IR 05000272/1997007
| ML18102B531 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/07/1997 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| References | |
| 50-272-97-07, 50-272-97-7, 50-311-97-07, 50-311-97-7, NUDOCS 9708260108 | |
| Download: ML18102B531 (15) | |
Text
August 7, 1997
SUBJECT:
COMBINED INSPECTION REPORT 50-272/97-07; 50-311 /97-07
Dear Mr. Eliason:
This letter refers to your June 13, 1997 and July 15, 1997 correspondence (LR-N970348 and LR-N970453), in response to our May 20, 1997 letter.
Thank you for informing us of the corrective and preventive actions for the Notice of Violation, as documented in your letter. The violations involved the failure to establish containment integrity, and to perform the required periodic reviews of the ALARA program as required by the Salem Technical Specifications. In your July 15, 1997 correspondence, you revised your commitment to evaluate the need for additional enhancements to the Technical Specification (TS) Action Tracking log, and to have any identified improvements implemented by August 15, 1997, instead of July 15, 1997. We acknowledge this change in your commitment. Your response to the two violations, including your enhancements to the TS Action Tracking log will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Docket Nos. 50-272; 50-311 97082601"08 970807
~DR ADOCK 05000272 PDR
Sincerely, Original Signed By:
James C. Linville, Chief Projects 6ranch 3 Division of Reactor Projects I llllll lllll lllll llllll llll lllll llll llll
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Mr. Leon cc:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support D. Powell, Manager - Licensing and Regulation A. Tapert, Program Administrator J. McMahon, Director - Quality Assurance & Nuclear Safety Review D. Garchow, General Manager - Salem Operations cc w/cy of Licensee's Letter:
A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
J. Keenan, Esquire J. Isabella, Manager, Joint Generation Atlantic Electric Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland R. Kankus, Joint Owner Affairs State of New Jersey State of Delaware
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Mr. Leon Distribution w/copy of Licen.see Region I Docket Room (with co Nuclear Safety Information Cen
's Response Letter:
NRC Resident Inspector PUBLIC W. Dean, OEDO J. Stolz, PD1-2, NRA D. Jaffe, Project Manager, NRA L. Olshan, Project Manager, NR M. Callahan, OCA J. Linville, DRP S. Barber, DRP D. Screnci, PAO C. O'Daniell, DRP R. Correia, NRA F. Talbot, NRA DOCDESK ncurrences)
ter (NSIC)
R Inspection Program Branch, NR R (IPAS)
DOCUMENT NAME: g:\\branch3\\9707res p.ltr To receive e copy of this document, indicate in the box: "C" = Copy without attachment/enclosure OFFICE Rl/DRP I
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NAME Jlinville DA TE 08/05/97 08/ /97 08/ /97
"E" = Copy with attachment/enclosure I
I 08/ /97 OFFICIAL RECORD COPY
"N" = No copy I
08/ /97
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AUG-13-1997 13=18 l'ubhc S~rviCQ EIP.ctnc and Gil~
Company P.02 Louis F. Storz Public Sel'V1ce Electric and Gas Compariy P.O. Box 236. Hancocks 8ridge, N.J 08038 609*339*5700 Sen1<jf Vice Pnls1dimt - Nu~lear OpereliO<'lo JUN 13 1997 LR-N970348 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/97-07 AND 50-311/97-07 SALEM GENERATING STATION UNIT NOS. l AND 2 DOCKET NOS. 50-272 AND 50-311 Gentlemen:
Combined Inspection Repor.t No. 50-272/97-07 and 50-311/97-07 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G) on May 20, 1997.
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Within the scope of this report, two violations of NRC r.equirements were cited.
The violations involved the failure to establish containment integrity, and to perform the required periodic reviews of the ALARA program as required by Technical Specifications.
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In accordance with 10 GE'R 2.201, l?SE&G is subrnj.tting its respo*nse to the cited violations in Attachment II to this letter.
Attachment III to this letter cont.:iins J.nfor.mation relative to the failure of the Technical Specificad.on Surveillance Improvement Project Phr.ise I to i.dentj.fy the inadequate surveillance testing relative to Technicr.iJ.
Specification 4.8.2.2.
Should there be any questions rega~ding this submittal, please contact us.
Sincerely,
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PrinlMon
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RUG-13-1997 13=18 Document Con~rol Desk T..R-N970348 Attachments (3)
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c Mr. Hubert J. Mill~r, Administrator. - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406.
JUN 13 1997 Mr. L. N. Olshan,*Licensing Project Manager - Salem u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14821
~ckville, MD 20852
-~~~- c. Marsch~ll - Salem (SD9)
USNRC Senior Resident Inspector Mr. K: Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 P.03
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AIJG-13-1997 13:18 ATTACHMENT I LR-N97034B APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Units J. and 2 Docket Nos:
50-272 50-311 License Nos: DPR-70 DPR-75 During an NRC inspection conducted on March 16, 1997 to April 26, 1997, a violation(s) of NRC requirements was (were) identified.
In accordance with the General Statement of Policy a.nd Procedure for NRC Enforcement Actions," NUREG-1600, the violation(s) is (are)
11sted below:
A.
Technical Specification 3.8.2.2 for Salem Unit 2 requires that,
- i.n modes 5 and 6 wj.th less than two AC electrical busses and inverters operable and energized, operators establish containment inte9d.ty within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Contrary to the above, on April 8, 1997, with Salem Unit 2 in mode 5 and less than two A.C eJ.ectr.ical busses*and inverters operable and energized, operators did not establish containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
P.04 B.
Technical Specification 6.11 states that procedures for personnel radiation protection... shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Procedure NC.NA-AP.ZZ-0024(Q), Rev. 7,
"Radiation Protection Program," Section 3. 6, states* th,;;it the Principal Health Physicist-Radiological Safety is responsible for ensuring periodic reviews of the ALARA program and periodic assessments of the station radiation protection program are conducted.
Contrary to the above, the Principal Health Physicist-Radiological Safety, has not scheduled or provided periodic reviews of the ALARA program or periodic assessments of the station radiation protection program for at least the last 4 years.
This is a Severity Level IV violat1on (Supplement 1).
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AUG-13-1997 13:19
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ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNITS 1 AND 2 LR-N970348 ttA.
Technical Specification 3.8.2.2 for Salem Unit 2 requires that, in modes 5 and 6 with less than two AC electrical busses and inverters operable and energized, operators establish containment. integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
contrary to *the above, on April 8, 1997, with Salem Unit 2 in mode 5 and less than two AC electrical busses and inverters operable and energized, operators did not establish containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />."
PSE&G concurs with the violation (1)
The reason for the violation.
The reason for the violation is attributed to the inadequate tracking of inoperable equipment by shift personnel.
A Technical Specification hction Statement (TSASJ tracking log entry which addressed the 2C 125 VDC Bus was used for tracking TS 3.8.2.2.
A separate entry for the zc* Instrument Bus should have been made.
On April 7, 1997, during the process of shedding loads from the 2C 125 voe bus to permit removal of the bus from service, Operations personnel swapped the 2C J.15 volt Instrument Bus to its F,C line regulator in accordance with SZ.OP-S0.115-0013, "2C 115V Vital Instrument Bus UPS System Operation. The control room operator.' s nar~ative log entry stated that TSAS 3.8.2.2 was being tracked.
However, the Action Tracking Log Sheet referred to w~s actually tracking the 2C 125 VDC Bus and did not specifically address the 2C 115 volt Instrument Bus.
on April s, 1997, the 2C Diesel Generator (DG) was removed from service to support the 2C 125 VDC bus outage.
Shortly after removing the 2C DG from serv:i.ce, Overhead Alarm (OHA) A-29 for the 2A Safeguards Equipment Controller: (SEC) was recej.ved.
Invest:i.gation determined the 2A SEC was inoperable which rendered the 2A DG inoperable.
Shift personneJ. correctly assessed the ramifications of having both the 21\\ and 2C AC electrical bl.ls trains inoperable, and immedi.::iteJ.y initiated actions to restore the 2C DG.
Tl"le 2C DG was declared operable at 0442 following surveillance testing, and TS 3.8.l.2 and TS 3.8.2.2 were exited.
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RUG-13-1997 13:19 ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNITS 1 f\\Nt> 2 LR-N970348 P.06 However, power for the 2C 115 volt Instrument Bus was not returned to the aJ.ignment required by TS 3.8.2.2.
During the subsequent shift turnover,, the crews discussed the activities involving the 2A. SEC, and 2A & 2C DGs.
The control room personnel on both the oncoming end off-going shifts were aware that power to the 2C J.15 volt J.nstrument Bus was not in a normal configurationr but failed to recognize that the 2C electrical bus train was inoperable.
Later on that day, as a result of an NRC Resident Inspector's questioning, the Unit 2 Nuclear Control Operator (NCO) recognized that the requirements of TS 3.8.2.2 were not satisfied due to the inoperable 2A DG and the off-normal alignment of 2C 115 volt Instl'.'ument Bus.
The 2C 115 volt Instrument Bus wa.s transferred to its inverter at 1438, and upon completion of sur*veillance testing, TS 3;e.2.2 was exited Qt 1600.
(2)
- The corrective steps that have been taken.
1.
on April 8, 1997, the 2C 115 Volt Instrument aus was tra.nsfer.red back to its inverter, and Technical Specification 3.8.2.2 was exited upon completion of the required surveillance.
2.
This event and the lessons learned were discussed with Operations personnel.. A rollout of this event was performed by the Operations Manager via a letter to all Operations Department Superv:i.sors.
In turn, supervision r.oJ.led out this event to Operations Department personnel.
3.
The appropriate personnel have been held accountable for their actions in accordance with PSE&G policies.
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The corrective steps that will be taken to avoid further violations.
1.
Licensed operators will be provided additional refresher training on electrical system Technical specifications.
This training will be completed by November 15, J.997.
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AUG-13-1997 13:20 P.07 2.
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ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNITS l AND 2 LR-N970348 The Technical Specifications A.ctj.on Tracking has been improved by removing items that were not pertinent to the applicable Mode and sectionalizing the Action Tracking log to mimic T.S.
Additional enhancements will be evaluated and any identified improvements will be j.mplemented by July J.5, 1997.
The date when full compliance will be achieved.
PSE&G achieved full compliance on April 8, 1997, when the 2C 115 VoJ.t Instrument Bus was transfer.red back to its inverter, and Technical Specification 3.8.2.2 was exited upon completion of the required surveillance.
"B.
Technical Specification 6.11 states that procedures for personnel radiation protection.,. shall be approved, maintained and adhered to for all operations involving personnel ra.diation exposure.
Procedure NC.NA-AP.ZZ~0024 (Q), Rev. 7,
"Radiation E'rotection Program," Section 3.6, states that the Principal Health Physicist-Radiological Safety is responsible for ensuring periodic reviews of the ALAM. program and periodic assessments of the station radiation protection program are conducted.
Contrary to the above, the Principal Health Physicist-Radiological Safety, has not scheduled or provided periodic reviews of. the ALARA program or periodic assessments of the station radiation protection program for at least the last 4 years."
PSE&G conet.trs with tha v1olation (l)
The reason for the violation.
The reason for the violation is attributed to inadequate management oversight of the assessment program as demonstrated by:
1.
An assessment program was being developed and existed :Ln "draft" form.
The program established the forma*t, scl1ed1.iles, and procedure on performing assessments; however, the program was not implemented following the management personnel changes; 2.
The radiological assessor position, which was responsible for developing and performing the assessment program was eliminated.
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AUG-13-1997 13:20 ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION SALEM GEN£RATING STATION UNITS 1 J\\ND 2 LR-N970348 3.
A speciUc departmental procedure o:r. dj.rective establishing organizational responsibilities does not exist.
Notwithstanding the lack of management over.sight of the assessment prog;r.am, assessment of the Radiation Protection (RP)pr.ograrn had been conducted by the Stations RP staff members, as well as industr.y peers.
Additionally, RE' Services group conducted informal assessments of the RP program.
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The correctiv~ steps that have ~en taken.
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The assessment program was established on June 6, 1997.
The first assessment under this program is being conducted of the Hope creek Radiation Protection program and will be completed by June 30, 1997.
The assessment of the Salem RP program will be inj.tiated following the Hope Creek assessment and vd.11 be completed by August 31, 1997.
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The radiological assessor position has been reestablished 3.
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effective May 27, 1997.
A review or. the HC and Salem UP.SAR's has been conducted to ensure that other applicable requirements are being met.
No other deficiencies were noted relative to the RP program.
The results of this investigation have been reviewed with department personnel for lessons learned.
The correctiv@ steps that will be taken to avoid further violations.
A procedure/directive to define organizational responsibilities will be issued by August J., 1997.
The date when full coriiplianae will be achieved.
The assessment program was established in June 6, 1997 and the first assessment commenced for Hope Cr.eek Station RP prog:r.am.
E'uJ.l compliance will be achieved by August 31, 1997, when the Salem RP program assessment is completed.
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AUG-13-1997 13:20 ATTACHMENT III RESPONSE TO NOTICE OF VIOLATION S~EM GENERATING STATION ONITS l ANO 2 LR-N970348 As requested in your Inspection Report, th~ following describes
~SE&G's evaluation of the failure of Technical Specification Surveillance Improvement Project (TSSIP) Phase 1 to identify the inadequacy relati*ve to the implementation of Technical Specification 4. 8. 2. 2.
PSE&G RESJ?ONSE BACKGROUND PSE&G initiated the Salem TSSIP to evalua.te the quality of the Technical Specification (T.S.) surveillance program.
TSSIJ? is designed to review the surveillance testing program to; a) enhance administrative controls, b) assure proper scheduling and tracking of surveiJ.lances, aind c) validate the impJ.ementj.ng procedures, with certain exceptions, for T.S. surveillance testing requirements.
TSSIP is being performed in two phases.
Phase 1, which ~ill be completed for each unit prior to the respective unit's restart, and Phase 2 is scheduled to be completed post restart.
Pha.se 1 involves a general review of the T. s. survei).lance requirements and implementation procedures, along with an evalt.lation of scheduling controls.
To carry out J?hase J., the T, s. surveillance reguirements were identified and placed into the Technical Specification Cross Reference Matrix.
Technical Specification surveillance requirements included conditional requirements and the associated trigger mechanisms, but did not include Section 6.0 Administrative Controls.
Approximately 1000 T.S. surveillance requirements were identified and reviewed during the Unit 2 Phase 1 process to ensure the matrix was complete, that recurring tasks were in place for each T.S. surveillance testing line item, and that the correct mode was referenced for each line item.
Phase 1 also included a scheduling review.
This involves a compa~ison of each surveillance-related Managed Maintenance Information System (MMIS) Recurring Task against the Technical specification requirements and a detailed evaluation of Mode transition controls and verifications.
This provides assurance that surveillance requirements are scheduled at the appropriate periodicity and performed in the correct Modes or conditions.
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I AUG-13-1997 13:21 ATTACHMENT III RESPONSE TO NOTICE O~ VIOLATION SALEM GENERATING STATION UNITS 1 AND 2 LP.-N970340 P.10 As stated above, the Phase 1 TSSIP review for Salem identified about 1000 unit 2 T.S. surveillance requirements.
This result~d in a Phase 1 review of over 900 Unit 2 and common Technical Sped.fication implementing procedures.
TSSJ.P has also :z:-eviewed approximately l,300 Unit 2 MMIS Recurring Tasks, as well as all departmental Mode transition procedures and T.S. conditional surveillance trigger
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The Phdse 1 TSSII? review resulted in identification of a number of surveillance testing discrepancies.
These have included examples of surveilla.nce r.equir.ernents with no implementing procedure or wj_ th inadequate implementing procedures, scheduling and tracking mechanisms not assuring su:z:-veillance implementation, and pr:ocedur;:iJ.
revisions inappropriately deleting referenced surveilJ.ance requirements.
Appropriate corrective acttons were initiated for these items and Mode change restraints were specified.
Action Request (AR) were l.ssued to ensure that conditions adverse to quality are addressed prior to the appropriate point in the restait process.
EVENT DESCRIPTION AND PSE&G ~SSESSMENT On April 8, J.997, Salem Unit 2 Operations personnel inappropriately exited T.S. action statement 3.8.2.2 with portions of two ac trains inoperable.
2A Diesel Generator was inoperable due to pr.oblems with the 2A safeguards equipment controller and the 2C train was inoperable because the 2C inverter was not aligned to j, ts vital instrument bus.
While reviewing this event, Operations management identified that Unit 2 surveillance procedure Sl/52.Ol?-ST. 4KV-0002 (Q) 1 "Electrical Power Systems AC Pistr.i.J,ution" did not fully implement surveiJ.lan.ce requirement 4. 8. 2. 2.
Fol.lowing the failure of the TSSIP phase 1 project to identify this deficiency, PSE&G management initia.ted a.n action request to formally investigate this condition.
The apparent cause of the TSSIP phase 1 failure to specifically identify this deficiency is attributed to inattention to detail by the individual performing the review.
The inconsistent requirements and wording between the Unit 1 s surveillance requirements, between the T.S. Limiting Condition for Operation and their associated surveillance also contributed to this event.
AUG-13-1997 13:22 ATTACHMENT II I RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION ONITS l AND 2 LR-N970348 corrective actions taken P.11 1.
Procedures Sl/S2. OP-ST. !lKV-0002 (Q), "Electrical P.ower systems AC Distr.ibution," were revised on April 10, 1997 to require ved.fication thait* the vital instrument bus inverters are energized by their normal ac power.
2.
Improvements to NC.NA-A!?.ZZ-OOOl(Q) Nuclear Procedure System,"
and NC.NA-AP.ZZ-0012(Q)"Technical Specification Surveillance Program" have been iml?lemented to enhance the overall surveii~ance program.
3.
A Technical Specific~tions license change request to make the Unit 1 and Unit 2 Technical Specifications identical will be issued by Decemter 31, 1997.
CONCLUSION PSE&G is confident that having completed TSSIP Phase 1, coupled with related restart efforts, will ensure that the T.S. surveillance testing program is adequate to support restart and power operation et Salem.
TSSIP phase 2 will v~lidate the adequacy of the procedures.
Based on results achieved to-date at Salem and Hope Creek, as well as other utility initiatives, PSE&G is confident that discrepancies, if found, will be of a type that can be corrected within the allowr.ible outage times specified by the Technical Specificatj,ons.
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AUG-13-1997 13:22 P.12 Publlr. ServiGll El!!Clric oM C;a$
Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hanwcks Bridge; NJ 08038 509.339.5700 S*miOf Vice Pr0Giden1 - Nuelear Op11t;iliQns LR-N970453
~UL 15 1997 United states Nuclear Regulatory Conun.ission Document Control Desk Washington, o.c. 20555 Gentlemen; REVISION TO COMMX'l'MENT SALEM GENEIV\\TING STATIONS UNIT NOS. l ANO 2 DOCKET NOS. 50-272 AND 50-311 By letters dated June 13, 1997 "Response to NRC Notice of Violation Inspection Report 50-272/97-07 and 50-311/97-07,"
{Our Ref: LR-N970348) and Licensee Event Report 311/97-004-00 dated May 7, 1997 (Our Ref: LR-N97278), Public Service Electric and Gas (PSE&G) committed to evaluate the need for additional enhancements to the Technical specification Action Tracktng log, and to have any identified improvements implemented by July 15, 1997.
According to the PSE&G commitment management program, PSE&G is revising its commitment to have the evaluation and the identified improvements implemented by August 15, 1997.
As stated in the June 13 letter, l?SE&G improved the Technical specification Action Tracking log by removing items that were not pertinent to the applicable Mode and sectionalizing. the log to mimic Technical Specifications.
The Operations Department staff has been significantly taxed as a result of a large emergent workload associated with the Salem Unit 2 restart and the annual requalification training.
However, based on the enhancements already implemented to the Technical Specification Action Tracking log, l?SE&.G concludes that delaying the implementati'on of any'additional identified enhancements to August 15, 1997, does not compromise the safe operation ot: the Salem Uni.ts.
Should there be any questions, please contact us.
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Prfnledon W
Aecycl!Jd Peper GIJncereLy,
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AUG-13-1997 13:23 Document Control Desk LR-N970453
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c Mr. Hubert J. Miller, Administrator - Region I U. s. Nuclear Regulatory commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager u. s. Nuclear. Regulatory Conunission One White Flint North 11555 Rockville ~ike ail Stop 14E21 ockville, MD 20852 r. c. Marschall - Salem (X24)
USNRC senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625
- Salem P.13
~UL 15 1997
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