, Licensing Engineer, Hope Creek J. Russell, Radiation Safety Specia1ist, Services E. Villar, Licensing Engineer, Salem NRC Employees C. Marschall, Senior Resident Inspector, Salem S. Morris, Resident Ins~ector, Hope Creek
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The above individuals attended the inspection exit meeting on October 27, 199 *
The inspector also interviewed other individuals during the inspectio **
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PURPOSE OF INSPECTION The purpose of this inspection was to review implementation of the solid radwaste/transportation program at the Salem Nuclear Generating Statio.0 AUDITS AND SURVEILLANCES The inspector re~iewed the licensee's program for auditing and providing independent surveillances of the solid radwaste/transportation progra The latest audit, No.94-152, was performed on May 16 through June 1, 1994 (a Technical Specific-ati-on biennial requirement). This audit was previously.
reviewed by the inspector during a previous inspection
- The previous inspection indicated that this audit was limited in technical depth and that there were no technical specialists included on the audit team due to scheduling conflicts.
1 NRC Inspection Nos. 50-272/94-20; 50-311/94-20; 50-354/94-20 conducted on August 29 through September 2, 199 *
The inspector reviewed the licensee's surveillance program with respect to the radwaste/transportation progra The licensee indicated to the inspector that the past station practice of providing an independent quality control surveillance of each radioactive shipment leaving the station had been modified in July of 199 At that time, quality hold points were developed that only required partial surveillance of radwaste shipments and exempted radioactive material shipments that were not shipped directly to a low-level radioactive waste disposal facilit The inspector questioned the reduction of management oversight of this program area. After some discussion and review by the licensee, the licensee determined that they would provide quality surveillance reviews for all radioactive material/waste shipments except for limited~uantity shipment The.-licensee also indicated the intention to develop a methodolo~t,.Q."'"aJlow-the radwaste* shipping group to provide their own self-assessment of shipment preparation and documentation to effect the same*resul No safety issues or violations were identifie. 0 TRAINING The inspector reviewed the training program with respect to NRC IE Bulletin 79-19 requirement Salem Nuclear Generating Station had four individuals that were authorized to ship radioactive materials/waste The inspector*
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checked the training records of each of these individuals and found that each had successfully completed a two-day.vendor-supplied course provided on February 6-7, 199 The inspector reviewed the course materials *and the final examination and found that the important shipping regulations were accurately represented and covere Final examination grades of greater than 70% were satisfied by each of the authorized shipping personne The inspector
- discussed with the licensee the recent publication of the revised NRC and Department of Transportation shipping regulations (10 CFR 71 and 49 CFR 171-17~, respectively) and the licensee indicated intentions to retrain the applicable personnel on these regulations in the near futur No discrepancies related to training were note.0 RADWASTE PROCESSING
- The Salem Nuclear Generating Station generated a total of 65 cubic meters of solid radwaste during 1994 and had generated a total of 42 cubic meters from January through September of 199 The licensee hassnown*a continuing downward trend in radwaste generation since 1983 when 78,000 cubic meters of radwaste were produce *
Salem Nuclear Generating Station produces primary resin wastes, various filter cartridge wastes, and various contaminated trash, also known as dry active waste (DAW).
In addition, miscellaneous waste water is processed throug vendor-supplied filter/demineralizer syste All spent primary resins and vendor-processed spent resins are dewatered in polyethylene containers according to procedure parameters that ensure less than 1% free standing water remains in these containers. The DAW materials are collected and shipped off site to Scientific Ecology Group, Inc. (SEG), for waste segregation and incineration. Since July 1995, when the Barnwell Low Level Radioactive Waste Disposal Facility reopened to allow radioactive waste disposal, the licensee has shipped dewatered spent resin wastes directly to Barnwell without
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requiring volume reduction processing by SE The characterization of radioactive shipments is determined through periodic sampling of the predominant solid radwaste streams and offsite radiochemical analysi From these analytical results, the licensee specifies the difficult to measure isotopes (non-gamma emitting radionuclides; through the use of scaling factors tied to an easily measurable radionuclide such as cobalt-6 The inspector reviewed Procedure SC.RP-RW.ZZ-0902(Q), Rev. 0, "Radioactive Waste Sampling and Classification." The inspector also reviewed the licensee's latest radioactive waste stream radiochemical analytical result The procedure depicted a sound sampling/characterization methodolog Analytfcal results were available for the following waste streams: DAW, DTI resin (radwaste resin), primary resin, primary filters, and fuel pool/reactor cavity filters. The DAW waste stream was current within 2 years and all others were analyzed within L-yea No discrepancies were noted in the radioactive waste stream sampl-ing and waste characterization are.0 TRANSPORTATION The inspector observed one radioactive material shipment from the Salem Nuclear Generating Station (described in this report) and one radioactive waste shipment from the Hope Creek Nuclear Generating Station (described in NRC Inspection No. 50-354/95-17) during the inspection.
. On October 24, 1995, the licensee made the final preparations and shipped an exclusive-use closed transport trailer containing contaminated steam generator maintenance equipmen ;'J"he -;inspector observed the loading of the individual boxes_of equipment, final survey, and reviewed the shipping records pertaining to the shipmen The inspector observed that two of the.shipping containers were empty and did not contain all of' the closure bolts (4 out of 12 on one container, and 11 out of 12 on the other)~ Federal ~egulations allow ~mpty- *
radioactive material contafoers to contain contamination.l.IP to 0."5 mR/hr on -
contact with the outside of the**packag The licensee ensured~that the two empty containers were sealed using the available bolts* to provide uniform closure pressure around the lid. The inspector advised the licensee that the newly published federal radioactive shipment regulations that have an April 1, 1996 implementation date, will -speCify design approval requirements for all shipping package Containers that were ~esigned and approved with 12 bolts, will require 12 bolts prior to shipmen The inspector observed very good loading and bracing of.the 15 equipment boxe into the trailer and a tamper seal was attached to the closed trailer by the licensee. Radioactive Material placards were attached on all 4 sides of the transport vehicle and a final radiation survey was conducted by the license All shipping records were completed and emergency directions were given to the driver with his signature attesting to his understanding and compliance with those directions. Approved transport routes were discussed with the driver and the shipment was allowed to leave Salem Statio No discrepancies were noted by the inspector.
The following Salem radioactive material shipment records we.re reviewed by the inspecto..
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Shi12ment N Activit~ (Ci}
Volume (ft
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95-29 0.166 2210 Fuel Rack 95-48 0.138 2560 DAW 95-62 0.005 920 Laundry 95-87 0.0005 1573 RCP Motor 95-114 4E-9
Samples95-118 0.0035'
1000 Equipment The inspector questioned the licensee's _derivation of activity and radionuclide characterization of sh1pmerit~number 95-2 The licensee utilized the primary resin waste stream radiochemical analytical re.sults to characterize shipment number 95-29 radioactive constituents. Dose rates of the used fuel racks were obtained and scaling factors representing primary resin wastes were used to determine the radioactive constituents of the fuel rack The inspector reviewed some swipe sample data that was taken from the fuel rack and compared the gamma-emitting radionuclides with the gamma-emitting radionuclides determined from primary resin wastes ~s shown below:
Co-60. Co-58 Sb-125 Cs-137 Cs-134 Mn-54 Co-57 Ag-llOm Nb-95 Fuel Rack Primary Resin Ratio 55%
36% %
3% %
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25%
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13%
1.4%
2%
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0.5%
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The inspector observed that there was.a significant variation in ratios of gamma-emitting radionuclides between the fuel rack swipe sample and primary resin radionuclides. Although the final activity determination would not have caused a reclassification of this Low Specific Activity (LSA) shipment, the licensee assumed a waste stream similarity *to primary resin that was not well founde Closer attention to matching waste streams shoul~ te~made and when comparisons show dissimilarities (as in this case}~ separate*waste stream radioche.mical analysis should be obtained to within a factor of ten (as specified in the.May 1983 Branch Technical Position on Waste Form)..
All other shipping records were determined to be complete and all were determined to meet.the applicable requirement~ of 10 CFR.Parts 20, 71 and 49 Parts 171-17 The inspector verified that all consignee licenses were on file as required. The_inspector revi~wed the following transportation procedure SC.RP-RW.ZZ-0906(Q), Rev. 3, "Shipm~nt of Radioactive Waste for Burial" SC.RP-RW.ZZ-0909(Q), Rev. 3, "Shipment of Radioactive Materials Excluding
~aste for Burial" SC.RP-RW.ZZ-09ll(Q), Rev. 0, "Use of the NUPAC 14-210 or CNSI 14-215 Radioactive Materials Shipping Package" NC.RP-TI.ZZ-0915(Q), Rev. 0, "Shipment and Receipt of Laundry" NC.RP-TI.ZZ~0930(Q), Rev. 0, "Interim Low Level Radwaste Transfer and Storage" The procedures reviewed, were of excellent quality with no discrepancies noted. No safety concerns or violations were identifie _*...
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5 ONSITE RADWASTE STORAGE The Salem radwaste building contains an inplant shielded high radiation storage area where various used mechanical filter elements are stored. The licensee maintains an excellent inventory of individual filters and at the time of this inspection, had in storage approximately 25 'primary filters and 27 other miscellaneous filters. The inplant storage consisted of less than I polyethylene liner shipment of waste filter '
The licensee completed construction and began opera,ti on of an* ans i te radwaste storage facility in late 1994. This facility, Building 41, was designed for the storage. _of _solid_radioactive wastes as generated by both Salem and Hope Creek Sfations during time-periods when a commercial disposal facility was not available. This facility is 68' X 266' and consists of a concrete and steel structure designed to hold approximately 1870 cubic meters of radwaste. This facility consists of a 2-foot thick concrete walled internal vault area for the higher dose rate wastes and the outside walls of Building 41 are 1-foot-thick concrete shieldin An overhead crane is operated remotely from a shielded control room area utilizing closed circuit television camer In addition, the crane hooks mate with-radwaste* container handling pallets and
"',,;,,_,.,.. _strongbacks with out the need for rigging personnel in the are *
At the time of this inspection, the licensee was in the process of emptying the Building 41 onsite radwaste storage facilit Remaining radwaste stored in the facility consisted of I polyethylene liner of spent DTI resin and 8 boxes of DAW ash/compacted wastes returned from SE In addition, Hope Creek radwastes included approximately 44, 55-gallon drums of bituminous waste medi Hope Creek was also in the process of transferring the remaining 85, 55-ga 11 on drums of bituminous -waste located inside the Hope Creek facility out to Building 41 to allow for radwaste shipment stag.ing.and packaging *-
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activities. The inspector observed a high degree of _activi.ty -di):,~~:ted to-shipping all remaining radioactive waste~--currentl_y in stora*ge-at*bath Salem and Hope Creek Station An area for enhancement was suggested to the license Inside Building 41, -there currently is no status board or other reference available to determine the building waste inventory or the location of individual waste containers in the building. A waste location/inventory reference located in the facility would improve the coordination of waste container movement activities conducted by crane operators and support personne In summary, the radwaste storage onsite was very low with very few shipments of radwaste remainin No safety concerns or violations were identified.